Ordinance No. 20222 - Laserfiche WebLink

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:r- If' C. CHARACTERISTIC CHEMICALS General guidelines: Characteristic chemicals include any chemicals that are not on the itemized list of reportable substances,. but that are !mown by the reporting facility to be either ignitable, corrosive, reactive, or toxic as ~ose terms are defined in 40 CFR261, Subpart C (Appendix E, 1998 Reporting Forms and Instructions). Characteristic chemicals are reportable. f' , Reporting entities are not expected to take extraordinary steps to determine whether substances are characteristic, but often this can be determined either by examining the MSDS for a sub- stance or by observing the substance's behavior. ii- ~ . 24. QUESTION: Some paints, stains, dyes, and inks may contain petroleum distillates that have ignitable characteristics (flash point <1400 F), but when combined with the pig- ments may raise the flash point to more than 1400 F, as stated on the MSDSs. If the CAS nUmbers are not on the Eugene list, are these products exempt from reporting? ANSWER: If the MSDS lists a flash point above 1400 F, then the business using the material does not need to report the matenal as a characteristic material, if the material's CAS# is not in the list already, and if the flash point of the material does not fall below 1400 during its life cycle in Eugene. This answer follows the principle of using MSDS information and not having to obtain information that is not already available to the business; i.e., flash point information for the component must be (a) on the MSDS from the silpplier of the product they are using, (b) be their own information on the material because that business has manufactured the product from its component parts, for which it would have an MSDS showing the under 1400 F flash point of the component, or (c) be otherwise known by the manufacturer, or else the material is not reportable. Thus, even if the information exists in some reference book, the business is not obligated to look for the information in a book that they mayor may not have, or do other research into the flash points. If the flash point of a substance is known and/or documented, and it is below 1400 F, the business is expected to report that substance or its reportable com- ponents. 25. QUESTION: My business uses a substance whose composition is a trade secret of the supplier, but which I know to be hazardous and reportable as a characteristic chemical. How should I report this? ANSWER: Report the substance in your regular materials balance accounting report under the appropriate generic characteristic substance category. You do not need to report it as a trade secret because it is not YOUR trade secret; it is someone else's. Busi- nesses are not required to seek additional information from suppliers. F-8