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<br />f' <br /> <br />r <br /> <br />Type 1 (inventory at the facility at the beginning of the accounting period): 30 <br />pounds (1,000 pounds x 10% ammonia x 30% used for manufacturing). <br /> <br />Type 4 (quantity brought to the facility): 30 pounds (same calculation). <br /> <br />Total inputs: 60 pounds <br /> <br />f' <br /> <br />~ <br /> <br />Outputs would be: <br /> <br />Type 6 (quantity discharged in~o publicly treated sewage): 45 pounds (given that <br />75 percent of the input is consumed during the reporting period). <br /> <br />Type 11 (inventory at the facility at the end of the accounting period): 15 pounds <br />(500 pounds x 10% x 30%). <br /> <br />Total outputs: 60 pounds <br /> <br />~ <br /> <br />E. MISCELLANEOUS <br /> <br />37. QUESTION: Is natural gas a reportable substance? <br /> <br />ANSWER: Natural gas is exempt from the reporting requirement. Apart from the <br />difficulties in measuring natural gas used in manufacturing processes, as opposed to non- <br />manufacturing processes in the facility, virtually all natural gas is consumed in combus- <br />tion, and the by-products are not reportable. <br /> <br />38. QUESTION: SARA Title ill exempts a variety of products from reporting. 29 CFR <br />1910.1200 (b) (5) (iii) HAZCOM rules for MSDSs exempts "any food, food additive, <br />color additive, cosmetic, or medical or veterinary device or product, including materials <br />intended for use as ingredients in such products (e.g. flavors and fragrances)." If I use <br />substances for which there is no MSDS requirement, am I required to track and report <br />these materials? <br /> <br />ANSWER: The Toxics Board has determined that substances are reportable if the manu- <br />facturer has evidence indicating that they are reportable, and are not reportable if the <br />manufacturer has no such evidence. MSDSs are one, but not necessarily the only, source <br />of such evidence. Manufacturers are not required to seek such evidence heyond informa- <br />tion that is readily available to them. However, the absence of an MSDS does not in <br />itself automatically exempt a substance from reportability. <br /> <br />The Toxics Board recognizes that this determination could temporarily have the effect of <br />requiring more reporting from busi~esses who have the most information about the chem- <br />icals they use. The Board in the future will consider adding specific characteristic chemi- <br /> <br />F-12 <br />