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<br />rl <br /> <br />~.ll <br />t I <br /> <br />11 <br />1 J <br />11 <br /> <br />Example: A raw material MSDS notes that a reportable hazardous substance is present <br />as a contaminant at the level of 100 ppm. A business purchases 1,000,000 pounds of the <br />raw material in a given year. In total, the business will have 100 pounds of the contami- <br />nant. If the CAS number is listed, the business must report the contaminant if it had <br />purchased 100 pounds of the contaminant as a pure substance. <br /> <br />fl <br />4 <br /> <br />r 1 <br />t j <br /> <br />H. IJse of Ranges: In estimating the amounts of hazardous substances to report, a business <br />may consider the range of compositions that it receives .as articles during the year, and <br />choose an average value within the range. For example, if the stainless steel that a busi- <br />ness uses for manufacturing contains, among other substances, chromium, and the busi- <br />ness generated 900 pounds of fumes, dust, filings or grindings from such articles, and the <br />chromium content ranged from 6-8%, the business could choose 7% (or another percent- <br />age they feel is more justifiable) and then report 63 pounds of chromium in the appropri- <br />ate output category(ies). <br /> <br />! 1 <br />t t <br />i J <br /> <br />''1 <br />.~ t <br />i } <br /> <br />Likewise, when an MSDS gives ranges of components of mix- <br />tures, the business may report the midpoint of the range, or be <br />prepared to explain their rationale for any other choice used <br />for reporting. <br /> <br />See Appendix F, <br />Question 49 <br /> <br />r, <br />\ <br />". } <br /> <br />Example: A MSDS gives the following composition: <br />Material 1 50-60% <br />Material 2 10-20% <br />Material 3 20-30% <br />Material 4 5-1 0%\ <br />TOTAL 85-120% <br /> <br />Reasonable Reporting: <br />55% <br />15% <br />25% <br />-5.% <br />100% <br /> <br />T <br />" 1 <br /> <br />VIII. ADMINISTRATION <br /> <br />A. Enforcement Actions: The law gives the Toxics Board broad powers to enforce viola- <br />tions. However, it is the intent of the Toxics Board to assist companies in their efforts to <br />comply with the law. Companies that make an honest and conscientious effort to comply <br />with the law and that work with the Toxics Board to continuously improve the quality of <br />their reporting are unlikely to face enforcement actions. Blatant disregard for the law or <br />the truth, or an unwillingness to provide adequate information as directed by the Toxics <br />Board, however, is likely to result in enforcement actions. There will be intermediate <br />cases of reporting errors involving gross inaccuracies and/or <br />omissions and/or data accumulation process errors. Whether or <br />not these errors result in enforcement actions will be a decision <br />of the Toxics Board, which will take into account the factors <br />listed in Section 8.2.C of the law. <br /> <br />See Appendix F, <br />Question 44 <br /> <br />18 <br />