Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. EXAMPLES: 1. A company uses a reportable substance to wash machinery. Some of the substance goes down the drain, and the rest is wiped off with rags, which are placed in a bin and later hauled away. The percentage of the substance that is on the rags may be determined based on the measurements of either output are being made. 2. In the same scenario, if the company does have information allowing it to calculate the amount of the reportable substance that is being released down the drain to the publicly owned treatment works, then the difference between that amount and the total amount used can be assumed to have been hauled away as waste, with the rags. 3. In manufacturing its product, a company applies an adhesive containing a reportable substance. The company later trims the product, generating some percentage of waste. Again, that percentage judgment, unless it is possible to make a more accurate determination based on information that is readily available. This could include the weight of unfinished product minus the weight of finished product, if those quantities are measured. Again, no additional measurements not otherwise being taken are necessary. g. Best information readily available. See Question 49 in Appendix F. It is not the policy of the Toxics Right-to-Know Program to require businesses to purchase new equipment or take additional measurements. Businesses are of course free to do so at their discretion in order to improve the quality of the information reported. As a general rule, however, information that is not available is not reportable. 2. Review Appendix F to this handbook, particular circumstances. 3. Technical assistance is available free of charge from the Toxics Program staff, 541- 682-7118. Technical assistance is also available for a fee, from a private consultant. Environmental & Ecological Services are listed in the Yellow Pages. 4. Begin preparing your report soon after the end of the calendar year, while there is still ample time to gather and organize your information. Do not postpone it. 5. Remember that the intent in enforcement is to be helpful and not punitive. The Toxics Board and City staff are more interested in providing complete and accurate information to the public than in assessing fines. Fines are only assessed in the event of egregious violations, and never for a first offense. - 6-