If you have a business in New York City and you store hazardous substances, the time to act is now! New York City’s Community Right-to-Know (RTK) regulations require all NYC businesses that store or handle hazardous substances to inventory and track those substances and file an annual report.
The Community Right-to-Know filing process can seem overwhelming, but it doesn’t have to be. Here are some basic definitions to help you navigate the jargon:
- MSDS: Material Safety Data Sheet – information about industrial chemical products including hazards, safety and emergency procedures. (These are now referred to simply as Safety Data Sheets [SDS] to comply with international standards.)
- FIF: Facility Inventory Form – one of the RTK reporting documents.
- CAS: Chemical Abstracts Service – they maintain a registry of chemicals and assign a unique ID number to each one.
- TRQ: Threshold Reporting Quantity – these levels determine whether or not you need to track and report on specific chemicals or products.
- DEP: Department of Environmental Protection.
Penalties for failure to report can be significant, up to $20,000. So here are some tips to help you file as painlessly as possible:
- OSHA requires you to create and maintain a binder with up-to-date SDS sheets that’s readily accessible within your facility. This supports your RTK filing, too, because needed chemical information is right at hand.
- You also need to maintain a current inventory of all chemical products that enter your facility. Updating your inventory will be easier if you clearly label everything, including compressed gas canisters and storage tanks. Good labeling is also important for safety.
- Store similar chemical products together. Better organization facilitates faster inventory, especially if you keep storage areas clear and dispose empty boxes or other containers.
- Community Right-to-Know specifically requires reporting of any “especially hazardous substances” in your inventory that appear on the Threshold Reporting Quantity (TRQ) list. If you use any of these chemicals in quantities over the designated “threshold” level, you must also create and submit a Risk Management Plan that explains your risk assessment program, risk reduction program and emergency response program.
Here’s some great news. It’s easy to register and file online, even if you have multiple facilities (you file separately for each one) and whether you’re filing an annual, revised or updated. The system is designed to facilitate filing by using drop-down lists to eliminate typing, and it retains your information to make future submissions even faster and easier.
Photo Credit: Sean McGrath