Right-to-Know Requirement Review
Even if you’ve filed Community Right-to-Know reports in the past, it’s a good idea to review the requirements to ensure you understand the finer points of this program and are not found to be in violation.
Some things to keep in mind:
- Know the difference between a pure substance and mixture. Each must be properly reported.
- Know the correct format. You must use the entire name as it appears on the container label or Material Safety Data Sheet (MSDS), no abbreviations, and include the chemical abstract services (CAS) number.
- Know the proper protocols for filling out the Facility Inventory Form (FIF).
- Refer to the container label to find manufacturer name and address, trade or chemical name and CAS number, concentration (whether pure or for each hazardous ingredient) and physical or health hazards.
- Each substance stored or used at your facility that appears on the NYC Hazardous Substance List or the physical and health hazards special list. It doesn’t matter if the substance is pure or in a mixture.
- Substances must be reported if they’re present at or above the Threshold Reporting Quantity (TRQ) any time during the reporting (previous) year. For mixtures, you must list the name and CAS number (if any) and also each hazardous ingredient’s name, CAS number, and concentration if it’s at or above the TRQ within the mixture.
- If you aren’t sure, multiply the ingredient concentration (weight %) by the entire mixture weight, then compare your result to TRQ requirements.
- For ingredients not on the Hazardous Substance List, you can identify the TRQ for that mixture by checking the physical and health hazards special list.
If you’re feeling overwhelmed, discussing your situation with an environmental consulting professional can alleviate uncertainty and ensure your annual reporting and year-round compliance are being handled correctly. Walden has prepared hundreds of Right-To-Know filings, so give us a call.