Making the P2 Connection with the FOUNDATION Product Approval Module
Passage of the Pollution Prevention Act by Congress in 1990 was intended to focus industry as well as the U.S. public on efforts to reduce the amount of pollution being generated across the country.
The law gave the United States Environmental Protection Agency (U.S. EPA) the responsibility and the authority to develop and implement a source reduction strategy. As a result, EPA worked to integrate Pollution Prevention (P2) practices into general industry and reduce pollution “at the source” and not at the tailpipe, outfall, or landfill. The Act also required that EPA collect and disseminate information related to P2 to the public.
After passage of EPA’s mandate, each state then implemented its own P2 program which the federal law required to be as or more stringent than the program implemented by EPA. In the early 1990s, Indiana, for instance, adopted a very narrow definition whereby true Pollution Prevention could only be achieved through process change, in-process closed-loop recycling, or input substitution.
Using Indiana’s model as an example, the state’s goal was to reduce pollution through improved efficiency, recycling/reusing waste before it could be sent to a landfill, and by making changes to the raw materials used in the manufacturing process (input substitution). By focusing on the raw materials used in, or incidental to, production, a facility could identify less toxic materials to facilitate more environmentally safe production processes.
How can Cornerstone help your facility improve its P2 performance?
In the early 1990s, Cornerstone developed a chemical inventory system to analyze and track the chemical composition of materials used in production and manufacturing. Over time, Cornerstone’s chemical inventory system was further developed by adding SDS management to create the current FOUNDATION SDS Management and Chemical Inventory System. In addition, FOUNDATION determines the applicability of substances to the Emergency Planning and Community Right-to-Know Act (EPCRA), Clean Air Act, and OSHA regulations to help ensure continuous compliance.
While working with IDEM (the Indiana Department of Environmental Management) during the development of its P2 program, Cornerstone introduced me to the methodology of using a chemical inventory system to assist with Input Substitution. It seemed like the perfect tool to support P2 efforts through the identification of materials that could be substituted thereby protecting the environment (i.e., P2) and creating safer workplaces.
What can FOUNDATION’s Product Approval Module do?
The Product Approval Module in FOUNDATION enables users to fully evaluate and approve (or reject) materials to be used in their operation. The regulatory lists reviewed range from EPCRA, HAPs, Proposition 65 Chemicals, Carcinogens, Reach, ROHS, and can also incorporate customer-specific restrictions and chemicals of concern. Candidate lists are generated for each applicable regulation to which a chemical is subject. The Product Approval Module is also useful in compiling information for ESG (Environmental, Social and Governance) reporting related to customer requirements.
If a team of individuals is responsible for approving materials to be used in production, Cornerstone’s IT team works with the client to create a fully customized Product Approval system which enables mutual review, evaluation, and approval. A streamlined online approval process such as this eliminates delays in review and ensures a holistic approach product review.
Further Information
For more information or a webinar on our Product Approval system, please contact Cornerstone or your Sales Representative.
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SDS and Document Hosting
A few years ago, Cornerstone was approached by a client that needed to improve how they were delivering branded safety data sheets (SDSs) to users of their products after they determined their staff was spending an excessive amount of time responding to these requests. Having used our IT solutions in the past, they reached out for support to design an automated, efficient system to manage this process and thus our SDS (and document) hosting platform was born.
How does a hosting platform work?
A document hosting application allows customers to visit your web site, search for the document they need and download it immediately.
Let’s look at an example. You sell cleaning products. You have a customer who is looking for an SDS for your brand of stainless steel polish. The customer would visit your website and click on a link which would forward them to a page to begin an SDS search.
After typing in ‘stainless steel polish’, they would be presented with the SDSs that best match from the hundreds of products you sell. The customer then clicks on a link to the exact product they need which would be displayed a PDF of the SDS that can be downloaded or printed.
With Cornerstone’s hosting platform, not only can you deliver SDSs more efficiently, the system also allows for easy distribution of other documents for the products you sell such as technical data sheets, instructions, manuals, or diagrams.
Sounds like it could be expensive and time consuming to set up, right? That’s where Cornerstone’s SDS and Document Hosting solution comes in. Our team will get you up and running quickly, cost effectively and with minimal IT resources required on your part.
Depending on your specific needs, our hosting solution can be deployed as a standalone website or can be seamlessly integrated into your existing website.
Some of the additional features of our Professional plan level include:
User definable fields
Password protection at the site level and at the document level if needed
Multi-language site support
Multi-language document support
Automated document distribution
For more information about Cornerstone’s SDS and Document Hosting platform, contact Cornerstone at info@corner-enviro.com, on our website at https://www.cornerstone-ehs.com/contact-us/ or call (317) 733-2637.
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Are You Prepared for the Tier II Emergency and Hazardous Chemical Inventory Reporting Deadline?
Tier II Emergency and Hazardous Chemical Inventory Reports are due annually on March 1. Since these reports cover materials for the entire previous year, it’s important to continually track the chemicals/products entering and leaving your facility. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season. Don’t let the deadline sneak up on you!
The following is a quick overview of the EPCRA regulation and Tier II reporting:
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. This regulation requires industry to report on the storage, use, and release of hazardous substances to federal, state, and local governments. EPCRA serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Reporting is applicable for any OSHA-hazardous chemical stored on site that exceeds the federal threshold quantity of 10,000 pounds, and any EHS stored in excess of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Exceeding the threshold at any time during the reporting year triggers the reporting requirement. It is also important to note that individual states may have more stringent reporting requirements.
What is an EHS?
The Extremely Hazardous Substance (EHS) list identifies chemicals that could cause serious irreversible health effects as a result of a release. A full list of EHS chemicals can be found on epa.gov.
What storage information is needed to file the Tier II?
Reporting requirements include details of specific location(s) within a subject site where reportable chemicals are stored. In addition, the type of container utilized and exact maximum amount (typically measured in pounds) of hazardous chemicals present at the facility at any one time during the previous calendar year must be reported.
How do I know what reporting requirements exist for my state?
Although each state’s reporting system may vary, any subject facility must file a Tier II report annually with the State, County (LEPC), and local Fire Department. Additional information regarding filing criteria by state, along with associated fees, can be found at https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
Further Information
With a well-organized system in place, compliance with the Tier II reporting requirements is much easier to achieve. Cornerstone is an industry leader in chemical inventory management, electronic SDS imaging, and software management systems. Our proprietary software (FOUNDATION) combines both EPA and OSHA chemical tracking and reporting functions and provides a foundation for all compliance recordkeeping and reporting. Additionally, we have a team of experts who can assist with Tier II reporting and help keep your hazardous chemical data up to date throughout the year, so you will always be ready for the March 1 deadline.
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Update SDS Regularly for Better Work Safety
Safety Data Sheets inform employees about the hazards of the chemicals in their workplace, how to obtain information on chemicals, and what to do if a spill or accident occurs with those chemicals in order to provide a safe, secure workplace. The information contained on each SDS also enables organizations to better understand the chemicals they use and how those substances impact the environment. Constant communication of SDS updates to staff is a vital way to promote a positive safety culture in any company. It creates a safer, more informed environment for employees. Changes to SDS can impact the handling or transport of material, as well as disposal methods, and the potential health hazards to employees.
What OSHA regulations require SDS?
The OSHA Hazard Communication Standard (OSHA, 29 CFR 1910.1200(g) and Appendix D) requires manufacturers and importers of a new hazardous chemical to obtain or develop safety data sheets. From there, the manufacturers, suppliers, and distributors are responsible for passing that information along as the product moves through the supply chain. Those entities also are required to update existing SDS as new information becomes available regarding identification, handling, and spill response of hazardous chemicals. This applies to every hazardous chemical they produce or import. The HCS requires that SDSs be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. The downstream or end users are responsible for the use and maintenance of SDSs, including accessibility to the most recent version of SDSs for all employees. Users can request updated SDS information from the original supplier or manufacturer. All along the supply chain, employers must provide training to employees regarding how to access an SDS and communicate changes to employees in a timely manner.
What other mandates require SDS?
The U.S. EPA also has regulations that address SDSs. These documents were a requirement under the Clean Water Act of 1970 and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980. Subsequently, these were reaffirmed under the Superfund Amendments and Reauthorization Act (SARA) section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), which is also known as Title III. Many state and local environmental and safety agencies have a number of regulations that may redundantly require SDSs. Most corporate safety and environmental protection programs also rely on SDSs to educate and inform workers about dangers in the workplace.
What are the dangers of an outdated SDS?
If a manufacturer chooses not to maintain up-to-date SDS documents on file, they are denying their staff valuable information about specific chemicals substances and how to safely handle them. This puts employees at risk and could lead to workplace incidents and injuries or environmental damage. In addition, OSHA or EPA inspectors have the authority to issue violations and assess fines for non-compliance with SDS-related regulations.
Further Information
With Cornerstone’s Foundation SDS Management and Chemical Inventory System, our Chemical Management team do the work for our clients to ensure that their SDS are regularly updated. For a free demo, contact us.
Yabelin Batista has been with Cornerstone since 2019. She is a member of the Chemical Management department at Cornerstone, Environmental, Health and Safety. One of her main responsibilities consists of sourcing and updating current Safety Data Sheets (SDS) for a wide array of products in our Foundation SDS Management and Chemical Inventory System. Her efforts help ensure our customers have the latest documents available.