tier-ii

 

What the regs require
The Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA) SARA Title III, Section 312 requires any facility that uses, stores, or processes a chemical requiring a Material Safety Data Sheet (MSDS) held above certain quantities to file a Tier II report. The Tier II reports are due on or before March 1st of each year.

EPCRA Section 325 allows civil and administrative penalties ranging up to $10,000-$75,000 per violation or per day per violation when facilities fail to comply with the reporting requirements.


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Do I need to file Tier II's?
The next few questions will help you answer the above. If you can answer “No” to any of the following questions then you may be in the clear:

Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.) 

Question #2: Do you have chemicals contained within these products that contain any of the extremely hazardous chemical (EHS) list?

Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day), meet or exceed the EHS Threshold Planning Quantities (TPQ) or 500 lbs.? (The only way that we can help you with this one is to screen for them.)

Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.


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Our View:  E&SSG has provided chemical screening services that have helped our clients cut through the regulatory red tape of regulated chemicals since 1993.

E&SSG has developed many systems to effectively track your chemical inventory and provide you "Peace of Mind" about your chemical requirements.

 

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What We Offer
Tier II Screening Service
This service is designed to virtually eliminate the amount of time you would spend studying the SARA Title III regulations as well as searching, cross-referencing and indexing your chemical inventory against the SARA Title III EHS list.

This simple and painless service provides you with the information you need to determine if you are required to file a Tier II. 


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Fast
The entire process can be completed in as little as a few days.*
Simple
Initially you simply provide to us copies of your Material Safety Data Sheets (MSDS) that represents your current chemical product inventory.
Professional
Our staff of trained professionals enter key information from your MSDS into our system.
Systematic
We send you back either an E-mail or hardcopy** form requesting your product inventory information on the just the products, present at your facility, that contain these regulated chemicals. This information includes your quantities, container types, areas stored and areas used.
Logical    After the information is received back from you and entered into your file, E&SSG's proprietary CIA software matches your inventory against the hundreds of chemicals listed on the EHS list.
Results
The reports of the findings and/or compliance instructions are then delivered back to you in PDF format.
Reports
The reports that you receive will show you weather or not you are required to file a Tier II and why. This includes the following 3 reports complete with detailed information showing your: 

•    Basic Total Chemical Inventory**
•    Extremely Hazardous Substances (EHS) Chemicals
•    10,000 lb. Chemicals

Ongoing     This service is a renewable annual (12 month) service that allows you to provide us your new or revised MSDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with any changes or modifications to the EHS list and notify you if your status changes.
Reporting
If required by the report findings pertaining to Tier II. E&SSG will prepare and file your State and Local reports as follows:

1)    Tier II Reporting – Just an additional $50/facility filing fee with this service.

Coming Soon     E&SSG will provide you secure access to your chemical inventory online via E&SSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes. 
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*  Results are subject to demand and response time from the client.
**This is a basic Total Chemical Inventory report that will list just the MSDS Number, Product Name and Manufacturer, and Maximum Pounds (if given).

 

 

all-sara-title-iii

 

All SARA Title III Chemical Screening Service

 

What the regs require
The Environmental Protection Agency’s (EPA) SARA Title III requires certain reporting based on the chemicals that are manufactured, used, stored, or processed at your facilty(s). The SARA Title III reporting requirements are due March 1st (Tier II) and July 1st (TRI) each year.

Failure to comply with either of these regulations can result in fines up to $25,000/day/occurrence.

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Do any of these regulations affect me?
This is the first and most critical answer that every facility must ultimately answer. The next few simple questions will help you answer the above. If you can answer “No” to any of the following questions then you’re in the clear:

Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.) 

Question #2: Do you have chemicals contained within these products that fall on any of these lists? (This one is a little more difficult; however, if the answer to question #1 was “Yes” then the answer to this one is most likely the same.)

Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day or annually), meet or exceed the reporting thresholds listed in SARA Title III? (The only way that we can help you with this one is to screen for them.)

Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.
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Our View:  E&SSG has provided chemical screening services that have helped our clients cut through the regulatory red tape of regulated chemicals since 1993.

E&SSG has developed many systems to effectively track your chemical inventory and provide you "Peace of Mind" about your chemical requirements.


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What We Offer
SARA Title III Screening Service
This service is designed to virtually eliminate the amount of time you would spend studying the SARA Title III regulations as well as searching, cross-referencing and indexing your chemical inventory against the SARA Title III regulated chemical lists.

This simple and painless service provides you with vital, “site specific”, information on how your facility(s) stand up against these regulatory lists and regulations. 
After this service is complete, it will be clear what areas of these regulations your facility(s) need to be concerned with or (better yet) have the defensible documentation to show that they don’t affect you.

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Fast
The entire process can be completed in as little as a few days.*
Simple
Initially you simply provide to us copies of your Material Safety Data Sheets (MSDS) that represents your current chemical product inventory.
Professional
Our staff of trained professionals enter key information from your MSDS into our system.
Systematic
We send you back either an E-mail or hardcopy** form requesting your product inventory information on the just the products, present at your facility, that contain these regulated chemicals. This information includes your quantities, container types, areas stored and areas used.
Logical    After the information is received back from you and entered into your file, E&SSG's proprietary CIA software matches your inventory against the thousands plus of regulated SARA Title III and Chemicals.
Results
The reports of the findings and/or compliance instructions are then delivered back to you in a three ring binder and/or PDF format.**
Reports
The reports that you receive will provide you with supportable documentation as well as a management tool to assess your hazards. This includes the following 7 reports complete with detailed information showing your:
•    Basic Total Chemical Inventory***
•    Emergency Release Priority Products
•    Extremely Hazardous Substances (EHS) Chemicals
•    Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Chemicals 
•    TRI (Form R/A) Chemicals
•    10,000 lb. Chemicals
•    Process Safety Management Chemicals
Ongoing     This service is a renewable annual (12 month) service that allows you to provide us your new or revised MSDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with the ongoing modifications to the SARA Title III lists and notify you if your status changes
Next Steps
Depending on the findings in your screening reports, there are potentially several additional steps for you to be fully compliant with all the sections listed. These steps could include additional analysis and/or reporting.

E&SSG has many services that can help you obtain compliance in the areas you need or desire. Most of our services are “turn-key” in nature, therefore, allowing you time to be more productive in your area of expertise.
Reporting
If required by the report findings pertaining to SARA Title III, sections 301-313 reporting, E&SSG will prepare and file your required Federal, State and Local reports as follows:

1)    Tier II Reporting – Just an additional $50/facility filing fee with this service.

2)    Toxic Release Inventory (TRI) (AKA-Form R/A) – Quoted separately
Coming Soon     E&SSG will provide you secure access to your chemical inventory online via E&SSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes. 
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*    Results are subject to demand and response time from the client.
**  Based on your preference.
***This is a basic Total Chemical Inventory report that will list just the MSDS Number, Product Name and Manufacturer, and Maximum Pounds (if given).
 

 

department-of-homeland-security

 

DHS Chemical Screen Service

 

What DHS Requires
DHS requires under the Chemical Facility Anti-Terrorism Standards (6 CFR Part 27) that any facility that manufactured, used, stored, or distributed chemicals listed in “Appendix A to Part 27 - DHS Chemicals of Interest” at or above the screening threshold quantity (STQ) must complete and submit an Internet based "Top-Screen" analysis using the DHS Chemical Security Assessment Tool (CSAT). Top-Screens are due January 22th, 2008 or within 60 calendar days of coming into possession of any such Chemical of Interest at or above the STQ.

Once DHS reviews a facility’s Top-Screen, the facility will be categorized into one of four tiers by DHS and will notified by DHS if it must evaluate the 19 elements of vulnerability and complete a Security Vulnerability Assessment (SVA) or if the facility can develop an Alternative Security Program (ASP). DHS will oversee the facility’s development of acceptable layering of measures used to meet the standards of the risk-based tier assigned to the facility. The facility will need to develop appropriate countermeasures and policies to meet DHS risk standards and complete a Site Security Plan (SSP).
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Our View:  The first and foremost task that needs to occur is to find out if your facility(s) have any of the DHS Chemicals of Interest present at your site that meet the requirements to go to the next step (Submitting a “Top-Screen”. E&SSG has provided services that help our clients cut through the regulatory red tape of regulated chemicals to find out what regulations affect them for more than 17 years. In light of this new standard, we have developed a service, utilizing our proprietary Chemical Inventory Analysis (CIA) system, to identify the DHS “Chemicals of Interest” present at your facilities and help you determine if this regulation is applicable to you. 
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What We Offer
DHS Chemical Screen Service
This service is designed to virtually eliminate the amount of time you would spend studying this regulation as well as searching, cross-referencing and indexing your chemical inventory against the DHS COI list. It will alleviate you from most of the countless hours you would spend just in order to determine if you need to perform, complete and submit an Internet based "Top-Screen" required by DHS. This simple and painless service provides you with vital, “site specific”, information about your chemicals and quantities needed to determine your requirements under this standard. 

After the DHS Chemical Screen Service is complete, you will either have the chemical documentation you need to submit your “Top-Screen” or the documentation you need to show that this standard is not applicable to you. 

Reports
The reports that you receive will show all the chemicals and what products they are in, percentages, as well as quantities at  your facility. The reports will aggregate those quantities that meet or exceed the minimum concentration given for each    chemical on the COI list. Those totals are then compared to the Screening Threshold Quantities (STQ) to show if you meet    or exceed the threshold(s). A worksheet with the chemicals that exceed the STQ is also sent to you with questions that may    allow you to eliminate particular products and/or chemicals from the totals.

The reports and subsequent worksheets include:
DHS Release – Toxic Chemicals
DHS Release – Flammable Chemicals
DHS Release – Explosive Chemicals
DHS Theft - CW/CWP (CUM 100 grams) Chemicals
DHS Theft - CW/CWP (Minimum DHS Concentration) Chemicals
DHS Theft - WME (CUM 100 grams) Chemicals
DHS Theft - WME (Minimum DHS Concentration) Chemicals DHS
Theft/Diversion - EXP/IEDP Chemicals
DHS Sabotage/Containment Chemicals


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Next Steps:  There are potentially several additional steps for you to be fully compliant with this standard (i.e. Top-Screen Submission, evaluate the 19 elements of vulnerability, complete a Security Vulnerability Assessment (SVA), develop an Alternative Security Program (ASP), develop appropriate countermeasures and policies to meet DHS risk standards, and complete a Site Security Plan (SSP). 

If desired…once we know what your required next steps, we can develop a quote for the service(s) to fit your needs.


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homeland-security-fact-sheet

 

DHS 6 CFR Part 27 Fact Sheet 
Department of Homeland Security Chemical Facility Anti-Terrorism Standard

 

Fact Sheet
DHS Final Rule for Chemical Facility Anti-Terrorism Standards - 6 CFR Part 27 The Department of Homeland Security (DHS) has issued a Final Rule for Chemical Facility Anti-Terrorism Standards, promulgated at 6 CFR Part 27. The regulation requires any facility that manufactured, used, stored, or distributed chemicals listed in the “Appendix A to Part 27 - DHS Chemicals of Interest” at or above the screening threshold quantity (STQ) must complete and submit an Internet based "Top-Screen" analysis using the DHS Chemical Security Assessment Tool (CSAT). DHS estimates approximately 40,000 facilities will have to complete this initial Top-Screen user registration. Top-Screens are due within 60 calendar days of the effective date of the final "Appendix A to part 27 - DHS Chemicals of Interest" or within 60 calendar days of coming into possession of any such Chemical of Interest at or above the STQ. This regulation is effective June 8, 2007, except for Appendix A, which was published November 20th, 2007. 

Once DHS reviews a facility’s Top-Screen, the facility will be categorized into one of four tiers by DHS and will notified by DHS if it must evaluate the 19 elements of vulnerability and complete a Security Vulnerability Assessment (SVA) or if the facility can develop an Alternative Security Program (ASP). The DHS will oversee the facility’s development of acceptable layering of measures used to meet the standards of the risk-based tier assigned to the facility. The facility will need to develop appropriate countermeasures and policies to meet DHS risk standards and complete a Site Security Plan (SSP). DHS will assign an agent to work with each facility to develop a schedule to implement site specific measures.
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DHS Deadline
Since Top-Screens are due within 60 calendar days of the effective date of the final "Appendix A to part 27 - DHS Chemicals of Interest" which was published November 20th, 2007. This makes the deadline to complete a CSAT Top-Screen January 22th, 2008 or within 60 calendar days of coming into possession of any such Chemical of Interest at or above the STQ.
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Penalties
Failure to complete a CSAT Top-Screen within the timeframe provided may result in civil penalties of $25,000 per day, a Department of Homeland Security audit and inspection, or an order to cease operations.
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Weblinks
The following are Weblinks related to the DHS Final Rule for Chemical Facility Anti-Terrorism Standards - 6 CFR Part 27
Final Rule (PDF, 41 pages)
Appendix A – DHS Chemicals of Interest (PDF, 14 pages)
Fact Sheet: Chemical Facility Anti-Terrorism Standards: Appendix A (HTML – DHS Website)
Frequently Asked Questions: Appendix A, Chemicals of Interest List (HTML – DHS Website)
Chemical Facility Anti-Terrorism Standards: Chemical Security Assessment Tool (HTML – DHS Website)
CSAT User Registration User Guide (PDF, 45 pages - 903 KB)
CSAT User Change Request Guide (PDF, 26 pages - 686 KB)
CSAT Top-Screen Questions (PDF, 79 pages - 1.1 MB) List of questions provided to assist chemical facility owners and operators in assembling the information needed to complete the secure web-based CSAT application
CSAT Top-Screen User Manual (PDF, 71pages - 1.5 MB)

 

 

sara-title-iii-dhs

 

SARA Title III & DHS Screening Service

 

What the regs require
The Environmental Protection Agency’s (EPA) SARA Title III and now The Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards require certain reporting based on the chemicals that are manufactured, used, stored, or distributed at your facilty(s). The SARA Title III reporting requirements are due March 1st (Tier II) and July 1st (TRI) each year. The new DHS “Top-Screens” are due January 18th, 2008 or within 60 calendar days of coming into possession of any Chemical of Interest at or above the STQ.

Failure to comply with either of these regulations can result in fines from $10,000-$75,000/day/occurrence, an inspection, or an order to cease operations.
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Do any of these regulations affect me?
This is the first and most critical answer that every facility must ultimately answer. The next few simple questions will help you answer the above. If you can answer “No” to any of the following questions then you’re in the clear:

Question #1: Do you do any one of the following; manufacture, use, store, process or distribute chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.) 

Question #2: Do you have chemicals contained within these products that fall on any of these lists? (This one is a little more difficult; however, if the answer to question #1 was “Yes” then the answer to this one is most likely the same.)

Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day or annually), meet or exceed the reporting thresholds listed in SARA Title III or the new DHS standard? (The only way that we can help you with this one is to screen for them.)

Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.
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Our View:  E&SSG has provided chemical screening services that have helped our clients cut through the regulatory red tape of regulated chemicals since 1993.

E&SSG has developed a many systems to effectively track your chemical inventory and provide you "Peace of Mind" about your chemical requirements.

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SETTINGS
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What We Offer
SARA Title III and DHS Screening Service
This service is designed to virtually eliminate the amount of time you would spend studying the SARA Title III and DHS regulations as well as searching, cross-referencing and indexing your chemical inventory against the SARA Title III and DHS regulated chemical lists.

This simple and painless service provides you with vital, “site specific”, information on how your facility(s) stand up against these regulatory lists and regulations. 

After this service is complete, it will be clear what areas of these regulations your facility(s) need to be concerned with or (better yet) have the defensible documentation to show that they don’t affect you.
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Fast
The entire process can be completed in as little as a few days.*
Simple
Initially you simply provide to us copies of your Material Safety Data Sheets (MSDS) that represents your current chemical product inventory.
Professional
Our staff of trained professionals enter key information from your MSDS into our system.
Systematic
We send you back either an E-mail or hardcopy** form requesting your product inventory information on the just the products, present at your facility, that contain these regulated chemicals. This information includes your quantities, container types, areas stored and areas used.
Logical    After the information is received back from you and entered into your file, E&SSG's proprietary CIA software matches your inventory against the thousands of regulated and/or flagged SARA Title III and DHS Chemicals.
Results
The reports of the findings and/or compliance instructions are then delivered back to you in a three ring binder and/or PDF format.
Reports
The reports that you receive will provide you with supportable documentation as well as a management tool to assess your hazards. This includes the following 16 reports complete with detailed information showing your: 

The reports that you receive will provide you with supportable documentation as well as a management tool to assess your hazards. This includes the following 16 reports complete with detailed information showing your: 

SARA Title III Reports
•    Basic Total Chemical Inventory***
•    Emergency Release Priority Products
•    Extremely Hazardous Substances (EHS) Chemicals
•    Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Chemicals 
•    TRI (Form R/A) Chemicals
•    10,000 lb. Chemicals

Department of Homeland Security Anti-Terrorism Reports****
•    DHS Release – Toxic Chemicals
•    DHS Release – Flammable Chemicals
•    DHS Release – Explosive Chemicals
•    DHS Theft - CW/CWP (CUM 100 grams) Chemicals
•    DHS Theft - CW/CWP (Minimum DHS Concentration) Chemicals
•    DHS Theft - WME (CUM 100 grams) Chemicals
•    DHS Theft - WME (Minimum DHS Concentration) Chemicals
•    DHS Theft/Diversion - EXP/IEDP Chemicals
•    DHS Sabotage/Containment Chemicals

Ongoing     This service is a renewable annual (12 month) service that allows you to provide us your new or revised MSDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with the ongoing modifications to the many different SARA Title III and DHS lists and notify you if your status changes.
Next Steps
Depending on the findings in your screening reports, there are potentially several additional steps for you to be fully compliant with all the sections listed. These steps could include additional analysis, reporting and possibly more. 

E&SSG has many services that can help you obtain compliance in the areas you need or desire. Most of our services are “turn-key” in nature, therefore, allowing you time to be more productive in your area of expertise.
Reporting
If required by the report findings pertaining to SARA Title III, sections 301-313 reporting, E&SSG will prepare and file your required Federal, State and Local reports as follows:

1)    Tier II Reporting – Just an additional $50/facility filing fee with this service.

2)    Toxic Release Inventory (TRI) (AKA-Form R/A) – Quoted separately
Coming Soon     E&SSG will provide you secure access to your chemical inventory online via E&SSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes. 
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SETTINGS
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* Results are subject to demand and response time from the client.
** Based on your preference.
***This is a basic Total Chemical Inventory report that will list just the MSDS Number, Product Name and Manufacturer, and Maximum Pounds (if given).
****The reports that you receive will show all the chemicals and what products they are a mixture of, percentages, as well as quantities at your facility. The reports will aggregate those quantities that meet or exceed the minimum concentration given for each chemical on the COI list. Those totals are then compared to the Screening Threshold Quantities (STQ) to show if you meet or exceed the threshold(s). A worksheet with the chemicals that exceed the STQ is also sent to you with questions that may allow you to eliminate particular products from the totals.

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