Date: Thu, 15 Feb 2007 10:15:05 -0500
Reply-To: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Organization: ASU Safety & WC Office
Subject: Re: Tier 2 Reporting
In-Reply-To: <s5d2e7d3.041**At_Symbol_Here**>
I wanted to briefly "second" Diane's post.  The previous post implying that
it's silly to have to include baby shampoo, rock salt, sand etc on the
annual Tier II to EPA and local emergency responders seems to kind of be
missing the point of what these reports are for.  No insult
intended...however it is important to keep the purpose of Tier IIs in mind
when deciding what to include.

Why report things that seem relatively innocuous (assuming you have a large
quantity)?  Because the purpose of EPA is to protect the environment (as
opposed to OSHA, which focuses on worker safety... what most of us safety
folks usually are focused on) and to protect the safety & health of the

A release of 5,000 gallons of baby shampoo may sound innocuous, but imagine
firefighters trying to rescue someone or keep a building full of flammables
cooled down in a parking lot full of liquid soap (the shampoo would probably
impact the nearby streams and maybe the soil too.)  A river overflowing its
banks into a 10,000 lb pile of road salt will probably impact the pH and
cause a fish kill.  The rupture of 150 lb cylinder of chlorine gas from
malfunction or fire could kill everyone within a certain radius.

These are examples of things the local emergency responders need to know are
there -- BEFORE they go roaring in w/lights and sirens.  [I personally might
not report sand on a Tier II unless it's required (we don't have enough for
me to have looked into it), but that doesn't mean it's not a significant
hazard to people who work around airborne silica. Sand at the beach isn't
typically airborne to a significant extent, and that which is is heavily

Too keep the reporting process from being too cumbersome, you only have to
report very large quantities, or items that are extremely hazardous in
smaller quantities (e.g. chlorine gas, for example).  EPA provides a list of
items they consider to be extremely hazardous.  So if you have 5 cases of
baby shampoo, no reporting; but if you have a 5,000 tank of it, then
probably yes.'s unusual for me to be in the position of defending EPA
regulations since they are typically ridiculously complicated in my opinion!
But much as I dread this annual exercise, this one actually has some basis
in sanity.


Mary M. Cavanaugh, CIH
phone  828.262.6838
email  cavanaughmm**At_Symbol_Here**

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Diane Amell
Sent: Wednesday, February 14, 2007 11:43 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Tier 2 Reporting

I was going to stay out of this, as I don't deal with SARA Title III
(although a good friend of mine coordinates all the Tier I/Tier
II/TRI/pollution prevention reporting in the state), but I'm afraid the
previous comment upset me a bit.
If you don't think silica sand is hazardous, please read NIOSH's Silicosis
in Sandblasting: A Case Study Adapted for Use in U.S. High Schools at (also available in
Spanish and as a pdf file). You may want to pay special attention to the box
on the Hawk's Nest incident.

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