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A mixture is a combination of two or more different substances, each retaining its own chemical identity. Facilities may have mixtures containing extremely hazardous substances (EHSs) or hazardous chemicals. To determine the quantity of an EHS or a non-EHS hazardous chemical component present in a mixture, multiply the concentration of the hazardous chemical component (in weight percent) by the weight of the mixture (in pounds).
However, the owner or operator of a facility can choose to report all the components of a mixture separately or report the mixture as a whole (e.g., if the composition of a mixture is unknown), unless it is not possible to do so. The catch is whichever option the facility uses, the reporting of mixtures must be consistent for reporting under both EPCRA 311 and EPCRA 312, where practicable. If a facility reports on mixtures as a whole in EPCRA 311, it must do the same in EPCRA 312, where practicable. (EPCRA 311 is about SDS/MSDS reporting, and EPCRA 312 is about Tier I (or Tier II) reporting.)
EPA regulation 40 CFR 370.14 offers a handy table to explain the mixture requirements:
If the mixture contains a hazardous chemical | To determine if the threshold level for that hazardous chemical is equaled or exceeded, the facility owner or operator must: | If the threshold level for that hazardous chemical is exceeded, then the facility owner or operator must: |
That is an EHS | Determine the total quantity of the EHS present throughout the facility at any one time, by adding together the quantity present as a component in all mixtures and all other quantities of the EHS (include the quantity present in a mixture even if the owner or operator is also counting the quantity of that particular mixture toward the threshold level for that mixture). |
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That is not an EHS | Determine either:
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A mixture is a combination of two or more different substances, each retaining its own chemical identity. Facilities may have mixtures containing extremely hazardous substances (EHSs) or hazardous chemicals. To determine the quantity of an EHS or a non-EHS hazardous chemical component present in a mixture, multiply the concentration of the hazardous chemical component (in weight percent) by the weight of the mixture (in pounds).
However, the owner or operator of a facility can choose to report all the components of a mixture separately or report the mixture as a whole (e.g., if the composition of a mixture is unknown), unless it is not possible to do so. The catch is whichever option the facility uses, the reporting of mixtures must be consistent for reporting under both EPCRA 311 and EPCRA 312, where practicable. If a facility reports on mixtures as a whole in EPCRA 311, it must do the same in EPCRA 312, where practicable. (EPCRA 311 is about SDS/MSDS reporting, and EPCRA 312 is about Tier I (or Tier II) reporting.)
EPA regulation 40 CFR 370.14 offers a handy table to explain the mixture requirements:
If the mixture contains a hazardous chemical | To determine if the threshold level for that hazardous chemical is equaled or exceeded, the facility owner or operator must: | If the threshold level for that hazardous chemical is exceeded, then the facility owner or operator must: |
That is an EHS | Determine the total quantity of the EHS present throughout the facility at any one time, by adding together the quantity present as a component in all mixtures and all other quantities of the EHS (include the quantity present in a mixture even if the owner or operator is also counting the quantity of that particular mixture toward the threshold level for that mixture). |
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That is not an EHS | Determine either:
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