Significant Changes to 2018 CERS Reporting for California: Are You Ready?
Effective December 28, 2017, CalEPA will replace the existing five (5) federal hazard categories available in CERS used for the completion of chemical inventories as part of the annual hazardous materials business plan submittal with twenty-four (24) new federal hazard categories adopted by the United States Environmental Protection Agency (U.S. EPA) as a result of changes to the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS).
The table below depicts the existing and new federal hazard categories:
In June 2016, the U.S. EPA amended its hazardous chemical reporting regulations (40 CFR part 370) as a result of changes to the OSHA HCS. OSHA’s HCS (29 CFR 1910.1200) was revised to conform to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Core elements of the GHS include standardized hazard testing criteria, universal warning pictograms, and harmonized SDSs.
The revised OSHA HCS requires chemical manufacturers and importers to:
• evaluate their chemicals according to the new criteria adopted from GHS to ensure chemicals are classified and labeled appropriately, and
• develop standardized SDSs and distribute them to users of their chemicals.
• replacing the use of “Material Safety Data Sheets (MSDSs)” with “Safety Data Sheets (SDSs)” as both terms have the same meaning;
• revising the definition of “hazardous chemical” to any chemical which is classified as a physical or health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified (HNOC); and
• replacing the existing five federal hazard categories for list reporting (40 CFR part 370 section 311) and annual inventory reporting (40 CFR part 370 section 312) with 24 new physical and health hazard categories established by the GHS.
The 24 New Federal Hazard Categories must be reported in companies Hazardous Materials Business Plan (HMBP) Submittals for 2018, due on March 1, 2018.
Chemical Safety’s EMS Software has the tools and automated calculations for CERS reporting.
Chemical Safety’s Environmental Management Systems (EMS) software has modified its CERS reporting tool to calculate and report those chemicals that meet the reporting thresholds with the new CERS hazard categories. Chemical Safety’s database of chemicals contains over 150,000 records with GHS and hazard categories including the entire CERS chemical library, and over one million of the latest manufacturer-specific Safety Data Sheets (SDS). Furthermore, EMS will automatically generate a CERS approved excel file automatically with all the reportable information in the format and with all the CERS required hazard classifications.
EMS also provides numerous reports that can be used to cross-reference and validate the information being reported in the CERS regulatory report.
Although the reporting deadline is close, we can upload and import your chemical inventory data into EMS with preformatted templates that make the import quick and efficient, cross-reference all the chemicals and obtain the hazard information required for reporting. EMS can then automatically generate your company’s Hazardous Materials Business Plan (HMBP) in electronic format that can be uploaded to the CERS portal. This can happen in a matter of days. We will work with you closely and support your reporting requirements quickly and cost-effectively.