Community Right-to-Know and Chemical Reporting Management Program Template

CommunityRight-to-Know and Chemical Reporting Management Program

Table of Contents

I.OBJECTIVE AND SCOPE

II. DEFINITIONS

III. RESPONSIBILITIES

  1. Program Manager
  2. Supervisors
  3. Employees
  4. Third Party Contractors

IV. PROCEDURE

  1. Community Emergency Planning Requirements
  2. Facility Emergency Planning Requirements
  3. Emergency Release Notification Requirements
  4. Hazardous Chemical Storage Reporting Requirements
  5. Toxic Chemical Release Inventory Reporting Requirements

V.TRAINING

A.Employee Training

B.Training Records

VI. REFERENCES

  1. NCH Global Environmental Health and Safety Policy
  2. Business Unit Policy references
  3. Site Policy references
  1. APPENDICES

Appendix A - Sample Emergency Release Follow-Up Notification form

Appendix B - Sample Emergency and Hazardous Chemical Inventory

VIII.DOCUMENT CONTROL

Community Right-to-Know and Chemical Reporting Management Program

for

[Company Name/Location]
I.OBJECTIVE AND SCOPE

The objective of the [Company Name/Location] Community Right-to-Know and Chemical Reporting Management Program is to document information that when provided to governmental agencies will facilitate protection of public health and the environment.

This Program has four major provisions:

  1. Emergency planning
  2. Emergency release notification
  3. Hazardous chemical storage reporting
  4. Toxic chemical release inventory reporting

The information gathered from these four provisions may be used by governmental agencies to develop a broad perspective of chemical hazards for the local community as well as for the individual facilities.

The procedures described in this Program are intended to facilitate compliance with applicable governmental regulations. If there is a conflict between this Program and a governmental regulation, the governmental regulation will apply and this Program will be modified. Specific information required by this program will be made available to agencies which respond to emergencies at[Company Name/Location] to enhance the level of response and provide safety information to the responders.

II.DEFINITIONS

Community or Governmental Agencies. Public entities such as Local Emergency Planning Committee (LEPC), fire department, police, and medical support (hospital).

Emergency Response Plans. Facility emergency response plans that contain pertinent information that can use at the time of a chemical accident.

Emergency Release Notification. Notification to a designated local authority of a release into the environment of a hazardous substance. Note: In some instances local governmental notification requirements establish minimum reportable quantities below which no notification is required.

Extremely Hazardous Substances (EHS). Chemical substances that are identified by environmental regulations because of their extreme toxicity, ability to disperse in the air and quantity used.

Community Right-to-Know. Governmental requirements that facilities submit material safety sheets (MSDS) for chemicals stored above specific quantities.

[Toxics Release Inventory (USA facilities only). Data on chemical releases and other waste management activities provided to governmental agencies when required by local governmental requirements.]

III.RESPONSIBILITIES
  1. Program Manager

[Responsible Person] shall manage this Program for [Company Name/Location].

It is the Program Manager’s responsibility to determine the requirements of any applicable governmental regulation and make any changes to this program that is required.

The Program Manager shall maintain all records as outlined in this Program. The Program Manager is responsible for scheduling and performing reviews of data, evaluating performance, initiating change, and reporting results to facility management except in North America (ORA).

B.Management

[Company Name/Location] will provide adequate controls, tools anddocuments to implement the Program.

C.Supervisors

Supervisors shall work with the Program Manager to provide data and information as required, maintain information needed to prepare reports and implement corrective actions.

D.Employees

Designated employees are responsible for gathering data required by this Program.

E.Third Party Contractors

Third Party Contractors are responsible for complying with this Program.

IV.PROCEDURE
  1. Facility Emergency Planning Requirements

As required by governmental requirements, the Program Manager will:

  1. Notify community agencies of any extremely hazardous substances stored at the facility;
  2. Provide facility emergency action plan to community agencies; and
  3. Participate in community emergency response plan exercises.
  1. Emergency Release Notification Requirements

As required by governmental regulations:

[Responsible Person] must notify the community agencies if there is a release into the environment of an extremely hazardous substance.

This emergency notification will include:

  1. The chemical name;
  2. An estimate of the quantity released into the environment;
  3. The time and duration of the release;
  4. Whether the release occurred into air, water and/or land;
  5. Any known or anticipated acute or chronic health risks associated with the emergency;
  6. Proper precautions, such as evacuation or sheltering in place;
  7. Name and telephone number of contact person; and,
  8. [Additional information required by governmental regulations].

[Responsible Person] will provide this information to ORA.

A written follow-up report will be submitted to the community agencies as required after the release. See Appendix A for sample Emergency Release Follow-Up Notification form.

  1. Hazardous Chemical Storage Reporting Requirements

[For North America, ORA will submit:

  1. MSDS or list of MSDS for chemicals held above certain quantities to the community agencies as requested within three months after they first receive a shipment.
  2. An emergency and hazardous chemical inventory form to the community agencies on or before March 1 each year. The emergency and hazardous chemical inventory form provides the following information for each chemical.

a)The chemical name or the common name as indicated on the MSDS;

b)An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount;

c)A brief description of the manner of storage of the chemical; and,

d)The location of the chemical at the facility.

See Appendix B for sample form for Emergency and Hazardous Chemical Inventory reporting.]

[Other countries, Program Manager will review requirements for compliance to the governmental regulations.]

  1. Toxic Chemical Release Inventory Reporting Requirements

[For North America, ORA shall complete a Toxic Chemical Release Inventory Form on or before [July 1] each year for specified chemicals by [EPA}. The purpose of this reporting requirement is to inform the public and government officials about releases and other waste management of toxic chemicals.

The following information is required on the Form:

  1. The name, location and type of business;
  2. Whether the chemical is manufactured (including importation), processed or otherwise used ;
  3. An estimate of the maximum amounts of the toxic chemical present at the facility at any time during the preceding year;
  4. Quantity of the chemical entering the air, land, and water annually;
  5. Off-site locations to which the facility transfers toxic chemicals in waste for recycling, energy recovery, treatment or disposal; and
  6. Waste treatment/disposal methods and efficiency of methods for each waste stream; and
  7. Collection of information on source reduction, recycling and treatment.

[Other countries, Program Manager will review requirements for compliance to the governmental regulations.]

V.TRAINING

A.Employee Training

Appropriate employees shall receive instruction on this Program. Training shall be provided:

  1. When there are any changes to the program and/or facility.
  2. When an employee’s responsibilities change that affects this Program.
  3. Annually as refresher training.

B.Training Records

[Responsible Person] shall document all training pertaining to this program in accordance with the facility Training Plan.

VI.REFERENCES

A.Business Unit Policy references

B.Site Policy references

VII.APPENDICES

Appendix A - Sample Emergency Release Follow-Up Notification form.

Appendix B - Sample Emergency and Hazardous Chemical Inventory form.

VIII.DOCUMENT CONTROL

This Program shall be reviewed annually, or as needed if changes to the facility operations, processes, or personnel are made, by [Responsible Person]. Following each change, [Responsible Person] shall document the change and inform all affected by the changes.

Document History:

Procedure version / Date Approved / Approved by / Reason for Change
Date: March 24, 2009
Version: Final 1.0 / Authorized by: Regulatory Affairs Counsel
Next Review: March 25, 2010 / Uncontrolled when printed

1

Appendix A

Sample Emergency Release Follow-Up Notification form

Appendix B

Sample Emergency and Hazardous Chemical Inventory form