As the deadline approaches for developing a written program for the newly modified Hazard Communication Standard, my office is starting to resemble a small Kinko’s. The new standard is 83 pages. In addition, a new 3 ring binder that is marked “Safety Data Sheets” is in the works. The binder contains a set of A-Z tabs and a 16 page list of chemicals that are common in preparation rooms. The Globally Harmonized System of Chemical Classification and newsletter are not counted since both are digital presentations.

  The revised programs are being reformatted with color headers and footers. While nice, all of this served to make the other 8 sections of our company safety plan out of date. We had to admit that it was a case of the Hazard Communication Plan being chrome while the other 8 sections of our company safety plan were rust. I made a decision to do the rest of the manual and to redo over 70 PowerPoint presentations in a drop box format. The entire project will take 8 months.

  There is a lesson here. Be careful when you brighten one part because the part that looked fine before will suddenly become the old rusty part. In fairness, this effort would not be possible without the assistance of Jarrett, Paulette, and Marc Stewart. They are more than staff. They are my son, my wife, and my step-son. It is, to say the least, a family affair.

Backtracking on EPA Tier II Reporting Requirements

  I made a rare road trip in June. One reason was to explain the Tier II reporting requirements that were the subject of my last submission. About 300 miles out, and well before my first stop, I got a call from an EPA official in Oklahoma. I had placed calls to several states the previous week. This one was different. He happened to be familiar with the funeral industry. I learned the following:

  The 100 pound threshold on formaldehyde pertained to the amount subject to a release at one time. Funeral homes don’t ever do that.

  The 500 pound threshold did pertain to the amount you could have at one facility. On this, the inspector was familiar with injection chemical and was aware that it was an approximate 37 percent formalin mixture. He indicated that he would only count 37 percent of the amount of formaldehyde at the location. Other state inspectors may not be aware of that and might count it in full. In that case, you might have to appeal.

  Most funeral homes should be able to schedule shipments so that they do not exceed the 500 pound threshold. One of my customers is an embalming service that handles over 6,000 cases a year. He buys his chemicals weekly. The most he will have on stock is ten cases. If he can stay within the threshold, it should not be a problem for the rest of the industry.

  I read, reacted, wrote and submitted. The thresholds were correct but I missed on how the EPA applied them. For those of you who are stocking more than 20 cases of injection fluid, I think you should call your state EPA office. Give them the particulars of my discussion and ask them if you need to report or cut back on your product inventory.