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Revised Hazard Categories for EPCRA 311 / 312 Reporting

On March 26 2012, the Occupational Safety and Health Administration (OSHA) revised its Hazard Communication Standard (HCS) by adopting the United Nations Globally Harmonization System of Classification and Labeling of Chemicals (GHS). Based on the new classification criteria that OSHA adopted, EPA revised the existing hazard categories for hazardous chemical inventory form reporting under EPCRA Section 312 and for list reporting under section 311 in a final rule published on June 13 2016 (81 FR 38104). What are these categories and when must facilities begin using them when complying with EPCRA 311 and 312 reporting requirements?

These hazard categories are defined in 40 CFR 370.66 and must be used starting January 1, 2018:

Hazard category is divided into two categories, health and physical hazards.

Health hazard means a chemical which poses one of the following hazardous effects: Carcinogenicity; acute toxicity (any route of exposure); aspiration hazard; reproductive toxicity; germ cell mutagenicity; skin corrosion or irritation; respiratory or skin sensitization; serious eye damage or eye irritation; specific target organ toxicity (single or repeated exposure); simple asphyxiant; and hazard not otherwise classified (HNOC).

Physical hazard means a chemical which poses one of the following hazardous effects: Flammable (gases, aerosols, liquids or solids); gas under pressure; explosive; self-heating; pyrophoric (liquid or solid); pyrophoric gas; oxidizer (liquid, solid or gas); organic peroxide; self-reactive; in contact with water emits flammable gas; combustible dust; corrosive to metal; and hazard not otherwise classified (HNOC).

The physical and health hazards are defined in the OSHA Hazard Communication Standard, 29 CFR 1910.1200.

EPA developed a crosswalk with OSHA to align EPA’s hazard categories with the GHS for Hazard Communication adopted by OSHA. The crosswalk is available at the following URL:

https://www.epa.gov/sites/production/files/2018-04/documents/crosswalk_old_and_new_physical_and_health_hazards_04_10_18.pdf