How should a person determine whether very similar hazardous substances (e.g., different colors of paint or different blends of gasoline) that have separate SDSs (Safety Data Sheets) should be aggregated for reporting in CHS Manager?
In general, "different" substances are represented by different SDSs. However, the fact that a facility has two or more SDSs for its hazardous substances does not necessarily mean that these are considered "different" mixtures. For example, if a facility receives multiple SDSs for essentially the same material simply because the substance is provided by different suppliers, or is just a different brand (e.g. Castrol Oil vs. Havoline Oil), all quantities of the substance present at the facility must be aggregated for reporting threshold determinations. Conversely, if two or more chemical combinations are represented by different SDSs and present different physical or health hazards, they would not be aggregated for reporting purposes. Beyond this, the facility owner/operator must determine, based on professional judgment, if the two materials present the same physical/health hazards and are sufficiently similar to warrant aggregation as the "same" mixture.
To determine which SDS should be linked to the aggregated substance, the facility should ensure the SDS sufficiently captures the physical and health hazards in a worst case scenario. Facilities should be mindful that first responders could use this reported information to respond to an incident involving the aggregated substance. If the SDSs are essentially the same, select the one that is most appropriate.
If a facility has questions about whether similar mixtures may be aggregated for reporting in CHS Manager, they should contact the Community Right to Know program. Click here to submit a request for guidance, or call 503-378-6835 or 800-454-6125.