Facilities required to comply with this new regulation must complete what is called a “Top-Screen” online application. DHS has identified these chemicals and established threshold limits for preliminary screening based on their potential to create significant human life or health consequences. Appendix A lists approximately 300 chemicals of interest and includes common industrial chemicals such as chlorine, propane, and anhydrous ammonia, as well as specialty chemicals such as arsine and phosphorus trichloride. Facilities that possess chemicals of interest at or above the listed screening threshold quantities are required to complete the Top-Screen within 60 calendar days of the publication of Appendix A. Although DHS has released Appendix A, the rule does not become effective until it is published in the Federal Register.
The M3V software application “Chemical Management Navigator” has incorporated these specific chemicals and can greatly assist in the ongoing monitoring of them along with all of the chemicals at your facility. The application will not only generate a list of the products at your facility containing these specific chemicals, but will assist you in complying with the new regulation by keeping a clean inventory of all the chemicals of interest in a secure database. This application is also able automatically generate certain SARA reports (such as Tier II) and VOC or HAP reports as required in air permits or NESHAP standards.