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3.5 OSHA Hazard Communication (HazCom) Plan The purpose of the OSHA HazCom plan is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees (29CFR 1910.1200(a)1). The chemicals that are included in the HazCom program are "hazardous chemicals". The definition of a hazardous chemical is any chemical that is a physical hazard or a health hazard (29CFR 1910.1200(c)). This definition is so broad that a list of chemicals is not provided in the regulations. Most chemicals (other than materials such as food, cosmetics, and drugs) are classified as hazardous chemicals. Manufacturers that supply hazardous chemicals to American Soda are required by law to label all containers and to provide Material Safety Data Sheets (MSDSs) with the chemical shipment. Labels must include the identity of the chemical, chemical manufacturer (or importer) name and address, physical hazards, and health hazards. MSDSs provide detailed hazard information on hazardous chemicals. American Soda must provide both label and MSDS information to all employees. Copies of typical MSDSs for materials that are planned to be used for the Yankee Gulch Project are provided in Appendix D. The hazards listed on these MSDSs are believed to be representative of the hazards that will be present on each respective site. However, these are probably not the exact chemicals that will be used on site. Copies of actual MSDSs for materials used for the project will be provided in the final Response Plan, once the manufacturer/supplier has been selected. American Soda will also be required to develop and provide sodium bicarbonate and sodium carbonate MSDSs for their customers because they are considered hazardous chemicals. Example MSDSs for these products are provided in Appendix E. A general outline of the OSHA HazCom Plan is provided along with the OSHA Emergency and Fire Prevention Plan information in Appendix C. Most of these requirements are met in this preliminary Response Plan. 3.6 EPCRA Reporting Requirements EPCRA (also known as Title [II of the Superfund Amendments and Reauthorization Act (SARA)) requires owners and operators of facilities to report on the hazardous chemicals present at their facilities and the releases of hazardous chemicals from their facilities into the environment. The four major parts of EPCRA are: • emergency planning (Sections 301, 302, and 303) emergency release notification (Section 304) 8 Preliminary Response Plan Yankee Gulch Sodmm Minerals Project American Soda, L.L.P.