Twin sticks, a.k.a. “Twix”, the candy bar baited some of its milk chocolate, caramel and wafer devotees into believing, before there were memes, that one stick was for immediate consumption, the other, presumably saved for one’s future enjoyment. The idea being masticate only one bar, the other, later.
Much like the Environmental Protection Agency’s (EPA) 40 CFR dueling hazardous substance lists. Their Section 302.4, Hazardous Substances and Reportable Quantities List focus is on the immediate notification, whereas in Appendix A of Part 355, the Extremely Hazardous Substance (EHS) List, deals with community safety, and preparing for future emergencies.
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), requires immediate reporting, response and liability for the roughly 800 hazardous substances listed in Section 302.4.
The Emergency Planning and Community Right-to-Know Act (EPCRA) mandates reporting chemical releases, community right-to-know requirements and developing Emergency Response Plans for the approximately 355 hazardous substances listed in Appendix A of Part 355. These requirements prophylactically prepare the community for future hazardous substance emergencies through annual inventory reports and local emergency planning commission release notifications.
If you took the bad apples, like Allyl Alcohol and Aldrin, out of Section 302.4 Hazardous Substances and Reportable Quantities List you would basically have Appendix A of Part 355, the Extremely Hazardous Substance (EHS) List.
Together, the Section 302.4 and the Appendix A Part 355 lists ensure a 24 hour time limit for notification to the National Response Center (NRC) and your Local Emergency Planning Commission, respectively, allowing for immediate response to hazardous substance releases.
As far as the Twix bars go, I would always eat one and save the other one and eat it after I was done with the first!
Please call us with any questions, comments or input. We look forward to hearing from you.
Hope to see you soon, thank you.
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.
www.hazmat-tsp.com
610-587-3978
hazmat-tsp@gmail.com
