Is combustible food dust subject to reporting under Sections 311 and 312?
The definition of hazardous chemical under OSHA HCS includes “combustible dusts”. So, if the facility accumulates 10,000 lbs of dusts at any one time, it is reportable under Sections 311 and 312.
Facilities may want to consult FDA regulations to determine if certain food dusts would be covered under their regulations as food or food additive. If FDA regulates such substances as food or food additive, then that amount would not be subject to reporting under EPCRA Sections 311 and 312.
Here is the link to OSHA’s website regarding information on Combustible dusts: