If the Material Safety Data Sheet (MSDS) and label for a particular liquid hazardous chemical does not indicate the weight of the substance, how should the facility owner or operator make threshold and applicability determinations for EPCRA §312 (Tier II) Reporting?

If a liquid is not labeled in pounds, its weight can be calculated by multiplying the liquid’s volume by its density.  The density (mass per unit volume) should be noted on the MSDS.  If the liquid’s density is not indicated on the MSDS, the facility owner or operator may estimate the weight based on the density of water (8.3 pounds per gallon, or 2.2 pounds per liter), when making EPCRA §312 threshold determinations.