Chemical Inventory ProgramsTriumvirate Environmental presents:

Chemical Inventory ProgramsTriumvirate Environmental presents:

Meet the ModeratorSasha Laferte

Chemical Inventory ProgramsTriumvirate Environmental presents:

Meet the PresenterSchuyler Stuart, Life

Sciences Operations Manager

• X Years Experience

• Fact A

• Fact B

• Fact C

Cell Phone: 518-569-1424

Email: sstuart@triumvirate.com

Learning Objectives

Regulatory Drivers

Financial and Operational

Drivers

Improve Onsite Safety and

Compliance and Reduce Costs

Chemical Inventory Life

Cycle

Plan and Strategy

Development

Regulatory Landscape

EPCRA (Emergency Planning Right to Know ACT)

Hazard Communication

Local Authorities

• Fire Department

• Waste Water Agencies

CFATS (Chemical Facility Anti-Terrorism Standards)

EPCRA – Codified in 40 CFR

Parts 355, 370 and 372

• Part 355 – Emergency Planning

and Notification

• Part 370 – Hazardous Chemical

Reporting: Community Right-to-

Know

• Part 372 – Toxic Chemical

Release Reporting: Community

Right-to-Know

EPCRA – 4 Major Provisions

• Emergency Planning

(Section 301-303)

• Emergency Release Notification

(Section 304)

• Hazardous Chemical Storage

Reporting Requirements

(Section 311-312)

• Toxic Chemical Release Inventory

(Section 313)

Sections 311/312 Community

Right-to-Know Requirements

Section 311 requires submittal of MSDSs or chemical lists to the SERC, LEPC and/or local fire dept.

Section 312 requires submittal of annual (by March 1) Tier II Chemical Inventory Reports to the SERC, LEPC and/or local fire dept.

EPCRA Inventory Checklist• Facility name, address,

location Tier II -Emergency and Hazardous Chemical Inventory

• Emergency contact

• Chemical Information:• Description

• Hazards

• Amounts

• Locations

Tier II reports are due by March 1st annually

EPCRA Inventory Checklist• CAS number

• Chemical name

• Descriptors: pure, mixture, liquid, solid, gas

• Physical and health hazards: • Fire hazard

• Sudden release of pressure

• Immediate (acute) health

• Delayed (chronic) health

Tier II reports are due by March 1st annually

• Maximum amount (range/pounds)

• Average daily amount

• Number of days on-site

• Storage codes:

• Site Plan

Tier II reports are due by March 1st annually

EPCRA Inventory Checklist

• Types of storage:• Cylinder

• Glass bottles

• Tote

• Rail car

• Etc.

• Storage conditions:• Ambient pressure

• Ambient temperature

• Confidential information

• Certification

Tier II reports are due by March 1st annually

EPCRA Inventory Checklist

OSHA – Employee Right to Know

• Hazard

Communication

Standard 1910.1200

• Lab Standard

1910.1450

“Employers must develop

systems to identify chemicals

and the associated hazards in

the work place, which must be

communicated to employees”

CWA and Discharge

Permits

• NPDES Permits

(EPA)

• Discharge Permits

to POTW

• Local authorities

Flammable Permits• Facilities must maintain

flammable levels at or

below permit levels

• State Building codes

provides specific

parameters on volumes

and locations of

flammable materials.

– Flammable Class

– Control Zones

DHS CFATS (6 CFR Part 27)November 20, 2007

Purpose of Rule:• Gain information about facilities

possessing specific chemicals.

• Identify high-risk chemical facilities based on risk-based-performance standards

• Improve Security of High Risk chemical facilities

http://www.dhs.gov/chemical-security-assessment-tool

Organizational Drivers

Purchasing R&D

Manufacturing EH&S

The Chemical Inventory Life Cycle

Purpose

Process

LaunchManagement

Review

Purpose

Create a Chemical Inventory Project Team

Identify program goals and objectives

Process• Types of chemicals

• Logistics– Centralized vs. decentralized

– Size/number of buildings, rooms, storage areas

– Purchasing

• Departmental users– Chemistry

– Biology

– Facilities

– EHS

– Purchasing

– Shipping/Receiving

Process Inventory Software

Examples:

• Microsoft Excel

spreadsheet

• CisPro/ChemSW

• MSDS Online

• CambridgeSoft

• SciQuest (ERM/Site

Hawk)

• Internally Developed

System

Launch

Ready, Set, GO!Assign Responsibilities

Data collection and management strategy

LaunchInventory Map

Create a Strategy to collect data• Identify what is to be inventoried

• Create location guide

• Notify lab personnel

• Prepare equipment and supplies

• Create a sustainable plan to

inventory new chemicals as they

arrive onsite

Launch Stakeholders

Communicate your

implementation

strategy

Managing Your

Inventory

• Need a sustainable

system for tracking

chemicals

• Identify the correct

stakeholders to

manage the data

• Chemical inventory

reconciliation

Review and Optimization

Written Plans Training

Onsite Chemical

Management

Ordering Chemicals

QUESTIONS?

Thank You For Attending!

• You will receive an email

tomorrow with a copy of

this presentation

• Please complete our

short survey

• Expect a transcribed copy

of the Q&A as well as a

free chemical inventory

management assessment

• Register for upcoming

webinars

http://www.triumvirate.co

m/training/events