BNL Chemical Inventory Requirement Table

Issue date 09/1/2014

The only official copy is on-line at the SHSD CMS Group website. Before using a printed copy, verify that it is current by checking the document issue date on the website.

What Chemicals need to be inventoried in the CMS

The Chemical Management System (CMS) at BNL is used to fulfill many regulatory requirements. One of the regulations that CMS is used to fulfill is the OSHA Hazard Communication Regulation - 1910.1200 (Hazcom). The purpose of Hazcom is to ensure that the hazards of chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.

For laboratories the OSHA Occupational exposure to hazardous chemicals in laboratories regulation - 1910.1450 (Lab Standard) supercedes Hazcom.

Definitions

  • "Chemical" means any element, chemical compound or mixture of elements and/or compounds. 1910.1200(c) - Definitions.
  • "Hazardous chemical" means any chemical which is a physical hazard or a health hazard. 1910.1200(c) - Definitions.
  • "Hazardous chemical" means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. 1910.1450(b) - Definitions.
  • "Physical hazard" means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive)or water-reactive. 1910.1200(c). Definitions of "physical hazard" terms.
  • "Health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes. 1910.1450(b). Definitions of "health hazard" terms.
  • "Consumer Product" means any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended. 1910.1200.(b)(6)(ix).
  • "Consumer Quantity" means a quantity typically found in the home. This is generally considered to be 1 to 2 containers, but, may be more.
     

Compliance

In order to comply with Hazcom and Lab Standard regulations, BNL has committed to inventorying chemical containers on site as described below in "Items the CMS REQUIRE to be Inventoried" except those exempted below under "Items the CMS DO NOT REQUIRE to be Inventoried" and "Items the CMS MAY REQUIRE to be Inventoried". Inventory of a chemical includes the bar-coding and tracking of the chemical in the CMS. By providing the ability for a user to search the inventory of chemicals by work area and to be able to obtain MSDSs the CMS helps communicate workplace hazards to the worker.

Consumer products are not inventoried if they are used in the workplace for the purpose intended and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended. CMS does bar-code consumer products if they are used in a commercial fashion. Commercial applications can be determined by the work area and the quantities in which the chemicals are found. (E.g. 12 cans of WD-40 in a shop area get inventoried while one can of WD-40 in an office does not)

In addition to the OSHA regulations for hazard communication, there are other regulations and guidelines, of which compliance is facilitated by an inventory system. Please read more about Regulations and Guidelines which drive the CMS.

The Memorandum of Agreement between EPA and DOE, March 23 1998 requires that we identify chemical materials in the Process Evaluation Work Plan to ensure research activities are evaluated for environmental, safety and health impacts. The CMS is used to help identify these chemical hazards.

To satisfy OSHA 29 CFR 1910.1020 "Access to Employee Exposure and Medical Records", the CMS is also used as a record which reveals the identity, as well as where and when a toxic substance or harmful physical agent was used. Records must be retained for at least 30 years.

The CMS is also used to satisfy DOE O 151.1 "Comprehensive Emergency Management System" , which states that Emergency planning shall include identification of hazards and threats.

Items the CMS REQUIRE to be Inventoried

Any, but not limited to, chemical containers that have a manufacture label which denote physical or health hazards, or whose MSDS denotes hazards, are included in the CMS inventory. In general, laboratory chemicals and reagents are inventoried even if the hazard is considered low.  Almost all chemicals received from chemical manufacturers such as Sigma-Aldrich, Fluka, Alfa Aesar, Fisher Scientific, Mallinckrodt Baker and Acros will be  included in the CMS inventory.

  • Abrasive Blasting Agents
  • Activated Charcoal
  • Alumina
  • Cements Powder Form (Establish as Static Inventory)
  • Chemicals Contained in Process, Storage, and Supply Tanks  (see section below)
  • Chemical Kits**
  • Chemicals or Toxins that are derived from plants or animals
  • Commercial Cleaners, Degreasers, Lubricants as Stock (Establish as Static Inventory)
  • Corrosive cleaning agents (e.g. strong base/acid solutions, RNASE away,etc.)
  • Degreasers
  • Desiccants
  • Dyes and Stains
  • Epoxy Resin/Hardener
  • Janitorial Stock Supplies (Establish as Static Inventory)
  • Laboratory Chemicals and Reagents (including Amino Acids, Sodium Chloride, Sucrose, Glycerin, Glycerol, Powdered Metals)
  • Compressed Gas Cylinders*
  • Laser Dyes and Solvents
  • Layout Fluids
  • Lecture Bottle Compressed Gas Cylinders (Bar Coded Individually)
  • Liquid Scintillation counting Cocktail
  • Metal Plating Solutions
  • Molecular Sieves
  • Oils, Lubricants and Greases including Vacuum Pump Fluid
  • Paints and Lacquers
  • Pesticides
  • Photographic Chemicals
  • Pool Chemicals
  • Propane Tanks (e.g. for fork lifts, BBQs, heaters, etc.)
  • Small Compressed Gas Cylinders
  • Small Propane Cylinders
  • Solvents
  • Spray Paint and Flammable Aerosols
  • Water Treatment Chemicals

* For Large compressed gas cylinders you may be able to use a static/revolving inventory due to their high turnover rate.  Fire suppression cylinder should be included.

 ** Chemicals with in a kit are usually not individually inventoried. They can be inventoried under the kit name.

Items the CMS MAY REQUIRE to be Inventoried

Chemicals that can be exempted from the CMS inventory are usually found in consumer quantities and used in a consumer fashion. The CMS drivers do not mandate an inventory for consumer use of chemicals. The list below lists items that may be exempted from the CMS inventory if the chemicals are normally available as a consumer product and are of a quantity that a consumer would use. The list below provides some examples of consumer products that can be excluded from the CMS Inventory. Next to each product is a quantity that in most cases will be considered a consumer quantity.

  • 5-Minute Epoxies and other Tube Glues (consumer quantity 1-2 per room/area)
  • 5 in 1 Oil (consumer quantity 1-2 per room/area)
  • PVC Pipe Primers and Cements (consumer quantity 1-2 per room/area)
  • Rubber Cement (consumer quantity 1-2 per room/area)
  • "ZEP"- and other cleaning type products (consumer quantity 1-2 per room/area)
  • Soldering Pastes and Fluxes (consumer quantity 1-2 per room/area)
  • WD-40 (consumer quantity 1-2 per room/area)

Items the CMS DO NOT REQUIRE to be Inventoried

Even though some items may not be entered into the CMS the user is still responsible to obtain current an MSDS for the product and to submit it to CMS for inclusion in the MSDS database.

  • Alkali Vapor Sources (Very small quantities)
  • Activated Charcoal in small pre-packaged laboratory scale cartridges
  • Batteries
  • Biological Material (e.g. plant or animal tissue, reproducing biological organisms, bacteria, viruses, fungi, or yeast)
  • Blood or Blood Products
  • Bloodborne Pathogen Kit
  • Buffer Solutions for Growth Media
  • Buffer Solutions for pH Probes
  • Calcium Chloride Ice/Snow Melt Products Working Quantities (Storage areas require static posting)
  • Cements Premixed Deliveries
  • Chemical Waste
  • Chemical containers with incomplete or illegible information
  • Chemical Spill Kits (includes wipes for chemical cleanup)
  • Consumer products when ordered/present in consumer quantities and used as appropriate
  • Custom DNA Sequencing
  • Empty Chemical Containers
  • Enzymes
  • Fire Extinguishers
  • First Aid Kit (HF Burn Kits are tracked by location)
  • Food or Food Additives (unless it will be used for R&D or operational purposes)
  • Gelatin
  • Growth Media
  • Hormones
  • Lead bricks, sheets, piping
  • Mineral Oil
  • Office Supplies (appropriate quantities for office administrative purposes)
  • Non-Hazardous Metals such as Foils, Bars, and Rods
  • Perlite for gardening/green house type work
  • Personal Items for Personal Use
  • Pharmaceuticals, Medication, including veterinary medicine when it is in solid, final form for direct administration to the patient (unless it will be used for R&D or operational purposes)
  • Photographic Film
  • Plasmids (when not combined with other hazardous chemicals)
  • Polymer Spheres (non-hazardous/low hazard or as non-hazardous suspensions)
  • Precious Metals (See Precious Metals Program)
  • Potting Soil and Mulch
  • Radiological Sources, Chemicals, and Waste
  • Sand/Polishing Paper, Buffing Compounds
  • Secondary Chemical Containers
  • Secondary Containers, Working Solutions, Dilutions
  • Small quantities (milligram or milliliter quantities) of sample materials and reagents brought to the NSLS for short duration experiments that leave the facility at the experiment conclusion. These sample materials and reagents must have a safety review and be documented on a Safety Approval Form or Set-up Laboratory Experiment Safety Review (LS-ESH-0069)
  • Solder
  • Special Nuclear Materials
  • Structural Material and Articles (example of Articles: beryllium tool, single crystal substrates, ammunition)
  • Synthetic Thermoplastic Polymer
  • Test strips (pH, Peroxide, Water Hardness, Iron, Phosphate, etc.)
  • Thermal Compounds available as a consummer product (e.g. for computers, silver based)
  • Water, Demineralized Water
  • Welding Rod

Tracking of Chemical Operations/Safety Equipment

In additional to chemicals being inventoried into  the CMS additional chemical operations and safety equipment may also be included.  The following is a list of chemical operations and safety equipment that CMS is presently tracking.

Chemical Process, Storage and Supply Tanks

In the past chemical tanks were allowed to be added to the CMS database but were not a mandatory requirement. In September 2014 a program was started to add chemical tank to the CMS database. By adding tanks to the CMS database the process tank volumes will now be included in area totals, the hazards of the chemicals will be included in chemical hazard summations, the hazards will be captured in the CMS Hazard Reports, the hazards will be inputted into the Hazard Validation Tool (HVT) and totals will be included in environmental reporting.  This project is expected to completed in FY 2018.

  • Chemical Tanks are defined as permanent process, storage and supply tanks containing chemicals in quantities greater than 55 gallons.
  • Chemical tanks will be added to the CMS database as a bar coded Non-Static inventory.  No bar code will be fixed to the tank and no chemical posting will be required.
  • The CMS Chemical Inventory Chemical Name entered into CMS for each tank will contain the words "Chemical Tank" or "Petroleum Tank" to help distinguish between laboratory chemicals and tanks. Unique identifiers such as Article XII tank numbers may also be used.
  • The maximum storage or operating level of the tank will be used as the volumn for the chemical in the tank.

 

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