THE IMPORTANCE OF CHEMICAL INVENTORY LISTS 

Inventories must be maintained for all hazardous chemicals. Hazardous chemicals include chemicals for which there is statistically significant evidence of health effects following exposure as well as flammable and explosive substances.

HAZARDOUS CHEMICAL MANAGEMENT

OSHA requires all businesses that use, store, or transport hazardous chemicals to keep an inventory list. They also require the designation of one or more employees to manage this list.

The OSHA Hazard Communication Standard requires chemical manufacturers, distributors, and importers to communicate the hazards of chemical products to users by providing Safety Data Sheets (SDSs; formerly known as Material Safety Data Sheets or MSDSs). SDSs for all chemical in-use and stored in the workplace must be readily accessible to all employees at all times. These SDSs are designed to provide essential hazard and protective measures information to chemical users and emergency responders. Keep in mind that any accident or incident involving a chemical will require a SDS being provided to emergency personnel and to the attending physician so proper treatment can be administered.

CHEMICALS THAT NEED BE LISTED ON CHEMICAL INVENTORY 

• Aerosol products
• Combustibles and flammables
  
• Controlled substances regulated by the Drug Enforcement Agency
• Compressed gases
  
• Corrosives
• Organic peroxides
  
• Poisons that aren’t already in one of the other categories
• Oxidizers

CHEMICAL INVENTORY REQUIREMENTS

The Toxic Substances Control Act (TSCA) established the requirements for chemical inventory lists. These lists include every chemical substance made, processed, or imported into the United States.

The Environmental Protection Agency (EPA) posts an update to this inventory on a bi-annual basis. 

This inventory includes 86,557 chemicals. Only 41,864 of the chemicals on this list are actively used in the United States at this time.

The TSCA Inventory updates describe new chemical substance additions. It also provides the current commercial regulatory flags and activity data. One example includes exemptions for polymers.

The following describes the minimum data that chemical inventory lists must include.

• Identification marker
• The location of the file for the corresponding SDS
• Name of the product
• Manufacturer’s name
• The address including city and state for the manufacturer
• The telephone and emergency number for the manufacturer

You don’t need to list non-hazardous materials, temporary solutions, or consumer products. Biohazardous or radioactive materials need their own separate inventory program.

BENEFITS OF CHEMICAL INVENTORY 

• Save money and space by reducing or completely eliminating unnecessary purchases
• Save time by maintaining stock at an appropriate level (Don’t run out, but don’t buy too much)
• Increase efficiency by making chemicals easy to locate
• Know when to remove old or expired chemicals
• Identify chemicals with specific shelf life and specific storage requirements
• Get your lab up and running again quickly after an emergency.  By helping emergency response personnel, including the Fire Department, make crucial decisions about your lab based on chemical information, delays in response to serious spills or fires will be minimized.
  

OPTIMIZE HAZARD COMMUNICATION PLAN AND CHEMICAL SAFETY PROCEDURES IN INVENTORY PROCESS

• Review the chemical hazards in your workplace.
• Identify concerns to determine if the chemical should be modified or substituted.
• Minimize the amounts and hazards of the chemicals in the workplace.
• Take the time to clean out surplus and waste chemicals and containers.
• Analyze chemical usage patterns, age, shelf life, and cost.

Chemical inventory can be as simple as a document, spreadsheet, or you can purchase professional software or contract with online inventory maintenance services. 

FINAL WORD

To some, chemical inventory regulation may seem like just another overreach and impediment to business success. Taking a deeper look, there are potentially cost savings and efficiency increases to be had.