August Mack Newsletter | September, 2017

A Good Chemical Inventory is a Must for Regulatory Management
by Mike Ogburn

Industrial facilities should always have a thorough chemical inventory system to be able to comply with the myriad of regulatory standards. This all starts off by complying with the Occupational Safety and Health Administration (OSHA) hazard communication standard (29 CFR 1910.1200). You can only comply with this regulatory standard if you have an accurate accounting of the chemicals utilized in the facility. But this is just the beginning of the many regulations which require a complete understanding of chemicals stored and used at a facility. Both safety (OSHA) and environmental (US EPA) regulations have many standards related to chemicals. In addition, many potential compliance plans and reports require utilizing this data so regulatory plans can be developed and implemented, or regulatory reports can be prepared and submitted. Often it is the type and quantity of a regulated chemical that will determine reporting responsibilities.

As simple as this may sound to some, it is quite often an overlooked task because it can be so burdensome to complete. The reality is, over half the industrial facilities I’ve audited over the past fifteen years did not have recent, complete, or up-to-date accounting of all the chemicals on-site. Many facilities have improved in recent years with the emphasis and awareness of the changes related to implementation of the Globally Harmonized System (GHS) standard.  

In addition to complying with the GHS standard and hazard communication standard, many other safety and environmental regulations will require an accurate chemical inventory. When it comes time to complete the Tier Two and the Toxic Release Inventory (Form R’s) reports, knowing what is on-site, quantities, and amount utilized all become necessary to adequately prepare these reports. And if the facility is subject to air reporting, it may be necessary to utilize the Safety Data Sheet (SDS) information to determine quantity of volatile organic compounds (VOCs) and other constituents.

The benefits of performing a chemical inventory allow you to remedy the problems that show up as a result of the inventory process. Typical outcomes usually include: (1) discovering chemicals you didn’t know you had, (2) finding “unknown” chemicals, (3) identifying outdated chemicals, and (4) finding many chemicals that may not have an associated SDS. There is not necessarily one right way to perform a chemical inventory but a consistent, systematic approach to managing your chemicals always starts with a chemical inventory. 


Mike Ogburn is the eCAP® Program Development Manager with August Mack Environmental, Inc. in the Indianapolis, Indiana office. He has more than 25 years experience and is responsible for designing customer specific web-based regulated chemical tracking systems for industrial manufacturers. Mike also manages August Mack`s web-based Safety Data Sheet module and has detailed knowledge of Emergency Planning & Community Right-to-know Act reporting (EPCRA), SDS management, chemical inventory audits, environmental auditing and environmental management systems (EMS). He can be reached at 317.916.3111 or via e-mail at mogburn@augustmack.com.

 


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