17 Jun Chemical Inventory Lists

Chemical Inventory Lists

An accurate chemical inventory is an important part of an effective Hazard Communication Program. Employers must identify hazardous chemicals present in the workplace and maintain information that allows employees to locate the appropriate Safety Data Sheet (SDS) and understand the hazards associated with those chemicals.

A current chemical inventory also assists supervisors, emergency responders, and safety personnel in identifying chemical hazards, evaluating storage conditions, planning emergency response, and managing regulatory requirements.

Purpose of the Chemical Inventory

The chemical inventory should provide employees with a practical way to identify hazardous chemicals used or stored in their work area and locate the corresponding SDS.

An effective inventory can help:

• Identify chemical health and physical hazards;
• Provide quick access to applicable SDSs;
• Determine required PPE and exposure controls;
• Support spill, fire, and emergency-response planning;
• Identify incompatible chemical storage;
• Track chemical locations and quantities;
• Identify outdated, damaged, or unnecessary chemicals; and
• Support applicable regulatory reporting requirements.

What Should Be Included

The inventory should identify hazardous chemicals known to be present in the workplace. Depending on the operation, these may include:

• Aerosols;
• Adhesives, paints, coatings, and solvents;
• Cleaning and degreasing chemicals;
• Compressed gases;
• Corrosives;
• Flammable liquids and other flammable materials;
• Combustible materials presenting chemical hazards;
• Oxidizers;
• Organic peroxides;
• Pesticides and other agricultural chemicals;
• Reactive chemicals;
• Toxic materials; and
• Other hazardous chemicals for which an SDS is required.

Do not limit the inventory to chemicals considered particularly dangerous. If a hazardous chemical is covered by the company’s Hazard Communication Program, it should be appropriately identified.

Recommended Inventory Information

At a minimum, the inventory should clearly identify each hazardous chemical or product and allow employees to locate its SDS.

For effective chemical management, the inventory should include, as applicable:

• Product or chemical name;
• Product identifier corresponding to the SDS;
• Manufacturer or supplier;
• SDS availability and revision date;
• Chemical location or work area;
• Container type and size;
• Approximate quantity;
• Date received or added to inventory; and
• Any applicable storage or hazard classification.

Manufacturer addresses and telephone numbers generally do not need to be duplicated on the inventory when that information is readily available on the corresponding SDS.

Safety Data Sheets

A current SDS should be maintained for each hazardous chemical covered by the Hazard Communication Program.

Employees shall:

• Know how to access SDSs during their work shift;
• Be able to match the chemical or product with the correct SDS;
• Review the SDS before using unfamiliar hazardous chemicals; and
• Notify their supervisor when an SDS is missing or cannot be accessed.

SDSs may be maintained electronically provided employees have immediate access during their work shift and there are no barriers to obtaining the information when needed. Appropriate backup access should be considered in case electronic systems become unavailable.

Updating the Inventory

Chemical inventories should be maintained as an ongoing process rather than completed only during an annual review.

The inventory should be reviewed and updated when:

• A new hazardous chemical is brought into the workplace;
• A chemical is permanently removed;
• Products are relocated to another work area;
• Significant quantities change;
• A product is discontinued or replaced;
• Updated hazard information becomes available; or
• Periodic inspections identify discrepancies.

Before a new hazardous chemical is introduced, the appropriate SDS should be obtained and employees should receive any necessary hazard communication training.

Conducting a Physical Inventory

Periodic physical inventories can verify that workplace conditions match existing records.

During the inventory:

• Inspect chemical containers and storage areas.
• Verify that containers are properly labeled.
• Match products to their corresponding SDSs.
• Identify missing or outdated SDSs.
• Record chemical storage locations.
• Identify damaged, leaking, deteriorated, or unlabeled containers.
• Check expiration or shelf-life information where applicable.
• Identify incompatible chemicals stored together.
• Determine whether unnecessary quantities are being accumulated.
• Arrange for proper disposal of unwanted chemicals in accordance with applicable requirements.

Never dispose of an unknown or hazardous chemical until its identity and proper disposal method have been determined.

Materials That May Be Exempt

Not every substance present at a workplace is necessarily subject to OSHA’s Hazard Communication inventory and SDS requirements. Certain materials may qualify for exemptions or be regulated under other requirements.

Examples may include:

• Certain consumer products used in the workplace in the same manner and frequency as normal consumer use;
• Articles that meet OSHA’s definition of an article;
• Certain foods, drugs, cosmetics, or alcoholic beverages;
• Hazardous waste subject to applicable waste regulations; and
• Certain biological or radioactive materials regulated under other requirements.

Do not automatically exclude a product simply because it is commonly available to consumers. The manner, duration, and frequency of workplace use can affect whether an exemption applies.

Chemical Storage Review

The inventory process provides an opportunity to evaluate chemical storage practices.

Check that:

• Flammable materials are stored appropriately.
• Incompatible chemicals are properly separated.
• Containers remain closed when not in use.
• Secondary containers are appropriately labeled.
• Compressed-gas cylinders are properly stored and secured.
• Corrosive and reactive chemicals are stored according to their hazards.
• Storage areas have appropriate ventilation and spill-control provisions.
• Emergency equipment is available where required.

The SDS should be consulted when determining chemical incompatibilities and storage requirements.

Inventory Management

The chemical inventory may be maintained using a:

• Written list;
• Spreadsheet;
• Database;
• Barcode or QR-code system; or
• Commercial chemical-management system.

The complexity of the system should reflect the number and types of chemicals used. Regardless of the method, the information must remain accurate, understandable, and readily accessible to those who need it.

Employee Responsibilities

Employees shall:

• Follow established procedures for bringing chemicals onto the worksite.
• Never use unidentified or improperly labeled chemicals.
• Ensure secondary containers are properly identified as required.
• Report missing or damaged labels.
• Report chemicals that are not included in the established inventory.
• Know how to access SDS information.
• Follow required chemical handling, storage, PPE, and disposal procedures.

Employees should not bring hazardous chemicals onto a worksite without authorization and appropriate review.

Remember

A chemical inventory is more than a list of products. It is a tool for managing chemical hazards. Know what hazardous chemicals are present, where they are located, how to find their SDSs, and keep the inventory current as workplace chemicals change.