EH&S Managers, lab managers, facilities staff, materials managers and more often balance multiple priority projects and space planning or inventory control conflicts that can make chemical inventory management challenging to maintain. In some cases, sites might even struggle to complete a baseline inventory in full or collect respective Safety Data Sheets (SDSs) which presents a compliance and safety risk to employees and the community. By implementing a strong chemical management program, these risks can be effectively managed, and time spent on updates can be minimized.
Why do I need an inventory and HAZCOM program?
Let’s start with the basics: why does a site need a chemical inventory under the HAZCOM standard? Because it’s required? Well sure. OSHA’s Hazard Communication Standard (29 CFR 1910.1200) outlines the need for a chemical inventory, SDSs and employee training. This standard is more commonly referred to as “Employee Right to Know” as it was put into law in order to ensure employers inform and employees understand the hazards and exposure potentials in their work environment.
Just as you would not want or allow your child to play under a kitchen sink of unlabeled cleaning supply bottles, so too should an employer not want or allow their employees or emergency responders to work with unknowns. If you don’t know what you have on site, how do you properly train employees? How do you ensure the properly labeling is met? How do you complete regulatory reports such as Community Right to Know (CRTK)? And how do you communicate all your risks to local emergency responders?
Having a complete chemical inventory is the stepping stone for having a complete and sustainable site-specific HAZCOM program.
How do I manage my inventory?
Spelling out roles and responsibilities in your hazard communication plan is key to your success. If your material management department is responsible for updating and maintaining the SDS binders because they receive items, then be sure to include them in your plan. Similarly, if the purchasing department is the gatekeeper for new chemical requests, make sure their roles and responsibilities are clearly defined. Following up a written HAZCOM program with training for all employees will lead to better employee understanding of your HAZCOM program, their respective roles and responsibilities and hazards/mitigations in their work environment. Understanding drives accountability which drives ownership of the program and a sustainable system.
Remember though, no matter the number or checks or having a seemingly flawless system, it is important to perform an audit of your program at least annually to capture any failures and create corrective action plans. This annual review should look at your written program, housekeeping and labeling issues and update your chemical inventory and SDS binders as needed.
How can EOI help?
Whether you need a full program overhaul or just some SDS updates, EOI can help with all your chemical inventory and HAZCOM needs.
Please refer to the list of services below and visit us at eoiconsultinggroup.com!
Chemical Inventory, SDS Management/Maintenance and Training Offerings:
Chemical inventory completion:
- Initial site survey/walk through and inventory collection
- Initial SDS file pull and entry into online database or file folder
Chemical Inventory Maintenance:
- Complete annual refresher inventory
- Update SDS data with most recent version
- HAZCOM Program Writing
- Site Specific HAZCOM Training
- Labeling inspection with corrective action findings
- Custom label solutions