In the world of environmental regulation, there are few things more mundane that the thought of the chemical inventory. While the concept is fairly simple, i.e. there should be a listing of the amounts and location of the chemicals that are maintained on-site. The reality is quite different. Even a facility as simple as a pipeline terminal can have multiple chemicals on-site in containers ranging from small bottles of white board cleaner to the storage tanks that can be seen from the highway. And, then there is the underlying factor, of why should I care and just how accurate does it have to be.
The first answer is you have to care. Each year facilities are required to provide a chemical inventory to the emergency planning agencies (local fire departments, local emergency planning committees, etc.). This of course is related to the regulations under Community-Right-to-Know and the inventory is affectionately known as the Tier II report. But, are you aware that there are reporting requirements for new chemicals that come on-site? And, tracking of chemical changes are not trivial. Additionally, there are local jurisdiction requirements such as California’s Proposition 65 posting requirements if certain chemicals can be found at your particular location. The key for this reporting is to provide some level of accountability to the community, and for help in pre-planning if something should go awry.
For the Tier II reporting, the accuracy that is required is dependent upon the amount and the hazard characteristics of the material being stored. Thus, for extremely hazardous substances; the accuracy required is greater than that of a simple flammable material. However, the accuracy of the amount stored may become extremely important bases upon how the material is viewed under a variety of other regulations – is it regulated by Homeland Security, does it carry a particular biohazard classification, etc.? For these materials, you maybe required to account for milligrams of the material and have special tracking and accountability requirements.
How is Chemical Inventory Information Used?
In addition to just knowing how much of a material is located at a site at any given time, chemical inventory information is used by other regulations, such as the Toxics Substance Control Act, and Toxics Release Inventory Reporting. So not only is the overall quantity and storage information important, but how the material is used, processed, reacted, and controlled is also necessary. Hence, understanding of chemical tracking and overall management is required, even for process intermediates that may or may not be stored. And, this doesn’t even take into account of the business type information that the accountants are trying to deal with –custody transfer of intermediates and products, and the inventory tax calculations.
Considerations for the Environmental/Safety Professional
The environmental/safety professional needs to have a good understanding of how the site tracks and maintains the chemical inventory. There needs to be an understanding of the labeling, storage, and emergency planning requirements associated with each type of chemical present at the site. Thus, the environmental/safety professional needs to be involved in decisions associated with how chemicals are purchased, how quantities are tracked, how materials are stored, and the rationale for why the material is needed. As these items impact which regulations the site may become subject, and how the material is reported under the various regulations.
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