Today most large organizations that must deal with hazardous materials follow a time-honored process for identifying critical compliance needs and spend the money necessary to make it work. However, committing this level of resources can be tough for smaller companies. The challenge is to effectively manage their entire chemical inventory to stay in compliance and avoid the dangers, fines and fees for noncompliance.
The big-company process starts with a sophisticated purchasing or procurement system, usually with a module that enables EH&S staff to review and approve all incoming hazardous items. Nothing arrives unnoticed. Next, some type of bar-code or RFID-tagged inventory management system tracks the chemical or product and records data on its location-specific usage. A sophisticated document and data management system that is tied into procurement and chemical tracking handles MSDSs. At the end of all this, the system generates and submits (usually electronically) compliance reports required by the EPA and local agencies. Then management plans are made or modified, staff are trained or re-trained and the company moves forward safely until the next monthly review period.
This Utopian view of compliance management has been practiced for so long in so many high-profile companies that it has become the de facto process for managing compliance. In the world most EH&S managers live in, however, the tools and resources just described do not exist. Their companies are forced to manage HazMat with limited budgets, staff, tools and systems.
Today companies need to create a new framework that takes into account the whole picture of HazMat compliance and its effect on the organization. They must set their sights and marshal resources in one key area — an accurate, up-to-date HazMat inventory. This inventory becomes the foundation upon which the company manages other critical data and turns those data into knowledge on the hazards present in each of its facilities. This knowledge, when applied on a geographical, functional and hierarchical level within an organization, helps EH&S staff make better business decisions to reduce risk, cost and liability.
A good HazMat inventory improves the bottom line and its basics are easy to understand and implement.
How often. The frequency with which an inventory should be reviewed will depend on the size of the business and number of locations/departments that contain hazardous materials, the sophistication of purchasing and approval processes, and the expected turnover of materials. In an ideal world, the person responsible for the inventory at a specific location/department should take a master inventory at least annually. Each new purchase or disposal should be tracked and the inventory modified throughout the year. EH&S supervisors at each facility should have pre-purchase review and approval rights for any new product or chemical. Inventories from separate locations within an organization should be rolled up into a corporate-level inventory for analysis and to ensure consistency in process and purchasing.
What data to record. At a minimum, record the name and location of each product or chemical, its maker and any part number or description assigned by that manufacturer, as well as the container size and quantity on hand. These basic data will enable EH&S staff to match the item to an MSDS, which can provide all the critical data needed for reporting and exposures.
Problems. The staff conducting the inventory may come across unlabeled, illegible and inadequately labeled secondary containers. Record these items in a separate “discrepancy” document, with their specific location and description; then physically flag each item with stickers, labels or string that is easily visible. Review the discrepancy document at the completion of the inventory to determine appropriate actions such as re-identifying products with appropriate labels or removing products from the facility.
Completing the picture
Once you obtain an accurate inventory, it is possible to begin to add value to each record by associating other data, documents or records with each item and supporting this information with on-site EH&S staff or outside resources to assist employees in use and interpretation. This is an important step in seeing the whole picture.
MSDS. Associate each item in the inventory with a manufacturer-specific MSDS and make the inventory list and MSDS easily accessible by employees. The MSDS provides vital information about exposures and the specific characteristics of the chemicals in a product or mixture. Many companies keep the inventory list and corresponding MSDSs in a file — hard copy or electronic — forever to meet OSHA’s exposure record-keeping requirements. A process for obtaining new or updated MSDSs will be required as products change or MSDSs go out of date.
Classification. Assign each item in the inventory a National Fire Protection Agency (NFPA) and Hazardous Materials Identification System (HMIS) rating and classify them for common modes of transport. NFPA is a system for identifying the hazards of a chemical that was developed with the needs of fire protection agencies in mind. The local fire department may require this information be provided along with the chemical inventory. The HMIS rating is a labeling system developed by the National Paint and Coating Association to help quickly identify the hazards associated with a given material. Inventory items should also receive a classification based on how the item is shipped, whether by ground, air or sea. Each mode requires a different classification based on the size and quantity of the chemicals being transported.
Shipping. Each item that is placed on a truck, boat, rail car or plane requires appropriate classification, packaging, marking, labeling, and placarding. Classification involves identifying the transportation hazards associated with your inventory in accordance with 49 CFR HMR, IATA or IMDG code requirements, depending on the mode of transportation. Instructions also will be needed on how to properly package different types of hazardous materials, what marking and labels go on the package, which placards appear on the vehicle, how to complete the required shipping documentation and who to call in a transport emergency.