How are you managing the hazardous materials (HazMat) used, stored, and produced in your facility? That is the question. Unless a facility manager has a multimillion-dollar budget and works in an organization with a cultural commitment to safety and risk management, they're probably managing ever-more-complex rules and requirements with smaller budgets, fewer resources, and less organizational commitment than the year before.
In today's perpetually resource-constrained operating environments, it is possible to manage the costs associated with HazMat management without compromising regulatory compliance, environmental performance, and workers' health and safety. At the heart of any procedural framework for managing environmental compliance is an accurate inventory of the HazMat present the facility.
By developing and then building on an accurate HazMat inventory, one can leverage the knowledge gleaned from inventory to make better day-to-day decisions. In doing so, it's possible to boost worker safety, safeguard the community, reduce waste and costs, and ensure more timely and effective environmental compliance.
An accurate, up-to-date inventory of the pure chemicals, raw materials, intermediates and finished products, fuels, solvents, maintenance and cleaning supplies is the foundation for managing other critical data and turning that data into knowledge on the hazards present in facilities.
This knowledge, when applied on geographical, functional, and hierarchal levels within an organization, allows one to make better business decisions. An inventory allows for: the implementation of specific processes across multiple locations; assignment of responsibility to appropriate individuals who can identify the hazards associated with products used in the workplace; and, tightened purchasing policies and procedures so the organization can control which chemicals are coming into each facility helps to reduce risk, cost, and liability. A good HazMat inventory will contribute to the bottom line, and the basics are easy to understand and implement.
The frequency with which to review the inventory of chemicals and other HazMat depends on the size of the business, the number of locations/departments that handle hazardous materials, the sophistication of purchasing and approval processes, and the expected turnover of chemicals and other HazMats. In an ideal world, a master inventory should be taken at least annually by the person responsible for the inventory in a specific location/department, and the inventory should be modified throughout the year with each new purchase or disposal.
To start an inventory program, conduct a full inventory at the beginning of the fiscal year. This single step will improve the quality of an environmental health and safety (EH&S) programs and drive down costs with higher compliance because it will provide a clear picture of what products actually exist - so that if an inspection occurred, there would be no surprises. A follow-up inventory should then be initiated at the beginning of the next fiscal year to validate assumptions on chemical usage and turnover. This "refresher" inventory should include one full inventory from a "bellwether" site within your organization and a "what's new" report from all other locations.
If there is more than a 20 per cent change, either in number of hazardous chemicals and products or in total pounds of HazMat substances from the previous year, you should consider conducting another full inventory at every site.
WHAT TO LOOK FOR
Ideally, the staff conducting an inventory of HazMat will be trained EH&S professionals who can easily identify the products and chemicals that should be represented there. If people with appropriate background are scarce in your organization, non-EH&S staff can be trained to read product labels as a method of HazMat identification. Manufacturers' labeling on industrial reagents and hazardous consumer products should contain identifiable hazard warnings; however, inner packaging of some materials (solder rolls or copier chemicals, for example) may not carry adequate hazard warnings.
WHAT TO RECORD
At a minimum, each product or chemical record should include: the location of the material; the container size; the quantity of the material on hand; the name of the product or chemical; the name of the company that made the product or chemical; and, any part number or description assigned by the manufacturer. This basic information will allow one to match the item to a Material Safety Data Sheet (MSDS), which can provide data needed for reporting and critical exposures.
The staff conducting the inventory may come across unlabeled containers or containers with illegible secondary labels. Record these items in a separate discrepancy document with their specific location and description, then physically flag the items themselves with stickers, labels, or string that is easily visible. Review the discrepancy document at the completion of the inventory process to determine appropriate actions, such as re-identifying products with appropriate labels and/or removing the products from the facility.
Once an inventory is complete, one can begin to add value to each record by associating other data, documents, or records with each inventory 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.
It's important to associate each item in the inventory with a manufacturer-specific MSDS and keep the inventory list and MSDSs available for easy access by employees. The MSDS provides vital information for exposures and the specific characteristics of the chemicals in a product or mixture. As products change, or MSDSs becomes outdated, implement a process for acquiring new or updated MSDSs.
In addition, inventory items should be classified based on how the item is shipped, whether by ground, air, or vessel. There are mode-specific requirements based on the size and quantity of the chemicals being transported. Hazardous material products, or "dangerous goods" as they are known in transportation, that you put on a truck, boat, railcar, or plane will need to have several pieces of data associated with it. When a dangerous good is prepared for transport, it must be appropriately classified, packaged, marked, labeled, and documented.
THE BOTTOM LINE
By focusing efforts on gathering and analyzing the right information, any organization can significantly streamline costs incurred to protect employees and manage regulatory compliance requirements, as well as the costs associated with acquiring, tracking, storing, shipping, and disposing of hazardous materials that a facility handles, stores, uses, and produces.
Jess Kraus is founder of 3E Company, based in Carlsbad, CA. For further information, e-mail firstname.lastname@example.org.