The development of and maintenance of an accurate chemical inventory [xls] not only facilitate smooth operations in a laboratory, it is also required by the Occupational Health and Safety regulation 29 CFR 1910.1200, also known as the OSHA Hazard Communication Standard. Ready access to safety data sheets of each hazardous chemical in the workplace is also an essential requirement of this standard.
Section 1910.1200(a)(2) of the OSHA Hazard Communication Standard states that “This occupational safety and health standard is intended to address comprehensively the issue of classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, and to preempt any legislative or regulatory enactments of a state, or political subdivision of a state, pertaining to this subject. Classifying the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures”.
The OSHA Hazard Communication Standard requires chemical manufacturers, distributors, and importers to communicate the hazards of chemical products to users by providing Safety Data Sheets (SDSs; formerly known as Material Safety Data Sheets or MSDSs). SDSs for all chemical in-use and stored in the workplace must be readily accessible to all employees at all times. These SDSs are designed to provide essential hazard and protective measures information to chemical users and emergency responders. Keep in mind that any accident or incident involving a chemical will require a SDS being provided to emergency personnel and to the attending physician so proper treatment can be administered.
To develop and maintain your lab chemical inventory:
- Download the chemical inventory [xls] template
- Using the template, enter the minimum information required: chemical name, CAS# if available (some proprietary mixtures may not have it) and amount (quantity and unit)
- Update as new chemicals come in or as chemicals are used or discarded
To maintain ready access to safety data sheets:
Option 1. Maintain printed copies of SDS for ALL chemicals stored and/or used in the lab in a binder.
- Upon receipt of a chemical shipment, take the enclosed SDS and place in a SDS binder. If no SDS is enclosed, visit the website of the manufacturer and print the SDS for the chemical received. Arrange SDS alphabetically according to chemical name.
- Place tabs for each letter of the alphabet to facilitate SDS search in the binder.
Indicate the location of SDS binder in Appendix V of the Chemical Hygiene Plan.
- Place SDS binder in a work area accessible to all lab personnel at all times.
- In case of an accident involving a chemical, provide the SDS of that chemical to the emergency responder and the attending physician.
Option 2. Maintain printed SDS for high hazard chemicals only. Maintain electronic access to SDS for all other low to moderate hazard chemicals.
In general, high hazard chemicals are classified into Category 1 or 2 based on the Globally Harmonized System for hazard classification and labeling of chemicals for the following hazard classes:
Acute Toxicity, Carcinogen, Mutagenicity, Reproductive Toxicity, Respiratory Sensitizer, Target Organ Toxicity, Aspiration Toxicity, Pyrophorics, Flammables (liquids; if used in large amounts or in combination with heat or open flame), Flammables (gases), Emits Flammable Gas, Self-reactives, Self-heating, Organic Peroxides, Skin Corrosion or Burns, Eye Damage, Explosives and Oxidizers.
If a chemical is classified into Category 3 or 4, consult with EH&S to determine if chemical is considered highly hazardous.
2.1. See Option 1 to maintain printed copies of SDS of high hazard chemicals.
2.2. For SDS of low to moderate hazard chemicals, describe the procedure on how to access SDS electronically in Appendix V of the Chemical Hygiene Plan . Specify the web link (s), how to perform SDS search for a specific chemical and how to print the SDS if requested (i.e., by an emergency responder during a release incident or an attending physician during an exposure incident).
2.3. Train all lab personnel on the procedure described in 2.2.
2.4. Specify a back-up source of the electronic SDS referenced in 2.2 in case electricity goes out or if the web link becomes unavailable. For example, maintain a CD that contains all the pdf files of SDS in 2.2 that can be accessed using a battery powered laptop.