In March 2014 CSU was inspected by Department of Homeland Security (DHS) and they noted specifically that compliance with applicable DHS regulations requires that we have and maintain a complete inventory of Chemicals of Interest, and that this must be met in a timely fashion. Strict compliance with DHS regulations is required, and the potential penalties for non-compliance can be severe. Environmental Health Services is committed to assisting all departments and PIs with compliance and to continuously improving the tools and methods for inventorying all chemicals on CSU campuses. The ultimate responsibility for compliance is shared by everyone who uses chemicals in their academic and research programs.
CSU maintains an online chemical inventory to facilitate federal and state regulatory reporting (ex. Department of Homeland Security; EPA, Right To Know, etc.). In addition, provides EHS with lab specific chemical hazard information and this in-turn helps EHS provide site specific training and provides local emergency response crews information regarding possible hazards.
Why are we conducting this inventory?
This inventory was initially undertaken in response to regulations from the Department of Homeland Security (DHS) regarding “Chemicals of Interest” (COIs). Although only a small percentage of all chemicals on campus qualify for COI status, performing a complete chemical inventory has proved a better and more efficient way for us to get an accurate snapshot of the number and amount of COIs, locate where they are being stored and used on campus, and address appropriate security measures for these substances. DHS auditors will return to campus in July 2014 to assess our progress on the COI inventory.
How do we know if we our COIs are below the threshold levels set by DHS?
A baseline inventory is the starting point to addressing this question. By the end of September 2014, CSU will have set this baseline through our chemical inventory program. Obviously, the next step in this process will be to maintain and update the chemical database inventory in a timely manner. Although the details of the maintenance plan have not been fully detailed, campus stakeholders will be involved in determining next steps and rational approaches to the inventory maintenance.
Does this mean I will have to log in to a database every time I use a chemical?
No. EHS does NOT expect researchers to constantly update quantities in the database each time a chemical is used. In most cases, the DHS requirements suggest the database should be updated when the original chemical containers are emptied or relocated. Again, details of this maintenance program will be determined in the coming months by the Chemical Safety and Compliance Committee (CSCC).
What’s the Chemical Safety and Compliance Committee?
The next stage of the inventory process is to determine how best to maintain the inventory, once it is complete. To that end, the VPR , VPUO, and OPC have teamed together to build a faculty-EHS partnership to address both chemical compliance issues (e.g. DHS regulations) and chemical safety concerns. This jointly created Chemical Safety and Compliance Committee (CSCC) will comprise EHS staff, faculty members from across the University, and other relevant stakeholders and subject matter experts. The committee will be charged with developing a chemical inventory maintenance plan and relevant chemical compliance/safety policies and guidelines for the campus. Over the next few months, look for additional information and opportunities for feedback and input on these activities coming from the CSCC. After the inventory is complete in a lab, storage or other area, the Chemical Management Online Portal Guide at http://www.ehs.colostate.edu/WChemMgt/ will be the place to go for information on the occupants’ responsibilities for maintaining the inventory.
What happens when I order a new chemical?
Currently, the program is set up to bar code the vast majority (>90%) of manufacturer's containers at Central Receiving. Users can then access the online inventory system to record the location of the chemical container upon receipt in the lab. Although not every chemical that comes to campus is successfully identified at Central Receiving, we are working on additional ways to ensure maintaining the inventory will have minimal impact on researchers’ time.
As a researcher, will I be able to access the chemical database?
Yes. EHS and the CSCC will work on logistics and best practices for use and maintenance of the chemical database. Ideally, this could be extremely valuable in those situations wherein only a small amount of a reagent is needed or when a time-sensitive experiment requires a chemical not available locally (i.e. within that lab). Creating such mechanisms for sharing and relocating chemical resources is a key element of the long-term plan for CSU’s chemical inventory. What are some of the other benefits of the inventory program?
Some extremely positive consequences have resulted from the chemical inventory initiative. These include
- The inventory process has provided an easy method to determine appropriate construction standards for areas that use chemicals. Building standards require the volume by chemical category (toxic, flammable, corrosive, etc.) be known so that appropriate controls can be in place during construction or renovation. The chemical inventory database will allow EHS to easily collect and report this information. This is invaluable for planning for new or renovated research spaces (e.g. Scott Engineering and Animal Sciences).
- The chemical inventory database will provide EHS with the capability to inform emergency workers of chemical risks prior to entering the building. Fire department personnel require the University provide an inventory at their request and the database will allow this to happen in an efficient and rapid manner. Such inventory information is also critical for insurance coverage when chemical inventory is lost.