Chemical inventories are the backbone of a good safety data sheet (SDS) management program. Without an accurate chemical inventory, you potentially may face multiple downstream issues in your environmental, health and safety initiatives. You expose yourself to hazard communication violations by not having an SDS for every hazardous material on site, you may not be able to prepare critical regulatory reports like Tier II and you’re not providing the safest work environment for your employees.
We’ll provide some guidance on the best ways to conduct a chemical inventory later, but let’s start at the end and ask: How do you measure the results of a chemical inventory? One way is to “score” your chemical inventory by comparing your physical count to the virtual count represented in your SDS management system. A chemical inventory score is a measurement comparing the number of materials found in an on-site inventory, sometimes called an OSI, to the number of materials in your SDS collection. It’s a good measurement of how effective your SDS management, chemical approval and waste disposal systems are.
The perfect score is 100%, which would mean that every chemical that you found in your inventory exists in your SDS system. However, that’s not likely or even achievable in a dynamic workplace environment that many of work in. Materials can move, be added or disposed on a weekly, or even daily basis. In a typical industrial environment, the score is much lower, sometimes in the 50s, if a business has not kept up with their chemical inventories or the SDS management system has not been properly maintained.
The Chemical Inventory Snapshot
A chemical inventory snapshot presents a summary of the on-site chemical inventory results and reconciles actual counts to what is recorded in your chemical management system. The chemicals in your inventory can have one of 3 states: 1) new materials found that don’t already exist in your SDS system, 2) materials found that match directly to your chemical collection or 3) materials that don’t exist in your collection but exist in your vendor’s global SDS library. Additionally, a fourth category exists for materials not found in the inventory but exist in your chemical records. Let’s review each category in more detail.
New Chemicals Found – new chemicals found represent materials that exist in your facility, but don’t have an SDS in your current system. These represent potential compliance violations until the SDS is added to your system.
Chemical Matches To SDS Collection – the material found matches a chemical in your specific SDS collection, which is the ideal situation. You’re good to go here.
Chemical Matches To Global SDS Library – the material found isn’t in your specific chemical collection, but the SDS is available in your provider’s “global library” of SDS sheets. In this case, you just add or associate the right SDS to what was inventoried in your chemical collection. Many software systems can do this automatically.
Chemicals Not Found – in this case, you have a chemical in your collection, but no matching chemical was actually inventoried. In this case, there are no compliance issues, so there is no risk there, but you may be paying extra for your provider to manage a chemical that you’re currently not using. Also, this could impact your regulatory reporting where you might be over-reporting chemicals that don’t actually exist in your facilities.
The Importance of Chemical Inventories
So, why are onsite chemical inventories important? There are several reasons, but let’s focus on the top three:
- Worker Safety – first and foremost, by conducting a thorough and accurate chemical inventory, you make your workers and facilities safer. You identify the nature and quantity of hazardous materials existing at your facility. Not only does this identify what’s hazardous and what’s not, but it can also identify potential hazards where conflicting materials may be stored too close together. Additionally, it can help you identify additional safety precautions that workers in a particular location might want to take based on the chemicals that are present.
- SDS Management and HazCom Compliance – the second benefit of an OSI is that you can reconcile actual hazardous material counts to your SDS management records, or what you think you have. From the inventory, you can build out an accurate SDS collection and provide that to meet internal safety objectives and OSHA hazard communication compliance.
- Regulatory Reporting – if you hold or use certain quantities of materials with certain hazardous ingredients, you may be subject to federal and/or state regulatory reporting including Tier II, CFATS, Form R, etc. This regulatory reporting is all based on detailed records of what you have, don’t have, or have used. Oftentimes, the only way to get this information is to perform an OSI. Having an accurate count is important because you don’t want to over-report or under-report – either situation can present problems for business.
Tips and Tricks for Inventory Success
Here are some tips to run a successful inventory and raise your chemical inventory score. First, get your house in order – tidy up, dispose of old materials that are no longer in use or needed. Second, have an accurate “map” of where your chemicals are stored. Defining and assigning chemicals to facilities, storage areas, and sub-locations is critical to achieving the most accurate inventory and getting the most benefit.
Next, consider labeling or bar-coding chemicals. Pre-labeled materials will speed up the inventory process and make it more accurate. Also, make it count. Oftentimes you get one chance to get the inventory right, so be thorough and detailed in your inventory efforts. Make sure you get the product name, manufacturer name, internal identifying codes, container type and quantities too if you want to know quantity on hand or help figure out usage during the year.
Finally, consider chemical inventory experts and/or software. Chemical inventory specialists have the inherent knowledge to know what’s important and what’s not. Some materials that you may not think are necessary for chemical inventories are and some materials like paint can present quantity and complexity challenges that you may not be familiar with. Chemical inventory software is always a good option, even when used by a third party doing the inventory. Software can help set the right starting point, assist in identifying materials on site, help record the information in a structured, repeatable format, and then reconcile actual results to prior records to product your Chemical Inventory Snapshot.
The benefits of chemical inventories are numerous, so consider making it an annual part of your EHS plan. The data derived from the inventory is used across the organization – safety, environmental, purchasing, production, and compliance, so the benefits cannot be underestimated.