Mastering Chemical Inventory Management: A Key to HazCom Compliance

Part of OSHA’s Hazard Communication (HazCom) written program requirement is the chemical inventory, which is essentially a list of chemicals for which the employer must have a Safety Data Sheet (SDS). It must include all chemicals present, even if they’re stored or not in use. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered by HazCom (29 CFR 1910.1200). (Paragraph (b) of the standard includes exemptions for various chemicals and workplace situations.) The inventory can be for the entire facility or for individual work areas. It must have a product identifier for each chemical that aligns with the chemical’s SDS and label. 

In order to maintain a complete inventory, you must know where your chemicals are stored. Many employers start by performing a department-by-department audit and look for chemicals present. Some audit by operation or task. Whichever you choose, make sure you include cleaning supplies, grounds maintenance chemicals, and vendor samples being used on a trial basis, as well as all chemicals used in daily operations. Be sure to check in all cabinets, closets, and other storage areas. Ask employees what they use and where it’s stored.

Sometimes people think of chemicals as being only liquids in containers. However, HazCom covers chemicals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are “contained” or not. In addition to chemicals in containers and pipes, think about chemicals that are generated during work operations. 

Toxic air emissions may be a by-product of a process or procedure in a facility. Areas that often get overlooked involve potentially toxic chemicals produced from welding operations, gasoline-powered forklift vehicles, power tools with internal combustion motors, and commercial trucks at the loading dock. Employee exposure to any air emissions that are being created in the facility must be accounted for. 

Once the inventory is compiled, the next step is to determine if an SDS has been received for all of the chemicals on it. If any are missing, contact the supplier and request one. Be sure to document your phone calls, emails, and letters. This is your proof of a good faith effort to obtain the SDS. If your efforts fail, ask your local OSHA office for help. 

OSHA doesn’t specify a frequency for updating your chemical inventory, but they do expect you to keep it current. This could be done annually if you’re a smaller location whose chemicals stay relatively the same; however, it should be more often if your chemicals change frequently. 

Approaches to chemical management

If you have few chemicals and they don’t change often, the simplest approach to chemical management is to use a spreadsheet to log your chemicals. Although OSHA only requires a product identifier, consider including columns for the Chemical Abstracts Service (CAS) number, location, quantity, and expiration date. This helps keep your inventory organized.

Larger organizations with numerous chemicals may prefer to use inventory management software or chemical management systems. Inventory management software can help track quantities, locations, and SDSs for each chemical. Some include features such as barcode scanning, real-time inventory management, checklists for SDSs, and automatic sensors to monitor storage conditions.

Chemical management systems or services can help you create your chemical inventory as well as quickly obtain, maintain, and provide ready access to SDSs. You may find solutions such as a centralized, searchable SDS database; ability to upload your own SDSs and create labels; chemical inventory creation based on your SDSs; and SDS binder creation for individual work areas or the entire workplace. Some services even conduct periodic chemical list reviews.

Choosing the right chemical management solution

Factors to consider when choosing the right chemical management solution include:

• Scope of services: Ensure the provider offers services that match your needs. This may include inventory management, SDS management, chemical inventory creation, and training. 

• Industry experience: Look for a provider with experience in your industry. They’ll be more familiar with the specific regulations, challenges, and best practices relevant to your field.

• Cost-effectiveness: Evaluate the cost of the services and compare it with the potential savings from reduced chemical use, waste, and compliance costs. A good chemical management service should provide a clear return on investment.

Stay ahead of OSHA compliance and ensure workplace safety with an effective chemical inventory strategy. Whether you're using a simple spreadsheet or an advanced management system, having an up-to-date chemical inventory is crucial.