EH-41 Logo Instructions for Module 1:
Inventory of Chemicals
Module 1 graphic
     
 
Instructions for: Step 1, Step 2, Step 3, Step 4, Step 5, Step 6, Step 7, Step 8, Step 9, Step 10, Step 11, Step 12, Step 13, and Step 14.
     
 
 
 
Instructions for Step 1        Back to Step 1    GOTO: Top of Instructions Page
 
 
These Material Safety Data Sheets (MSDSs) should be maintained in the areas where the chemicals are used at the facility. Many facilities also keep a duplicate set of MSDSs at a central location with other occupational safety and health information.
 
There is no definate list of Hazardous Substances (HS). OSHA regulations require facilities to maintain a MSDS for any product or chemical which meets the defination of a HS unless it falls under one of OSHA's exepmtions (29 CFR 1910.1200). Manufactures and distributors usually include the MSDS for each HC/HS with at least the first shipment of that HC/HS. If the facility does not have a MSDS for a chemcial or product, the facility may develop a MSDS for the chemical or may obtain a MSDS from the manufacturer of the chemcial.
 
 
 
Instructions for Step 2        Back to Step 2    GOTO: Top of Instructions Page
 
 
Every chemical, product, and mixture present at the facility will need to be inventoried in order to complete the EPCRA compliance determination. Suggestions for implementing the Optional Inventory or other inventory method are included at the end of this module.
 
If the inventory of chemicals at the facility is small enough to be managed by written worksheets and other hardcopy means, then using copies of the Optional Inventory Worksheets may be useful for collecting the needed information. Some facilities may already have a more sophisticated system for tracking and compiling inventory information on chemicals. When complete inventory information is already available, the user can quickly review the rest of this module for useful information or move to another module of interest.
 
Every hazardous chemical present at the facility which is on one of EPA's chemical classification lists (Extremely Hazardous Substance - EHS, Hazardous Substance - HS, and/or Toxic Chemical - TC) will need to be identified as EHS, HS and/or TC on the Optional Inventory Worksheet. Some hazardous chemicals may meet more than one classification, others may not meet any classifications. The classification of a chemical determines how that chemical is regulated under EPCRA.
 
 
 
Instructions for Step 3        Back to Step 3    GOTO: Top of Instructions Page
 
 
The EHSs are requlated under Section 302 (Emergency Response Planning Notification), Section 304 (Emergency Release Notification), Section 311 (HC list submission), and Section 312 (Tier 1 or Tier II form). Every hazardous chemical listed on the Optional Inventory must be examined to determine if it is listed on EPA's Extremely Hazardous Substance (EHS) list. It is advisable to become familiar with the list of EHSs so that the EHS identification process can be most effective. (40 CFR 355 Appendicies A and B).
 
The full HS list is found in 40 Code of Federal Regulations (CFR) Part 355. The CFR is available from the Government Printing Office (GPO). The phone number for the GPO in Washington, DC is (202) 783-3238. Regional GPO offices should also be able to process requests for the CFR.
 
Check both the names and the Chemical Abstract Service (CAS) numbers on the MSDS for chemicals which are on EPA''s EHS list. Manufactures will often use synonyms for the EHS which are different from EPA's regulatory chemical names, so examining chemical names alone is not enough to guarantee that all EHSs are identified.
 
Be sure to mark the block next to the hazardous chemical which is an EHS, rather than the block next to the product which contains the EHS.
 
 
 
Instructions for Step 4        Back to Step 4    GOTO: Top of Instructions Page
 
 
The HSs are regulated under Section 304 (Emergency Release Notification). Every hazardous chemical listed on the Optional Inventory must be examined to determine if it is listed on EPA's Hazardous Substance (HS) list. It is advisable to become familiar with the list of HSs so that the process of identifiying HSs contained in the inventory will become easier and more effective. (40 CFR 302.4).
 
The full EHS list is found in 40 CFR Part 302.4. The CFR is available from the Government Printing Office (GPO). The phone number for the GPO in Washington, DC is (202) 783-3238. Regional GPO offices should also be able to process requests for the CFR.
 
Check both the names and the CAS numbers on the MSDS for chemicals which are on EPA's HS list. Manufactures will often use synonyms for the HS which are different from EPA's regulatory chemical names, so examining chemcial names alone is not enough to guarantee that all HSs are identified.
 
The Hazardous Substance list includes a number of chemical categories. CAS numbers for chemcials in these categories will not be listed on EPA's HS list. You must be familiar with these categories as you examine the chemicals on the Optional Inventory to prevent missing any of these HSs.
 
Be sure to mark the block next to the hazardous chemical which is an HS, rather than the block next to the product which contains the HS. If you are unsure whether a chemical fits one of the categories, you may call the RCRA/CERCLA Hotline at 1 (800) 424-9346 for assistance.
 
 
 
Instructions for Step 5        Back to Step 5    GOTO: Top of Instructions Page
 
 
The Toxic Chemicals (TCs) are regulated under Section 313 (Toxic Chemical Release Notification). Every hazardous chemical listed on the Optional Inventory must be examined to determine if it is listed on EPA's Toxic Chemial list. It is advisable to become familiar with the list of TCs so that the process of identifying TCs contained in the inventory will become easier and more effective. (40 CFR 372.65).
 
The full TC list is found in 40 CFR Part 372.65. The CFR is available from the Government Printing Office (GPO). The phone number for the GPO in Washington, DC is (202) 783-3238. Regional GPO offices should also be able to process requests for the CFR.
 
Check both the names and the CAS numbers on the MSDS for chemcials which are on EPA's TC list. Manufactures will often use synonyms for the TC which are different from EPA's regulatory chemical names, so names alone are not enough to guarantee that all TCs are identified.
 
The Toxic Chemical list includes a number of chemical categories. CAS numbers for chemcials in these categories will not be listed on EPA's TC list. You must be familiar with these categories as you examine the chemcials on the Optional Inventory Worksheets to prevent missing any of these TCs. If you are unsure whether a chemical fits one of these categories, you may call the EPCRA Hotline at 1 (800) 535-0202.
 
Be sure to mark the block next to the hazardous chemical which is a TC, rather than the block next to the product which contains the TC.
 
 
 
Instructions for Step 6        Back to Step 6    GOTO: Top of Instructions Page
 
 
The facility may not have a MSDS for every hazardous substance at the facility. It is possible that the personnel who carried out each phase of compiling information for the Optional Inventory may have missed some reportable chemicals. This step is designed to provide quality assurance for the Optional Inventory. Personnel unfamiliar with certain operations may be unaware that some substances are created in waste streams as a result of a neutralization process, others may be by-products of combustion, and some chemicals may be present in unexpeceted ways and locations. Examine the processes at the facility for any of these additional chemcials because they may still be regulated under EPCRA.
 
The steps used to compile information about EHSs, HSs, and TCs will need to be performed for these chemcials just as they were performed for the chemicals whihc were already listed on the Optional Inventory. Some adjustments may need to be made, such as estimating concentrations instead of reading them off the MSDS to obtain all of the inventory information.
 
The same classification procedures that were carried out in STEPS 5 through 7 need to be performed on the chemicals which were newly added to the Optional Inventory.
 
 
 
Instructions for Step 7        Back to Step 7    GOTO: Top of Instructions Page
 
 
The inventory must contain information about the entire facility. An efficient way to creat the inventory is for personnel throughout the facility to gather inventory information on their sections of the facility. The Hazardous Materials (HM) Manager coordinates this information gathering, but does not need to personally inventory each chemical. The HM manager will compile the information collected in each section of the facility.
 
 
 
Instructions for Step 8        Back to Step 8    GOTO: Top of Instructions Page
 
 
Personnel will examine the MSDSs for each product/chemical/mixture present in their section of the facility. From the MSDSs and their inventory records, they will complete each non-shaded section of the inventory. If inventory information is not readily available, the personnel may use reasonable estimates. If the weight percent of any hazardous chemical in a product is not listed on the MSDS or on the product, the personnel may leave the "Wt % of HC in Product" column blank.
 
 
 
Instructions for Step 9        Back to Step 9    GOTO: Top of Instructions Page
 
 
This step is clarified in Steps 4 through 8 of Module 1: Inventory of Chemicals. Go to Step 4.
 
 
 
Instructions for Step 10        Back to Step 10    GOTO: Top of Instructions Page
 
 
The Optional Inventory Worksheet(s) are designed to be used to compile information on the chemicals/mixtures/products which may be present in your work area. The facility HM manager can explain to you the area for which you will be responsible and should be able to answer any other questions you may have concerning this project. MSDS for each chemcial used in your work area should be maintained somewhere in the area where the chemicals are used. Each product should have its own MSDS.
 
 
 
Instructions for Step 11        Back to Step 11    GOTO: Top of Instructions Page
 
 
Record the product name in the "Product Name" column. The Hazardous Chemicals or ingredients section of the MSDS should contain the names of all hazardous chemicals present in the product, as well as the weight percent of each hazardous chemical in that product. For each MSDS present in the work area, record the product name and the names of any hazardous chemicals containted in that product.
 
 
 
Instructions for Step 12        Back to Step 12    GOTO: Top of Instructions Page
 
 
Determine what was the highest amount of each chemical that was present in your work area at any one time during the previous calendar year. Enter this quantity in the "Max. Quant. of Product On-Site at Any One Time (lbs.)" column.
 
Use inventory records or other information to determine how much of the product was used in your work area during the previous calendar year and enter that amount in the "Quant. of Product Used During Calendar Year (lbs.)" column.
 
 
 
Instructions for Step 13        Back to Step 13    GOTO: Top of Instructions Page
 
 
Use the Storage Type codes and the Temperature and Pressure Conditions as they appear in the lower right-hand corner of the Worksheet to describe the conditions of each product. You only need to enter one three-block code for each product, unless the product is present in your work area in more that one condition.
 
Select a method for completing the storage location on the inventory worksheet. There are three options for completing the storage location information on the Optional Inventory Worksheets:
 
  1. Entering a short description of the location of each product in the Storage Locations section of the worksheet;
     
  2. Drawing a site plan and labeling it with number corresponding to each product and entering these numbers on the Storage Locations section of the worksheet; or
     
  3. Drawing a site plan with coordinates and entering the coordinates for each product in the Storage Locations section of the worksheet.
 
Unless the HM manager tells you that a particular methods will be the standard method for your facility, you may use any one of the three methods. Examples of the three methods are provided below. Record each location in the column labeled "Storage Location". You only need to enter one location for each product, unless the product is present in your work area in more than one location.
 
 
 
Instructions for Step 14        Back to Step 14    GOTO: Top of Instructions Page
 
 
Make sure you have listed on the Optional Invnetory Worksheets, each product, chemical, or mixture which is present in your work area.
 
 
 

DOE Office of Environmental Policy and Guidance