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- Step 1
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- OSHA requires employers to have a MSDS for each hazardous chemical which they use (29 CFR 1910.1200 (g)).
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- A hazardous chemical is any chemical which is a physical hazard or health hazard (29 CFR 1910.1000 (c)). The term chemical includes mixtures and products.
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- There may be hazardous chemicals present for which the facility has no MSDS. MSDSs for these chemicals must be developed by the facility or obtained for the chemical manufacturer or distributer.
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- Step 2
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- OSHA requires employers to have a MSDS for each hazardous chemical which they use (29 CFR 1910.1200 (g)).
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- The Comprehensive Inventory will not need to be submitted to the administering agencies for reporting under EPCRA. However, creating it is a necessary step toward EPCRA compliance. Most facilities will find multiple advantages to developing this comprehensive inventory of all chemicals present at the facility. It will serve the facility in other management/environmental compliance efforts (i.e., Clean Air Act, HAZMIN, HAZCOM).
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- The following sections (Steps 3 through 5) involve searching through every hazardous chemical which is listed on the Optional Comprehensive Inventory and classifying these chemicals according to EPA's classification scheme for EPCRA.
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- Step 3
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- Check both the names and the CAS numbers against the EPA list. Manufactures often use synonyms which are different from EPA's regulatory chemical names.
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- Step 4
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- Be cautions not to miss chemicals which belong to the regulated chemical categories (i.e., PCBs).
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- Check both the names and the CAS numbers against the EPA list. Manufactures often use synonyms which are different from EPA's regulatory chemical names.
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- Step 5
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- Be cautions not to miss chemicals which belong to the regulated chemical categories (i.e., PCBs).
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- Check both the names and the CAS numbers against the EPA list. Manufactures often use synonyms which are different from EPA's regulatory chemical names.
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- Step 6
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- All hazardous chemicals present at the facility must be included in the inventory even if they do nto have MSDSs. Reportable chemicals which may require additional attention because they may be missing from the comprehensive inventory might include, but are not limited to: reaction intermediates, chemicals contained in waste steams, and chemicals which are not typically considered hazardous by employees who are unfamiliar with the regulations (i.e., compressed gases).
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- Step 7
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- The HM Manager determines the appropriate method to divide the facility into work areas and identifies the appropriate personnel to complete the Inventory Worksheets PDF Form.
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- Step 8
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- Personnel in each work area will complete the worksheet(s) for each chemical stored or used in their work area. They will not complete the Regulatory Exemptions or Chemical Classification sections (shaded) because effective and efficient exemptions identification and chemical classification requires a substantial familiarity with EPCRA.
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- Step 9
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- The HM Manager identifies the EHSs, HSs, and TCs recorded on each worksheet, utilizing the lists found in the CFR, additional EPA guidance (i.e., the Toxic Chemical Synonym list) and his/her own hazardous materials background. The exemptions to each section are addressed in each module.
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- Step 10
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- The employees in the work area will be completing the non-shaded parts of the Inventory Worksheet PDF Form. The HM Manager will complete the shaded areas.
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