Chemical Inventory Information
Chemical Inventories Needed for Each Lab
The Department of Homeland Security has issued a new rule that requires all chemical facilities to report to them if they possess certain chemicals over their "screening threshold quantity". I have included further details below from their summary of the rule. At this time, this rule does apply to colleges and universities.
It should be noted that the threshold for some of the chemicals is "any amount". In order to determine if we have any of the chemicals of interest, and in what amounts, we need a complete inventory of the chemicals on campus.To that end, I am asking each lab to provide me with a complete chemical inventory by July 20, 2007. This includes any common areas, walk-in coolers, or other shared spaces. Please be sure to use this form. Our electronic inventory system will be rolled out across the campus in the next year or so and the form will make it easy to upload your inventories to the new system. (Please note that the form was updated in 2006 to accommodate the new system). It is imperative that this inventory be done completely and in a timely manner in order to comply with the new federal regulations. I thank you in advance for your compliance with this; we apologize for the short notice. Please feel free to contact us with any questions.
Why the short notice?
There have been a few questions generated by the request for an up to date inventory of the chemicals being used in the teaching and research labs. It has been a requirement at Creighton for each user to supply Environmental Health and Safety (EH&S) with an inventory of chemicals in their possession but the amount of chemicals was not always supplied. The driving force for this information at that time was the requirements of the Fire Marshal; the amount was less important than the need to know what chemicals were in the rooms. We can all understand the importance of safety for the fire fighters when they enter an area.
Enter a larger and more powerful federal agency into the information requirements: The Department of Homeland Security (DHS). Currently each chemical storage facility must supply the DHS with the amount of any of 342 chemicals if the total that they have exceeds their “amount of concern”. Unfortunately over 100 of these chemicals are listed as “any quantity”. DHS is insisting that each University know how much and where these chemicals are.
The reason behind requesting these inventories now is that we will have 60 days to complete an online survey at the DHS website. Stanford University, a school that has one of the better computerized chemical tracking systems in the country, took 150 man hours to complete the DHS website form. While they are a larger university than Creighton, they already have the inventories in hand and it still took them 150 hours to complete the form. So please understand that while we know that it may take you some time to complete the form sent for your use, it will also take EH&S a significant amount of time to consolidate and prepare this information for submittal.
Thank you for your cooperation and timely assistance in meeting the regulatory requirement.
Questions about filling out the form
The form is a little confusing, so we have added some further instruction.
For the amount, we are asking for the amount listed on the bottle, not the estimated amount left in the bottle.
Amt is the amount in the bottle
Size is the unit of measure
Container Count is the number of containers of that size.
So, for instance if you have 2 50-gram bottles of sodium chloride, you would have
Chemical name | CAS # | Amt | Size | Container Count | Date in |
Sodium chloride | 7647-14-5 | 50 | gram | 2 | 6/12/2007 |
Similarly, hazard type and NFPA rating are for your use; these will help you determine the correct information to put on your green door placard.
Chemical Facility Anti-Terrorism Standards -- Summary
Federal Register, April 9, 2007, Page 17687 - 17745
The Department of Homeland Security (DHS or Department) issues this interim final rule (IFR) pursuant to Section 550 of the Homeland Security Appropriations Act of 2007 (Section 550), which provided the Department with authority to promulgate "interim final regulations" for the security of certain chemical facilities in the United States. This rule establishes risk-based performance standards for the security of our nation's chemical facilities. It requires covered chemical facilities to prepare Security Vulnerability Assessments (SVAs), which identify facility security vulnerabilities, and to develop and implement Site Security Plans (SSPs), which include measures that satisfy the identified risk-based performance standards. It also allows certain covered chemical facilities, in specified circumstances, to submit Alternate Security Programs (ASPs) in lieu of an SVA, SSP, or both.
The rule contains associated provisions addressing inspections and audits, recordkeeping, and the protection of information that constitutes Chemical-Terrorism Vulnerability Information (CVI). Finally, the rule provides the Department with authority to seek compliance through the issuance of Orders, including Orders Assessing Civil Penalty and Orders for the Cessation of Operations.
More information can be found on the Department of Homeland Security's website.
Final Rule Announced
The final Rule was announced November 20, 2007. The final Appendix A can be found here.