Inventory and tracking

Decommissioning of buildings, facilities and structures for government laboratories must be in accord with Federal regulations in 10 CFR 835, Occupational Radiation Protection and DOE Order 5400.5, Environmental Radiation Protection (online at http //www.directives.doe.gov as of Dec. 2005). All equipment valued over 5,000 is inventoried and tracked, and the final disposition is directed by regulations. 

Chemical inventory and tracking systems provide current information on the site s hazardous chemical and material inventories. A properly integrated inventory and tracking system can support other environment, safety, and health requirements (directives). This is a continuous process performed from acquisition, through storage and use, to final disposal. 

Several inventory and tracking systems, often using bar code scanners and computer databases, are used throughout the complex. The databases typically include locations, amounts, uses, hazards, and custodians. Regardless of the inventory and tracking software used, it is important to integrate this software with other computerized environment, safety, and health systems, such as Hazard Communication, waste disposal, medical surveillance, and MSDS systems, at a particular site. 

The following DOE directives and OSHA and EPA standards pertain to inventory and tracking. At the activity or worker level, DOE O 440.1A requires the identification of workplace hazards and evaluation of risk (440.1A.9). This Order also calls out OSHA standards included in Title 29 of the CFR. Examples of OSHA and EPA standards which call for inventory and tracking include 29 CFR 1910.120, HAZWOPER, 29 CFR 1910.1200, Hazard Communication, 29 CFR 1910.1450, Laboratory Standard, and Section 313 (EPCRA). 

Examples of available inventory and tracking software can be found in Appendix C, Program Resources. 

The documentation and periodie eonfirmation and validation of inventory records can be performed by the chemical inventory system mentioned in Section 2.3, Inventory and Tracking. 

The following are a sampling of computerized inventory and tracking systems across the complex ... 

Inventory and tracking of chemicals are primarily driven by Federal regulations, DOE requirements, and good business practices. Various site organizations utilize the chemical database as an information source for compilation of regulatory and DOE-required reports, for example, the EPCRA Tier II inventory, the Toxic Chemical Release inventory, the Ozone Depleting Substances inventory, the Air Emissions... 

Direct requirements for an inventory and tracking system are found in OSHA s regulation 29CFR1910.1200, and EPA s 40CFR370.25. In addition, there are many regulations and standards for which an inventory and tracking system is an implied requirement since inventory information facilitates compliance. Therefore, implied requirements are summarized here but are not ineluded as mandatory requirements in this chapter. 

NOTE The information that follows is a consolidation of existing federal safety and health requirements and national standards that relate to the inventorying and tracking of chemicals. It... 

This chapter identifies and consolidates existing chemical user safety and health requirements that address the inventory and tracking of chemicals and chemical products. It addresses relevant DOE and Federal chemical-related regulations and National Standards applicable to all locations involved in the storage and/or use of chemicals and chemical products (see def) and excludes State and local code requirements. 

Key to this chapter is its inclusion of the many regulations and standards for which an inventory and tracking system is an implied requirement that is necessary for proper compliance. Of additional importance in this regard is that whether direct or implied, requirements for the inventory and tracking of all classes of chemicals are consistent with OSHA s general duty clause which requires employers to protect their employees from all recognized hazards in the workplace. 

This chapter is divided into two major sections. The first section, 4.1, includes requirements that are directly applicable to the inventory and tracking of all chemicals. The second section, 4.2, consolidates additional, implied requirements specific to various health and safety regulations. 

Section 4.1 consolidates the inventory and tracking requirements for the workplace, and includes specific regulatory reporting requirements. Section 4.2 consolidates those requirements that do not directly require an inventory of hazardous chemicals, but for which use of a chemical inventory and tracking system would be necessary for compliance with mandatory standards, or would facilitate compliance. 

The committee recommends that chemical suppliers adopt a uniform bar code identification system that would facilitate establishment and maintenance of laboratory chemical inventory and tracking systems. 

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