Virtually all compliance laws from OSHA, EPA, and DOT are based on chemicals. Therefore, it is essential to perform a Hazardous Materials Chemical Inventory on products used, stored, processed, produced, manufactured, and imported as part of a facilities operations.
The EPA recognizes, for its own compliance purposes, a chemical is “anything reflected in a Material Safety Data Sheet – liquid, solid, or gas.” Thus, accurate recommendations would be impossible without informing the client of those issues surrounding compliance issues relative to the facility’s chemical inventory.
EHS Data Summary Documentation is provided as a reflection of the Hazardous Materials Inventory Services, thus presenting numerous management reports as they relate to the facility’s EHS compliance requirements from EPA, OSHA, & DOT legislation. This document stands as a defensible “inspection showpiece” upon visitations by enforcement agents.
Some organizations may find it useful to have Envirosure put portions of this data on-line in secure fashion for reference by selected employees throughout their organization or by authorized personnel in local fire departments.
Due to the Sarbanes-Oxley Act of 2002, an up-to-date Hazardous Materials Chemical Inventory has become more necessary than ever, ensuring the site’s adherence to a broad realm of legislation. The Act addresses compliance management, and as EHS issues directly relate to legislative compliance, these requirements must be taken into serious consideration. The Sarbanes-Oxley Act, as well as an initiative approved by the Government Accountability Office, maintains that, in terms of publicly traded companies, EHS enforcement, compliance, and reporting must be disclosed.
Through the Hazardous Materials Chemical Inventory, potential EHS problems may be identified and rectified.
Hazardous Material Chemical Inventory
initiate database by numbering all MSDSs and create an inventory guide sheet used during the on-site audit
Perform on-site physical inventory:
Determine inactive products and compile an inactive MSDS system.
Locate products that do not have MSDS on file and obtain MSDS from the manufacturer.
Determine maximum pounds on-site, calendar year usage in pounds, container type, location of, use, & physical state of each hazardous material.
Inspect storage procedures and complete a summary of the facility’s compliance with SARA Title III Laws and Uniform Fire Codes – Article 80.
Ensure that existing MSDS are the most updated version. If not, contact manufacturer for data required under the supplier notification section of SARA Title III.
Envirosure Solutions Advanced Database
Enter chemical identity, ingredients CAS numbers, and site inventory information for each chemical. The software compares this data against preloaded databases and compiles information on:
Chemical Specific Information
304 Process Safety Management & 112R of the CAA
Storm water Priority Chemicals
Evaluate Data and Make Regulatory Determinations
Determine if any Tier II reports need to be filed.
Complete and file if necessary.
Complete and file Hazardous Materials Inventory Statement to city, county or state (as necessary).
Review database for materials on-site in quantities great enough to require reporting. Prepare a report on these chemicals for use during any potential release.
Determine if the facility separately has manufactured, processed or otherwise used, more than the threshold limit of the aggregate total of all SARA Title 313 candidate chemicals. Based on determination, make recommendations for Form R reporting.
Provide a Site-Specific Regulatory Roadmap and Site-Specific Environmental and Safety Compliance Calendar.
Much more than a simple chemical inventory, Envirosure’s HMIS service is used by major industries as the basis for their EHS compliance programs. Many of our clients elect to have the information generated from this service available on-line for convenient access by authorized individuals.
Denver HMIS Reporting
The Denver Fire Department’s HMIS program incorporates reporting requirements from:
Title III of SARA, the Superfund Amendments and Reauthorization Act, which deals with hazardous materials.
EPCRA (Emergency Response Planning and Community Right-to-Know Act).
The City and County of Denver’s requirements for hazardous materials operational permits, Denver Fire Code Section 105.6.63. The permit process provides the Denver Fire Department with information on what, where, how, and when specific hazards are being installed, manufactured, stored, and/or used within the City, and allows us to meet the Sara Title III reporting requirements.
The Denver Fire Department’s program is further supported by proposed legislation currently before the U.S. Senate, the Safe Chemical Act of 2011, which requires, among other things, that all hazard potential of any chemical must be divulged for first responders and the community to quickly determine risks and assess health and environmental concerns.
Permit Application Requirements
1. HMIS (Hazardous Materials Inventory Statement) – SARA Title III requires submittal of an HMIS form annually.
2. HMMP (Hazardous Materials Management Plan) – This is a facility site plan designating locations and amounts of hazards and locations and types of emergency equipment.
Envirosure’s HMIS service
Much more than a simple chemical inventory, Envirosure’s HMIS service is used by major industries as the basis for their EHS compliance programs.
Envirosure’s HMIS defines and establishers a site specific Environmental, Health, and Safety Regulatory Roadmap assisting our clients to become proactive in satisfying compliance mandates required for their facilities by local, county, state, and federal jurisdictions of the EPA and OSHA.
The HMIS summary assists our clients pinpoint the site-specific compliance mandates for their particular facility, thus saving time, effort, and energy trying to determine their status under current laws.
Many of our clients elect to have the information generated from this service available via the internet, thus providing time saving, up-to date information available for authorized individuals.
Before deciding on a source for annual update of your MSDS data, review our HMIS checklist, and see what you may be missing.
Call us today at 480-784-4621, talk with one of our EHS professionals, and fast track your EHS compliance requirements.