Hazardous chemical inventories are managed by following these
steps:
- Identify and track hazardous chemicals. ChemTrack is the primary chemical
tracking tool. See Section 3.5.1.
- Control quantities of hazardous chemicals. An important part of inventory
control is determining when to dispose of hazardous chemicals, which can be done
based on predetermined age, testing procedures, or upon observation of an
unsatisfactory condition. See Section 3.5.2.
- Conduct reviews of hazardous chemicals in use and in storage areas
periodically to ensure age and testing procedures are being fulfilled, and to
identify cases where containers or their contents show evidence of
deterioration. See Sections 3.5.3 and 3.5.4.
The authorizing organization is responsible for implementing these
steps, except where specified in the text of this section. In addition, some
chemicals can become hazardous with the passage of time, most notably chemicals
that form peroxides. These are addressed in Sections 3.5.5
and 3.7.3. Legacy chemical concerns associated with the
departure of workers or the decommissioning of a facility are addressed in Section 3.5.6.
3.5.1 Chemical Tracking and Inventory Management
Functions
ChemTrack is the primary tool for tracking hazardous chemicals,
although local inventory systems may be needed to address hazardous chemical use
not captured by ChemTrack. To this end, chemical custodians shall:
- Ensure that ChemTrack bar code labels are on all primary and certain
secondary containers (see Appendix A for the definition of a
€œsecondary container€) when required. Contact your ES&H Team for guidance on
when to bar code label secondary containers.
- Update or notify ChemTrack (Ext. 4-4404) when obtaining either new chemicals
or items to be entered into ChemTrack.
- Update or notify ChemTrack when disposing of bar coded chemical containers
or transferring them to a non-LLNL location. This can be done by:
- Accessing the ChemTrack Home Page
and clicking on Update Inventory
http://chemtrack.llnl.gov/
- Alternatively, remove the lower half of the bar code, affix it to a
ChemTrack Disposal/Transfer Form, and mail the form to the ChemTrack Group
(L-621).
- Comply with the facility€™s chemical inventory procedures.
- Working with facility management and RIs, ensure that hazardous chemical
inventories are compiled and annually updated for both laboratory and
nonlaboratory areas as part of the annual ChemTrack inventory and reconciliation
process.
- Ensure that current, accurate information is entered into ChemTrack to
facilitate informed decision making by the authorizing organization decisions
concerning retaining, testing/treating, or disposing of stored chemicals per Section 3.5.5.
The ChemTrack Operations Group shall provide assistance with
chemical inventories, and also maintains the Laboratory€™s MSDS database, the
Chemical Safety databases, and ChemTrack/MSDS Hotline (extension 4-4404).
ChemTrack responsibilities are defined in Document
21.1.
3.5.2 Controlling Quantities of Hazardous
Chemicals
Authorizing organizations shall:
- Establish controls for hazardous chemical inventories based on quality
control and program considerations.
- Manage chemical inventories and ensure that hazardous chemical inventories
are limited to amounts needed to meet operational requirements. This shall be
done by evaluating the:
- Amount of a hazardous chemical in inventory,
- Use,
- Age (e.g., if older materials are in use or reasonably could be used, if the
containers are deteriorating, or if other changes listed in Section 3.5.4 are evident), and
- Safety or suitability of the chemicals for use.
- Ensure that hazardous chemicals are procured and stored consistent with
program, ES&H, and waste minimization objectives (the LLNL Waste
Minimization Program and how to minimize the quantities of chemicals in storage
or use are described in Section 3.2.3).
Chemical custodians shall ensure that inventories of chemicals
that are not being used (€œstockpiles€) are reviewed annually to assess ongoing
need (based on ES&H and/or quality control considerations). The chemical
custodian or designee shall also evaluate the status of hazardous chemicals
being stored (e.g., use, age, condition of storage container) on an ongoing
basis to guide decisions about retaining or removing chemicals in an
inventory.
3.5.3 Inspections
A visual periodic examination of stored hazardous chemicals is
important for safety and decision making on continuing to store or dispose of
chemicals. General requirements for evaluating hazardous chemical storage follow
in this section.
Chemical Custodian Reviews. Chemical custodians
shall ensure that their hazardous chemicals, including those on or in shelves
and cabinets used to store chemicals, are periodically reviewed. A review
frequency may be determined by the authorizing organization as appropriate.
These reviews can be informal evaluations used to identify:
- Incompatible chemicals.
- Out-of-date chemicals.
- Chemicals no longer in use.
- Problem indicators listed in Section 3.5.4.
Hazards Control Department Inspections. The area
ES&H Teams shall periodically check hazardous chemicals in accordance with
Chemical/Biological Safety Discipline Action Plan Item 30, €œChemical Storage.€
The chemical custodian and Hazards Control Department inspection
activities can be coordinated.
3.5.4 Visible Changes Indicating a Chemical is
Dangerous or Ready for Disposal
Some visible changes may indicate a chemical presents an imminent
danger.
Contact the RI or, if the RI or other knowledgeable person
is not available, call the Fire Department [dial 911, or, if using a cell phone
or calling from offsite, dial 1 (925) 447-6880] if any of the following are
found:
- Evidence of material peroxidization, such as
- Exterior crystal growth.
- Layering of liquids.
- Discoloration.
- Bulging or overpressurization.
- Any other reaction that could potentially cause container handling to be
extremely hazardous. This condition may have been observed, or an individual may
have reason to believe it might have occurred.
These visible changes may indicate a chemical is ready for disposal:
- Slightly cloudy liquids.
- Change in chemical color.
- Spotting on solid chemicals.
- Caking of anhydrous chemicals (evidence of reaction with moisture).
- Presence of precipitates or particulates in liquids, or of liquid in
solids.
- Container damage and age-related effects, such as
- Signs of corrosion.
- Cracking.
- Changing shape or color.
- Fading or deteriorating labels, labels falling off, or missing
labels.
- Missing, deteriorating, or broken caps.
3.5.5 Stability of Hazardous Chemicals in Storage
Chemicals can become hazardous with the passage of time. At this
time, the only groups of chemicals assessed for age-related hazards are the
organic peroxides, peroxidizable compounds, explosives, and certain alkali metal
compounds, although other chemicals exist that can become hazardous with the
passage of time. Age limits have been set to minimize these hazards associated
with peroxidizable chemicals (see Section 3.7.3). Age
limits have also been set for toxic, corrosive, and reactive gases for a mixture
of safety- and quality-related reasons.
Information on specific groups of materials that pose age-related
hazards can be found in the ES&H Manual as follows:
- Storage and age limits of explosives: Documents
17.1, €œExplosives,€ and 17.2, €œLLNL
Energetic Materials Stability Review Program.€
- Age limits for toxic and reactive gases: Document
14.3, €œToxic, Corrosive, or Reactive Gases.€
- Age-related hazards of peroxide and superoxide compounds of alkali metals:
Document
14.7, €œSafe Handling of Alkali Metals and Their Reactive Compounds.€
A list of specific peroxidizable chemicals can be obtained by
going to the ChemTrack home page, clicking on the €œReports€ button to the left,
then clicking on the ES&H button, logging in and then entering the type of
report sought (e.g., €œLLNL peroxidizables€).
For the chemicals described in this section, the chemical
custodian shall ensure that:
- Those nearing the ends of their safety- or quality-based age limits are
evaluated to determine if they are still useful and test them, if
practical.
- Those at the end of their shelf lives, as evident by visible signs described
in Section 3.5.4 or other means, are promptly sent off for
disposal.
Chemical custodians, working with RIs, shall also ensure that
chemicals are periodically, but not less than annually, evaluated to determine
if they are to be retained or sent for disposal.
3.5.6 Chemicals Used by Departing Workers
RIs shall ensure that workers moving out of a lab or shop either
dispose of hazardous chemicals for which they are responsible as hazardous
waste, or transfer unused or partially used hazardous chemicals to others before
leaving. Chemicals that are still usable but no longer needed should be recycled
through the CHEW, if it is safe to do so. See Documents
12.7, €œShutdown or Transfer of Facilities, Operations or Associated
Equipment,€ and 12.8,
€œDecontamination and Disposition of Process-Contaminated Facilities and
Associated Equipment,€ in the ES&H Manual for requirements relating
to chemicals in an activity that is being discontinued and for facilities being
demolished or entering inactive status, respectively.
3.6 Labeling and Signage
This section addresses labeling and signage requirements.
3.6.1 Labeling
Proper labeling of hazardous chemicals warns users of hazards that
may include environmental aspects and helps ensure that eventual disposal is
carried out properly. Workers shall read the label of any chemical they are
using for the first time to determine if it is hazardous, what the hazards are,
and to identify appropriate controls.
RIs shall ensure that the labeling requirements of Documents
10.2 regarding labeling chemical containers, and requirements of Document
14.2 regarding labeling chemicals in laboratories are met.
3.6.2 Signage
RIs shall ensure that areas where chemicals are used and stored
are posted with the appropriate signs, and that Documents
10.2 and 14.2
requirements for signs are met. Signs for specific chemicals or chemical classes
are noted in the chemical-specific documents in Part 14 of
the ES&H Manual.
For both laboratory and nonlaboratory areas, the RI shall
indicate, or arrange to indicate, the hazards present by generic categories
(e.g., corrosive, flammable, oxidizer, reducing agent, explosive, highly toxic,
and reactive) on the Hazard Notice Door Signs, as specified in Document
10.2.
3.7 Chemical Handling
This section discusses the requirements for handling solid and
liquid chemicals, gases, peroxides, and peroxidizable materials.
3.7.1 Precautions for Handling Hazardous Solid
and Liquid Chemicals
Workers shall:
- Keep the work area as clean and orderly as the operation will allow.
- Use exhaust ventilation (e.g., laboratory hoods, flexible duct exhausts,
lateral exhaust hoods) to minimize personnel exposures to air contaminants when
performing operations that can generate air contaminants (e.g., aerosols and
gases/vapors), unless the ES&H Team has evaluated the work and approved
performing the work without these controls. See Documents 12.2, 12.3, 12.4, and 12.5 for
planning and using exhaust ventilation.
- Use protective equipment such as safety shields and enclosures, and lower
the sashes of laboratory hoods so the face is protected from spatter and
splinters. Enclosures also maximize protection provided by exhaust
ventilation.
- Do not eat, drink, smoke, or apply cosmetics, or store these items in an
area where hazardous chemicals are handled.
- Wash hands immediately after handling all chemicals, regardless of whether
gloves have been worn.
- Use mechanical aids for all pipetting procedures (never mouth
pipette).
- Evaluate hazards and environmental aspects and identify proper containers
and controls before transferring or dispensing chemicals from
manufacturer-supplied chemical containers.
- Provide secondary containment for retaining spills as appropriate.
- Limit the volume of volatile or flammable chemicals, preferably to the
amount required for daily operations.
- Follow the requirements in Document
18.1, €œPressure,€ in the ES&H Manual if the operating system is
used under pressure or if it can generate pressure.
- Keep hazardous chemicals out of offices.
- Use the required PPE as specified in Document
11.1.
To the extent feasible, workers should observe the following
guidelines:
- Isolate hazardous operations by performing them in separate rooms and limit
the number of workers involved.
- Assure that safe and convenient lavatory facilities are available.
- Do not use solvents for personal cleanup.
Facility management shall ensure that break areas are not located
where hazardous chemicals are handled or stored.
Newly synthesized chemicals, of which the toxicity, chemical, and
physical properties have not been fully characterized or studied, shall be
considered hazardous by all workers. Therefore, use only a small quantity of
these chemicals to minimize both the effects of unexpected reactions and the
potential for toxicity resulting from exposure.
The Hazards Control Department is responsible for conducting the
workplace chemical hazard monitoring. This monitoring measures or otherwise
evaluates the extent of an employee€™s exposure to hazardous chemicals and
assesses compliance with regulations and documenting the monitoring results.
This activity is described in more detail in Document
10.2.
3.7.2 Handling Chemically-Hazardous Gases
Workers who handle gases shall be familiar with their properties
and health effects, and exercise care in handling them. Gases may be corrosive,
flammable, toxic, radioactive (e.g., tritium), or explosively reactive when they
come into contact with other chemicals (including air, water, or nonhazardous
chemicals).
RIs shall be familiar with Document
18.1, Document
18.5, €œCryogens€; and 14.3,
€œToxic, Corrosive, or Reactive Gases€ in the ES&H Manual. For
detailed information on specific gases, especially those that are toxic,
see:
- Matheson Gas Data Book.
- Fire Protection Guide on Hazardous Materials (National Fire
Protection Association).
- The area ES&H Team.
3.7.3 Peroxidizable Chemicals
Workers shall implement the requirements specified in LLNL€™s
Standard for Storing and Using Peroxidizable Organic Chemicals (UCRL-AR-133218, Rev.
1), when working with peroxides or peroxidizable chemicals. This standard
contains requirements for special labeling and periodic testing of contents and
can be found at the following intranet address:
http://www.llnl.gov/tid/lof/documents/pdf/235232.pdf
Peroxidizable chemicals form unstable peroxides when they are in
the presence of oxygen, stored for long periods of time, or exposed to light.
Peroxides may also be formed even if preservatives or inhibitors are added to
slow down the peroxidization process. These chemicals may explode when
disturbed, when the caps are removed from their containers, or when they are
used. Thus, these chemicals shall be protected from exposure to light, heat, and
air. The chemicals indicated as High Hazard in Table 2
shall be stored under inert gas, while the remaining chemicals listed in Table 2
are stored in sealed containers.
In addition, workers shall store peroxidizable chemicals in
accordance with the time limitations specified in Table 2.
Old containers of peroxide-forming chemicals improperly stored are most likely
to be dangerous, especially if discoloration, crystallization, or layering is
observed. If you believe that dangerous levels of peroxides may be present in a
container (e.g., observing visible signs of deterioration as listed in Section 3.5.3), immediately contact the Fire Department [dial
911 or, if using a cellular phone or dialing from offsite, 1 (925) 447-6880].
The Fire Department manages the response until it is determined that the
container does not pose an imminent hazard.
Peroxidizable chemicals are the best understood of the chemicals
with age-related hazards. However, age has played a role in incidents involving
other types of chemicals. Chemical/Biological Safety (CBS) shall set hazardous
chemical age-related limits based on known safety considerations using available
information, including consultation with knowledgeable people (e.g., chemists
performing research using such chemicals). Most chemicals will not be affected
by safety-related age limits.