Overview
Weill Cornell Medical College (WCMC) is required to
maintain an inventory of all hazardous chemicals and report annually on the
types, quantities and locations where these chemicals are being stored and used
at the College. All locations which store and/or use hazardous chemicals must
maintain a complete and current inventory for their area. On an annual basis,
the chemical inventory must be submitted to Environmental Health and Safety
(EHS). EHS will compile all the chemical inventories for the College and submit
the annual WCMC chemical inventory reports to the appropriate Federal and local
government agencies as part of the Community Right-to-Know Program. Information
reported to external agencies is generalized by building and does not contain
any personal identifying information. More detailed information is kept in the
EHS Office and made available during an incident requiring emergency response in
an area storing hazardous materials. In order to facilitate this process, all
chemical inventories must be completed electronically on the EHS-formatted
Chemical Inventory Form (MS Excel spreadsheet) and submitted annually according
to this procedure.
Applicability
This inventory is required of all areas (e.g.
laboratories, clinics, service areas, mechanical rooms, print shops) that store
and/or use hazardous chemicals (i.e. chemicals which possess a physical or
health hazard). Refer to the chemical抯 Material Safety Data Sheet (MSDS) to
determine if the chemical is hazardous. Unless the manufacturer states the
chemical is non-hazardous, the chemical should be assumed to be a hazardous
chemical.
Definitions
Hazardous chemical means any chemical which
has a physical hazard or a health hazard.
Health hazard means a chemicals which are
carcinogens, toxic or highly toxic agents, reproductive toxins, irritants,
corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which
act on the hematopoietic system, and agents which damage the lungs, skin, eyes,
or mucous membranes.
Physical hazard means a chemical for which
there is scientifically valid evidence that it is a combustible liquid, a
compressed gas, explosive, flammable, an organic peroxide, an oxidizer,
pyrophoric, unstable (reactive) or water-reactive.
Responsibilities
Environmental Health and Safety (EHS)
obtains current copies of all chemical inventories; prepares and submits
chemical inventories to appropriate government agencies; and provides assistance
and training on completing the chemical inventory as needed.
Principal Investigators and Directors
ensure a chemical inventory for their area(s) is maintained, including updating
as chemicals are added or removed from the area, and that the inventory is
submitted to EHS annually by the first week of January using the EHS-supplied
Excel Spreadsheet.
Procedure
The following procedure must be utilized to
complete the chemical inventory and submit it to EHS:
1. Obtain a copy of the EHS-formatted Chemical
Inventory Form (MS Excel spreadsheet) from the EHS?website (http://www.med.cornell.edu/ehs/forms/ChemicalInventory.xls).
This is the only inventory form version and format which is acceptable. Contact
EHS if assistance is needed in using the form.
2. A separate Chemical Inventory Form must be
created for each unique Principal Investigator or Director. However, each
Principal Investigator or Director may enter chemicals from multiple locations
onto the same Chemical Inventory Form. Enter the following information into the
Chemical Inventory Form:
- PI / Director ? Enter the name of the
Principal Investigator for a laboratory or the Director responsible for
non-laboratory areas (e.g., clinics, service areas, print shops).
- Department ?Enter the official department
name for the area(s).
- Division ?Enter the official division name
for the area(s).
- Inventory Date ?Enter the date the
inventory was last updated.
- Bldg ?Enter the official building code
where the chemicals are located.
- Room ?Enter the room number where the
chemicals are physically located. The room number should be indicated on a
placard adjacent to the entrance to the area.
- Full Chemical Name ?Write out the full
chemical name of each hazardous chemical. Abbreviations and chemical
nomenclature are not acceptable.
- Volume ?Enter the estimated total
volume or weight (numerical value only) of the chemical located in the
designated room number. Do not enter the unit of measure in this field.
Enter the unit of measure in the UM field to the immediate right of the Volume
field.
- UM ?Enter the correlating unit of measure
for the total volume using the appropriate unit of measure abbreviation
indicated on the Chemical Inventory Form.
- Manufacturer (optional) ?If desired, enter
the Manufacturer of the chemical.
- Comments (optional) ?Enter any additional
information.
- MSDS ?Utilize this annual submission of the
chemical inventory to verify a Material Safety Data Sheet is available for each
hazardous chemical in the area. The MSDS is created by the chemical manufacturer
and should be obtainable by contacting the manufacturer. Contact EHS if
assistance is required or visit the MSDS page at http://www.med.cornell.edu/ehs/msds.htm.
3. Email the Chemical Inventory Form to ehs@med.cornell.edu by the first week of
January.
4. Contact EHS with
any questions on completing and/or submitting the Chemical Inventory
Form.
References
EPA - SARA Title III - Emergency Planning and
Community Right-to-Know Act OSHA 1910.1200 - Hazard Communication Standard OSHA
1910.1450 - Occupational Exposure to Hazardous Chemicals in Laboratories Title
15, Chapter 41-05 of the Rules of the City of New York