From: Frankie Wood-Black <FWood-Black**At_Symbol_Here**TRIHYDRO.COM>
Subject: Re: [DCHAS-L] Chemical Inventory Regulations
Date: September 10, 2012 6:57:40 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <C119D3AA0D71314C8685D324C07D9D5982A5B801DF**At_Symbol_Here**>

It is the SARA Community Right to Know - Google List of Lists - it has the specific references.

I have gotten the List of Lists (which convers EPCRA, SARA, RCRA, Clean Air Act) and the CFATS (Anti-Terrorism List) - there used to be an ATF (alcohol, tobacco and firearms) list, but I think it has been rolled into the CFATS list. I know there are exemptions and potential other requirements - if it is a drug precursor (DEA), a bioagent, covered under FIFRA (insecticide, biocide, and/or rodenticide), or a material covered under the NRC.

The ATF list that used to be at 27 CFR 55.23 was moved to 27 CFR 555.23, then ended up in ATF Publication 5400.8
The most current List of Explosive Materials (2011R-18T) was published in the Federal Register / Vol. 76, No. 202 / Wednesday, October 19, 2011 pg 64974

The Laboratory Exemption for Explosive Materials is found at 27 CFR 555.141 (9)

(a) General. Except for the provisions of 555.180 and 555.181, this part does not apply to:
Industrial and laboratory chemicals which are intended for use as reagents and which are packaged and shipped pursuant to U.S. Department of Transportation regulations, 49 CFR Parts 100 to 177, which do not require explosives hazard warning labels.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Debra Brickey
Sent: Sunday, September 09, 2012 5:52 PM
Subject: [DCHAS-L] Chemical Inventory Regulations


I was wondering if anyone could provide me with the regulations that specifically state that a chemical inventory is required rather than a should or best practice? How frequently must a chemical inventory be updated?

Does the International Building Code (IBC) or the International Fire Code (IFC) require a chemical inventory?

I am working on a presentation to justify the implementation of a electronic chemical inventory such as Chemtracker or ChemSW rather than an annually updated spreadsheet system.

I would appreciate your advice.


Debra Brickey, PhD CBSP
Research Safety Manager
Oregon Health & Science University

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