From: Michael Ng <Michael.Ng**At_Symbol_Here**LIU.EDU>
Subject: Re: [DCHAS-L] Chemical Inventory Regulations
Date: September 10, 2012 8:40:41 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <34F6B23D8B008F48828D4D0B76ACAEB21747239C**At_Symbol_Here**EX10.trihydro.com>

Hi Debra,

The Emergency Planning and Community Right-to-Know Act of 1986 is what you
are looking for. It is under the Superfund Amendments and Reauthorization
Act (SARA). This law applies to all facilities that use or store hazardous
materials. SARA Title 313 has a list of chemicals of interest, whereas
reporting is required if the quantity of the chemical of interest exceeds
the reported threshold quantity.

Each state has a Community Right-to-Know reporting / filing scheme. In
NYC, we have the NYC Department of Environmental Protection Community
Right to Know Tier II Online Filing. NYC DEP has a more stringent list
compared to SARA Title 313.

Oregon has its own unique Community Right-to-Know regulations. Here is the
link.

http://cms.oregon.gov/OSP/SFM/Pages/CR2K_Home.aspx#Hazardous_Substance_Rele
ase_Reporting

http://cms.oregon.gov/osp/SFM/docs/cr2k/cr2k_general/surveyinstrbook.pdf


Hope that helps.

Michael Ng
Environmental Health and Safety Manager
Long Island University Brooklyn Campus
Buildings and Grounds
1 University Plaza M101
Brooklyn, NY 11201
Tel: (718)-488-1608
Fax: (718)-488-3337
michael.ng**At_Symbol_Here**liu.edu


On 9/10/12 6:57 AM, "Frankie Wood-Black" wrote:

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
http://www.gpo.gov/fdsys/pkg/FR-2011-10-19/pdf/2011-26963.pdf

The Laboratory Exemption for Explosive Materials is found at 27 CFR
555.141 (9)
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=13a29c83dc9499be9
4a6c6ea22d53920&rgn=div8&view=text&node=27:3.0.1.3.5.8.31.1&idno=27

(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
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Chemical Inventory Regulations

All,

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.

Regards,

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

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