OEH&S Chemical Safety Manual Chapter 10

CHEMICAL INVENTORIES

Federal and California laws provide for “cradle to grave” regulation of hazardous chemicals. In California, the California Department of Toxic Substances Control is the state’s lead agency in implementing these regulations. One regulation (Chapter 6.95 Sections 25500 et.seq. of the Health and Safety Code) requires each California business to submit a Business Plan, describing how the business plans to handle hazardous chemicals. This information is intended for use by local emergency agencies, such as fire and police, providing awareness of hazards to be encountered at that business.

This regulation is implemented at the city or county level; for UCSF the implementing agency is the City and County of San Francisco’s (CCSF) Department of Public Health (DPH). The CCSF can establish “inventory reporting thresholds” for the businesses under its jurisdiction. For San Francisco, the reporting threshold is 25 grams or 100 milliliters of a chemical, or 100 cubic feet of compressed gases or liquids. Chemicals that present known hazards (toxic, carcinogenic, …) must be included regardless of the quantity present.

The requirements of the Business Plan include two major elements that directly affect the laboratories at UCSF:

• DPH will perform regular (annual or biannual) inspection of all laboratory areas.
• Each laboratory must submit an annual inventory of all chemicals in that laboratory.

• The name of the chemical.
• The manufacturer’s name.
• The manufacturer’s product number.
• The container type.
• The maximum quantity on hand.
• The annual usage of that chemical.
• The California Waste code for the chemical, if applicable.

OEH&S is responsible for collecting and submitting the inventories; upon request each laboratory is expected to submit the updated inventory to OEH&S. OEH&S personnel are available to assist Principal Investigators or supervisors in preparing the annual inventory.

The annual inventory process is an excellent time for laboratory personnel to review their use of each chemical and to consider:

• Alternate, less hazardous chemicals as substitutes.
• Purchase of smaller containers of chemicals to decrease quantities on hand.
• Disposal of chemicals which have not been used.
• Disposal of outdated chemicals.
• Verifying that purchase date has been written on each container.
• General housecleaning.

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