Applies to: (examples; Faculty,Staff, Students, etc)
Faculty , Staff , Students
Faculty , Staff , Students
In order to comply with numerous regulatory requirements, the University of Health Sciences and Pharmacy in St. Louis must compile an annual inventory identifying the location (building and room) and quantity of all hazardous materials on campus. We have implemented an on-line inventory system known as MSDS Online (now known as Velocity EHS), which will be used to aide in the fulfillment of all regulatory requirements.
This policy applies to all UHSP investigators, faculty, staff, visiting scientists, postdoctoral fellows, students, scholars, and any other person working at or for UHSP.
Purpose
One of the major regulatory elements the inventory is used to fulfill is the OSHA Hazard Communication Regulation - 1910.1200 (HazCom). The purpose of HazCom is to ensure that the hazards of chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. In addition to the OSHA regulations for hazard communication, there are other regulations and guidelines, which require an inventory system.
Compliance
In order to achieve and maintain compliance, University of Health Sciences and Pharmacy in St. Louis has committed to inventorying chemical containers on site as described below in "Items REQUIRED to be Inventoried," except those exempted below under "Items NOT REQUIRED to be Inventoried". Initially, all labs will have to comply by manually inventorying all required material items mentioned in the "Items REQUIRED to be Inventoried" below. Thereafter, all hazardous and non-hazardous materials that are ordered through the purchasing system must be entered into the chemical inventory for each individual lab as they are received/accepted by each designated person. On an annual basis, each lab will be responsible for verifying that the items in the electronic inventory match what is currently found in the lab and other storage areas, such as common areas, refrigerators/cold rooms, and freezers. However, there are other materials which are highly regulated and may require more frequent inventory updates. These materials are items of interest to federal and local agencies, such as Department of Homeland Security, Centers for Disease Control and Prevention, Local Fire Department, etc. and are more controlled to prevent the following:
Items REQURED to Be Inventoried
Any, but not limited to, chemical containers that have a manufacture’s label which denotes physical or health hazards, or whose SDS denotes hazards, are to be included in the inventory. In general, laboratory chemicals and reagents are inventoried even if the hazard is considered low. Almost all chemicals received from chemical manufacturers such as Sigma-Aldrich, Fisher Scientific, Mallinckrodt Baker, Bio-Rad, Invitrogen, etc., will be included in the lab inventory. The list below provides some examples of common materials that need to be inventoried:
Items NOT REQUIRED To Be Inventoried
Even though some items may not be entered into the inventory, the user is still responsible to obtain a current SDS for the product. The list below provides some examples of common materials that do not need to be inventoried:
Note: Each PI or designated person(s) will be responsible for the proper hazard determination for all mixtures that are commonly made and used in the research lab. For hazard classification guidance concerning mixtures and solutions, the Hazard Communication Standard (29 CFR 1910.1200) states that a mixture (or solution) will be considered as having the same health hazards as the components that comprise ≥1% of the mixture (≥0.1% for known carcinogens in the mixture). If the PI or designated person(s) is not comfortable with making hazard determinations or is unsure about the hazard classification of a particular solution, they should consult with EH&S.
Resources to guide you through entering in chemicals can be found here:
Position/Office/Department |
Responsibility |
PI or laboratory designated person |
Properly determining hazards for all mixtures that are made and entering in ordered chemicals into the online inventory system. |
|
|
Name |
Contact Information |
Eric Knoll |
314-446-8375 |
Carlin Harp |
314-446-8133 |
DHS Appendix A: Chemicals of Interest (COI): https://www.dhs.gov/appendix-a-chemicals-interest-list
Federal Select Agent Program. Select Agents and Toxins List: https://www.selectagents.gov/selectagentsandtoxinslist.html
MSDSonline Help Center: http://help.msdsonline.com/products/hq