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Hazard Identification and Analysis - doe-hdbk-1139-2-20060021
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DOE-HDBK-1139/2-2006
The CSLM Manager should institute procedures for implementing the above policies on
reutilization and source reduction, and further institute procurement controls to minimize
chemical-related hazards. A recommended hazard control mechanism is to require chemical and
environmental hazard reviews of new procurement requests to identify chemicals that pose
unreasonable risk to workers or the environment. Purchases will not be made in such cases
without a written justification by the user and a thorough investigation of reduced risk
alternatives.
The preferred option is to eliminate the use of the hazardous chemical by choosing an
appropriate non-hazardous or less hazardous substitute. Where substitution is not feasible, the
minimum required amount should be procured. Another method of reducing hazards is by
reducing the qua ntity of hazardous chemicals onsite through the use of strategic-source and Just-
in- Time (JIT) contracts for high- volume chemicals and special- hazard chemicals (e.g., peroxide-
formers, NFPA Class 4 oxidizers, shock-sensitive chemicals and explosives ).
5.2.3
Chemical Inventory Management and Tracking
An inventory tracking system for the CSLM program will preferably be automated and will
contain electronic inventory records of all chemicals onsite. This system should integrate
information from multiple sources, including:
Inventory data throughout the entire chemical lifecycle covering procurement, storage, use,
transfer/movement, disposition, and final disposal;
MSDS data including product composit ion, CAS number, physical and health hazard
information, and hazard ratings;
Chemical regulatory information (such as threshold quantities (TQs), threshold planning
quantities (TPQs), and reportable quantities (RQs)); and
Data that are needed for facility safety basis verification.
Automated tracking of chemicals requires a complete record of site chemicals indicat ing, at a
minimum, locations, amounts, hazards, MSDS numbers, and custodians. The tracking and
inventory system should be able to generate all required regulatory information in support of
reporting requirements.
An automated tracking system will assist CSLM oversight by providing real-time (dynamic)
inventory of chemicals in all site facilities, enabling monitoring of special hazard chemicals,
identifying those chemicals subject to various regulations, and flagging chemicals with an
expired shelf- life so that they may be dispositioned appropriately. Integrating the use of bar-
coded labels or RFID tags with the tracking system can facilitate monitoring of newly purchased
chemicals throughout their lifecycle.
To ensure the quality of data in the tracking system, the site's chemical inventory should be
verified periodically through physical walk-downs of all site facilities as prescribed by the on-
site CSLM authority or Steering Committee.
10


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