Chapter 3 - Chemical Inventory and Tracking
This chapter identifies and consolidates existing user safety and health requirements found in DOE
and Federal chemical-related safety and health regulations and National Standards that address the
inventory and tracking of chemicals (see definition) and chemical products (see definition). State
and local codes and requirements are NOT included. This chapter specifically consolidates
requirements found in the Occupational Safety and Health Administration (OSHA), and certain
Environmental Protection Agency (EPA) regulations and Department of Energy (DOE) Rules and
Orders, including technical standards that are made mandatory by their specific reference within a
regulation, rule or DOE Order.
Direct requirements for an inventory and tracking system are found in OSHA's regulation
29CFR1910.1200, and EPA's 40CFR370.25. In addition, there are many regulations and standards
for which an inventory and tracking system is an implied requirement, since inventory information
facilitates compliance. Therefore, implied requirements are summarized here but are not included as
mandatory requirements in this chapter.
This chapter is intended to list chemical-related safety and health requirements and to consolidate
those that are overlapping and/or duplicative. The list of requirements includes "pointers" to the
sources of those requirements.
This document does NOT create any new or additional requirements.
The information presented here applies to all locations that use or store chemicals or chemical
products. It applies to chemicals prior to their becoming waste (See Disposition, Chapter 9, for
requirements for the disposition of chemicals and chemical products.) [NOTE: Throughout this
document, the term "chemicals" is used to indicate chemicals and/or chemical products as described
in Section 3, below.] This chapter consolidates existing, core safety and health requirements that all
sites must follow when engaged in chemical-related activities.
The requirements included in this chapter come from sources that have different safety purposes. As
a result, some of these requirements may not always be applicable to the work being performed at an
individual site or facility. It is the responsibility of each user to determine the applicability of specific
requirements to their work and how they are implemented. The reference sources for the
requirements included in this chapter can be used to determine the applicability of those requirements
to the work being performed.
3.0 Definitions and Acronyms
4.0 Requirements for Chemical Inventory and Tracking
[NOTE: The information that follows is a consolidation of existing Federal safety and health
requirements and national standards that relate to the inventorying and tracking of chemicals. It