Requirements for Chemical Inventory and Tracking cont'd

DOE-HDBK-1139/3-2003

therefore contains "shall" statements that are taken from, or based on "shall" statements in those

existing requirements. While requirements from national standards that are referenced here are not,

in and of themselves, mandatory, they are made mandatory by DOE and Federal requirements,

including OSHA regulation 29CFR1910.6, which incorporates them by reference. DOE O 440.1A

mandates compliance with OSHA regulations found in Title 29 of the Code of Federal Regulations

(CFR). National standard requirements referenced here are thereby made mandatory for DOE

contractors through contracts that include DOE O 440.1A. Please see the Introduction to this section

of the Chemical Management Handbook for more information.]

Sources10

Consolidated Requirements

4.1 Chemical Inventory Requirements

4.1.1

Maintain a list of the hazardous chemicals known to be

29CFR1910.1200(e)(1)

present using an identity that is referenced on the

appropriate material safety data sheet (the list may be

compiled for the workplace as a whole or for individual

work areas).

[NOTE: Some chemical specific regulations, such as those

for Asbestos and Beryllium, may also contain their own

inventory tracking requirements.]

4.1.2

The owner or operator of a facility shall annually submit an

40CFR370.25(a) to (d)

inventory form (Tier 1 or equivalent State or local form)

containing information on specified hazardous chemicals

present at the facility during the preceding calendar year

above specified threshold levels to the state emergency

response commission, the local emergency planning

committee, or the fire department with jurisdiction over the

facility. For any specific hazardous chemical at the facility,

the owner or operator may submit a Tier II form

(40CFR371.41) in lieu of the Tier I information.

4.1.3

For laboratories chemical inventories shall be maintained

NFPA 45, 7.2.3.3

within facility limits.

While requirements from

4.2 Implied Chemical Inventory Requirements.

national standards that are

There are many mandatory standards that do not directly require an

referenced here are not, in and

inventory of hazardous chemicals, but for which use of a chemical

of themselves, mandatory, they

inventory and tracking system would be necessary for, or would

are made mandatory by DOE

facilitate compliance. A list of major standards with implied

and Federal requirements,

requirements for keeping a chemical inventory and/or for tracking

including OSHA regulation

chemicals follows. The applicability of specific DOE Orders will

29CFR1910.6, which

depend on each site's individual contract.

incorporates them by reference.

DOE O 440.1A mandates

compliance with OSHA

regulations found in Title 29 of

the Code of Federal Regulations

(CFR). National standard

requirements referenced here

are thereby made mandatory for