Attachment X Chemicals Management Procedures.pdf

CENTER FOR DOMESTIC PREPAREDNESS

FACILITY OPERATIONS AND SUPPORT SERVICES

ATTACHMENT X

Chemicals Management Procedures

FOR OFFICIAL USE ONLY

STANDARD OPERATING PROCEDURE

Organization: Center for Domestic Preparedness Date: September 24, 2014

Title: Chemicals Management

CDP-COBRATF-OPS SOP 001.0

I. Purpose

To control use of chemicals that might result in interference with toxic agent air monitoring either by MINICAMS or DAAMS.

II. Supersession

This is the initial issue of this document.

III. Authority

Chemical Surety Program Standards Document

IV. References

Air Monitoring Plan

V. Acronyms and Definitions

A. AD – Assistant Director

B. DAAMS – Depot Area Air Monitoring System

C. IH – Industrial Hygienist

D. MINICAMS – Miniature Continuous Air Monitoring System

E. MSDS – Material Safety Data Sheet

F. OM – Operations Manager

G. POC – Point of Contact

H. SDS – Safety Data Sheet

VI. Responsible Office

Operations Manager

VII. Standard Operating Procedures

NOTE: Whenever a user determines that they need to utilize a chemical at the

COBRATF, they must obtain written approval for use from the AD prior to that use; to facilitate approval, OPSF 001 must be filled out as outlined below.

A. Chemical Use and Justification

1. Use Requestor (Name & Company): Enter the name of the company that will use the chemical and the designated POC including phone number and email address.

CDP-COBRATF-OPS SOP 001.0

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2. Item Name and Description: State the name exactly as it is listed on the MSDS/SDS

(must be attached to form) as well as its “common” name. Provide a general description of chemical’s use (e.g. herbicide, epoxy paint, etc.).

3. Proposed Use Location: Clearly state where the chemical will be used on the site (e.g.

outer perimeter fence, bay 5 floor sealing, etc.).

4. Description of and Justification for Use: State why use of this chemical is required, how much will be used and how often. If the chemical is a known interferent, state why this chemical should be used rather than a previously reviewed non-interferent

(MINICAMS interference list is available on a common computer drive).

5. The user forwards the completed form, with the MSDS/SDS, to the OM for preliminary review.

B. Preliminary Review of Exclusion from Testing

1. The OM reviews the information provided and makes an initial determination as to whether the data warrants exclusion from further testing. Examples include but are not limited to: 1) the location of use is well outside any air monitoring location so it does not require testing; or 2) the same chemical was previously tested for use in one area and the request is to approve use in another area based on the previous test data.

2. If the OM concurs with the exclusion, skip to block E.2 (IH/CHO Review) on OPSF

001.

3. If the OM does not concur with the exclusion, the OM notifies the user to coordinate with the Chemist for sample collection and testing (documented on block C of OPSF

001, Sample Chain of Custody and Analysis).

C. Sample Chain of Custody and Analysis

1. The user must coordinate with the chemist regarding the quantity and type of sample prior to the collection of the sample; including proper container and labeling. The user then collects the sample and properly labels.

2. Record sample collection data including printed name of individual who collected and packaged sample, signature and date/time on OPSF 001. If the sample is transported by someone other than the collector, complete the subsequent chain of custody blocks.

3. The receiving laboratory representative inspects the sample to ensure it is in the proper sample container and is the quantity required. The label is checked to ensure it matches the form and MSDS/SDS. The laboratory representative signs and dates the chain of custody section.

D. Laboratory Results

1. The Lead Air Monitoring Technician, in coordination with the Chemist, determines the proper instrument calibration level.

2. The sample is analyzed using established procedures. The analyst records a summary of the results on OPSF 001 including any observed analytical issues beside agent interference. The air monitoring packet should include the form, MSDS/SDS, chromatogram, results printout and any other relevant data.

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3. The completed air monitoring packet is sent to the Chemist for quality review and final determination that the chemical is or is not an interferent.

E. Conditions of Use Review

1. The Chemist provides recommendations with regard to any further testing required

(e.g. DAAMS tube sampling to determine if it can be differentiated from agent should the need arise, etc.). The Chemist also recommends any sample points for deselection or other conditions of use limit recommendations. The packet is then forwarded to the

IH/CHO.

2. Similar to the Chemist review, the IH/CHO reviews the data and recommendations from the Chemist and either concurs or makes additional conditions of use limit recommendations. The IH/CHO forwards the packet to the OM.

3. Similar to the Chemist and IH/CHO reviews, the OM reviews the data and recommendations from the Chemist and either concurs or makes additional conditions of use limit recommendations. The OM forwards the packet to the AD for final action.

F. Approval for Use

1. If the AD does not approve the chemical for use at the COBRATF under any conditions, block F.1 is signed and dated.

NOTE 1: Approval for use of a chemical is contingent on the user complying with all conditions specified in block F.3.

2. If the AD approves use, block F.2 is signed and dated.

NOTE 2: In addition to these listed conditions, the use location and description contained in part A are also required. If the user decided to use the chemical at locations other than those listed in part A, or in a quantity or manner other than listed in part A, a new or revised form must be completed.

NOTE 3: Failure of a user to fully comply with all the conditions of use will result in immediate suspension of the use approval and a full review of the specified conditions. Self-reporting is required.

3. Block F.3 is used to identify all special use approval conditions, such as but not limited to, location, time, quantity and other conditions of use including approved sample deselect sample points.

4. After signing OPSF 001, the AD returns the packet to the OM. The OM forwards the packet to MINICAMS for distribution. The original is retained by MINICAMS with a copy provided to the user and the Chemist.

VIII. Forms Prescribed

CDP COBRATF OPSF 001, COBRATF Chemicals Management Form

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APPROVED BY:

Gary L. Milner Date

Assistant Director, COBRATF

Center for Domestic Preparedness

Quality Review Date Chemical Hygiene Review Date

James Johnstone John Blandamer