Attachment_2_EPA-RTP_OARM.pdf

OARM Chemical Inventory Management System Plan

April 5, 2017

Office of Administration and Resource Management (OARM)

Facility Management and Services Branch (FMSD) U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

MariaAColville Typewritten Text Attachment 2

ID10180005

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OARM Chemical Inventory Management System Plan April 2017 EPA Research and Administration Campus, RTP, North Carolina Page i

OARM Chemical Inventory Management System (CIMS) Plan

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

The mission of the U.S. Environmental Protection Agency (EPA) is to protect human health and safeguard the natural environment. Integral to this mission is the protection of employee, grantor, contractor, and visitor health and safety. This document has been prepared and the policies and procedures within are hereby instituted in order to comply with this mission. The EPA Research Triangle Park (RTP) Chemical Inventory System Management Plan contains requirements for practices and procedures to protect EPA-RTP Office of Administration and Resources Management (OARM) employees, OARM contractors, and visitors from hazardous chemicals.

This plan is intended to ensure compliance with Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.1200, Hazard Communication. This plan establishes a means of hazardous chemical inventory and tracking of hazardous chemicals procured, stored, used, and disposed of at the EPA-RTP campus and satellite locations. This plan applies to all EPA-RTP OARM employees, OARM contract employees, and visitors.

Arron Helm, Director

EPA Research and Administration Campus, RTP, North Carolina Page ii

Plan Updates & Reviews

Plan Review Date Reviewer Reviewer Signature Updates Made

- July 2012 Jonathon

Borntrager, BAH Contractor

Original plan.

1 September

Kaitlin Hartman, BAH Contractor

2 February

Kaitlin Hartman, BAH Contractor

Addition of roles & responsibilities; numerous changes to Section 4.0 to meet current procedures;

additions to align this plan with the ORD SOP

3 February

Kaitlin Hartman, BAH Contractor

No plan changes. Update to Director and hyperlinks.

4 March

Jeff Nichols, BAH Contractor

Update to Director. Added

OSHA 29 CFR 1910.1200,

Hazard Communication requirement for a chemical inventory in Section 2.

EPA Research and Administration Campus, RTP, North Carolina Page iii

OARM Chemical Management Plan

Table of Contents

1.0 Introduction

2.0 Objective

3.0 OARM Roles & Responsibilities

3.1 Facility Management and Support Division (FMSD)

3.2 On-site OARM FMSD SHEM Contractor

3.3 OARM Chemical Custodians

4.0 Chemical Procurement and Management

4.1 Procurement

4.2 Distribution

4.3 Chemical Container Barcoding Procedures

4.4 Storage

4.5 Removal from Inventory

5.0 Reprinting Barcode Labels

6.0 Chemical Inventory Management

7.0 Contact Information

8.0 References

Appendices Appendix A Guidance for Determining Chemical Hazards and Complying with the

OSHA Hazard Communication Standard (1910.1200)

Attachments Attachment 1 Do Not Barcode List (Items exempt from CIMS) Attachment 2 OARM New Chemical Procurement Approval Form Attachment 3 OARM Chemical Procurement Form Attachment 4 OARM Chemical Inventory Reconciliation Form

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EPA Research and Administration Campus, RTP, North Carolina Page 1

1.0 Introduction

Chemical management and control are the responsibility of all persons involved in the acquisition, distribution, use, and disposal of chemicals. The United States Environmental Protection Agency, Research Triangle Park (EPA-RTP) is accountable to local, state, and federal government agencies for the proper use and security of all hazardous (and non-hazardous) substances on our campus, and must adhere to strict guidelines for handling, labeling, storing, and disposing of hazardous substances. To satisfy these obligations, EPA-RTP has implemented a Chemical Inventory Management System (CIMS) managed by the Office of Research and Development (ORD) Safety, Health and Environmental Management (SHEM) office. The CIMS is applicable to the Main Campus only. The EPA Chapel Hill facility maintains their own chemical inventory.

The CIMS includes procedures for chemical management and a computerized inventory system to provide a perpetual record of all chemicals at this facility. The ORD SHEM office has utilized licensed software developed by Vertere to track the facility’s chemical inventory since 2000. The licenses and support contract for the software are managed and paid for by EPA Safety, Health and Environmental Management Division (SHEMD) located in Washington, DC.

The following procedures are specific to the Office of Administration and Resources Management (OARM) and detail how OARM will implement the EPA-RTP CIMS within OARM. This document is supplemented by the ORD SHEM Chemical Inventory Management with Vertere Inventory Manager Standard Operating Procedure. All OARM personnel (including contractors) must comply with these procedures and are urged to provide suggestions to improve these standard operating procedures.

Several items have been exempted from barcode requirements because they have been deemed by ORD SHEM to be either non-hazardous or unsuitable for the CIMS due to the duration and frequency with which they are used or stored at the various facilities at EPA-RTP. The Materials Exempt from barcoding can be found in Attachment 1 of this document.

2.0 Objective

The objectives of the CIMS are to:

1. Ensure that chemicals and their locations are properly identified.

2. Maintain an accurate inventory of chemicals and their locations to be accessed during an emergency event, as required by OSHA 29 CFR 1910.1200, Hazard Communication.

3. Develop accountability procedures to comply with:

a. Reporting requirements under the Emergency Planning and Community Right-to- Know Act, the Clean Air Act, and the Department of Homeland Security.

4. Facilitate the physical control of chemicals through maintenance of a standard tracking system ("bar-coding") and an automated chemical inventory management system.

5. Minimize the number and amount of chemicals stored throughout the facility.

6. Document and track chemical usage.

EPA Research and Administration Campus, RTP, North Carolina Page 2

3.0 OARM Roles & Responsibilities

3.1 Facility Management and Support Division (FMSD)

The overall responsibility for managing the chemical inventory for OARM and OARM contractors lies with the OARM FMSD office. However, everyone involved in the inventory control process plays a key role in maintaining the program.

Responsibilities of the OARM FMSD office include the following:

1. Ensure OARM contractor compliance with this program.

2. Coordinate and direct physical inventories of janitorial, café, and operation and maintenance (O&M) spaces.

3.2 OARM Safety & Occupational Health Manager

Responsibilities of the on-site OARM Safety & Occupational Health Manager / FMSD SHEM Contract Staff include following:

1. Approve for use all new chemicals prior to use at EPA-RTP.

2. Identify one person to serve as the primary user who is ultimately responsible for the management of OARM entries into the database.

3. Receive all significant changes to a chemical inventory from the OARM Chemical Custodians.

4. Supply barcode labels to OARM Chemical Custodians (received from Chemical Services Contractor), as needed.

5. Input data from incoming chemicals from facility O&M, janitorial operations, and café operations into the Vertere database.

6. Receive Barcode Reconciliation Forms from facility O&M, janitorial operations, and café operations and remove them from the inventory.

7. Conduct physical inventories annually to maintain accurate inventory information in the

CIMS.

3.3 OARM Chemical Custodians

OARM Chemical Custodians are identified in the Vertere database as the Contracting Officer Representative (COR) for each of the OARM related contractors (O&M, Janitorial, Cafeteria, and the FEELC). However, each contractor will designate an authorized representative to fulfill the role of the Chemical Custodian as detailed within this plan. Custodians are required to complete initial and annual chemical inventory management training facilitated by OARM.

Responsibilities of the OARM Chemical Custodians include the following:

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1. Attach barcodes to incoming chemicals and input data onto the OARM Chemical Procurement Form and turn into the on-site OARM FMSD SHEM Contractor for input into the Vertere database.

2. Store chemicals in such a manner that the integrity of the barcodes is maintained.

3. Return barcodes to the on-site OARM FMSD SHEM Contractor, on the Chemical Reconciliation Form, when containers are empty or at least monthly.

5. Notify the OARM FMSD Safety & Occupational Health & Safety Manager if there are significant changes to a chemical inventory (e.g., departure of a chemical custodian, transfer of materials to another location).

6. Reviewing annual chemical inventories of chemical storage/use areas for which they are responsible and ensuring that the inventory is consistent with the chemicals in those designated storage spaces.

7. Maintain Safety Data Sheets (SDSs) for each hazardous chemical in their inventory.

8. Submit a New Chemical Procurement Form for approval prior to purchasing a new chemical which has never been used or approved of previously.

4.0 Chemical Procurement and Management

The CIMS inventory provides a means of identifying hazardous substances used at our facility.

Any item that requires a Safety Data Sheet (SDS) should be considered for inclusion in the inventory.

4.1 Procurement

Approval by the OARM FMSD Safety & Occupational Health Manager is required when purchasing chemicals that have not been purchased previously. The New Chemical Procurement Approval Form (Attachment 2) and the chemical’s SDS must be submitted to the Contractor’s COR and the Safety & Occupational Health Manager for review prior to bringing a new chemical on campus. The Chemical Custodian and their COR will be notified through email upon chemical approval or will be asked to look for an alternate product if not approved. If an alternate product is required, it must also be approved by the OARM FMSD Safety & Occupational Health Manager prior to use.

Note: All pesticides, including common household insecticides, are prohibited from purchase or use on the EPA-RTP campus without prior approval by the IPM Committee Chair or their authorized representative (see the Integrated Pest Management Plan). All pest problems should be reported to the OARM FMSD Office.

4.2 Distribution

Chemical orders for an OARM contractor will be delivered directly to that contractor or may be routed through the EPA-RTP shipping and receiving area located in the Building A, C and/or D loading dock(s) on the first floor. OARM staff/contractors will then be notified of the chemical shipment for pick-up or for delivery to the respective storage locations.

EPA Research and Administration Campus, RTP, North Carolina Page 4

4.3 Chemical Container Barcoding Procedures

The Chemical Custodian (or their designee) is responsible for safely transporting the chemical to its’ designated location. Once the chemical(s) have been received in the designated location, the Chemical Custodian (or their designees) will be responsible for attaching a barcode to the chemical container. The chemical custodian shall also record the required information to the Chemical Procurement Request Form (Attachment 3), ensuring that the barcode information matches the contents. The Chemical Procurement Request Form must be turned in monthly to the OARM FMSD Safety & Occupational Health Manager (or designee). The barcoded labels will be adhered to containers, with the bottom of the bar-coded label facing the manufacturer’s label as shown below. Mixtures of chemicals (e.g. diluted spray bottles for satellite use) do not need to be barcoded. Do not cover the manufacturer label with the barcode.

The barcoded labels are small and only contain barcodes and a corresponding number.

The barcoded label is printed and attached by the chemical custodian, or their designee, for each chemical shipment before the chemical is stored or used. The barcode will be placed either on the box (i.e. one label per case) or on the chemical container (i.e. one label per bottle), depending on what was decided upon chemical approval between the OARM FMSD Safety & Occupational Health Manager and the Chemical Custodian. If the label is placed on the chemical container it should be placed on the container such that it minimizes curvature or disturbance to the barcode pattern as this can potentially hamper the scanner’s ability to read it. Pre-printed labels will be provided by the OARM Safety & Occupational Health Manager (or designee) to the Chemical Custodians periodically and/or as requested.

EPA Research and Administration Campus, RTP, North Carolina Page 5

4.4 Storage

Store the chemical container with the bar-coded label facing out to allow for easier visibility during the periodic chemical inventory by the OARM FMSD Safety & Occupational Health Manager (or designee).

4.5 Removal from Inventory

When the chemical containers have been used and the container has been emptied, remove the barcoded label and place the label on a Chemical Inventory Reconciliation Form (Attachment 4).

The Chemical Inventory Reconciliation Form must be submitted to the OARM FMSD Safety & Occupational Health Manager (or designee) monthly in order to be removed from inventory.

Empty containers should be appropriately disposed of.

The barcode label shall be left in place only if the contents of the container have not been removed and the chemical custodian wishes to either: discard remaining material as waste, or place remaining material into the Chemical Adoption Program. In order to place a material into the Chemical Adoption Program, the container with the barcode label intact must be taken to the chemical services area. Items returned to the chemical services area for disposal or adoption will be reassigned by the Chemical Services Contract Staff. The Chemical Services Contract Staff or the OARM FMSD Safety & Occupational Health Manager (or designee) will scan the sheet to remove the barcodes from inventory.

If a chemical has been determined to be a hazardous waste upon disposal, a Waste Pickup Request, Form 435e, must be completed and sent to the Chemical Services Contract Staff. Chemical Services can be reached by telephone at 541-4626 or 541-4957 respectively. Upon completion of the Waste Pickup Request, it should be submitted to Chemical Service Contract Staff either by hand or via email at: wastepickup@epa.gov. Waste should not be brought to these areas by staff.

Instead, staff should submit the Waste Pickup Request for processing, and pickup will subsequently be coordinated through the Chemical Services Contract Staff. If there are any

FISHER

Aq ui si tio n D at e

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EPA Research and Administration Campus, RTP, North Carolina Page 6 questions regarding how a chemical must be disposed of please contact the Chemical Services Contract Staff or the OARM FMSD Safety & Occupational Health Manager.

5.0 Reprinting Barcode Labels

The barcode labels are made of plasticized material with scratch and smear resistant ink and are designed to be used in laboratory environments.

In the event the barcoded labels become unreadable, damaged, or lost, the OARM FMSD Safety & Occupational Health Manager should be notified and the Chemical Custodian should create a replacement barcoded label for that chemical container and reconcile the system by removing the damaged barcode’s information. Any requests for new labels by OARM contractors/staff should be sent to the OARM FMSD Safety & Occupational Health Manager (or designee).

6.0 Chemical Inventory Management

In order to maintain an accurate inventory of the material on hand at the EPA-RTP Facilities, the OARM FMSD Safety & Occupational Health Manager (or designee) will conduct an annual chemical inventory. This process accurately updates quantities and types of chemicals at EPA- RTP used by OARM staff and contractors.

Chemical inventories will be accomplished in the following manner:

1. OARM facilities staff and contractors will be notified that a physical inventory will be conducted.

2. The Safety & Occupational Health Manager, or designated on-site contractor, will conduct the inventory and reconcile the data.

3. Missing items that cannot be located will be marked as “consumed” in the database and removed from the current inventory.

4. Any chemicals that are found that do not have a barcode will be barcoded and added to the database at the time of the inventory.

5. A copy of the updated chemical inventory will be forwarded to the contractor and their Project Officer once all data is reconciled and missing inventory is accounted for.

7.0 Contact Information

For any questions regarding bar-coded labels and/or the Chemical Inventory Management System, please contact:

• EPA-RTP OARM Safety & Occupational Health Manager: Kaitlin Hartman o Telephone: 541-3310 o Email: Hartman.Kaitlin@epa.gov

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8.0 References

[29 CFR 1910.1200] – Occupational Safety and Health Administration (OSHA) General Industry;

Hazard Communication

ORD’s Chemical Inventory Management with Vertere Inventory Manager Standard Operating Procedure

Appendix A - Guidance for Determining Chemical Hazards and Complying with the OSHA Hazard Communication Standard (1910.1200)

OSHA’s Hazard Communication (Hazcom) Standard is designed to ensure that the hazards of all chemicals produced or imported are classified and that information concerning the hazards is transmitted to employers and employees. This will provide sufficient information for employers and employees to anticipate, recognize, evaluate and control chemical hazards and take appropriate protective measures to minimize illnesses and injuries related to chemical exposures.

Let’s get started by looking at a couple of key terms:

What exactly is a chemical? OSHA defines a chemical as any substance, or mixture of substances.

Okay, so what is a substance? OSHA defines a substance as chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.

Basically, the definition of chemical, as used in the Hazcom Standard, can apply to virtually any product or material. Although virtually all materials are considered “chemicals” under this definition, the Hazcom Standard identifies certain categories of chemicals that are not covered by the standard. These categories are as follows:

Any hazardous waste as defined by the Solid Waste Disposal Act when subject to regulations issued under that Act by the Environmental Protection Agency;

Any hazardous substance as defined by the Comprehensive Environmental Response, Compensation and Liability Act when the hazardous substance is the focus of remedial or removal action being conducted under that Act in accordance with Environmental Protection Agency regulations;

Tobacco or tobacco products;

Wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard they pose to employees is the potential for flammability or combustibility (wood or wood products which have been treated with a hazardous chemical covered by this standard, and wood which may be subsequently sawed or cut, generating dust, are not exempted);

Articles, defined as a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard or health risk to employees.

Food or alcoholic beverages which are sold, used, or prepared in a retail establishment (such as a grocery store, restaurant, or drinking place), and foods intended for personal consumption by employees while in the workplace;

Any drug, as that term is defined in the Federal Food, Drug, and Cosmetic Act, when it is in solid, final form for direct administration to the patient (e.g., tablets or pills); drugs which are packaged by the chemical manufacturer for sale to consumers in a retail establishment (e.g., over-the-counter drugs); and drugs intended for personal consumption by employees while in the workplace (e.g., first-aid supplies);

Cosmetics which are packaged for sale to consumers in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace;

Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act and Federal Hazardous Substances Act, respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended;

Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard covered under this section;

Ionizing and nonionizing radiation; and

Biological hazards.

The Hazcom Standard requires that an inventory of hazardous chemicals found in the workplace be put together and that each chemical on the inventory have a safety data sheet available for use.

The Standard defines a hazardous chemical as any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. The following is a list of hazard categories as identified by the Hazcom Standard:

Physical Hazards Health Hazards Fire Hazards Systemic Effects

Combustible liquid Carcinogen Flammable liquid Toxic agent Flammable aerosol Highly toxic agent Flammable gas Corrosive Flammable solid Irritant Oxidizer Sensitizer Pyrophoric Target Organ Effects

Explosion Hazards Hepatotoxin Compressed gas Nephrotoxin Explosive Neurotoxin

Reactive Hazards Blood/hematopoietic toxin Organic peroxide Respiratory toxin

Physical Hazards Health Hazards Unstable (reactive) Reproductive toxin Water-reactive Aspiration toxin Cutaneous hazard

Eye hazard

Keep in mind, the hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered and must be included in the inventory. If it is not hazardous, it is not covered. If there is no potential for exposure, (e.g., the chemical is inextricably bound and cannot be released), the rule does not cover the chemical. Also, it is the chemical manufacturer’s responsibility to perform a hazard determination and provide such information on their products in the form of a safety data sheet. This will provide employers and employees with the information needed to take proper protective measures to minimize illnesses and injuries related to chemical exposures.

Attachment 1 - Do Not Barcode List (Items exempt from CIMS)

DO NOT BARCODE LIST

Items exempt from Chemical Inventory Management System

(Revised 6-19-14)

Item or Material Activated Charcoal Agar Prep Materials (Nutrient Broth) Agarose Alumina (Aluminum Oxide) Analytical Grade Electrode Cleaner Anion Exchange Resin Biological Products:

enzymes (–ase suffix), proteins, amino acids, antibodies, glucose, dextrose, maltose, sucrose, sucralose, glycogen, fetal bovine (calf) serum (FBS), etc.

Boiling Stones (also called Hengar Granules) Buffer Solutions:

Tris, EDTA, EGTA, HEPES, Versene, Phosphate Buffer Solution (PBS), Saline Solutions, Hanks Balanced Salt Solution, Dulbeccos phosphate buffered saline (DPBS), Earle’s balanced salt solution, Trypsin, etc.

Cellulose Powder Cleaners/Detergents – Household and Commercial (Examples of commercial cleaners are Triton X-100, Tween, etc.)

Compressed air for cleaning (ex: Duster II) Corn Oil Drierite Florisil (synthetic magnesium silicate) Gelatin Glass Wool Glycerol Ion Exchange Resin (ex.: resin beads) Kits:

PCR purification, DNA/RNA isolation, cloning kits, sequencing kits Leak Detector (Snoop or bubble solutions) Lubricating Oil (for Laboratory Use) Magnesium chloride Magnesium sulfate (ex.: Epsom salts) Mineral Oil (for Laboratory Use) Molecular Sieve Beads (ex: glass beads) Polystyrene microspheres Potassium Acetate Potassium Bicarbonate Potassium Phosphate (prefix: mono-, di-, tri-) Potassium Sulfate Sample Preparation Cartridges

Item or Material Sand, White Quartz Silica Gel Sodium Acetate (sodium ethanoate) Sodium Bicarbonate (sodium hydrogen carbonate) Sodium Chloride Sodium Phosphate Sodium Sulfate (Sodium Dodecyl Sulfate (SDS) and Sodium Lauryl Sulfate (SLS)) Tissue Culture Media (all types):

Dulbecco’s Modified Eagle’s Medium (DMEM), Modified Eagle’s Medium (MEM), Iscove’s Mofidied Dulbecco’s Medium (IMDM), Ham’s tissue culture medium (F12), RPMI 1640, F10 nutrient mixture, etc.

Ultra Clean Resin Urea Uric Acid Water XAD Resin X-gal (BCIG)

Attachment 2 - New Chemical Procurement Approval Form

March 27, 2017

NEW CHEMICAL PROCUREMENT APPROVAL FORM

(for OARM use only)

INSTRUCTIONS

All new chemicals purchased by OARM or an OARM contractor must be approved by the OARM Safety & Occupational Health Manager prior to purchase. This form must be filled out and submitted to Kaitlin Hartman at hartman.kaitlin@epa.gov along with a copy of the Safety Data Sheet (SDS) for approval prior to new chemicals being brought to EPA-RTP.

CHEMICAL/PRODUCT INFORMATION

Date:

Product Name:

Manufacturer:

Primary CAS#:

Product Number:

Volume: Container Type:

Storage Location:

Describe Planned Chemical Use:

(include working dilution, if applicable, and anticipated frequency of use)

Flammable or Combustible Material? Yes No Reactive Material? Yes No Corrosive Material? Yes No Health Hazard? Yes No Aerosol? Yes No Drain Disposed? Yes No Will Chemical become Hazardous or Universal Waste? Yes No Meets EPA Green Purchase Guidelines Yes No

CHEMICAL/PRODUCT APPROVAL SIGN OFF

Approved By:

Date:

Product to be barcoded by: The container or bottle The case or box

Attachment 3 - OARM Chemical Procurement Request Form

EPA-RTP OARM Chemical Procurement Form

Month/Year: __________________

Return to OARM SHEM Office electronically or to C661-C Please call 1-3310 with any questions

Instructions: For OARM use only. Any chemical that has not been previously procured and used on-site at the EPA-RTP facility, please submit a Safety Data Sheet (SDS) and the New Chemical Procurement Approval Form to the OARM FMSD SHEM office prior to purchasing for approval. For previously procured chemicals, please enter the fields below, along with the preprinted bar code number.

Please note any other changes when applicable (i.e. change from 1 gallon to 5 gallons). Submit this form to the OARM FMSD SHEM office monthly.

Acquisition Date (mm/dd/yy) Product Name Manufacturer

Name Product or Stock

Number Volume

& Unit of Measure

Container Type (Box, Plastic

Bottle)

Storage Location

(Room #) Barcode #

Name Product or Stock

Number Volume

& Unit of Measure

Container Type (Box, Plastic

Bottle)

Storage Location

Name Product or Stock

Number Volume

& Unit of Measure

Container Type (Box, Plastic

Bottle)

Storage Location

Attachment 4 - OARM Chemical Inventory Reconciliation Form

EPA-RTP OARM Chemical Inventory Reconciliation Form

Instructions: For chemicals ready for disposal, remove the preprinted barcode and place in the designated field below. Initials should be of the person removing the barcode from the chemical for disposal. Return this form to the OARM FMSD SHEM office at the end of every month.

Barcode Date Removed Initials