Chemical Inventory

The simple answer is that it is required by laws that the university must comply with. Those laws include the Emergency Planning and Community Right-to-Know Act (EPCRA), the Texas Community Right-to-Know Act (TCRA, Health & Safety Code, Chapters 505, 506 & 507), the federal Hazard Communication Act, and the Texas Hazard Communication Act (Texas Health & Safety Code, Chapter 502).

Chemical inventory should be conducted at least twice per year. As new chemicals are received or unneeded/expired chemical are removed, the inventory should be updated to include those changes. Essentially, a working chemical inventory should be maintained at all times, but staff should go through the inventory at least twice per year to verify that the inventory is correct.

An email will be sent out twice per year requiring all inventory owners to review their inventory and sign the Chemical Inventory Review Statement. The statements must be submitted by January 31st and July 31st of every year.

Your inventory is used for two important purposes.  First and foremost, it is used to aid EHSREM and local emergency responders in assessing hazards that may be present in your lab/building during an emergency event. 

In addition, your inventory is used to compile a report required by the federal and Texas Community Right-to-Know Acts, known as the Tier II Chemical Inventory report. The report is required to be submitted annually to the Texas Commission on Environmental Quality. 

The final report provides information to the state and local emergency responders on chemicals which meet or exceed specified reporting thresholds at any time during a calendar year. In order to calculate if the university has met or exceeded these thresholds, it is necessary to obtain a chemical inventory from all laboratories, shops, warehouses, or other offices who house hazardous materials or chemicals every year. 

Once all inventories are received, EHSREM compiles all of this data and determines whether thresholds have been exceeded for each chemical. If any chemicals used or stored at the university collectively exceed the threshold, EHSREM reports those chemicals, along with their locations and volumes, to the TCEQ and the Local Emergency Planning Committee.

All primary containers of chemicals, compressed or cryogenic gases, and controlled substances should be included in your inventory. Mixtures and solutions made from chemicals in these primary containers (including hazardous waste) should not be included as this leads to duplication and over-reporting of quantities.

Chemicals that must be included in your inventory may include, but are not limited to the following:

• Highly toxic materials: oral LD50 ≤ 50mg/kg; inhalation LC50 ≤ 200ppm (2mg/l); or dermal LD50 < 200mg/kg.
• Toxic materials: oral LD50 50-500mg/kg; inhalation LC50 200 - 2000ppm (2 - 20mg/l); or dermal LD50 200 - 10000mg/kg.
• Explosive materials as defined by the U.S. Department of Transportation, 49 CFR 172, Subpart B.
• Extremely Hazardous Substances as defined by 40 CFR 355, Subpart D.
• Flammable or combustible liquid, solid, or gas.
• Carcinogenic, mutagenic, or teratogenic materials.
• Pyrophoric, water-reactive, or peroxide forming materials.
• Compressed or cryogenic gas.
• Strong acids or bases.
• Reducing agents.
• Oxidizers, such as nitrates, iodates, perchlorates, or organic peroxides.
• Toxins of biological or synthetic origin (e.g. diphtheria toxin, conotoxins, endotoxins, cholera toxic, etc.).
• Controlled substances (DEA listed materials).
• Chemicals of Interest (DHS listed materials).
• Any other hazardous substance, not listed in previous bullet points, that has an NFPA 704 or HMIS hazard rating of greater than or equal to 1. For the NFPA or HMIS ratings, consult the material's Safety Data Sheet.

While EHSREM recommends that ALL chemicals be included in your inventory, certain non-hazardous chemicals may be excluded. You may exclude the following:

• Water.
• Non-hazardous buffers, sugars, and salts.
• Growth media without toxic components.
• Non-toxic biochemicals (e.g. nucleotides, enzymes, protein extracts, lipids, nucleic acids, etc.).
• Commercial assay kits.
• Secondary containers of mixtures and solutions made from chemicals in primary containers (including hazardous waste).
• Retail products used for routine household-like activities (e.g. cleanser, soaps, bleach, etc.) with a duration and frequency of exposure that is equivalent to a consumer's home use, and which do not appear on the list in the previous section.

No, but the bottles must be labeled in accordance with the University’s Chemical Hygiene Plan.

Only if you maintain those household cleaners for something other than their intended purpose. For example, if you are using Windex as part of a chemical process, then you must report the Windex in your chemical inventory; however, if you have Windex to clean your windows, then you do not have to add it. 

Yes, a CAS number is required since chemical names can vary greatly. You can find CAS numbers on the Safety Data Sheet or you can visit CAS Common Chemistry to search the CAS number by chemical name.

Note: A CAS number is separated by hyphens into three parts: the first consisting from two up to seven digits; the second consisting of two digits; and the third consisting of a single digit. There should be no spaces between hyphens or numbers. The CAS number should not contain any letters, and the hyphen must be used in its proper location.

The University’s Chemical Hygiene Plan requires that you record the date received and date opened on each chemical container.  It is helpful to include this information on your inventory.

Disposal of old or expired chemicals is required by the University’s Chemical Hygiene Plan.  EHSREM can help you dispose of expired, old, and unwanted chemicals.  If you have a large number of bottles to dispose of, contact EHSREM (512-245-3616) for assistance and guidance.  Otherwise, place the chemicals in your Satellite Accumulation Area (SAA), and fill out the Hazardous Waste Pickup Request form.