Five Common Questions About Your Chemical Inventory

A chemical inventory is easy to build and hard to keep up to date, which is why so many of them quietly stop being accurate. The same handful of questions tend to come up in every organization, usually from whoever has just inherited the job. Here are five of them.

‍

What has to be included in a chemical inventory list?

Under OSHA’s Hazard Communication Standard, your written program must include a list of the hazardous chemicals known to be present, with each being identified using a product identifier referenced on the corresponding safety data sheet. The identifier must allow the chemical to be cross-referenced reliably between the inventory list, the container label, and the SDS.

‍

Do cleaning products and hand sanitizers need to be on a chemical inventory?

Usually not, but the exemption isn’t as broad as many people assume.

Consumer products are exempt where the employer can show they are used for the purpose the manufacturer intended, and the exposure is no greater in duration or frequency than a consumer would reasonably experience.

OSHA has given an example of where the line sits. Office cleaning products kept for staff to occasionally wipe down their own workstations fall inside the exemption. But if cleaning is somebody's job and that person uses chemicals routinely at a frequency or duration greater than ordinary household use, the exemption may not apply. In that case, the product may need to be covered by the employer’s Hazard Communication Program, including SDS access and training where applicable.

The same product may actually be exempt when used occasionally by office staff but covered when used routinely by cleaners. Every employer should assess and document the basis for applying any exemptions.

‍

How often should a chemical inventory list be updated?

OSHA doesn’t specify a fixed review interval for the chemical inventory list. [JP4.1] The written Hazard Communication Program, however, must include a list of the hazardous chemicals known to be present in the workplace, again identified using the product identifier referenced on the relevant SDS.

As such, the inventory list should be updated whenever a hazardous chemical is introduced, removed, or otherwise changes the chemicals known to be present. A scheduled review can help ensure the list remains accurate, but it shouldn’t be the only process for keeping it current. A list that was accurate in March and is wrong in June doesn’t become compliant because your review is scheduled for December.

The simplest solution is to treat inventory maintenance as an ongoing control. When a new chemical is purchased, the process should automatically trigger its assessment, an addition to the chemical inventory list, and the collection of the relevant SDS. Scheduled audits should verify the inventory but shouldn’t serve as the only time to update it.

‍

Does each site need its own chemical inventory list?

The list can be compiled for your workplace as a whole, or broken out by work sites.

The choice that suits you depends on how your team works. Breaking the chemical inventory list out by area can be useful on a large site where a maintenance crew has no reason to read the laboratory's inventory. A single list is easier to keep updated across a handful of smaller locations.

What often causes trouble is a hybrid of the two options, where each site keeps its own chemical inventory list in its own format, and no one holds a comprehensive view across all of them. That’s how the same product ends up on five lists under four different names.

‍

Who’s responsible for maintaining the chemical inventory list?

OSHA’s standard doesn’t say, which means the answer in practice is often whoever will actually do it.

One pattern that fails is the one where the chemical inventory list belongs to everyone. Someone keeps the list updated alongside a full-time operational job, purchasing sits with another department, and a new solvent can be ordered, delivered, and put to work without the person maintaining the list ever hearing about it.

The arrangement that works has one person accountable at each location and a connection to purchasing, so that buying a chemical and recording it are the same event rather than two things that depend on constant communication.

The chemical inventory list is the easiest part of hazard communication to get right, but also the easiest to quietly lose.

ChemAlert keeps your chemical inventory and safety data sheets connected in one place across every site, so a new product entering the business shows up in the record instead of slipping past it. See how it works at rmtglobal.com/us/chemalert/chemical-management-software.

‍