All labs are required to maintain an updated chemical inventory in accordance with CalEPA, Office of the State Fire Marshal, Cal-OSHA, Los Angeles Fire Department (LAFD), and USC policies. An accurate chemical inventory is essential for emergency planning and incident response.
Currently, chemical inventories are maintained and updated in EHS Assistant (EHSA). However, EH&S is in the process of transitioning USC to Risk and Safety Solutions (RSS), a new system for chemical inventory management.
During the transition, EH&S will visit every laboratory space at USC to inventory and RFID tagall chemicals. Principal Investigators (PIs) will be contacted by EH&S in the coming months to coordinate a specific time to begin work in their individual spaces. NOTE: PIs awaiting an official chemical inventory with EH&S, will continue to maintain their inventories in EHSA. The PI will manage their inventory in RSS upon completion of EH&S’ initial inventory and will remain ultimately responsible for compliance requirements.
A step-by-step process of managing the chemical inventory in RSS can be found in the RSS Chemical Inventory Management SOP.
All hazardous chemicals shall be entered in the inventory including:
- Any chemical which falls into one or more OSHA/GHS health or physical hazard class according to its labeling and safety data sheet (SDS).
- Any compressed, liquefied, or frozen gas (including inert gases).
PIs are ultimately responsible for compliance with chemical inventory record requirements. Inventory accuracy will be assessed during laboratory safety inspections; omissions and inaccuracies will be noted as a finding.
Recommendations:
- Assign an Inventory Lead to ensure that:
- The chemical inventory is up-to-date.
- All chemicals contain an RFID tag when using RSS.
- Hazardous materials are appropriately stored and labeled.
- Time sensitive materials are not stored or used past their expiration.
- Institute group rules whereby personnel are required to search the inventory before ordering new chemicals to:
- Avoid duplicate orders and excessive inventory.
- Ensure timely usage of time-sensitive chemicals.
- Conduct a comprehensive re-inventory annually. NOTE: EH&S will assist with periodic inventory reconciliation using RFID technology in RSS to certify that inventories are up to date.
- Avoid purchasing chemicals in bulk. An unnecessarily large chemical inventory presents a very significant and avoidable hazard. The following are considered best practices:
- Purchase the minimum quantity of the chemical needed for research.
- Purchase hazardous chemicals in amounts that can be used within six months, or the recommended shelf life or storage period if shorter.
- Share chemical inventories and chemicals with peers within a building, department, or school. RSS application features a Checkout option to allow labs to search inventories and borrow chemicals from other labs at USC. Sharing chemicals can:
- Eliminate unnecessary expenses.
- Improve overall safety.
- Encourage collaborations between research personnel.
- Consider offering other research groups chemicals that are no longer required, but are in good condition, before contacting Hazmat for disposal.
- RSS application features a Transfer option for any chemical that is not needed for future use.