SafetyNet #7 - Hazardous Material Inventory Requirements
Background
The federal Superfund Amendments and Reauthorization Act (SARA) was enacted in 1986 after incidents in Bhopal, India and Institute, West Virginia. Title III of SARA requires businesses to submit an annual inventory of hazardous materials to the Environmental Protection Agency (EPA) or an equivalent state agency. The California legislature passed Assembly Bill 2185 in 1987, incorporating the provisions of SARA Title III into a state program administered by local government agencies. The Yolo County Communications Emergency Services Agency (YCCESA) hazardous materials division is responsible for AB 2185 oversight at all UC Davis facilities in Yolo and Solano counties.
In addition to fulfilling the requirements of federal and state laws, chemical inventory information assists the campus in establishing occupancy codes for buildings and provides valuable data for calculating air pollutant emis.
What Chemicals Need to be Listed on the Inventory?
State law requires businesses to list all hazardous materials on chemical inventories. All substances for which an MSDS has been produced are considered reportable under state law. Businesses must also list hazardous wastes on the inventory.
YCCESA exempts certain categories of hazardous substances from business plan requirements. These materials are:
- Radioactive isotopes and materials registered under RUAs
- Chemical solutions of less than 10% concentration (including formalin, dilute acids and bases and buffer solutions)
- Registered drugs
- Distilled water, saline solutions and sugar solutions
- Unknown compounds or mixed radiological/chemical wastes
Local Agency Requirements for Chemical Inventories
YCCESA requires that businesses list all hazardous materials above specific threshold quantities based on the physical state of the material. These thresholds are the following:
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Solids: |
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Quantities > l lb. or 0.45 kg. |
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Liquids: |
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Quantities > 1 gal. or 3.8 L. |
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Compressed Gases: |
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Any amount. |
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Perchlorates: |
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Any amount. |
YCCESA requires information about hazardous materials including location, physical state, type of container, amount present at time of inventory, and maximum amount stored on site during the year.
Acutely Hazardous Materials
Materials included on the California list of Acutely Hazardous Materials (AH Materials) must be reported no matter how small the quantity present at a site. A list of AH Materials
can be viewed at the EH&S website.
Completing the Chemical Inventory
EH&S has developed an on-line Chemical Inventory System (CIS) for campus hazardous materials users to submit chemical inventories. For additional information, contact your EH&S Safety Advisor, EH&S at 530-752-1493 or ehsdesk@ucdavis.edu
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Reviewed/Revised. 01/2007
BDW