the chemicals - Stanford University

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Transcript the chemicals - Stanford University

Stanford University
Environmental Health & Safety (EH&S)
Hazardous Materials Division
What does the Haz Mat Division Do?
We provide software and customer support for
chemical tracking
How Can the Haz Mat Division Help You?
- Provides regulatory reports such as HMMP reports
- Processes hazardous material permits and fees
- Facilitates self and regulatory agency inspections of labs
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HMBP/HMMP Report
(Hazardous Materials Business Plan/
Hazardous Materials Management Plan)
http://www.unidocs.org/hazmat/business-plan/un-020.doc
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All facilities in Unidocs member jurisdictions that use or store hazardous materials
(defined as either virgin or waste materials) in any quantity are required to report
such use or storage to the appropriate local agency.
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A Hazardous Materials Business Plan (HMBP) is a document containing detailed
information on the storage of hazardous materials at a facility.
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A Hazardous Materials Management Plan (HMMP) contains facilities storage maps
and the Hazardous Materials Inventory Summary (HMIS)
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The intent of the HMBP is to satisfy federal and state Community Right-To-Know
laws and provide detailed information for use by emergency responders.
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The owner of a facility must complete a HMBP if it handles any individual
hazardous material or mixture containing a hazardous material which has a
quantity at any time during the reporting year equal to or greater than:
– 500 pounds for solid hazardous materials
– 55 gallons for liquid hazardous materials
– 200 cu ft for gases
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Information in the HMBP Report
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Business Activities
Business Owner/Operator Identification
Hazardous Materials Inventory Summary (HMIS)
Facility Map(s)
Emergency Contact Information for the building
Emergency Response/Contingency Plan
Employee Training Plan
Recordkeeping
*An individual building only has to submit an annual HMMP report containing
the first five items above. Stanford University submits a HMBP report every
March 1 which includes the last three items and a HMMP report for all campus
buildings with chemicals once year according to the EH&S schedule.
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What Does EH&S Do
With the HMBP?
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If the campus building is located in
Santa Clara County, we provide both
the County and the Palo Alto Fire
Department with copies.
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If the building is located in the City of
Palo Alto, only the Palo Alto Fire
Department receives a copy.
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Frequency of HMMP Submission
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HMMP report is annually submitted one year from the submission
date of the last HMMP report.
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Within 30 days of the occurrence of any of the following events,
the HMMP shall be revised and the revisions submitted to the
local agency:
– (1) There is a 100% or more increase in the quantity of a
previously disclosed material
– (2) The facility begins handling a previously undisclosed
material at or above the aforementioned HMMP amounts
– (3) Facility floor plan changes such as lab renovations or lab
closure
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Additionally, if the local agency determines that the HMMP is
deficient in any way, the plan shall be revised and the revisions
submitted to the local agency within 30 days of the notice to
submit a corrected plan.
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Hazardous Materials Permit Fee
(Effective July 1, 2005 through June 30, 2006)
> Go to http://www.ehinfo.org/content
> Click on Hazardous Materials Compliance Division
>Hazardous Materials Program Home
> Fees
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FEES: Fees are subject to change July 1 of each
year.
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HAZARD CLASSES: A separate permit is required
for each hazard class of material stored. For
classification purposes, U.S. Department of
Transportation (DOT) Hazard Classes are used.
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PERMIT CATEGORY: The permit category is
determined by Quantity Ranges based on the
aggregate amount of materials handled per hazard
class.
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Quantity Ranges and Fees
Fees
Quantity
Range
2006
2005
Quantity
Range
Gallons
(Liquids)
Pounds
(Solids)
Cubic Feet
(Gases)
1
$367.00
$363.00
1
< 55
< 500
< 200
2
56 to 550
501 to
5,000
201 to
2,000
3
551 to
2,750
5,001 to
25,000
2,001 to
10,000
4
2,751 to
5,000
25,001 to
50,000
10,001 to
20,000
5
5,001 to
10,000
50,001 to
100,000
20,001 to
40,000
2
3
4
5
$515.00
$586.00
$660.00
$735.00
$509.00
$579.00
$652.00
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HazMat Permit Process
Considerations
Permit period: 04/01/05 – 03/31/06
 Based on inventories as of 01/31
 Revoked compressed gas exemptions
 Per category fees have increased slightly
 All permit fees based on reporting from
ChemTracker inventory
 Inventory is a Departmental responsibility
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Basic ChemTracker Functions
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Retrieves current inventory (with sorting capability)
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Allows updating of inventory
– Modify current inventory item (i.e. location)
– Delete current inventory item
– Add new inventory item
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Provides helpful chemical information
–
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Guidance on chemical storage segregation
MSDS (Material Safety Data Sheets)
Hazard and toxicology information
Chemical structures
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ChemTracker/Chemical Inventory
Update
Main page: https://chemtracker.stanford.edu/ct/stanford.html
ChemTracker v.1: https://chemtracker.stanford.edu/stanford/
ChemTracker v.2: https://chemtracker.stanford.edu/ctv2stanford/
1. To obtain ChemTracker access:
Email the following info to [email protected]
or [email protected]
- Your first and last name
- PI who “owns” the chemicals
- Your phone number and e-mail address
2. EH&S will email you your user name and password
3. Log in to the ChemTracker website*
*For ChemTracker training, contact
Teresa Ho (3-9667) or Julie Wang (5-7521)
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What Does EH&S Do With the
ChemTracker Information?
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Assign hazard classification on chemical
inventory if information is available on our
database
Generate Facility Storage Map
Generate HMIS report
Generate Billing report
Generate CBC report upon request
Update the LSB boxes annually
– Only the front cover page and the chemical inventory summary sheet
– Lab personnel update the room map and the Emergency Notification
Sheet
Room map: http://web.stanford.edu/dept/EHS/prod/researchlab/chem/inven/map/chem_storage_map.pdf
Emergency Notification sheet:
http://web.stanford.edu/dept/EHS/prod/general/erprep/forms/hazmat/erlong.pdf
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EH&S Process and Timeline
for 2006 Permit Fees
OVERVIEW
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Update notification requests sent to Building
Manager or USP
Manager distributes to P.I.s and lab managers
Review and update inventory and maps
12/10 Report changes to EH&S
November County inspections
1/13 EH&S submits final reports
February EH&S receives bill and pays fees
EH&S requests reimbursement from Departments
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EH&S Process and Timeline
for 2006 Permit Fees
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Update notification requests sent to Building
Manager or USP
Manager distributes to P.I.s and lab managers
- Requests contain instructions, spreadsheets, timeline, and contact info
- Should be forwarded to P.I. or appropriate lab personnel for review
- Two types of spreadsheets: “room list” and “gas list” are generated from
ChemTracker
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EH&S Process and Timeline
Review and update inventory and maps
 12/10 Report changes to EH&S
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- Using spreadsheets, current ChemTracker inventory, physical checks, and last
year’s report, determine if changes to the online inventory are needed.
- Make any required changes in ChemTracker.
- Using last year’s report or current building maps available online at
https://maps-secure.stanford.edu/sims/_grs/hazmat/ (must be authorized),
determine if changes are needed based on any redistribution of inventory.
- Report changes to Teresa Ho at [email protected] or 3-9667.
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EH&S Process and Timeline
•
November County inspections
- County inspects while EH&S inventory reporting process ongoing.
- Entitled to make unannounced inspections but usually calls us first.
- Use Life Safety Box report and/or last year’s HMMP.
- Must be an EH&S representative present (usually CAP team member).
- If truly unannounced inspection, follow guidelines published at:
http://web.stanford.edu/dept/EHS/prod/aboutus/InspectionGuidance.html
or search the EH&S website for keyword “inspections.”
- If an issue is found, an EH&S representative may search ChemTracker
online to determine if inventory is up to date – if so, inspector will pass.
- If a citation is issued, we have 30 days to amend and resubmit reports.
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EH&S Process and Timeline
for 2006 Permit Fees
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1/13 EH&S submits final reports upon request
– the permit fee is based on last submitted HMMP report
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February EH&S receives bill, pays fees
EH&S requests reimbursement from Departments
- If citations found or last minute requests are made (“discovered” issues),
the last day we can submit a completed HMMP is 1/13/2006, but we
should always wrap up the process as early as possible.
- EH&S updates Life Safety Box printouts annually or upon special request.
- EH&S receives bill and pays fees in February.
- EH&S administrative staff contacts departments for reimbursement.
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Barriers to Compliance
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Incorrectly or under reported inventory
- Department /lab responsibility
- General awareness of changes in inventory resulting
from changes in research, researchers, equipment,
rooms
- Maintain reasonably accurate inventories
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Unlinked inventory
- Joint lab/EH&S responsibility. Try to use pick lists to
indicate chemicals, careful spelling, and accurate pstates.
- EH&S performs SAMONSing, will train if interested
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Unclassified materials
- EH&S responsibility, but if you are using a significant
quantity of an unclassified material, we will ask your
help - MSDS’s, CASnum, manufacturer, product number,
etc.
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Impact on Stanford University
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Billing reports are issued at same time, usually in
February
More inventory to check, new buildings
Higher overall fees
Inert gas (except Air & helium) exemption phased out
aside from the general category increases:
To estimate fee increase due to loss of gas exemption, refer to your most
recent HMMP report for section 2.2 Non-Flammable, Non-Toxic Gas, and
compare it to a current “Mass Quantity Report by Hazard” for the same
hazard category. Take the difference between the two amounts, and
subtract from it the current quantities of Helium and Compressed Air.
The remaining amount is what will be billed on next permit.
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Fines for non-compliance are assessed, Stanford
University pays, and then passes the cost to the
departments.
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Hazardous Materials County Inspection
List of compliance assistants
http://web.stanford.edu/dept/EHS/prod/researchlab/cap/by_bldg.htm
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Laboratories should be inspected quarterly, more frequently for some hazardous
operations, monthly for special storage room.
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Lab self inspection list:
http://web.stanford.edu/dept/EHS/prod/researchlab/lab/checklists/labshop.pdf
Areas that require special attention:
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Information on the LSB boxes front cover sheet should be in agreement with the
chemicals stored in the lab, especially gases information
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Initial hazardous waste accumulation date needed to be indicated clearly on the
container and the hazardous waste has to be disposed within 9 months from its
starting date
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All chemicals have to be stored in a compatible manner, namely, these chemicals
would not react violently, generate heat or cause fire if breakage occurs
*For additional information, please contact your Compliance Assistant or
Russell Furr at [email protected] or 3-7487.
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2003-2004 Santa Clara County Inspections
Frequency of Violations
Violation Category
Totals
Percentage
Hazardous Waste
557
34.97%
Separation/Contamination/Monitoring
463
28.67%
Inventory, HMBP/HMMP
233
14.68%
Recordkeeping and Labeling
146
9.07%
Fire
137
8.63%
Training, Emergency Response,
Unauthorized
56
3.53%
Other Violations
9
0.44%
1601
100%
TOTALS
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Inventory Reduction Suggestions
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Order the minimum quantities needed
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Promptly dispose of unwanted materials by submitting a Hazardous Chemical
Waste Pickup Form:
http://web.stanford.edu/dept/EHS/prod/enviro/waste/pickup/WastePickup_form.htm
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Keep your ChemTracker inventory up to date and use reports to identify
unneeded material.
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Modify research protocols if possible and appropriate.
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Share “stock material” with other labs if possible.
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Request revised HMIS submission if required.
Email [email protected] or [email protected]
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ChemTracker Assistance
To help determine the extent of “un-linked” materials in your inventory, run an
“Un-Linked Items” report from the Mass Quantities Reports page:
If there are materials listed that you suspect might be hazardous and are in
significant quantities, notify EH&S or your CAP team member.
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ChemTracker Assistance
You may also want to generate a “Quantities by Hazard” report to list your
inventory by hazard classification:
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Information You Can Find
on the EH&S Web Site
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Training
http://web.stanford.edu/dept/EHS
http://safetytrain.stanford.edu
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Chemical inventory
https://chemtracker.stanford.edu/ct/stanford.html
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MSDS
http://msds.stanford.edu
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Chemical Safety
http://chemsafetydata.stanford.edu
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Waste Pickups
http://wastepickup.stanford.edu
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Radiation
http://radsafety.stanford.edu
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Free chemicals
http://freechemicals.stanford.edu
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Forms
http://ehsforms.stanford.edu
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Questions?
For help with your ChemTracker application contact:
Teresa Ho
723-9667
[email protected]
Julie Wang
725-7521
[email protected]
For help with compliance-related issues contact:
Your EH&S CAP Team Member or
Russell Furr
723-7487
[email protected]
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