CHEMICAL PROCUREMENT, TRANSPORTATION, AND INVENTORY
Some chemicals and equipment have inherent safety hazards that require special safety controls and authorizations. It is important that these controls are in place before the material is purchased and used on site. Several materials of concern are listed in the Restricted Items List that is maintained by the Procurement Department in consultation with EH&S. The Laboratory has a notification and approval procedure for these materials that is initiated at the time of procurement. This Restricted Item List includes chemicals and equipment such as:
Requesters, preparers, buyers and other personnel who are responsible for purchasing materials must review the Restricted Item List and the Procurement Item Categories List, to identify purchases that require EH&S notification or approval. It is important that the chemical or equipment name as well as the vendor’s catalog number be identified on the requisition and that the hazardous properties of chemicals are declared. The EH&S Division reviews and approves procurement of materials such as toxic and pyrophoric gases, biological agents, selected reactive (unstable) chemicals and respiratory protection equipment.
Before receiving a hazardous material, information on proper handling, storage, and disposal must be understood. It is the responsibility of safety line management to ensure that the facilities in which the substance will be handled are adequate and that those who will handle the substance have received the proper training. The MSDS should be reviewed prior to using the substance. An Industrial Hygienist may also be consulted for guidance. It is also important to limit chemical purchases to the amount actually needed.
The Berkeley Lab has adopted a Laboratory Scale Quantity (LSQ) to control chemical inventories within safe and manageable levels. This is discussed in the Emergency Management Program. An LSQ is defined as “any purchase, receipt, or use of a chemical with an NFPA Health Hazard rating of 3 or 4 in a bulk quantity of >5 gallons (liquid), >40 pounds (solid), or >10 pounds (gas).” Chemical procurement, use, or storage of quantities that exceed an LSQ requires notification to the Emergency Management Program office.
Some equipment contains chemicals that can pose a hazard when mishandled, such as elemental mercury in porosimeters. When normal operation or reasonably foreseeable mishandling of equipment that contain chemicals may result in a loss of control (such as a spill) that could pose an exposure hazard, cause extensive area contamination, or result in environmental damage, the Line Manager shall do a hazard assessment in consultation with an EH&S Division Subject Matter Expert. The using Division determines if a formal authorization is needed on the basis of the risk assessment performed. Further information is provided in Chapter 6, Work Authorizations.
Hazardous materials will be transported by Transportation Services or a Department of Transportation authorized carrier (except as outlined below). Transporting hazardous materials by employees in public transportation (such as the shuttle bus) or in private or government vehicles, is not permitted. This is to minimize risk to Lab employees and the public. This also ensures that the federal and state laws regarding packaging, manifesting and placarding hazardous materials are met. There are exceptions for transporting research samples hazardous materials and field sampling materials as described later.
The following parties are permitted to transport hazardous materials between non-adjacent LBNL buildings and from off-site locations (e.g., UC Berkeley Campus):
Transportation Services (ext. 5404) will transport hazardous materials, provided they are unopened and still in their original U.S. Department of Transportation (DOT) shipping containers. They will also transport gas cylinders. In addition, Transportation Services will package and label hazardous materials in accordance with DOT Title 49 regulations for shipment by commercial carriers. MSDSs and hazard warning labels are required for off site shipments of chemicals that are created or synthesized at LBNL. Refer to the section on Material Safety Data Sheets for additional information.
EH&S Waste Management Group (ext. 5877 ) will transport hazardous materials that have previously been opened. This is normally needed for laboratory moves.
Facilities craft personnel will transport paints, solvents, cleaners, and other materials necessary to perform their work.
Transporting Small Quantities of Hazardous Materials by Laboratory Employees, Subcontractors, and Casual and Participating Guests
These parties may move small quantities of hazardous materials for short distances within a building or between adjacent buildings, provided that it can be done safely and without spilling the materials. Individuals must use hand carts and drip trays (to contain any spilled material). Employees must also complete Chemical Hygiene & Safety Training EH&S 348 (or 345 for Facilities personnel or 352 for summer students). Use standard cylinder dollies to transport compressed gas cylinders. While dollies are preferred, cylinders weighing 11 Kg (25 lbs) or less may be hand-carried.
Never move a cylinder with a regulator connected to it. Cylinder valve-protection caps and valve-opening caps must be in place when moving cylinders. Lecture bottles and other cylinders that are not normally equipped with valve-protection caps should be transported in either the original DOT specification package or an equivalent container.
NOTE: Contact an EH&S Radiological Control Technician for guidance regarding transporting radiological isotopes.
Policy and Procedure
The policy for transporting research samples, hazardous materials and field sampling materials by LBNL staff is established in Pub 3000 Traffic and Transportation, Section 5.8.14. The process described below is the procedure for implementing this policy.
LBNL staff (i.e., anyone with an LBNL badge) may transport research samples and small quantities of hazardous materials by hand or in a passenger vehicle under the conditions defined by this procedures described below. “Small quantities” is defined below in the Scope and Application section. A research sample is a material used or developed in a laboratory for research purposes, for further use, study, analysis or characterization.
Shipping samples and hazardous materials by common carrier (FedEx, UPS, USPS) to off site locations must be done by Facilities Material Services. This is addressed in the Requirements for Shipping by Common Carrier section of this procedure.
Questions regarding this policy may be addressed to the EH&S Deputy Division Director (x7002).
Scope and Application
This policy applies to LBNL staff who:
This policy applies to research samples and hazardous materials in the following DOT hazard categories. These materials must be contained in proper packaging (see below) and shall not exceed 0.5 kg (1 lb) or 0.5 L (1 pint) gross packaging size. To determine hazard class, consult a Material Safety Data Sheet (MSDS) or contact the EH&S Transportation Subject Matter Expert (ext. 4826).
Contact the EH&S Deputy Division Director (ext 7002) for exemptions to the above hazard class/quantity limitations, or for transporting materials in the following DOT hazard categories:
This policy does not apply to biological materials and materials that are radioactive, self-reactive, pyrophoric, explosive, water reactive, acutely toxic by inhalation, or a hazardous waste. "Acutely toxic" refers to substances that may be fatal or cause damage to target organs from a single exposure or from exposures of short duration. It also includes materials capable of causing intense irritation that can result in pulmonary edema (fluid and swelling in the lungs), chemical asphyxia, and systemic (body-wide) poisoning. A substance's acute toxicity may be determined by consulting a Material Safety Data Sheet. Contact the EH&S Transportation Subject Matter Expert (ext. 4826) for further information.
Staff transporting hazardous materials must have Chemical Hygiene and Safety Training (EHS0348), Chemical Hygiene and Safety Refresher Training (EHS0353) as applicable, and Safe Handling of Engineered Nanoscale Particulate Matter (EHS 0344) if they transport engineered nanoscale particulate matter. Employees’ JHAs must note that they transport research samples and small quantities of hazardous materials.
Facilities Material Services personnel who package materials for common carrier shipment must be qualified in accordance with the U.S. Department of Transportation (DOT) or the International Air Transport Association (IATA) regulations.
Requirements for Hand Carrying and Transportation by Vehicle:
“Nanoscale – This material’s toxicity, reactivity and
Other Requirements for Staff hand carrying and transporting by vehicle:
Requirements for Shipping by Common Carrier
The OSHA Hazard Communication Standard (29CFR1910.1200) requires MSDSs and container labeling for research samples and hazardous chemicals that are shipped from laboratories. There is no exemption based on size or volume. Consult the section entitled, Control Procedures for Chemicals Produced in Laboratories and Shipped Off Site. for hazard communication requirements. LBNL also requires adherence to PUB-3000, Section 5.8.13, Traffic and Transportation. Only qualified individuals in Facilities Material Services (ext. 5084) may pack and ship these materials off site. LBNL employees intending to send research samples and hazardous materials off site must:
Related documents and references:
The purpose of the site wide chemical inventory is to provide chemical users, EH&S staff and emergency response teams with accurate and up-to-date lists of chemicals that are stored on site. Furthermore, OSHA requires that a chemical list be maintained. Current chemical inventory reports must also be provided for compliance with DOE and City of Berkeley regulations. The inventory is also used to categorize chemicals into their respective hazard classes and utilize this information as a tool to a) identify users of particular materials b) communicate hazard information including special controls or procedures; and c) assist EHS in helping chemical users to determine if exposure assessments are needed. This permits emergency personnel to respond to unplanned releases with appropriate training, equipment, and organizational support. A well-maintained chemical inventory can also aid in internal laboratory management of business and research needs.
The EH&S Division hosts a site-wide chemical inventory database contained within the Chemical Management System.
All hazardous materials are required to be included in the Chemical Management System (CMS). Material Safety Data Sheets (MSDS) for materials should be consulted to determine hazard status. An EH&S Industrial Hygienist may be consulted to provide assistance in determining the hazards of a chemical or product.
It is the Owners responsibility to ensure that all hazardous chemicals/materials for which they are responsible are entered into the CMS as soon as possible and that all chemicals are removed/disposed from the inventory when the materials have been used up, disposed, or taken offsite.
The CMS identifies containers (or groups of identical containers) with a barcode containing a six-digit ID number. The barcode should be affixed to the container with the ID number completely visible in the case of small containers. The barcode should be attached vertically to facilitate electronic scanning. The container barcodes appear in pairs; one barcode to be affixed to the container and one to be affixed to a chemical inventory data sheet. Barcodes can be obtained through chemical management at ext. 2994, CMS@lbl.gov.
The following information must be added to the CMS for each chemical:
Consumer adhesives and sealants: All adhesives and sealants must be inventoried.
Mixtures: The chemical name and concentration fields should be filled with data on the most hazardous component (consult MSDS), while the remaining components and respective concentrations should be entered into the comment field. The following are examples of how various mixtures should be entered into the database:
Consumables: Consumable materials such as grinding wheels, welding rods, or soldiering material that can be used up, dispersed or aerosolized during utilization must be entered into the Chemical Management System.
Prepackaged Kits: Kits, prepackaged sets of chemical components intended for usage for a specific task, test, or procedure, must be entered into the Chemical Management System. NOTE: Individual components do not need to be entered individually. The Kit may be entered as a whole, identified by the name as it appears on the manufacturer’s MSDS.
Multi-Container Data Sheets
Exception: California and DOE regulations on the usage of greenhouse gases require Berkeley Lab to report amounts annually. This multi-container option does not apply to greenhouse gases such as sulfur hexafluoride (SF6). All greenhouse gases, such as SF6, must be individually entered into the Chemical Management System to enable accurate reporting. [<http://www.arb.ca.gov/cc/sf6nonelec/sf6nonelec.htm>, <http://www1.eere.energy.gov/femp/pdfs/fleetguidance_13514.pdf>]
Examples of Multi-Container Data Sheets in Use:
Please contact Chemical Management System Support at ext. 2994 or CMS@lbl.gov for database access and information regarding roles and responsibilities.
Last updated: 10/22/2013