CIA Comprehensive Chemical Screen
Managing your company's chemical inventory
What the Regs Require
More than 90 percent of all Environmental, Safety and Homeland Security requirements are concerned with the chemicals that you use, store, process and ship within your facility. Most EPA, OSHA and DHS regulations require you to report, permit and/or train on; the storage, usage, handling, releases, processes, spills and exposures related to your chemical inventory. Thousands of chemicals are listed in the EPA, OSHA and DHS regulatory lists alone. These lists are changing all the time as well as your chemical inventory making it a continual challenge to keep up. Failure to comply with some of these requirements can result in fines from $10,000 - $75,000/day/occurrence.
Do any of these regulations affect me?
This is the first and most critical answer that every facility must ultimately answer. The next few simple questions will help you answer the above. If you can answer “No” to any of the following questions then you’re in the clear:
Question #1: Do you do any one of the following; manufacture, use, store, process or distribute chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a (M)SDS. They include solids, liquids and gases.)
Question #2: Do you have chemicals contained within these products that fall on any of these lists? (This one is a little more difficult; however, if the answer to question #1 was “Yes” then the answer to this one is most likely the same.)
Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day or annually), meet or exceed the reporting thresholds listed in SARA Title III, Clean Air Act, Storm Water, Clean Water Act, RCRA, OSHA or the new DHS standard? (The only way that we can help you with this one is to screen for them.)
Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.
Our View: The first and most critical step in finding what regulations affect you, relating to regulated chemicals, is to screen for them. You need to find out which ones you have and compile them in a way to show you how your quantities match up against the thresholds set for those chemicals. Then you need to continually monitor the changes in your chemical inventory along with the changes in the regulated chemical themselves.
ESSG has provided the Chemical Inventory Analysis (CIA) services that has helped our clients cut through the regulatory red tape of regulated chemicals to find out what regulations affects them since 1993.
ESSG has developed a way to effectively track your chemical inventory that can not only allow you to have "Peace of Mind" when thinking about your chemical compliance but also improve your bottom line.
What We Offer
Chemical Inventory Analysis (CIA) Comprehensive Screening Service
This service is designed to virtually eliminate the amount of time you would spend studying the numerous regulation as well as searching, cross-referencing and indexing your chemical inventory against the many Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA) and Department of Homeland Security (DHS) lists.
This simple and painless service provides you with vital, “site specific”, information on how your facility(s) stand regarding many EPA, OSHA and DHS regulatory lists and regulations.
After this service is complete, you will either have the chemical documentation you need to show why your facility needs to comply with a particular standard or (better yet) prove that it does not.
After this service is complete, it will be clear what areas of these regulations your facility(s) need to be concerned with or (better yet) have the defensible documentation to show that they don’t affect you.
The entire process can be completed in as little as a few days.*
Initially you simply provide to us copies of your Material Safety Data Sheets ((M)SDS) that represents your current chemical product inventory.
Our staff of trained professionals enter key information from your (M)SDS into our system.
We send you back either an E-mail or hardcopy** form requesting product inventory information on each chemical product to show quantities, container types, areas stored and area used along with some additional general site information required for reporting.
Logical After the information is received back from you and entered into your file, ESSG's proprietary CIA software matches your inventory against the thousands of regulated and/or flagged EPA, OSHA and DHS Chemicals.
The reports of the findings section and/or compliance instructions are then delivered back to you in a three ring binder and/or PDF format.**
The reports that you receive will provide you with supportable documentation as well as a management tool to assess your hazards. This includes the following 26 reports complete with detailed information showing your:
SARA Title III Reports
• Total Chemical Inventory
• Emergency Release Priority Products
• Extremely Hazardous Substances (EHS) Chemicals
• Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Chemicals
• TRI (Form R/A) Chemicals
• 10,000 lb. Chemicals
Other Environmental Reports
• Ozone Depleting Chemicals;
• Clean Air Act Chemicals (Title V and others);
• Storm Water Chemicals;
• Clean Water Act Chemicals
• Resource Conservation and Recovery Act (RCRA) Chemicals;
• Flammable Hazards;
• Pressure Hazards (heat sensitive);
• Reactive Hazards;
• Acute Health Hazards;
• Chronic Health Hazards;
• Process Safety Management
• Methylene Chloride Chemicals;
Department of Homeland Security Anti-Terrorism Reports****
• DHS Release – Toxic Chemicals
• DHS Release – Flammable Chemicals
• DHS Release – Explosive Chemicals
• DHS Theft - CW/CWP (CUM 100 grams) Chemicals
• DHS Theft - CW/CWP (Minimum DHS Concentration) Chemicals
• DHS Theft - WME (CUM 100 grams) Chemicals
• DHS Theft - WME (Minimum DHS Concentration) Chemicals
• DHS Theft/Diversion - EXP/IEDP Chemicals
• DHS Sabotage/Containment Chemicals
Ongoing This service is a renewable annual (12 month) service that allows you to provide us your new or revised (M)SDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with the ongoing modifications to the many different EPA, OSHA and DHS lists and notify you if your status changes.
There are potentially several additional steps for you to be fully compliant with all the sections listed.
If you are interested in any additional services related to these reports we would please request a quote in those sections of our website or contact an ESSG representative.
If required by the report findings pertaining to SARA Title III, sections 301-313 reporting, ESSG will prepare and file your required Federal, State and Local reports as follows:
1) Tier II Reporting – Just an additional minimal filing fee with this service.
2) Toxic Release Inventory (TRI) (AKA-Form R/A) – Quoted separately
3) Air Emissions Inventory - Quoted separately
Coming Soon ESSG will provide you secure access to your chemical inventory online via ESSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes.
* Results are subject to demand and response time from the client.
** Based on your preference.
*** The reports that you receive will show all the chemicals and what products they are a mixture of, percentages, as well as quantities at your facility. The reports will aggregate those quantities that meet or exceed the minimum concentration given for each chemical on the COI list. Those totals are then compared to the Screening Threshold Quantities (STQ) to show if you meet or exceed the threshold(s). A worksheet with the chemicals that exceed the STQ is also sent to you with questions that may allow you to eliminate particular products from the totals.