Creating a Chemical Inventory: Your Requirements Under HazCom

Rachel Krubsack, EHS Editor

May 25, 2023

Man on laptop

If you’re required under OSHA’s hazard communication (HazCom) standard to have a written HazCom program, part of that requirement includes a chemical inventory. The inventory is a list of all hazardous chemicals present in the workplace, including those that are stored or not in use.

A hazardous chemical is defined by OSHA as “any chemical which is classified as a physical or health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.” The terms “health hazard” and “physical hazard” are defined at 1910.1200(c).

What information must be included on the chemical inventory?

OSHA only requires a product identifier (such as the common name) that aligns with the label and safety data sheet (SDS). You don’t have to indicate the hazards of the chemicals on your list, but it can be helpful as a training tool to give employees an overview of the hazards in their area.

How do you create a chemical inventory?

Start by performing a department-by-department audit and look for any chemicals present. Sometimes people think of “chemicals” as being only liquids in containers. However, HazCom covers chemicals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they’re “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered by the standard. In addition to chemicals in containers and pipes, think about chemicals that are generated during work operations. For example, welding fumes, dusts, and exhaust are all sources of chemical exposures.

Once you’ve compiled your chemical inventory, the next step is to determine if you’ve received safety data sheets (SDSs) for all of them. Check your files against the inventory you’ve just compiled. If any are missing, contact your supplier and request one.

Learn more about how J. J. Keller can help with Chemical Management or call 888.473.4638 for more information.

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OSHA's Hazard Communication (HazCom) Standard is based on the concept that employees have both a need and a right to know the chemical hazards they may be exposed to in their work areas, and how they can protect themselves from those chemical hazards.

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