Ensuring Chemical Compliance: A Conversation with Dr. Michael Cournoyer

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Large organizations involved in research and production typically handle large volumes of chemical inventory that require different types of storage and tracking. When a laboratory environment is part of the mix, managing the chemical inventory used by the lab presents a challenge to lab managers and environment, health, and safety (EHS) professionals, who must submit regulatory reports that accurately reflect the status of chemicals on-site. Ensuring that the chemical inventory data is accurate is challenging; providing that information in regulatory reports can be a time-consuming and frustrating task if it is not automated.

In March 2013, Lab Manager hosted an “Ask the Expert” webinar titled “Five Checklists You Need to Verify Compliance with Lab Chemical Management Requirements.” During the webinar, Dr. Tanuja Koppal, contributing editor for Lab Manager, interviewed Dr. Michael Cournoyer, a scientist with Los Alamos National Laboratory (LANL), about the system of checklists he developed to effectively address different regulatory standards.

Koppal: Why is it so difficult to prove that the lab is managing chemicals in compliance?

Cournoyer: It’s difficult because many organizations today handle and store a number of different chemicals that must be managed safely. There are lubricants, solvents, flammable materials, and corrosives, to name just a few, so the scope is enormous. It’s not enough to ensure that you know where chemicals are, provide training and information about correct handling procedures, and ensure that chemicals are stored and disposed of appropriately. There are many rules and regulations to ensure that these minimums take place. Because of all these requirements— some of which conflict—it is extremely important to ensure that your organization is able to pass chemical management audits to prove that your system works both well and safely.

You can’t just work through the lab standards [for] OSHA. For instance, researchers often tell me that the OSHA lab standards do not state that you have to do a chemical inventory. And they’re absolutely right. On the other hand, we don’t just do work based on the requirements of the lab standard; we also have to perform tasks according to EPA requirements. The EPA specifically requires the lab [to] do a chemical inventory at least once a year. That’s one of the difficulties: there are many regulations that require compliance, and just because one doesn’t require something doesn’t mean you don’t need to do it.

Koppal: Some of the webinar attendees say they’ve never had a chemical management audit. How does that process work?

Cournoyer: I can only speak from my experience, but if you have chemicals on-site, you may be subject to a chemical audit at some point, so you want to be prepared. Typically, the regulatory agency notifies you prior to an audit. The easiest way to be prepared is to show that you are meeting each of the particular regulation’s requirements, and that’s where the checklists come in.

Koppal: What are some of the solutions you have developed to ensure that chemicals and safety processes are in compliance with regulations?

Cournoyer: You need to look at each requirement that applies to your site and try to figure out how to address it in a way that documents it. As I went through the regulations, I found that if I had an excellent chemical inventory management system, I could address 80 percent of chemical-related audit questions. For example, one of the requirements concerns training for working with beryllium. If you have beryllium in your inventory, the system can flag it and indicate that using it requires specific training. A good chemical container inventory system can easily track a number of criteria associated with your chemicals.

Now, there are many steps involved in managing chemical inventory. First, if you only have 10 chemicals, you can do that by yourself. If you have 200 chemicals, I recommend that you get a chemical inventory software program. That way you’ll spend most of your time working on your chemistry and only a small percentage of your time managing your chemicals.

Koppal: A poll taken during the webinar asked the audience what they found to be the most difficult aspect of chemical management: tracking, storage, reporting, or ensuring compliance. Based on the results, 48 percent found tracking to be the most difficult task. Do you find that surprising?

Cournoyer: Surprising? No. These are the same issues that I’m concerned with. Now, tracking depends on the number of chemicals you need to manage, and if you get into the hundreds of chemicals, you need a chemical inventory system that tracks not only the chemical container, but also the chemical location. This is because if you have to write down every room, every cabinet, every shelf for each chemical, it can be very tedious. On the other hand, if you come in with a bar-code reader and scan the location and then scan all the chemicals, it doesn’t take that long. For example, I had an inventory of 27,000 chemicals in two major facilities, and I was able to do inventory reconciliation in less than two weeks. When you have a chemical inventory system that tracks both the chemicals and the location, ensuring compliance is 80 percent done, and for the chemicals themselves it’s probably 90-95 percent [done].

Koppal: The five checklists you developed have been broken into categories: chemical inventory and tracking, chemical storage, chemical purchases, on-site chemical transportation, and hazards analysis. Can you tell us about them?

Cournoyer: Because many of the regulations approach chemical safety from different perspectives and contain provisions that overlap and are sometimes contradictory, I created a series of activity-based checklists to govern chemical-related work activities. I divided the checklists into five categories to consolidate core safety and health requirements—such as those from OSHA, ANSI, and the NFPA—that companies engaged in chemical-related activities are required to [comply with].

A key reason for creating the checklists is to track hazardous materials, and a large part of hazardous materials tracking is proving that you are under certain threshold levels that require extra controls. Therefore, while there are checklists specific to hazardous materials, how those hazardous materials are tracked, stored, and disposed [of is] also addressed on other checklists. The questions on the checklists are the questions that the auditors ask. So when an auditor asks where your chemicals are, your chemical inventory report should list the facilities and the chemicals in those facilities, and your checklists will confirm this data.

Koppal: What benefits can labs expect after implementing the best-practices checklists you developed?

Cournoyer: By using the checklists, you can prove you’re in compliance with the regulations. It’s a very thorough way to ensure that you are addressing the requirements and that you have a time stamp on your documentation to prove you’re in compliance. And if your supervisor signs off on the checklist, it shows that he or she is aware of the compliance as well.


To watch the webinar, please visit www.labmanager.com/chemexpert

For a copy of Dr. Cournoyer's checklists, request ChemSW's white paper "How to Survive a Chemical Management Audit" at www.chemsw.com/white-papers.aspx


Dr. Michael Cournoyer is a scientist with Los Alamos National Laboratory (LANL). Dr. Cournoyer has more than 35 years’ experience in organic chemistry, combined with deep knowledge of federal, state, and local regulations that address lab chemical and hazardous material management. He has been the recipient of several awards and has published more than 60 papers on topics that range from fire suppression systems to glovebox safety to hazardous material operations.

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Herding Cats

Published: July 1, 2013

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