04/11/231

What does the Haz Mat Division Do?What does the Haz Mat Division Do?

We provide software and customer support for We provide software and customer support for chemical trackingchemical tracking

How Can the Haz Mat Division Help You?How Can the Haz Mat Division Help You?

- Provides regulatory reports such as HMMP reports- Provides regulatory reports such as HMMP reports- Processes hazardous material permits and fees - Processes hazardous material permits and fees - Facilitates self and regulatory agency inspections of - Facilitates self and regulatory agency inspections of labslabs

Stanford University Stanford University Environmental Health & Safety (EH&S)Environmental Health & Safety (EH&S)

Hazardous Materials DivisionHazardous Materials Division

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HMBP/HMMP ReportHMBP/HMMP Report(Hazardous Materials Business Plan/(Hazardous Materials Business Plan/

Hazardous Materials Management Plan) Hazardous Materials Management Plan) http://www.unidocs.org/hazmat/business-plan/un-020.doc

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.

A Hazardous Materials Business Plan (HMBP) is a document containing detailed information on the storage of hazardous materials at a facility.

A Hazardous Materials Management Plan (HMMP) contains facilities storage maps and the Hazardous Materials Inventory Summary (HMIS)

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.

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

04/11/233

Information in the HMBP ReportInformation in the HMBP Report

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.

04/11/234

What Does EH&S Do What Does EH&S Do With the HMBP?With the HMBP?

If the campus building is located in Santa Clara County, we provide both the County and the Palo Alto Fire Department with copies.

If the building is located in the City of Palo Alto, only the Palo Alto Fire Department receives a copy.

04/11/235

Frequency of HMMP SubmissionFrequency of HMMP Submission HMMP report is annually submitted one year from the

submission date of the last HMMP report.

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

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.

04/11/236

Hazardous Materials Permit FeeHazardous Materials Permit Fee(Effective July 1, 2005 through June 30, 2006)(Effective July 1, 2005 through June 30, 2006)

> Go to > Go to http://www.ehinfo.org/content > Click on Hazardous Materials Compliance Division > Click on Hazardous Materials Compliance Division

>Hazardous Materials Program Home >Hazardous Materials Program Home > Fees> Fees

FEES: Fees are subject to change July 1 of each year.

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.

PERMIT CATEGORY: The permit category is determined by Quantity Ranges based on the aggregate amount of materials handled per hazard class.

04/11/237

Quantity RangesQuantity Ranges and Feesand Fees

Quantity Range

Gallons (Liquids)

Pounds (Solids)

Cubic Feet (Gases)

1 < 55 < 500 < 200

2 56 to 550501 to 5,000

201 to 2,000

3551 to 2,750

5,001 to 25,000

2,001 to 10,000

42,751 to

5,00025,001 to

50,00010,001 to

20,000

55,001 to 10,000

50,001 to 100,000

20,001 to 40,000

Fees

QuantityRange 2006 2005

1 $367.00 $363.00

2 $515.00 $509.00

3 $586.00 $579.00

4 $660.00 $652.00

5 $735.00  

04/11/238

HazMat Permit Process HazMat Permit Process ConsiderationsConsiderations

Permit period: 04/01/05 – 03/31/06Based on inventories as of 01/31Revoked compressed gas exemptionsPer category fees have increased slightlyAll permit fees based on reporting from

ChemTracker inventory Inventory is a Departmental responsibility

04/11/239

Basic ChemTracker FunctionsBasic ChemTracker Functions

Retrieves current inventory (with sorting capability)

Allows updating of inventory– Modify current inventory item (i.e. location)– Delete current inventory item– Add new inventory item

Provides helpful chemical information– Guidance on chemical storage segregation– MSDS (Material Safety Data Sheets)– Hazard and toxicology information– Chemical structures

04/11/2310

ChemTracker/Chemical Inventory ChemTracker/Chemical Inventory UpdateUpdate

Main page: Main page: https://chemtracker.stanford.edu/ct/stanford.htmlChemTracker v.1: ChemTracker v.1: https://chemtracker.stanford.edu/stanford/

ChemTracker v.2: ChemTracker v.2: https://chemtracker.stanford.edu/ctv2stanford/

1. To obtain ChemTracker access:Email the following info to teresaho@stanford.edu or qlwang@stanford.edu- 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)

04/11/2311

What Does EH&S Do With the What Does EH&S Do With the ChemTracker Information?ChemTracker Information?

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

04/11/2312

EH&S Process and TimelineEH&S Process and Timelinefor 2006 Permit Feesfor 2006 Permit Fees

OVERVIEW

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

04/11/2313

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

EH&S Process and Timeline EH&S Process and Timeline for 2006 Permit Feesfor 2006 Permit Fees

04/11/2314

Review and update inventory and maps12/10 Report changes to EH&S

- 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 athttps://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 teresaho@stanford.edu or 3-9667.

EH&S Process and TimelineEH&S Process and Timeline

04/11/2315

• 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.

EH&S Process and TimelineEH&S Process and Timeline

04/11/2316

1/13 EH&S submits final reports upon request– the permit fee is based on last submitted HMMP

report 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.

EH&S Process and Timeline EH&S Process and Timeline for 2006 Permit Fees for 2006 Permit Fees

04/11/2317

Barriers to ComplianceBarriers to Compliance 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

Unlinked inventory- Joint lab/EH&S responsibility. Try to use pick lists to indicate chemicals, careful spelling, and accurate p-states.- EH&S performs SAMONSing, will train if interested

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.

04/11/2318

Impact on Stanford UniversityImpact on Stanford University 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.

Fines for non-compliance are assessed, Stanford University pays, and then passes the cost to the departments.

04/11/2319

Hazardous Materials County InspectionHazardous Materials County InspectionList of compliance assistantsList of compliance assistants

http://web.stanford.edu/dept/EHS/prod/researchlab/cap/by_bldg.htmhttp://web.stanford.edu/dept/EHS/prod/researchlab/cap/by_bldg.htm

Laboratories should be inspected quarterly, more frequently for some hazardous operations, monthly for special storage room.

Lab self inspection list:http://web.stanford.edu/dept/EHS/prod/researchlab/lab/checklists/labshop.pdf

Areas that require special attention:

Information on the LSB boxes front cover sheet should be in agreement with the chemicals stored in the lab, especially gases information

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

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 orRussell Furr at rfurr@stanford.edu or 3-7487.

04/11/2320

2003-2004 Santa Clara County Inspections2003-2004 Santa Clara County InspectionsFrequency of ViolationsFrequency 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%

TOTALS 1601 100%

04/11/2321

Inventory Reduction SuggestionsInventory Reduction Suggestions

Order the minimum quantities needed

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

Keep your ChemTracker inventory up to date and use reports to identify unneeded material.

Modify research protocols if possible and appropriate.

Share “stock material” with other labs if possible.

Request revised HMIS submission if required. Email teresaho@stanford.edu or qlwang@stanford.edu

04/11/2322

ChemTracker AssistanceChemTracker AssistanceTo 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.

04/11/2323

ChemTracker AssistanceChemTracker AssistanceYou may also want to generate a “Quantities by Hazard” report to list your inventory by hazard classification:

04/11/2324

Information You Can Find Information You Can Find on the EH&S Web Siteon the EH&S Web Site

http://web.stanford.edu/dept/EHShttp://web.stanford.edu/dept/EHS Training

http://safetytrain.stanford.edu

Chemical inventoryhttps://chemtracker.stanford.edu/ct/stanford.html

MSDShttp://msds.stanford.edu

Chemical Safetyhttp://chemsafetydata.stanford.edu

Waste Pickupshttp://wastepickup.stanford.edu

Radiationhttp://radsafety.stanford.edu

Free chemicals http://freechemicals.stanford.edu

Formshttp://ehsforms.stanford.edu

04/11/2325

Questions? Questions? For help with your ChemTracker application

contact:

Teresa Ho723-9667teresaho@stanford.edu

Julie Wang725-7521qlwang@stanford.edu

For help with compliance-related issues contact:

Your EH&S CAP Team Member or

Russell Furr723-7487rfurr@stanford.edu