Going Virtual with Chemical Reporting

Imagine the frustration of a company's new environmental compliance supervisor working against a deadline to submit a report on the company's chemical inventory; or the intensity of a plant manager, trying to determine if a spilled solvent is reportable to the National Response Center (NRC) or if vapors in the area exceed permissible exposure limits set by Occupational Health and Safety Administration (OHSA).

Until the development of chemical management software, providing an accurate and timely response to either scenario could place the company and its employees in a costly and possibly dangerous situation. Prepared or not, companies are under regulatory microscopes to comply with chemical reporting requirements under Title III of the Superfund Amendments and Reauthorization Act (SARA), also known as the Emergency Planning and Community Right to Know Act (EPCRA).

The Hazard Communications Standard (HCS) was designed to protect workers from the effects of hazardous chemicals in the workplace. The HCS, also known as the "Right to Know Law," requires all employers to provide information and training on chemical hazards to all employees who may be exposed to hazardous chemicals.

Civil and administrative penalties of $10,000 to $75,000 per violation are effective regulatory sticks that can prod reporting compliance.

Chemical management software helps companies comply with environmental regulations, as well as contributing to improvements in worker health and safety.

Complying with SARA and HCS guidelines involve the careful cataloging and updating of Material Safety Data Sheets (MSDS). Each MSDS lists the physical and health hazards of a particular chemical, its control measures and the personal protective equipment required during use. A MSDS also contains vital emergency information, such as first aid measures and spill mitigation procedures.

Many companies must also report the "percent volatility" of inventoried chemicals. A Volatile Organic Compound (VOC) report describes the ability of a material to evaporate, which could highlight the need for ventilation and other precautions to control vapor concentrations, as well as added site specific air reporting requirements.

The paperwork can be extensive. Facilities that file MSDS may be required to submit annual inventory forms (known as SARA 312 or "Tier II" forms) to local and state agencies, and the local fire department. This report is required for MSDS-listed hazardous substances that are in inventory in excess of 10,000 pounds. The form is also required if the company uses or stores extremely hazardous substances (EHS) in excess of the threshold planning quantity (TPQ) or 500 pounds, whichever is less. There are approximately 360 on the EHS list.

SARA Section 313 requires Form R reports, also known as TRI reports, which address releases of toxic chemicals to all venues (waste, air, water, land disposal, etc.). Companies are required to file a Form R if they have more than 10 full time employees, fit into a specified Standard Industrial Classification (SIC) code, and manufacture, process, or otherwise use a listed toxic chemical in excess of specified threshold. There are over 650 toxic chemicals listed under SARA 313.

Civil and administrative penalties of $10,000 to $75,000 per violation are effective regulatory sticks that can prod reporting compliance. Yet each year, companies are fined for failing to comply with emergency planning and notification as well as inaccurate or incomplete Tier II and Form R reporting.

Weyerhaeuser: A Case Study

Weyerhaeuser is a forest products company that has a tradition of taking its environmental obligations seriously. But, like many companies, it also used to trudge through a swamp of hard-copy MSDS chemical record keeping.

Under Weyerhaeuser's old system, each site's MSDS coordinator maintained a series of binders containing anywhere from 10 to 10,000 MSDS documents. Outdated volumes were replaced by hand and Weyerhaeuser employees found it could take hours to locate one particular MSDS - not a good scenario in the event of an environmental or safety emergency.

Clearly, a change had to be made.

Weyerhaeuser's Conversion Process

In 1992, when Weyerhaeuser began looking for a computerized MSDS system, the company had three goals: to have all MSDS information standardized company-wide, to better utilize resources related to MSDS compliance and chemical management, and to meet all hazcom and chemical safety regulations.

After evaluating several companies, Weyerhaeuser selected Dolphin Software's Comply Plus. Currently, the software services employees in each of the company's 250 North American locations, including workers in British Columbia, Alberta and Saskatchewan.

The initial implementation of the new software involved setting up a corporate Wide Area Network and Local Area Network (WAN/LAN) system. Each location collected its MSDS and sent copies to Dolphin where the sheets were tagged, sorted, and entered into a computer. A central database was created at Weyerhaeuser's Federal Way, Washington headquarters.

Weyerhaeuser has taken this solution even one step further. Today, each of Weyerhaeuser's 300 plus sites are running the system over the Web. Each site has access to any of the companies 58,000 MSDS over the company Intranet.

For easier searching and retrieval, each MSDS is indexed in several ways, including the chemical's common name, the site where it's used, its manufacturer and its primary compounds. Since Canadian law requires that MSDS information be updated every three years, Weyerhaeuser's system contains each sheet's revision date.

Making the Switch

There are a number of software products that help companies manage their chemical inventories and reporting. They vary in features, price and customization. Companies will want to consider a few of the following features in selecting an MSDS software management company:

  • MSDS text conversion
  • - Select software that can translate hard-copy MSDS to electronic text and file it in a database. Make sure that the software company has highly accurate text conversion.
  • Flexible data indexing and retrieval
  • - Choose a MSDS system that permits searching by chemical name, generic term or manufacturer's name.
  • Walk-up
  • MSDS viewing stations - These read-only/print-only workstations make it easy for all employees to access MSDS information from a central server.
  • Revision management
  • - Since MSDS information is constantly undergoing revision by the manufacturer, be sure the database is easy to update. Some software companies provide revision management - including contacting the chemical manufacturer on a regular basis - to ensure the MSDS data's integrity.
  • Multiple location access
  • - If a company has chemicals at multiple locations, access to MSDS data using a WAN/LAN system or the Internet/Intranet will make managing information, inventories and purchases much easier. If a company has its own intranet, select software that can take MSDS files written in ASCII text and automatically convert them to HTML format.

In addition to the above basic services, some software providers can offer specialized features:

  • Customized secondary labeling
  • of containers - This generates special labels that include manufacturer information as well as the company's choice of key MSDS information.
  • Emergency MSDS faxing
  • - This service provides urgent first aid information or mitigation procedures on demand.
  • Customized regulatory reporting software
  • Some providers can create software packages that assist with regulatory reporting activities. This type of software can integrate data found on MSDS with inventory records to drive Tier II and Form R reporting, as well as air emission reports for VOC, hazardous air pollutants (HAPs) and particulates.

Environmental Auditing and Reporting Assistance

Once a company decides to convert to MSDS management software, it is helpful to have an internal or external environmental compliance audit (ECA). This audit will help ensure adherence to regulatory requirements and possibly save the company a bundle in avoided fines.

It is also important to have automated SARA reporting that incorporates on-site inventory control, report generation and validation, spill notifications and other services.

For example, the threshold for EHSs are based upon an aggregated total, meaning that all of the sources of a particular chemical must be totaled and compared with the TPQ (normally 500 pounds). With the thousands of chemicals on site at a facility, such an aggregated total is often underestimated, or even totally forgotten. With such low reporting thresholds, it is easy to overlook even one source and fail to accurately report.

Improving the Bottom Line

Companies that switch to chemical management software often discover benefits that go beyond simplified chemical reporting. For instance, now that Weyerhaeuser's chemicals are inventoried in one database, it is enjoying a pleasant economic side-effect: the company now has larger chemical purchasing leverage with volume discounts.

But the greatest benefit has been increased employee access to safety and environmental compliance information. Indexed computer searches reduce research time to a matter of minutes instead of hours. Weyerhaeuser has achieved an emergency MSDS retrieval response time of less than two minutes.

This article originally appeared in the April 2001 issue of Environmental Protection, Vol. 12, No. 4, p. 43.

This article originally appeared in the 04/01/2001 issue of Environmental Protection.