About Hazardous Materials
The Hazardous Material Program at SLAC is multifaceted and addresses chemical safety at every point in the chemical lifecycle from transportation, procurement, use, storage, and inventory management.
The information generated in this program is used by emergency management and environmental protection programs at SLAC, DOE and regulatory agencies. This information is part of the Emergency Planning & Community Right-to-Know Act (EPCRA 302) and helps increase the public's knowledge and access to information on chemicals at our site, their uses, and releases into the environment. Regional emergency management and local fire departments can use the information to improve chemical safety and protect public health and the environment. SLAC uses this information to plan for possible emergencies through the safe management and use of hazardous materials.
Safe management of hazardous materials includes inventory control, segregation of incompatible materials, secondary containment, appropriate use of chemical storage assets (tanks, flammable and chemical cabinets, Fume hoods, chemical refrigerators, gas racks...), chemical storage maps, and following DOT shipping requirements. The goal is to provide the guidance and tools to assist each work group in maximizing chemical safety.
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Frequently Asked Questions
- How do I ship Hazardous Materials other than product returns (i.e. samples, collaborator materials)? Note: For product returns see CMS procedures.
To ship Hazardous Materials you must first fill out and submit a request for a shipper using the SLAC shipper Form describing the material, to and from information, how it will be paid and the Department of Transportation information that will allow shipping and receiving personnel to appropriately package, label and mark the material. You will need an
MSDS sheet to do this. If you are shipping samples that you have synthesized you will need to generate an
MSDS based on your knowledge.
Shipping and receiving will verify and confirm your shipment. There will be additional screening and certifications required if the material is being shipped outside the country. If your foreign shipment is time critical you are encouraged to discuss these requirements with Pamela Elliott prior to the shipment request.
- What is the Chemical Storage Asset Custodian Program?
The Chemical Storage Asset Custodian program is designed to support the safe storage and handling of chemicals at SLAC. The program has three elements:
Identified custodians for each storage asset (tank, flammable or chemical cabinets, fume hood, gas racks...). The custodian's contact information should be on each asset or in a prominent location for a storage area.
Monthly documented inspections of chemical storage assets. Custodians will inspect their assets to document status, observe and resolve potential problems, and to verify the location is captured on the CMS map.
Mapping of each storage area. All storage assets should be on the CMS map. If, on review, the custodian notes the area or asset isn't accurately captured on the map they should contact Stafford McCaskill to make any corrections.
- How do I become a Chemical Storage Asset Custodian?
Chemical Storage Asset Custodians are those people identified through the Property Control database as having ownership for an asset. Assets include storage tanks, flammable material cabinets, corrosive material cabinets, fume hoods with storage cabinets, other chemical cabinets. For assets that do not have PC numbers (e.g. gas racks) the manager of the operation that owns the asset would appoint a custodian. As temporary default the ESH coordinator for the group may fill the role until a more appropriate employee is identified.
- What are my responsibilities as a Chemical Storage Asset Custodian?
The responsibilities of a custodian include:
- Ensuring compliance with the chemical storage requirements of Chapter 40
- Maintaining documentation about the location, inspection, and testing of chemical assets under their control
Training Requirements: Custodians must take Course 105 Hazardous Materials. If hazardous waste is stored in their asset/area, they must also take Course 105R Hazardous Waste annual refresher
Management Requirements: Custodians are responsible for the management of the asset. This may include securing the asset and limiting use to specified employees, or creating a gate keeper role that would require employees using the asset to get approval from the custodian.
Proficiency Requirements: Custodians must know what is stored in their asset and who uses it. They need to be able to determine if a material is abandoned, expired, or damaged and take steps for its removal. Custodians need to understand how to determine chemical compatibilities and any special storage and handling requirements for the materials in their charge. They need to know what resources are available to them to meet these responsibilities.
Monthly Inspections: Using this knowledge they inspect and assess their asset and document their finding monthly.
- What types of chemical inventories are there and why are they needed?
There are different types of chemical inventories that meet different regulatory and management goals. The two that are currently being used at SLAC are the Hazardous Materials Inventory Statement (HMIS) and the HazCom inventory. The table below compares the similarities and differences:
|Area Of Concern||Fire Control Area or whole building||Work Group storage under control of one supervisor/manager|
|Threshold levels that must be considered||
- 55 gallons or 275 gallons aggregate- lubricating oils
- 55 gallons or more - all other liquid hazardous materials including waste oil
- 500 pounds or more - solid
- 300 gallons - Propane used for heating
- 200 cubic feet or more- all other hazardous material gases
- Any amount of radioactive material that requires an emergency plan under Parts 30, 40, or 70 of Title 10 CFR or applicable quantities specified above, whichever amount is smaller.
|No lower threshold limit -
Includes any hazardous material except :|
- Materials whose hazardous components are inextricably bound in a product and cannot be released,
- Consumer products used for the purpose intended by the manufacturer in quantities not greater than those purchased by the average consumer must be inventoried.
|Does it include hazardous waste?||Yes||No|
|Is there a quantitative element?||Yes - Maximum and average amount for each separate chemical or product stored or used||No - it consists of a list of chemicals used/stored and MSDSs |
|Driver||Emergency Management and Community-Right-to-Know||Worker protection and Right-to-know|
|Driver||HazMat Program manager for site; Building manager||Work Group supervisor|
|CMS/Haas support||Partial - for chemical purchases, does not include process tanks, hazardous waste, or oil filled equipment||Partial - for chemicals purchased since August 2005. Does not include legacy chemicals purchased prior to that date. Does not include chemicals that came from another work area and moved.|
|Documentation||Submitted to the Santa Clara County CUPA and Palo Alto Fire Department at least annually.||Must be able to demonstrate compliance when asked. |
- What is a "control" or "use" area?
A control or use area is a designated area, either indoors or outdoors, within which limited quantities of hazardous materials are allowed to be stored, used, handled, or dispensed. A building is the control area unless there are storage areas designed within the building with specified fire protection (fire walls and doors).
- What is the quantity limit on the amount of chemicals stored within a control area?
It varies and depends on a fire code analysis that considers the type and phase of the hazardous material, presence of fire walls, sprinklers, and approved flammable material and chemical storage cabinets. Only 10 gallons of flammable material may be stored outside a flammable materials cabinet within a control area. Contact the Fire Marshall or the HazMat Program Manager for specific thresholds for your area.
- When anchoring a cabinet for seismic activity, wouldn't the integrity and listing of the cabinet be affected?
Yes, the integrity and listing of the cabinet could be compromised by seismic anchoring. Care should be taken not to alter or damage a cabinet in any way during anchoring. ESH recommends that you contact the manufacturer of the cabinet before anchoring the cabinet.
- Does my flammable liquid and hazardous materials storage locker need self-closing doors?
Since the adoption of the 1979 Uniform Fire Code, a flammable liquid storage cabinet has been required to have doors that are self-closing and tight-fitting. An older cabinet approved without self-closing doors and that has been in continuous use since 1978 in the same location can continue to be used provided it meets all required criteria.
A complete outline of these requirements can be found in the 1997 Uniform Fire Code.
- How do I buy a flammable material or chemical storage cabinet?
Flammable material and chemical storage cabinets need to meet specified performance standards and included on the CMS map. Prior to purchase it is highly recommended that you discuss your storage plans with the Fire Marshall or HazMat Program Manager. Once you are assured that the cabinet will meet the standards you precede with the purchase requisition. You will be listed as the custodian for that asset unless you notify Property Control of another designated custodian.
- How do I get rid of a flammable material or chemical storage cabinet?
Cabinets must be emptied of materials before salvage. Contact Waste Management to dispose of any unneeded, expired, abandoned hazardous materials. Follow the requirements on the salvage form including the removal of any chemical residual. Radiation Protection must scan for activation before it will be accepted by salvage.
Make sure the property control database is updated and no longer lists the salvaged asset. Contact Stafford McCaskill to update the CMS map and chemical storage asset database.
If the removed cabinet does not meet current Fire Code requirement it cannot be reused elsewhere for the storage of flammable materials. It is recommended that it be marked "not for re-use -for salvage only", prior to pick-up.
- What constitutes proper separation of incompatible materials?
Generally, materials which are incompatible may not be stored in the same cabinet.
The following guidelines apply:
- Flammable liquid cabinets should contain flammable and combustible liquids only. Compatible solvents such as methylene chloride and 1,1,1-trichloroethane are allowed.
- Incompatible acids should be stored separately from each other (ie. nitric acid, perchloric acid, acetic acid).
- Acids and bases must be stored separately.
- It is recommended that all cabinets that contain hazardous materials, whether approved or not, be labeled on the outside as to its contents. Letters must be at least 1 inch high (i.e. flammable material, corrosives, bases, acids...)
Incompatible material outside of a cabinet must be segregated by a distance of 20 feet or by separate secondary containments.
- What is the difference between legacy, excess and surplus chemicals and how does it affect me?
Legacy chemicals are chemicals that were purchased prior to the activation of the CMS (Haas) chemical procurement system in August 2005. Legacy chemicals are not tracked within CMS and must be inventoried by the chemical storage asset custodian manually.
Excess chemicals are chemicals that are no longer needed and can be donated to other DOE facilities.
Surplus chemicals are excess chemicals that aren't needed within DOE and can be donated or auctioned to public parties.
Legacy, excess, and surplus chemicals all increase the risk and liability of
managing hazardous materials. If the material isn't being used the custodian
should move it out of their inventory. For more information contact the
HazMat Program Manager or the WasteMin/Pollution Prevention Coordinator.