Subject: 2009 Chemical inventory Updates
From: David Shearer
Date: Mon, 30 Mar 2009 14:51:06 -0600
To: ABCD Distribution , NMSU hotline
BCC: David Shearer

EH&S logo


To:          Department Heads, Directors and Deans with areas using or storing chemicals
               Please distribute to all individuals responsible for chemical use/storage


From:      David Shearer, Assistant Director, Environmental Health & Safety (EH&S)


Subject:   2009 Chemical Inventory  (Updates for OSHA and to comply with DHS security chemical rule)


We require your help to ensure that NMSU complies with the OSHA Hazardous Communication Act and with the 2008 DHS Chemical Facility Anti-Terrorism Standards.  Both require the all NMSU facilities with chemicals (including all Colleges, Maintenance, Housing, Research Facilities, Farms,
at all campuses and NMSU owned/operated facilities) review and update their chemical inventories via NMSU HazCom Chemical Inventory System (NOTE: an update within the last 9 months, satisfies this requirement). As part of the update we need for you to be aware of the following:

  1. OSHA Hazardous Chemical  - Any chemical which is a physical or health hazard (has a MSDS) must be inventoried by April 15, 2009 via the Chemical Inventory System (link is on Safety website homepage at http://safety.nmsu.edu).
  2. DHS list for Chemicals Of Interest - In order to determine if any of these are in excess of the screening threshold quantity (STQ) they must be reported via the chemical Inventory System (DHS COI list is at http://www.nmsu.edu/~safety/programs/chem_safety/DHS-ChemsOfInterest.htm).
  3. Chemical Toxin List - The chemical toxins on the list below are to be reported (name, location, quantity, msds, etc) as part of the chemical inventory and to be used/stored under IBC approval (Please call John Balog, BioSafety Manager, EH&S, 646-3327, if there are concerns or questions on allowed use of these toxins).

    Abrin Saxitoxin     Staphylococcal enterotoxins    
    Conotoxin   Shiga-like ribosome inactivating proteins
    Clostridium perfringens epsilon toxin    
    Diacetoxyscirpenol (DAS)
    Tetrodotoxin     Shigatoxin    
    Ricin
    Botulinum neurotoxins      T-2 toxin
Environmental Health & Safety is the lead for OSHA compliance and is the institutional representative to the Department of Homeland Security to determine the reporting for all NMSU facilities.  Affected facilities include laboratories, warehouses, trades, heating/cooling facilities, farms and experimental stations. We recently sent emails to all individual contacts listed in the EH&S web based chemical inventory system and requested an update and identification of COI by April 15, 2009

If you have areas that have not submitted a chemical inventory to EH&S, you must have them submit it now. 
Once the inventories are completed, EH&S will review the inventories and will file a Top Screen with the Department of Homeland Security for any NMSU facility exceeding the STQ.  Department Heads and Directors of facilities with COI in quantities exceeding or approaching the STQ will be advised on additional procedures.


If you have questions or comments on this requirement, you can contact me at EH&S (dshearer@nmsu.edu or directly 575-646-3327)

Thank you
 
David Shearer, Assistant Director,
Environmental Health & Safety,
New Mexico State University,
PO Box 30001 / MSC-3578,
Las Cruces, NM 88003,
Phone: 575-646-3327, Fax: 575-646-7898