chemical security compliance - stony brook university · chemical security compliance surveys must...

Chemical Security Compliance

Surveys must be completedSurveys must be completed by January 31, 2008

Overview of SBU CFATS Requirements

Survey the campusSurvey the campusComplete DHS Top Screen if neededDHS determines “not regulated”

No further action requiredDHS determines “may be regulated”DHS determines may be regulated

DHS assigns Tier 1 to 4 based on level of riskCampus develops a security plan

EHSD0191 (01/08) of 15 www.stonybrook.edu/ehs

Chemical Survey

Appendix A: list of “Chemicals of Interest” (COI)Appendix A: list of Chemicals of Interest (COI)Quantify materials at or above the Screening Threshold Quantities (STQ)

YES: Complete Top ScreenNO: No further action requiredSTQ is for entire campus not individual locationsSTQ is for entire campus, not individual locations

DOCUMENT ALL EFFORTS

Not REAL TIME Inventory

Top Screen is a snapshotTop Screen is a snapshotLargest Quantity in 60 days past or futureNo timeline for additional surveysUpdate or submit Top Screen if inventory changes significantly and STQ exceededchanges significantly and STQ exceeded

Now is the time to get rid of materials that are on the list but you no longer use!


Chemicals of Interest (COI)

Categories:Categories:Release: Toxic, Flammable or ExplosiveTheft: Chemical weapons, precursors, weapons of mass effect, explosives, improvised explosive device precursorsSabotage: Sabotage or contaminationg g

Mixtures must be countedMinimum concentrations for mixtures varies: as low as 1% for Release COI

Chemical Quantities

Include only material in “transportationInclude only material in transportation packaging” bottles:

Excludes materials in beakers, equipment, stationary containers, etc.

All bottles counted as fullChemical Weapons and PrecursorsChemical Weapons and Precursors

Add together the total quantities of all of these materialsSTQ = CUMULATIVE 100 g


Shipping Chemicals

Must count COI SHIPPED by the UniversityMust count COI SHIPPED by the UniversitySHIPPING includes:

Lab moves on public roadsChemicals shipped when a researcher leaves campusOther research shipments

Special Issues:pShipping P or U listed Hazardous waste:

Aluminum phosphideAcetone cyanohydrinPhosphorus pentasulfide

Tracking COI after Top Screen

On going federal requirementOn-going federal requirementPossible methods:

Monitor chemical purchasesMonitor shipmentsPeriodically re-survey campusy y pImplement chemical inventory system


Chemical Security

If COI is less than STQ may still need toIf COI is less than STQ, may still need to implement some security measuresPossible requirements:

Perform Security Vulnerability AnalysisMake security improvements for highest risksy p g

Security measures will be based on risk analysis for each location using COI

Require authorization for purchase or use of COI

Possible Security RequirementsAll unoccupied laboratories must be kept locked at all timesbe kept locked at all times.

Current requirement in Chemical Hygiene Plan

Lock cabinets, freezers, etc. storing COI.Chemical inventories are maintained and highly hazardous chemical inventories closely monitored.Chemical storerooms are kept locked and access limited to specific employees.


Possible Security RequirementsChemicals received by persons other than the

d t t b l ft i dend user must not be left in an unsecured (unlocked) area. Chemical receiving areas (for chemicals not received directly by the end user) must have a receipt log that indicates the name of chemicals received and also the name of the person whoreceived and also the name of the person who the chemical is released to.All employees are expected to wear their ID badges at all times.

EH&S Survey


http://www.stonybrook.edu/ehs/lab/dhs_chem_sec.shtml

Additional Resources

Print this out to start your inventory!


http://www.stonybrook.edu/ehs/lab/dhs_chem_sec_db.shtml

You need a Lotus Notes Account

BEFORE you can use this database.


This is your LOTUS NOTES

login information.

BEGIN HERE

Your inventories will be listed here. You can return to edit them. No other user can access or see your inventories.


All of this information must be

completed.


You must select one of these units.


Even if there are no chemicals on this list in your lab, a survey must be completed!

THIS IS VERY IMPORTANT!


Some TipsHow do I estimate the quantity of the contents in a bottle?

Do not try to estimate the quantity in any bottle. All bottles are counted f llas full.

Do process or secondary containers need to be counted?No. Do not count process or secondary containers. Only count "chemicals of interest" that are in the original manufacturer's containers.

Do I have to count hazardous waste in my accumulation area?No. Do not count chemicals in hazardous waste containers.

The original letter said something about "threshold quantities". Is there a minimum quantity that needs to be counted?

No The "threshold quantity" refers to the entire quantity of the chemicalNo. The threshold quantity refers to the entire quantity of the chemical on campus, not in individual labs or locations. Every container of a "chemical of interest" must be counted. EH&S will total the responses and determine if the threshold quantity has been met.

How do I count my nitrocellulose paper?Do not count nitrocellulose paper, membranes or filters used for Western blots, etc.

Some TipsMy lab has, but no longer uses, a chemical on the list. Do I still need to count it?

If you have, but are no longer using a COI, dispose of it through the EH&S Hazardous Waste collection process. If it is disposed of before 1/31/08 it doesHazardous Waste collection process. If it is disposed of before 1/31/08 it does not need to be included in your inventory.

I have chemicals, but my area is not a "lab". Do I need to complete the survey?

All areas that have chemicals must complete the survey. Some tips:Janitorial supplies are exempt.Aerosol cans ("Dust-Off", other cleaners and supplies) do contain propellants that may be a COI. The University wide threshold for each of these propellants is 10,000 pounds. Do not count these cans, since this quantity will not be reached even if we count every aerosol can.Paint and other general maintenance supplies do not contain COIPaint and other general maintenance supplies do not contain COI.Acetylene and ammonium nitrate fertilizer (23% nitrogen) are COI and must be inventoried.

My area does not have any of these chemicals. Do I need to do anything?

Yes. If your area does not have any COI you must still complete the survey. Use the "NO CHEMICALS" entry at the very bottom of the list and SAVE your response.


Some TipsDo I need to have Lotus Notes email on my computer in order y pto use the DHS inventory?

No. You do not have to use Lotus Notes email or have Lotus Notes installed on your computer. You must have a Lotus Notes username and password to access the inventory through the web. Follow the instructions in the "Troubleshooting Guide" to obtain an account.

I am a Principal Investigator/Lab Manager and have designated someone else in my group to complete the survey. Can I review the surveys that have been entered for my area using my Lotusthe surveys that have been entered for my area using my Lotus Notes account?

Yes. As the PI/Manager, you can see all surveys that were entered under your name, even if someone else entered the data. For surveys that had been completed prior to 1/10/08, the individual who entered the data must go back into each of their surveys and re-save.

Some TipsI am a Principal Investigator/Lab Manager, but my name does p g g ynot appear on the drop down list.

The drop down list is from the Lotus Notes accounts. If your name does not appear there, you must first obtain a Lotus Notes username and password. Follow the instructions in the "Troubleshooting Guide" to obtain an account.

What chemicals on the list have the smallest "threshold quantity" and are therefore the most important to get an accurate inventory across campus?

The 26 chemicals categorized as "chemical weapons" have a cumulative threshold quantity of 100g Contact EH&S if you would like this listthreshold quantity of 100g. Contact EH&S if you would like this list.

Do I need to submit or save the chemical inventory worksheet?No. The worksheet was provided to make it easier for you to take a physical inventory of your lab. The only inventory that is submitted is the online inventory. You can keep the worksheet for records if you want.


Questions?

Check EH&S web site for updates:Check EH&S web site for updates:http://www.stonybrook.edu/ehs/lab/dhs_chem_sec.shtml

DHS FAQsDHS web site FAQs:

http://csat-help.dhs.gov/pls/apex/f?p=100:1:659861960404678#1174

“The purpose of this Part is to enhance the security of our Nation by furthering the mission of the Department as provided in 6 U.S.C. Sec. 111(b)(1) and by lowering the risk posed by certain chemical facilities.”Laboratories & storerooms must be supervised by technically qualified individual:

(1) who, because of education, training, or experience, or a combination of these factors, is capable of understanding the health and environmental risks associated with the chemical substance which isenvironmental risks associated with the chemical substance which is used under his or her supervision, (2) who is responsible for enforcing appropriate methods of conducting scientific experimentation, analysis, or chemical research to minimize such risks, and (3) who is responsible for the safety assessments and clearances related to the procurement, storage, use, and disposal of the chemical substance as may be appropriate or required within the scope of conducting a research and development activity.”


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