Like an unannounced visit from your in-laws, chemical regulators usually show up when you’re least prepared and often throw your whole operation into a panic.
One of the best ways to be prepared for a chemical regulatory inspection is to perform regular internal audits of your chemical inventory and chemical safety programs. Internal audits can help your team identify gaps in your processes, procedures, and inventory before they get flagged (and possibly fined) by an outside regulator. Internal audits can also uncover hazards that could lead to accidents or injuries. What's more, they can help your organization operate with greater efficiency on a day-to-day basis.
So which issues should you be on the lookout for during a chemical internal audit? Each organization will look a little different depending on the types of research performed and the chemicals onsite. However, there are a few common problems that pop up frequently. To help you on your next internal audit, we’ve compiled a list of five common issues to watch for.
Chances are you’ve been on an inspection and seen this before: acids stored with bases. Or oxidizers stored with flammable solvents. Storing incompatible chemicals together can lead to an unintended reaction such as a fire, explosion, or the production of hazardous gasses.
Fortunately, internal audits can help identify storage issues before problems occur. For example, checks for the most common issues — such as acids and bases stored together — may be easy enough to spot that you can have multiple different inspectors keep an eye out for them. This will greatly reduce the potential for an accident without creating more work for your team.
There are also some controls you can implement to prevent these situations from happening in the first place. It starts with educating your user base on proper storage procedures. Make sure researchers know how to identify problematic chemical pairs, how to properly store chemicals, as well as what to do if they find chemicals stored incorrectly. Appointing a point person in each group can help ensure that these procedures are being followed and provide some much-needed accountability. Add to that a good chemical inventory system that gives you visibility into your chemical inventory, and you’ll be well-positioned to pass your next compliance inspection.
Peroxide formers are a common class of chemicals in many research spaces. They encompass a broad range of substances including ethers, acetals, and aldehydes. While peroxide formers are stable under normal conditions, expired peroxide formers can degrade and become unstable explosive materials. Expired peroxide formers need to be identified and disposed of properly. The same goes for peroxide formers that are opened without the date opened marked on the bottle.
As we said before, the best place to start is education. Make sure that everyone who uses peroxide formers (or works in a lab where they are used) has been trained on the correct procedures for adding dates, checking dates, and disposing of expired chemicals.
A good chemical inventory system helps you not only locate peroxide formers, but also stores information about containers and users, manages training, and sends reminders about proper handling procedures. Taking a holistic approach to peroxide former safety will lead to much more effective safety initiatives.
Here’s another common — and dangerous — issue frequently seen in research spaces: flammable substances such as ether stored in a conventional fridge or freezer instead of an explosion-proof one. Sometimes, this happens because a particular lab doesn’t have an explosion-proof fridge or freezer. Other times, it’s an oversight, a lack of knowledge, or simple complacency (“This chemical doesn’t really need to be stored in that fridge down the hall, does it?”).
It’s worth adding this item to your regular inspection checklist so it doesn’t get overlooked. Additionally, you can assign self-inspections to members of a group to specifically check for this issue. Having this be the lab personnel’s responsibility improves awareness and accountability.
Your equipment tracking system should help you quickly locate labs that don’t have an explosion-proof fridge or freezer, and you can cross-reference that with the information from your chemical inventory system to ID the labs that also appear to have explosive substances that should be refrigerated.
When you inspect these labs, you can quickly double-check the regular fridge or freezer to make sure there aren’t any flammables stored improperly and talk to the lab members to see if there is anything you can do to help them store their chemicals safely.
An out-of-date chemical inventory is unsurprisingly a particularly common problem. Whatever the reason, if your internal audits don’t catch these instances, it can lead to a serious violation or fine from a regulator depending on the infraction.
As with most things, an ounce of prevention is worth a pound of cure. In the same way that it’s much easier to keep your house clean if you put your dishes in the dishwasher after every meal instead of letting them pile up, it’ll be much easier to keep your chemical inventory tidy if you have routine workflows for entering and updating information.
To do that, you’ll need to invest in a chemical inventory system that can not only accurately quantify your inventory but also enable scientists and inventory specialists to access, manage, and share information. When it comes to chemical inventory, the volume of work is simply too large to rely on hacked-together systems that aren’t carrying a great deal of the administrative burden for you.
In fast-paced research environments, it’s not unusual for containers from one group to end up in another. Researchers may borrow chemicals and forget to return them to their original shelf or storage location. At best, containers get misplaced and people waste time looking for what they need. At worst, hazardous materials end up unaccounted for or “temporarily” stored in a dangerous location.
Each chemical should have a designated storage area and be returned there after use. Of course, that’s easier said than done. Regular reminders can not only help researchers remember to put things back, they can also help build better habits. By automating these reminders with chemical inventory software, you can dramatically improve compliance.
Regular internal audits can also help to uncover chemicals that are out of place. However, taking inventory with a pen and clipboard can be a time-consuming exercise — especially if you have hundreds or thousands of containers. Using chemical inventory software along with barcoding or RFID speeds up the process, making the auditing process a much more sustainable one.
Additionally, this is another great place to leverage self-inspections, as the personnel in research spaces might have an easier time of recognizing when that tub of salts they borrowed or lent out last week wasn’t returned.
Internal audits are a valuable tool to identify common issues such as incompatible chemical storage, expired or missing chemicals, and out-of-date inventory. Today, technology has simplified that way you can perform these audits. What once took weeks now can be completed in a single day, and you can reap the rewards of a better and more organized research environment.
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