1. 12/16/2014 1 What does the Haz Mat Division Do? We provide software and customer support for chemical tracking How Can the Haz Mat Division Help You? - Provides regulatory reports such as HMMP reports - Processes hazardous material permits and fees - Facilitates self and regulatory agency inspections of labs Stanford University Environmental Health & Safety (EH&S) Hazardous Materials Division

2. 12/16/2014 2 HMBP/HMMP Report (Hazardous Materials Business Plan/ Hazardous Materials Management Plan) http://www.unidocs.org/hazmat/business-plan/un-020.doc http://www.unidocs.org/hazmat/business-plan/un-020.doc All facilities in Unidocs member jurisdictions that use or store hazardous materials (defined as either virgin or waste materials) in any quantity are required to report such use or storage to the appropriate local agency. A Hazardous Materials Business Plan (HMBP) is a document containing detailed information on the storage of hazardous materials at a facility. A Hazardous Materials Management Plan (HMMP) contains facilities storage maps and the Hazardous Materials Inventory Summary (HMIS) The intent of the HMBP is to satisfy federal and state Community Right-To-Know laws and provide detailed information for use by emergency responders. The owner of a facility must complete a HMBP if it handles any individual hazardous material or mixture containing a hazardous material which has a quantity at any time during the reporting year equal to or greater than: –500 pounds for solid hazardous materials –55 gallons for liquid hazardous materials –200 cu ft for gases

3. 12/16/2014 3 Information in the HMBP Report Business Activities Business Owner/Operator Identification Hazardous Materials Inventory Summary (HMIS) Facility Map(s) Emergency Contact Information for the building Emergency Response/Contingency Plan Employee Training Plan Recordkeeping *An individual building only has to submit an annual HMMP report containing the first five items above. Stanford University submits a HMBP report every March 1 which includes the last three items and a HMMP report for all campus buildings with chemicals once year according to the EH&S schedule.

4. 12/16/2014 4 What Does EH&S Do With the HMBP? If the campus building is located in Santa Clara County, we provide both the County and the Palo Alto Fire Department with copies. If the building is located in the City of Palo Alto, only the Palo Alto Fire Department receives a copy.

5. 12/16/2014 5 Frequency of HMMP Submission HMMP report is annually submitted one year from the submission date of the last HMMP report. Within 30 days of the occurrence of any of the following events, the HMMP shall be revised and the revisions submitted to the local agency: –(1) There is a 100% or more increase in the quantity of a previously disclosed material –(2) The facility begins handling a previously undisclosed material at or above the aforementioned HMMP amounts –(3) Facility floor plan changes such as lab renovations or lab closure Additionally, if the local agency determines that the HMMP is deficient in any way, the plan shall be revised and the revisions submitted to the local agency within 30 days of the notice to submit a corrected plan.

6. 12/16/2014 6 Hazardous Materials Permit Fee (Effective July 1, 2005 through June 30, 2006) > Go to http://www.ehinfo.org/content > Click on Hazardous Materials Compliance Division >Hazardous Materials Program Home > Fees Hazardous Materials Permit Fee (Effective July 1, 2005 through June 30, 2006) > Go to http://www.ehinfo.org/content > Click on Hazardous Materials Compliance Division >Hazardous Materials Program Home > Fees http://www.ehinfo.org/content FEES: Fees are subject to change July 1 of each year. HAZARD CLASSES: A separate permit is required for each hazard class of material stored. For classification purposes, U.S. Department of Transportation (DOT) Hazard Classes are used. PERMIT CATEGORY: The permit category is determined by Quantity Ranges based on the aggregate amount of materials handled per hazard class.Quantity Ranges

7. 12/16/2014 7 Quantity Ranges and Fees Quantity Range Gallons (Liquids) Pounds (Solids) Cubic Feet (Gases) 1< 55< 500< 200 256 to 550 501 to 5,000 201 to 2,000 3 551 to 2,750 5,001 to 25,000 2,001 to 10,000 4 2,751 to 5,000 25,001 to 50,000 10,001 to 20,000 5 5,001 to 10,000 50,001 to 100,000 20,001 to 40,000 Fees Quantity Range20062005 1$367.00$363.00 2$515.00$509.00 3$586.00$579.00 4$660.00$652.00 5$735.00

8. 12/16/2014 8 HazMat Permit Process Considerations Permit period: 04/01/05 – 03/31/06 Based on inventories as of 01/31 Revoked compressed gas exemptions Per category fees have increased slightly All permit fees based on reporting from ChemTracker inventory Inventory is a Departmental responsibility

9. 12/16/2014 9 Basic ChemTracker Functions Retrieves current inventory (with sorting capability) Allows updating of inventory –Modify current inventory item (i.e. location) –Delete current inventory item –Add new inventory item Provides helpful chemical information –Guidance on chemical storage segregation –MSDS (Material Safety Data Sheets) –Hazard and toxicology information –Chemical structures

10. 12/16/2014 10 ChemTracker/Chemical Inventory Update Main page: https://chemtracker.stanford.edu/ct/stanford.html ChemTracker v.1: https://chemtracker.stanford.edu/stanford/ ChemTracker v.2: https://chemtracker.stanford.edu/ctv2stanford/ https://chemtracker.stanford.edu/ct/stanford.htmlhttps://chemtracker.stanford.edu/stanford/https://chemtracker.stanford.edu/ctv2stanford/https://chemtracker.stanford.edu/ct/stanford.htmlhttps://chemtracker.stanford.edu/stanford/https://chemtracker.stanford.edu/ctv2stanford/ 1. To obtain ChemTracker access: Email the following info to teresaho@stanford.edu or qlwang@stanford.eduteresaho@stanford.eduqlwang@stanford.edu - Your first and last name - PI who “ owns ” the chemicals - Your phone number and e-mail address 2. EH&S will email you your user name and password 3. Log in to the ChemTracker website* *For ChemTracker training, contact Teresa Ho (3-9667) or Julie Wang (5-7521)

11. 12/16/2014 11 What Does EH&S Do With the ChemTracker Information? Assign hazard classification on chemical inventory if information is available on our database Generate Facility Storage Map Generate HMIS report Generate Billing report Generate CBC report upon request Update the LSB boxes annually –Only the front cover page and the chemical inventory summary sheet –Lab personnel update the room map and the Emergency Notification Sheet Room map: http://web.stanford.edu/dept/EHS/prod/researchlab/chem/inven/map/chem_storage_map.pdfhttp://web.stanford.edu/dept/EHS/prod/researchlab/chem/inven/map/chem_storage_map.pdf Emergency Notification sheet: http://web.stanford.edu/dept/EHS/prod/general/erprep/forms/hazmat/erlong.pdf http://web.stanford.edu/dept/EHS/prod/general/erprep/forms/hazmat/erlong.pdf

12. 12/16/2014 12 EH&S Process and Timeline for 2006 Permit Fees OVERVIEW Update notification requests sent to Building Manager or USP Manager distributes to P.I.s and lab managers Review and update inventory and maps 12/10 Report changes to EH&S November County inspections 1/13 EH&S submits final reports February EH&S receives bill and pays fees EH&S requests reimbursement from Departments

13. 12/16/2014 13 Update notification requests sent to Building Manager or USP Manager distributes to P.I.s and lab managers - Requests contain instructions, spreadsheets, timeline, and contact info - Should be forwarded to P.I. or appropriate lab personnel for review - Two types of spreadsheets: “ room list ” and “ gas list ” are generated from ChemTracker EH&S Process and Timeline for 2006 Permit Fees

14. 12/16/2014 14 Review and update inventory and maps 12/10 Report changes to EH&S - Using spreadsheets, current ChemTracker inventory, physical checks, and last year ’ s report, determine if changes to the online inventory are needed. - Make any required changes in ChemTracker. - Using last year ’ s report or current building maps available online at https://maps-secure.stanford.edu/sims/_grs/hazmat/ (must be authorized), determine if changes are needed based on any redistribution of inventory. https://maps-secure.stanford.edu/sims/_grs/hazmat/ - Report changes to Teresa Ho at teresaho@stanford.edu or 3-9667.teresaho@stanford.edu EH&S Process and Timeline

15. 12/16/2014 15 November County inspections - County inspects while EH&S inventory reporting process ongoing. - Entitled to make unannounced inspections but usually calls us first. - Use Life Safety Box report and/or last year ’ s HMMP. - Must be an EH&S representative present (usually CAP team member). - If truly unannounced inspection, follow guidelines published at: http://web.stanford.edu/dept/EHS/prod/aboutus/InspectionGuidance.html or search the EH&S website for keyword “ inspections. ” http://web.stanford.edu/dept/EHS/prod/aboutus/InspectionGuidance.html - If an issue is found, an EH&S representative may search ChemTracker online to determine if inventory is up to date – if so, inspector will pass. - If a citation is issued, we have 30 days to amend and resubmit reports. EH&S Process and Timeline

16. 12/16/2014 16 1/13 EH&S submits final reports upon request –the permit fee is based on last submitted HMMP report February EH&S receives bill, pays fees EH&S requests reimbursement from Departments - If citations found or last minute requests are made ( “ discovered ” issues), the last day we can submit a completed HMMP is 1/13/2006, but we should always wrap up the process as early as possible. - EH&S updates Life Safety Box printouts annually or upon special request. - EH&S receives bill and pays fees in February. - EH&S administrative staff contacts departments for reimbursement. EH&S Process and Timeline for 2006 Permit Fees

17. 12/16/2014 17 Barriers to Compliance Incorrectly or under reported inventory - Department /lab responsibility - General awareness of changes in inventory resulting from changes in research, researchers, equipment, rooms - Maintain reasonably accurate inventories Unlinked inventory - Joint lab/EH&S responsibility. Try to use pick lists to indicate chemicals, careful spelling, and accurate p- states. - EH&S performs SAMONSing, will train if interested Unclassified materials - EH&S responsibility, but if you are using a significant quantity of an unclassified material, we will ask your help - MSDS ’ s, CASnum, manufacturer, product number, etc.

18. 12/16/2014 18 Impact on Stanford University Billing reports are issued at same time, usually in February More inventory to check, new buildings Higher overall fees Inert gas (except Air & helium) exemption phased out aside from the general category increases: T o estimate fee increase due to loss of gas exemption, refer to your most recent HMMP report for section 2.2 Non-Flammable, Non-Toxic Gas, and compare it to a current “Mass Quantity Report by Hazard” for the same hazard category. Take the difference between the two amounts, and subtract from it the current quantities of Helium and Compressed Air. The remaining amount is what will be billed on next permit. Fines for non-compliance are assessed, Stanford University pays, and then passes the cost to the departments.

19. 12/16/2014 19 Hazardous Materials County Inspection List of compliance assistants http://web.stanford.edu/dept/EHS/prod/researchlab/cap/by_bldg.htm http://web.stanford.edu/dept/EHS/prod/researchlab/cap/by_bldg.htm Laboratories should be inspected quarterly, more frequently for some hazardous operations, monthly for special storage room. Lab self inspection list: http://web.stanford.edu/dept/EHS/prod/researchlab/lab/checklists/labshop.pdf Areas that require special attention : Information on the LSB boxes front cover sheet should be in agreement with the chemicals stored in the lab, especially gases information Initial hazardous waste accumulation date needed to be indicated clearly on the container and the hazardous waste has to be disposed within 9 months from its starting date All chemicals have to be stored in a compatible manner, namely, these chemicals would not react violently, generate heat or cause fire if breakage occurs *For additional information, please contact your Compliance Assistant or Russell Furr at rfurr@stanford.edu or 3-7487.rfurr@stanford.edu

20. 12/16/2014 20 2003-2004 Santa Clara County Inspections Frequency of Violations Violation CategoryTotalsPercentage Hazardous Waste55734.97% Separation/Contamination/Monitoring46328.67% Inventory, HMBP/HMMP23314.68% Recordkeeping and Labeling1469.07% Fire1378.63% Training, Emergency Response, Unauthorized 563.53% Other Violations90.44% TOTALS1601100%

21. 12/16/2014 21 Inventory Reduction Suggestions Order the minimum quantities needed Promptly dispose of unwanted materials by submitting a Hazardous Chemical Waste Pickup Form: http://web.stanford.edu/dept/EHS/prod/enviro/waste/pickup/WastePickup_form.htm http://web.stanford.edu/dept/EHS/prod/enviro/waste/pickup/WastePickup_form.htm Keep your ChemTracker inventory up to date and use reports to identify unneeded material. Modify research protocols if possible and appropriate. Share “ stock material ” with other labs if possible. Request revised HMIS submission if required. Email teresaho@stanford.edu or qlwang@stanford.eduteresaho@stanford.eduqlwang@stanford.edu

22. 12/16/2014 22 ChemTracker Assistance To help determine the extent of “ un-linked ” materials in your inventory, run an “ Un-Linked Items ” report from the Mass Quantities Reports page: If there are materials listed that you suspect might be hazardous and are in significant quantities, notify EH&S or your CAP team member.

23. 12/16/2014 23 ChemTracker Assistance You may also want to generate a “ Quantities by Hazard ” report to list your inventory by hazard classification:

24. 12/16/2014 24 Information You Can Find on the EH&S Web Site http://web.stanford.edu/dept/EHS Training http://safetytrain.stanford.edu Chemical inventory https://chemtracker.stanford.edu/ct/stanford.html MSDS http://msds.stanford.edu Chemical Safety http://chemsafetydata.stanford.edu Waste Pickups http://wastepickup.stanford.edu Radiation http://radsafety.stanford.edu Free chemicals http://freechemicals.stanford.edu Forms http://ehsforms.stanford.edu

25. 12/16/2014 25 Questions? For help with your ChemTracker application contact: Teresa Ho 723-9667 teresaho@stanford.edu Julie Wang 725-7521 qlwang@stanford.edu For help with compliance-related issues contact: Your EH&S CAP Team Member or Russell Furr 723-7487 rfurr@stanford.edu