Chemical Regulatory Reporting

Each lab or work area with chemicals needs to submit a report, whether or not the lab or work area has any of the regulated substances.  The report must be submitted by December 18, 2019.

 

SARA, Department of Homeland Security (DHS) and MIT Restricted Poisons reporting has been combined for efficiency.

  • Please submit the combined SARA/DHS chemical regulatory report for your PI or Supervisor's laboratory/ies online at: Chemical Reporting Application in Atlas.  (Go to Atlas, select "Full Catalog" from left menu, then search for "EHS PI Space". Then select "Annual Chemical Reporting".). You must submit the report whether or not you have any of these regulated substances.

  • You will have to provide information on formaldehyde, paraformaldehyde and/or formalin usage in your report.  This includes:how many people in the lab use them, how much is used at a time and how often, where is it being used (fume hood, bench area) and a brief description of the process(es) they are being used in.

  • Detailed set of instructions on regulatory reporting

  • Chemical Regulatory Reporting Worksheet

  • If your lab has a complete, up-to-date chemical inventory in the EHS Office-supported inventory system (EHS Assistant - EHSA), there is a filter you can run to extract your reportable chemicals. Go to Inventory / Quick Chemical Entry and Search, then select List Filter / MITAnnual Chemical Report. On the resulting page, select Options / Export to Excel to see your reportable chemical list. Please note you must have CAS#s associated with your chemicals for this filter to work.

  • If you have a well-formatted Excel or Googledocs inventory (including CAS #'s, chemical names,physical state, quantity, amount and chemical room location), and you would like to have uploaded to EHS Assistant, please send it, and your contact information, to ehs-it@mit.edu and EHS IT will reach out to you to discuss this option.

  • Below is the gas cylinder conversion chart for your use. You can also apply for data warehouse permission to access your lab's compressed gas inventory via the online Airgas Inventory - updated weekly. For instructions... :

 

Chemical Name

Size

Volume (scf)

Weight (lbs)

Ammonia (gas)

 

 

5 and 50

Argon

 

336

24.3

Carbon dioxide

H

437

50

Helium

 

291

21

Hydrogen

200

197

1.43

Hydrogen chloride (gas)

 

 

8 and 60

Nitrogen

H

230

16.7

Oxygen

E

24

2

Oxygen

 

200

14.5

Sulfur dioxide

 

 

5 and 115

  • For further instructions or questions, please contact the EHS Office at environment@mit.edu, or call 617-452-3477.

SARA

As part of the EPA's Superfund Amendments and Reauthorization Act (SARA), Congress decreed that facilities that use large quantities of hazardous chemicals must inform the local community of their presence and work with local fire departments to plan for accidents and releases. These requirements to inform the public of chemical use and storage are known as Emergency Planning and Community Right to Know Act (EPCRA).

 

In order to comply with these regulations, EHS Office requires chemical users on campus to fill out a specific chemical inventory each year, which is then submitted to the local and state officials. A chemicals database by building and room enables the fire department to know what materials are in a building in the event of a fire. Representatives from the Medical Department, the EHS Office, the Nuclear Reactor, and MIT Police participate on LEPC subcommittees and in mock emergency preparedness drills.

 

Department Of Homeland Security (DHS) Ongoing Monitoring Requirement

U.S. Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) are aimed to prevent potential misuse of certain chemicals. The rule’s broad definition of “chemical facility” makes colleges and universities subject to its requirements. The DHS list has 325 Chemical of Interest (COIs) and a reporting threshold limit for each. MIT EHS Office has significantly narrowed this list down to those that might be present in our labs in an effort to make the reporting burden as low as possible.

  • 40 chemicals on the DHS COI list have very low reportable threshold amounts. Under the leadership, advice and counsel of the Committee on Toxic Chemicals, the EHS Office determined the best way to assess the presence of these 40 chemicals is to require that the EHS Rep or lab personnel notify their EHS Coordinator for their department, lab or center any time you purchase or use any of these 40 COIs.

 

Chemical Inventory Requirement

Laboratories working with chemicals are required to maintain a chemical inventory, as specified in the Chemical Hygiene Plan template. Although not mandated by the Institute, MIT’s online chemical inventory application is provided by the EHS Office at no charge.

If you are interested in learning more about the chemical inventory system, please contact the EHS Office (environment@mit.edu or call (617) 452-3477). 

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