DHS Chemical Security FAQ
Do we need to report if we do not have any of the listed chemicals?
Yes, all departments must report, through the database, even if they do not have any chemicals or labs.
What is the time frame?
The rule gives the University 60 days to compile information and report to the Department of Homeland Security (DHS) if we have regulated chemicals.
Departments must complete reporting to EH&S for all labs, shops, and other workspaces housing listed chemicals by January 31, 2008.
What will departments need to do?
Provide current information on any of the Appendix A chemicals that they possesss. This will be done through a new DHS Regulated Chemical Inventory database that is accessible to departments on the DHS Chemical Security page.
Or properly dispose of listed chemicals prior to the deadline.
Provide information on how retained listed chemicals are currently stored.
Inform EH&S of the planned procurement of any of the listed chemicals prior to receipt.
How 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 as 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 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.
My 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 "chemical of interest", dispose of it through the EH&S Hazardous Waste collection process. If it is disposed of before January 31, 2008 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 "chemical of interest". 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 "chemicals of interest".
- Acetylene and ammonium nitrate fertilizer (23% nitrogen) are "chemicals of interest" 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 "chemicals of interest", you must still complete the survey. Use the "NO CHEMICALS" entry at the very bottom of the list and SAVE your response.
Who to contact with questions?
Your Department Laboratory Safety Coordinators
Environmental Health and Safety, Sandhya Muralidharan at (631) 632-9672 or email firstname.lastname@example.org
How do these regulations affect Stony Brook University?
SBU will need to report the current or typical quantity of any of the listed chemicals above the STQ's provided in Appendix A.
DHS will provide SBU with a risk tier classification based on their assessment of the security risk of these chemicals and stored quantities.
All covered facilities will be required to review risks and provide adequate security.
How will SBU comply with these new regulations?
EH&S is coordinating University compliance with the regulations.
EH&S will collect information on the Appendix A chemicals from University departments, compile data for campus locations, and submit a Top Screen covering facilities with chemicals of interest above the published STQ's.
Based on the DHS tier classification, the location of chemicals, and quantities, EH&S will work with DHS and University departments to define covered facilities, and complete any required risk assessments.
EH&S will work with any affected departments to create and implement Site Security Plans to comply with the regulations.
Do I need to have Lotus Notes installed on my computer in order to use the DHS Regulated Chemical Inventory Database?
No, you do not need to have Lotus Notes installed on your computer. However, you must have a Lotus Notes username and password to access the DHS Regulated Chemical Inventory Database 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 enetered 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 January 10, 2008, the individual who entered the data must go back into each of their surveys and re-save.
I am a Principal Investigator/Lab Manager, but my name does not appear on the drop down list.
The drop down list is populated from Lotus Notes. If your name does not appear there, you must first obtain a Lotus Notes account. Follow the instructions in the Troubleshooting Guide to obtain an account.
What chemicals on the list have the smallest "threshold quantities" 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 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.