Maintaining a hazardous chemical inventory is not just a procedural task; it is a legal necessity for businesses that handle, store, or transport hazardous substances. In most jurisdictions, failure to comply can lead to significant legal, financial, and reputational consequences. This article provides a comprehensive, SEO-optimized guide for businesses on what exactly must be done when managing hazardous chemical inventories. We will focus solely on the obligations, requirements, and compliance standards, avoiding peripheral or general safety discussions.
What Is a Hazardous Chemical Inventory?
A hazardous chemical inventory is a documented list of all hazardous chemicals used, handled, or stored at a workplace. It forms a core part of an organisation’s hazard communication program and is a fundamental requirement under occupational health and safety laws.
In the UK, the relevant legal framework is the Control of Substances Hazardous to Health Regulations 2002 (COSHH), while in the United States, the primary legislation is the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS), codified at 29 CFR 1910.1200.
Legal Requirements for Hazardous Chemical Inventories
1. Identify and Catalogue All Hazardous Chemicals
Your company must:
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Identify all chemicals that are classified as hazardous under applicable legislation.
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Catalogue each hazardous chemical on the premises, regardless of the quantity stored or used.
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Update the inventory regularly, especially after introducing new chemicals or ceasing the use of others.
Legal Backing:
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UK (COSHH Regulation 6): Employers must assess the risks from hazardous substances and maintain records of substances and their potential risks.
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US (29 CFR 1910.1200(e)(1)): Employers must develop, implement, and maintain a written hazard communication program, which includes a chemical inventory list.
2. Maintain a Centralized and Accessible Inventory List
Your company must:
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Keep the inventory in a centralized location, ideally both digitally and physically.
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Ensure it is readily accessible to all employees, emergency responders, and safety officers.
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Include product names, CAS numbers, and locations where chemicals are stored or used.
Legal Backing:
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OSHA 29 CFR 1910.1200(g): Safety Data Sheets (SDSs) must be readily accessible to employees for all hazardous chemicals in the workplace.
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HSE Guidance (COSHH ACoP L5): Access to risk assessment records and inventories must be provided to all relevant parties.
3. Ensure Accuracy and Completeness
Your company must:
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Verify chemical classifications to ensure the inventory only includes substances that meet the hazardous criteria.
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Avoid listing chemicals under outdated or generic names.
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Include specific hazard categories such as flammable, corrosive, carcinogenic, etc.
Legal Backing:
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Globally Harmonized System (GHS): Requires accurate hazard classification.
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REACH (EC 1907/2006): Imposes data accuracy obligations on chemical importers and users within the EU and UK.
4. Link Each Entry to Its Corresponding Safety Data Sheet (SDS)
Your company must:
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Ensure that each chemical listed in the inventory has a current SDS available.
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Update SDSs as new versions become available from manufacturers or suppliers.
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Ensure SDSs are compliant with the 16-section format required by the GHS and OSHA.
Legal Backing:
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29 CFR 1910.1200(g)(2): Employers must have an SDS for each hazardous chemical.
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COSHH Regulation 12: Requires employers to take reasonable steps to obtain the latest safety information for substances used at work.
5. Document Chemical Use, Storage, and Quantities
Your company must:
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Record where and how each chemical is stored.
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Include information on quantities—either exact amounts or ranges.
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Track daily usage volumes for high-risk or regulated chemicals.
Legal Backing:
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COMAH Regulations 2015 (UK): Quantities of dangerous substances must be documented for establishments that meet threshold levels.
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EPCRA Sections 311 and 312 (US): Requires documentation of chemical storage locations and amounts for emergency planning and community right-to-know compliance.
6. Conduct Periodic Reviews and Audits
Your company must:
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Audit the chemical inventory at regular intervals, at least annually.
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Review inventory during safety inspections or after incidents.
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Remove obsolete or expired chemicals promptly.
Read Also: Handling Hazardous Materials in the Workplace
Legal Backing:
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COSHH Regulation 6(4): Risk assessments and inventories must be reviewed when circumstances change.
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OSHA Best Practices: Encourage routine checks as part of overall workplace safety programs.
7. Train Employees on Inventory Access and Use
Your company must:
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Provide training on how to read and interpret the inventory.
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Train staff on the use of associated SDSs and emergency procedures linked to listed chemicals.
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Include inventory use in chemical-specific training modules.
Legal Backing:
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29 CFR 1910.1200(h): Employers must train employees on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard is introduced.
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COSHH Regulation 12: Requires provision of information, instruction, and training.
8. Integrate Inventory into Emergency Response Planning
Your company must:
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Share the chemical inventory with local emergency services.
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Use the inventory to develop spill response, fire prevention, and chemical exposure plans.
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Ensure emergency signage and placards align with inventory details.
Legal Backing:
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EPCRA Section 302-303: Facilities must notify emergency planning commissions of hazardous chemicals and assist in the development of emergency response plans.
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Health and Safety at Work etc. Act 1974 (UK): Employers must ensure safety, including through emergency preparedness.
9. Manage Confidential Business Information (CBI) Responsibly
Your company must:
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Protect trade secrets without compromising safety.
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Apply for CBI protection formally when excluding information from public records.
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Ensure that emergency personnel can still access full chemical identities if needed.
Legal Backing:
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OSHA 1910.1200(i): Allows withholding of chemical identities if proper steps are taken to protect trade secrets.
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REACH Article 119(2)(d): Certain information may be kept confidential, but health and safety data cannot.
10. Use Inventory Data to Inform Risk Assessments
Your company must:
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Base COSHH or HAZCOM risk assessments on the chemicals listed in the inventory.
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Use the data to determine control measures such as ventilation, PPE, and substitution.
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Review controls as inventory changes.
Legal Backing:
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COSHH Regulation 6(2): Requires a risk assessment for every hazardous substance used or generated in the workplace.
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OSHA HCS 1910.1200(e): Hazard communication programs must include methods for evaluating chemical hazards.
Read Also: Hazardous Materials Identification System (HMIS)
What Must Be Included in the Hazardous Chemical Inventory?
To comply with regulations, each entry in the hazardous chemical inventory should include:
| Item | Description |
|---|---|
| Chemical Name | Trade name and IUPAC name (if applicable) |
| CAS Number | Unique Chemical Abstracts Service identifier |
| Amount | Quantity in use and in storage |
| Location | Exact area(s) where the chemical is present |
| Hazard Classification | As per GHS or local regulations |
| SDS Link | Physical or digital path to the Safety Data Sheet |
| Use Description | Purpose or function of the chemical in operations |
| Date of Entry | When the chemical was added to the inventory |
| Expiry Date | If applicable, for perishable chemicals |
| Responsible Person | Contact point for issues relating to the chemical |
Penalties for Non-Compliance
Failure to maintain a compliant hazardous chemical inventory can lead to:
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Fines: Up to £20,000 per offence in the UK, and civil penalties of up to $15,625 per violation in the US (as of 2023).
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Criminal Charges: For serious breaches under the Health and Safety at Work Act or OSHA’s General Duty Clause.
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Operational Shutdowns: Regulatory bodies may issue prohibition or improvement notices.
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Reputation Damage: Public exposure of chemical mishandling or lack of transparency can harm brand integrity.
Read Also: GHS Compliant MSDS: What Health and Safety Professionals Must Know
Conclusion
In the hazardous chemical inventory, your company must take a proactive, detailed, and legally compliant approach. Every step—from identification to training and emergency planning—must align with specific regulatory obligations. The inventory should not be treated as a static document but rather as a dynamic, integrated component of your overall safety management system.
By strictly adhering to the legal frameworks such as COSHH in the UK and OSHA’s Hazard Communication Standard in the US, businesses can ensure regulatory compliance, protect employees, and maintain operational integrity.