By Phil Molé, MPH
Keeping your safety data sheets (SDSs) organized is an important part of chemical management. But as we discussed in a recent blog, it’s only one part.
Knowing what a chemical is doesn’t automatically tell you where it is, how much of it you have, how much you’ve used, or whether quantities have changed enough to affect your regulatory obligations.
That’s where chemical inventory management comes in.
For organizations still relying on spreadsheets, paper records, emails, and manual inventory counts, keeping that information current can become a job of its own.
Your Chemical Inventory Doesn’t Stand Still. Your Management System Needs to Keep Up
If your workplace is like most companies, your chemical inventories are constantly changing.
A shipment arrives. A container moves from one building to another. A maintenance team starts using a new product. One department stops using a chemical, while another increases its use. A container is emptied, replaced, transferred, or disposed of.
Each individual change may seem small. But multiplying those changes across dozens of facilities, hundreds of storage locations, and thousands of chemical products makes it difficult to maintain an accurate inventory.
With a manual system, documenting this change depends on someone first being aware of it, and then updating the right spreadsheet, logbook, or other record. Miss one step and your inventory starts drifting away from reality quickly.
Over time, that gap can become significant. A spreadsheet might tell you a chemical is in one location when it moved to another location months ago. Quantities you see in your inventory list may reflect what was purchased rather than what is onsite. Making matters worse, separate facilities or departments may maintain different versions of the same information because there’s no single source of truth.
At some point, when the need for accurate inventory data becomes most urgent, perhaps after an external audit, a workplace chemical incident or a regulatory inspection, someone needs to reconcile all of it. Unintentionally or not, this establishes a baseline expectation: Chemical inventory management is very hard work, so you’re only going to prioritize getting caught up when circumstances make it a major priority.
This is the epitome of reactive safety management and leaves you chronically unable to leverage chemical information to prevent future incidents, like chemical reactions from incompatible products, explosions from storage at temperatures above recommended ranges, and harmful employee exposures.
The Real Cost Isn’t Just Time Spent Updating Spreadsheets
Manual chemical tracking creates obvious administrative work. Someone needs to collect information, enter it, check it, follow up on missing records, and periodically conduct inventory reconciliations.
But as the previous discussion about chemical incidents shows, the bigger cost is the uncertainty that gaps in manual tracking create. Without a sustainable way to get insights about your chemicals and their hazards, you’re caught in a reactive safety management trap.
How much insight do you have right now about your chemical inventory? Here’s a quick temperature check. Can you confidently answer:
- Which chemicals are currently at each of your facilities?
- Where are they located within those facilities?
- How much of each chemical product is onsite?
- How much was manufactured, processed, or otherwise used during the previous calendar year?
- Which chemicals have entered or left the inventory since your last review?
- Are you approaching a regulatory reporting threshold, whether based on storage (Tier II) or usage (Form R, NPRI)?
If getting those answers requires opening multiple spreadsheets, checking purchasing records, contacting individual facilities, and walking through storage areas with a clipboard, you only have a collection of records that doesn’t translate into a current view of your chemical inventory. That, in turn, leaves you vulnerable to gaps in regulatory compliance and workplace chemical safety.
Chemical Quantities Matter for Compliance
That distinction becomes especially important when regulatory applicability depends on how much of a chemical your organization manufactures, processes, or otherwise uses.
Programs like the U.S. EPA’s Toxics Release Inventory (TRI)/Form R and Canada’s National Pollutant Release Inventory (NPRI) include chemical-specific reporting criteria and quantity thresholds. Determining whether your facility has crossed those thresholds requires more than knowing that a chemical is present.
You need reliable information about the quantities that you use over the applicable reporting period because applicability thresholds are activity-based, meaning they reflect the amounts of the chemical that you manufacture, process, or otherwise use. On reports like Tier II, you also need to provide information about the types of containers the chemical is stored in, including whether it’s found in 55-gallon drums, 300-gallon totes or aboveground storage tanks (ASTs).
It’s difficult to have that level of information when inventory data is scattered across disconnected spreadsheets and paper records.
Consider a chemical that arrives at several points throughout the year and is used by multiple departments. Looking at today’s inventory tells you how much you have now. It doesn’t necessarily tell you how much moved through the facility over the course of the year. That historical picture matters.
If your process for reconstructing that information depends on purchase orders, handwritten logs, spreadsheet entries, and memories from individual employees, determining regulatory applicability becomes slower and more vulnerable to gaps.
Good chemical inventory management gives you a much stronger starting point because you’re maintaining the information throughout the year instead of trying to recreate it when a reporting deadline arrives.
But Remember: Product-Level Inventory Data Is Only Part of the Picture
There’s one more complication.
Regulations don’t necessarily care about the name printed on the side of a drum. They may apply to the individual regulated substances contained within that product.
A facility might purchase several different products that all contain the same reportable chemical ingredient in different percentages by weight. Understanding your potential regulatory obligations may require you to look beyond product-level quantities and understand your inventory at the ingredient level.
That’s where chemical ingredient indexing becomes important. For example, you need to identify chemicals listed as EPA Extremely Hazardous Substances (EHSs) because they’re reportable at much smaller storage quantities. Similarly, poly and perfluoroalkyl substances (PFAS), known as forever chemicals, require more regulatory accountability and stakeholders demand evidence that the companies they support or partner with are exercising good governance. There’s quite a bit more to that process, so we’ll save it for another discussion. For now, the important point is simple: knowing which products you have is valuable, but complete chemical management requires understanding what’s in those products, too.
From Chemical Records to Chemical Visibility
Spreadsheets and paper logs may work when your chemical inventory is small and rarely changes, but inventory size and complexity change the equation.
As inventories grow, facilities multiply, and chemicals move frequently, maintaining an accurate picture manually requires more effort. And especially if you’re still managing your inventory using paper or disconnected systems, that creates more opportunities for information to fall out of date. Modern chemical inventory management is about creating visibility into that movement.
Instead of periodically asking, “What chemicals do we think we have?”, organizations can maintain a more current picture of what chemicals are present, where they are located, and how quantities change over time.
That visibility makes everyday chemical management easier. It also gives EHS teams better information when they need to evaluate reporting requirements, investigate potential exposures, respond to emergencies, or simply understand what’s happening across their facilities. Remember, too, that the most significant reason you need better chemical tracking isn’t compliance related, as important as compliance is. It’s that you need a high level of visibility of chemicals and their associated hazards to ensure that all of your people have the information they need to work safely with the chemicals every day.
Chemical management isn’t just about having the right SDSs and providing employees with access to them. It’s about knowing your chemicals, and understanding where they are, how much you have, and how they’re moving through your organization. And finally, it’s about using all of that information to improve your chemical management practices and keeping all of your people safe.
Are You Ready to Level Up Your Chemical Management?
The VelocityEHS Chemical Management solution, part of the Accelerate® Platform, gives you visibility and control to stay ahead of compliance, act quickly before risks escalate, and keep every shift safe.
Yes, you can maintain an up-to-date SDS library and provide access from anywhere, but that’s just the beginning. From support for workplace container labeling to container-level tracking and inventory mapping to our machine language powered chemical ingredient indexing service, including our AI PFAS Indicator, you’ll finally have all the governance you need in one place.
