A level detection float gauge fails in a fuel tank, leading to an overfill and a spill into a storm drain and nearby waterway. A forklift mishap accidentally damages a tank of pressurized gas, resulting in an evacuation. An electrical fire in a facility causes an overpressure event and rupture of a chemical storage tank – resulting in contamination of both onsite and offsite soil. In the immediate aftermath of an unexpected incident, resulting in a pollution release or environmental exposure, the facility needs efficient access to the appropriate response equipment, personal protective gear, and possibly a response contractor. Should the local press show up, facility staff must have a clear understanding of how to interact, as inevitably seemingly innocuous statements are taken out of context on the six-o’clock news.

These incidents have one critical component in common: time is critical. Delay means the potential for greater liability and cost. Hazardous materials and substances can travel rapidly and impact air, soil, surface waters and groundwater, as well as endanger human health.

The Environmental Contingency Plan

To prevent, control, and respond to unexpected releases of hazardous materials, chemical and manufacturing facilities will develop Environmental Contingency Plans. These plans are often referred to as the “Red Binder” or “Red Book.” Conceptually, the environmental contingency plan is the facility’s written road map outlining the actions to be implemented in the event of a hazardous material release. Not unlike a playbook for a sports team, it should be part of staff member training and practiced. The plan should also be periodically updated – to reflect changing facility conditions, surrounding communities, and response capabilities.

A well-developed environmental contingency plan is specific to each facility; there is no one-size-fits-all plan. Each industrial operation and facility is different. The types and quantities of chemicals used are unique to each facility and operation. Some facilities are located in metropolitan areas and others in rural locations, with varying distances from residential and commercial neighbors. The infrastructure and natural resources that could be affected will also differ from one facility to another.

What’s Included in the Environmental Contingency Plan?

The following are some basic sections that should be included in the plan. Because of the complexity of the environmental contingency planning process, development of the plan may require a multidisciplinary team with representatives from operations, facilities, safety, security, and environmental departments.

• Hazard identification and risk assessment: Hazards that are not identified cannot be evaluated. This makes an understanding of the hazardous materials on site critical. Once the materials are identified, the plan should address potential release scenarios and environmental pathways.
• Response procedures: Step-by-step actions for spills, leaks, emissions, containment, isolation, cleanup, and escalation. This should include shutdown procedures, if needed. Employee training is vital to the proper implementation of a facility’s contingency plan. The training must involve all levels of employees – from those responsible for reporting the initial incident to senior-level management personnel who make regulatory notifications and authorize the use of environmental consultants and cleanup contractors. ¨
• Roles and communication protocols: Defined responsibilities, notification trees, and internal and external reporting procedures. In the event of a catastrophic release, having a media relations consultant available to assist with statements or manage press releases can help ensure that the public and other stakeholders receive clear and timely information and can reduce the spread of misinformation.
• Equipment: Spill kits, personal protective equipment (PPE), monitoring tools, and containment materials. There should be documented, periodic inspections of response equipment and PPE; and deficiencies should be corrected in a timely manner.
• Coordination with outside agencies: Information for contacting local fire departments, emergency responders, medical support providers, and regulatory agencies. Larger incidents may require the use of multiple third-party vendors. Vetting vendors as part of contingency plan development is a crucial step in the process. Having current agreements in place with environmental response contractors, environmental consultants, and media relations firms will allow for a timelier response. No one wants to negotiate terms and conditions for service while the building is on fire.
• Recovery and documentation: Procedures for waste handling, investigation, corrective action, and post incident review.

Beyond the Written Plan

Developing a plan is only the beginning. A response plan works only if it is effectively implemented and maintained. Operations change over time through the introduction of new materials, revised processes, staffing changes, equipment modifications, and updated regulations. Facilities should review and update the plan regularly, train employees on their responsibilities, inspect emergency equipment, and conduct drills to determine whether the plan works under realistic conditions.

Inviting local responders to participate in drills or conduct a facility tour is an effective way to inform them of site-specific hazards and assist them in providing a timelier and more effective response. Integrating lessons learned from debriefings after drills or actual incidents is critical to keeping the hazardous materials contingency plan reliable.

Hazardous material contingency plans are facility-specific and based on operational hazards, chemical types and uses, and the response actions to be implemented. Developing and maintaining a response plan is an investment in preparedness, resilience, and responsible operations. For chemical manufacturing facilities, it can make the difference between a limited incident and a large-scale hazardous material release.

How HETI Can Help

The same planning elements that make a contingency plan useful during an emergency also make it challenging to develop and maintain. HETI assists clients with the development, review, and implementation of facility-specific hazardous materials and environmental contingency plans. Our environmental health & safety (EHS), industrial hygiene, environmental, and risk management professionals can help identify release scenarios, evaluate response resources, develop notification and communication procedures, coordinate with emergency responders and regulatory agencies, and support employee training, drills, and post-incident reviews.

We also provide environmental emergency response, regulatory support, compliance auditing, risk management, and remediation-related services to help clients prepare for incidents before they occur, respond effectively when they do, and to help reduce risk exposures and costs.

For further information on HETI’s environmental services, please contact us.

Russell Greatorex Senior Environmental Scientist

Legionella is a naturally occurring waterborne bacterium that becomes dangerous when it colonizes and amplifies in human-made water systems. The most common sources are cooling towers, but may also include hot tubs, decorative fountains, hot water tanks, and complex plumbing systems.

People are infected by inhaling contaminated water droplets (mist), not through person-to-person contact. The resulting illness, Legionnaires’ disease, is a severe pneumonia with an average fatality rate of roughly 10% – rising substantially in healthcare and long-term-care settings. Risk factors for contracting illness include age (over 50 years old), smoking, and individuals with a history of lung disorders or compromised immune systems. The onset of symptoms may occur 2-10 days after exposure. Legionella exposure claims frequently implicate property owners, facility management companies, and water-treatment contractors. Increasingly, cases of illness draw plaintiff firms’ marketing directly to potential claimants within days of a public health announcement.

This issue of HETI Horizons reviews the major confirmed U.S. Legionella events during the past 12 months, the causation patterns responsible parties should watch for, and the regulatory landscape shaping liability exposure. Several of these events, particularly the ongoing New York City cluster, were still under active investigation at the time of writing and figures may have changed since.

Major U.S. Outbreaks: July 2025-July 2026

Over the past year, there have been several Legionella events that resulted in illness and death. As of July 2026, in the Upper East Side in Manhattan, NY, CNN reported 74 confirmed cases of Legionnaires’ disease – including 12 people hospitalized and three fatalities with the illness. New York City (NYC) identified this as a likely community cluster with cases limited to three ZIP codes and by mid-July had inspected all 183 cooling towers in the Carnegie Hill/Yorkville investigation zone – finding 76 with preliminary Polymerase Chain Reaction (PCR) positive results. No definitive source building has been confirmed and officials noted that confirmatory culture testing was being conducted. This incident was the first major test of NYC’s tightened cooling tower inspection law, effective May 2026.

In Westchester County, NY, 37 cases of Legionnaires’ disease, including two deaths, occurred in the Summer of 2025. This incident included a five-case Yonkers sub-cluster in which investigators were unable to match patient sample results to any specific cooling tower.

A similar outbreak of Legionnaires’ disease occurred in July through August 2025 in central Harlem, NY. In this event there were 118 confirmed cases and seven deaths. Genomic sequencing matched clinical sample results to two cooling towers on the same city block – one of the more definitive source confirmations among last year’s clusters.

From August through September 2025, 74 cases of Legionnaires’ disease, including two deaths, occurred in Marshalltown, Iowa. State epidemiologists attributed the outbreak to a cooling tower. The business responsible was never publicly identified, shielded by Iowa’s communicable-disease privacy statute. Notably, Iowa has no statewide cooling tower registration or testing requirement and any future regulation would have to come from local ordinance.

In Ector County (Odessa), Texas,12 cases of Legionnaires’ disease, including two deaths, were reported from November 2025 through January 2026. Local health officials were unable to identify a single source, stating there was no reason to suspect municipal water and instead pointing to individual risk factors such as unsanitized home respiratory equipment.

Over the past year, there were a number of smaller clusters – including a gym in Orlando, Florida (14 cases, 0 deaths), a nursing facility in Bloomingdale, Illinois (2 cases, 0 deaths), a hospital in Cincinnati, Ohio (2 cases, 0 deaths), and a resort in Avon, Colorado (3 cases, 0 deaths).

Why the Trend Line Keeps Climbing

Centers for Disease Control and Prevention (CDC) surveillance data show reported Legionnaires’ disease cases have been rising since the early 2000s, peaked in 2018, and rebounded after a COVID-era dip. 2024 and 2025 provisional figures continue that upward trend, per CDC. Aging cooling tower and plumbing infrastructure; inconsistent water management program adoption; warmer and more humid summers that extend the seasonal risk window; and an aging, more comorbid population all contribute to sustained frequency. Detection is also improving in well-resourced jurisdictions, which increases reported case counts even where underlying exposure hasn’t changed – an important consideration when comparing loss trends across the United States.

Regulatory and Compliance Landscape

Regulations to control Legionnaires’ disease occurrences vary among the states. New York requires registration, annual certification, monthly inspection, and Legionella testing at least every 90 days for all cooling towers – with the law tightened further in May 2026 after the Harlem outbreak. Other states, including Iowa and Texas noted in the events above, have no comparable statewide mandate, leaving water management program (WMP) adoption largely voluntary and governed by industry guidance, such as ASHRAE 188, rather than statute.

Risk Management Takeaways

Reducing Legionella exposure is best achieved through a rigorous building-specific WMP and active case management. Some of the preventative measures that can be taken include:

• Properties with cooling towers, hot tubs, decorative fountains, or complex plumbing (hotels, hospitals, senior living, large multifamily, gyms, resorts) should have a documented, currently maintained WMP, and treatment, if needed.
• Frequency of testing should be in accordance with applicable state/local requirements. Voluntary compliance with ASHRAE 188 should be a minimum threshold – even where no statute exists.
• Source-attribution failure is a real possibility in claims handling; not every outbreak resolves to a single confirmed premises source, which affects both coverage triggers and subrogation potential.
• Rapid plaintiff’s bar activity should be expected following any public health advisory; claims development can begin before final case counts or environmental testing are complete.

How HETI Can Help

HETI’s team of Certified Industrial Hygienists and EHS professionals work with property owners, facility managers, and insurance carriers to reduce Legionella exposure before it becomes a claim. Our services include on-site water system risk assessments and cooling tower inspections; development and audit of water management programs aligned with ASHRAE 188 and applicable state/local requirements; coordination of Legionella sampling, culture, and both PCR or culture testing with accredited laboratories; post-remediation verification/documentation; and rapid-response consultation when a cluster or positive test result is identified.

By combining technical expertise with regulatory knowledge across jurisdictions, HETI helps clients close the gap between voluntary guidance and enforceable compliance – reducing both the likelihood of an outbreak and the liability exposure that follows one.

To find out more about HETI’s industrial hygiene and EHS services, please contact us.

Michael Henderson, PhD, CIH Director, Industrial Hygiene

The reliability of the U.S. electrical grid is under increasing pressure. Aging transmission and distribution infrastructure, combined with more frequent and more severe weather events, has elevated the risk of extended power outages for commercial and industrial facilities across the country. The North American Electric Reliability Corporation (NERC) has identified elevated risk of energy shortfalls during peak demand periods in multiple regions, and has warned that power generation facilities are being shut down faster than new ones are being built to replace them.1 For many businesses, an extended outage is not just an inconvenience; it translates directly into property damage, production loss, and potential regulatory non-compliance.

These realities have prompted facility owners, operators, and their insurers to take a closer look at backup power preparedness. Advances in distributed generation and battery storage technology are expanding the options available beyond traditional diesel and gas generators; and a growing understanding of global fuel price volatility has added another argument for diversifying energy sources. This edition of HETI Horizons examines the current state of grid reliability, key backup power plans and strategies for reducing exposure to fossil fuel supply disruptions.

Grid Reliability Under Pressure

The February 2021 winter storm in Texas provided a prime example of what large-scale grid failure looks like in practice. More than four million homes and businesses lost power, with outages lasting up to several days and resulting in an estimated $195 billion in economic damage.2 The event exposed vulnerabilities in aging infrastructure, fuel supply chains, and weather forecasting that had been known for years but never fully addressed.

NERC’s 2023 Long-Term Reliability Assessment identified elevated risk of energy shortfalls during both summer and winter peak demand periods across the Midcontinent Independent System Operator and Southwest Power Pool regions, as well as portions of the Western Interconnection. Retiring coal and older natural gas plants have left thinner operating margins than traditional grid planning was built around.

For individual facilities, the practical consequence of these trends is that power interruptions are likely to become more frequent, longer in duration, and harder to anticipate. Facilities that have rarely dealt with serious outages may need to take a harder look at whether their backup power is actually adequate.

Emergency Generator Maintenance and Testing

Diesel and natural gas generators remain the most common backup power solution for commercial and industrial facilities, and they remain highly effective when properly maintained. However, generator failure during actual emergencies is not uncommon; and the root cause is usually maintenance related, not a problem with the equipment itself.

The National Fire Protection Association’s NFPA 110, Standard for Emergency and Standby Power Systems, establishes minimum maintenance and testing requirements for emergency power systems. Level 1 systems (those serving critical life-safety applications such as hospitals and emergency response facilities) require monthly testing under load. Level 2 systems (non-critical business operations) must be tested at least every six months.3

Diesel fuel degrades within six to 12 months, and moisture intrusion and microbial growth in fuel tanks can clog injectors and filters, preventing a clean start. Dead starting batteries are among the most common reasons generators fail when actually needed, yet battery condition is often the last thing to get attention in a maintenance program. Loss prevention guidance for emergency and standby power systems recommends comprehensive maintenance programs that include regular fuel testing, annual load testing, and battery replacement on a two-to-four-year cycle.4

Organizations should maintain detailed maintenance logs consistent with NFPA 110 recordkeeping requirements.3 After an outage, a well-documented maintenance history can be the difference between a covered claim and a denied one.

Solar Generation and Battery Storage as Backup Power

Solar photovoltaic systems paired with battery energy storage have emerged as a practical complement to, and in some cases a partial replacement for, conventional backup generators. A solar-plus-storage system consists of solar panels, battery storage, and power electronics that manage energy flow between the panels, the batteries, and the facility’s loads. When the utility grid fails, the system automatically disconnects from the utility and continues to supply power using stored energy and active solar generation.

The economic case for solar-plus-storage has improved substantially over the past decade as equipment costs have declined. Unlike a diesel generator that sits idle between outages and generates no return during normal operations, a battery storage system can reduce peak demand charges, participate in power buyback programs, and serve as a dispatchable resource, providing more value than traditional generators.5

Extended outages – the very scenario that represents the greatest risk – may exceed battery capacity, particularly when solar generation is unavailable due to weather or nighttime conditions. Most commercial installations can sustain critical loads for two to eight hours on stored energy alone. Facilities are therefore pairing a conventional generator for long outages with solar-plus-storage for shorter interruptions. This approach offers additional resilience that neither technology provides on its own.

Fossil Fuel Supply Volatility

The cost of diesel and natural gas is exposed to geopolitical shocks and supply chain disruptions that facility operators cannot see coming. The 2022 Russian invasion of Ukraine and the restriction of Russian natural gas exports, and the ongoing conflict in the Middle East with its disruption of global oil supplies, produced sharp increases in global natural gas prices, with effects that elevated utility costs for everyone. Depending on a single fuel type or supply chain introduces a category of risk that is separate from grid reliability, but just as significant for operating costs.

Solar-plus-storage systems offer a meaningful buffer against these types of uncertainties. Once installed, the operating cost of solar generation is effectively zero and unaffected by commodity markets or international events. Battery storage extends this advantage by capturing excess solar output for use during periods of peak grid pricing or constrained supply. For facilities with substantial generator runtimes, incorporating solar-plus-storage into a hybrid energy strategy can reduce fuel consumption and minimize operating costs associated with price swings.

A facility that draws from multiple energy sources, including renewable generation, grid power, and stored or conventionally fueled backup, is less exposed to any single point of failure – whether that failure originates in grid infrastructure, an extreme weather event, or a policy decision made overseas.

How HETI Can Help

HETI’s staff of engineers, environmental scientists, and technical professionals can assist facility owners and operators in evaluating their backup power preparedness, identifying gaps in maintenance programs, and assessing opportunities to incorporate renewable and distributed energy resources into a comprehensive site energy strategy. Our services in this area include backup power system assessments, emergency response procedure development, maintenance program review, and regulatory compliance support.

References

1 North American Electric Reliability Corporation. (2023). 2023 Long-Term Reliability Assessment.

2 The Perryman Group. (2021). Preliminary Estimates of Economic Costs of the February 2021 Texas Winter Storm.

3 National Fire Protection Association. (2022). NFPA 110: Standard for Emergency and Standby Power Systems.

4 FM Global. (2022). Data Sheet 5-23: Design and Protection for Emergency and Standby Power Systems.

5 Ramasamy, et al. (2021). U.S. Solar Photovoltaic System and Energy Storage Cost Benchmarks: Q1 2021. National Renewable Energy Laboratory. NREL/TP-6A20-81408.

For further information on HETI’s risk management and EHS services, please contact us.

Alexander Ostrobrod,

LSRP Senior Environmental Scientist

Reports of bed bug infestations in the workplace have risen in recent years. Consider this scenario: a facilities manager receives an urgent call. Several employees in an office building have reported itchy welts after returning from business travel. Within days, signs of bed bugs appear in conference room chairs and cubicle partitions. What begins as an isolated complaint quickly escalates into widespread concern, temporary workspace closures, costly remediation, and significant impacts on employee morale and productivity.

Incidents like this are no longer rare. Once considered a problem confined to hotels and residential housing, bed bugs have made a dramatic resurgence across workplaces, healthcare facilities, transportation hubs, and commercial buildings – representing a growing occupational health concern that demands proactive attention.

What Are Bed Bugs?

Bed bugs (Cimex lectularius) are small, flat, oval-shaped insects approximately four-five millimeters long (about the size of an apple seed). They are reddish-brown, wingless, and feed exclusively on human blood, typically at night. During the day, they hide in tiny cracks and crevices – in mattresses, furniture seams, baseboards, electrical outlets, and even behind wall pictures or in luggage.

Unlike many other pests, bed bugs do not breed in filth or require food waste; they thrive wherever people rest or sit for extended periods. They are excellent hitchhikers – spreading easily on clothing, briefcases, furniture, and shared equipment. A single pregnant female can initiate a new infestation that grows rapidly if left unchecked.

Health and Safety Impacts

Bed bugs are not known to transmit diseases to humans. However, their bites can cause significant physical and psychological effects. Common reactions include itchy red welts or raised skin lesions, often appearing in linear clusters. Allergic responses range from mild irritation to severe swelling in sensitive individuals. Secondary skin infections from scratching and elevated indoor histamine levels from shed skins, feces, and saliva may exacerbate respiratory or allergic conditions.

The psychological toll is often more profound. Workers may experience anxiety, insomnia, embarrassment, and social stigma. In severe cases, infestations have been linked to depression, reduced productivity, absenteeism, and even post-traumatic stress like symptoms. For employers, these issues translate into morale problems, workers’ compensation claims, and potential liability under the Occupational Safety & Health Administration (OSHA) General Duty Clause.

Why the Resurgence

Bed bug populations declined sharply after World War II due to widespread pesticide use. Their return since the early 2000s stems from increased international and domestic travel, pesticide resistance in modern strains, reduced public awareness, the popularity of second-hand furniture, and the sharing economy.

Workplaces are particularly vulnerable because employees, vendors, visitors, and contractors unknowingly transport bed bugs from hotels, homes, public transit, or other sites. Sectors at higher risk include hospitality, healthcare, offices with open-plan seating, call centers, and facilities managing shipped goods or furniture.

Detection Challenges and Early Warning Signs

Bed bugs are masters of concealment. Visual inspections often miss early infestations. Key signs include tiny dark fecal spots or blood smears on sheets, mattresses, or walls; cast skins resembling small translucent seeds; a distinctive sweet, musty odor in heavy infestations; and live bugs or eggs in seams and crevices.

Because bites may not appear immediately and can be mistaken for mosquito bites or other dermatological issues, many infestations go undetected until they spread. The “breakfast, lunch and dinner” pattern refers to small clusters of bed bug bites, often in a line or zigzag pattern, caused by sequential feeding on exposed skin and can differentiate from typical mosquito or other bites. Traditional reactive approaches – waiting for complaints – allow populations to explode.

Integrated Pest Management: The Most Effective Strategy

The gold standard for bed bug control is Integrated Pest Management (IPM), which emphasizes prevention, monitoring, and minimal pesticide use. Effective IPM includes routine visual inspections and employee education programs; use of monitoring devices and canine detection teams; non-chemical methods such as heat treatment, steam, vacuuming, and mattress encasements; targeted, low-toxicity pesticide applications only when necessary; and sealing cracks, reducing clutter, and implementing travel protocols.

IPM not only controls infestations more effectively than chemical treatments alone but also reduces risks from pesticide exposure – an important consideration under OSHA and Environmental Protection Agency (EPA) guidelines.

Regulatory and Compliance Considerations

The EPA regulates pesticides used against bed bugs; but specific reporting and management regulations are administered at the state level. While OSHA does not have a specific standard for bed bugs, the General Duty Clause applies, so employers must address recognized hazards that can cause death or serious physical harm. Failure to respond appropriately can lead to citations.

Many states and local health departments also have guidance or requirements for commercial facilities. Bed bug laws and obligations vary by state; but generally, landlords are responsible for addressing infestations, while tenants must report issues promptly. Approximately 23 states have enacted bed bug-specific legislation or regulations; but often the focus is on responsibilities for landlords and property managers. Proactive environmental health & safety (EHS) programs that incorporate bed bug policies, training, and rapid response plans demonstrate due diligence and help mitigate liability.

How HETI Can Help

HETI’s team of certified industrial hygienists and EHS professionals works with organizations to integrate bed bug prevention and response into comprehensive workplace health and safety programs. Our services include on-site risk assessments and facility inspections; development of customized bed bug prevention policies, employee training materials, and response protocols; coordination with licensed pest management professionals to ensure treatments align with IPM principles and minimize chemical exposure; and post remediation verification.

By combining technical expertise, regulatory knowledge, and practical field experience, HETI helps clients reduce the likelihood and impact of bed bug incidents while protecting worker health and organizational reputation.

To find out more about this and other HETI industrial hygiene and EHS services, please contact us.

Stephen Bell, CIH Senior Industrial Hygienist

A laboratory technician opens a long-forgotten cabinet and finds a sealed bottle of diethyl ether with crystalline material forming around the cap. Unknown to the current staff, the solvent has sat undisturbed for years – slowly forming explosive peroxides. What began as routine housekeeping now presents an immediate detonation hazard.

Incidents like this are not rare. Incompatible chemical storage, degraded materials, and abandoned containers continue to drive fires, exposures, and costly emergency responses across industries. In many cases, the root cause is not the chemical itself; it is the absence of an accurate, actively managed inventory.

For organizations managing chemical risk, the question is not simply “What do we have?” but “Do we actually know what we have – and is it being managed appropriately today?”

When Inventory Fails: Preventable Incidents

Chemical incidents tied to poor inventory management tend to follow familiar patterns. Peroxide-forming chemicals, such as ethers and certain olefins, can become increasingly unstable over time. Without tracking receipt dates, opening dates, and storage conditions, these materials may remain on shelves well beyond their safe lifespan – transforming into shock-sensitive hazards.

In other cases, incompatible chemicals are stored in close proximity due to space constraints or poor labeling practices. Oxidizers stored alongside organic materials, or acids stored near cyanides, can create conditions where a simple container breach escalates into a fire, toxic release, or both.

A third common issue is the accumulation of “legacy chemicals” – containers left behind by prior staff, contractors, or tenants. These materials are often unlabeled, degraded, or unknown – complicating emergency response and disposal. For insurers and property stakeholders, such unknowns represent unquantified liability.

Each of these scenarios shares a common thread: the organization lacked a current, verified understanding of what was present on-site.

The Regulatory Backbone: More Than a Paper Exercise

Regulatory frameworks reinforce the importance of maintaining an accurate chemical inventory; but compliance alone does not guarantee safety.

Under the Occupational Safety & Health Administration’s (OSHA’s) Hazard Communi cation Standard (29 CFR 1910.1200), employers are required to maintain a list of hazardous chemicals and ensure that Safety Data Sheets (SDS) are readily accessible. This inventory forms the foundation for employee training, labeling, and hazard communication.

However, the regulatory landscape is evolving. The Environmental Protection Agency’s implementation of the Toxic Substances Control Act (TSCA) increasingly emphasizes “conditions of use,” requiring organizations to understand not just what chemicals are present, but how they are handled in specific operational contexts. This shift places greater importance on accurate, site-specific data.

An incomplete or outdated inventory can lead to cascading compliance failures: incorrect hazard classifications, improper personal protective equipment (PPE) selection, and training programs that do not reflect actual workplace risks. From a regulatory standpoint, if an organization cannot demonstrate control over its chemical inventory, it is unlikely to be viewed as compliant.

Chemical Inventory and Hygiene Audits: A Proactive Approach

A growing best practice is the implementation of what can be termed a “Chemical Inventory and Hygiene Audit.” This process moves beyond simple recordkeeping to provide a structured evaluation of chemical risk at the facility level.

A comprehensive audit typically includes:

• Verification of inventory accuracy through physical inspection
• Assessment of storage compatibility and segregation practices
• Review of labeling and alignment with current SDS information
• Identification of time-sensitive or unstable materials (e.g., peroxide formers)
• Flagging of chemicals subject to specific regulatory requirements
• Evaluation of opportunities for elimination or substitution

Importantly, these audits also provide a mechanism to apply the Hierarchy of Controls in a meaningful way. By identifying unused, redundant, or high-hazard chemicals, organizations can eliminate risks entirely or substitute less hazardous alternatives – often achieving greater risk reduction than PPE or administrative controls alone.

Rather than reacting to incidents or regulatory findings, organizations that conduct periodic audits can identify and address risks before they escalate.

The Hidden Risk: Inventory Drift

One of the most persistent challenges in chemical management is “inventory drift”: the gradual divergence between documented inventory and actual conditions on-site. Over time, chemicals are consumed, relocated, repackaged, or abandoned without corresponding updates to inventory records. New materials are introduced without full integration into the Hazard Communication program. The result is a growing gap between what is believed to be present and what actually exists.

This gap creates both regulatory and financial risk. Inaccurate inventories undermine training programs and PPE selection – increasing the likelihood of worker exposure. An unmanaged inventory represents an unknown risk profile – one that may only become visible after a loss event. In practical terms, an unmanaged chemical inventory is not just a safety issue; it is an unquantified liability.

How HETI Helps

HETI works with organizations across industries to transform chemical inventories from static lists into active risk management tools.

Through on-site chemical inventory audits, HETI’s Certified Industrial Hygienists verify the presence, condition, and storage of chemicals while identifying gaps in compliance and risk controls. This process goes beyond counting containers; it involves interpreting regulatory requirements, evaluating storage practices, and identifying chemicals that present elevated risk.

HETI also supports the development and implementation of Hazard Communication programs that are aligned with actual site conditions. This includes updating written programs, ensuring SDS accuracy, and delivering targeted training that reflects the specific hazards present in the workplace.

For clients in insurance, real estate, and industrial operations, these services provide critical clarity. Accurate inventories support due diligence, improve risk assessment, and reduce the likelihood of unexpected liabilities tied to chemical hazards.

In an environment where regulatory expectations and chemical risks continue to evolve, proactive inventory management is no longer optional. It is a foundational element of operational resilience.

To find out more about this and other HETI industrial hygiene services, please contact us.

Kevin Murphy, CIH, CSP Senior Industrial Hygienist

Jim Durant, MSPH, CIH Senior Industrial Hygienist