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