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What is a chemical inventory?

Why have a chemical inventory?

Although establishing and maintaining a comprehensive chemical inventory requires an initial investment of time, doing so significantly reduces resource expenditure in the long term. 

Maintaining a chemical inventory offers several strategic and operational advantages: 

  • All chemical-related information is centralized, simplifying updates and ongoing data maintenance. 

  • Inventory data supports legal compliance documentation, ensuring alignment with regulatory requirements. 

  • The potential impact of upcoming legislation on operations can be assessed quickly and accurately. 

  • Tailored data retrieval is possible, enabling access to specific information as required. 

  • The inventory facilitates verification that all required information is complete and current.

What are the legal requirements?

EE

Estonia

Ohtlike kemikaalide arvestuse kord 

Procedure for keeping records regarding the use of hazardous chemicals 

When keeping records, the following need to be included at a minimum:  

1) Name of hazardous substance, CAS/EC1 number and registration number acc. to REACH;  

2) Name or trade name of the hazardous mixture and list of hazardous ingredients incl. substance identification as in Section 3 of the mixture’s Safety Data Sheet (SDS);  

3) Date of receipt and amount of the chemical;  

4) Usage time and quantity of the hazardous chemical;  

5) Time and quantity of the hazardous chemical transferred as waste for waste management. 

LV

Latvia

/MK noteikumi Nr. 795 Ķīmisko vielu un maisījumu uzskaites kārtība un datubāze 

Cabinet Regulation No.795 Procedures for Registration of Chemical Substances and Mixtures and the Database thereof 

The following information must be collected regarding manufactured and imported chemical substances and mixtures:   

1) Substances:  Trade name, scientific name (IUPAC2), CAS/EC, field of application according to NACE3 code system, Classification and Labelling (C&L), Manufactured amount [t/a]; Imported amount [t/a]; Storage address; SDS; the country from which the substance is imported if the substance falls under the PIC4 regulation; PRODCOM5 code if relevant;  

2) Mixtures: Trade name and composition, IUPAC name, CAS/EC of components, classification of substances, concentration, content of volatile organic compounds (VOC), product group; field of application according to NACE codes, PRODCOM code; amount of manufactured/imported mixture; addresses of storages; the mixture’s SDS; if a chemical substance included in Annex 1 to PIC Regulation is present in the composition, the country from which the mixture is imported shall be indicated.  

LT

Lithuania

Description of the accounting procedure for chemical substances and chemical mixtures 

Order No. D1-360 of the Minister of the Environment of the Republic of Lithuania on July 2, 2008  

The inventory must contain at least: the name of the chemical substance; the name of the chemical mixture; CAS number, the registration number under REACH if granted; the country of origin if imported; the name of the supplier; the amount of the substance/mixture that is purchased, produced, imported, supplied to the market, consumed, or exported. 

PL

Poland

Ustawa z dnia 26 czerwca 1974 r. Kodeks pracy. (Dz. U. 1974, nr 24, poz. 141) z póżniejszymi zmianami  

It is unacceptable to use a hazardous substance or a hazardous mixture without having an up-to-date list of these substances and mixtures and safety data sheets, as well as packaging protecting against their harmful effects, fire or explosion. (Article 221, § 2)  

Ustawa z dnia 25 lutego 2011 r. o substancjach chemicznych i ich mieszaninach  (Dz. U. 2011, poz. 322) z późniejszymi zmianami  

The manufacturer, importer and downstream user are obliged to establish, maintain and update on an ongoing basis a list of hazardous substances or hazardous mixtures produced, imported or used. (Article 25) 

The inventory facilitates verification that all required information is complete and current.

Both the Baltic States and Poland require companies to have a chemical inventory and define the minimum amount and type of information it should include. 

What information should a chemical inventory contain?

A chemical inventory should list all substances and mixtures you use. This includes substances and mixtures which: 

  • Are included in your products, i.e. the mixtures you produce

  • You use as processing agents, e.g. to clean or lubricate your machinery

  • You use for lab analysis, neutralisation of wastewater, etc.

If you use mixtures as input materials, at least all ingredients indicated in the SDS, i.e. which are classified, should be listed separately but clearly linked to that mixture.

Miscellaneous

You may also purchase other types of goods, such as stationary for the offices. Although these goods have no immediate connection to your production, they may also contain chemicals. Therefore, you may include them in the CRM of your company and hence, in the inventory, potentially in a separate section. For non-chemical input materials, include any available information regarding the content of Substances of Very High Concern.

See minimum and additional requirements

Minimum requirements

Type of informationReason
Product/ Trade/ Scientific nameProduct identification.
Hazard statements (from SDS or other sources) – CodesCore information for all risk management, e.g. risk assessment, prioritisation, compliance checking and documentation, answering customer requests, etc.
Content of hazardous substances in mixturesLinks information about substances to the mixture / article of which they are an ingredient.
Unique identifier of substances (e.g. CAS number or EC number) in a mixtureAllows comparison with external sources via these numbers, ensures that substances can be sorted and searched, and facilitates compliance checking.
Concentration (ranges) of substances in a mixtureAllows calculation of annual usage amounts (c.f. above) and compliance checking (e.g. restrictions with concentration thresholds).
Fate/Purpose: included in product xyz or processing aid, such as lubricantsImportant information facilitating monitoring of the flow of chemicals through the company. If substances/mixtures end up in products, the specific product(s) must be listed. For instance, this information can be used for the purpose of compliance checking or identifying impacts of future regulation on the relevant products.
For processing auxiliaries that do not end up in a product, e.g. cleaning agents or lubricants, it is useful to define terms/categories in the inventory to make it easier to sort and search for these terms.
Concentration in the final productThe concentration of a substance in a final product is important so that it possible to verify that the produced mixture complies with restrictions, and to analyse resource efficiency within production.
SDS dateSupports verification that the company possesses the most recent information about chemicals.
SupplierContact information is useful, so that the supplier can be contacted quickly if needs be.
Purchased amount per yearInput information for risk assessment and prioritisation, compliance checking and reporting, assessment of resource efficiency et

Additional requirements

Type of information Why 
Internal identifierMakes it possible to link the inventory to other internal data systems via the internal identifier if one is used.
Stored amount: start of the year
Stored amount: end of the year
Makes it possible to calculate the exact amount used in combination with the purchased amount. Useful to check the applicability of the SEVESO Directive.
SDS locationInformation for everyone about where the SDS is archived.
Legal informationYou may include legal requirements, such as restrictions or if a substance is an SVHC (Substance of Very High Concern).
SDS qualityIt may be useful to centralise this information, so it is accessible to all, e.g. evaluating suppliers.
Supplier evaluationCan be useful to centralise documentation of experience with suppliers, e.g. in order for purchasers or product developers to assess sourcing options for new materials.

Step by step implementation of inventory

It is essential to define the responsibility for setting up and maintaining the inventory and allocate sufficient resources for this. Do not split the responsibilities between departments and staff. However, please note that it is useful to train several staff members to conduct the inventory.  

For instance, you could assign responsibility for the inventory to the purchasing department, the chemicals or environmental manager or to the technical department. Staff should have knowledge about chemicals and the own products and be well connected to other units of the company to ensure information flows. 

Decide on the inventory tool and the type of information to include. 

If you do not use /expand an existing material management system, you may use the excel-template or apply the MS Access®-based inventory tool. Assess at which scale you want to implement a chemical inventory. If your company handles a high number of input materials and products, it may be useful to choose a commercially available tool, as they can handle large amounts of data. 

List substances and mixtures by (trade/product/scientific name)

A list of all purchases should be available in the purchasing department. Use it to include all substances and mixtures purchased, e.g. those bought during the last year. Use the trade or product name of the substances or mixtures for the initial list. 

Get the SDS of all listed substances and mixtures

The safety data sheet (SDS) belongs to the chemical and should provide sufficient information for safe handling and use. It is vital for management of your chemicals that the information is correct and useful, and you should therefore ensure that it is of good quality. This simple checklist shows how you can judge the quality thereof. Checklist for screening the quality of safety data sheet. 
In SDSs, the following can be found: 

  • Substances (as such or mixture components): CAS number and/or EC Number; 
  • Mixtures: substances in the mixture and concentration ranges, The concentration ranges may be rather broad, and it may be necessary to have more precise information about the content of individual substances, e.g. if their use is restricted in the mixtures you produce. In such cases, you should ask your supplier for more information (c.f. chapter 12.3 on supplier communication); 
  • H statements of substances identified in the SDS. You may check the correctness of the H statements of your supplier by comparing them to information in public databases, in particular the classification and labelling inventory by ECHA.7; 
  • Supplier name and contact address; 
  • SDS date. 

Add purchased amounts

Obtain the purchased amounts of substances and mixtures from the purchasing department. Define the period of use as one calendar year or align the period with any relevant processes in the company. 

Add purpose of chemicals

The intended use of a chemical may have to be ascertained from different departments within the company. Product recipes should include information about input materials that end up in the product. Be specific and enter the exact name of the product(s) a substance ends up in. This is important for later analyses of what products are or may be affected by legislation applicable to a particular substance. Information on processing auxiliaries may be available from the technical departments of quality officers. 

Include information about stored amounts

Get data on the stored amounts of chemicals from the staff members responsible for storage and/or if the company has inventoried materials. It is useful to include information about stored amounts at the beginning and the end of the year for which the inventory is set up.

Add additional information

Additional information, such as regarding legal requirements or from internal evaluations of suppliers, SDS, etc. can be added when necessary. As staff members will be the main source of information, instruct them to forward such information to all relevant people who need to be informed. Check what additional information is required and for what purpose. 

How should the chemical inventory be used?

The main purpose of a chemical inventory is to provide structured and reliable data on chemicals that support decision-making and help to answer specific questions. Using the inventory usually involves three steps:  

Define what the company needs to know

For example: Which SVHCs are used in the company and for what purpose? How much explosive material is stored and are safety measures adequate? What quantities of solvents are used and do they exceed permissible thresholds?

Identify the required information based on point No.1 to answer questions: 

1) Lists of SVHCs, purchased amounts, and their use. 2) Lists of explosive substances and quantities stored or purchased. 3) Lists of solvents, their purpose (product or processing aid), and amounts.

Retrieve information from the inventory

Depending on the system:

In Excel – sort and filter data directly. In database tools – run or create queries. In commercial software – use predefined data extraction forms.

The inventory can be used to demonstrate the absence of certain chemicals to the authorities (compliance) or be used as a basis for declaring compliance with specific requirements to customers. 

* When defining this, consider the level of detail required by the company – overall quantities, site- or department-level data, and substance-specific information.

How should the chemical inventory be updated?

The chemical inventory is only useful if it contains complete and up-to-date information. In addition, there may be national requirements stipulating the updating of the inventory. Therefore, it is essential that the following routines are implemented: 

  • Purchasers must ensure that any new products they purchase are included in the inventory. 

  • If it is decided that a certain product is not produced anymore, the relevant product manager must order input materials solely used for this product to be removed from the inventory or marked as “no longer in use”. 

  • Purchasers or technical staff receiving updated SDSs should ensure that new/changed information is transferred to the inventory and that the date of the SDS is updated. 

  • If the composition of a product is changed, the product manager is responsible for providing this information for changing the fate/purpose of the respective input materials, including the concentration thereof. 

  • Purchasers must update supplier information. 

  • If SDSs are quality checked, suppliers evaluated or any other assessments are made which may support decision-making regarding which chemicals to buy and from which supplier, this information should be communicated by the assessors to those maintaining the chemical inventory and included, e.g. as a “note”. 

You may sort the inventory according to the SDS date once a year, and request updated versions of inventories that over 3 years old. 

TOOLS 

  • Chemical inventory 
  • MS Access® inventory 
  • How to use ECHAS