Chemical Inventory Transition
What do you do with your chemicals and samples when you leave the Lab or change positions?
LBNL has developed updated policy to ensure that chemicals are properly transitioned to a new owner, fully accounted for, tracked, and managed appropriately. This will help to alleviate our ongoing problems with legacy and abandoned chemical containers.
The policy changes are relatively simple and can be summed up as follows:
Before vacating an area or leaving the Lab, chemical owners must ensure that all hazardous materials (including chemicals and samples) are removed, transferred to new ownership, or properly disposed of. Work areas must be cleaned prior to transfer of ownership.
New chemical owners must formally accept the inventory to be transferred, the hazards involved, and the responsibilities as a chemical owner. This process is integrated in CMS 2.0. See the training video for an overview.
Once you know which chemicals are to be transferred and to whom, please contact cms@lbl.gov to have the changes made in our Chemical Management System.
Expand for more information by role.
For Supervisors:
As a supervisor, it is your responsibility to ensure that your direct reports clean out all their chemicals and samples before they vacate a space or leave the Lab. Refer to the section below for more details.
As soon as you know your employee is leaving or retiring from the Lab or will close out his/her lab, check if they own any chemicals (by searching in CMS) and samples (by walking the lab spaces with the departing employee).
Even if the employee will be re-hired or become an affiliate, they cannot be chemical owners anymore. The employee's chemicals will still need to be transferred.
If there are any chemicals and samples, make sure the departing employee follows the guidance below and starts the transfer or disposal request as early as possible.
It is the supervisor's responsibility to verify if the departing employee has chemicals in CMS, monitor progress for chemical inventory transition, and verify completion of transfer/disposal before signing off on the departing employee exit form.
For any deficiencies that are not corrected by the chemical owner, the Division Director is accountable for all deficiencies. The Division line management (supervisor and Division Director) should correct all deficiencies within 3 months of departing employee’s termination date and is responsible for all costs associated with disposing of orphan containers.
For Chemical Owners:
Before vacating an area or leaving the Lab, chemical owners must ensure that all hazardous materials (including chemicals and samples) are removed, transferred to new ownership, or properly disposed of. Work areas must be cleaned prior to transfer of ownership.
If you’re not sure whether you own chemicals in CMS, always check. Go here, under basic search, enter your last name in the “owner’s last name” field. The search will show if you have chemicals under your name and where they are.
The key is to start dealing with your chemicals early, as soon as you’re thinking of leaving or retiring from the Lab or closing out your lab, or preferrably 3 months before your last day.
Go to your lab spaces, identify all chemicals and samples and do a physical inventory. The list in CMS may not be 100% accurate and does not typically include samples.
Make sure all your samples are clearly labeled with the chemical identity/compositions and hazards commensurate with the necessary time to be stored. Initiate a waste requisition for samples that are no longer needed.
Make an up-to-date inventory list for all your chemicals. You may start finding new owners by reaching out to other labs. DSCs and the CMS program manager may also be able to help.
If you have a large number of chemicals and you do not expect others will take them all, contact your waste GA immediately. Depending on how many containers you’re disposing of, your waste GA will inform you the best disposal path. Inform your GA early, especially if you have a large number of containers (e.g., > 200). A vendor cleanout can be scheduled but it can take a few months depending on the waste vendor’s availability. This process is expected to be completed prior to your last day.
If you’re transferring chemicals to others, initiate the CMS inventory transfer request through CMS 2.0 (Training Video). Inventory transfer will take longer if you have high hazard chemicals such as time-sensitive chemicals. All chemicals must be in good condition and all time sensitive chemicals must have a clear testing history and must not be expired to be eligible for transferring. Other high hazard chemicals include pyrophoric chemicals, alkali metals, hydrofluoric acid, and high acute toxicity chemicals. Again, start the process early in case there are chemicals that cannot be transferred and easily disposed of, such as expired time-sensitive chemicals.
Criteria for chemicals that cannot be transitioned to a new owner:
Expired time sensitive chemicals (TSCs) (failed TSCs , failed peroxide formers, or TSCs that have passed manufacturer’s expiration date)
Chemicals that are not clearly labeled or with unknown composition.
Gas cylinders that do not belong to a manufacturer that has an active contract with the Lab
Chemicals that should not be transferred unless there is an immediate research need or other justification provided:
Old high hazard chemicals (e.g. WPC Risk Level 3 chemical hazards > 5 years old)
Chemicals that may become unsafe to transport (per DOT and LBNL’s waste vendors)
For chemicals that cannot be transitioned to or are not accepted by a new owner, work with your Waste Generator Assistant to identify disposal paths.
If you have any questions about inventory search or the hazards of your chemicals, contact your DSC or cms@lbl.gov.
Clean out your workspace or lab space before you leave the Lab.