In the past 12 months, we’ve fielded many questions from colleges and universities, big and small, from across the country, to help them comply with maximum allowable quantity (MAQ) requirements.
MAQ rules are specific thresholds for the amount of any given hazardous material that can be stored in a building at any given time. Since the COVID-19 pandemic, many fire inspectors have renewed their dedication to chemical inspections—with special emphasis on identifying MAQ violations.
Complying with MAQ guidelines can be tricky—in large part, because they require institutions to have a clear picture of all hazardous materials stored on-site, and in every specific location. For decentralized institutions like colleges and universities, this presents a unique and particularly large challenge. It’s a problem that all school leaders and their undersized (and often over-stretched) environmental, health, and safety (EHS) departments must cope with, however.
Higher Ed MAQ Requirements and Enforcement
Let’s look a little more closely at what the MAQ rules stipulate. As this blog has noted, they are a key guide for any higher education (or other) organization. Among their assorted functions, they ensure a facility, and its workforce, are protected from dangerous chemical (or combination of chemical) concentrations.
MAQ rules can vary by state—but the primary guidelines are in the National Fire Protection Association’s (NFPA’s) 400 Hazardous Materials Code. This code defines hazardous materials and offers 14 substance categories—generally based on a material’s chemical properties and flammability. These rules also factor in a building’s layout and designate MAQs based on the site’s fire-control zones.
The rules are heavily enforced, typically by local fire departments, which also handle inspections. In case of violations, inspectors can issue sanctions and demand financial and other penalties. In the last 12 months, we’ve seen increased enforcement at colleges and universities across the United States. Frequently, the local fire departments are pressing academic leadership and EHS departments to devise action plans to provide accurate and transparent chemical counts for MAQ compliance.
The Road to Academic MAQ Compliance
To demonstrate adherence to MAQ rules, inspectors demand that higher education managers produce and share robust chemical inventory reports. To be accepted, these reports must clearly quantify the types and volumes of hazardous materials in each building control zone.
To create these data-rich reports, however, institutions must have already implemented and actively use a modern chemical inventory management system. This will require a solution capable of tracking all incoming chemicals by chemical name, characteristics, and container size. And that is only the minimum requirement for data compilation, as chemical inventories are active, living, and ever-changing.
For example:
- When a chemical bottle is empty, it must be removed from the inventory, or it will erroneously count against MAQ limits.
- Similarly, if a bottle moves from one control zone to another, the transfer must be captured, and again, applied to the official limits.
- And don’t forget about hazardous waste! These materials must be accounted for when measuring MAQs.
Quantifying and measuring relevant MAQ limits require analysis of several of each chemical’s extremely specific characteristics. It also necessitates a detailed breakdown of a facility’s control zones. In turn, this demands accurate and current inventories—and a system to track, in real-time, the movement of chemicals into and out of each control zone.
For these and other reasons, regulatory agencies and inspectors are beginning to reject annual Excel-based chemical inventories. This type of solution is outdated, cumbersome, and error prone. Plus, chemical inventory managers and technicians can’t use Excel to produce timely reports with verifiable, up-to-date data.
University Chemical Inventory Management
Full MAQ compliance is a daunting task for college and university leaders and their EHS departments. It has never been more so than now, given that enforcement agencies are requiring more accurate real-time counts to ensure ongoing adherence.
Over the past year, our MAQ and chemical inventory management experts have been working closely with institutions of varying sizes, from small to very large, across the country. This has enabled them to craft a five-step process that enables higher education institutions to build a sustainable inventory program—and one that can power MAQ compliance. These five steps are listed below.
One: Select a Specialized Chemical Inventory Tracking Database
Historically, to comply with local safety regulations, principal investigators annually submitted Excel spreadsheets to fire departments. However, today, as we noted, more and more authorities are rejecting this format in favor of modern, accurate reporting solutions. To comply, managers must have current chemical inventory systems, with embedded, specialized databases that can capture all required information.
Additionally, managers must have a clear picture of the hazardous materials in each control zone at any given time. This demands a real-time solution that can track chemicals and their associated characteristics. Fortunately, during the past decade, there have been huge technological advances in chemical inventory software. The result: There are some great platforms optimized to handle chemical inventory data.
Two: Go Live With an Accurate Current Inventory
Once you have selected the best software for your chemical inventory program, put it to work, campus-wide, as quickly as possible and to its fullest extent! There are two options for database population, and some safety concerns, which we list below:
- Automated data migration: With this method, managers directly transfer all existing chemical information from an existing electronic repository into the new database solution. Obviously, this is a convenient option for campuses that already have barcoded chemical bottles and easily accessible and accurate inventory information.
- Manual data inputting: This is the most common method, as, typically, managers lack accurate data and haven’t barcoded all their chemical bottles. In this scenario, staff must manually add each bottle’s information—a time-consuming, cumbersome, and hazardous task. Workers must handle each chemical bottle, affix a barcode to it, and enter the content’s complex and very specific chemical characteristics information into the database.
- Safety concerns: During the manual data inputting, the physical challenges are serious, and will vary, depending on the campus’ specific layout and hazards. To reduce the risk of chemical injury or accident in this phase, hazardous material professionals should perform this task. Their skills can reduce the risk of a chemical injury or accident. Also, workers must carefully enter the data, according to the system requirements. Otherwise, they will introduce inaccurate or incomplete information into the solution, which will skew MAQ reporting. Obviously, manual data inputting can eat up vast time and resources: Depending on the amount of chemicals and other factors, this operation can require hundreds, if not thousands, of working hours for each lab.
Three: Diligently Maintain Chemical inventory
The inputting-migration phase ends when a manager has all the chemical bottles barcoded and compiled the relevant data in the solution. The inventory team members can now accurately report on the chemicals at their campus—at least for one day!
Inventories are moving targets. So, it is crucial administrators also develop a system to track new bottles entering (and old ones leaving) the campus. The decentralized structure of colleges and universities poses some unique challenges to execute this program at scale.
Also, there is another obstacle: how to authorize only the best people for system access and updating. The more individual labs allowed to manage chemical movement tracking and barcoding, the greater the risk of introducing inaccuracies. One data integrity workaround, then, is to limit the number of personnel or departments that can touch the system.
Four: Regularly Reconcile Your Inventory
Every chemical inventory program will experience what we refer to as “drift”—or the accumulation of natural variances between database records and actual stock levels. Given the amount of data requiring daily management, drift naturally occurs in every inventory program—even the best-run ones.
Managers with strong programs can minimize drift—if not necessarily eliminate it. Depending on the relative strength of the inventory program, we’ve seen drift run from 10%-80% annually. Unchecked, drift can grow exponentially year over year—so, ignoring it can drive major programmatic inaccuracies.
To reduce drift, we recommend that every program manager conduct a chemical inventory reconciliation at least annually. As with the initial barcoding exercise, reconciliation involves handling all the chemical bottles. This makes reconciliation time-consuming and hazardous—but given the barcodes are already in place, it shouldn’t take as long as the initial go-live preparation.
Five: Find a Chemical Inventory Management Partner
It’s a major feat to design and implement a sustainable higher education chemical inventory management program—especially one that enables MAQ compliance over the long term. It is a complex, risky undertaking that requires the application of many distinct roles and skills.
Additionally, it requires leaders to perform due diligence—that is, to do the proper assessments of the existing chemical inventory program and craft the best management program to improve it. It means stakeholders must analyze the diverse types of inventory software on the market—then select and implement the proper application.
It also demands a clear understanding of MAQ requirements and reporting expectations. Complete program success requires the stakeholders to design specific human workflows and processes. Administrators must also organize individuals to handle very specialized and hazardous tasks, and then lead the team through go-live and into full operations mode.
Lastly, managers must complete these various tasks rapidly in a tightly defined time frame. Such an implementation doesn’t allow room for errors. Therefore, it often makes sense to seek out third-party expertise that can streamline solution design and implementation. A capable partner can also support ongoing maintenance—and help an organization rapidly meet important regulatory requirements, at scale.
Partnering for Chemical Inventory Management Success
Are you an academic administrator or EHS manager who needs to get a better handle on your chemical inventories? Are you considering choosing a partner to assist with MAQ compliance? Are you seeking help with software selection, program design, or chemical handling and data entry outsourcing? Ultimately, finding an expert to complete any phase of a daunting MAQ compliance project quickly (and at scale) can reduce risk and increase the chance for success.
Triumvirate Environmental has partnered with numerous colleges and universities of varying sizes and helped them comply with MAQ requirements. From start to finish, we can assist with project plans and rollout—and then we can help tackle the challenges and manage your program on an ongoing basis. Let’s discuss your needs today.
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