Completing a Hazardous Materials Inventory Statement (HMIS)

In the aviation industry it seems that potential hazards are abundant. A common potential risk is the presence of hazardous materials.  In general, these may be kept in small quantities and could include products such as fuels, cleaning agents, or paints. Larger quantities may be required for specific operations.  These specific operations could include agricultural aviation services, where large amounts of pesticides or fertilizers may be stored and used. Another specific operation may be in hangars specifically used for aircraft maintenance.

NFPA 410, Standard on Aircraft Maintenance, provides guidance on the many components of aircraft maintenance that are necessary for successful flight operations.  These maintenance duties consists of work on electrical systems, oxygen systems, fuel systems, and exterior and interior cleaning and refurbishing. These operations often require the use of flammable, combustible, or hazardous materials.

Where hazardous materials are used the Fire Code allows the AHJ (Authority Having Jurisdiction), to require that a Hazardous Material Inventory Statement (HMIS) be completed and submitted. Whether this is required by the local jurisdiction or not, it is a useful tool for facility managers and building owners.  This document allows an individual to quickly see and know what types of chemicals are on the property and what hazards they may pose.

The HMIS will include seven pieces of information for each hazardous material on-site.

1. Hazard class
2. Common or trade name
3. Chemical name, components, and concentration
4. Chemical Abstract Service number (CAS)
5. Physical state
6. Maximum quantity on hand at any one time
7. Storage conditions related to type, temperature, and pressure

Hazard class. The Fire Code and NFPA 400, Hazardous Materials Code, both list fourteen classes of hazardous materials.  All chemicals will fall into one of these categories.

• Corrosive solids, liquids, or gases
• Flammable solids
• Flammable gases
• Flammable cryogenic fluids
• Inert cryogenic fluids
• Inert gases
• Organic peroxide formulations
• Oxidizer solids or liquids
• Oxidizing gases
• Oxidizing cryogenic fluids
• Pyrophoric solids, liquids, or gases
• Toxic or highly toxic solids, liquids, or gases
• Unstable (reactive) solids, liquids, or gases
• Water-reactive solids or liquids

These are each defined within chapter 3 of NFPA 1, and NFPA 400, and in our Glossary of Hazardous Materials and HMIS Data Sheet.

Common or trade name. This is the name of the chemical as it is commonly referred to, as opposed to its chemical name. For example, a common name is ‘antifreeze’, but antifreeze is actual the chemical ethylene glycol. A list of common and trade names of chemicals can be accessed at, https://www5.csudh.edu/oliver/chemdata/com_name.htm.

Chemical name, components, and concentration. This is the full chemical name, or mixture of chemicals, that make a single product.  If the product is a chemical mixture, the concentrations, percentage amounts, of each chemical in the product should be listed.

Chemical Abstract Service (CAS) number. The CAS number is assigned by the American Chemical Society.  All identified chemical substances since the year 1957, some earlier, have been a numerical identifier. All of these numbers, chemical compounds, names and other pertinent information can be found in the NIOSH Pocket Guide to Chemical Hazards, published by the Centers for Disease Control and Prevention.

Physical state.  This refers to the products form. Some hazardous materials can be stored, used, or dispensed in different forms or states. Is the material a solid, liquid, or gas?

Maximum quantity. How much of the product is generally stored on-site? Knowing this information can show the level of risk the facility may be exposed to.  It will also indicate what types of fire protection or special construction features may be needed.

Storage conditions. Various products require different storage methods. Factors to consider may be certain pressures or temperatures the chemical must be maintained at. This will also determine the storage “medium” such as, above ground tanks, pressurized cylinders, plastic totes, or other storage method.

It is important to note that a separate HMIS is required for each building, or structure, that stores hazardous materials. The HMIS information can be documented in a simple, seven column, spreadsheet using Excel or similar software. Or it can be created and maintained on paper using one a template such as the one provided here.

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This article has been re-printed by permission. It originally appeared on the blog page of Aerospace Property Consultants.

Aerospace Property Consultants provide peace of mind to aviation professionals by ensuring the protection of life and property by eliminating risk in aviation investments. Choose Aerospace Property Consultants for risk assessments, site surveys, and hazardous materials inventories.