Tenant Handbook

Hazardous or Controlled Materials




  • Hazardous or controlled materials are generally defined as those having properties that are a physical hazard such as toxicity, corrosiveness, flammability, reactivity, or are regulated because of environmental or health hazard concerns, or are classified as hazardous by the Federal OSHA Communication Standard, 29 CFR 1910 subpart “Z” or the ACGIH threshold limit values for chemical substances and physical agents in the work environment (latest edition). 


Reporting Policy


  • All tenants/contractors shall report all hazardous/controlled materials used or stored within tenant space to Property Management at least annually, or whenever a change in the type and/or quantity of the materials change.  The Hazardous/Controlled Material Storage Questionnaire shall be used for all reporting.
  • Prior to commencement of any work, contractors shall furnish Property Management with a Hazardous/Controlled Material Storage Questionnaire, listing all chemicals intended for use or necessary to the completion of his/her contractual tasks.  Additionally, the location of where the Material Safety Data Sheets will be maintained and copies of any permits and/or registrations shall be provided to Property Management.


Existing Hazardous or Controlled Material


  • All areas of the property have the potential for containing hazardous or controlled materials. Information regarding specific areas may be obtained by contacting Property Management.  Property Management will furnish tenants or contractors with information applicable to their leased space and/or work areas, upon request.


Employee Training


  • It is the responsibility of the tenant and contractor to provide their respective employees with information, training, and essential safety equipment relative to hazardous chemicals or materials in their work areas at the time of their initial assignment and/or whenever a new hazard is introduced into their work area.


Storage and Transfer of Hazardous or Controlled Materials


  • Property Management must review and approve all proposed storage areas for hazardous or controlled materials.  Property Management reserves the right to require specific storage area arrangements including special containment, ventilation, fire protection, construction or other considerations.
  • Methods of storage, use and handling of hazardous or controlled materials shall be in accordance with applicable federal, state, and local regulations and/or with the manufacturer’s instructions.  Prior to storage, Property Management shall conduct a survey of the proposed area to identify active or inactive floor drains or other passages through which spills could be transported.
  • Property Management must review and approve the transfer route of materials from the designated storage area to the point of use.
  • Dispensing of hazardous or controlled materials shall not be done in common areas or other areas not specifically approved or equipped for dispensing.


Operating Procedures


  • Tenants/contractors owning or using the materials shall be responsible for compliance with applicable federal, state, and local laws, ordinances, and regulations applicable to the use, storage, and disposal of hazardous materials as defined in applicable federal, state, and local laws, ordinances, rules, and regulations.  This includes any permits and/or other reporting requirements.
  • Tenants/contractors shall also ensure compliance with the following One Freedom Square chemical safety operating procedures:
    • Flammable and combustible liquids are to be stored in approved, fire-rated flammable liquid cabinets inside the building.  If approved, fire-rated flammable liquid storage cabinets are not available, tenant/contractor shall ensure that flammable and combustible liquids are removed from the building when not in use.  All containers shall be clearly labeled.
    • Tenant/contractor shall ensure that flammable and combustible materials are used with extreme caution when near possible ignition sources.
    • Hazardous chemical containers are not to be stored directly on the floor/ground.  Secondary containers or baffled trays are to be used to ensure containment of potential spills.  Additionally, spill control kits and trained personnel to handle spills shall be provided by tenant/contractor owning or using the materials.
    • All chemical containers utilized by the tenant/contractor shall be labeled in accordance with the state and federal regulations and have a sticker affixed identifying the tenant/contractor by name and emergency phone number, chemical name and hazards associated with the use of the material.
    • All work performed with the following materials [(i) Toxic Chemicals, (ii) Glues, (iii) Urethanes, (iv) Epoxies, (v) Oil Paint, Lacquers, etc. (vi) Any other product containing petroleum distillates or which emits a strong or offensive odor must be scheduled and approved in advance with Property Management.  Depending upon the material, work location, time of day, outside temperature, etc., the appropriate ventilation precautions as listed below shall be implemented.
    • Proper ventilation shall be provided to minimize large concentrations of fumes generated from the materials.
    • Air handling equipment or other building ventilation systems may need to be arranged to minimize the transfer of fumes generated from the materials.
    • It may be necessary to complete the work during non-business hours.
    • It may also be necessary to implement a temporary ventilation system connected directly to outside air.
  • Chemicals of any type are not to be discharged or released into any sewer drain, placed in trash containers, or emptied onto the ground or water.
  • All unused chemicals and/or chemical containers and related waste products are to be removed by the tenant/contractor and disposed of in accordance with all the applicable local, state, and federal regulations.
  • Tenant/contractor shall notify Security at (703) 709-9131 or (800) 899-9872 after hours in the event of any chemical spill or leak in order to initiate required emergency responses, proper notifications and clean-up procedures.  Chemically contaminated debris resulting or arising from actions of the tenant/contractor (i.e., sand, gravel, dirt, concrete) are the responsibility of the tenant/contractor and are not to be disposed of without notification to Property Management.
  • Tenant/contractor shall report the location of any/all observed unlabeled chemicals/materials to Property Management.
  • Consumption of food and beverage is prohibited in areas designated for the storage of hazardous/controlled substances.