United States Department of Agriculture 

Animal and Plant Health Inspection Service 

WS Directive 2.465 1/02/08

ACCOUNTABILITY AND OVERSIGHT OF HAZARDOUS MATERIALS

1. PURPOSE 

To provide guidelines for maintaining accurate hazardous material inventories and 

records, and to established accountability and oversight by all field personnel, supervisors 

and managers. 

2. REPLACEMENT HIGHLIGHTS 

 This directive revises WS Directive 2.465 dated 11/23/04. 

3. POLICY 

Accountability and oversight of hazardous materials (as defined in the Control Materials 

Inventory Tracking System (CMITS) Users Guide) is the responsibility of pesticide users 

as well as supervisors in WS Operations. To ensure that these activities are conducted in 

an orderly manner, several requirements are implemented. 

All users of hazardous materials will conduct a quarterly physical inventory using the

CMITS application within the Management Information System (MIS) to reconcile the 

perpetual inventory. 

During the fiscal year, at least one annual physical inventory will be conducted by the 

hazardous material user and one reviewing official (i.e., District Supervisor, Assistant 

District Supervisor, collateral duty safety officer) designated by the State Director. In 

addition, State and District offices with a hazardous material inventory will conduct at 

least one annual physical inventory which will be verified by a second party other than 

the official responsible for this inventory. Annual inventories will be signed and dated by 

all associated individuals after conducting the inventory and submitted to the State 

Director for concurrence and use in compiling the annual State inventory. 

All hazardous materials discrepancies will be resolved by the pesticide user and/or the 

reviewing official at the time of the physical inventory, if possible. This inventory will 

be reviewed by the immediate supervisor or designated official within 14 days of receipt 

of inventory record. All discrepancies will be corrected and accounted for in the MIS 

CMITS application within 30 days. 

Other deficiencies not associated with the inventory (i.e. inadequate storage containers, 

equipment) that have been identified in the inspection or review process will be 
addressed and resolved within 60 days. The appropriate supervisor will follow up prior 

to the next quarterly inventory to ensure these deficiencies have been addressed. 

All hazardous material users will submit copies of their certified inventories to their 

appropriate District/State/Regional Office. State Offices will submit annual State 

inventories using the CMITS form entitled “Transaction Summary by Product” to their 

appropriate regional office. The State Transaction Summary by Product Report will be 

signed and dated by the State Director and Regional Director certifying that the inventory 

is correct and current. Copies of these signed annual State inventories will be mailed by 

the Regional Office to the Operational Support Staff (OSS) for further review and 

concurrence. 

The State Director is ultimately responsible for ensuring that all discrepancies have been 

corrected. The Regional Director (or designated official) will further ensure that all 

inventories within the Region are accurate. 

All State Program Evaluations will include conducting at least two physical inventories 

and storage site inspections of hazardous materials, one at a central storage/distribution 

facility (i.e. State or District Office) and the other at a field Wildlife Specialist’s storage 

site. These inventories and inspections will be compared with those records in the state 

MIS based CMITS to ensure hazardous materials accountability and accuracy. The 

review team comprised of Regional, State, and Headquarters representatives will conduct 

the State Program Evaluations. Some of the subject matter that will be reviewed 

regarding hazardous materials is as follows: security, storage, warning signs, inventory, 

receipt of and transfer documentation, handling, disposal of any pesticides, I&E drugs 

and pyrotechnics, etc. Inventory discrepancies and results of the storage site inspections 

will be noted in the State Program Evaluation report, as appropriate. 

The National Wildlife Research Center (NWRC) will continue to verify and account for 

pesticide usage in accordance with their Chemical Management Plan. Copies of NWRC 

certified annual inventories will be provided to OSS for analysis and concurrence. 

4. REFERENCES 

 

WS Directive 2.401, Pesticide Use (1/02/08). 

WS Directive 4.210, Program Evaluation (3/1/04). 

Deputy Administrator