Chemical Control

Chemical Control

The purpose of a chemical control program is to protect the product from contamination by any chemicals, as well as employees who may be exposed to the chemicals. 

All facilities will handle some type of chemical within its production areas, whether these chemicals are part of processing or if they are used for cleaning equipment. Some chemicals should be avoided altogether in a facility, while others are allowed but must be used appropriately to avoid contamination of the product or creating risk to employees.

In this training we’ll discuss how to develop a chemical control program for your facility, including:

• Selecting proper storage methods for all non-ingredient chemicals
• Segregating chemicals from non-compatible chemicals and other materials
• Using a log and inventory to document all chemicals in use within the facility and their storage location
• Heeding safety data sheets and chemical labels
• Controlling secondary chemical containers to prevent product contamination
• Approving chemicals brought on-site , and using control measures for contractors who may bring chemicals on site.

Chemical Control

The first step in creating a chemical control program is to put together an exhaustive list of chemicals in use at the facility. It’s important to inventory each area of the facility to identify any risks of cross- contamination with product. It may not be necessary to identify chemicals used in cleaning offices if those offices are completely segregated from the manufacturing area. However, restrooms used by manufacturing employees should be included, especially if they are adjacent to the production area, since employees will travel back and forth between these two areas. Also, keep in mind that chemicals can be in liquid, solid or gas form and include commercial products or generic store-bought products.

Controlled Storage

Chemicals need to be controlled, and this includes how they are stored. All chemicals should be locked away in a storage closet, room, or cage, where only trained and authorized individuals can access them. These individuals should be trained on the how to safely store, use, monitor, and dispose of the chemicals and their containers. Access to chemicals can be controlled in different ways. For instance, if you have a laboratory where chemicals are used by trained lab technicians, then it may not be necessary to lock the chemicals up in a separate storage area inside the laboratory, that is, if all the technicians in the lab are trained and only lab technicians have access to the laboratory. On the other hand, if chemicals are kept in an area that is accessible to trained and untrained personnel, then the chemicals would ideally be stored in a manner that only authorized personnel can access them, such as in a chemicals locker. 

Segregated Storage

Chemicals should never be stored with ingredients, packaging or any other materials used for manufacturing a product.

Also, chemicals in storage should be segregated from each other based on compatibility. Certain chemicals if stored together could pose major health risks if those chemicals were to become mixed. Pay attention to the safety data sheets when planning segregation of chemicals. 

Categorizing chemicals can be useful when planning storage. For example, all cleaning supplies could be kept in the same general area. And sanitation supplies should not be kept with pest control chemicals, for example. Also, chemicals could be separately stored and identified based on their intended purpose, to avoid mix-up. For example, it would not be good practice to store restroom cleaners with product-contact sanitation chemicals.

Labels

For every chemical kept in your facility, an internal label should be created (in addition to the manufacturers label) and a Safety Data Sheet should be made immediately available.  

Internal labels should be created for each chemical for many reasons. 

First, by keeping a record of your labels, you also keep a record of all the chemicals that have been used in the facility. Often one product is replaced with another, but you will need a history of the chemicals used, including replacements over time, in order to comply with regulations.

Also, manufacturer’s labels are necessary, but perhaps insufficient. Your internal label can focus on the information that is most pertinent to your risk assessment and operations. For example, disposal information. Your disposal requirements may exceed those recommended by the manufacturer. If so, you can clearly indicate your disposal requirements on your internal label. 

Safety Data Sheets

A Safety Data Sheet must be available for every chemical in your facility. The Safety Data Sheet provides important information regarding how the chemical should be used, as well as important safety information, such as health risks that come with exposure to the chemical, including any effects the product may have if used improperly.  

All labels and Safety Data Sheets should be kept on file as records in the event that questions arise about how these products were used. The Safety Data Sheet must be retained for 30 years as part of OSHA regulations.

Chemical Approval

A facility should have a way of controlling all chemicals that enter the premises. This is commonly done through creating an approval process. This approval process typically includes the review, approval, documentation, and provision of training for each chemical to be used in the facility. This process helps you to identify each chemical being used, how its being used, risks and safety guidelines, storage guidelines, and proper disposal information. Part of the documentation process includes adding the chemical to logs and inventories and creating the labels and Safety Data Sheets. The approving authority is often responsible for the entire approval process, including making sure that all chemicals are accounted for and documented appropriately, and that all relevant people are properly trained. 

Contractor Chemicals

Often chemicals will be brought on-site by external contractors. For instance, pest control or maintenance workers may bring their own chemicals in to complete a job. It is up to you to ensure that each contractor discloses what chemicals they will be using. Each chemical may need to go through your approval process, or, at the very least, you will need to obtain the product label and Safety Data Sheet for all chemicals the contractor will be using. It is your responsibility, not the contractors’ to ensure that the chemicals are safe for their intended use.  Ensure that you have fulfilled this responsibility before the contractor brings the chemical in the facility.  

Container Control

Some chemicals may be taken from their original package and put into secondary containers, such as spray bottles or buckets. It’s not uncommon to buy cleaning agents in bulk and fill up a secondary bottle that is easier to transport around the facility. These secondary containers should never be reused with a different chemical, no matter how many times it has been cleaned out. To help ensure this happens, it is important that these containers each have their own label that identifies the chemical and any potential hazards. Some facilities may use a color-coding system to identify the level of risk for each chemical, and if that is the case then color-code keys should be displayed throughout the facility for reference.

Chemical Log & Inventory

A log of all chemicals used in the facility should be created and maintained regularly. This log should identify the chemical, its intended use, location of use, and any authorized persons who will use the chemical. 

An inventory should also be kept. An inventory is similar to the log, but it should be kept at the location of chemical storage. The inventory should include the quantity of the chemicals, when and how chemicals are used or replaced, and a date of storage.