Effective chemical control is an essential part of maintaining a safe workplace. It helps minimize the risk of employee injury due to improper use of chemicals and helps limit potential product contamination.
Hazard Analysis Critical Control Point (HAACP), and other food and feed systems, require chemical control programs. Address each of the following topics in your chemical program to meet the requirements outlined in OSHA’s Hazard Communication standard (HCS) and industry standards (29 C.F.R. § 1910.1200.)
Establish a safety team for chemical purchase approval
Establish a food safety team to manage essential pre-requisite programs, such as chemical control. Designate one or more members to serve as a chemical approval team to evaluate chemical purchase requests and give purchase approval.
The chemical approval team should:
- Review chemical purchase requests to authorize the intended use and location of use
- Verify that requested chemicals are safe for food and feed operations and contact surfaces
- Check if a similar chemical is already available in the facility. If so, decide whether both are necessary or if the former chemical can be eliminated.
Keep chemical labels and Safety Data Sheets for reference. The labels contain important usage information and the Safety Data Sheets detail specific chemical hazards.
Develop a master list of approved chemicals
Develop a master list of all approved chemicals that identifies the name, manufacturer, intended use, locations of use and departments authorized for use. Divide the list into categories, such as boiler and water treatment, pesticides, herbicides, laboratory, janitorial, sanitation and maintenance. This list serves as a reference for departments to learn which chemicals are approved for regular purchase.
Receiving and storage of chemicals
When accepting a chemical shipment, receiving personnel should verify that each chemical is on the master list of approved chemicals and update chemical inventory logs to reflect the current quantity and lot numbers.
Chemicals should never be left unattended. It could lead to mishandling or misuse by personnel who are not trained to use chemicals safely. Receiving personnel should keep chemicals in designated storage areas and notify the appropriate department of the arrival. Move unapproved chemicals to a controlled storage area until the chemical approval team determines to accept or return it.
Controlled storage areas for chemicals
Controlled storage areas restrict chemical access to authorized personnel using electronic keypads or badges, padlocks or key locks. Some companies incorporate security cameras to keep digital records of personnel entering and exiting these areas.
It is essential that authorized personnel maintain control of chemical containers during usage and that chemicals are returned to the controlled storage area upon completion of the task. It is also beneficial to maintain a list of the chemicals stored in each controlled storage area.
The setting and type of chemical influence what kind of controlled storage area is suitable. Chemical cages or designated rooms may be needed to store pesticides or chemicals for maintenance, sanitation or boiler and water treatment, while controlled access closets are often appropriate for storing janitorial chemicals. Laboratory chemicals should be stored in controlled access cabinets in the laboratory itself and, in some circumstances, it may be best to secure the entire laboratory. Some storage areas may require spill containment equipment, ventilation and personal protective equipment (PPE.)
It may be necessary to separate certain chemicals within controlled storage areas. For instance, separation may be required to prevent non-compatible chemicals from generating dangerous gases that could cause serious respiratory injury. Sometimes separation is necessary to isolate specific chemicals from a particular ingredient, packaging, work-in-progress or finished product. It also helps avoid cross-contamination (for example, food grade and non-food grade lubricants should be stored separately; sanitizers and general cleaning chemicals should be stored separately.)
Labelling chemical containers
The original chemical container labels detail appropriate handling and usage requirements. When transferring chemicals to secondary containers, it is imperative that the secondary containers be labeled properly to comply with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and OSHA Hazard Communication standard (HCS) (29 C.F.R. § 1910.1200.)
The label must indicate the chemical name and the hazards present. There are many ways to communicate this information, such as color-coding or attaching laminated or engraved identification tags. Select a system that will work for each location.
Secondary containers must comply with labeling requirements if any of the following occurs:
- The employee who made the transfer does not use all of the chemical during the work shift
- The employee who made the transfer leaves the work area
- The employee who made the transfer is no longer in possession of the container and it is moved to another work area
Labels on secondary containers are not required if the employee who made the transfer uses all of the contents during the work shift.
Chemical inventory logs and usage records
It is important to keep accurate documentation of chemical inventory and usage records, in fact, many third-party audit programs require these records.
Update the chemical inventory log with the new inventory quantity upon receiving a new shipment of chemicals. If you are adding chemicals to a bulk storage container, record the total amount of chemical in the container. If the chemical arrives in individual containers, it may be more efficient to track containers (for example, 14 cartridges of food grade grease) or in the quantity of chemical present (for example, 10 gallons.)
Usage records track the amount of chemical used and where it is used. You can use electronic dispensing systems to track specific usage amounts of chemicals stored in bulk containers. Many companies find electronic dispensing systems advantageous because they can record the quantity of chemicals remaining, reduce chemical overuse by only dispensing predetermined amounts at designated times and control chemical access by requiring a password, user ID or electronic access card.
It may not be possible to track specific usage amounts of chemicals packaged in containers such as aerosol cans or grease cartridges. In these instances, the inventory log should be updated as containers are taken from the controlled storage area.
Chemical concentration verification
Sometimes chemicals are in a concentrated form and need to be diluted or mixed. Refer to the chemical label for the required concentration, diluting method and mixing instructions.
Concentration checks may be necessary to ensure the appropriate concentration has been mixed. For example, some cleaning chemicals and sanitizers require specific concentrations for usage. When used at the proper concentration, they may not require a potable rinse from equipment surfaces. However, if they are used at a higher concentration, equipment surfaces require rinsing.
Consult with the chemical supplier regarding the best method of verifying chemical concentrations. Concentration checks may be conducted via titration, test strips, chemical meters, etc. If metering systems are used, calibration of these devices should be conducted on a pre-determined schedule.
Proper disposal method for chemicals
Chemical container disposal protocols should be implemented and chemical label instructions should be followed for appropriate procedures. For example, some pesticide labels state that the container needs to be punctured and triple-rinsed before disposing. Chemical containers should never be reused for other purposes within the operation.
Chemical spill containment procedures
Chemical spills may occur in the storage area or during usage. According to OSHA’s HCS, the Safety Data Sheet must detail accidental release measures, such as personal precautions, PPE, emergency procedures, methods and materials for containment and clean up (29 C.F.R. § 1910.1200.)
Spill containment devices and materials should be present in chemical storage areas and authorized personnel should know how to use them. Appropriate disposal considerations should also be followed.
Chemical spills and clean-up procedures should be documented on a company-approved form for recordkeeping. See OSHA’s HCS for further information on spill containment.
Chemicals and contractors
Contractors often use chemicals while completing their tasks. Assign authorized personnel to oversee contractors to help ensure that your chemical control program is followed. This may include obtaining chemical approval and Safety Data Sheets, updating chemical inventory and usage records, maintaining controlled storage areas while on-site and performing proper chemical applications.
Training for chemical usage, storage and application
Authorized personnel should be trained in chemical usage, including proper storage, application and documentation (such as, inventory logs and Safety Data Sheets.) They must understand the health hazards of the chemicals they utilize and be trained to use PPE and perform first aid (29 C.F.R. § 1910.1200.)
It is important that all personnel understand that mishandling chemicals creates a risk to themselves and the food or feed being produced. In addition, all personnel should receive general chemical training and education on company protocols, (for example, controlled storage access requirements, prohibited use of unapproved chemicals and personnel authorization for chemical usage.) All personnel should be instructed to report suspicious activity, unsecured areas or missing chemical quantities. If a color-coding program is utilized, all personnel should be aware of color designation and usage.
Implementing and maintaining a fully developed chemical control program
Implement and maintain a fully developed chemical control program. It is a vital component of food and feed pre-requisite programs by helping increase employee, customer and product safety. Conduct periodic inspections to help ensure compliance with industry and regulatory agency standards.
Contact your Nationwide risk management consultant to learn how our team of food safety experts can help you create a safer workplace.