The ingredients of a sound chemical safety program include an accurate chemical inventory, on-demand safety data sheets (SDS) and an efficient, yet robust chemical approval process. While there are many approaches to track chemical inventories and approvals, there are some best practices to achieve chemical compliance and ease the burden of managing your chemical inventories. In this post, we’ll discuss how companies today utilize a mix of business process and software to achieve worker safety and hazard communication compliance.
Process as Prevention
As with our own health, the best medicine is prevention. Identifying and tracking hazardous chemicals coming into a facility is the best way to boost your chemical safety efforts and better prepare your organization for any regulatory spot-checking. By taking a preventative approach through a well-designed chemical introduction process, rather than relying solely on prescriptive measures based on periodic inventories, your understanding of your organization’s chemical footprint gains immediacy and transparency.
A good chemical approval process contains three vital elements: the approval form, an approval process, and technology to run the workflow. The approval form contains all relevant chemical, use and regulatory data required for approval. The approval process is the logic and step flow of appropriate reviewers and approval steps. Finally, the technology is the software that powers the form and business logic through the workflow process.
Make Your Approval Form Work for You
A chemical approval form is a document of record, completed and submitted online or in print, that enumerates the data that initiates the request as well as data required for the material to be approved for the facility. Often created by the EHS team or safety manager, the form outlines the required and optional fields to be completed for chemical approval.
The form is then incorporated in the business process developed by the safety team. Again, the entire process can either be virtual, through the use of software and online workflow tools, or physical where individuals physically pass a paper document around for sign-off or via email.
A significant advantage of an online document workflow is the opportunity for dynamic response and action. In a dynamic form, the questions and fields can change based on the previous answers, whether in terms of data input or on the unique requirements of your process itself. For example, online forms can dynamically expand or contract depending on the hazardous nature of the material. A form to approve more hazardous materials might include more fields, while safer chemicals may be adequately covered by a much shorter form.
Your chemical approval form can include any type of data or question that you feel is important to answer when introducing a new chemical to your facility. Safety, environmental and company-specific data points can be included and your form can be as brief or exhaustive as you see fit. Common questions include:
- material name
- requestor name
- date requested
- intended use and location
- special handling or use instructions
- exposure limits
- PPE requirements
- disposal considerations
The form should also reflect compliance data such as ingredients, GHS hazard statements, and regulatory cross-references to state or federal regulatory lists or to any internally banned substance lists.
What to Look for in a Chemical Approval Process
As you strategize your chemical approval process, look for ways to get the most return for the time spent by your submitters and reviewers. When workers submit a chemical for approval, is there an easy or automatic way for them to know immediately whether that chemical already exists in your system, either at their facility or at a corporate level? As reviewers consider the new chemical request, does your process enable them to quickly correct errors or add any missing information? Are there criteria such as chemical type or quantity thresholds that can trigger an automatic approval or rejection?
Once it is determined that the requested new chemical requires review by your approvers, consider the transparency of your workflow. The ability to track who is reviewing, seeing at a glance the real-time status of the request and receiving prompt notification of approval or rejection can significantly streamline report generation. A technology solution that can automatically flag any roadblock on the way to approval allows the process owner to proactively intervene to ensure each approval request is brought to a timely conclusion.
Perhaps most importantly, once a chemical is approved, an automated system associates the correct SDS to that chemical, making vital safety information immediately available and ensuring you have required documentation readily at hand during a regulatory inspection or whenever you perform a compliance spot-check on your physical inventory.
There are significant time-saving and cost-efficiency benefits to implementing an online chemical approval workflow. From responsive forms with pre-populated fields to dynamic customization where the process itself can evolve based on the chemical or prior approval steps, a technology solution beyond the static Excel spreadsheet can move an organization from mere record-keeping to true chemical intelligence.