Chemical Control Program
1.0 Policy:
Company will proactively manage a Chemical Control Program to control procurement,
storage, use and disposal of all non-food chemicals within the facility and on the premise.
The program will ensure the containment of chemicals and safety of food and personnel
working in the facility.
2.0 Scope:
This program provides guidance for the identification and control of all non-food chemicals in
the facility to include chemicals used in pest management, equipment maintenance,
cleaning, sanitation, and personnel hygiene. The policy applies to all manufacturing facilities
and attached structures in use by Schwebel employees.
3. Responsibility: The Corporate Quality Assurance Director and/or Manager are responsible
for program development. Management Teams from each facility are responsible for the
management and implementation of the program.
4.0 Procedures:
A. Program Overview: The Site Management Team shall be responsible for chemical control
in the facility. The Management Team shall monitor/manage a list of all non-food
chemicals as part of the sites Chemical Control Program. The Management Team shall
assess the safety and containment risks associated with the purchase, storage, use, and
disposal of all chemicals within the program. The facility’s chemical list shall be reviewed
at least annually or as required due to significant changes within the facility operations.
B. Chemical Approval and Purchase:
1. All non-food chemicals are to be approved by the Management Team.
2. Purchase authority for chemicals approved by the Management Team shall be
restricted.
3. As much as possible, food grade chemicals will be preferentially sourced.
(Manufacturing facilities only)
4. Non-food chemical approval shall be based on obtaining the proper paperwork
(SDS, Product Specification Sheet), the need for the chemical,
assessment of alternative chemicals, and review of a plan of how the chemical
shall be stored, handled, used and disposed. Key to approval shall be
consideration of the location of the chemical use within the facility.
5. When possible the avoidance of strongly scented products.
C. Chemical Handling and Storage:
1. Once approved, the department associated with the use, handling and storage
of the chemical shall keep a Chemical List and where and how they shall be
stored.
i. Chemical handling and storage requirements shall be based on the SDS
guidelines. Handling & Storage must also meet BRC requirements.
ii. All chemicals within the facility must be stored and handled in a manner that
protects the employee and all products.
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iii. Handling and storage requirements should minimally consider ventilation,
lock and key access, flammability, temperature, and personnel protection
equipment (PPE).
2. No chemicals, lubricants or any other non-food chemical can be stored with
packaging materials, incoming product or finished product.
3. Cleansers, sanitizers and paints must be stored in well ventilated designated
areas and used in compliance with the written sanitation procedures and can
label.
4. Individuals working with non-food chemicals require training on SOP’s to include
chemical handling and storage. Chemicals shall be used by trained personal
only.
D. Labels/Labeling:
1. All non-food chemicals within the facility must be clearly labeled in both the
primary, as well as, any secondary containers.
i. Secondary containers must be adequate to store the chemical as
defined by the chemical SDS.
ii. Secondary containers must be clearly labeled with the name of the
chemical and hazard ratings.
2. Differentiation must be established between food grade and non-food grade
lubricants.
i. Non-food grade lubricants must be kept in a separate cabinet when not
in use.
E. Actual Usage and Safety:
1. Written Chemical Control Procedures (site specific SOP’s) shall govern the
use of non-food chemicals for the specific task to which the chemical is intended.
i. The written procedures shall clearly communicate all safety
considerations as described in the SDS.
2. Site specific SOP’s will be reviewed and approved by management within the
department where the chemical will be intended for use.
i. Site specific SOP’s are controlled documents that must be reviewed
and updated as changes in process and procedure occur.
3. If the chemical must be diluted from the primary package to create a use
dilution, specific methods must exist to allow for verification of correct
concentration of the use dilution.
4. Individuals working with chemicals require training on SOP’s to include
chemical safety, handling and usage.
F. Disposal and Inventory Control:
1. All non-food chemicals will be disposed of as prescribed through the SDS
and in compliance with all safety and environmental requirements as mandated
by local, state and federal agencies.
G. Spill Containment and Control:
1. Any spills of non-food chemicals in the plants Chemical Control List must be
handled immediately. Reference the chemicals SDS and all local, state and
federal safety and environmental requirements for guidance in spill containment
and control.
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H. Document Control:
1. The site must manage and maintain a list of all non-food chemicals within the
facility.
2. Each chemical must have an updated SDS on-site accessible to employees.
SDS should be archived and maintained for 30 years.
3. Each chemical within the Chemical Control Program requires documentation
of containment, handling and storage conditions.
4. Each chemical requires documentation of usage through site specific SOP’s
and key safety information and PPE requirements to ensure employee safety.
5.0 Approved Exception and Addendums:
6.0 Program Verification:
A. Annual Internal Audits
B. Third Party Audits
C. Monthly GMP inspections
7.0 Management Review:
A. The program/policy and all controlled documents that are part of the Food Safety and
Quality Management system will be reviewed at least annually as part of the Internal
Audit Program.
8.0 Revision Control:
A. See Master Document Revision Log for Change Description.
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