Chemical Management Procedure

All,

I have been struggling with this procedure for quite some time and still am wondering if we have it right.  In our locked chemical cabinet we have smaller containers of chemicals used routinely by our process techs -- mainly to lub machinery.  At this time, we are not having individuals sign out what they're using--the rule is that when they've finished their task, they place the container back into the locked cabinet as it is impossible to know quantities used as it is a "squirt or spray" of this or that.

Is there some iron clad rule or are we good with stating the procedure and doing what we say?  In the IFS PACsecure Standard I'm unable to find a directive regarding a log, simply that it must be stated who uses chemicals and show that they are trained.

I just want to make sure that I'm not missing anything as our audit is coming up shortly. 

Any feedback would be great. 

Thank you!

We are a paperboard converter making food packaging. Not sure about IFS Pacsecure as we are SQF but I believe the GFSI standard is universal. We have simplified this by storing all of the lubes for our machinery in the maintenance dept (area is controlled access) and the PM SOPs outline how they are used and stored. (The only lubricants we use are synthetic, food grade anyway.) The only chemicals that are stored at machines are used in normal operation processes, are included in the SOPs for those machines and have separate storage for food grade and non food grade chemicals. Hope this helps.

If you identified chemical inventory (other than just a register of all chemicals on site) as a needed control for food defense or whatever, you could also do it more simply by taking a once weekly inventory under normal conditions of use, then argue that if someone were to be theiving/using chemicals at unsafe levels you would presumably see it when you suddenly had a much higher usage than normal that week.