Chemical Approval Questions
When approving a chemical in a FDA regulated facility the maintenance manager, sanitation manager, EHS manager, & Q.A. manager are the typical approvers (Did I capture them all). My question is what do each of these roles look for when approving? I'm looking to put a list of questions together to put on the chemical approval form to ensure they are approving with knowledge, not just pencil whipping ang not realizing the consequences. Also, what all jurisdictions would I consider? Example, local sewage plant, EPA, FDA, etc.? Thank you for your help. Truly appreciated.
When approving a chemical in a FDA regulated facility the maintenance manager, sanitation manager, EHS manager, & Q.A. manager are the typical approvers (Did I capture them all). My question is what do each of these roles look for when approving? I'm looking to put a list of questions together to put on the chemical approval form to ensure they are approving with knowledge, not just pencil whipping ang not realizing the consequences. Also, what all jurisdictions would I consider? Example, local sewage plant, EPA, FDA, etc.? Thank you for your help. Truly appreciated.
Hi AK,
Not meaningfully answerable without knowing what the chemical actually is and what you are doing with it.
Can you give some context ?
Here is my list of things to consider in your approval process:
compatible for intended use & effectiveness.
sds / label on file
appropriate ppe available
health hazards considered / addressed - think diacetyl.
where will it be stored (segregation and security)
what changes are needed for procedures & training to ensure it is used according to label.
are sanitation chemicals epa / registered.
NOP complaint - if required
titration procedures for sanitation chems
do you have appropriate docs for food grade lubes (nsf, reg, allergens, etc
are additives GRAS or approved
food safety plan update needed?
do boiler chems meet appropriate standard (21 CFR 173.310,etc)
strongly scented (BRC)
regulatory or state band lists or special requirements - California.
spill clean up procedures
accidental release procedures
disposal procedures
Kingstudruler gave you a lot of things to consider, but I will add one more:
Ensure chemicals will not react with each other. Especially if they are used consecutively in your cleaning process.
An example would be using bleach after ammonia (chloramine gas), rubbing alcohol (chloroform), or vinegar (chlorine gas).
If you order most of your chemicals from the same supplier, such as Ecolab, they will be better able to assist you with the chemistry aspect.