Definition of a "Hazard or Toxic Chemical"
In order to comply with SQF section 11.6.4, I need to update our Chemical registry so that each hazardous or toxic chemical is identified. Before doing so, I'd like to confirm the definition of "Hazardous or Toxic" chemicals and where to find these classifications.
These designations must live on the SDS. I just need to know the exact section or subsection to look for, or if this is another vague, subjective classification that each practitioner must perform a risk-assessment on (e.g., Health Hazard score greater than 0).
Insights appreciated
From the code appendix 2, page 92:
Hazardous Chemicals and Toxic Substances: Solids, liquids or gasses that are radioactive, flammable, explosive, corrosive, oxidizing, asphyxiating, pathogenic, or allergenic, including but not restricted to detergents, sanitizers, pest control chemicals, lubricants, paints, processing aids, bio-chemical additives, which if used or handled incorrectly or in increased dosage may cause harm to the handler and/or consumer. Hazardous or toxic chemicals may be prescribed by regulation as “dangerous goods” and may carry a “poison,” “Hazmat” or “Hazchem” label depending on the jurisdiction.
Ok, so if it has ANY score greater than 0 on the hazardous info plackard it is considered hazardous? Is that the best way for me to identify which chemicals are hazardous?
I'm looking for a simple, straight forward way to identify hazardous, toxic or non-hazardous. There has to be a simple, YES/NO answer for this, right?
For example, we have food-grade oil-based flavorings. They are used to flavor our product, however they have a 3-Flammable classification. Does this make it hazardous?
In my facility (we manufacture flavors such as the one mentioned), we have numerous chemical ingredients that are "hazardous," so we cannot go off of the placard information. Hazardous doesn't mean the same as Hazardous Material (HazMat). We have tried to make it simple by saying if it is not an approved raw material/ingredient we call it hazardous. That means that we include such other things as the equipment cleaner and sanitizer, laboratory chemicals, office and break room products (e.g. coffee pot cleaner) as hazardous - they do not belong in the food we make. (We decided to lock it all up.) If it is an ingredient that has the potential to be hazardous, we accept the risk and then manage with appropriate actions, such as controlling who has access to them, more frequent inventory monitoring to account for quantities taken, etc. We're still developing our program, but so far this has worked for us in differentiating what is hazardous and what is not.
For example, we have food-grade oil-based flavorings. They are used to flavor our product, however they have a 3-Flammable classification. Does this make it hazardous?
A flammable product is indeed hazardous.
You need to store them securely and you need to be able to show auditors that you have the risk managed by not having too much stock of the material and have fire fighting equipment nearby (and competent staff to use them). Don't forget that the staff also needs to be briefed on how to use the material and the material also needs to be marked correctly (even if weighed into smaller quantities).
Ok, so if it has ANY score greater than 0 on the hazardous info plackard it is considered hazardous? Is that the best way for me to identify which chemicals are hazardous?
I'm looking for a simple, straight forward way to identify hazardous, toxic or non-hazardous. There has to be a simple, YES/NO answer for this, right?
It isn't going to be a YES/NO answer for many items. You'll need to do Risk Analysis to determine any other factors that take into a risk category that requires special attention.
I would include ingredients if they're listed as hazardous.
All things are poison, and nothing is without poison; the dosage alone makes it so a thing is not a poison. —Paracelsus, 1538
The only thing which doesn't make them hazardous in your finished product is the quantity. Therefore as an error or malicious act could introduce excessive quantity, it's valid to list all hazardous chemicals.