Bringing a new chemical on site: approval first, then a seven-step procedure for use

Many sites manage chemicals only once they are already in the store. Good practice is to treat every new chemical, or every new use of an existing one, as a change that needs approval. Then the first person to use it follows a set procedure.

Stage 1: before purchase (approval)

• Is it needed? Can an existing approved product do the job? Is there a less hazardous alternative?
• Get the SDS before ordering. Check it is current, in the 16-section GHS format and in English.
• Screen the hazards. Look for carcinogens, mutagens, reproductive toxicants, respiratory sensitisers, Schedule 8 chemicals under the National Environment Act Cap. 181, and CWC-scheduled chemicals. These need extra justification, or should be refused.
• Check legal status. Is it covered by your NEMA registration and licence under the Hazardous Chemicals Regulations, 2024?
• Assess the risk of the intended task: exposure route, quantity, frequency and existing controls.
• Plan storage and disposal. Where will it be stored, what is it incompatible with, and who will take the waste?
• Authorise. The site health, safety and environment (HSE) lead and the user department sign off, and the chemical is added to the register.

Stage 2: first use (seven steps for the worker)

1. Identify the product by checking its GHS label.
2. Read the SDS and any Safe Work Procedure to learn the hazards and the PPE required.
3. Prepare for emergencies: know where the eyewash station, safety shower and spill kit are.
4. Put on the PPE required by SDS Section 8 or the procedure. Wash off any skin contact immediately.
5. Use the chemical as intended. Stop and reassess steps 1–4 if anything changes.
6. Close the container, store it properly and wash your hands and any exposed skin.
7. Dispose of empty containers and unused product as the waste management plan and the Waste Management Regulations, 2020 require.

Why both stages matter. Stage 1 keeps unnecessary or high-hazard chemicals off site and makes sure the paperwork exists. Stage 2 makes sure the person using the chemical knows what they are handling. Incidents often trace back to a skipped stage: a chemical bought by a contractor without approval, or used by someone who never saw the SDS.

What to do

• Put a "no SDS, no purchase order" rule into procurement.
• Require contractors to submit chemicals for approval before mobilising them to site.
• Print the seven steps on a card at every store and decanting point.

How INRC can help

INRC helps sites write chemical approval procedures into their occupational health and safety arrangements and management systems management systems, and trains the people who must apply them. Contact us to discuss your site.

This article is general guidance, not legal advice. Check current legislation and regulations for your specific project.