Change Notice No. 1
CRITERIA AND LINES OF INQUIRY
Procedures and/or mechanisms for activities involving chemicals require adequate planning of individual
work items to ensure that hazards are identified and analyzed, and that appropriate controls are
identified and selected for subsequent implementation.
Lines of Inquiry
What is the process used to identify potentially hazardous chemicals that are used or stored in the
facility? What hazard analyses are conducted for such chemicals and for chemical processes in the
facility? What is the "driver" for these hazard analyses?
What are the qualifications of personnel performing chemical hazard analysis? Are "hands-on"
employees involved in all chemical hazard analyses conducted by SMEs? Do environment, safety
and health (ES&H) professionals conduct walk-downs of facilities in which chemicals are to be used
or stored, prior to completing the hazard analysis?
Do the work packages reflect a well-developed planning process that incorporates potential chemical
Has the facility adequately implemented a job hazard analysis procedure for work planning? Is
chemical safety integrated into this process? Is identification (and reduction) of waste generation
integrated into this process?
Are there procedures or instructions in place to specify when review and approval are needed on
project documentation to ensure that any chemical hazards management concerns are addressed?
Does a facility-specific procedure exist to implement a comprehensive chemical hazard management
program? Does it reflect site-wide requirements and all applicable standards?
Are waste types, quantities, and their associated hazards identified in the job hazard analysis and
work planning process?