Change Notice No. 1
Are hazards of legacy chemicals (e.g., abandoned, residual chemicals in tanks and pipes with
inadequate controls) properly identified and addressed? Have their potentially degraded storage
conditions been considered? Have these chemicals been sampled and characterized? Are there
adequate controls to prevent and mitigate adverse consequences? Are the containers of these
chemicals periodically inspected and maintained? Are the hazards of these chemicals appropriately
and sufficiently addressed in the facility's safety basis?
What is the regulatory status of the legacy chemicals in the facility? Has the regulatory status of the
legacy chemicals as hazardous waste been appropriately determined?
Has pollution prevention (substitution with a non-hazardous material or reduction in quantity used)
been considered, when applicable, as a way to prevent or mitigate chemical hazards?
Are adequate and appropriate controls for chemical hazards identified through the hazard analysis?
Are adequate controls identified for all chemical hazards? Are engineered controls preferred over
administrative controls? Are administrative controls preferred over personal protective equipment?
Are passive controls preferred over active controls?
Are hazard assessments essential to emergency response established and maintained?
Procedures and/or mechanisms for the acquisition, storage, use, and disposal of chemicals contain clear
roles and responsibilities. Chemical management is effectively integrated with line support managers to
ensure that line managers are responsible for chemical management.
Lines of Inquiry
Are the responsibilities of line management for chemical safety and chemical management clearly
defined, documented, and understood?
Are the roles and responsibilities of support staff and other personnel associated with the facility's
chemical management program/system clearly defined, documented, and understood? Have the
primary and secondary points of contacts been identified?