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Management of Requirements
Chemical Management - index
Program Ownership and Consolidation

associated with them, yet most of the regulations are written to protect against a single chemical
hazard. For example, one regulation requires water-reactive chemicals to be stored where there
is no water-based fire suppression system while another regulation states that flammable liquids
must be stored where a water-based fire suppression system exists. What does one do with a
chemical that is both a flammable liquid and water reactive? Chemical hazards may also be
dependent upon chemical concentrations, chemical form, or the environment within which the
chemical is placed. For example, many metals are benign when in the form of an ingot, shot, or
turning, but become water-reactive, flammable, or pyrophoric when present in the form of a
powder. As a part of the hazard identification and analysis function under ISMS, one must
determine the point at which, as the particle size decreases, a metal ceases being benign and
becomes more hazardous, requiring additional controls.
4.2.2 Organization of Requirements
Because of the complexity of requirements and the multitude of regulatory sources, a
coordinated, site wide effort is needed to consolidate and interpret those requirements related to
chemical activities. This effort should focus on grouping requirements by work activity instead
of chemical hazard class, and should result in a process for providing and communicating the
definitive interpretation for chemical req uirements onsite. Although regulations typically
address requirements by chemical type or hazard class, activities such as transport ing, storing, or
working with chemicals almost always involve chemicals that have multiple hazards or are from
multiple hazard classifications. If requirements are organized by hazard class to mirror
regulatory literature, it makes performing chemical work confusing and can lead to increased risk
and regulatory noncompliance. If, instead, regulations are grouped by work activity (e.g.,
storage, in- house transportation, laboratory experimentation), they are more easily
understandable. An additional benefit is that they will reside in one location, eliminating the
need to search for additional regulations.
Interpreting Chemical Requirements
Chemical requirements must be organized in order to make clear a company's determination
regarding the interpretation of individual and overlapping requirement s. If an inconsistency
appears to be present between two sets of requirements in the regulatory literature, management
needs to determine how these conflicting requirements will be interpreted from a corporate
perspective. Once these determinations are made, they must be published so that a record of the
decision exists. If the company does not interpret and publish them for the workforce,
individuals with varying levels of expertise throughout the co mpany will arrive at their own
interpretations through "answer shopping" leading to inconsistent applicat ion of requirements
and a less effective CSLM program.
Requirements Ownership
In accordance with the second ISMS guiding principle, which describes the need for clear roles
and responsibilities, management must identify the owners of CSLM requirements. Without
clear ownership, consistency will be lost as individuals make changes to the company
interpretations of requirements based upon immediate needs.

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