Food processing operations use a wide variety of chemicals which can have negative impacts on human health and the environment if handled incorrectly. Chemical safety is a regulatory requirement to comply with legal requirements for industrial handling of chemicals. Managers must work in collaboration with Joint Health and Safety and Occupational Health and Safety within the company to provide risk management and operating procedures. Managers provide accountability and compliance with regulations such as Workplace Hazardous Materials Information System (WHMIS), Transportation of Dangerous Goods, and environmental management.
LO1. Integrate regulatory requirements for chemical safety according to applicable regulations.
In different areas, chemical safety regulations have different requirements, including procurement, transportation, storage, handling, segregation, labelling, and fire suppression requirements and disposal of the chemical. In some cases, such as with alcohol and cannabis manufacturing, tax and excise related segregation of chemicals may also be required. Managers must identify and interpret necessary compliance systems.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Identify the appropriate laws and regulations for the organization and the risks involved based on the chemicals used at the facility.
- P2. Identify the regulatory agencies with inspection and compliance requirements for chemical safety such as: fire code, building code, food safety, tax and excise, transportation requirements, environmental requirements, etc.
- P3. Review regulatory requirements for the development of operating procedures, documentation, and record keeping.
- P4. Review regulatory requirements for safe storage, worker access, movement, and usage of chemicals within the workplace.
- P5. Create communications pathways within the organization for chemical safety concerns.
LO2. Collaborate with Occupational Health and Safety Committees for chemical safety monitoring, training, and compliance
Chemical safety is a major component of overarching Occupational Health and Safety programming, with unique programming requirements. Chemical safety programming must define its unique role in health and safety. Managers must both collaborate and create systems specific for chemical safety that would be overseen by the Joint Health and Safety Committee.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Define the terms of reference with the Joint Health and Safety Committee for chemical safety management.
- P2. Identify chemical risks within the facility with members of the Joint Health and Safety Committee.
- P3. Perform chemical safety inspections with members of the Joint Health and Safety Committee.
- P4. Develop an inventory of chemicals within the workplace.
- P5. Train and verify employee compliance with risk reduction protocols (use of personal protective equipment, respecting recommended concentrations, chemical products segregation, etc.)
- P6. Perform preventive maintenance of equipment to prevent chemical risks (ventilation system, ammonia sensor alarms, spill kits, chemical cabinets, etc.)
- P7. Maintain a communication channel with chemical product suppliers to use up to date safety procedures (updated Safety Data Sheets [SDS], changes to the composition of products, etc.)
- P8. Plan for calibration services for environmental chemical detectors within appropriate timelines.
- P9. Review and update standard operating procedures for chemical safety protocols.
- P10. Develop chemical spill or emergency exposure protocols for the workplace.
- P11. Develop emergency response and environmental abatement assistance plans for potential chemical spills. Develop emergency contact lists for chemical accidents.
- P12. Provide training for employees for management of various chemical accidents that could occur based on the chemicals present in the workplace.
- P13. Implement practice drills in case of chemical accidents (ammonia leak, chemical spill, etc.)
LO3. Develop a WHMIS-GHS system for the facility
Management must provide accountability for compliance and operating procedures for Workplace Hazardous Materials Information System (WHMIS) and Global Harmonized System (GHS) within the workplace. Managers must provide inventories, labelling systems, chemical safety inspections, and workplace training for workers.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Develop a catalogue of Safety Data Sheets (SDS) from chemical and ingredient suppliers.
- P2. Review SDS documentation on a routine basis to ensure compliance and currency with regulations.
- P3. Develop signage and labelling systems for chemicals within the workplace, including manufacturing labels and work-in-progress (WIP) chemical labels.
- P4. Provide routine training for employees and supervisors for chemical handling and safety according to WHMIS-GHS requirements.
- P5. Provide appropriate personal protective equipment and barrier protection to workers to reduce chemical exposure risks.
- P6. Perform risk reduction practices and analysis to identify lower risk alternatives for chemicals in the workplace.
- P7. Review standard operating procedures on a routine basis with the Health and Safety Committee to ensure compliance, current status with operations, and effectiveness within the facility.
LO4. Develop protocols to safely manage the Transportation of Dangerous Goods
Chemicals of many sorts are transported as part of food manufacturing operations. From cryogenic gases for cooling, to sanitation chemicals, refrigerants, flammable propellants, compressed gasses, alcohol, nitrates, many chemicals commonly used have enhanced risk protocols, signage and documentation requirements for transport and handling. Managers must ensure compliance with Transportation of Dangerous Goods (TDG) when contracting with transporters, and when handling materials within operations.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Identify chemicals requiring TDG classification within manufacturing operations.
- P2. Integrate signage requirements on TDG mandated materials, including United Nations Dangerous Goods Number (UN number) and placard requirements for goods.
- P3. Determine risk category and packing class of chemicals.
- P4. Determine quantities of restricted materials to be transported.
- P5. Identify TDG requirements in transportation contracts.
- P6. Evaluate if the control measures used by suppliers of chemicals requiring TDG classification meet your requirements.
- P7. Monitor training requirements of staff involved with TDG.
- P8. Track TDG with the required documentation.
- P9. Maintain TDG record keeping and reporting requirements.
LO5. Develop controlled materials handling protocols for the facility.
Safe handling and containment methods are required for chemicals in food manufacturing. Emergency prevention and preparedness are managed with the development of robust protocols. Depending on the type and quantity of chemicals within the workplace, formal Emergency Response Assistance Plans or CANUTEC registration may be required for regulatory compliance.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Monitor the integrity of safety containment devices.
- P2. Establish procedures to avoid contamination with cleaning and sanitizing products (Cleaning In Place (CIP) cycle, concentration monitoring, etc.)
- P3. Monitor employee use of personal protective equipment and other guarding devices.
- P4. Provide spill abatement and containment materials relevant to the chemical risks.
- P5. Develop Emergency Response Assistance Plans (ERAP) for anticipated chemical risks.
- P6. Evaluate the need for CANUTEC registration depending on quantity and risk level of chemicals present in the workplace, and chemical transport and handling practices.
- P7. Collaborate with formal inspection services for regulatory compliance inspections.
- P8. Report health and safety deficiencies that have mandatory reporting to regulatory authorities (Ministry of Labor, Ministry of Transportation, or other inspection services, etc.) and follow up on corrective and preventive actions requirements to prevent reoccurrence.
LO6. Develop environmental control mechanisms for chemical wastes.
Chemicals within food processing can have environmental impact in waste streams. Control of chemicals entering sewage and solid waste streams can be a municipal, provincial and/or federal regulatory requirement. Managers must ensure compliance with environmental regulations.
Detailed Competencies = Performance indicators include but are not limited to:
- P1. Register with the Hazardous Waste Information Network (HWIN) or other waste management inventories per regulatory requirements.
- P2. Identify chemical risks that may impact the environment and sewage infrastructure (including chemical by-products resulting from processing operations).
- P3. Determine if wastewater streams require rectification such as pH adjustment prior to release to sewage.
- P4. Monitor processing waste streams for water and solid waste contamination.
- P5. Monitor Total Soluble Solids and Biological Oxygen Demand in wastewater streams.
- P6. Evaluate the need for further degradation option prior to wastewater release to sewage.
- P7. Calculate wastewater treatment surcharges with municipal services.
- P8. Monitor solid waste streams for chemical or biohazard risk.
- P9. Calculate solid waste surcharges for hazardous waste.
- P10. Identify and implement safe disposal protocols for solid waste with potential chemical contamination risks.
- P11. Identify and implement safe disposal protocols for surplus chemicals from food processing.
- P12. Evaluate opportunities to reduce or eliminate hazardous waste streams within the manufacturing system.
- P13. Communicate with Ministry of Environment or other allied organizations regarding compliance, monitoring, and reporting requirements.
