Restricted and Approved Chemical List Greg Moss, NiSource

The Challenge  Goal = A process to ensure workforce is using hazardous chemicals in a safe

manner  Example: Isocyanates in spray-on insulation  Example: Nickel in anti-sieze compounds  Example: Epoxy resins in floor coatings  Need a stream-lined process  Consistent, quick, and simple  Need a proactive approach

 Shouldn’t ban chemicals one-by-one due in response to incidents  Need flexibility during emergencies  Storm response

Important Questions  Review all chemical purchases?  Only new chemicals?  New chemicals and new intended uses?

 Publish an “approved” chemical list?

 Publish a “restricted” chemical list?  Who is going to review the purchases / uses?  Are they qualified?

 How is the new program going to be trained and communicated?  How do you verify the process is being followed?

Potential Solutions  Internal purchasing system  “Flag” to indicate chemical purchase  Review workflow required prior to proceeding  P-card program  Incorporate chemical review / approval process into P-card

training  Training and manual instruction  Supply chain audits of credit card purchases  3rd party chemical inventory management provider  Restricted chemical list; requires EHS review

My Ideal Solution  Develop restricted chemical list  Utilize 3rd party chemical inventory management provider for review /

approval workflow 

All chemical purchases require SDS upload 

System verifies whether product currently exists at property



System looks for “restricted” component in product



Purchaser is required to provide intended use info 

Customizable questions



Customizable thresholds for auto-rejection



EHS is notified for review and approval



Purchaser receives approval or denial



SDS is retained in system at applicable property

My Ideal Solution (Continued)  Emergency & storm response 

Initial review and approval not required, but must still be submitted within 10 days for continued use assessment

 Communication & training 

“Train the trainer” for front line Supervisors 



Classroom, webinar, or both

Proceduralize expectations in HazCom program or elsewhere

 Verification & enforcement 

Look for “restricted chemicals” being used in the field and verify that approval is retained in the system for that product and application

Implementation Challenges  Involve operations during development and implementation;

don’t “surprise” them  Perform pilot on small population to work out kinks and get

comfortable  Review current uses of “restricted chemicals” and clean up

current inventory to start off on the right foot  Provide time for workforce to prepare; communicate

implementation date

Chemical Approval Process Challenges and potential solutions for developing and implementing chemical review and approval processes

The Challenge  Goal = A process to ensure workforce is using hazardous chemicals in a safe

manner  Example: Isocyanates in spray-on insulation  Example: Nickel in anti-sieze compounds  Example: Epoxy resins in floor coatings  Need a stream-lined process  Consistent, quick, and simple  Need a proactive approach

 Shouldn’t ban chemicals one-by-one due in response to incidents  Need flexibility during emergencies  Storm response

Important Questions  Review all chemical purchases?  Only new chemicals?  New chemicals and new intended uses?

 Publish an “approved” chemical list?

 Publish a “restricted” chemical list?  Who is going to review the purchases / uses?  Are they qualified?

 How is the new program going to be trained and communicated?  How do you verify the process is being followed?

Potential Solutions  Internal purchasing system  “Flag” to indicate chemical purchase  Review workflow required prior to proceeding  P-card program  Incorporate chemical review / approval process into P-card

training  Training and manual instruction  Supply chain audits of credit card purchases  3rd party chemical inventory management provider  Restricted chemical list; requires EHS review

My Ideal Solution  Develop restricted chemical list  Utilize 3rd party chemical inventory management provider for review /

approval workflow 

All chemical purchases require SDS upload 

System verifies whether product currently exists at property



System looks for “restricted” component in product



Purchaser is required to provide intended use info 

Customizable questions



Customizable thresholds for auto-rejection



EHS is notified for review and approval



Purchaser receives approval or denial



SDS is retained in system at applicable property

My Ideal Solution (Continued)  Emergency & storm response 

Initial review and approval not required, but must still be submitted within 10 days for continued use assessment

 Communication & training 

“Train the trainer” for front line Supervisors 



Classroom, webinar, or both

Proceduralize expectations in HazCom program or elsewhere

 Verification & enforcement 

Look for “restricted chemicals” being used in the field and verify that approval is retained in the system for that product and application

Implementation Challenges  Involve operations during development and implementation;

don’t “surprise” them  Perform pilot on small population to work out kinks and get

comfortable  Review current uses of “restricted chemicals” and clean up

current inventory to start off on the right foot  Provide time for workforce to prepare; communicate

implementation date