Chemical Approval Request

This request is the entry point for a substance not yet on the chemical register. Using it to document a substance already in routine use, or to revisit one already approved, duplicates other templates without adding a decision.

ISO 45001 treats a new hazardous substance as a managed change and a hazard to identify before exposure, not an inventory event to record afterwards. Defensibility rests on whether every triggered review was actually independent, not how many fields were completed.

Few regimes require formal pre-approval of a new chemical by name. What most require is that the substance be assessed and its hazard communicated before exposure occurs, which is the practical effect this request delivers.

The reviews the form prompts for are straightforward to complete individually. What it cannot enforce is whether they were treated as independent judgements or a chain of formalities behind an approval already decided.

Because this request sits at the front door, its findings usually surface later, once a substance in use turns out to have been approved on an incomplete picture.

A bakery site's usual descaler was discontinued by its supplier. The line manager raised a request for a like-for-like replacement, attached the new safety data sheet, and it moved through safety, health and environmental review without incident. Food safety passed because the product touched equipment, not product-contact surfaces. Safer alternative was marked no, take forward was recorded within the week, and the product went into use.

A later inventory review, prompted by an unrelated audit, found the replacement was corrosive and a respiratory sensitiser, materially more hazardous than what it replaced, and that other suppliers offered a non-corrosive alternative. Nobody in the four independent reviews had been asked to establish that, because none of the reviews existed to answer it; each checked whether the product in front of them was acceptable on its own ground, not whether it was the right product to be looking at. The safer alternative field had recorded a no with nothing behind it, and every review afterward had answered the wrong question well.

The request itself is a short form. What actually fails is the review marked not applicable on the wrong assumption, and the register entry that never catches up with a decision already made.

KnowSafe

Holds the approval request against the substance register, flags a take-forward decision with no register entry, and tracks whether every triggered review reached pass.

KnowEnviro

Picks up the environmental review and carries the substitution question into a deeper comparative assessment when the substance is a genuine replacement candidate.

KnowQuality

Checks food safety and food contact answers against the product's actual site of use, and reopens the review where use later changes.

Ella

Watches for an unreasoned no on the safer alternative field, and holds the decision for review before it reaches take forward without every review at pass.

Approval gate

A control point a chemical must clear before arriving on site, distinct from the ongoing records that apply once it is approved and in use.

Like-for-like

A replacement changing nothing about exposure route, storage, quantity or process, distinct from one constituting a change requiring its own MOC record.

Independent review

A review conducted by a function on its own criteria, whose fail or partial outcome is not overridden by a pass from a different function.

Incidental contact

Exposure of a food-contact surface to a chemical not intended to touch food, such as a lubricant, which still requires food-grade or approved status.

Management of change

The record required when an introduction alters process, method, layout or quantity enough to no longer count as like-for-like.