Manufacturing & Engineering

Chemical manufacturer: compliance checklist

A verification checklist for makers of chemicals and chemical products (SIC division 20). Use it to confirm that UK REACH registration, GB CLP classification and labelling, product authorisation, COMAH duties, environmental permits, DSEAR controls, explosives licensing and core workplace health-and-safety duties are all in place before a production run.

UK-wide
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UK-wide

Use this checklist to confirm that your chemical manufacturing business meets its obligations before a production run. Work through each item and answer yes or no. If you answer no to any item, follow the linked guide for that regime before you proceed. The product and market rules apply when you place substances or products on the GB market; in Northern Ireland the EU rules apply under the Windsor Framework, so check the NI position separately.

Substances and products on the market

Confirm the registration, classification and authorisation rules for what you make are met.

  1. 1

    UK REACH registration

    Have you registered each substance you manufacture at one tonne a year or more with the UK REACH service, and prepared the safety data sheets you must supply down the chain? UK REACH applies in Great Britain; in Northern Ireland, EU REACH applies under the Windsor Framework, so check the NI position separately.

  2. 2

    GB CLP classification, labelling and packaging

    Have you classified each substance and mixture for its hazards, applied the correct CLP label (pictograms, signal word, and hazard and precautionary statements), and confirmed the packaging is safe and compliant?

  3. 3

    Product authorisation, if applicable

    If you make biocides, plant protection products or cosmetics, have you obtained the required authorisation or notification before placing the product on the GB market?

Major-hazard, environmental and explosives controls

If your site holds dangerous substances, runs a permitted installation or handles explosives, confirm the site-based controls are in place.

  1. 1

    COMAH duties, if applicable

    If your site holds qualifying quantities of dangerous substances, do you hold a major-accident prevention policy, have you notified the Competent Authority, and, for an upper-tier site, produced the safety report and on-site emergency plan?

  2. 2

    Environmental permit

    If you run a chemical installation on an industrial scale, do you hold a current environmental permit from the Environment Agency, Natural Resources Wales, SEPA or NIEA for your nation?

  3. 3

    DSEAR assessment and zoning

    Have you assessed fire and explosion risks under DSEAR, classified hazardous areas into zones, and selected and maintained equipment that is safe to use in them?

  4. 4

    Explosives licence, if applicable

    If you make or store explosives, do you hold the required licence under the Explosives Regulations 2014, and are the precursor supply controls in place where they apply?

Workplace health and safety

Whatever you make, confirm the core workplace duties are met. Chemical manufacture is high-hazard, so these duties carry real weight.

  1. 1

    COSHH assessment and control

    Have you assessed exposure to the hazardous substances you handle, put controls in place to prevent or reduce that exposure, and arranged the monitoring and health surveillance required?

  2. 2

    General health and safety duties

    Are you meeting your general duty to protect the health, safety and welfare of your employees and others affected by the work, with the assessments, equipment controls and arrangements that involves?

  3. 3

    Supporting workplace duties

    Have you also covered the related workplace duties — safe work equipment under PUWER, manual handling, fire safety, employers' liability insurance, equality duties and ICO data protection registration — that apply to every business?

If you answered no to any item

Do not proceed with a production run until you have closed the gap. For registration, classification and product authorisation, see the guide on placing chemical substances and products on the GB market. For COMAH, environmental permits, DSEAR and explosives, see the guide on operating a safe chemical manufacturing site. If you are not sure which regimes apply, see the guide on which chemical regulations apply to your products and site, or confirm it with the relevant regulator before you commit.

Which chemical regulations apply to your products and site

A reference guide for chemical manufacturers (SIC division 20) that routes you to the regimes that apply to your products and your site. It points you to UK REACH and GB CLP for substances and mixtures, product authorisation for biocides, plant protection products and cosmetics, COMAH and environmental permitting for major-hazard sites, and the explosives licensing regime.

Set up and run a safe metal production plant

Producing basic metals — smelting, casting, rolling, refining and founding iron, steel, aluminium and other non-ferrous metals — is among the highest- hazard things a manufacturer does. Whatever you produce, this is the universal spine. It takes you through your core workplace health and safety duties, control of metal fume and silica, explosive-atmosphere and work-equipment safety, fire, insurance, equality and data protection, the environmental permits your installation needs, the COMAH major-accident controls at threshold, and — for the few nuclear-fuel sites — the ONR nuclear site licence.

Set up and run a safe oil refinery or coke works

Refining crude oil and making coke is among the highest-hazard manufacturing there is — large quantities of flammable and toxic substances, high temperatures and pressures, and major-accident potential. This is the universal spine. It takes you through your core workplace health and safety duties, explosive-atmosphere controls, work equipment, manual handling, fire safety, the COMAH major-accident regime and your environmental permit, the UK Emissions Trading Scheme, insurance, equality and data protection.

Place chemical substances and products on the GB market

A task guide for chemical manufacturers (SIC division 20) placing substances and products on the GB market. It covers UK REACH registration, GB CLP classification, labelling and packaging, and product authorisation for biocides, plant protection products and cosmetics, with the placing-on-market sequence in order.