Introduction

Chemical control in food manufacturing encompasses the comprehensive management of all non-food chemicals used within production facilities to prevent contamination of food products. This includes cleaning agents, sanitising compounds, maintenance lubricants, pest control substances, laboratory reagents and any other chemical materials that could potentially come into contact with food, food contact surfaces or the production environment. Effective chemical control involves establishing robust systems for the approval, procurement, storage, handling, use and disposal of these substances, alongside procedures to manage strongly scented or taint-forming materials that may be required for building work or maintenance activities.

The scope of chemical control extends beyond simple storage arrangements to encompass a holistic approach that considers the entire lifecycle of chemicals within the facility—from the initial approval process through to safe disposal or return of obsolete materials. It recognises that chemicals, whilst essential for maintaining hygiene and operational efficiency, represent a significant contamination risk if not managed with appropriate rigour.

Significance and Intent

The primary significance of chemical control lies in preventing chemical contamination of food products, which can arise through direct contact, cross-contamination, or through tainting where volatile compounds transfer odours or flavours to food even without physical contact. Chemical contamination incidents can have severe consequences, including product recalls, regulatory enforcement action, harm to consumers and substantial reputational damage to manufacturers.

Beyond food safety, effective chemical control serves several critical purposes. It protects employees from hazardous exposures, ensures compliance with health and safety legislation, and demonstrates due diligence in preventing contamination. The management of chemicals is recognised as a prerequisite programme within food safety management systems, forming part of the foundational controls that create an environment suitable for safe food production.

The ideal outcome of robust chemical control is a manufacturing environment where all chemicals are appropriately selected for their intended use in a food production setting, stored securely away from food and food contact materials, handled exclusively by trained personnel, and used in a manner that eliminates any risk of contamination. This includes having effective procedures to manage exceptional situations, such as building work requiring strongly scented materials, and maintaining complete traceability of all chemicals on site.

Chemical tainting presents a particularly insidious risk, as some tainting compounds can affect food products at extraordinarily low concentrations—in some cases below 100 parts per trillion. This means that even materials stored at a distance from production areas, or used for brief periods during maintenance work, can compromise product quality if adequate controls are not in place.

Overview of Compliance

Achieving compliance with chemical control requirements necessitates both documented management systems and practical operational controls that work in tandem to eliminate contamination risks. The documented framework establishes the “what” and “why” of chemical control, whilst operational practices ensure the “how” is executed consistently.

Food manufacturers should develop a comprehensive chemical control procedure that integrates with their broader food safety management system and HACCP plan. This procedure forms part of the prerequisite programmes that underpin the HACCP approach, addressing environmental and operational controls necessary for safe food production. The procedure should clearly define responsibilities, approval processes, storage requirements, training expectations and emergency response protocols.

Alignment between documented systems and operational practices is achieved through several mechanisms. Training programmes ensure that personnel understand both the requirements and the rationale behind them, fostering a culture where chemical safety is embedded in daily activities. Regular internal audits and inspections verify that documented procedures are being followed and identify opportunities for improvement. Management oversight, including review of chemical-related incidents and near-misses, ensures that the system remains effective and responsive to emerging risks.

The chemical control system should be dynamic rather than static, with documented procedures reviewed and updated when new chemicals are introduced, when processes change, or when incidents reveal gaps in existing controls. This ensures that the documented framework accurately reflects actual operations and continues to provide effective risk management.

Documented Systems

Approved Chemical List

A foundational documented system is the approved chemical list, which serves as the definitive record of all chemicals authorised for use within the facility. This list should encompass all categories of non-food chemicals, including cleaning and sanitising agents, maintenance lubricants, pest control products, laboratory chemicals and any other substances used on site.

For each approved chemical, the list should include sufficient detail to enable proper identification and management. This typically includes the chemical name, supplier details, intended use or application, location where it will be used and stored, and confirmation that supporting documentation (such as material safety data sheets and technical specifications) is available. The list should also indicate whether each chemical has been confirmed as suitable for use in a food processing environment.

The approved chemical list should be maintained as a controlled document, with a clear version control system and documented approval for any additions or amendments. It should be readily accessible to relevant personnel, particularly those involved in procurement and goods receipt, to prevent unauthorised chemicals from entering the facility.

Material Safety Data Sheets and Technical Specifications

For every chemical on the approved list, current material safety data sheets (MSDS) or safety data sheets (SDS) should be maintained and readily accessible. These documents provide critical information about hazards, safe handling procedures, first aid measures, and emergency response actions. They are essential not only for regulatory compliance but also for ensuring that personnel can respond appropriately in the event of spills, exposures or other incidents.

In addition to safety data sheets, technical specifications should be obtained from suppliers. These specifications provide information beyond health and safety considerations, including details about the chemical’s suitability for use in food processing environments, compliance with relevant standards, allergen status, and absence of strongly scented components. Technical specifications enable the assessment of whether a chemical is appropriate for its intended application and whether it poses any specific risks to food products.

Documentation should be organised in a manner that allows quick retrieval during emergencies. Many facilities maintain both physical copies in chemical storage areas and electronic versions accessible through their document management systems.

Suitability Assessment Documentation

Before any chemical is added to the approved list, a formal assessment of its suitability for use in a food processing environment should be completed and documented. This assessment should consider multiple factors: whether the chemical is appropriate for its intended application, whether it complies with relevant British and European standards for food contact or food processing use, whether it contains allergens that could pose cross-contamination risks, and whether it is strongly scented or could cause tainting.

For chemicals that will come into direct contact with food or food contact surfaces, confirmation should be documented that they meet food-grade requirements and comply with applicable legislation. For maintenance lubricants and other chemicals that may inadvertently contact food, documentation should confirm whether they are food-grade or what controls are necessary to prevent contact.

The suitability assessment should also consider the specific production environment where the chemical will be used. A cleaning agent suitable for enclosed product areas may not be appropriate for use in high-risk or high-care zones, whilst a lubricant acceptable for external equipment may be unsuitable for machinery that processes open products.

Chemical Storage Procedures

Documented procedures should specify requirements for chemical storage, addressing both physical arrangements and access control. The procedures should mandate that chemicals are stored in designated areas that are physically separate from areas where food, food contact materials, raw materials and packaging are stored. This segregation prevents accidental contamination and ensures that chemicals cannot be mistaken for food ingredients.

Storage procedures should specify requirements for different categories of chemicals. Food-grade chemicals used as processing aids or that may contact food should be stored separately from cleaning chemicals and other non-food-grade substances. Within chemical storage areas, incompatible chemicals should be segregated to prevent dangerous reactions.

The procedures should also address storage conditions, including requirements for temperature control, protection from direct sunlight, ventilation and secondary containment (such as bunding) to contain spills. Requirements for securing storage areas and restricting access to authorised personnel only should be clearly documented.

Labelling and Identification Procedures

All chemical containers should be labelled and identifiable at all times, and documented procedures should specify the requirements for labelling both primary containers received from suppliers and any secondary containers used for decanting or daily use. Supplier containers should retain their original labels, which provide essential hazard information and comply with regulatory labelling requirements.

When chemicals are transferred to secondary containers, procedures should mandate that these containers are immediately labelled with, at minimum, the chemical name and key hazard information. Unlabelled containers should never be tolerated, as they present serious risks of misidentification and misuse.

For facilities with multiple chemical storage locations or categories of use, additional identification systems may be appropriate, such as colour-coding or location-specific labelling, to further reduce the risk of chemicals being used incorrectly.

Training Documentation

Documented systems should specify training requirements for all personnel who handle or use chemicals. This should include initial training before individuals are authorised to work with chemicals, as well as periodic refresher training to maintain competence and address any changes to chemicals or procedures.

Training content should cover the hazards associated with chemicals used in the facility, safe handling and use procedures, personal protective equipment requirements, emergency response procedures including spill management, and the importance of maintaining segregation between chemicals and food products. Training should be tailored to the specific roles and responsibilities of personnel—production staff, maintenance technicians, cleaning operatives and laboratory personnel may require different levels of detail.

Records should be maintained documenting who has been trained, when training occurred, what topics were covered, and evidence of competency (such as assessment results). These records demonstrate that only trained personnel are handling chemicals and provide evidence of due diligence.

Spill Management Procedures

Documented procedures should establish clear protocols for responding to chemical spills, addressing both immediate response actions and longer-term corrective measures. The procedures should specify initial response steps: alerting nearby personnel, evacuating the area if necessary, containing the spill to prevent spreading, and calling emergency services if the spill is large or involves particularly hazardous materials.

Spill procedures should identify what equipment and materials are required for spill response (such as spill kits with appropriate absorbent materials), where this equipment is located, and who is trained to use it. The procedures should also reference safety data sheets as sources of chemical-specific spill response information.

Following spill containment and cleanup, procedures should address proper disposal of contaminated materials, assessment of any product or equipment that may have been contaminated by the spill, and investigation to determine root cause and prevent recurrence. Clear assignment of responsibilities for each step ensures that spills are managed promptly and effectively.

Disposal Procedures

Documented procedures should establish requirements for the safe, legal disposal or return of obsolete or out-of-date chemicals and empty chemical containers. These procedures should specify how to identify chemicals that are no longer needed or have exceeded their shelf life, how they should be segregated and stored pending disposal, and what disposal routes are appropriate for different categories of chemicals.

The procedures should address regulatory requirements governing chemical waste disposal, including classification of waste, use of authorised waste carriers, and any required documentation or consignment notes. For certain chemicals, return to the supplier may be more appropriate than disposal, and procedures should clarify when this option should be pursued.

Empty chemical containers also require proper management. Procedures should specify whether containers can be disposed of as general waste or require treatment as hazardous waste, and whether any rinsing or decontamination is necessary before disposal.

Procedures for Strongly Scented or Taint-Forming Materials

Specific documented procedures should address situations where strongly scented or taint-forming materials must be used, such as during building work, maintenance or equipment installation. These procedures recognise that whilst such materials should generally be avoided, there may be circumstances where their use is unavoidable.

The procedures should establish a risk assessment and approval process before strongly scented materials can be brought into the facility. This assessment should consider the proximity to production areas, the duration of use, air flow patterns that could carry odours or vapours to product areas, and what controls can be implemented to prevent tainting.

Control measures that should be documented include requirements to schedule such work during non-production periods, physical segregation using temporary barriers or enclosures, increased ventilation or extraction, and monitoring of product areas to detect any tainting before production resumes. The procedures should also specify what product testing or assessment is required before production can restart after strongly scented materials have been used.

Practical Application

Procurement and Approval Process

In practical terms, the chemical approval process should function as a gateway that prevents unsuitable chemicals from entering the facility. When a need for a new chemical is identified—whether for a new cleaning application, a different maintenance requirement or any other purpose—the requisition should be directed to designated approval authorities who have responsibility for different chemical categories.

For maintenance chemicals, the engineering or maintenance manager typically holds approval authority. For cleaning and sanitising chemicals, the sanitation or hygiene manager is usually responsible. For pest control products, responsibility often lies with the quality or technical manager, particularly if pest control is outsourced. For laboratory chemicals, the laboratory manager would typically approve.

These approval authorities should review the chemical against established criteria before authorising purchase. This includes verifying that material safety data sheets and technical specifications are available, confirming the chemical is suitable for use in a food processing environment, checking that it is not strongly scented, and ensuring it does not introduce new allergens to the facility. The approval authority should also consider whether an already-approved chemical could serve the same purpose, reducing the number of different substances on site.

Once approved, the chemical should be added to the approved chemical list before it is ordered, ensuring that goods receipt personnel can verify that arriving chemicals are authorised. This systematic approach prevents unauthorised chemicals from being purchased by well-meaning staff who may not fully appreciate food safety implications.

Goods Receipt and Verification

Personnel receiving chemical deliveries should have access to the approved chemical list and should verify that arriving chemicals appear on the list before accepting them. This check prevents unauthorised chemicals from entering the site and provides an opportunity to reject deliveries that do not match specifications or that arrive in damaged condition.

At goods receipt, verification should also include checking that containers are properly labelled, that material safety data sheets accompany the delivery or are already on file, and that the chemicals are within their shelf life. Any discrepancies should be reported to the relevant approval authority before the chemicals are accepted into storage.

For facilities using electronic inventory management systems, goods receipt can trigger automatic updates to chemical inventory records, facilitating stock management and ensuring that usage can be tracked.

Storage Management

Factory workers and stores personnel are responsible for ensuring that chemicals are stored in accordance with documented procedures. Upon receipt, chemicals should be moved promptly to designated storage areas—they should never be left in production areas, goods receipt areas or corridors even temporarily.

Within chemical storage areas, personnel should maintain segregation between different categories of chemicals. Food-grade processing aids should be stored separately from cleaning chemicals. Within cleaning chemical storage, different product types may need segregation—acidic and alkaline chemicals, for example, should not be stored in immediate proximity. Maintenance lubricants designated as food-grade should be stored separately from non-food-grade lubricants to prevent mix-ups.

Storage areas should be kept clean, tidy and well-organised, with older stock rotated to the front to ensure it is used before newer deliveries. Damaged containers should be removed from storage, and any spillages cleaned immediately to prevent accumulation of contamination.

Access control is a critical practical measure. Chemical storage areas should be locked when unattended, with access restricted to personnel who have been trained in chemical handling and are authorised to access these areas. This prevents untrained personnel from removing chemicals, reduces the risk of malicious contamination, and ensures accountability for chemical usage.

Daily Use and Handling

When chemicals are required for use in production, maintenance or cleaning activities, only trained personnel should remove them from storage and transport them to the point of use. Chemicals should be transported in a manner that prevents spillage, using appropriate containers, trolleys or carriers designed for chemical transport.

At the point of use, personnel should dispense or apply chemicals according to manufacturers’ instructions and facility procedures. This includes using correct concentrations, applying chemicals only to intended surfaces or equipment, and wearing required personal protective equipment.

When chemicals are decanted into secondary containers for daily use—such as cleaning solution in spray bottles—these containers should be labelled immediately, and only the quantity needed should be prepared to avoid waste and reduce the risk of contamination. Secondary containers should be dedicated to specific chemicals and should not be reused for different substances without thorough cleaning and relabelling.

In production areas, strict discipline is necessary to ensure that chemicals are never placed near open products or food contact surfaces where accidental contamination could occur. Cleaning chemicals should be removed from production areas before production starts, stored in designated cleaning stations or locked cleaning cupboards, and only returned when needed.

Use During Building Work and Maintenance

When building work, refurbishment or major maintenance requires the use of strongly scented or taint-forming materials such as paints, solvents, sealants or adhesives, additional practical measures are necessary. Ideally, such work should be scheduled during planned production shutdowns to eliminate any risk of product contamination.

When work must occur whilst production continues in other areas of the facility, physical segregation should be implemented using temporary barriers, sheeting or enclosures to contain odours and prevent vapours from reaching production areas. Additional extraction may be installed to remove vapours from the work area and exhaust them safely outside.

Before production resumes in areas where strongly scented materials have been used, the area should be thoroughly ventilated, cleaned to remove any residues, and assessed to ensure no tainting odours remain. This may include sensory assessment by trained personnel or, in some cases, testing of sentinel products to verify that no tainting has occurred.

Contractors undertaking such work should be briefed on these requirements and should understand the critical importance of preventing taint contamination. Contract specifications and site induction processes should clearly communicate expectations regarding strongly scented materials.

Record Keeping

Administrative personnel play a vital role in maintaining records that demonstrate effective chemical control. This includes maintaining the approved chemical list as a current, controlled document, ensuring material safety data sheets and technical specifications are up to date and readily accessible, and maintaining training records for all personnel who handle chemicals.

Records of chemical stock levels, usage rates and disposal activities provide valuable management information and can help identify unusual patterns that might indicate problems. Records of spill incidents, including investigations and corrective actions, demonstrate continuous improvement and learning from events.

When chemicals reach their expiry dates or are no longer needed, administrative processes should ensure they are segregated, clearly identified as obsolete, and disposed of in accordance with procedures and regulatory requirements. Records should document what was disposed of, when, how, and by whom.

Routine Inspections and Monitoring

Supervisors and quality assurance personnel should conduct routine inspections of chemical storage areas to verify compliance with procedures. These inspections should check that only approved chemicals are present, that containers are properly labelled and in good condition, that segregation is maintained, that access controls are functioning, and that storage conditions are appropriate.

Inspection findings should be documented, with any non-conformances addressed promptly through corrective action. Trends identified through inspection programmes can highlight areas where additional training or procedural changes may be needed.

Pitfalls to Avoid

Inadequate Segregation

A common shortfall is inadequate physical segregation between chemical storage and food production or storage areas. Some manufacturers store chemicals in production corridors, in goods receipt areas shared with food deliveries, or in rooms adjacent to production without adequate barriers. This significantly increases contamination risk and typically constitutes a non-conformance during audits.

To overcome this, facilities should designate separate, dedicated areas for chemical storage that are physically isolated from food storage and production zones. If space constraints make this challenging, facilities may need to consider external chemical storage or reducing the quantity and variety of chemicals held on site.

Lack of Access Control

Another frequent problem is failing to restrict access to chemical storage areas. Storage areas that are left unlocked or where keys are widely available do not effectively control who can remove chemicals. This increases risks of unauthorised use, accidental misuse by untrained personnel, and potential for malicious contamination.

Overcoming this requires implementing robust access control measures—locks, key control systems or electronic access systems that track who enters chemical storage areas. Facilities should maintain records of authorised personnel and review access rights regularly.

Unlabelled or Poorly Labelled Secondary Containers

Many food manufacturers struggle with secondary containers—spray bottles, smaller jugs or buckets into which chemicals are decanted for daily use. These containers are often unlabelled or have faded, illegible labels, creating risks of chemicals being misidentified and used incorrectly.

Addressing this requires establishing clear expectations that all secondary containers must be labelled immediately upon filling, using durable labelling methods that withstand the working environment. Regular inspections should check for unlabelled containers, which should be removed from use until properly labelled.

Insufficient Training and Competency

Inadequate training of personnel who handle chemicals is a widespread problem. Training may be generic rather than specific to the chemicals actually used in the facility, may not be refreshed regularly, or may not include practical assessment of competency.

Manufacturers should develop comprehensive, role-specific training programmes that cover the actual chemicals personnel will handle and include both theoretical knowledge and practical assessment. Training should be documented, and competency should be verified before individuals are authorised to work with chemicals independently. Refresher training should occur at regular intervals and whenever new chemicals are introduced or procedures change.

Failure to Manage Obsolete or Out-of-Date Chemicals

Many facilities accumulate chemicals that are no longer used or have exceeded their shelf life. These chemicals may remain in storage areas, creating clutter and increasing the risk that they could be used inappropriately.

Manufacturers should implement regular reviews of chemical inventory to identify obsolete or expired materials. These should be segregated immediately, clearly marked as not for use, and disposed of or returned to suppliers promptly in accordance with procedures. Some facilities find it helpful to implement inventory management systems that flag approaching expiry dates.

Inadequate Risk Assessment for Strongly Scented Materials

When building work or maintenance requires strongly scented materials, some manufacturers fail to conduct adequate risk assessment or implement sufficient controls, resulting in taint contamination of products. The potency of some tainting compounds—effective at parts per trillion—means that even brief exposures or materials used at distance from production can cause problems.

To avoid this, facilities should implement a formal risk assessment and approval process before any strongly scented materials are used. Controls should be conservative, with strong preference for scheduling work during production shutdowns. When work must occur during production, multiple controls should be layered—physical barriers, increased ventilation, continuous monitoring, and product testing before release.

Poor Spill Response

Many facilities have inadequate spill response capabilities. Spill kits may be absent, out of date or inadequate for the types and quantities of chemicals stored. Personnel may not know how to respond to spills or where emergency equipment is located.

Addressing this requires ensuring appropriate spill response equipment is available at all chemical storage locations and is maintained in serviceable condition. Personnel should be trained in spill response procedures and should participate in practical drills or exercises. Clear signage should identify the location of spill response equipment and emergency contact information.

Lack of Integration with HACCP

Sometimes chemical control is treated as a standalone issue rather than integrated into the facility’s HACCP plan and prerequisite programmes. This can result in chemical controls not being validated, monitored or verified with the same rigour as other food safety controls.

Chemical control should be explicitly included within prerequisite programmes that form part of the HACCP system. Control measures should be validated to ensure they are effective, monitoring should verify consistent implementation, and verification activities should confirm the overall effectiveness of chemical control.

In Summary

Chemical control in food manufacturing facilities represents a critical prerequisite programme that prevents contamination whilst enabling the effective cleaning, maintenance and operation of production facilities. At its core, effective chemical control requires a systematic approach encompassing rigorous approval processes, designated and secured storage arrangements, comprehensive training of personnel, careful handling practices, and robust procedures for managing exceptional situations such as building work requiring strongly scented materials.

The documented framework—including approved chemical lists, safety data sheets, suitability assessments, storage procedures, training specifications, and spill response protocols—provides the necessary structure and clarity. However, documentation alone is insufficient; practical implementation through disciplined procurement processes, effective physical segregation, restricted access control, proper labelling of all containers, and routine monitoring is what ultimately protects food products from chemical contamination.

Key takeaways for food manufacturing professionals include recognising that chemical control is not merely a compliance exercise but a fundamental food safety measure that requires ongoing attention and continuous improvement. The most successful facilities treat chemical management with the same seriousness as other critical food safety controls, integrating it fully into their HACCP systems and food safety culture.

Manufacturers should prioritise robust access control and comprehensive training as these measures address multiple risks simultaneously — preventing unauthorised access, ensuring competent handling, and reducing the likelihood of incidents. Regular internal inspections and audits should verify not only that procedures exist but that they are being followed consistently across all shifts and all areas of the facility.

The management of strongly scented or taint-forming materials deserves particular attention given the extraordinarily low levels at which some tainting compounds can affect food products. A cautious, risk-based approach with strong preference for scheduling such work during production shutdowns, combined with multiple layers of control when work must occur during production, protects both product quality and brand reputation.

Finally, chemical control should be viewed as a dynamic system that evolves with the facility’s operations. Regular review of the approved chemical list, assessment of whether chemicals continue to meet food safety requirements, evaluation of storage arrangements as facilities change, and updating procedures to reflect lessons learned from incidents or near-misses ensures that chemical control remains effective over time.