Developing Your Own Vetting System
The first step in the gatekeeper continuous improvement technique is to collect a library of all banned substance lists and emission limits that apply to your facility, including U.S.-based NESHAPs, MACTs, air permits, along with other international permit conditions, should they apply. For most of these, there will be standardized regulatory guidelines and documentation indicating which materials will put you at risk if you use them, and which you are outright prohibited from using.
This combined library of conditions acts as your filter to catch potential problems. Proper maintenance is critical to ensuring the long-term success of your system.
Next, it’s time to examine and possibly reinvent your material acquisition processes. If you employ a specialized chemical inventory manager for this responsibility, they should “take point” and oversee the gatekeeper system’s operations. Whenever a facility purchases a new material, it will need to undergo a rigorous vetting process against the filters you have compiled.
While collecting chemical component information of the materials purchased should be the bare minimum first step, you may also begin to request that your suppliers provide energy efficiency details and the material’s e-factor.
This vetting process can be done either manually or electronically, depending on the resources you have available and the nature of your industry.
For example, the automotive industry regularly purchases vast quantities of different chemical coatings, and coating vendors are constantly adjusting the chemical compositions of their formulas. This means even materials you’ve used before may need to be vetted every time a change is made and the product is ordered. While this may increase the workload for the EH&S department, it will also ensure there is a fine control mechanism in place for ensuring absolute management over your regulatory risks.
If you organization has integrated your environmental management system (EMS) and material inventory management systems, the best solution is to create an automated gatekeeping system that vets all incoming materials against your internal electronic databases.
This option of automating your vetting process is hands down the most efficient way of making your chemical inventory management as lean as possible. Compared to the manual option for vetting chemicals, you could save dozens of hours each month, as well as all-but-eliminating your instances of preventable noncompliance.
