13.06.PR.002 Chemical Management

Procedure NO.
Issue Date Page

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13.06.PR.002
Revision NO. Written by: Approved by:
1 Roijals, Oscar Alishahpour,
(HSE Manager) Siavash (All
Departments)
HSEQ Procedure
Subject Chemical ManagementChemical Management
1. Changes to previous revisions:
None, this is the first version
2. Objective
To have a process in place for assuring that worker’s health and the environment are protected
from unreasonable risk resulting from exposure to chemicals through the application of
appropriate risk management measures.
3. Definitions
ALARP As Low As Reasonable Possible

GHS Globally Harmonized System
HSEQ Health, Safety, Environment and Quality
Interim action A limited on time transient action which is used to control some chemical
hazards until the definitive actions can be implemented. It aims business
continuity under a risk-based decision making process.
MOC Management of Change
MSDS Material Safety Data Sheet
PPE Personal Protective Equipment
QoL Quality on Line
UAE United Arab Emirates
4. Responsibilities and competences
R = Responsible
representatives
All employees
Management
A = Accountable
HSEQ focal
Warehouse
Other focal
Contractor
C = Consulted
Manager
Manager
General
HSEQ
points
I = Informed
Team
point
staff
Write and keep updated this procedure A R

Approve this procedure R A
Lead the VTTI FTL chemical management
R A R -
process (gatekeeper)
Propose the introduction of a new chemical
according to the principles relaying on this A I R
procedure
Obtain the MSDS and other chemical information A R
Uncontrolled copy if printed

Procedure NO. Issue Date Page
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R = Responsible
representatives
All employees
Management
A = Accountable
HSEQ focal
Warehouse
Other focal
Contractor
C = Consulted
Manager
Manager
General
HSEQ
points
I = Informed
Team
point
staff
Perform risk assessment before introduction of
any chemical (FTL – 13.06.PR.09-F002: Risk I/C A/C R R
Assessment for new chemicals introduction)
Define actions to be implemented before using
A/C A/C R R
the chemical
Upload long term actions into QoL A R
Approve the use of a new chemicals by having in
A R R I I
place interim actions during a period of time
Approve exceptions to any requirement R
Upload long term actions in QoL A R
Receive the chemical (first time entrance) and
A A R R R
perform first inspection, acting accordingly.
Receive the chemical and perform inspection
A R
(once it has been used before)
Keep update the chemical list form in QoL (FTL
A R
– 13.06.PR.02-F001: Chemical List)
Ensure all control and preventive measures are
A R I
in place before start using any new chemical
Ensure all chemicals are labelled A A R R R
Label chemical samples taken from process
areas according to the requirements set in this A R R
procedure
Ensure all chemicals are storage in proper areas
A A R R
and complying with the compatibility matrix
Perform periodic inspections A A R R
Perform a yearly basis chemical sweeping A A R R I R
Inform about any new chemical to be storage or
I/C I/C I/C R
use in VTTI FTL facilities by contractors
5. Procedure / work instruction
5.1 Introduction
5.1.1. The introduction of a chemical substance into the facility is, as per MOC VTTI procedure,
one of the changes which needs an evaluation before the chemical is in place. The

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purpose of this procedure is to deal with this requirement trough a flexible but rigorous
process wherein the hazards of this new chemical can be identified to confirm that the
appropriate controls and preventive measures are in place under the ALARP approach.
5.1.2. With the exclusion of vessels / barges unloading activities, under the control of the
Terminal procedures, the introduction of any new chemicals into the VTTI FTL facilities
needs to follow the requirements stated in this procedure.
5.2 Focal points
5.2.1. Every Department Manager shall appoint one or two focal points through whom this
process will be deployed, implemented and periodically checked.
5.3 Need of introducing a new chemical
5.3.1. If any Department needs to introduce a new chemical it shall inform the concerned focal
point to start the process described in this procedure.
5.3.2. First of all, the focal point will check that the chemical is not present in the facility (by
means of other departments). If it is present, no further actions are needed, rather than
asking for its acquisition. For doing that he will consult the updated chemical list
published in QoL (FTL – 13.06.PR.02-F001: Chemical List).
5.3.3. If this chemical has never been used in the facility and a potential supplier has been
identified (no matter after that the chemical can be purchased to other supplier), the focal
point will ask them for the updated MSDS.
5.4 Risk Assessment
5.4.1. The philosophy relying on the Risk Assessment phase is to avoid in an early stage, as
much as it can be reasonably possible, the entrance of new hazardous chemicals in
terms of health, which means special focus on high toxics (H304, H310, H330),
carcinogenic (H350, H351), mutagenic (H340, H341), teratogens (H360, H361) and
sensibilizers (H334, H317).
5.4.2. As a part of the risk assessment process, the concerned department shall try to find other
suitable chemicals free of all or some of the hazards mentioned above. If there are
evidences that there are no other reasonable or suitable alternatives in the market, then a
further evaluation together with the HSEQ Department regarding the technical and
procedural measures in place or to be taken is needed.
5.4.3. Once the MSDS is available, the focal point will send it to the HSEQ Department focal
point for starting the risk assessment process.
5.4.4. This HSEQ focal point shall evaluate the risk by using the form FTL – 13.06.PR.002-
F002: Risk Assessment for the introduction of new chemicals. For doing that he will
appoint a meeting with the interested counterpart to understand why the chemical is
needed, where it is going to be used and storage, how it is expected to be handled, etc.
5.4.5. Once all these subjects are understood the HSEQ focal point will complete the evaluation
and shall fill the form, highlighting the following issues:

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 Special hazards of this new chemicals.

 Compatibility of the chemical with the process metallurgy (to be confirmed by
engineering department).
 Special procedural and administrative measures for handling and storage.
 Specific technical and engineering arrangements to implement before using the
chemical (for example: local exhausting systems, gas detectors, etc.).
 Evaluation of the current facilities to ensure the previous requirements are in place.
 Special training or specific information to be provided to the concerned staff.
 Explicit authorization / rejection (in this case through a clear explanation for rejecting
it). This authorization shall be signed by both focal points (HSEQ and concerned
Department) and both Department Managers.
5.4.6. All engineering actions identified in RA shall be uploaded on QOL by HSEQ focal point &
shall appoint department focal point as a coordinator for follow up.
5.4.7. All engineering actions needed shall be uploaded into QoL by the concerned department
focal point for tracking them. The HSEQ focal point shall be appointed as a coordinator
(for follow up).
5.4.8. If the definitive actions can’t be done in a short time, interim actions to control the risks
will be also valid (procedures, PPEs, etc.). These actions shall be authorized by the
HSEQ Manager and the concerned Department Manager in QoL during a specific period
of time. If the definitive action is not in place after this period, the use of this chemical
shall require a written authorization from the General Manager.
5.5 Purchasing and receiving
5.5.1. The Purchasing Department shall be in charge of launching the bidding process and
buying the chemicals, accordingly to the current purchasing procedures. During this
process, VTTI FTL shall explicitly demand the MSDS (without MSDS there shall not be
possible to buy any chemical substance).
5.5.2. Once the chemical substance arrives to the facility, the warehouse staff shall conduct a
first inspection covering the following aspects:
Subject Aspect Action in case of any deviation

Containers External damages.  Inform EHSQ Department to define how to
Mechanical Integrity proceed and push aside to a safe area the
Proper seals (not damaged cointainer.
tempered)  Inform the supplier about the situation to
resolve responsibilities and actions.
Safety Data Connection between  Warehouse: Inform to the supplier to ask a
sheet the MSDS and the written clarification to verify that the chemical
chemical delivered is the right chemical.
a. If it is not the case, inform HSEQ
Department to define where can be
temporarily storage until picked-up
(preference: the chemical paved and diked

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area).
b. If it is the right chemical, ask the supplier
for the correct MSDS and do not use the
chemical until the MSDS is in place.
Pallet Good condition  Warehouse: If the pallet is not in good
conditions, change it by another one and
issue a complaint to the supplier informing
about this situation.
Labelling Check all containers  If Warehouse detects some incongruences,
have the proper inform the HSEQ Department for advice and
labelling in place start further actions if needed.
(according to MSDS)
5.5.3. In case of being in front of the first arrival of a new chemical (first time the chemical
enters into the facility), the first inspection shall be performed by all concerned parties:
HSEQ, Warehouse and the concerned department focal point.
5.5.4. If the inspection is OK, the chemical can be stored and used in the pre-established areas.
5.6 Recordkeeping
5.6.1. Recordkeeping ensures that all hazardous chemicals being used at the workplace are
under control and the related information kept up-to-date.
5.6.2. The main purpose of recordkeeping is to have an accessible chemical list to provide the
proper information to all workers involved in using, handling or storing hazardous
chemicals.
5.6.3. Recordkeeping starts once the new chemical has been approved and when the
purchasing department provides the HSEQ focal point the MSDS of the winner bidder.
The HSEQ focal point shall update the Chemical List with the proper information
according to the form FTL – 13.06.PR.002-F001: Chemical List and then he will issue it in
Quality on Line. The corresponding MSDS shall be also attached to this list.
5.6.4. For laboratory chemicals it shall be used a specific list associated to the cupboard the
chemical is stored according to the form FTL – 13.06.PR.002-F003: Laboratory
Cupboards Chemical Control.
5.6.5. After that he will send an e-mail to the concerned parties informing of the new
introduction of the chemical and informing them the availability of the MSDS in QoL.
5.6.6. If any worker has no access to Quality on Line he/she always can ask his/her supervisor
to get access to this list or any Safety Data Sheet he/she would need.
5.6.7. If training is needed, see Section 5.13.
5.7 Labelling
5.7.1. All chemical substances and mixtures must have a clear label indicating their identity, no
matter the place where they are.

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5.7.2. The objective is to identify the hazardous properties of these chemicals which may
constitute a risk during normal handling or use, risks to health, property or to the
environment.
5.7.3. Usually labels combine written information with some symbols and pictograms which give
an immediate idea of the type of hazards that chemical can cause.
5.7.4. Table 1 below shows examples of elements on a label that indicates the type of hazard
and the severity of the hazard.
Table 1: Examples of hazard information on a label
Label element Examples
Signal words – these provide an Danger or Warning
immediate warning to the reader
Hazard statements – these May cause cancer

describe the nature and severity Fatal if inhaled
of the chemical hazard based on Flammable liquid and vapour
a chemical’s classification
Causes severe skin burns and eye damage
May cause respiratory irritation
Pictograms – these provide a

pictorial representation of the
type of hazard that can be easily
recognised at a glance
5.7.5. There are different labelling systems used around the world which are currently accepted
within the UAE. The UAE code of practice stipulates that classification of hazardous
materials must comply with "applicable international model regulations”, meaning that
manufacturers may choose from among such regulations including the United Nations
Globally Harmonized System of Classification and Labelling of Chemicals (GHS). In
Appendix 1 there is a correspondence between the previous pictograms and the hazards
statements under GHS.
5.7.6. According to that, VTTI FTL does not require a specific labelling system to the suppliers.
However, the potential coexistence of different labelling systems in the facility is
addressed to ensure that all workers involved in chemical handling and storage
operations understand the different types of labelling, by means of the following actions:
 Basic training in chemical hazards identification and MSDS interpretation.
 Guidelines for interpretation attached in the main chemical storage areas.
 Pictograms and main hazardous statements included in the chemical list form (FTL
– 13.06.PR.002-F001: Chemical List).
5.7.7. Containers that have had chemicals transferred into them (decanted) in the workplace,
and containers of chemical wastes need to be labelled correctly.
5.7.8. Bottles containing samples from different tanks related to loading and unloading
operations with ships and barges shall be labelled with the following information:

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a. Origin of the sample (for example: top T-119).

b. Data
c. Hour
No other information is needed for these operations. All these samples are crude-based
ones so identical precautions shall be taken in all cases (condensates assimilation) and
generic MSDS are available in QoL.
5.8 Storage
5.8.1. Chemicals shall be stored, in all concerned areas (including Laboratory), according to the
following general compatibility matrix (See appendix 1 for pictograms clarification).

 
  
   
    
     
 = OK, can be stored together  = Incompatible chemicals. Do not storage together.  = Can
be stored together if certain measures are in place. Ask EHSQ Department for assessment.
5.8.2. Following special precautions shall be taken regarding laboratory chemical storage
practices:
 Highly toxic and carcinogenic chemicals shall be stored in the same cupboard if no
other incompatibilities are present.
 Maximum volume allowed in one fire-resistant cupboard for extremely flammable
chemicals is 100 litres.

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 Flammable and explosive chemicals shall be stored in flame-resistant cupboards

(minimum requirement RF-30).
5.8.3. Any storage chemical area shall comply with the additional requirements:
 It will be partially covered (roof) but with proper ventilation (open walls).
 It will be surrounded by a kerb with a height enough to keep all the contents of the
major vessel.
 Fire extinguishers will be available outside the chemical area to fight against any
potential fire.
 Regardless the previous requirement, it must comply with the applicable UAE code
in terms of fire protection.
 At least one eye wash-shower shall be available near the chemical area, properly
maintained and inspected.
5.8.4. The previous requirements shall not be applicable to:
 IBCs or drums placed in process areas for injecting chemicals. This vessels are
considered as a process ones.
 Waste disposal areas containing different kind of wastes.
5.9 HSE Inspections
5.9.1. The HSE Officer and the chemical focal point of the concerned department shall perform
in a quarterly basis an inspection to the different places where chemicals are present,
including laboratory, storage areas and process areas.
5.9.2. The inspection report shall be uploaded into QoL. There is not a specific check list for
carrying out the inspection, rather than the accomplishment of the requirements
established in this procedure.
5.9.3. In case of detecting any container without a label or being incorrectly labelled, an
immediate action must be taken.
5.9.4. If the contents of the container are not known, this should be clearly marked on the
container, for example, 'Caution - do not use: unknown substance'. Such a container
should be stored in isolation until its contents can be identified for properly labelling and
disposal.
5.9.5. In case of detecting long term engineering actions or structural actions, the situation shall
be analyzed in the Safety Committee. This kind of actions shall be uploaded into Quality
on Line for traceability (those related to immediate labelling do not need to be upload as
an action, just showing the action taken in the audit report is enough). Immediate actions
solved during the inspection (specific labelling, etc.) will remain in the inspection report,
not being needed to upload them into QoL.
5.10 Chemical Sweeping
5.10.1. In a yearly basis, during the 1Q of every year, all departments’ focal points shall perform
a chemical sweeping in coordination with HSEQ department.

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5.10.2. The purposes of the chemical sweeping are:

 Update the chemical list of VTTI FTL, by ruling those chemicals are not any more in
the facility out or by adding new chemicals that are present in the facility and that for
any reason were not passed through the process described above.
 Identify potential chemicals that are not being used and it is expected they won’t be
used any more to start thinking the way of its disposal.
 Identify, especially in laboratory operations, chemicals with expired dates, to start
thinking the way of its disposal.
5.10.3. Every focal point will use the official and updated chemical list from QoL to sweep and
update the list accordingly. After that, they shall send the list by email to the HSEQ focal
point in order to compile all the information and issue a new updated chemical list (FTL –
13.06.PR.002-F001: Chemical List).
5.10.4. HSEQ focal point shall keep these emails as an evidence of this process in front of an
audit.
5.10.5. If during the chemical sweeping it is detected that new chemicals are in place, the HSEQ
focal point shall meet with the concerned focal point to apply, retroactively, the hazard
assessment and to check that all necessary measures are in place for a safe handling of
the product. Immediately, after that, all concerned workers shall be informed about these
new chemicals through the corresponding Safety Data Sheets.
5.10.6. If during this last analysis any unsafe situation is detected, the following steps must be
taken:
 If the risk is in the yellow area, interim actions defined between HSEQ and the
concerned department shall be taken immediately until definitive actions can be put
in place to reduce the risk ALARP.
 If the risk is considered as unacceptable (red area), the use of the chemical shall be
suspended immediately until the defined measures were in place (if the use of
interim actions allows to reduce the risk temporarily to the yellow area, the use of the
chemical could be activated again).
5.11 Chemicals used by contractor companies
5.11.1. All chemicals used by contractor companies in their own yards (inside VTTI FTL fence)
are excluded of complying with the process described above, but shall be mandatory for
them the following requirements:
a. Contractors shall inform VTTI HSEQ Manager about the chemical substance
they want to introduce in their yards, how much quantity of the chemical will be
present and they shall provide the MSDS. HSEQ manager will discuss in
morning meeting with Department Managers and will forward the proposal to
chemical management focal points for further assessment
b. Compatibility matrix and emergency response equipment requirements in their
storage areas shall be followed.

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5.11.2. If any contractor needs to use a chemical during any job performed in our facilities (and
outside the contractor’s yard) they must proceed according to the next requirements.
5.11.3. The contractor shall send to the concerned VTTI FTL supervisor the name of the
chemical, MSDS and the corresponding risk assessment related to all activities where
they expect to use this chemicals. Contractor shall also specify if the use of the chemical
is for a short period of time or it will have a continuous use (for example, supplying lube
oil to rotary equipment).
5.11.4. The VTTI HSEQ Department shall review the risk assessment and shall provide
comments to the Risk Assessment related to the control and preventive measures to be
in place during the use of the chemical. If any specific training to employees is required, it
shall also be considered.
5.11.5. VTTI shall maintain a list of chemicals used by contractors only for long-term use ones.
Those chemicals related to particular jobs shall be evaluated under the corresponding
Risk Assessments and are excluded from recordkeeping and chemical sweeping.
5.11.6. Within the Contractor Yard Inspection that HSEQ performs periodically, chemical
management shall be also considered in reference with the requirements stated in this
procedure.
5.12 Information and communication requirements
5.12.1. Once issued, this procedure requires familiarization through Quality on Line to the
following positions:
 All members of the Management Team.
 All members of the HSEQ Department.
 All supervisors / superintendents / section heads of the Technical Department.
 All members of the Warehouse section.
 All members of the Laboratory section.
 All Shift Superintendents (Refinery & Terminal).
 All persons acting as a chemical focal point (appointed by their managers).
 All persons acting as an internal certified ISO auditors.
5.12.2. Once issued, this procedure shall be provided through the HSEQ Manager to all long
term contractors with presence in the VTTI FTL contractor’s yard. An “acknowledge”
signature from these contractors shall be kept as an evidence of the communication.
5.12.3. After a new and approved chemical substance enters into the facility, the HSEQ focal
point shall communicate this event by e-mail all concerned Departments.
5.12.4. After the chemical sweeping process, once the updated chemical list has been issued in
QoL, the HSEQ focal point shall inform all employees by e-mail about it.
5.13 Training requirements
5.13.1. As a part of the HSEQ Training Matrix, all employees belonging to VTTI FTL need to
have a basic training to cover the following expectations:

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 Ensure they are able to understand the chemical labelling.

 Ensure they are able to understand the basic hazards related to chemical
handling.
 Ensure they know how to get access to the different MSDS’s.
6. References to other procedures / work instructions
Appendix 1 Pictograms Simple picture to correlate every chemical

pictogram under GHS to the corresponding hazards
VTTI - 13.01.PR.001 VTTI Risk Matrix Used for risk evaluation during the Risk
Assessment step before introducing any chemicals
VTTI - 13.01.PR.009 Management of The Risk Assessment phase fits the purpose of the
Change MOC VTTI procedure in terms of evaluate risks
before any new chemical introduction.
FTL – 13.06.PR.002-F001 Chemical List A form created in this procedure. Once filled it is a
record which contains all the chemicals present at
the facility.
FTL – 13.06.PR.002-F002 Risk Assessment for A form created in this procedure. Once filled it is a
Chemical Introduction record which shows how the risk of a new chemical
introduction has been evaluated.
FTL – 13.06.PR.002-F003 Laboratory A form used by Laboratory to keep under control
Cupboards Chemical the chemicals they have stored in every cupboard.
Control Once filled it is a record.

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APPENDIX 1: THE MEANING OF SOME PICTOGRAMS

13.06.PR.002 Chemical Management

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Procedure NO.

Issue Date Page

1. Changes to previous revisions:

None, this is the first version

ALARP As Low As Reasonable Possible

4. Responsibilities and competences

Write and keep updated this procedure A R

Uncontrolled copy if printed

5. Procedure / work instruction

Uncontrolled copy if printed

5.2 Focal points

5.3 Need of introducing a new chemical

5.4 Risk Assessment

Uncontrolled copy if printed

 Special hazards of this new chemicals.

5.5 Purchasing and receiving

Subject Aspect Action in case of any deviation

Uncontrolled copy if printed

Uncontrolled copy if printed

Hazard statements – these May cause cancer

Pictograms – these provide a

Uncontrolled copy if printed

a. Origin of the sample (for example: top T-119).

Uncontrolled copy if printed

 Flammable and explosive chemicals shall be stored in flame-resistant cupboards

5.9 HSE Inspections

5.10 Chemical Sweeping

Uncontrolled copy if printed

5.10.2. The purposes of the chemical sweeping are:

5.11 Chemicals used by contractor companies

Uncontrolled copy if printed

5.12 Information and communication requirements

5.13 Training requirements

Uncontrolled copy if printed

 Ensure they are able to understand the chemical labelling.

Appendix 1 Pictograms Simple picture to correlate every chemical

Uncontrolled copy if printed

APPENDIX 1: THE MEANING OF SOME PICTOGRAMS

Uncontrolled copy if printed

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