Recording Standards for Judgments and Decisions in Chemical Substitution Review Meetings

Risk Assessment and Safety System

Recording Standards for Judgments and Decisions in Chemical Substitution Review Meetings

A meeting to change chemical substances is not a forum for naming candidates, but rather a place to compare the risk, workability, and manageability of existing substances and replacement candidates using the same criteria and to decide on the next steps. If data is insufficient or test results differ from expectations, adoption should not be rushed; instead, the substance should be placed under conditional testing or deferred to ensure that future risk assessments and field work standards remain intact.

The conclusion of the alternative review is not that it 'looks safer'
It must be a decision that retains the basis for comparison and the following verification conditions.

📌 Answer first

At least in the meeting minutes What is intended to be changed, which candidates were compared, what is the basis for determining that the risk is lower than the existing one, what areas lack data, and who will conduct testing and reconfirmation and when. This must be revealed. If candidates are determined based solely on a single MSDS or purchase price, new risks may be missed regarding exposure during the use phase, mixing, storage, disposal, and changes in work methods.

Recording decisions in three categories minimizes confusion in practice. Classify them as 'Adopted' if there is sufficient comparative evidence and on-site verification is complete; 'Conditionally Tested' if key data exists but actual process testing or additional measures remain; and 'Pending' if hazard data, performance, or exposure control has not been confirmed, or if there is a possibility that the risk will increase compared to existing conditions.

🔎 Scope of judgment covered in this article

This article is not intended to determine the safety of specific substances on behalf of others or to establish the same alternative standards for all workplaces. Results may vary at each workplace depending on handling volume, processes, ventilation, working hours, worker exposure, equipment compatibility, and disposal methods. Therefore, it is recommended that the record forms be integrated with existing risk assessment, purchase change, and work standard systems, and that professional hazard and exposure assessments be verified by safety and health personnel and relevant experts.

Domestic risk assessment is a procedure for identifying hazardous and dangerous factors in structures, facilities, raw materials, and work behaviors, and for establishing and implementing improvement measures to reduce risks. Chemical substitution can be viewed as an example dealing with changes in raw materials and processes, and records of substitution reviews must be linked to the change history of the existing assessment.

🧭 ① Match the information of existing materials and candidates using the same criteria.

Comparing existing substances with detailed data while candidates only have promotional materials will lead to a biased judgment. First, determine the comparison reference date and target process, then apply the same questions to both the existing substance and each candidate. You must also verify whether the actual active ingredient, concentration, usage amount, and operating temperature differ even if only the product name changes.

Comparison area	Questions to check	Examples of supporting evidence
Hazardous Information	How do the hazard and risk classification and composition information differ from the existing ones?	Latest SDS, labels, and supplier verification data
Possibility of exposure	Does the exposure path change during the mixing, spraying, heating, and washing processes?	Work observation, usage amount, ventilation and sealing conditions
Workability	Do working hours, temperature, pressure, tools, and protective equipment change?	Process condition table, worker opinions, trial work
Manageability	Can storage, leak response, disposal, and training methods be maintained or improved?	Storage standards, emergency procedures, disposal and training materials
Change Impact	What changes will occur to work standards, equipment, quality, and supplier procedures?	Change management request, equipment compatibility verification

Do not fill in cells with no data as 'no problem' Needs verification Indicated by . If the candidate's SDS is old or the component and concentration information is unclear, a comparison may be conducted, but the decision may be withheld.

⚖️ ② In the candidate comparison table, leave the basis for your judgment rather than the advantages.

The purpose of the comparison table is not to generate scores and automatically determine a winning candidate. It is to enable meeting participants to view on the same screen which data has been verified and which items still leave uncertainty. Even when using expressions such as 'low,' 'medium,' or 'high,' the meaning is aligned with the company's existing risk assessment standards, and legal safety is not expressed using arbitrary numbers.

For example, when switching an existing cleaning agent between Candidate A and Candidate B, if A has sufficient volatility data but is incompatible with the ventilation system, and B has a lower ventilation burden but could increase working time, neither is deemed 'safe.' The key to documentation is to record the supplementary conditions and test methods for each, marking them as conditionally tested or deferred.

Overseas public guidelines regarding alternative reviews also present a flow that involves identifying the risks of existing substances, finding alternatives, reviewing potential consequences of the alternatives, comparing the existing substances with the alternatives, and evaluating their performance after introduction. This flow is not a standard that replaces domestic laws, but rather a general principle that can be referenced when designing the sequence of comparisons.

🧪 ③ Set the 'termination conditions' first before the test.

When starting a conditional test, you must not define only the success conditions. You must list in advance the conditions that require stopping the test and re-evaluating, such as unexpected odors, vapors, or skin contact; equipment corrosion; poor quality; increased working hours; or increased waste. Narrow the scope of the test subjects and duration to the necessary range, and do not generalize laboratory results directly from the actual field, as they differ.

Items to decide before the exam	Record example
range	Target equipment, process, shift, and test period
Verification materials	SDS, process conditions, worker opinions, measurement and inspection data
Success conditions	Achieve work objectives, maintain or improve existing control measures
Suspension conditions	New exposures, signs of an accident, equipment damage, quality issues, and data discrepancies
Court date	Test result review date, person in charge, next decision

Stopping a test is not a sign to hide failure, but a decision to manage uncertainty. Recording the reason for the suspension along with temporary safety measures can also reduce the need to retest the same candidate.

🗳️ ④ Differentiate and record Adoption, Conditional Testing, and Deferral.

The more meeting attendees there are, the easier it is to mix 'decisions' and 'opinions' in writing. In the decision section, briefly write the current actions and conditions, and link the detailed rationale to comparison tables, attachments, or risk assessment numbers. Ensure the status matches the documentation and labels to prevent the purchasing department from placing orders based solely on price, or field managers from mistaking a candidate under testing for an official substance.

Decision state	When using	Content to leave together
Adoption	When proceeding with the formal transition after comparative data and on-site verification are completed	Transition date, changed evaluation/standard documents, training/storage/disposal measures
Conditional test	When making a judgment after additional testing, measurement, and equipment supplementation	Test scope, success/termination conditions, person in charge, judgment date
hold	When there is a lack of data, a possibility of increased risk, or a lack of control measures	Reason for hold, temporary use criteria, additional verification materials, review conditions

It is advisable to set an expiration date for the 'pending' status as well. You must specify a date to review whether the supplier has supplemented the data, changed the process, or whether the use of the existing material should continue, so that the decision does not get buried in the documents.

📝 ⑤ In meeting minutes, link the grounds for judgment rather than people's opinions.

It is not necessary to transcribe every remark made by the attendees in the meeting minutes. Instead, link the location of the materials that influenced the decision with the verifiers. For example, instead of simply writing "Candidate A Adopted," record the SDS version, test task number, ventilation inspection date, worker feedback, remaining actions, and the person responsible. If materials were added after the meeting, distinguish between the materials verified at the time of the decision and the materials supplemented afterward.

Internal management example: Agenda Change in cleaning process raw materials → decision 'Candidate B Conditional Test' → reason 'SDS 2026-08 version, worker demonstration 2 times, ventilation equipment inspection results' → condition Retesting including night shift after reinforcing the sealed cover → Court date September 30, 2026

🔄 ⑥ Re-align the risk assessment and work standards after implementation.

The review is not complete simply because a replacement has been purchased. Actual usage, worker exposure, equipment condition, and waste volume may differ from those during the trial. For formal implementation, the raw materials, work methods, SDS storage locations, labels, work standards, and training materials in the risk assessment must be updated with the same change number, and the previous standards must be retrieved.

If problems arise after implementation, rather than defending the existing candidate as "safe," verify which assumptions were incorrect. If a worker reports a new odor, irritation, or leak, review it as a near-miss or a change in the work environment; if necessary, suspend use or reinforce temporary measures before re-evaluating.

✅ Pre- and Post-Meeting Checklist

The items below are not a scoring system for automatic candidate approval, but rather for internal verification to ensure that no comparative data or follow-up actions are missing. If even one item is not verified, it is recommended to leave the status as 'Verification Needed' or 'Pending' and schedule a re-verification date with the person in charge.

check	Inspection items	check
range	The existing materials, processes, usage amounts, and operating conditions are clear.	☐
data	The SDS, labels, and supplier data of the existing substances and candidates were verified using the same standards.	☐
On-site	We verified the opinions of workers and supervisors, as well as equipment compatibility.	☐
test	The test scope, success conditions, termination conditions, and re-evaluation date were determined.	☐
decision	The current status is clear: Adoption, Conditional Testing, or Pending.	☐
connection	Personnel responsible for risk assessment, work standards, training, and label changes have been assigned.	☐
tracking	There is still time to verify the effects and new risks after the introduction.	☐

⚠️ Commonly missed points

• Cases where only the product names of candidates are compared and ingredients, concentration, and usage amounts are not verified

• Cases where improvements in price or workability are used as grounds for risk reduction

• When labeling or storing the substance under test as if it were an officially introduced product

• Cases where a review date and a person responsible for additional materials are not determined, even though the matter was deferred at the meeting

• Cases where previous standards remain on-site because work standard documents and training materials are not updated after replacement

Timing for Ad-hoc Risk Assessments and Recording Criteria

Methods for Worker Participation in Risk Assessment and Standards for Recording Opinions

💬 Frequently Asked Questions

Q1. If the candidate has an SDS, can I replace them immediately?

While the SDS is an important verification document, it does not fully account for actual process exposures and changes in work methods. It is advisable to make a decision after verifying usage conditions, equipment, storage, disposal, and the necessity of field testing.

Q2. If there is insufficient data, should the comparison itself be stopped?

You can indicate insufficient data in the comparison table and request supplementary information from the supplier. However, it is safer to avoid making adoption decisions when key hazards or exposure information has not been confirmed, and instead classify it as a pending or limited conditional trial.

Q3. If workability improves in the test, can safety also be considered improved?

Reduced working hours or improved quality are separate advantages. Do not conclude that the risk of hazards or exposure has been lowered based solely on these factors; instead, you must re-examine safety and health data and site conditions using the same comparison standards.

Q4. May the existing risk assessment be discarded after replacement?

Rather than deleting existing assessments, it is recommended to record the version and the reason for the change to ensure consistency between the materials and measures before and after the change. If the risk has changed in the new process, verify the latest assessment separately and preserve the previous documents as a history.

👉 Next step

If you need to review the work environment, risk assessment, and employee support system along with changes to chemical substances, consider an operational direction that suits your organization's situation.

Go to Nudge EAP Implementation Consultation →

📚 Source and Information

• National Law Information Center, Implementation of Risk Assessment under Article 36 of the Occupational Safety and Health Act

• UK HSE, Substance substitution

• Korea Occupational Safety and Health Agency, Chemical Information (MSDS)

Reference verification date: September 14, 2026

This content is intended for general informational purposes. Specific laws, occupational safety and health regulations, chemical management, and workplace environment assessments may vary depending on the size, industry, and processes of the workplace, as well as the latest laws and official guidelines; therefore, a review by a safety and health manager or relevant expert may be required if necessary.

Risk Assessment & Safety Management System

Recording Standards for Judgments and Decisions in Chemical Substitution Review Meetings