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Risk Assessment & Safety Management System

Safety and Health Review Process Before Chemical Purchase | Checks on MSDS Before It Enters the Site
2026.10.14 13:38
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Risk Assessment and Safety System

Safety and Health Review Process Before Chemical Purchase | Checks on MSDS Before It Enters the Site

When introducing new cleaning agents, adhesives, or paints, check the MSDS After receiving Upon receipt, posting, training, warning labels, and risk assessments all follow. The MSDS is received first at the purchase request stage, and after verifying regulatory applicability and usage conditions, it is imported. 5-Step Pre-purchase Review Process And I have organized the roles by department.

short answer
Pre-purchase review of chemical substances is not a legally mandated procedure. However, business owners using chemical substances are required to post and keep MSDS available, post management guidelines for each work process, provide worker training (Article 114 of the Occupational Safety and Health Act), and place warning labels on workplace containers (Article 115); additionally, they must conduct periodic risk assessments when introducing new raw materials. To avoid neglecting these obligations Before placing an order, obtain the MSDS to determine: ① whether the substance is prohibited or requires permission; ② whether it is a hazardous substance subject to management, workplace environment monitoring, or special health examinations; and ③ whether it is a hazardous chemical under the Chemical Substances Control Act. It is most reliable to include the step of verifying and deciding on approval, conditional approval, or deferral within the purchasing process. Rather than the health manager reviewing all ingredients alone, a structure where the purchasing and usage departments filter them initially, and the health, safety, and environment departments share the responsibility for expert judgment, is more realistic.

📌 Why 'Before Purchase' and Not 'After Stocking'

The responsibility for creating and modifying the MSDS lies with the manufacturer or importer (Article 110 of the Occupational Safety and Health Act). However, the responsibility for managing the site using the received MSDS is... The company using that substance It is located at. The obligations arising for the company the moment a new substance is introduced are as follows.

What happens when a new substance enters detail reason
Posting and availability of MSDS One or more of the following: the location where the handling process takes place, a visible location within the workplace, or computer equipment easily accessible to workers during work. Article 114(1) of the Act, Article 167 of the Enforcement Rules
Posting management guidelines Product name, hazards/risks, handling precautions, protective equipment, first aid/accident response methods Article 114(2) of the Act, Article 168 of the Enforcement Rules
MSDS training When new target chemicals are introduced, provide training and record and preserve the training time and content. Article 114(3) of the Act, Article 169 of the Enforcement Rules
Warning signs Warning labels on containers, etc., used for transfer at the workplace (exceptions include cases where the supplier has already marked them). Article 115② of the Act, Article 170 of the Enforcement Rules
Ad-hoc risk assessment Frequent risk assessment when introducing new raw materials, etc., or changing Article 15, Paragraph 2 of the Risk Assessment Guidelines
Equipment, Measurement, and Health Checkups If the substance is a hazardous substance subject to management, local exhaust ventilation systems, etc.; if it is a substance subject to measurement, workplace environment measurement; and if it is a substance subject to special health examinations, management of the subjects. Article 422 of the Occupational Safety and Health Regulations, Annexes 21 and 22 of the Enforcement Regulations

If you start this work after the goods arrive at the warehouse, you end up in a situation where the items are already being used on-site, but the MSDS is in the email inbox, training is scheduled for next month, and the local exhaust ventilation system is still being quoted. This is especially true for materials requiring equipment, such as local exhaust ventilation; if you discover the issue after they have been brought in, there is insufficient time to respond. Therefore Moving the review point forward to before placing the order This is the key.

Please also refer to the penalty standards. According to Annex 35 of the Enforcement Decree of the Occupational Safety and Health Act, failure to post or provide MSDS results in a fine of 1 million won per Class 1 substance or workplace for the first offense (2 million won for the second offense, and 5 million won for the third offense or more), while failure to provide MSDS training results in a fine of 500,000 won per worker subject to training for the first offense. A separate fine of 100,000 won is stipulated for cases where MSDS could not be posted because it was not obtained from the supplier, Records of requests made to the supplier It is also important to keep [it]. Businesses with fewer than 100 regular employees have reduction criteria based on their size.

🧭 5 Steps to Review Before Purchasing Chemicals

1) Purchase Request | We accept usage, quantity, and location together.

When a user department submits a purchase request, it cannot be reviewed if only the product name is written. Purpose, estimated monthly usage, location/process of use, method of use (spraying, coating, washing, etc.), existing replacement products The first step is to change the request form to include this information. Requiring the import of small quantities of samples or test materials to also go through the same request form is necessary to prevent entry into the site without an MSDS.

2) Obtain MSDS | Verify that it is the latest version received from the supplier.

The transferor or provider must provide the MSDS to the recipient (Article 111, Paragraph 1 of the Act), and the MSDS must reflect the Material Safety Data Sheet System submission number (Article 160, Paragraph 1 of the Enforcement Rule). The purchasing department must provide to the supplier before placing an order. MSDS and copy of warning label It is based on the principle of requesting and receiving them. Searching for MSDS on the Korea Occupational Safety and Health Agency's Material Safety Data System is for reference only, and the Agency also advises that statutory MSDS must be obtained from the supplier.

If the ingredients in the alternative MSDS are concealed as 'trade secrets,' health managers, occupational health physicians, employee representatives, etc., may request the manufacturer or importer to provide the actual names and contents to prevent health hazards to workers (Article 112, Paragraph 10 of the Act). Please utilize this channel if it is essential for your judgment.

3) Regulatory Screening | Check applicability in the table first.

Review MSDS Item 3 (Name and Content of Components) and Item 15 (Status of Legal Regulations) and check for applicability in the following order. If the result is 'Applicable', the criterion for judgment is whether the corresponding obligations can be prepared prior to introduction.

Confirmation items If applicable reason People who usually watch
substances prohibited from manufacture, etc. Prohibition of manufacture, import, transfer, provision, and use (exceptions include approval for testing or research purposes) Article 117 of the Act, Article 87 of the Enforcement Decree Health manager
Permitted substances Permission from the Minister of Employment and Labor required before manufacturing or use Article 118 of the Act, Article 88 of the Enforcement Decree Health manager
Hazardous substances subject to management and specially managed substances Closed-loop facilities or local exhaust ventilation systems (when handling indoors), and additional management for specially controlled substances. Articles 420 and 422 of the Occupational Safety and Health Regulations, and Appendix 12 Health and Safety Manager
Targets for workplace environment measurement Reflect in measurement plan (verify exceptions such as consumption below allowable limits or temporary work) Enforcement Rule Article 186 · Appendix 21 Health manager
Special health examination subjects Management of workers subject to special health examinations Article 201 of the Enforcement Rules and Appendix 22 Health manager
Hazardous chemical substances (Chemical Substances Control Act) Verification of handling standards, inspection of handling facilities, and eligibility for business permits or notifications Articles 2, 13, 24, and 28 of the Chemical Substances Control Act Environment Manager

The Chemical Substances Control Act, through the amendment effective August 7, 2025, [regarding] hazardous chemical substances Acute hazardous substances to humans · Chronic hazardous substances to humans · Ecological hazardous substances · Accident preparedness substances It has been reclassified. If you are using an internal list based on the old 'toxic substance' standards, it is recommended to check the latest classification with your environmental manager. Regulatory information by substance can be viewed on the Chemical Substances Information System.

4) Review and Determination of Usage Conditions | Approval · Conditional Approval · Deferral

Even for the same substance, the actual risk varies depending on usage volume, ventilation conditions, working hours, and protective equipment. We examine the ventilation facilities at the site of use, necessary protective equipment, storage locations, and whether there are less dangerous alternatives to existing products. Risk assessment guidelines prioritize hazardous and dangerous substances as the first step in reduction measures. Replacement Since [it] is [in place] (Article 12), if a request is made to replace an existing product, it is also recorded whether the change is made to a safer option. The method for comparing alternative candidates is Chemical Substitution Review Meeting Recording Standards It is organized in.

verdict Criteria Example Next steps
approval Not subject to prohibition or permission, necessary equipment and protective gear already exist Pre-stocking preparation (Step 5) in progress
Conditional approval Use when conditions are met, such as supplementing local exhaust ventilation systems, protective equipment, and storage cabinets, and adding subjects for measurement and special inspection. Record the conditions, completion deadline, and verifier together.
hold MSDS unavailable, insufficient ingredient information, subject to prohibition or authorization, need to review alternatives Request supplier re-request or review of substitutes

5) Preparation Before Entry | Posting · Training · Warning Signs · Risk Assessment

Once approved, determine the location for posting and storing the MSDS, handling procedures, container warning labels, training for handling workers, and the schedule for ad-hoc risk assessments before the substance is received. Since ad-hoc risk assessments must be conducted when raw materials are newly introduced or changed (Risk Assessment Guidelines Article 15, Paragraph 2, Subparagraph 2), grouping them with the purchase approval process ensures they are not missed. The timing of implementation and the recording method are Timing for Ad-hoc Risk Assessments and Recording Criteria Please refer to [this]. Finally, the review is completed once the chemical substances are registered in the workplace chemical list and the MSDS management ledger.

👥 Departmental Roles | The Health Manager does not need to view everything.

In workplaces with high purchasing volumes, it is difficult to sustain a system where health managers personally review every ingredient in every MSDS in the long run. Since the law does not specify departmental divisions, as follows: Initial verification is performed at the request and purchase stages, while expert judgment is determined by each department. We recommend a sharing method.

role The role of pre-purchase review
User Department (Supervisor) Complete request form (purpose, usage, location), confirm replacement of existing products, share on-site ventilation and protective equipment status, and post and conduct training after receipt.
Purchasing Department Request MSDS and warning labels from the supplier before placing an order, withhold orders for items without MSDS, and keep records of supplier requests.
Health manager Determination of whether subject to prohibition, permission, management, measurement, or special inspection; determination of protective equipment and training content; final judgment
Safety Manager Physical hazards such as flammability and explosiveness, storage conditions, and periodic risk assessments
Environment Manager Whether it is a hazardous chemical substance under the Chemical Substances Control Act, and whether it is subject to handling facilities and business permits

The role chart, which includes who receives, replaces, and trains when the MSDS changes, is MSDS Update Responsibility Allocation Table I organized it in Excel.

✅ Pre-purchase Review Checklist

The items below are the minimum items to check before pressing the order button. In particular Securing MSDS, identifying prohibited and authorized items, pre-receipt training schedule This is a basic requirement. If even one is 'No', it is safer to leave it as conditional approval or hold.

Inspection items Confirmation details check
Request form The purpose, monthly usage, place of use, and method of use are written therein. □
MSDS It is an MSDS received from the supplier and has a submission number and creation/revision dates. □
Sample The same procedure was followed for the import of small quantities for testing. □
Prohibition/Permission It is not a substance prohibited from manufacture, etc., or a substance requiring permission. □
Subject to management We verified whether the substances were hazardous or specially managed, and confirmed the necessary equipment. □
Measurement and Special Counsel Checked whether it was subject to workplace environment measurements and special health examinations. □
Flower crown method We checked with the environmental department to see if it was a hazardous chemical. □
Protective gear and storage Necessary protective equipment and storage facilities are provided. □
Preparation before stocking We determined the posting locations, management guidelines, warning signs, training schedule, and schedule for ad-hoc risk assessments. □

🤝 Please also address the employees' concerns when new materials arrive.

Field staff are prone to health concerns when first encountering products with strong odors or MSDS containing phrases like 'carcinogenic.' Explaining why these substances are used and what protective measures have been taken during training can help reduce vague anxiety.

After experiencing a chemical leak or exposure accident, anxiety or sleep problems may persist in addition to physical symptoms. Medical treatment and accident investigations are conducted according to established procedures, and if an employee so desires... EAP psychological counseling Please also inform them that they can use the service. As a general rule, information regarding the use of consultation and its details must be managed separately from accident investigation records.

❓ FAQ

Q1. Do health managers need to check all ingredients of new chemical substances?

The relevant laws do not specify a designated person for pre-purchase review. However, it is appropriate for the health manager to oversee aspects requiring health judgment, such as items subject to prohibition or permission, hazardous substances under control, or whether measurement or special health examinations are required. The burden can be reduced if the user and purchasing departments handle the acquisition of request forms and MSDS, while the safety and environment departments handle physical risks and the Chemical Substances Control Act.

Q2. May I receive and post the search results for the Corporation's MSDS?

The data found in the KOSHA Material Safety Data Sheet System is for reference only. You must obtain the MSDS for the actual product you use from the supplier, and even for the same ingredient, the content and composition may vary from product to product.

Q3. Is it okay to view the MSDS on a PC instead of attaching it on paper?

It is possible. Article 167 of the Enforcement Rules recognizes the method of keeping the equipment on computer equipment installed in a location easily accessible to workers during work. However, since measures prescribed by the Minister of Employment and Labor must be taken, please verify whether on-site workers can actually access the PC and find it immediately.

Q4. Is an MSDS required even for small samples received for testing purposes?

The obligation to post MSDS and provide training is not uniformly waived simply because the quantity is small or the item is a sample. While there are regulations allowing the posting of management guidelines to substitute for temporary or part-time work (Article 167, Paragraph 2 of the Enforcement Rules), an MSDS must be posted if requested by a worker. It is safer to require samples to go through the steps of submitting a request form and obtaining an MSDS as well.

Q5. How many hours of MSDS training are required?

There is no separately prescribed minimum time for MSDS training. The training content specified in Annex 5 of the Enforcement Rules (product name, risks and hazards, handling precautions, personal protective equipment, first aid procedures, and how to understand MSDS and warning labels) must be covered, and the training time and content must be recorded and preserved. The duration of the training is deemed to constitute regular safety and health training.

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👉 Next step

There are times when the anxiety felt by on-site staff following the introduction of new substances or accidents cannot be fully resolved by safety measures alone. Please also prepare counseling channels that employees can use comfortably.

Inquire about EAP Implementation →

📚 Source and Verification Criteria

This article serves as a general practical guide for safety and health reviews prior to purchasing chemical substances. The pre-purchase review procedures and departmental roles are practical recommendations based on relevant provisions, not prescribed by statutes; furthermore, the regulatory status of individual substances must be verified using the supplier's MSDS and the original text of relevant laws. For matters requiring workplace-specific judgment, please consult the competent Regional Employment and Labor Office, the Korea Occupational Safety and Health Agency, or the Regional Environmental Office. Date of verification of laws and official data: October 14, 2026.
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Comments4
  • Unknown User4
    원재료 새로 들이면 수시 위험성평가 대상이니까 구매 승인이랑 같이 묶어두라는 게 현실적인 팁 같아요
  • Unknown User3
    화관법 분류가 작년 8월에 바뀐 거 놓치고 있었네요. 예전 유독물질 기준 목록 그대로 쓰고 있어서 환경 담당이랑 다시 봐야겠어요
  • Unknown User2
    승인·조건부 승인·보류로 나눠서 기록하는 거 좋네요. 그동안 메일로 괜찮다고만 회신해서 나중에 근거 찾기가 힘들었어요;;
  • Unknown User1
    샘플로 소량 받는 것도 같은 요청서를 거치게 하라는 부분 공감이요. 테스트용이라고 MSDS 없이 먼저 들어오는 경우가 제일 많더라구요

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