Feature article - Has summer left you with safety drift?

David Picton, SVP safety and sustainability at EcoOnline, examines how summer workarounds can leave chemical safety controls out of date

As summer turns to autumn, a familiar pattern shows up in many companies: workforce levels stabilise as regular staff return from holidays, releasing temporary workers or easing the strain on colleagues who have covered longer shifts. Whilst this might feel like a return to normal, it may have left behind a problem lurking in chemical management. Left unchecked, this is the start of a potentially deadly safety drift.

Even for the best-managed sites, the accuracy of their chemical inventories depends on employees manually recording substitutions, deliveries and change of use, the kind of administration work that can be delayed or overlooked when staffing is thin. Gaps like these naturally widen over holiday periods as people take time off across entire supply chains. 

Delayed shipments require purchasing teams to source alternative substances, and maintenance work can leave chemicals stored somewhere outside their usual locations. Immediate problems get resolved but, because of staff shortages, tasks like inventory updates or risk assessments can fall by the wayside. 

The lag matters more than ever this autumn, because chemical inventory will be the starting point for identifying the reassessment of hazardous substances. Items placed in the EU market before 1 May 2025 must comply with the Classification, Labelling & Packaging Regulation’s new hazard classes by 1 November 2026. Mixtures placed on the market before 1 May 2026 have until 1 May 2028, which means businesses handling both are working to different transition dates. 

Incomplete records will make it much harder for businesses to know what needs to change. This is the safety drift that we see in certain circumstances – when temporary arrangements become embedded in routine operations without sufficient review of hazards. If that drift goes unchallenged, workers may handle substances under outdated instructions, putting their safety at risk while the business may be unable to demonstrate that its arrangements comply with current regulatory requirements. 

Temporary workarounds; permanent solutions 

Temporary arrangements often begin as practical responses to specific problems. For instance, if usual solvents are unavailable, a purchasing team may approve a substitute to keep production moving. Other gaps can develop around planned work, exacerbated by holiday leave and someone providing holiday cover who knows the procedure but has less familiarity with the plant. 

Even actions as simple as decanting products into secondary containers can introduce risk, when correct labels are unavailable (for that secondary container) and handwritten ones are used instead. In the face of production pressures, workarounds may seem defensible, but they are the start of dangerous trend. Over time, this may be reinforced by habits, informal training, weak handovers or procedures that do not clearly assign responsibility for restoring original protocols. The reason for the workarounds may eventually disappear, but the altered practice remains because it is easier and familiar. 

Safety drift hard to identify 

Once an altered practice becomes routine, there is often little indication that anything is wrong – for a while. Safety drift builds slowly but steadily. Workarounds become normalised as shortcuts become ingrained into work processes and built into habits that are not questioned. The trouble is that a shortcut that works 99 times does not mean it is safe. It simply means that the people taking it were lucky. The 100th time could lead to a serious incident. 

The same problem affects the information used to manage chemical controls. Regulations can evolve while a safety data sheet (SDS) remains the same, particularly when a new hazard class takes effect and handling instructions change. Over time, documents that were accurate when issued may no longer reflect the classification against which substances should currently be assessed. The scale of the administrative task can be easy to underestimate. 

At Wilhelmsen Chemicals, part of a global maritime company operating in 57 countries, a four-person team is responsible for maintaining and creating SDS, distributing chemical safety information and keeping pace with a dynamic regulatory environment. New chemical hazard classes such as endocrine disruptors, tighter regulation of PFAS and the realities of complex international operating models all add pressure to an already demanding function. 

Across the wider market, an ECHA enforcement project checking imported substances found that one out of three substances in mixtures was missing a REACH registration. In addition, restricted hazardous substances were present in some of the imported consumer products above the allowed limits. 

Inspectors found that 35% of the inspected SDS did not comply with the legislation, either because the content did not meet the requirements or the SDS was not provided at all. Paperwork can therefore appear complete while the information reaching the plant floor is already behind the hazard. 

Closing out summer changes 

Compliance slips found in SDS does not mean chemical businesses lack formal controls. Substitutions will normally pass through an approval process, but the follow-up can involve several people across procurement and regulatory teams before updated information reaches the customer. When holiday cover slows those handovers, an approved temporary change may remain open longer than intended.

September is therefore a point at which businesses should check that summer changes have been fully closed out. This means confirming that the material received matches the inventory record and establishing whether its use affects an existing risk assessment. Where a substitution changes the classification of a product, the review must continue through to the information supplied downstream.

The scale of that final step should not be underestimated. Valvoline Oil distributes SDS to around 600 customers, so a single revision may need to be communicated across a large customer base. 

A reliable process should show which version each customer received and when, rather than treating the update of a master document as the end of the task. That visibility helps prevent an administrative delay during the summer from becoming outdated handling information elsewhere in the supply chain.

Using September as a control point

The return from the summer holidays gives businesses a natural opportunity to check whether temporary arrangements are still in place as teams return to full strength and decisions made during reduced staffing are still recent enough to trace. 

The purpose is not to revisit every summer decision, or assume that a workaround was poorly judged, but rather to establish which changes remain open and whether the assessments or documents affected by them have caught up. Any arrangement that needs to continue should be reviewed on that basis instead of being allowed to persist because it has caused no visible harm.

Chemical safety drift develops in the space between an operational change and the record intended to govern it. Closing that gap after the summer allows businesses to enter the busier autumn period with an inventory that reflects current practice and clear responsibility for anything still outstanding.