Chemical substitution is becoming a central priority for companies that handle hazardous substances. Traditionally, finding safer alternatives has required significant manual effort. AI is changing this entirely. In this article, we explain in what way.
Challenges in Traditional Chemical Substitution
Finding safer alternatives (substitution) is essential for reducing health risks, improving environmental performance and meeting global regulatory expectations. Substitution is increasingly expected by regulators, customers and investors across Europe, the Middle East, North America and Asia-Pacific.
Despite its importance, substitution is traditionally difficult.
Many organisations must manually compare hazard classifications, performance characteristics, regulatory requirements and supply chain constraints. As a result, substitution processes are often slow, fragmented and prone to human error. This can delay safer chemical adoption and make it harder for companies to meet growing ESG expectations.
How AI Can Affect Chemical Substitution
AI introduces a more intelligent, data-driven approach to chemical substitution. Instead of relying on manual comparisons, scattered data and expert judgement alone, AI can analyse large volumes of chemical information in seconds and highlight safer, compliant and operationally suitable alternatives. It brings structure, consistency and predictive capability to a process that has traditionally been slow and uncertain.
Faster Identification of Safer Alternatives
Instead of searching manually, AI can instantly analyse extensive chemical datasets and SDS records and suggest alternatives that offer reduced hazards, similar performance and better regulatory outcomes. This speeds up decision-making by helping organisations respond quickly to regulatory changes.
Automated Hazard and Risk Assessment
AI can help interpret complex data, classify hazards and estimate risk scores automatically. This removes inconsistency caused by manual interpretation and ensures every substance is evaluated within a standard, reliable framework. AI can also help flag chemicals with missing or outdated data, ensuring assessments remain accurate.
Compliance Assurance Across Global Regulations
With operations often spanning multiple countries, compliance demands may vary. AI continuously tracks regulatory updates across regions and automatically checks whether a substance or its alternative is compliant. This protects organisations from unintentional non-compliance and helps maintain a proactive approach to international chemical safety expectations.
Enhanced Sustainability and ESG Performance
AI can help organisations assess environmental impacts by comparing biodegradability, ecotoxicity, emissions and lifecycle considerations. As a result, it can help with ESG reporting and strengthen the organisation’s environmental profile across global markets.
Important: Although AI provides valuable insights, it is not fully reliable on its own. All AI-generated recommendations should be reviewed and validated by qualified experts to ensure accuracy, safety and regulatory compliance.
AI is transforming chemical substitution by simplifying complex processes, speeding up evaluations and enabling safer, more sustainable decisions. For organisations looking to reduce risk and meet global regulatory and ESG expectations, AI-powered chemical systems may be the way to go forward. By integrating AI into their systems, companies can modernise operations, improve safety and be prepared for future regulatory requirements.
Chemicals play a vital role in the oil and gas sector, but behind everyday use lie significant risks. When chemicals are poorly managed, they can threaten health, damage equipment, and harm the environment.
Chemicals in Offshore and Land-Based Operations
Chemicals are used daily across offshore installations and land-based facilities. They are essential for drilling, production, maintenance, and cleaning activities, supporting everything from corrosion protection and scale prevention to water treatment and lubrication.
Used correctly, these substances enable reliable and efficient operations for both operators and drilling contractors. However, their widespread use also means that even minor lapses in handling, labelling, or documentation can create significant safety and environmental consequences.
Common Chemicals and Their Use:
Acids: Used for cleaning and well stimulation.
Biocides: Prevent bacterial growth in water systems.
Corrosion inhibitors: Protect pipelines and equipment from rust.
Degreasers: Clean machinery and remove oil residues.
Demulsifiers: Separate oil, water, and solids in production.
Drilling additives: Control pressure and lubricate during drilling.
Glycols: Prevent freezing and hydrate formation.
Hydraulic fluids: Power valves, pumps, and tools.
Scale inhibitors: Prevent mineral build-up in wells and pipelines.
Typical Chemical Hazards and Risks
Chemical hazards affect people, the environment, and operational performance across the oil and gas sector.
Health Hazards
Toxic exposure: Inhalation of vapours, mists, or dusts may cause respiratory irritation, dizziness, or long-term health effects.
Skin and eye contact: Many chemicals are corrosive or irritating, posing risks of burns, dermatitis, or eye injury.
Flammability and explosion risk: Solvents, fuels, and gases can ignite under specific conditions, especially in enclosed or poorly ventilated areas.
Reactivity: Incompatible chemicals may react violently, generate heat, or release toxic gases.
Chronic health effects: Long-term exposure can contribute to neurological, reproductive, or carcinogenic outcomes.
Sensitising risk: Certain substances, including diisocyanates, are strong respiratory and skin sensitisers. Repeated or prolonged exposure may cause allergic skin reactions, occupational asthma, or long-term breathing difficulties, with symptoms potentially occurring even at very low exposure levels once sensitisation has developed.
Environmental Hazards
Marine pollution: Offshore spills can spread rapidly, affecting marine life and coastal ecosystems.
Soil and groundwater contamination: Land-based spills or improper disposal can cause long-term environmental impact.
Air emissions: VOCs and other fumes released during handling or disposal contribute to air pollution and create hazardous vapours.
Operational Hazards
Corrosion and material degradation: Poor control of corrosive substances can weaken pipelines, tanks, and valves.
Equipment malfunction: Contamination or incompatible products may damage pumps, sensors, or control systems.
Storage and containment failures: Poor segregation, temperature control, or maintenance increases the risk of instability or leaks.
Process disruption: Mismanaged inventories can cause delays, shutdowns, or reduced efficiency.
Emergency response limitations: Incorrectly labelled or untraceable chemicals complicate firefighting and incident response.
Staying Clear of Chemical Hazards and Risks
Managing chemical risks is all about preventing incidents before they occur.
Stay Compliant
In the oil and gas sector, chemical management must meet strict industry-specific regulations alongside general health and safety requirements. Clear documentation, robust controls, and regular audits help ensure safe operations and ongoing compliance.
Clear Procedures and Training
Conduct regular risk assessments and ensure clear handling and storage guidelines are in place. Continuous training and a strong safety culture help staff recognise hazards early and respond effectively.
Accurate Labelling and Documentation
Keep safety data sheet (SDS) and risk report updated and accessible, and use standardised, multilingual labelling across all sites. Full traceability, from delivery to disposal, reduces the risk of errors and non-compliance.
Adequate Personal Protective Equipment (PPE)
Select and use PPE suited to each chemical and task. Proper gloves, eye protection, and respiratory equipment reduce exposure risks and support safe handling.
Safe Storage and Maintenance
Separate incompatible chemicals, maintain containment systems, and carry out regular inspections to detect leaks or corrosion before they escalate.
Digital Oversight
Digital tools make it easier to track inventories, check compatibility, and share data between locations. Real-time visibility helps prevent incidents and simplifies reporting. Real-time visibility helps prevent incidents and simplifies reporting, particularly in complex, multi-site oil and gas operations. Where connectivity is limited, offline functionality ensures critical chemical data remains available, with updates synchronised automatically once a connection is restored.
Chemicals will always be a vital part of the oil and gas industry, supporting everything from drilling and production to maintenance and safety. But with their benefits come undeniable risks. In such complex and high-pressure environments, effective chemical management is not optional – it is essential. By combining clear procedures, continuous training, and digital tools, companies can turn chemical safety from a compliance task into a core part of the operation.
GHS labels provide a standardised approach to chemical labelling that is recognised across borders and industries. By presenting hazard information consistently and clearly, these labels ensure that everyone handling chemicals understands the associated risks and the measures needed to work safely, regardless of location or language.
What is GHS?
GHS is short for the “Globally Harmonized System of Classification and Labelling of Chemicals” and represents an internationally agreed framework developed by the United Nations to ensure that information about chemical hazards remains consistent and understandable worldwide.
The purpose of GHS is to harmonise how chemicals are classified based on their physical, health and environmental hazards, and how those hazards are communicated through labels and safety data sheets (SDS). Previously, different countries used different systems, symbols and terminology, which created confusion and increased the risk of accidents, particularly for companies operating across borders.
Why GHS Labels Are Important
GHS itself is not a law. Instead, it provides a common foundation that countries and regions use to develop their own chemical regulations.
GHS labels provide clearly structured and standardised information about chemical hazards, thereby supporting safe handling, storage and use. For example, in oil and gas operations, where chemicals may be flammable, corrosive, toxic or harmful, incorrect or inconsistent labelling can have serious consequences.
Furthermore, by standardising how hazards are communicated through text and symbols, GHS labels help reduce risk, improve safety awareness, and support regulatory compliance across international operations.
Key Elements of a GHS Label
A GHS label consists of key elements designed to communicate hazard information clearly and effectively:
Product identifier: The chemical name or identifier that matches the substance with its SDS.
Supplier information: Details of the manufacturer, importer or distributor, including contact information.
Signal words: “No signal word”, “Danger” or “Warning”, indicating the relative severity of the hazard.
Hazard statements: Standardised phrases describing the nature and degree of the hazard.
Precautionary statements: Guidance on measures to minimise or prevent adverse effects, including safe handling, storage, disposal and emergency response.
Hazard pictograms: GHS uses a set of standard hazard symbols, also known as pictograms, to visually communicate chemical hazards. These symbols are easy to recognise and quick to understand, even in multilingual workplaces.
Together, these elements ensure that chemical hazards are communicated in a clear, consistent and internationally recognised way.
GHS Implemented Worldwide
GHS is a global system, but countries and regions implement it through national and regional regulations. Although the underlying principles are aligned, specific legal requirements may vary. Therefore, global organisations must carefully manage chemical classifications, hazard statements, and hazard symbols to remain compliant across jurisdictions.
Examples of GHS implementation include:
Europe: GHS is implemented through the Classification, Labelling and Packaging Regulation, commonly referred to as CLP. CLP defines how substances and mixtures must be classified, labelled, and packaged within the European Economic Area. The United Kingdom continues to apply a similar CLP-based framework after Brexit, with some local adaptations.
United States and Canada: In the United States, GHS is incorporated into OSHA’s Hazard Communication Standard. Canada applies GHS through the Workplace Hazardous Materials Information System, known as WHMIS.
Middle East and Asia-Pacific: Many countries in the Middle East and Asia-Pacific, including Saudi Arabia, the United Arab Emirates and India, have adopted or are continuing to develop GHS-based regulations.
GHS labels play a key role in improving chemical safety and supporting regulatory compliance across global operations. By standardising how hazards are classified and communicated, GHS helps organisations reduce risk and improve safety awareness. With varying regional requirements, managing GHS compliance can be complex.
Working with offshore chemical management on the Norwegian Continental Shelf, you’ll quickly come across terms such as HOCNF, NEMS, green and red chemicals, and discharge permits.
These are all part of Norway’s environmental management framework for offshore chemicals. Understanding how they fit together is essential for anyone working with chemical management, occupational hygiene, environmental compliance or HSE in the offshore industry.
This article explains how the framework works, how the different components are connected, and the role each plays in protecting the marine environment.
A Different Approach to Offshore Chemical Management
Norway’s approach to offshore chemical management is rooted in a long-term ambition to minimise the environmental impact of petroleum activities.
In 1997, the Norwegian Parliament adopted national zero-discharge targets for environmentally hazardous substances from offshore petroleum operations. Rather than prohibiting all chemical discharges, the objective was to eliminate or minimise discharges of substances that could harm the marine environment while encouraging the industry to replace hazardous chemicals with less environmentally harmful alternatives wherever possible. Over the following decades, this policy became one of the driving forces behind Norway’s environmental management framework for offshore chemicals.
The Building Blocks of the Norwegian System
Supporting this ambition requires more than simply knowing which chemicals are used offshore. Operators and authorities need consistent information about each chemical’s environmental properties, a common way of classifying environmental hazard, and a regulatory framework for controlling what may be discharged.
This is why Norway combines several complementary systems:
HOCNF provides the environmental data
NEMS manages and classifies the environmental data
The Norwegian Environment Agency (Miljødirektoratet) uses this information when assessing applications for discharge permits
Operators use the same information to ensure their offshore activities remain within the conditions of those permits.
Together, these elements create a transparent and consistent framework for protecting the marine environment while enabling offshore operations.
HOCNF: The Environmental Data Behind Every Assessment
Every environmental assessment starts with data. The Harmonised Offshore Chemical Notification Format (HOCNF) was developed by the OSPAR Commission to provide a standardised way of documenting the environmental properties of chemicals intended for offshore use. Rather than allowing suppliers to submit environmental information in different formats, the HOCNF defines exactly what information should be provided and how it should be presented. This allows operators and regulators across the OSPAR region to assess offshore chemicals using a consistent set of environmental criteria, regardless of who manufactures the product.
The HOCNF is normally prepared by the chemical supplier, who has access to the product formulation and technical information. Environmental test data is generated through laboratory testing using recognised international methods, while the supplier compiles the complete HOCNF documentation.
Importantly, an HOCNF is not an approval. It is the environmental data package used by operators and authorities to assess the potential environmental impact of offshore chemicals.
The Difference Between HOCNF and SDS
Why isn’t a Safety Data Sheet (SDS) sufficient? The answer is that the two documents have different purposes.
A Safety Data Sheet is designed to protect people. It provides information about hazards, safe handling, storage, transport, emergency response and occupational health in accordance with regulations such as REACH and CLP.
An HOCNF is designed to protect the marine environment. It provides the environmental information needed to assess the potential impact of offshore chemical discharges, including marine toxicity, biodegradation and bioaccumulation.
Because the two documents are developed under different regulatory frameworks and assess different types of risk, the same chemical may have different classifications in an SDS and an HOCNF. A product that presents relatively low risk to workers may still contain substances that persist in the marine environment or are harmful to aquatic organisms.
For this reason, an SDS alone is not sufficient for chemicals intended for offshore use on the Norwegian Continental Shelf. The HOCNF provides the additional environmental information needed for classification in NEMS and for discharge permit applications to the Norwegian Environment Agency.
The resulting colour category then helps operators determine whether a chemical can be used offshore within the limits and conditions of their discharge permit.
HOCNF and SDS Compared
Safety Data Sheet (SDS)
HOCNF
Protects workers
Protects the marine environment
Required under REACH/CLP
Required for offshore environmental assessment in the OSPAR framework
Human health and physical hazards
Marine toxicity, biodegradation and bioaccumulation
Used across industries
Used for offshore chemicals
NEMS: Turning Environmental Data into Practical Information
Once the HOCNF has been completed, the chemical supplier submits the environmental information to NEMS Chemicals, the industry’s shared database for offshore chemical information on the Norwegian Continental Shelf.
NEMS provides a common source of environmental information for operators and supports the registration, classification and management of offshore chemicals.
Before a chemical is made available to operators, the submitted HOCNF documentation undergoes quality assurance by the NEMS KPD Centre, an independent organisation responsible for verifying that the environmental data has been generated and documented in accordance with the applicable standards. This includes reviewing laboratory documentation and confirming that the required environmental testing has been performed using recognised international methods.
Once the HOCNF has been verified, NEMS calculates the Norwegian environmental colour category according to the criteria defined by the Norwegian Environment Agency. The verified chemical information is then made available to operators through the NEMS database.
Because all chemicals are documented using the same HOCNF format and verified through the same process, operators can compare products using consistent environmental criteria.
NEMS also protects commercially sensitive information. While authorities can access the full chemical composition where required, operators use verified environmental information without necessarily having access to proprietary formulations.
Understanding Norway’s Colour Categories
One of the most recognisable features of the Norwegian system is the environmental colour classification.
Using the environmental information contained in the HOCNF, NEMS automatically calculates the Norwegian environmental colour category according to the criteria defined by the Norwegian Environment Agency.
The colour categories provide a standardised way of communicating a chemical’s inherent environmental hazard and play an important role in environmental assessments, discharge permit applications and offshore chemical management.
The four main categories are:
Green – Chemicals considered to pose the lowest environmental concern
Yellow – Chemicals that are acceptable for offshore use but remain subject to environmental control
Red – Chemicals that should be substituted where reasonably practicable and require stronger justification
Black – Chemicals containing substances subject to the strictest environmental restrictions
A chemical’s colour category is based solely on its inherent environmental properties and does not change according to how much of the chemical is used. However, the planned quantity, intended application and expected discharge remain important factors when the Norwegian Environment Agency assesses the overall environmental impact of offshore activities and determines the conditions of a discharge permit.
Discharge Permits: From Application to Compliance
Unlike some regulatory systems, Norway does not approve offshore chemicals as individual products. Instead, operators apply to the Norwegian Environment Agency for permission to use and discharge chemicals as part of their offshore activities.
Preparing the Application
When assessing an application, the Norwegian Environment Agency considers information including:
the environmental data documented in the HOCNF
the chemical’s registration and classification in NEMS
its environmental colour category
the intended application and expected discharge volumes
substitution assessments where required
the overall environmental impact of the planned activities
The environmental colour category plays an important role during this assessment. It reflects the inherent environmental hazard of the chemical and helps determine how it should be managed within the regulatory framework. Green and yellow chemicals are generally easier to justify, while the use of red chemicals requires stronger justification and active consideration of safer alternatives. Black substances are subject to the strictest restrictions.
Operating Within the Permit
If the planned activities are approved, the Norwegian Environment Agency issues a discharge permit that establishes the conditions under which chemicals may be used and discharged during the operation.
From that point onwards, responsibility shifts to the operator. The operator must ensure that chemical use remains within the conditions of the discharge permit, that substitution requirements are addressed where applicable, and that actual chemical use and discharges are monitored and reported in accordance with regulatory requirements.
This means the discharge permit is not simply an approval issued at the start of an operation. It forms the legal framework for environmental compliance throughout the lifecycle of offshore activities, from planning and chemical selection to operational reporting.
Reporting and Continuous Environmental Management
Operators continue to record chemical consumption throughout offshore operations and calculate actual discharges based on how each chemical is used. This information forms the basis of mandatory environmental reporting and demonstrates compliance with the conditions of the discharge permit.
The same environmental information that supported the original assessment therefore continues to support environmental management throughout the chemical’s operational lifecycle, enabling both operators and authorities to verify that actual chemical use and discharges remain within the conditions of the discharge permit.
The Framework at a Glance
Framework component
Role
OSPAR
Defines the international framework for offshore environmental management.
HOCNF
Provides standardised environmental data for offshore chemicals.
NEMS Chemicals
Registers, manages and classifies offshore chemical information.
Environmental colour categories
Indicate the inherent environmental hazard of offshore chemicals.
Norwegian Environment Agency
Assesses discharge permit applications and regulates offshore discharges.
Operators
Ensure chemicals are managed and used in accordance with discharge permit conditions.
Environmental reporting
Documents actual chemical use and discharges throughout offshore operations.
Although each component has a distinct role, they all support the same objective: protecting the marine environment while enabling safe offshore operations.
Rather than viewing HOCNF, NEMS, colour categories and discharge permits as separate requirements, it is more helpful to see them as interconnected parts of Norway’s offshore chemical management framework. Together, they provide a consistent approach to assessing, permitting, managing and reporting offshore chemical use on the Norwegian Continental Shelf.
Where does ChemCenter fit? ChemCenter helps operators integrate environmental information into their wider chemical management processes, supporting operator approval workflows, risk assessments, substitution, operational documentation and traceability throughout the chemical lifecycle. It complements the Norwegian offshore chemical management framework rather than replacing the specialised environmental assessments performed through HOCNF and NEMS or the discharge permit process administered by the Norwegian Environment Agency.
Floating Liquefied Natural Gas (FLNG) facilities use chemicals throughout gas processing, LNG production, utilities, maintenance and marine operations. Managing these chemicals requires accurate information about what is onboard, where chemicals are used, their hazards and the controls required to protect personnel and the environment.
What chemicals are used on FLNG facilities?
The chemicals used on an FLNG facility depend on the composition of the natural gas, process technology, operating conditions and facility design.
Common examples include methanol and monoethylene glycol (MEG) for hydrate control, amine solutions for acid gas removal, glycols for gas dehydration, corrosion inhibitors, antifoaming agents, biocides and water treatment chemicals.
These chemicals support different stages of gas production and processing before and during LNG production.
Gas treatment and dehydration
Natural gas must meet specific requirements before it can be liquefied. Depending on the process, amine-based solutions can be used to remove acid gases such as carbon dioxide (CO₂) and hydrogen sulphide (H₂S).
Water also needs to be controlled. Glycols are commonly associated with gas dehydration, while methanol and MEG can be used for hydrate prevention and control in gas production systems.
Other chemicals may be required for corrosion control, water treatment, cleaning and supporting utility systems.
FLNG chemicals extend beyond LNG processing
Not every chemical onboard an FLNG facility is a process chemical.
Maintenance and asset integrity activities can involve paints, coatings, lubricants, solvents, degreasers, adhesives and cleaning products. Laboratories may use chemicals for sampling and analysis, while utility systems can require products for water treatment and equipment operation.
As an FLNG installation is also a floating marine facility, additional chemicals may be associated with vessel maintenance and marine operations.
How are chemicals managed on an FLNG facility?
Chemical management on an FLNG facility involves controlling chemical information throughout the lifecycle of a product, from approval and introduction to use, storage and eventual removal.
This can include:
Chemical approval before a new product is introduced
Maintaining an accurate chemical inventory
Keeping safety data sheets (SDS) up to date
Assessing chemical and exposure risks
Documenting appropriate controls and protective measures
Evaluating hazardous chemicals for substitution
Managing environmental and regulatory information
Chemical information also needs to reflect operational changes. A product may be replaced, an SDS may be updated or a chemical may begin to be used in a different location or process.
Why is chemical management important for FLNG operations?
FLNG facilities bring several complex operations together on one floating asset. Chemicals can be stored and used across gas processing, liquefaction, utilities, maintenance and marine areas.
For HSE managers, this creates a need for visibility across departments and locations. Production personnel may focus on chemicals required for reliable processing, while maintenance and marine teams manage different products and associated risks.
A central chemical management system can help provide one source for chemical inventories, SDS, approvals, risk assessments and other chemical information.
