Chemical Management System Manual 2015

CHEMICAL2015 MANAGEMENT SYSTEM GUIDANCE MANUAL JOINT ROADMAP DELIVERABLE ZERO DISCHARGE OF HAZARDOUS CHEMICALS PROGRAMME I N A S S O C I AT I O N W I T H ES121114083500GNV Contents Section Page Acronyms and Abbreviations........................................................................................................ v Introduction ..................................................................................................................... INTRO-1 Overview......................................................................................................................... INTRO-1 ZDHC Goal....................................................................................................................... INTRO-1 Objective ........................................................................................................................ INTRO-1 ZDHC CMS Goals ............................................................................................................. INTRO-2 Engagement with ZDHC Stakeholders ............................................................................ INTRO-2 Structure of the CMS Manual ......................................................................................... INTRO-3 1 Commitments to CMS ................................................................................................... 1-1 1.1 Management Statement ........................................................................................... 1-1 1.1.1 Requirements ............................................................................................... 1-1 1.2 Scope of CMS............................................................................................................. 1-1 1.2.1 Requirements ............................................................................................... 1-1 2 Assessment, Planning and Prioritisation ........................................................................ 2-1 2.1 Systematically Identify and Document Chemicals Used and Stored in Your Organisation .............................................................................................................. 2-1 2.1.1 Purpose......................................................................................................... 2-1 2.1.2 Facility Plan and Walk Through .................................................................... 2-1 2.1.3 Chemical Material Flow Diagrams (Element 2.1.2) ...................................... 2-2 2.1.4 Creating a Comprehensive Chemical List ..................................................... 2-2 2.2 Regulatory Assessment ............................................................................................. 2-5 2.2.1 Monitoring Regulations and Permits ........................................................... 2-5 2.2.2 Verification of Compliance ........................................................................... 2-6 2.3 Procurement/Supplier Practices ............................................................................... 2-6 2.3.1 Chemical Purchasing Policy Considerations ................................................. 2-7 2.3.2 Identify Chemical suppliers .......................................................................... 2-8 2.3.3 Supplier Approval/Removal Process ............................................................ 2-9 2.4 Chemical Risk Assessment......................................................................................... 2-9 2.4.1 Hazard and Risk Assessment ........................................................................ 2-9 2.4.2 Environmental ............................................................................................ 2-10 2.4.3 Health and Safety ....................................................................................... 2-11 2.5 Chemicals and Processes of Concern ...................................................................... 2-12 2.5.1 Identify Gaps and Losses in Current Processes .......................................... 2-12 2.5.2 RSL and MRSL Process ................................................................................ 2-13 2.6 Performance Goals and Action Plans ...................................................................... 2-14 2.6.1 MRSL Compliant Formulations ................................................................... 2-14 2.6.2 Alternatives Assessment ............................................................................ 2-14 3 Chemicals Management ................................................................................................ 3-1 3.1 Organisational Structure ........................................................................................... 3-1 3.1.1 Roles and Responsibilities ............................................................................ 3-1 3.1.2 Communication ............................................................................................ 3-2 3.2 Training ...................................................................................................................... 3-2 3.2.1 Management ................................................................................................ 3-2 3.2.2 Regulatory .................................................................................................... 3-2 3.2.3 Work Practices.............................................................................................. 3-2 3.2.4 ZDHC Training ............................................................................................... 3-3 3.3 Document Development ........................................................................................... 3-3 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY III CONTENTS, CONTINUED Section Page 3.4 Document and Record Control.................................................................................. 3-3 3.5 Chemical Management Work Practices .................................................................... 3-4 3.5.1 Exposure Control Measures ......................................................................... 3-4 3.5.2 Safety Data Sheet Management .................................................................. 3-5 3.5.3 Chemical Handling ........................................................................................ 3-6 3.5.4 Chemical Storage.......................................................................................... 3-6 3.5.5 Chemical Transportation .............................................................................. 3-6 3.5.6 Chemical Labelling ........................................................................................ 3-7 3.5.7 Chemical Use – Regular and Optimisation ................................................... 3-7 3.5.8 Personal Protective Equipment.................................................................... 3-7 3.5.9 Laboratory Practices..................................................................................... 3-8 3.5.10 Maintenance and Housekeeping ................................................................. 3-8 3.5.11 Waste and Disposal ...................................................................................... 3-9 3.6 Emergency Procedures.............................................................................................. 3-9 4 Monitor ........................................................................................................................ 4-1 4.1 Monitor and Measurement (Continuous Improvement) .......................................... 4-1 4.1.1 Goal Progress................................................................................................ 4-1 4.1.2 Regulatory Compliance ................................................................................ 4-1 4.1.3 Work Practice and Customer Requirements Implementation..................... 4-1 4.2 Internal Audit ............................................................................................................ 4-2 4.3 External Audit ............................................................................................................ 4-2 4.4 Change Management and Corrective Action ............................................................ 4-2 4.4.1 Change Management ................................................................................... 4-2 4.4.2 Corrective Action .......................................................................................... 4-3 5 Management Review .................................................................................................... 5-1 5.1 Disclosure of Substance in Use.................................................................................. 5-1 5.2 Stakeholder Review ................................................................................................... 5-1 5.3 Management Review ................................................................................................ 5-2 6 CMS Resources ............................................................................................................. 6-1 7 Glossary........................................................................................................................ 7-1 Appendixes A Assessing Status B Tables C Chemical Inventory D Risk Assessment Template Example E AAFA Environmental standards JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY IV mutagenic or toxic for reproduction CMS chemical management system CMWG Chemicals Management Working Group CO carbon monoxide CoA certificate of analysis CPSIA Consumer Product Safety Improvement Act DTSC Department of Toxic Substances Control (California) ED endocrine disruptor GHG greenhouse gas GHS Globally Harmonized System of Classification and Labelling of Chemicals GIZ Gesellschaft für Internationale Zusammenarbeit GPSD General Product Safety Directive HAP hazardous air pollutants HVAC heating. Authorization and Restriction of Chemicals RSL restricted substances list SAC Sustainable Apparel Coalition JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY V .Acronyms and Abbreviations AAFA American Apparel and Footwear Association AHA activity hazard analysis AST aboveground storage tank CFC chlorofluorocarbon CMO chemical management officer CMR carcinogenic. bioaccumulative and toxic PM particulate matter REACH Registration. Evaluation. ventilating and air conditioning JHA job hazard analysis JSA job safety analysis KPI key performance indicator LEV local exhaust ventilation MRSL manufacturing restricted substances list NIOSH National Institute for Occupational Safety and Health NOx nitrogen oxides NRDC Natural Resources Defense Council O&M operations and maintenance OIA Outdoor Industry Association OSHA Occupational Safety and Health Administration PBT persistent. ACRONYMS AND ABBREVIATIONS SDS safety data sheet(s) SO2 sulfur dioxide SVHC REACH substances of very high concern THA task hazard analysis US EPA United States Environmental Protection Agency UST underground storage tank VOC volatile organic chemical(s) ZDHC zero discharge of hazardous chemicals JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY VI . These tools fit within the CMS framework in this guidance manual. Tier 1 and 2 suppliers and chemical suppliers in understanding their roles. Later versions will include more detailed content on progressive and aspirational matters. brands and their supply chain partners while accommodating the complexities of the ZDHC roadmap work and the textile supply chain chemistry applications. retailers. its suppliers and other stakeholders a well‐defined structure to move toward zero discharge. This framework will build on ISO management standards and other applicable frameworks. Tier 1 and 2 suppliers and other stakeholders who wish to contribute to the success of the ZDHC Group’s commitment. A management system is a framework that allows inclusion of all projects introduced in the Joint Roadmap. structure and documentation needed to create and support a Zero Discharge of Hazardous Chemicals (ZDHC) Programme CMS. by developing clear guidelines that allow all committed supply chain stakeholders to participate and take responsibility for their part JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-1 . • A management approach allows continuous chemical management improvement and minimisation of environmental impact. The CMS Guidance Manual is intended to be a living document that will be periodically updated. the ZDHC Group affirms that: • A CMS is an effective framework for improving overall environmental and chemical performance while achieving the goal of zero discharge. Objective The ZDHC CMS objective is to develop a management framework that assists brands. including the chemical industry. A CMS provides the ZDHC Group. such as the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) Practical Chemical Management Toolkit and the Outdoor Industry Association (OIA) Chemicals Management Working Group (CMWG) Framework. brand and government regulations. Information provided in this manual should be easily internalised by retailers. ZDHC Goal The ZDHC Group’s goal is to achieve zero discharge of hazardous chemicals across supply chains and product life cycles in the production of apparel. brands. This first version of this manual focuses mainly on foundational matter. Specifically. Version 2. • A management approach can provide the structure for current roadmap projects. The group has developed tools like the Manufacturing Restricted Substances List (MRSL) and chemical guidance sheets to improve chemical management and to assist facilities in achieving or maintaining compliance with retailer. Chemical Management System Guidance Manual Zero Discharge of Hazardous Chemicals Group Introduction Overview This Chemical Management System (CMS) Guidance Manual focuses on the approach. A sound chemical management system is paramount to worker safety and will reduce environmental impacts on the community and the broader environment. A CMS is therefore one of the cornerstones for ensuring continuous improvement towards our 2020 goal of zero discharge of hazardous chemicals throughout the life cycle of our products. footwear and accessory goods by 2020. • A management approach allows an entry point for different actors in the supply chain. Size and organisational structure The CMS requirements specified in this manual are complementary to product requirements and can be used by internal and external parties to assess an organisation's ability to meet customer. Tier 1. Products provided 5. yet pragmatic management system. we provide the ZDHC programme with a sound structure that is recognised. mission and 2020 goal. Global Social Compliance Program and OEKO-TEX® • Perception of the framework as an effective mechanism for driving change and delivering improvements by the supply chain partners in all tiers. The ZDHC Group’s commitment for a CMS is: • Adoption of the overall management framework by ZDHC members and stakeholders that serves as a structure for delivering environmental improvements and systematic change in the supply chain • Alignment and coupling of the overall management framework and the ZDHC Audit Protocol(s) in an effective manner • Use of the framework as a holding structure for the ZDHC Group collaboration for the benefit of ZDHC members and their stakeholders • Alignment of the tools and processes with industry and organisation stakeholders such as the Sustainable Apparel Coalition (SAC). changes in that environment and risks associated with that environment 2. retailers. Processes employed 6. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-2 .INTRODUCTION of the value chain. understood and easy to communicate to the textile industry. but especially for Tiers 2 and 3 suppliers Engagement with ZDHC Stakeholders As stated in the ZDHC CMS goals. By developing a CMS structure for the apparel and footwear supply chain that includes all our existing and future work activities. ZDHC CMS Goals The adoption of a CMS should be a strategic decision of an organisation. Varying needs 3. This level of alignment and harmonisation will be key to delivering on the ZDHC vision. Specific objectives 4. The ZDHC Group goals cannot be effectively accomplished without the support of a variety of stakeholders throughout the life cycle of apparel and footwear products. Design and implementation of an organisation's CMS is influenced by its: 1. 2. Organisational environment. and 3 suppliers and chemical suppliers. the creation of a CMS is intended to be applicable for brands. statutory and regulatory chemical and product requirements. OIA. Documentation in this manual includes outcomes of the ZDHC Group’s work activities and thereby creates a comprehensive. Management Review (Act Phase) Each phase consists of a number of elements designed as a stepwise framework that an organisation can follow to create a systematic and thorough process for managing hazardous chemicals. Commitment to CMS (Plan Phase) 2.INTRODUCTION Structure of the CMS Manual The CMS Manual is structured in five sections that follow the Plan-Do-Check-Act framework used in all management systems: 1. The ultimate goal for a CMS is to create an organisation that is committed to the safe. sustainable and environmentally-responsible management of chemicals and chemical discharge. Monitoring (Check Phase) 5. Throughout. These checklists reflect the efforts of CMWG to harmonise the collective knowledge of key stakeholders and brands around chemical management. If you are uncertain about how to categorise your facility please consult the checklists in Appendix A. Assessment. Planning and Prioritisation (Plan Phase) 3. the framework is marked with symbols indicating the suggested attainment of organisational skills. Organisational skill symbols used in this manual: Symbol Organisational Skill Skill Definition Foundational Foundational (beginning) chemical management Progressive (started but with room to grow) chemical Progressive management Aspirational Aspirational (advanced) chemical management JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-3 . Chemicals Management (Do Phase) 4. The framework presented here is not intended to be prescriptive – it was designed to create minimum requirements with flexibility in the implementation details. 2 Scope of CMS 1. chemical classification.1 Requirements Expected CMS Deliverable: Statement Indicating Where the CMS Is Applicable Each organisation implementing a CMS needs to define the scope of the system by describing and documenting the boundaries of the organisation to which ZDHC Audit Question the CMS applies. Is documented. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 1-1 . The scope may include either the entire Are there Standard Operating organisation or specific operating units. Includes a commitment to comply with requirements ZDHC Audit Question and continually improve the CMS effectiveness Does the facility have a third-party 6. The ZDHC system map can be a useful tool in making your scope determinations. chemical suitable. Such commitments clearly indicate an organisation’s overarching strategy and intentions.SECTION 1 Commitments to CMS The first step in implementing any chemical management system is for an organisation to clearly and publicly commit to the system. Is communicated widely inside and outside the organisation 4. 1. Facilities should note that while there is flexibility disposal and more? (CRS 1.1 Requirements Expected CMS Deliverable: Management Policy Statement Management statements are written endorsements from senior leadership that clearly communicate goals and ZDHC Audit Question aspirations regarding chemical management.2. At a minimum it is Procedures (SOPs) that cover chemical recommended that all production facilities or units are management such as approved included in the CMS.1 Management Statement 1. Includes a goal of zero discharge of hazardous chemicals throughout a product’s life cycle 2. Endorses sustainable chemistry practices 5. Is reviewed for continuing suitability of a chemicals management programme.1) ISO standard (such as 9000 or 14000) or that already has Does your facility have current made a commitment to attain one of these levels of certification for ISO 14000? excellence is typically required to develop a management Does the facility’s management statement.3. This statement can be expanded to become a statement address chemical CMS policy statement that is appropriate to its operations. implemented and maintained 3. the credibility of the management system is dependent on logical system boundaries. to improve their environmental An organisation participating in the process of adopting an performance? (CRS 1. substances that is applied to all Organisations adopting CMS should draft a management chemicals used at the facility? (CRS 1. The goal of Is there a policy for monitoring and management statements is to clearly communicate those controlling banned and restricted organisational goals to internal and external stakeholders.1) statement that: 1.1.2) in choosing the scope. For organisations that are starting to chemical list. management? 1. a stepwise approach might be the most safe chemical handling. implement a CMS. Is appropriate to the organisation’s purpose certified system.1. relevant to any element 7.1. The following information provides tools for resolving any questions answered with No. If most questions are answered with Yes. Process areas facility? (CRS 1.9) maintenance areas The Factory Plan should be reviewed annually with a physical walk through and updated as needed.1. electronic)? (CRS 1. a walkthrough inspection checklist is located in Appendix B Table 2: Walk-through Inspection Sheet for your use. Planning and Prioritisation 2. but coordination and communication may be lacking.1 Requirements Expected CMS Deliverable: Factory Plan Create a Facility Plan that details the physical areas of the property involved in chemical storage and usage.2. Initially conduct a safety pre-screening walk through to identify and resolve any imminent hazards and follow this with a more detailed inspection.1. To assist you in planning.1 Purpose An organisation should have a robust process for creating and updating chemical inventories.1.2. Does the facility have an up-to-date chemical inventory 2. such as laboratories and facility map? (CRS 1. A questionnaire will help your team gather information about how your system is working (Appendix B Table 1: Facility Chemical Management Assessment Questionnaire). A pictorial Facility Plan is recommended with each of the following areas individually labelled on the plan: 1. the facility should focus on Sections 3 to 5 to gauge improvement opportunities.1.3) 2. Purchasing and delivery areas 2. consider how waste and waste disposal are managed for chemicals and off-specification materials.2 Facility Plan and Walk Through (on paper. 2. It may be beneficial to have senior leadership participate in the initial walk through.3 take a stepwise approach in ZDHC Audit Question reviewing and documenting chemicals in an organisation. Manufacturing areas 5. Your team may have many elements of a CMS in place. As part of the pre-screen and walk through. The GIZ Practical Chemical Management Toolkit includes an example Factory/Ground Plan in their Company Handbook Module 1. and 2. The checklist is a simple tool that should aid in identifying areas that may need immediate and overall improvement.1.1.1. Product storage areas ZDHC Audit Question − Chemical storage areas Does the facility have basic − Non-chemical storage areas documentation for the production and chemical operations performance in the 3.1.5) 4. This process should provide a clear understanding of the chemicals stored and used in a facility and promote responsible usage and pollution prevention.8) − Wastewater storage − Non-chemical waste storage areas Are discharge pipes shown on the 6. Waste storage areas Are closed loop (circular) − Chemical waste storage areas cooling/heating lines identified on industrial piping drawings? (CRS 1. Elements 2.1.SECTION 2 Assessment.1.1.1 Systematically Identify and Document Chemicals Used and Stored in Your Organisation 2. Other areas with chemicals. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-1 . handling. A chemical material flow diagram indicates the general flow of chemicals through the organisation’s processes and equipment. your vendor may have an electronic system available for your use. (CRS 1. processing and disposal. you may select an electronic inventory system that can be used and maintained for long-term tracking.4f) Company Handbook Module 1. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-2 .1.2.2.3 Chemical Material Flow Diagrams (Element 2.2. Additionally.4b) process been considered? Does the verification include following the • Have all intermediary products been identified? flow of chemicals through storage? (CRS 1.ASSESSMENT. The Chemical Inventory will be used in upcoming sections to build further information and enable better chemical management.2) Expected CMS Deliverable: Chemical Material Flow Diagrams Create chemical material flow diagrams to assess where the main processes and material streams and wastes occur.4g) Inventory all chemicals in the facility to identify the name of the chemical. locations of containers and dates on which solutions were prepared or expire.2. The GIZ Practical Chemical Management Does the verification include following the Toolkit has example material flow diagrams in their flow of chemicals through disposal? (CRS 1.4d) to collect further information? Does the verification include following the flow of chemicals through Chemical material flow diagrams should be reviewed processing/production? (CRS 1.1.2.2. This diagram should indicate the flow of chemicals through purchasing. Flow streams Does the facility have a flow diagram of the can be further refined as you gather additional production processes to identify hazardous information.4c) • Have you been able to quantify inputs and outputs? Does the verification include following the • Can you clearly assign costs to the different wastes? flow of chemicals through dispensing? • Are there information gaps. water and energy) and product and non-product outputs.2.4e) annually and updated as needed due to operational changes.3) materials into more specific categories such as raw Does the facility regularly conduct materials.1. Identify chemicals of concern for your customers. ask yourself the following questions: flow of chemicals through purchasing steps? • Can/do you recognise the sources of your non. do not forget to ZDHC Audit Questions indicate storage and transfer activities. you can develop your own database (Appendix C) or the GIZ Practical Chemical Management Toolkit includes example material chemical inventories for your use (Company Handbook Module 1). hazard class. personal protective equipment (PPE).2.4 Creating a Comprehensive when inefficiencies /inaccuracies are Chemical List identified during process flow reviews or are Expected CMS Deliverable: Chemical Inventory they updated on a planned schedule or as needed? (CRS 1. comprehensive chemical lists will help assess chemical hazards. by breaking down raw chemical release points? (CRS 1. chemicals. for which you may need (CRS 1. if applicable. The systematic identification of all chemicals at your organisation will allow you to conduct a risk assessment of each chemical and rank the chemicals according to their hazard potential. inventory controls and environmental risks and improve an organisation’s management of chemical use and disposal.4) To determine if your flow chart contains all relevant Does the verification include following the information. for example. storage. container size. To track your inventory.4a) product outputs? Does the verification include following the flow of chemicals through receiving? • Have all important inputs in each production (CRS 1.2. Each diagram should include inputs (such as raw materials. PLANNING AND PRIORITISATION 2. Is there a corrective action procedure(s) 2. (CRS 1. delivery. When preparing a flow diagram. chemical groups or individual substances and verification of the process flow(s)? auxiliary material. (e. Although overall one term will account for the total balance on the system.2. sells or discards). is as follows: Input = Output + Accumulation The above equation also holds for systems with chemical reactions if the terms in the balance equation are understood to refer to total mass (i. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-3 . This modified equation can be used not only for reactive systems. is an application of the law of conservation of mass that states that a system will remain constant over time if nothing is added or removed from it. By accounting for material entering and leaving a system with this technique. then the quantities of these materials can be calculated.g. So. the conventional form of this equation is written to account for both a positive generation term (product of reaction) and a negative consumption term (the reactants used to produce the products). then the mass balance equation must be amended to allow for the generation or depletion (consumption) of each chemical species. However. but for population balances that arise in particle mechanics problems. Mass balance..1 Accurate Chemical Inventory Using Mass Balance The concept of mass balance can help with creating a chemical inventory.1.1 Chemicals in Process Expected CMS Deliverable: Chemical Process Control Documents While conducting your inventory.e. Inventories should be updated annually or as process changes occur. this will be negative for depletion and positive for generation.6) adjustment instructions or formulation sheets and should describe major operations and the chemicals Does the facility regularly identify the and quantities that may be required for those quantity of chemicals lost due to accidents processes. both terms are necessary.4. including processes that support balance? (CRS 1.10) Written chemical use instructions should include process control parameters and check points. poor labelling. Mass balances are used widely in engineering and environmental analyses. also called a material balance. Does the facility record quantities of Instructions can be in the form of recipe cards. It also may be of benefit to work with chemical supplier(s) to optimise recipes. PLANNING AND PRIORITISATION 2.ASSESSMENT..4. In the absence of a chemical reaction. such as cleaning equipment). the sum of all the chemical species of the system).. technical data sheets will provide information regarding process and usage. the amount of any chemical species flowing in and out will be the same. Typically. mass flows can be identified which may have been previously unknown or difficult to measure..1. process chemical products used for each work order/production order? (CRS 1. in the absence of a chemical reaction. spillages. Input + Generation = Output + Accumulation + Consumption A helpful understanding of the above equation may be to confirm theoretical mass balance equations against the effluent discharge and sludge analysis from ZDHC Audit Questions all the processes.1.1. Sometimes one term in this equation is used to account for chemical reactions.1. accidental mixtures)? (CRS 1. The equation provided below simplifies to earlier equation when the generation term is zero. 2. chemicals that the organisation re-uses. If this is not the case. Does the facility calculate the amount of They may assist you in optimising usage of chemicals in chemicals used in its facility by mass your process(es).g. Mathematically the mass balance for a system. instructions and processes. if the amount of a material that enters a series of processes is recorded and accounted for in the process pathways. Intermediate chemicals created during production do not have to be captured. if this balance equation is to be applied to an individual species and then the entire process.6) production processes (e. such as chemicals used for cleaning equipment between run changeovers (i. ZDHC Audit Questions Written instructions for the proper use of a chemical should be available where chemicals are used. Work with your chemical suppliers. this gives rise to an equation for each species present in the system.e. create a list of chemicals used both in production processes and to support production processes. ASSESSMENT.1. The ZDHC MRSL is accessible at the ZDHC Roadmap to Zero web site. MRSL limits are designed to eliminate the possibility of intentional use of listed substances. Your facility may have several customer MRSLs and RSLs. Many companies have Health. The MRSL addresses hazardous substances knowledge of volatile organic chemicals potentially used and discharged into the environment (VOCs)? (CRS 1.1. air. The MRSL establishes acceptable concentration limits for substances in chemical formulations used within manufacturing facilities.g. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-4 ..1. water) released from manufacturing processes.1) communicated via a MRSL for the apparel and footwear Is the facility able to demonstrate industry. For example. Safety and Environment staff that can help determine chemical waste stream regulatory requirements. Understanding the processes and chemical reactions taking place also will aid in establishing best practices for disposal.3 Chemicals as Discharge Expected CMS Deliverable: Chemical Inventory with Hazardous Identification There are many environmental regulations designed to protect human health and the environment by placing limits on the quantity and chemical make-up of waste streams (e.4. A typical RSL sets concentration limits for substances in materials or finished products to comply with product regulation and safety standards. 2. one statute places restrictions on how hazardous waste from industry is stored. the industry has also established RSL limits for finished products. Your team should harmonise these lists into one (1) factory MRSL and RSL using the most stringent standard of those available. local Source: GIZ. It is important to understand that chemicals discharged from the facility can impact the health and safety of employees. The MRSL is a list of chemical substances banned from intentional use in facilities that process textile materials and trim parts in apparel and footwear.12) during manufacturing and related processes.1) products. 2014 residents and our eco-systems. PLANNING AND PRIORITISATION 2. Additionally.1.4. transported and treated. The basic chemical inventory can serve to quickly identify chemicals which will need special handling and disposal. not just those substances that could be present in finished Does the facility require its suppliers to follow a MRSL/RSL? (CRC 1. These are typically used at the facility? (CRS 1. This harmonised list should be communicated and distributed to all chemical suppliers to ensure that the chemicals supplied meet all the facility needs to operate more safely and in conformance with regulations.1. The MRSL establishes concentration limits for substances in chemical formulations used within manufacturing facilities.2 Chemicals in Final Products Expected CMS Deliverable: Factory MRSL and RSL ZDHC Audit Questions in addition to a compliant chemical inventory to the MRSL and RSL Is there a policy for monitoring and controlling banned and restricted Final products must conform to industry and substances that is applied to all chemicals government regulations. for example. Assign the initial regulatory identification to a specific position(s) or team. Does the facility have a system of tracking changes in laws and regulations governing 4.ASSESSMENT. Source: GIZ. 1. Assign the ongoing regulatory monitoring and ZDHC Audit Questions applicability determinations to a specific position(s) or team.1. chemical (e. Where it is Generated and How it Will be Disposed Optimised processes will still result in waste generation from. as defined by the ZDHC Group.1. 3. such as an approved chemical Permits list.2) Establish. State the applicable regulatory jurisdictions.1 Monitoring Regulations and management.1. 2. For details on which chemicals cannot simply be discharged to the environment. PLANNING AND PRIORITISATION 2. document and implement a process for Does the facility have programmes in place identifying and monitoring regulations applicable to to phase out the intentional use of the 11 chemical management permits. of the permits required for their facility? The process should result in regulatory monitoring and (EPP 1. safe Expected CMS Deliverables: Regulatory Monitoring chemical handling procedures or chemical SOP and Legal Requirement Permits Inventory disposal? (CRS 1.2)I legal inventory (regulations and permits) standard operating procedures (SOPs) that are updated at least annually.1) constraints or operational limits are being Is there a process for monitoring the validity approached.4 Chemical Waste Expected CMS Deliverable: Factory Plan for How and Where to Safely Store Chemical Waste.1.1. hazardous waste and recycled wastes? (CRR 1. chemical classification system. consult the SDS for each compound. This waste may not be able to be discharged to air. with clear target dates? identifying and monitoring regulations applicable to (CRC 1. storage and disposal of all regulations and permits necessary to operate wastes such as chemical. country). state/province.2) chemical management should: Are permits required for the collection. The process for priority chemical groups. production runs and spent cleaning liquids.2 Regulatory Assessment ZDHC Audit Questions Are there SOPs that cover chemical 2. water or soil but needs to be collected onsite and disposed of as chemical waste in accordance with relevant rules and regulations.4. city.3) 2.2.1. Describe how management will be informed of environmental management and reporting significant regulatory changes and/or when permit to management? (EPP 1..g. transportation. 2014 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-5 . Identify a representative from all departments that purchase chemicals. 4. 3. Review Current Purchasing Procedures Identify how chemical purchasing is currently done within each department.S.5) Practices Does the facility have procedures in place to comply with Registration.1) reviewing regulations and verifying compliance during In the past 3 years. To reduce costs. ZDHC MRSL and brand MRSL and RSL requirements prior to the purchase of chemicals will help your organisation reduce hazardous chemical storage.2 Verification of Compliance ZDHC Audit Questions Expected CMS Deliverable: Senior Management Is there a process that verifies that all Compliance Report and Internal Audit chemicals used in manufacturing the (CMS Element 4.3 Procurement/Supplier Safety Directive (GPSD)? (CRR 1.1.ASSESSMENT.2) conducted and the compliance results. Does your facility have a purchasing and disposal policy Authorization and Restriction of Chemicals for chemicals? Do you know what you can and cannot (REACH) regulations? (CRR 1. chemicals could be purchased at the facility level. The goal of a purchasing policy is to reduce the risk. 2. handling and use. has the facility received implementation and maintenance of the CMS. Documents and records environmental legislation or regulation? must be maintained that indicate how verification was (CRR 1. These If the facility has U. or EU customers. liability and cost to workers and staff by eliminating the purchase of unnecessary hazardous products. This representative must have the requisite skills and authority to review their department’s purchase requests. Steps to Developing a Chemical Purchasing Policy 1.1. document and implement a process for requirements? (CRR 1.6) order? Are there any guidelines on accepting chemical donations? Creating an approved chemical list and a tracking system can assist with purchasing decisions and help control future disposal costs.2. This allows greater purchasing power than purchases made by individual departments.1. Careful consideration of the legal. Evaluation. individual buildings and complexes with multiple buildings.1. For example. Identify Department Representatives to Participate in the Review Process This group will participate in the development and implementation of the purchasing policy and purchase review criteria.2. Assess Chemical Inventory System If there is no existing chemical inventory system in the facility. PLANNING AND PRIORITISATION 2.2) product(s) meet applicable permit Develop. is a documents and records should be maintained according process in place to comply with the USA to local regulations or a minimum of 3 years. Identify a Purchasing Coordinator Ideally this should be a designated administrator or someone from the business office who can oversee budget issues and approve purchases across all departments and who has an understanding of chemical issues. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-6 . This will enable departments to screen purchase orders against what already is in stock across the facility. safety. an official notice or prosecution for Compliance verification could be part of the audit non-compliance with respect to process in CMS Element 4. Explore how to integrate the chemical purchase request review within the existing purchasing system. tracking chemical storage may indicate that there are excess chemicals in another facility that would allow you to avoid additional purchases. initiate the development of a facility-wide system. Consumer Product Safety Improvement Act (CPSIA) legislation and EU General Product 2. Things that should be considered: 1. staff and other personnel (CMD 2.ASSESSMENT.4) 4.1.1.1.1. supplier name. its purchase should be Do large quantity deliveries have additional discouraged. matching supplier documentation and quantity tracking? Before ordering chemicals. subcontracted activities? (CRP 1.3) provisions for a chemical. first out policy to keep Does the organisation document receipt of chemicals from becoming outdated. Do not buy extra chemicals in bulk for anticipated savings. Create a policy for acceptance of appropriate labelling. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-7 . The real cost of purchase chemicals? (CRP 1. • Train personnel so that they are capable of assessing chemical hazards. Are chemicals sampled and tested when 3. ensure sharing of chemicals among common users and develop plans for leftover chemicals. tracking information.1 Chemical Purchasing Policy Considerations Expected CMS Deliverables: Chemical Purchasing Policy Tracking of chemicals in facilities is easier if there are purchasing policies in place. 2. Note expiration monitored?(CRP 1.1) chemicals should be regarded as the initial purchase Are chemicals purchased against a price plus any ultimate disposal costs.9) should: • Make sure the chemical is on the facility system’s list of approved chemicals and check against any MRSL/RSL in effect in the facility. Use older stock first: Rotate chemical stocks to Are subcontracted activities identified and avoid expiration of their shelf life. receipt donations. Tighten purchasing controls: Institute procedures that are designed to restrict hazardous chemical purchases to those needed for current business or research programmes and in minimal amounts for short term use.1. • Train personnel to be sufficiently knowledgeable in recognising requests from others for non- essential chemicals. Avoid chemical donations: Do not accept donated Has the organisation documented and chemicals or free samples unless they meet a implemented procedures to ensure that the specific need. A centralised purchasing system can be used to monitor requests for chemicals.2) often offset savings from buying in quantity. Consider disposal cost at time of purchase: Many ZDHC Audit Questions chemicals deteriorate with time. Disposal costs specification? (CRP 1. This helps prevent contractors/subcontractors covering waste due to surplus or shelf-life expiration.3.1. the disposal cost may be 20 to 50 Is there a procedure on how to select and times the original purchase price.7) dates.1. Reduce expired stock: Negotiate expiration dates of chemicals with suppliers based on their intended Is there a written contract or agreement established. purchased chemicals? (CMD 2. Try to use non-hazardous chemicals or controls to assure chemical purity and those that are suitable for reuse. Consider handling and disposal requirements: If the received for approval against specifications? facility does not have adequate storage and safety (CRP 1. Use a first in. mutually confirmed and use. implement policies such as staggered deliveries. Order reagents in amounts needed and stock controlled between the factory and its smaller containers of chemicals.5) 6. Chemicals should be ordered in quantities consistent with the rate of use.1. These can become a future waste identification of raw chemicals includes disposal problem.6) 5. PLANNING AND PRIORITISATION 2. freedom from contamination/substitution prior to off-loading to storage? (CRP 1. • Develop a current inventory of existing chemicals. When they must be removed. Does the facility actively monitor RSL/REACH supplier certificates and track against their inventory? (CRG 1. For urgent the relevant retailers' or the facility's own RSL and/or MRSL? (CRP 1. These general guidelines can be modified for chemicals used in the maintenance department. PLANNING AND PRIORITISATION • For each chemical used. hazards. The requestor also should consider the: • Relative hazard level of the chemical • Research value of using the chemical • Staff experience or lack of experience in using the substance • Degree to which the laboratory/factory is equipped for safe use of the chemical A requestor who wishes to use a substance not on the appropriate list should seek the permission of the designated chemical administrative supervisor by submitting a written request. A copy of the proposed trial/pilot or research exercise 2.1) number and address.2 Identify Chemical suppliers Does the facility have signed and dated Expected CMS Deliverable: Chemical Inventory with declarations from their dye and chemical Chemical Suppliers suppliers confirming that the formulations Identify and document suppliers for each of the supplied to the facility are compliant with chemicals listed in the Chemical Inventory. transport and safe disposal? − Can proper storage be provided for the chemical? − Are the facilities appropriate for the use of this chemical? − Will the chemical or its end products require disposal as hazardous waste? − Is appropriate PPE available for safe use of the chemical or its end product? − Have persons who will handle and use the chemical been trained in handling these chemicals? Are they aware of the hazards? Before making a request to use a chemical not on the facility’s system approved list or if there is doubt about its value.5) technical support or other emergencies. The request should include the following: 1. ask the following questions: − Can the supplier provide a Safety Data Sheet (SDS) in the local language containing the relevant sections on proper handling. Use of the substance is necessary b. Adequate safeguards are in place to ensure proper use of the substance e. phone follow a MRSL/RSL? (CRC 1. office area and other areas of the facility. process or concept c. Workers are instructed in the proper handling of the substance 3.1. The trial/pilot project using the substance is a way to demonstrate an important property. Information on the extent of staff and worker exposure to the chemical to enable the supervisor to make an informed decision. Information supporting the following assertions: a. auto shop. the requestor should read and research the appropriate SDS to determine whether the chemical under consideration can be safely used with workers and the system process.1. Tables 3 and 4 in Appendix B provide tools for making chemical ordering decisions. No satisfactory substitute for the substance is readily available d. identify each supplier and document their relevant contact Does the facility require its suppliers to information such as point-of-contact name.3.1) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-8 .ASSESSMENT. Additional information can be found in Appendix A and B as well. ZDHC Audit Questions 2.1. 3. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-9 .5. from SDS. contact the supplier for their GHS classification as shown on its label and/or SDS? (CRR 1. corrosivity or toxicity. Has a chemical risk assessment of all the • To what substances are workers exposed? chemicals used on the facility been − Use the chemical inventory to consider all undertaken and available? (CRA 1. Hazardous chemicals are those that have an inherent property that can cause harm to humans or the environment and/or cause damage through fire. 2. • What activities can increase exposure risk? − Removal of a chemical from the original packaging for weighing or dispensing can increase risk.ASSESSMENT. the internet. SDSs. a specialist in your factory or the processes? (CMW 2. staff chemists and chemical suppliers.1. At a minimum.2) − Chemical information can be found on Does the facility use or produce highly packaging labels. An organisation should communicate expectations to their dye and chemical suppliers to confirm that formulations supplied to the facility are compliant with facility RSL/MRSL.2 RSL and MRSL Process (CMS Element 2. Have worker exposure routes or possible releases been identified for the facilities • What harm can the chemical cause? chemical list? (CRA 1.12) relevant information? Are hazardous chemicals categorised by ─ If not provided.1. your chemical sensitising or toxic substances during its supplier.1. preferred suppliers should be those that provide an SDS in the local language that contains all the relevant information according to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) standards (and adhere to the appropriate portions of CMS Element 2. document and implement a process for identifying and using preferred suppliers and removing suppliers from the preferred list when appropriate.1.1. When carrying out a chemical hazards risk assessment. document and implement a process for assessing the hazards and risks associated with chemicals identified in the chemical inventory and update those inventories annually. ZDHC Audit Questions a number of key questions need to be asked: Is the facility able to demonstrate • Has the local supplier provided a proper SDS with knowledge of VOCs? (CRS 1.1 Hazard and Risk Assessment Expected CMS Deliverable: Hazard and Risk Assessment Inventory Establish.5.7) internet. Hazard and risk information can be obtained from container labels.3 Supplier Approval/Removal Process Expected CMS Deliverables: SOP for Supplier Approval and Removal Establish.4 Chemical Risk Assessment 2. PLANNING AND PRIORITISATION 2.2). • What risks need to be controlled? − The risk significance may depend on the duration and frequency of exposure as well as the concentration of the substance involved.4.1) persons who may have contact or exposure. explosion. − Pouring a chemical can result in exposure by spills or splashes.4) assistance. The ZDHC MRSL can be accessed at the ZDHC web site publications page. ZDHC Audit Questions 2. Hazard statement: R-phrases from the SDS 7. RSL/MRSL: Compliant chemical. Hazard type: Physical (flammability. the organisation should identify Do maintenance shops. Appendix F (Overview of a Risk Assessment Process) and Appendix G (Risk Assessment Checklist) at this web site also are useful hazard and risk management tools. document and implement a process for responsible manner and in accordance with identifying and controlling the potential environmental any applicable legal/regulatory impacts from use of their chemical inventory. Chemical names: From inventory created in CMS Element 2.1. Hazard Prioritisation: Prioritisation and ranking of the overall risks of the chemicals.12) for discharges and how to monitor the control mechanisms. See Appendix D for Risk Assessment Template example All work areas must at all times maintain an inventory of the hazardous chemicals according to the following guidelines: • When new hazardous chemicals are acquired. storage and printing 4. eco-toxicity) 8. • When hazardous chemicals are expended or disposed.14) of the below areas.1. • The inventory must be readily available to anyone entering the work area. Environmental media that could be impacted are: • Air • Noise and nuisance • Soil • Waste and sludge • Groundwater • Wastewater JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-10 . explosivity). • The inventory must be examined and updated periodically (at least annually). Safe Work Australia maintains a document on their web site called Managing Risks of Hazardous Chemicals in the Workplace Code of Practice. toxic to reproduction) and environmental (bioaccumulative. For each requirements? (CMD 2. Yes or No 6. where wastes other ancillary spaces practice proper or discharges occur. Amount per usage/batch/process: Estimate of how much of the chemical is used at one time 10. yes or no 9. maintenance. PLANNING AND PRIORITISATION The SDS is the first place to look for hazardous and risk exposure information. appropriate control mechanisms chemical waste disposal? (CMW 2. laboratory and environmental roles and responsibilities.1 a. The organisation also should set goals to reduce chemical wastes or discharges. they must be removed from the inventory or a single line shall be drawn through them. SDS: Availability of SDS. the facility should create a hazard and risk assessment inventory that includes: 1. discharge and other relevant information 3. Amount lost to the environment: Use of information developed from mass balance and waste records. Supplier: Emergency contact information 5. persistency. Common b. CAS number 2. final product. Process: Production.4. they must promptly be added to the inventory.2 Environmental Has the organisation established procedures Expected CMS Deliverable: Process/Plan for to ensure that all wastes are collected and Reducing Environmental Impacts handled in a timely and environmentally Establish.ASSESSMENT. laboratory. estimate of the quantities of chemicals lost to the environment 11. Using information from any of the above sources. Area: Examples include dye kitchen. health (carcinogenicity. This document includes good reference materials. hazards identified? (CMW 2. used and Does the facility have and maintain PPE.3 Health and Safety Expected CMS Deliverable: Process for Reducing Health and Safety Impacts (such as Action Plans) Expected CMS Deliverable: JSA with PPE for Chemical Handling/Exposure Establish. develop areas in which authorised personnel are monitoring steps for the control mechanisms and set allowed to enter? (CMW 2. Contact the chemical supplier for all appropriate information (CMS Element 2.4) should be bottles or stations. document and implement a process for monitoring and setting goals to reduce their environmental impact.1. facility and environment. This information can be found in the SDS for each chemical. document and implement a process for identifying and controlling the potential health and ZDHC Audit Questions safety impact from chemicals stored.3.g. If an SDS is not currently available or does not contain information on health and safety.5) goals to reduce the potential for health and safety impacts. laboratory/factory eye wash previously developed (Section 2. including the use of PPE (e.1.4) An organisation should identify health and safety roles Has management established procedures and responsibilities and appropriate control that clearly define and communicate the mechanisms to protect health and safety. See Appendix E for example environmental standards from the American Apparel and Footwear Association (AAFA). and more that are appropriate for the chemical supplemented with this information.4. The chemical inventory safety showers. the chemical should not be used.3). fire extinguishers. discarded at your site. Creating a Waste Action Plan An action plan for managing chemical waste should contain the following: • Names of persons in charge • Waste generation data that must be collected • Investment (capital) and running cost associated with waste • Measures for reducing waste • Timeframe to reduce waste • Expected environmental benefits/results (for monitoring and later evaluation) • How to train and qualify personnel involved in handling hazardous waste about: − Presence of the specific materials − Potential physical and health hazards associated with these materials − Proper procedures for handling and use of these materials.. gloves and protective goggles) − Location and appropriate use of the chemical SDSs Procedures to be followed in the event of an emergency 2. PLANNING AND PRIORITISATION An organisation also should establish.1.ASSESSMENT. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-11 . Chemicals without a proper SDS pose a risk to the workers. establish.1.ASSESSMENT.1. Job Hazard Analysis (JHA) and Task Hazard Analysis (THA). An organisation also should consistently maintain records of the chemical inventory and material inventory balances and update the organisation’s hazard and risk assessment inventory (CMS Element 2. 2.10) 2. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-12 . the work group must review all of the steps thoroughly to ensure that they are controlling all of the hazards for this job. The JSA should be created by the work group performing the task.1. Job step 2.5 Chemicals and Processes of Concern 2.4.13) determine where there are potential chemical knowledge and safety gaps and chemical losses not accounted for in the mass balance.1) accordingly. A JSA is also known as an Activity Hazard Analysis (AHA). exposed parts of the body after work is how) completed • Ensure proper PPE is worn for as needed • Prevent contaminated items from being • Provide storage. The work group should initially breakdown the task into its component steps and then identify hazards for each step. PLANNING AND PRIORITISATION Ensure Good Personal Hygiene Properly Use and Maintain PPE • Provide suitable eating and smoking areas • Select the correct type (for the chemical • Provide washing facilities near the work in question) and fit of PPE. Material Balances and Material Does the facility regularly identify the Incident Report/Log quantity of chemicals lost due to accidents Using the chemical inventory chemical flow diagram(s) (e.1 and CMS Element mixtures)? (CRS 1.3. accidental developed in CMS Element 2. where. considering areas where skin exposure may occur potential exposure (use guidance from • Advise workers to remove splashes/spills the SDS) on skin immediately • Provide clear instruction to workers on • Advise workers to thoroughly wash the proper use of PPE (when. Controls A hazard is any factor that can cause damage to personnel. it can be expedient to review a prepared JSA that has been performed before. document and implement a process for Is there a documented procedure to deal creating chemical inventory and material balances to with spills and leaks? (CMD 2.g.. If available. poor labelling. The GIZ Practical Chemical Management Toolkit Company Handbook Module 1 includes examples on how to identify these gaps and losses. The aim of a JSA is prevention of personal injury to a person or their colleagues and workplace.1. Some companies include loss of production or downtime in the definition as well. Typical three column headings include: 1. A JSA is usually completed on a form with the most common configuration a three column table (although many companies include additional columns). A control is any process in place for controlling a hazard. Hazard 3. Controls should be recorded in column three of the JSA for each hazard identified. cleaning and moved around the facility maintenance of PPE • Remove and wash separately any • Plan and budget for PPE replacement at contaminated item of work clothing after recommended intervals using chemicals A Job Safety Analysis (JSA) is one of the risk assessment tools used to identify and control workplace hazards. spillages. When conducting this type of JSA.5. property or the environment.1 Identify Gaps and Losses in Current Processes Expected CMS Deliverable: Chemical Inventory ZDHC Audit Questions Reconciliation. 5.1. PLANNING AND PRIORITISATION 2.2.13) 2.2) RSLs.1) verification was conducted and the results obtained.1.2 RSL and MRSL Process 2.6) MRSL or chemical purchasing policy or should be removed from the approved supplier list (CMS Element 2.1 ) Establish.3 Integration with Contracts of Suppliers Expected CMS Deliverable: Inventory of Chemical Suppliers (CMS Element 2.3.ASSESSMENT.2. an organisation should annually review ZDHC MRSL.4. instead it should be properly disposed of according to local and regional regulations and safety information. associated with supplied to the facility are compliant with companies to which they sell products.1. and the ZDHC the relevant retailers' or facility's own RSLs MRSL.6.4 Business Process Compliance with Contracts Expected CMS Deliverable: Business Process Hazard and Risk Assessment Inventory (CMS Element 2.1.5.5. Contracts implemented procedures for situations in with suppliers should include language that requires which chemical(s) can be accepted on the compliance with these elements. RSL and MRSL.6. as defined by the At a minimum. 2.2. document and implement a process to encourage suppliers to use the organisation’s MRSL compliant formulation list (CMS Element 2. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-13 .1 ) Establish.2 RSL and MRSL Update and ZDHC Audit Questions Maintenance Does the facility have programmes in place Expected CMS Deliverable: Hazard and Risk to phase out the intentional use of the 11 Assessment Inventory (CMS Element 2. document and implement a process for suppliers confirming that formulations verifying compliance with RSLs.4.1). Maintain records of suppliers that are willing to use your organisation’s MRSL compliant formulation list (CMS Element 2.5) purchase and audit process in CMS Element 4.1 ) priority chemical groups. and the ZDHC MRSL to determine if the Does the facility have a control hazard and risk assessment inventory needs to be policy/procedure for the use of durable updated. Compliance verification can be part of the and/or MRSLs? (CRP 1. Suppliers who fail to basis of the supplier's certificate? meet the standards laid out in the organisational RSL. Does the facility require its suppliers to Maintain documents and records indicating how the follow a MRSL/RSL? (CRC 1. associated with the companies to which they sell products.3. with clear target dates? (CRC 1. 2. document and implement a process for ZDHC Audit Questions monitoring supplier compliance with the organisation’s Has the organisation documented and chemical purchasing policy. brand MRSL or brand RSL should not be inventory? (CRG 1.1. This assessment can be combined with the water repellent finishes based on review in CMS Element 2.2.1 Verification of Compliance Expected CMS Deliverable: Chemical Inventory ZDHC Audit Questions with Column Identifying ZDHC MRSL Compliant Formulations Does the facility have signed and dated declarations from dye and chemical Establish.1). (CMD 2.1) used.1).5.4. fluorinated chemistry? (CRC 1.5.2.1. An Does the facility actively monitor RSL/REACH in-stock chemical found to be non-compliant to the supplier certificates and track against their ZDHC MRSL. ASSESSMENT, PLANNING AND PRIORITISATION 2.5.2.5 Going Beyond Regulatory Expected CMS Deliverable: Target Goals and ZDHC Audit Questions Metrics Does the facility have a hazardous chemical Establish, document and implement a process that goes reduction plan beyond the 11 priority beyond legal compliance. Document best practices chemical groups with clearly set targets? regarding the use of greener materials, chemistry or (CRG 1.3.1) procedures that assess leading green practices and Does the facility use a process to examine, innovations. Also, document training classes, categorise and rank chemicals/formulations conversations with suppliers or customers, conference to be purchased against impact(s) such as attendance, research and other relevant activities. human or environmental risk? (CRG 1.3.5) 2.6 Performance Goals and Action Plans 2.6.1 MRSL Compliant Formulations Expected CMS Deliverable: Chemical Inventory with MRSL Compliant Formulations ZDHC Audit Questions Expected CMS Deliverable: Phase Out Target Is the facility using suppliers’ ZDHC MRSL Dates and Action Plan for 1 1 Priority Chemical compliant formulations to purchase Groups chemicals? (CRG 1.1.2) Create (and maintain a chemical inventory list which references MRSL compliant formulations and their suppliers and update this list annually. Set an annual chemical inventory goal for the percentage of formulations that are MRSL compliant and work towards that goal through the development of action plans, assigned responsibilities, timeframes for actions and an estimate of resource needs (e.g., financial, human). This list of substances should represent chemicals that score well on the hazard and risk assessment inventory (CMS Element 2.4.1) and that have low to near zero discharges to the environment. The ZDHC Group has set a high priority for eliminating or substituting hazardous chemicals in our members’ products and their manufacture by 2020. Develop a process to phase out the intentional use of ZDHC Audit Questions priority hazardous chemicals using clear target dates. Does the facility have programmes in place A chemical inventory with a hazard assessment and to phase out the intentional use of the 11 MRSL compliant formulations is a great starting point priority chemical groups, as defined by the for review and goal setting. Discussions and action plans ZDHC Group, with clear target dates? should be formed with the chemical supplier to ensure (CRC 1.1.2) a successful target completion date without impacting the facility’s process efficiency and product performance. For guidance on the industry’s best management practices, regarding chemical management, see additional CMS Resources in Section 6. 2.6.2 Alternatives Assessment Expected CMS Deliverable: Best Practice Alternative Assessment Establish, document and implement a process for assessing alternatives for chemicals that are found to have significant hazards, risks or discharges and set an annual goal for the number of alternatives it will assess. The process for assessing alternatives should include the development of action plans, assigned responsibilities, timeframes for actions and an estimate of resource needs (e.g., financial, human) to conduct the assessment. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-14 SECTION 3 Chemicals Management 3.1 Organisational Structure 3.1.1 Roles and Responsibilities Expected CMS Deliverable: CMS Organisational ZDHC Audit Questions Chart Does the factory have an individual or team responsible for chemical management? For a successful CMS, senior leadership must commit (CMO 2.1.1) and ensure (see Section 1) the availability of resources essential to establish, implement, maintain and improve Does the facility have procedures to ensure CMS and customer satisfaction. Resources include that the approval for use of purchased human resources and specialised skills, organisational chemicals is carried out by the authorised personnel responsible for quality? infrastructure, technology and financial resources. (CMD 2.1.11) Incorporate the following roles and responsibilities into a CMS. Each role should include a named point of contact and that contact name should be communicated to applicable supply chain partners. The CMS organisational chart and roles and responsibility should be updated annually and as the organisation changes. Role Responsibility Reports to senior leadership CMS Oversight Responsible for day-to-day management of CMS Responsible for tracking progress on key performance indicators (KPIs) and goals Systematically monitors applicable regulations on a regular schedule for each applicable Regulatory Compliance legal jurisdiction Identifies new or changing compliance requirements Responsible for RSL and MRSL compliance and communication with supply chain RSL and MRSL Oversight partners Responsible for process and product chemical knowledge Chemical Application and Management Responsible for knowing the contact names of individuals at supply chain partner organisations with the same duties Responsible for activities related to chemical hazard assessment Hazard Assessment and Risk Management Responsible for knowing the contact names of individuals at supply chain partner organisations with the same duties Responsible for activities related to safer alternative assessment and communicating Alternatives Assessment information to supply chain partners Community of Practice and Acts as organisation’s representative for Chemical Management Community of Practice Sustainable Chemistry Responsible for chemicals management and sustainable chemistry metrics JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-1 CHEMICALS MANAGEMENT 3.1.2 Communication Expected CMS Deliverable: Safety Communication/ ZDHC Audit Questions Hazardous Chemical Placards/Posted PPE Does the facility have a current (chemical) Warnings SDS for each chemical, provided in the local language and placed in chemical handling Establish, document and implement a process for and storage areas? (CMW 2.1.2) communicating about the CMS amongst all of levels of the organisation. An organisation also should establish, Has management established procedures document and implement a process for receiving and that clearly define and communicate the areas in which authorised personnel are responding to external stakeholders, including allowed to enter? (Primary focus is documenting communications. chemicals.) (CMW 2.1.5) 3.2 Training Is there a chemical emergency response plan in place and practiced on a planned To achieve a goal of zero discharge of hazardous schedule? (CME 2.1.1) chemicals, organisations should: 1. Ensure that personnel are competent through appropriate education, training or experience. Train employees about: a. Preventive environmental and work safety practices b. Saving resources c. Proper use of goggles and face shields to avoid eye and skin contact d. Use of protective clothing to avoid skin contact with chemicals e. Selecting suitable gloves and removing gloves to avoid skin contact with chemicals f. Proper hand washing 2. Retain associated chemical records ZDHC Audit Questions 3. Establish, document and implement a process to Are training records maintained to conduct and track training demonstrate that facility personnel handling chemicals have the required education, 4. Assess training effectiveness with a quiz or by training and skills to perform their assigned monitoring an appropriate activity to demonstrate responsibilities and activities? (CMT 2.1.1) learning 5. Ensure that personnel are aware of the relevance and importance of their activities and how they contribute to achieving chemical objectives 3.2.1 Management Establish, document and implement a process for informing top management of their roles in managing chemicals. Include information about the hazards and risks associated with the existing chemical inventory, the improvement goals of the organisation and the human and financial resource needs for CMS implementation. 3.2.2 Regulatory Establish, document and implement a training process for making appropriate staff knowledgeable about the legal requirements (CMS Element 2.2) associated with chemicals in the organisation’s inventory (CMS Element 2.1.3). 3.2.3 Work Practices Establish, document and implement a process for making chemical-handling staff aware of appropriate work practices. At a minimum, appropriate staff should be trained on the SOPs created to fulfil CMS Element 3.5. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-2 3. This can be used to develop a CMS record-keeping procedure. Records required by the CMS are a special type of document and require strict control procedures. determined by the storage and conditions are appropriate for organisation to be necessary to ensure the effective the chemical hazard class? (CMD 2.1) • Documented procedures and records required by Does the organisation have a written this manual chemical safe handling plan to ensure that • Documents.1. supplier certificates of compliance and chemical spill logs. ZDHC materials can be found at http://www.3 Document Development Expected CMS Deliverable: CMS Manual ZDHC Audit Questions Create a CMS Manual that describes the main elements Have procedures documenting the proper of the CMS and references related documents.7) planning. JSA. determined by the organisation to be necessary for the planning and operation of the CMS. Establish a documented record keeping procedure to: 1. Review.com. updated and re-approved as needed Examples of documentation include SDS. Ensure that the most up to date versions of documents are available at the appropriate points of use 5.2) • Documents are approved for adequacy prior to use Are records available and retained which • Correct versions are available at points of use and show chemical usage and traceability within versions are tracked the factory? (CMD 2.roadmaptozero. retrieval. storage and disposal of manual should include: chemicals and hazardous chemicals • Documented statements of a chemical policy and according to the SDS/technical sheets been written and implemented at the facility? chemical objectives (CMD 2. Approve documents for adequacy prior to issue 2.4 ZDHC Training Expected CMS Deliverables: Training Matrix Outlining Training Needs. use. An ISO-certified facility may have an existing system for control of records and record keeping.1. Ensure that changes and the current revision status of documents are identified 4. PPE safety. Ensure that documents of external origin.3) • Documents are legible.CHEMICALS MANAGEMENT 3. retention and disposal. RSL.2. update and re-approve documents 3. operation and control of its processes Review the CMS manual annually and update as needed. Training Content and a Roster of Training Attendees Establish. Prevent the unintended use of obsolete documents and apply suitable identification to the files JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-3 . The CMS handling. 3.1. including records. The document control process should ensure that: chemical inventory records for at least one year? (CMD 2. Ensure that documents are legible and readily identifiable 6.1.4 Document and Record Control Expected CMS Deliverable: Procedure to Control Documents and Records ZDHC Audit Questions Establish. document and implement a process for Does the facility have a document retention controlling documents and records associated with the procedure that requires retention of key CMS. document and implement a process for appropriate staff to participate in the ZDHC Group’s sponsored training on chemicals management. the ZDHC MRSL and future training modules to be developed. are identified and their distribution controlled 7. The record control process should address record protection. MRSL. 1. chemical classification. Specifically. ZDHC Audit Questions protective clothing and other required PPE (specific Does the facility have procedures in place to for the types of chemicals in use) to protect workers document the proper handling.5 Chemical Management Work Practices Establish. storage areas? (CMW 2.2) Expected CMS Deliverable: Procedure to Control Exposure Do personnel have access to and comply with the documents needed to do their A control approach. an ZDHC Audit Questions organisation must establish documented SOPs for each Are there SOPs that cover chemical of the topics discussed in this section.1. though a necessary action. chemical disposal? (CRS 1. storage • Maintenance and replacement of equipment so and disposal of chemicals and hazardous chemicals according to the SDS/technical that control measures remain effective sheets been written and implemented at Safe Work Australia maintains a good reference the facility? (CMD 2.2) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-4 . use. local exhaust ventilation [LEV] as an integrated part of the containment and differential pressure). document and implement a processes for chemical management work practices. Substance releases should/can be prevented through containment systems. The best practice for controlling chemical exposure is through the use of technical protection measures. PPE can only be part. control strategy or control level of work and related to their responsibilities? exposure is the sum of the control measures required to (Primary Focus – Chemicals) (CMT 2.CHEMICALS MANAGEMENT 3. • A chemical with a high hazard level should be controlled by a higher protection level than the level needed for a non-hazardous chemical.g. Control examples: • A highly volatile organic solvent requires a higher precaution level than a water-based chemical product that doesn’t contain volatile components. such as suitable mechanical barriers (e. The intent of PPE use should be protection during accidents and incidents that may occur despite appropriate management systems and operational procedures.5. SDS for each chemical that is available in the Chapter 4 and Appendix J also are applicable to local language for chemical handling and controlling chemical risks. of a safety concept.2) reduce risk from a specific chemical.1. enclosures) and air dynamic barriers (e. Exposure control measures for skin contact include preventive activities such as: • General occupational controls to prevent and reduce release of dust and splashes • Selection and use of personal protective gloves. safe chemical 3.. management such as an approved chemical list.g. The physico-chemical properties of a substance are another factor to consider when determining the right design to achieve the necessary control precautions and process conditions.1 Exposure Control Measures handling.1) document on their web site called Managing Risks of Does the facility have a current (chemical) Hazardous Chemicals in the Workplace Code of Practice..1. • Specify the flashpoint (the lowest temperature at which a chemical releases flammable vapour).1) spills. which gives clues about the possible effects on water.1) • Indicate appropriate security precautions and Does the facility have chemical hazard needed controls. Does the organisation have a written.1.1. (CAC 3. • Specify the hazard level. soil and human health. An SDS for every chemical substance used in your operation should be kept in a central location and also at the point of use so that it is readily available for consultation by workers and supervisors.CHEMICALS MANAGEMENT 3.g. signage and safe handling equipment available in the facility areas where • Provide written emergency procedures in case of exposure may occur? (CD 4. preferred chemicals. the more hazardous the chemical is as a source of fuel for fire or explosion. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-5 . fire or explosion. are the chemicals of construction suppliers should be those that provide a SDS in the local appropriate to prevent cross language and that information should contain all contamination? (CRS 1.1. properties and quality of the chemical hazard class? (CMD 2. ventilation). The lower the boiling point.1.1) Does the organisation have a written • Provide information about proper storage and chemical change management process? handling (e.1. including PPE. • Specify the boiling point. which is used to determine volatility. The lower the flashpoint.7) the chemical that influences the end product. At a minimum. Does the facility have appropriate controls • Allow determination of chemical compatibility for in place for batch/continuous chemical proper mixing. The information provided on SDSs serve as the basis for providing oral and written instructions to workers in the safe use of chemicals.5. The ZDHC Audit Questions sheets provide valuable information that you can use to optimise chemical use and improve workplace health If portable equipment and utensils are not dedicated to specific chemicals or classes of and safety standards.7) relevant GHS standards. • Specify the vapour pressure which also is used to determine volatility. the higher the volatility.. • Indicate steps for first aid. SDSs: chemical safe handling plan to ensure that storage and conditions are appropriate for • Indicate characteristics. processes? (CMW 2.2 Safety Data Sheet Management Expected CMS Deliverable: Procedure to Make SDSs Readily Available for Every Chemical SDSs can be obtained from your chemical suppliers. as outlined in the SDS.3 Chemical Handling ZDHC Audit Questions Expected CMS Deliverable: Has the facility identified and documented any types of Procedures for Safe Chemical installation/processes that have a potential to leak and cause Handling significant environmental degradation (e. includes useful checklists and Has the organisation documented and implemented a guidance on the storage and handling of procedure to re-evaluate chemicals after a defined period of chemicals. During the transport of a chemical.1. of adequate width.. Checklist Based on chemicals are stored and an emergency response plan in Best Available Techniques in the Textile place for those critical areas? (CRS 1.1. storage to determine their suitability for use? (CRS 1. Another good storage reference is the German Technical Rules for Hazardous Substances.4 Chemical Storage chemical specifications or SDS? (CMW 2.1. aboveground Procedures should be provided for storage tanks. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-6 .g.CHEMICALS MANAGEMENT 3.1. underground storage tanks. check the SDS.1.5.15) Are special storage conditions identified and followed from 3.6) Improve the storage of chemicals with Is there adequate space in and around weigh areas.1. Before transport.1. • Leak-proof equipment should be used when transporting small amounts of hazardous chemicals.3) CMS Deliverable: Procedure for Are chemicals stored in a well-ventilated space designated Chemical Storage only for this purpose? (CMW 2.5 Chemical Transportation CMS Deliverable: Procedure for Chemical Transportation and Training on Transport of a Chemical Chemicals may be transferred to or from work areas through pipelines or conveyors or by using forklift trucks. ensure the proper PPE safeguards are available in case of leakage or the unexpected spill or rupture of a container.14) Industry. The Is there secondary containment at all locations where ÖKOPOL document.10) • Separation of incompatible chemicals • Handling spillages and leaking containers • Provision for a drainage system connected to the effluent treatment plant • Adequate storage of halogenated solvents • Adequate storage of flammable liquids • Fire protection measures The ÖKOPOL document.9) • Ventilation and grounding Are flammable chemicals stored separately and securely? (CMW 2. • Containers for flammable liquids should be specially constructed with spring-located caps and flame arresters in their spouts.5.8) • Information provided in the SDS Are incompatible chemicals stored separately to ensure that • SOPs and checklists no dangerous chemical reactions can occur? (CMW 2. wastewater handling chemicals in the safest way treatment plant bulk storage)? (CRS 1. During transport the following should be considered: • Chemicals transported by forklift truck should travel on clearly marked passageways. has useful checklists and guidance on the storage and handling of chemicals. the help of: machinery and storage and appropriate environmental controls to preclude mix ups or contamination? (CMW 2. to reduce the possibility of collision and spillage. labels and replace all broken. Checklist Based on Best Available Techniques in The Textile Industry. The transfer of flammable liquids should only be conducted in well-ventilated areas with the containers earthed and bonded. trolleys or wheelbarrows. 3.1.5.13) possible. • Avoid shaking hazardous chemicals to prevent leaking due to over volatilisation. torn or incorrectly located labels. 10) Keep SDS up to date and review regularly for new Has the organisation established and implemented procedures to ensure content (at least annually).5. should be followed at all times.CHEMICALS MANAGEMENT 3. working stock prior to acceptance for use? • Read chemical labels before using. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-7 . such as laboratories.8 Personal Protective Equipment Is there an internal audit group that reviews. machinery and storage along procedures.11) manufacturer should indicate whether the substance you are using may be hazardous and pose a risk to humans or the environment through contact or accidental release. location and Are incoming chemicals segregated from point(s) of contact. for labelling compliance 3.1. CMS Deliverable: Procedure for PPE Use audits and verifies chemical hazards and The main purpose of PPE should be to protect inventory? (CAA 3. • Wash hands after handling chemicals.7 Chemical Use – Regular and Optimisation The following rules. ZDHC Audit Questions 3. ZDHC Audit Questions • Perform regular inventory audits to identify Does the facility have established procedures or alternative systems to ensure chemicals that are not being used. categorized? (CMW 2. markings.12) • Do not use food containers for chemicals and do not eat near chemicals.1.1.S. regarding use of chemicals. • Use ventilation systems to reduce chemical inhalation of dust/fumes. Best labelling practices include: • Adopting a standard labelling procedure for chemicals and waste. (CMD 2.1. permanent labels • Designating a responsible person or team for labelling and inventory control • Using tags.5. regular listing to chemical users chemicals are used? (CMD 2. risk-phrases or hazard statements are commonly used by chemical manufacturers and suppliers to indicate a chemical’s hazard risk.5. using colourfast. PPE includes the following: Have boiler and effluent treatment • Eyes: Wear appropriate protective eyeglasses or chemicals been inventoried and chemical safety goggles as described by the U. • Use a first-in/first-out policy. • Do not smoke near chemical storage areas.1. chemicals used are from oldest to newest • Do not mix unknown chemicals. Internationally standardised labels (like GHS).8) for each chemical. receipt date? (CMD 2.1.1.1) employees should an accident or incident occur despite Is there adequate space in and around appropriate management systems and operational weigh areas.15) Occupational Safety and Health Administration’s (OSHA’s) eye and face protection regulations in 29CFR 1910. with appropriate environmental controls to preclude mix ups or contamination? Information on appropriate PPE can be found in the SDS (CMW 2.133 or European Standard EN166.6 Chemical Labelling CMS Deliverable: Procedure for Chemical Labelling ZDHC Audit Questions Chemical containers and packaging should allow for Are intermediate and/or chemical transfer containers properly labelled? clear identification of chemical substances. workshops and waste effluent treatment. A (CMW 2. symbols. that only quality-control approved • Provide a simple. bar codes or some other system to establish tracking of chemicals • Reviewing all areas of the facility.8) that includes available chemical stocks. nih. 3. • Ask employees to determine and record which chemical containers are: ─ Unlabelled ─ In poor condition ─ Expired ─ Not essential • Chemicals that meet one of these conditions are candidates for disposal.9 Laboratory Practices CMS Deliverable: Procedure for Safe Work in the Laboratory Develop safe laboratory practices procedures and make them accessible. Many resources for developing safe lab programmes are available. National Institute for Occupational Safety and Health (NIOSH) or European Standard EN149 approved respirator when one is necessary.134 or European Standard EN149. • Clothing: Wear appropriate protective clothing to prevent skin exposure.) Location 4/2/08 1-Propanol 71-23-8 100% N/A 2 x 500 Poly 750 mL Flammable JS mL cabinet Room 202 6/5/08 Aluminium 7429-90-5 100% N/A 500 g Glass 200 g Chemical Storage MA Room 110 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-8 . Always use the U.aspx.ors. including a checklist at http://www. Amount Storage Date/ Initial Name Date container size Type (est. • Respirators: Follow the OSHA respirator regulations found in 29CFR 1910.5.od.S. then there are four activities to consider: ─ Create a list of chemicals for disposal (Disposal List) ─ Identify a qualified professional to assist in the chemical cleanout and disposal process ─ Prepare for the chemical cleanout and disposal ─ Take steps to reduce the need for future chemical cleanouts (for example. inventory management) EXAMPLE: Completed Disposal List Storage Chemical CAS Conc Exp. 3. purchasing controls.5. or Cont.10 Maintenance and Housekeeping CMS Deliverable: Procedure for Maintenance and Housekeeping Regularly conduct maintenance and housekeeping activities.CHEMICALS MANAGEMENT • Skin: Wear appropriate protective gloves to prevent skin exposure. also consider: ─ Approximately how much of each chemical is used every year? ─ How many months/years of supply of a chemical are currently on hand? • If the team determines that disposal is in order. To determine if disposal is appropriate. Amt.gov/sr/dohs/BioSafety/Pages/student_goodlab. • Keep a first aid kit that is clearly marked. • Primary and secondary escape routes with simple instructions should be posted at significant spots. up-to-date Emergency Response Plan for your company (covering all workplaces) is essential. Test emergency procedures periodically. such as verifying that all workers have been evacuated. These procedures should be updated as appropriate after practice drills and actual emergencies. water or soil but needs to be collected and disposed of as chemical waste in accordance with local regulations. Treat the drills as if they were an actual emergency. easily accessible and protected against dust and water.5. • Emergency Response Leaders should be assigned specific duties. • Disabled workers and those with a history of certain medical conditions should be assigned an Emergency Response Leader to guide them to safety. fire department and internal Emergency Response Leaders should be posted close to every telephone. Handling.6 Emergency Procedures CMS Deliverable: Emergency Response Plan Establish. It should include detailed instructions on how to evacuate the building and contain contact names/information for individuals in charge of the evacuation. • Stairways should be kept free of materials that could block or hinder an evacuation. • Important telephone numbers such as emergency. • Regular fire drills should be conducted to identify problems before an actual fire occurs. Storing and Disposal No process will run without generating waste that cannot be discharged to air. The kit should include: − An inspection tag to document monthly checks − Written first aid instructions in the local language JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-9 . Emergency Response Plan A written. 3. document and implement a process to identify and respond to potential chemical accidents. at entrances and near elevators and telephones.CHEMICALS MANAGEMENT 3. In addition to the Emergency Response Plan: • Maintain an emergency shower and eye wash station for removing chemicals that may contact the skin or eyes.11 Waste and Disposal CMS Deliverable: Procedure for Proper Waste Collection. with chemical spills and leaks? (CMD 1.15) ─ Continually improve the effectiveness of the Is there a corrective action plan in place for the facility non-compliance? (CRR 1.2.SECTION 4 Monitor 4.1.2.1.2) health or the environment. These could include amount of hazardous substances used? MRSL. Does the facility maintain appropriate spill containment kits in use and storage areas? 4.1.2a) CMS Is there a documented procedure to deal • Include determination of applicable methods. document and Is there a process for monitoring the validity implement a process to monitor operating conditions of permits required for their facility? needed to prevent the potential for adverse impacts to (EP 1. air emission (CAG 3. Make sure to document information used schedule? (CME 2.2.1.1 Monitor and Measurement ZDHC Audit Questions (Continuous Improvement) Is there secondary containment at all locations where chemicals are stored and an CMS Deliverable: Process to Monitor Goal Progress emergency response plan in place for those General Requirements: critical areas? (CRS 1. 4.2) restrictions or other qualitative or quantitative conditions set through regulation or permits. wastewater discharge limits.1. analysis and improvement chemicals after a defined period of storage processes needed to: to determine their suitability for use? ─ Ensure conformity of the CMS (CRS 1. at least monitor progress towards regulatory conditions annually. document and implement a process to Does the facility set and review. priority chemical groups and ZDHC goal of 4.14) Has the organisation documented and • Plan and implement the monitoring.1 Goal Progress (CMW 2. Equipment needed to conduct the measurements should be calibrated and associated records maintained as well.1) to monitor performance and maintain associated Is management aware of the ZDHC 11 records.1.1.1. and the extent of their use in the plan. The organisation should Is there a process in place that verifies all document performance against the operating criteria chemicals used in producing the product(s) and maintain associated records. meet applicable permit requirements? (CRR 1. Make sure to document performance and maintain associated records.3 Work Practice and Customer ZDHC Audit Questions Requirements Implementation Does the facility have a system of tracking changes in laws and regulations governing CMS Deliverable: Monitor Operating Conditions and environmental management and reporting Customer Satisfaction to management? (EP 1.1.13) Establish. formal targets to reduce the identified in CMS Element 2. RSL.1) Does the facility have targets in place to CMS Deliverable: Process to Monitor Regulatory reduce or eliminate the use of hazardous Conditions chemicals in the facility? (CAG 3.1.1.6.13) including statistical techniques. implemented procedures to re-evaluate measurement.2 Regulatory Compliance zero discharge? (CAG 3.1) Establish.1) Organisations should establish. document and implement a process to Is there a chemical emergency response monitor progress towards the goals created in CMS plan in place and practiced on a regular Element 2.1.1) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-1 .1. 2. Does the facility have a process to follow and update legal requirements as they apply 4. engineering/operational or regulatory changes need to be reviewed to determine if updates are needed to work practices.MONITOR As one of the measurements of CMS performance.4 Change Management and Corrective Action 4. audits.1) documented. document and implement a process to periodically audit the organisation against the ZDHC audit criteria. Facilities may send quality and technical Does the facility require a ZDHC audit or a certified third-party audit regarding staff to observe or review their practices as well. and the results.1 Change Management Most businesses routinely receive change orders or new/revised specifications.1) process. The ZDHC audit checklist may be Does the facility periodically audit or a useful recording tool. Process. the hazard and risk assessment inventory and other CMS elements. engineering/operational or regulatory changes for impacts on the CMS. Methods for obtaining and using this and review its business registration and customer information should be gathered and regulatory permits? (CRR 1. document and implement a process to ZDHC Audit Questions periodically audit performance against the CMS Is there an internal audit group that reviews.1) practices are especially useful for verification of certificates of compliance or other certification letters regarding MRSL/RSL compliance. A good CMS should ZDHC Audit Questions establish a system to handle internal and customer Does the organization have a written chemical inventory changes. document and chemical change management process? implement a process for reviewing planned or actual (CAC 3. including an audit plan.3.2. Best practices for chemical management suggest that ZDHC Audit Questions even suppliers should practice and audit chemical management. the organisation should monitor customer perception ZDHC Audit Questions regarding whether the organisation has met customer Does the facility have a process to monitor requirements.4. Documents and records associated with the audit.1) 4. ZDHC Audit Questions should be maintained. These chemical management? (CAA 3.1) maintained and is contributing to the overall goal of reducing the discharge of hazardous chemicals. should be maintained. The ZDHC audit checklist maybe a useful tool for maintaining this information.1. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-2 . otherwise verify suppliers? (CAA 3.2) CMS Deliverable: Process for Internal Audits Establish. 4. Documents and records associated with the audit. Elements and associated processes.3 External Audit CMS Deliverable: Participate in External Audits Establish. audit checklist and audit results.2 Internal Audit to facility operating permits and customer's products? (CRR 1.1. Establish. including an audit plan.2. The audits should audits and verifies chemical hazards and determine if the CMS is properly implemented and inventory? (CAA 3. audit checklist. 5) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-3 . documenting the facility non-compliances? (CRR 1.1.2 Corrective Action ZDHC Audit Questions CMS Deliverable: Procedure for Change Is there a corrective action procedure(s) Management and Corrective Action when inaccuracies are identified in the Establish.1.2a) actions taken and verifying the effectiveness of the Is there a corrective action plan actions taken.11) non-compliance.2.4. document and implement a process for chemical inventory reconciliation? dealing with actual and potential non-conformity(ies) or (CRS 1. implemented and monitored in case of chemical non-compliance by chemical supplier(s) when identified by the facility? (CRS 1. This process should include taking Is there a corrective action plan in place for corrective and preventive actions.MONITOR 4. carbon footprint and Is the facility a chemical/product steward? energy conservation.4) provide the basis for an organisation’s disclosure practices. Status of change management and corrective actions 4. available in the local Documents and records.1 Disclosure of Substance in Use CMS Deliverable: Process for Disclosing Substances in Use ZDHC Audit Questions Does the facility have chemical hazard Establish. located in areas where chemicals indicating performance of this element shall be maintained. (CD 4.1. the placement of a logo or label may be allowed for use on the product. An organisation should available in areas of the facility where determine and document which stakeholders will be exposure could occur? (CD 4. control plans and future phase out plans for hazardous chemicals.2.1) spills). Regulatory changes Stakeholders are responsible for providing feedback on how ZDHC Audit Questions to improve the system and guide the organisation closer to Does the facility have a current (chemical) achieving the goal of zero discharge of hazardous chemicals. SDS for each chemical. This communication channel also should permit enquiries and acknowledgements in response to the communicated plan. document and implement a process for periodically engaging with stakeholders to determine the suitability and effectiveness of the CMS.1. for fires and (CME 2. language. 5. including meeting minutes. Audit results 3. This may include providing effluent discharge reports Are chemical management efforts shared to Pollutant Release and Transfer Register sites and the with the public? (CD 4.1) provided the substance in use information and how the Is the annual usage (volume) of each information will be communicated.2) Information regarding chemical inventory and hazardous Is there a chemical emergency response chemicals should be shared with local public officials in case plan in place and practiced periodically? of needed emergency response (for example.1) Organisational best practices are those in which the facility becomes an environment or product steward through participation in a programme such as Responsible Care or other universally recognised programme. Progress toward goals 2.4 can (CRS 1.1. Facilities should publicly disclosure their sustainability ZDHC Audit Questions efforts.1.2 Stakeholder Review CMS Deliverable: Process for Engaging Stakeholders Establish. Stakeholders should be given data on the status of the CMS that includes: 1. Establish a channel of communication to disclose hazardous chemicals. document and implement a process for signage and safe handling equipment disclosing the substances in use. When those programme requirements are meet.1) efforts taken to control water usage. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 5-1 .3.SECTION 5 Management Review 5. The chemical risk chemical monitored and recorded? assessment information gathered in Section 2. are handled or stored? (CMW 2. Input from stakeholders 6. Top management should be given data on the status of the CMS that includes: 1. Changes that could affect the CMS 8. Audit results Is management aware of the ZDHC 11 3. Documents and records. document and implement a process for periodically engaging with top management to determine the suitability and effectiveness of the CMS. Progress toward goals ZDHC Audit Questions 2.MANAGEMENT REVIEW 5.1. Regulatory changes 5. Status of change management and corrective priority chemical groups and ZDHC goal of actions zero discharge? (CAG 3. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 5-2 . Recommendations for improvement Senior management should be responsible for providing feedback on how to improve the system and guide the organisation closer to the goal of zero discharge of hazardous chemicals.1) 4.3 Management Review CMS Deliverable: Process for Engaging Senior Management Establish. indicating performance of this element shall be maintained. including meeting minutes. Follow-up actions from previous management reviews 7. iso.fl.pdf Sized Enterprises 2.dep.html 2.emas-easy.3 Florida Guide to Writing a Waste Minimization Plan http://www.1 Example COSHH risk assessment – Warehouse: Use it http://www.us/waste/quick_topics/publications/shw/HWRegulation/Bi nder1_waste_min_guide.1.4 Guidance for creating mass balances http://serc.tex.pdf 2.4.1.1 Code of Practice on Safety Management – basic http://www.ro/biblioteca/carti/Articole/Waste_Minimisation_Guide_for_t steps to cleaner production he_Textile_Industry_A_Step_Towards.html http://www.4.2.gov.pdf Management of Hazardous Chemicals Programme 1.1 OIA Chemical Management Module – toolkit http://outdoorindustry.1 Workplace Safety and Health Guidelines – https://www.SECTION 6 CMS Resources Organisational Skill CMS Manual Section Title & Description Hyperlink Level (Symbol) Reference Foundational 1.4.tuiasi.1.wshc.pdf 2.htm?refid=Ref1669 1.3 Waste Minimisation Guide for the Textile Industry – http://www.uk/coshh/riskassess/warehouse.1 Chemical Management Guide for Small and Medium http://www.1.eu/ days with 10 people on 10 pages in 30 steps 2.1.com/PDF12/AppendixF-ChemicalGuidance.org/responsibility/chemicals/cmpilot.org/iso/home/news_index/news_archive/news.labour.edu/introgeo/mathstatmodels/examples/MassBalance.4 AFIRM Chemical Guidance Document –provide an http://www.2 EMAS “easy” for Small and Medium Enterprises – in 10 http://www.utexas.pdf expectations of a Safety Management System 2.afirm-group.hse. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-1 .mtpinnacle.pdf overview to types of chemicals used in textiles and leather goods 2.html 2.state.htm as a guide to think through some of the hazards in your business and the steps you need to take to control the risks.1.1 ISO 9001 for Small Business – what to do advice http://www.gov.edu/bmeb/resources/mass.ce.hk/eng/public/os/manage.sg/files/wshc/upload/cms/file/WSH_Guidelines_MHCP.com/pdfs/Guide_E_300708.2.carleton. 6.de/en/Topics-from-A-to-Z/Hazardous-Substances/workplace- substances – practical guide for small and medium size control-scheme.com/df.gov/OSHA/PDF/ertk_gi.pdf Resource Links provide more regulatory information.gov/dsg/safer_chemicals/index.org/safer-chemicals/guide-to-safer-chemicals BizNGO principles for safer chemicals 2.0.4.1 International Chemical Control Toolkit – list of http://www.com/ChemicalStorageGuidelines.ehso.3 Easy-to-use workplace control scheme for hazardous http://www.pdf Assessment Guide Version 1.0 – collection of alternative assessment guides 2.2 Transitioning to Safer Chemicals – a toolkit for https://www.org/downloads/GC3_guidance_final_031011.bizngo.htm 3.5 An Employer’s Guide to Developing an Employee http://www.pdf?__blob=publicationFile businesses 3.pdf 2.5.CMS RESOURCES Organisational Skill CMS Manual Section Title & Description Hyperlink Level (Symbol) Reference 2.2 Meeting Customers’ Needs for Chemical Data – a http://greenchemistryandcommerce.1 ZDHC Research List – 2014: Chemical Substance www.4 Chemical Storage Guidelines from the CDC – guidelines http://www.roadmaptozero.nap.2 A Framework to Guide Selection of Chemical https://download.2 Interstate Chemicals Clearinghouse – Alternatives http://theic2.3 Safety in the use of chemicals at work – basic guidance http://www.org/wcmsp5/groups/public/---ed_protect/---protrav/--- to protect workers from the hazards of chemicals safework/documents/normativeinstrument/wcms_107823.pdf Right-to-Know Program – basic steps in developing a training program 3.org/article/download-pdf/file_name/IC2_AA_Guide_Version_1.nap.6.ilo.com/ghs-msds/format-and-sections-of-the-ghs-sds/ http://msdssearchengine.2 The Guide to Safer Chemicals – implementing the http://www.1 Identifying and Evaluating Hazards in Research http://www.org/content/dam/acsorg/about/governance/committees/chemicals Laboratories – while oriented to the lab many factors afety/identifying-and-evaluating-hazards-in-research-laboratories-draft.mn.pdf can be adapted to the factory.5.php?record_id=18872&page=http%3A%2F%2Fww Alternatives – 13 step framework to support decision w.6.osha.ghs-msds.org/legacy/english/protection/safework/ctrl_banding/toolkit/icct/sh guidance sheets on various exposures eets.edu/login.php?query=red+27&search=1 3.php?file=pdf/ResearchList.2.5.4.6. 3.php%3Frecord_id%3D18872 making about alternatives to chemicals of concern.ilo.htm for safe chemical storage JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-2 . 2.edu%2Fdownload.acs.2 Accessing SDSs for chemicals http://www.com/engine/search. 2.p guidance document for suppliers df 2.html employers and workers 2.dli.baua.5.5. theiia.com/programme-documents.4.org/assets/1/7/AAFA_VPEP_12-20-12_final.2 The Internal Auditing Pocket Guide – prepare.fema.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev05/English/ Labelling of Chemicals (GHS) ST-SG-AC10-30-Rev5e.2 ZDHC Audit – Tool 8 CAPA Worksheet Template – http://www.pdf 4. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-3 .pdf supplier disclosure form that allows suppliers and buyers to easily exchange vital information on the chemical makeup of products and the environmental impact of apparel and textile products and processes. 4.2 International Standards for the Professional Practice of https://na.pdf 3. report and follow up of internal audits 4.epa.aspx available.4 AAFA – Voluntary Product Environmental Profile .htm use and waste via Lean strategies 2.ie/web/WWW/Faculties/Science_%26_Engineering/Departments/C hemical_%26_Environmental_Science/Resources/Chemical%20Risk%20Assessment %20Template 2.1 SAC Higg Index – sustainability tools http://www.1 Chemical Agent Risk Assessment Sheet – template http://www2.6 Emergency Response Plan Template http://www.1 The Lean and Chemicals Toolkit – addressing chemical http://www.gov/niosh/docs/2005-149/pdfs/2005-149.3 NIOSH Pocket Guide to Chemical Hazards – source of http://www.org/higgindex/ 4.a https://www. http://asq.gov/media-library-data/1388775706419- f977cdebbefcd545dfc7808c3e9385fc/Business_EmergencyResponsePlans_10pg_20 14. 2.5.pdf general industrial hygiene information on industry chemicals.5.2.html?item=H1300 perform.6 Globally Harmonized System of Classification and http://www.php factory tool for corrective actions Progressive 2.4.cdc.wewear.org/standards-guidance/mandatory- Internal Auditing – multiple language versions guidance/Pages/Standards.5.unece.CMS RESOURCES Organisational Skill CMS Manual Section Title & Description Hyperlink Level (Symbol) Reference 3.gov/lean/environment/toolkits/chemicals/index.org/quality-press/display-item/index.roadmaptozero.ul.4.apparelcoalition. ifc.pdf Reference Requirements: provides a common understanding of good environmental practice.6.osha.ccohs. EPA: best management of =EPA&Index=1995%20Thru%201999&Docs=&Query=&Time=&EndTime=&SearchM pollution prevention ethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&Q FieldDay=&UseQField=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5 CZYFILES%5CINDEX%20DATA%5C95THRU99%5CTXT%5C00000006%5C30004Q2U.4.wbcsd. Profile of the Textile Industry – EPA 1997 – general http://www.umweltbundesamt.tx t&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C- &MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g1 6/i425&Display=p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&B ackDesc=Results%20page&MaximumPages=1&ZyEntry=1 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-4 . 2. and Safety Guidelines for Textile l%2B-%2BTextiles%2BManufacturing.pdf Global Social Compliance Programme – Environmental http://gscpnet.pdf.ca/oshanswers/hsprograms/job-haz.org/ Toolbox — a compilation of resources relevant to chemical substitution and alternatives assessments 4.gov/Publications/osha3071.6. oks/textilsn. http://www.oecdsaatoolbox.epa.2 OECD Substitution and Alternatives Assessment http://www. 2.pdf Best Management Practices for Pollution Prevention in http://nepis.1 Life Cycle Metrics for Chemical Products – guideline http://www.3 Guidance for creating Job Safety Analysis http://www.epa.txt?ZyActionD=ZyDocument&Client the Textile Industry – U.htm and https://www.2 Guide on Sustainable Chemicals – a guide that can be http://www.de/en/publikationen/guide-on-sustainable- applied by enterprises for the selection of substances chemicals and mixtures.umweltbundesamt.1.aspx?ID=16329 for chemical sector to assess and report on environmental footprint of products BEST Practices International Finance Corporation: Environmental.org/wps/wcm/connect/2a66470048865981b96efb6a6515bb18/Fina Health.org/Pages/EDocument/EDocumentDetails.S.gov/compliance/resources/publications/assistance/sectors/notebo industry report with several case studies.pdf?MOD=AJPERES&id=1323162617789 Manufacturing Environmental Standard in the Textile and Shoe Sector http://www.de/sites/default/files/medien/publikation/long/428 – Best Available Techniques Reference Document 9.CMS RESOURCES Organisational Skill CMS Manual Section Title & Description Hyperlink Level (Symbol) Reference Aspirational 2.gov/Exe/ZyNET.exe/30004Q2U.com/gscpfiles/GSCP_Environmental_Reference_Requirements. pdf metering for water and energy Reference Document on Best Available Techniques for http://eippcb.pdf repellent products JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-5 . bleaching.ec.greenbiz.com/PDFs/Guidance-for-Best-Environmental-Practices-BEP-for- Global Apparel Industry – focus on fluorinated the-Global-Apparel-Industry.org/Documents/IndustrySupport/CIA%20Process%20Safety%20- %20Best%20Practice%20Guide.pdf Guidance for Best Environmental Practices for the http://fluorocouncil.nas.umweltbundesamt.bizngo.pdf 2003 (above) Best Practices in Product Chemicals Management in http://www.nrdc.eu/reference/txt.pdf Process Safety Leadership in the Chemicals Industry http://www.org/sustainable-materials/plastics-scorecard plastics scorecard Natural Resources Defense Council’s (NRDC’s) 10 Best http://www.nrdc.0 – showcases 22 mills NRDC Guide to Metering in Textile Mills – overview of http://www. mercerisation) or dyeing of fibres or textiles.html Textile Industry – July 2003 – This BREF addresses installations for the pretreatment (operations such as washing. Checklist based on best available techniques in the http://www.edu/resources/static-assets/bcst/miscellaneous/Chemical- prudent chemical management Laboratory-Safety-and-Security.pdf Pollution = a practical guide to responsible sourcing version 2.jrc.europa.de/sites/default/files/medien/publikation/long/429 textile industry – Good summary of the BREF – July 5.CMS RESOURCES Organisational Skill CMS Manual Section Title & Description Hyperlink Level (Symbol) Reference Evaluating the Chemical Footprint of Plastics – a http://www.org/international/cleanbydesign/files/responsible-sourcing- Practices for Textile Mills to Save Money and Reduce guide.com/research/report/2009/12/09/best-practices-product- the Retail Industry – examples of how retailers are chemicals-management-retail-industry moving to better chemical practices Chemical Laboratory Safety and Security – a guide to http://dels.org/international/cleanbydesign/files/CBD-Metering-Guide.cefic. SECTION 7 Glossary alignment agreement analytics lab reports from air. apparel and footwear products around the world retailer the business which sells goods or commodities directly to consumers stakeholder individual or organisation with an interest in the outcome or status supply chain system of activities. service or organisation downstream pertains to the latter part of a process or system framework organisational structure used to manage or create key performance indicator unit of measure to mark whether or not wanted progress is being made law/regulation statements from states and countries requiring adherence to specific standards and protocols life cycle from initial creation to final disposition Manufacturing Restricted Substances list of substances banned from intentional use in processing List (MRSL) metrics type of measurement used to gauge some measurable/quantifiable component of performance milestone critical project/deliverable/performance date or accomplishment prioritisation determining level of importance relative to others Restricted Substances List (RSL) information related to regulations and laws that restrict or ban certain chemicals and substances in finished home textile. soil and water chemical testing audit an inspection or review best practices processes and procedures exceeding requirements to achieve best results brand a trademark or distinctive name identifying a product. information and resources involved in moving a product or service from supplier to customer tier 1 suppliers tier 1 suppliers sell their product directly to major brands tier 2 suppliers tier 2 suppliers sell their product to a company that then sells product directly to the major corporation training providing knowledge to improve competency and overall capabilities zero discharge of hazardous chemicals non-detectable limit based on best available testing capability ZDHC MRSL compliance formulations list of chemicals/chemical formulas that comply with the facility’s MRSL/RSL JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 7-1 . Appendix A Assessing Status . Select product(s) on which to gather data? Do you engage with other communities of practice to share information and knowledge about chemical management. the community and the environment (including communicating the chemical hazards and training on how to safely handle. chemical hazard [assessment]. the community and the environment (including communicating the chemical hazards and training on how to safely handle. The final product? b. Applicable chemical use regulations? b. use and dispose of chemicals that are used)? Has your company implemented a process to communicate to your suppliers the desire to know more about chemicals used in manufacturing processes and/or residing in: a. Your MRSL/RSL at least annually? Does your company offer RSL education and training to your employees and your suppliers? Does your company have a named point of contact for chemical management (this includes activities related to process chemicals and products used. MRSL/RSL compliance. chemical safety and risk management. health and safety programme with documented procedures to protect workers. continuous improvement and public reporting best practices? Does your senior level management support the integration of chemical management into voluntary sustainability initiatives and trade association practices and do you use chemical management as an internal benchmarking tool? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-1 .What Chemical Management Means in Practical Terms – Foundational Level For the Retailer/Brand: Assessment YES NO Remarks Do you have written statements from your company’s senior level leadership that clearly communicate goals and aspirations around Corporate Social Responsibility and that also include chemical management? Does your company publish a RSL/MRSL or do you reference existing. safer alternatives and sustainable chemistry) and have you shared that name with your supply chain partners? Has your company’s chemical management point of contact documented the names and addresses of his/her counterparts at all your final product suppliers? Does your company know and document all manufacturing locations of your final product suppliers? Does your company require – by contract –all of your suppliers to comply with regulatory requirements in the legal jurisdictions where you operate and where you sell your final product? Does your company have an occupational and environmental health and safety programme with documented procedures to protect workers. sustainable chemistry. business management systems. publicly available documents? Do you have a process to regularly implement updates and changes for: a. use and dispose of chemicals that are used)? Does your company require your suppliers to have an occupational and environmental. Contract obligations? Do you have a process to regularly implement updates and changes for: a. Brands/retailers b. Your customer’s MRSL/RSL? c. Applicable chemical use regulations? b. Regulations where your products are manufactured and sold? b. use and dispose of chemicals that are used)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-2 . the community and the environment (including communicating the chemical hazards and training on how to safely handle. All of your brand/retail customers? Does your facility have a purchasing policy for chemicals (list of approved chemicals that are allowed on site)? Does your procurement department know what it can and cannot order? Does your facility have a documented inventory of chemicals purchased (including your supplier’s manufacturing locations). safer alternatives and sustainable chemistry) and have you shared that contact name with your supply chain partners? Has your facility’s chemicals management point of contact documented the names and addresses of his/her counterparts for: a. Suppliers? Do representatives from your facility participate in RSL/MRSL education and training opportunities provided by brands/retailers? Does your facility have an occupational and environmental health and safety programme with documented procedures to protect workers. chemical safety and risk management. stored (including their location) and used at your facility? Does your facility maintain an archive of current SDS of all currently stored and used chemicals (in English and the local language in the GHS format)? Does your facility maintain a database that includes the functional use of chemicals at your facility? Are you able to verify that your facility only utilises chemicals that are in compliance with: a. Retailer/brand RSLs? Does your facility have a communication process to timely respond to information requests related to chemicals used at your facility and potentially present in your products from: a. All of your chemical suppliers? b. chemical hazard [assessment].What Chemical Management Means in Practical Terms – Foundational Level For the Supplier: Assessment YES NO Remarks Does your facility have written statements from the senior level leadership of your company clearly communicating the organisation’s goals and aspirations around Corporate Social Responsibility? Does your facility have a named point of contact for chemical management (this includes activities related to process chemicals and products used. MRSL/RSL compliance. use and dispose of chemicals that are used)? Do you engage with other communities of practice to share information and knowledge about chemical management. business management systems. continuous improvement and public reporting best practices? Does your senior level management support the integration of chemical management into voluntary sustainability initiatives and trade association practices and do you use chemical management as an internal benchmarking tool? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-3 . sustainable chemistry. Assessment YES NO Remarks Does your facility require your chemical suppliers to have an occupational and environmental. the community and the environment (including communicating the chemical hazards and training on how to safely handle. health and safety programme with documented procedures to protect workers. . California Department of Toxic Substances Control DTSC)]? Does your company go beyond compliance with regulations and MRSLs/RSLs and has it implemented further restrictions on chemicals in use or chemicals in products? Do you have a documented business process for this? Have you provided your supplier with consumer use information for your products. REACH Substance of Very High concern (SVHC).. in the product design and development phase)? Do you follow a process in which you collaborate with your suppliers to use chemical hazard assessment data to assess the potential environmental exposure through the product life cycle before you use a certain chemical (i. label and report “chemicals in consumer products” (e. in the product design and development phase)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-4 ..g.e.. including (un)intended use and disposal? Have you asked your retailer for this information? Do you follow a process in which you collaborate with your suppliers to use chemical hazard assessment data to assess the potential risk of relevant human (i..g. US CPSIA. State of Washington’s Children’s Safe Products Act)? Does your company build/maintain a Bill of Chemical Substances used in manufacturing and/or residing in the final product to verify compliance and to identify opportunities for substitution? Do you collaborate with your suppliers to share the Bill of Chemical Substances (directly or via a third party) with your other suppliers and retail customers? Do you collaborate with all of your suppliers to maintain a list of chemicals present in your final products? Can you verify that you follow a process in which you regularly review the chemicals used in processes. worker. against published lists to identify chemicals of concern [e.What Chemical Management Means in Practical Terms – Progressive Level For the Retailer/Brand: Assessment YES NO Remarks Have you completed the Foundational Level assessment and answered all (most?) questions with YES? Can you verify that you have a business process to ensure compliance (including to monitor and verify) with your RSL/MRSL and do you have a process to implement corrective actions in case of non-compliance? Can you verify that you have an established procurement process that makes MRSL/RSL compliance part of contractual obligations with all your suppliers? Can you verify that all chemicals in use and products you manufacture are in compliance with the most stringent global regulatory requirements? Do you monitor and can you verify that all your suppliers meet their contractual obligation to comply with final product regulatory requirements? Do you have an established business process to report chemicals in products to meet regulatory requirements to certify.e. and/or that can be found in your products. CA Prop 65.e. community and consumer) exposure through the product life cycle before you use a certain chemical (i. conduct safer alternatives assessments and identify preferred substances)? Do you make your alternative assessments (including the resources you used) publicly available? Do you promote transparency of sustainable chemistry information on an equal basis with the performance attributes of the material you purchase? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-5 . assess hazards or risks of chemicals. Assessment YES NO Remarks Do you collaborate with your suppliers and customers to prioritise and select chemicals from substances of concern and/or restricted substances lists for alternatives assessment? Do you collect information on alternatives to selected chemicals from your suppliers? Do you work with government agencies and/or advocate for chemical management framework implementation along supply chains (this includes advocating for policies and initiatives to know product and process chemistry. . including (un)intended use and disposal? Do you follow a process in which you use chemical hazard assessment data to assess the potential risk of relevant human (i. conduct safer alternatives assessments and identify preferred substances)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-6 . DTSC)? Have you provided your suppliers and your customers with consumer use information about your products. assess hazards or risks of chemicals. against published lists to identify chemicals of concern (e. worker.g. SVHC.. and/or that can be found in your products.What Chemical Management Means in Practical Terms – Progressive Level For the Supplier: Assessment YES NO Remarks Have you completed the Foundational Level assessment and answered all (most?) questions with YES? Can you verify that all chemicals in use and products you manufacture are in compliance with the most stringent global regulatory requirements? Can you verify that you have an established procurement process that makes MRSL/RSL compliance part of contractual obligations with all your chemical suppliers? Can you verify that your facility is in compliance with all of your customers’ RSLs and do you have a process to implement corrective actions in case of non-compliance? Does your facility go beyond compliance with regulations and RSLs and has it implemented further restrictions on chemicals in use or chemicals in products? Do you have a documented business process for this implementation? Can you verify that you have a valid Certificate of Analysis for each chemical you use in your facility? Does your facility maintain a Bill of Chemical Substances to verify compliance and to identify opportunities for substitution? Have you shared the Bill of Chemical Substances (directly or via a third party) with your customers? Does your facility maintain a list of chemicals present in your final products? Can you verify that you have a process in place in which you regularly review the chemicals you use in your processes. community and consumer) exposure through the product life cycle before you use a certain chemical? Do you follow a process in which you use chemical hazard assessment data to assess the potential environmental exposure through the product life cycle before you use a certain chemical? Do you collaborate with your suppliers and customers to prioritise and select chemicals from substances of concern and/or restricted substances lists for alternative’s assessment? Do you provide information on potential safer chemical alternatives to your customer’s list of prioritised chemical substances? Do you work with government agencies and/or advocate for chemical management framework implementation along supply chains (this includes advocating for policies and initiatives to understand product and process chemistry.e. REACH. Assessment YES NO Remarks Do you make your alternative assessments (including the resources you used) publicly available? Do you promote transparency of sustainable chemistry information on an equal basis with the performance attributes of the material you purchase and the products you manufacture? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-7 . energy usage. carcinogenic.. beginning with substances of concern? Do you have a business process to verify your suppliers are accurately reporting all chemicals in your products? Do you have a process that is part of your selection and procurement decisions that requires from your suppliers a Bill of Chemical Substances? Can you verify that you practice a process to assess all chemicals used to make your products against a defined and transparent set of human and environmental hazard criteria (e. mutagenic or toxic for reproduction [CMR].g.What Chemical Management Means in Practical Terms – Aspirational Level For the Retailer/Brand: Assessment YES NO Remarks Have you completed the Foundational Level assessment and answered all (most?) questions with YES? Have you completed the Progressive Level assessment and answered all (most?) questions with YES? Do you have a business process to fully disclose (upon request to any interested party) the Bill of Chemical Substances for all your products. suppliers and chemical suppliers? Can you verify that you have a business process in place to evaluate alternatives to determine which are most preferable and to decide on substitutions or other actions and communicate your decision to your suppliers and chemical suppliers? Can you verify that you have a business process in place to use alternatives assessments to develop and maintain a preferred substances list? Can you verify that you have a business process in place to verify your suppliers’ compliance with your preferred substances list? Do you collaborate with your suppliers to evaluate and document the impacts of existing and proposed alternatives on the product life cycle (e. wastewater treatment requirements and disposal) on a functional unit level? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-8 . endocrine disruptor [ED]) that helps to prioritise actions and encourages use of chemicals towards safer alternatives? Can you verify that you have a business process that factors hazard assessments into chemical supplier and procurement decisions? Can you verify that you have a business process to collaborate with your supplier to use chemical hazard assessment data combined with your knowledge of the manufacturing processes to assess the potential risk of relevant human (worker and consumer) and environmental exposure routes in your product’s life cycle? Can you verify that you collaborate with your suppliers to implement risk management actions as a result of the hazard. water usage.. bioaccumulative and toxic [PBT]. exposure and risk assessments conducted earlier? Can you verify that you have a business process in place that factors your supplier’s risk management actions into supplier selection and procurement decisions? Can you verify that you have a business process in place to communicate your alternatives assessment process (including criteria for identifying preferred substances) to retailers.g. persistent. Assessment YES NO Remarks Can you verify that you have a business process in place to: a. Give priority to those chemicals scoring higher as more preferable? Do you publicly engage in advocacy to encourage programmes to provide better information about product and process chemistry. metrics and an audit programme to document the performance and continuous improvement of your chemicals management and sustainable chemistry efforts. Score the sustainability of the chemicals and intermediates used to make your products? b. how to assess the hazards and risks of chemicals and how to best provide information on safer alternatives? Can you verify that you have a business process in place to reward suppliers who employ sustainable chemistry in the design and manufacture of their products? Can you verify that you have a business process in place to score materials and intermediate products made with more sustainable production processes (documented and validated)? Can you verify that you have business goals. including public reporting that communicates progress? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-9 . . wastewater treatment requirements and disposal) at a functional unit level? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-10 . that is part of your selection and procurement decisions. CMR.g. which requires from your suppliers a Bill of Chemical Substances? Can you verify that you follow a process to assess all chemicals used against a defined and transparent set of human and environmental hazard criteria (e. water usage.What Chemical Management Means in Practical Terms – Aspirational Level For the Supplier: Assessment YES NO Remarks Have you completed the Foundational Level assessment and answered all (most?) questions with YES? Have you completed the Progressive Level assessment and answered all (most?) questions with YES? Do you have a business process to verify all chemicals in your processes and in the products you manufacture? Do you have a process. ED) that helps to prioritise actions and encourages use of chemicals towards safer alternatives? Can you verify that you have a business process that factors hazard assessments into chemical supplier and procurement decisions? Can you verify that you have a business process that uses chemical hazard assessment data combined with your knowledge of the manufacturing processes to assess the potential risk of relevant human (worker and consumer) and environmental exposure routes in your product’s life cycle? Do you collaborate with your customers (brands and/or retailers) and your suppliers to review the results if the chemical hazard assessment data to jointly identify opportunities for safer alternatives and to a build a preferred substances list? Can you verify that you have implemented risk management actions as a result of the hazard.g. PBT. including criteria for identifying preferred substances) in-line with your customer’s (brand/retailer) expectations? Can you verify that you have a business process in place to collaborate with your customers (brands/retailers) and your chemical suppliers to implement substitutions or other actions agreed upon from the alternatives assessment? Can you verify that you have a business process in place to maintain and implement site-specific lists of preferred substances? Can you verify that you have a business process in place to verify the use of preferred substances and compliance from all your suppliers and communication to your customers (brands/retailers)? Do you collaborate with your suppliers and your customers (brands/retailers) to evaluate and document the impacts of existing and proposed alternatives on the product life cycle (e. energy usage. exposure and risk assessments conducted? Can you verify that you have a business process in place that factors your chemical supplier’s risk management actions into chemical supplier selection and procurement decisions? Can you verify that you have a business process in place to evaluate alternatives (using the alternatives assessment process.. including public reporting that communicates progress? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-11 . Give priority to those scoring higher as more preferable? Do you proactively share the results of the sustainability scoring with your customers (brands/retailers) and suppliers? Do you publicly engage in advocacy to encourage programmes to provide better information about product and process chemistry. Assessment YES NO Remarks Can you verify that you have a business process in place to: a. how to assess the hazards and risks of chemicals and how to best provide information on safer alternatives? Can you verify that you have a business process in place to reward suppliers who employ sustainable chemistry in the design and manufacture of their products? Can you verify that you have a business process in place to score materials and intermediate products made with more sustainable production processes (documented and validated)? Can you verify that you have business goals. Score the sustainability of the chemicals and intermediates you purchase? b. metrics and an audit programme to document the performance and continuous improvement of your chemicals management and sustainable chemistry efforts. Appendix B Tables . Do laboratories have a Chemical Hygiene Plan. Does your facility have an individual or team responsible for chemical management or environmental health and safety? If so. Does the facility have a proper waste management system in place to assure proper management and disposal of chemicals? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-1 . Does the facility have Safety Data Sheet (SDS) for the hazardous materials used in the facility? Where are these sheets kept? Are they current within the last 3 years? 9. if required? 7. Has the facility had a comprehensive facility-wide hazardous materials clean out to rid the business of old. Does the facility have an inventory of the hazardous materials used in the facility? If so. Are chemicals stored separated by hazard class and compatibility in a uniform storage system? Is there sufficient storage area? 5. Does the facility have a chemical emergency response plan? Is the staff trained in chemical emergency response? 10. Does the facility have a chemical purchasing policy? Who is responsible for chemical purchasing? 11. is the inventory electronic or paper? Where is it kept? How often is it updated and by whom? 4. who? Do department heads know their responsibilities? 3. when was the last clean out? 6. Facility Chemical Management Assessment Questionnaire Conditions Yes No 1. Does your facility have a chemical management plan or system? 2.Table 1. Is chemical management or safety training available to staff? Is Right-To-Know training for all staff handling hazardous materials conducted annually? 8. Is the facility properly registered under its applicable generator status of hazardous waste with the local or regional government? 12. unwanted chemicals? If so. quantities and storage locations of hazardous waste.. Comments: The location. fire extinguisher. Comments: The location. amount and appropriateness of personal protective equipment (PPE).g. Comments: An effective system in place for chemical emergency response. quantities and storage locations of chemicals. conditions. such as ventilation systems. Comments: JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-2 . condition. amount and appropriateness of the emergency response supplies and equipment (e. equipment and environmental controls. Comments: The location. completeness and availability of Safety Data Sheets (SDSs) in each department using chemicals. the status of these inventories and who maintains them. condition. fire host) for the amount and type of chemicals stored. Comments: Designation of the staff responsible for each of these locations. conditions. Comments: Any chemical inventories for these storage areas. Comments: The types.Table 2: Walkthrough Inspection Sheet Location: Date: Evaluated by: General Items to Evaluate  The types. Comments: The condition and appropriateness of the chemical storage area. Table 3: Checklist for Purchasing Chemicals Purchasing Yes No 1. 6. One person or department designated with the responsibility of purchasing chemicals (i.e. Alternatives considered if warranted. Chemicals purchased in a manner consistent with the facility's purchasing policy.. Proper storage and ventilation requirements of chemical confirmed/met before purchase. Required safety precautions associated with chemical known before purchase. Reagents ordered in polyethylene (PE) bottles or plastic coated glass bottles to minimise breakage. 7. Environmental impact of chemical considered before purchase. purchase request forms). 3.. 5. Purchasing procedure for personnel in place (e. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-3 . 13. 11. 10. Chemicals purchased in quantities needed for current year only. Chemicals not purchased if hazardous properties exceed business value. Appropriate means of chemical disposal determined before purchase (i. 2. (including manufacturing. A check is made of the chemical inventories in other locations for duplication or excess. use and disposal). 12.e. Rate of use and shelf life considered in order to minimise purchase quantity. confirmed before purchase. 9. Is disposal as a hazardous waste required?). basic knowledge of chemistry required).g. Adequate funds for appropriate and legal disposal of the chemical. or its end product. corrosion and rust.. 8. 4. Proper protective/safety equipment necessary for chemical on hand before purchase. The CMO with the assistance of the Chemical Management Committee will make a final determination about whether the chemical requested may be purchased. if any ______________ _____ Is this chemical on the MRSL?  Yes  No Quantity requested Name of supplier _____ Purpose of ordering this chemical: Special handling or storage requirement (list) Chemical will be used completely by:  End of current order  End of current year What type of waste will be produced by this chemical?  Hazardous waste: amount by volume ___ (to be stored for proper disposal)  Non-hazardous waste (to be disposed of in trash)  Non-hazardous waste (to be disposed of down the drain) Signature: _______________________ CMO Signature (if approved):______________________ Date_____________________ Date_____________________ JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-4 . An incomplete response will automatically be denied.Table 4: Request to Procure and Use a High Hazard Chemical Please complete this form and submit it to the Chemical Management Officer (CMO) for review. Name Department_____________________________ Name of chemical requested_______________________________________________________ Common name. Appendix C Chemical Inventory . Glauber's salt Sodium sulfate Company 7757-82-6 1000 kg YES Non-hazardous N/A N/A No No Jun-15 xxx-xx-xx JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-1 . CHEMICAL INVENTORY Responsible for Area and Title Person Completing Inventory and Title Date Inventory Completed and Reviewed 11 ZDHC Priority On Catalogue Order Room Chemical Factory/ZDHC On Brand's Number/Supplier Department Building # Product name Chemical Name Chemical Supplier CAS # Quantity Units SDS on file? Hazard Class R Phrase Classes MRSL? RSL? Shelf Life Order Number Use drop down arrow Use drop down Use drop down Use drop down Use drop down to select arrow to select arrow to select arrow to select arrow to select XYZ Chemical Dye Weigh House #1 12 Hydrochloric acid (37%) Hydrochloric Acid Company 7647-01-0 2 litres YES Class 8 R 35 N/A No No Jun-15 xxx-xx-xx ABC Chemical Dyeing #3 . 10%. pilot facilities and other locations such as tool shops • All compressed gases • Any flammable paints. etc. enter names of all suppliers.5 in the QUANTITY column and litres in the UNITS column. Chemical suppliers often have unique numbers assigned to the chemicals they sell.*OPTIONAL FIELD* ROOM: Indicate the room number where the chemical is located. Column N . Do not put a dash (-) between numbers or letters. contact your customer(s). Hazard classification provides information concerning adverse reactions of the chemical and proper storage. DO NOT USE abbreviations or chemical formulas.*REQUIRED FIELD* On Factory/ZDHC Manufacturing Restricted Substances List (MRSL): Compare chemical inventory you have obtained to all MRSLs available. Columns R-U: DO NOT CHANGE . Example: 7768-77-0 Note: Paints. Column Q . Step 4: Save the newly updated file. solvents.*REQUIRED FIELD* 11 ZDHC priority chemical groups: Please use drop down arrow: If the information is unknown. choose “Cannot Be Determined” and submit an SDS for this chemical with your inventory.*SUGGESTED FIELD* QUANTITY: Indicate the total amount of the chemical using a numerical value ONLY. If you buy the chemical from the trading company. and many prepared solutions/cleaners do not have a CAS Number. please contact: Fill in name. not S-106. Column L . glues. Column C . enter "manufacturer" (if known) also in brackets. Example: Formaldehyde.*REQUIRED FIELD* UNITS: Indicate liquid chemicals in gallons or litres.*REQUIRED FIELD* PRODUCT NAME: Indicate the common name listed on the label or packing.) Step 3: Complete the columns on the form as outlined below: Column A . Example: 2 and 1/2 litres containers of toluene would be recorded as 2. Column K . consider disposing the chemical according to all applicable regulations. Colum D . Example: S106. Please include dashes in the CAS number. caution. This information is critical to the effectiveness of the database. danger. Step 1: Save the blank Chemical Inventory Form to your computer. Column B . visit http://www. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-2 . It is in Microsoft Excel format. magnesium. choose the appropriate hazard class(es). If you have any questions. If you cannot determine the correct class. silos and more. It is very important that hazardous chemicals are properly disposed before they become shock sensitive or explosive. If the RSL is not available. Column M . Column P .*REQUIRED FIELD* SDS On File: Please use drop down arrow: Check your Safety Data Sheet file and ensure that you have an SDS for each chemical that you use.com/ Column O .*REQUIRED FIELD* DEPARTMENT: Indicate the name of the department or area that controls the chemical inventory. fuels and other petroleum products • Materials that would create an explosive or toxic vapour hazard to unprotected personnel during fire emergencies (lead. Column H .*REQUIRED FIELD* BUILDING: Indicate the building where the chemical is located. If none available. etc. please indicate that in this column.*REQUIRED FIELD* SHELF LIFE: Indicate the expiration date of the chemical by month and/or year for time sensitive chemicals. if available. Column G . please consider using the Chemical Inventory Transparency form (separate resource from brands) to ask your supplier for any missing 11 ZDHC priority chemical group information. This includes tanks. solid chemicals in pounds or grams. If you have more than one supplier for an item. (e.roadmaptozero. CHEMICAL INVENTORY INSTRUCTIONS These are the instructions for completing the Chemical Inventory Form. The SDS can be obtained from the chemical manufacturer or distributor.: The Chemical Abstracts Service (CAS) Registry Number may be found for specific chemicals on the chemical container. Column J . Chemicals that must be included in the inventory: • All chemicals with a hazard indication or pictogram on the container label (warning. mercury. safety data sheets (SDSs) or at online search sites that are available below.*REQUIRED FIELD* On Brand's Restricted Substances List (RSL): Compare inventory you have obtained to all brands'/retailers' RSLs available. rail cars.*SUGGESTED FIELD* CHEMICAL SUPPLIER: Indicate the name of the company or supplier that manufactures or sales the chemical listed.the information here populates the drop down lists.) • All chemicals and materials used in laboratories. Note: The three preceding fields can be copied and pasted for the whole inventory.g. From the choices listed on the spreadsheet. n-butanol). Step 2: Review the chemicals at each of the locations in your facility.. If you have not used a chemical in the past 3 years and do not plan to use it in the future. If there is a concentration listed or if the substance is anhydrous. Be sure to include any prefixes.*SUGGESTED FIELD* CHEMICAL NAME: Indicate the proper chemical name of the chemical/chemical mixture.*SUGGESTED FIELD* CATALOGUE NUMBER: Indicate the catalogue number for the chemical listed. Column I .*REQUIRED FIELD* CAS No. chemical mixtures. Leave this field blank for chemicals that are not time sensitive. and gases by indicating the size of the tank.*SUGGESTED FIELD* R-phrases (short form for Risk Phrases): defined in Annex III of the European Union Directive 67/548/EEC: Nature of special risks attributed to dangerous substances and preparations. Completion of this section will aid in Environmental Health and Safety assessment.*REQUIRED FIELD* HAZARD CLASS: Please use drop down arrow: Review the label on the container and the SDS. Column F . Column E . represents the retail members of ZDHC. Shelf Life: Indicates the expiration date of the chemical by month and/or year for time sensitive chemicals. litres. heavy metals. It streamlines and improves the former legislative framework on chemicals of the European Union (EU). kilograms. Units: in this document. MRSL: Manufacturing Restricted Substances List . grams.roadmaptozero. It entered into force on 1st June 2007.. ZDHC: Zero Discharge of Hazardous Chemicals . organotin compounds (e. Glossary 11 priority chemical groups: These are alkylphenol ethoxylates/alkylphenols (APEOs/APs). R phrase: R-phrases (short form for Risk Phrases): defined in Annex III of the European Union Directive 67/548/EEC: Nature of special risks attributed to dangerous substances and preparations. per‐ and polyfluorinated chemicals (PFCs). RSL: Restricted Substances List . REACH: REACH is the Regulation on Registration. and azo dyes that may release carcinogenic amines as defined in Annex XVII of REACH. chlorinated solvents. this is a small scale production line(s) which represents a full scale production line(s).g. SDS information may include instructions for the safe use and potential hazards associated with a particular material or product. chlorobenzenes. Pilot: In this document. CAS: Chemical Abstracts Service (CAS) Registry number. phthalates (ortho‐phthalates). Health and Safety Hazard Class: A chemical material is generally assigned to a class based upon the characteristic that poses the highest degree of danger in transportation.www. EH&S: Environmental. 11 chemical group: see 11 priority chemical groups. short‐chain chlorinated paraffins (SCCPs). Authorization and Restriction of Chemicals. SDS: Safety Data Sheet. Evaluation. cataloguing information on chemicals.com JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-3 . units of measure gallons. brominated and chlorinated flame retardants. hazard pictograms are one of the key elements for the labelling of containers under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). APEOs: Alkylphenol ethoxylates NPEO: Nonylphenol ethoxylates APs: Alkylphenols Brand: As used in this document.a list of chemicals and substances which are not to be used in customer manufacturing facilities. chemical compounds and chemical mixtures. TBT). Pictogram: in this document. chlorophenols.a list of chemicals and material which have specific limits or restrictions of use in a manufacturing facility or as residuals after processing in a brand’s product. Appendix D Risk Assessment Template Example . accident reports. skill or experience of workers who do the work • Systems of work being used • Range of foreseeable conditions How do you rank or prioritise the risks? Ranking or prioritising hazards is one way to help determine which hazard is the most serious and thus which hazard to control first. The following factors play an important role: • Percentage of workforce exposed • Frequency of exposure • Degree of harm likely to result from the exposure • Probability of occurrence There is no simple or single way to determine the level of risk. air sampling of workplace. you are creating a ranking or an action list. Hazard Who Is Risk Controls In Further Priority Action Date Action Involved (Severity and Place Action By Likelihood) Example: 3 process Splashing – PPE only face Consider 1 Immediate Mgt. objective judgement. Priority is usually established by considering the employee exposure and the potential for accident. solution from extreme harm Restructure bulk tank process. How do you know if the hazard is serious? Each hazard should be studied to determine its' level of risk: • Product information/manufacturer documentation • Past experience (e. near misses. urgency of situations and. Competent persons undertaking chemical risk assessments may amend this template to suit site-specific work activities.g. Ranking hazards requires the knowledge of the workplace activities. biological) • The expertise of an occupational health and safety professional • Information about previous injuries. atmospheric. illnesses.1. Pouring sodium employees skin/eye burns shield and eliminating hydroxide Very likely and gloves pouring.. Very high risk *This template is for illustrative purposes only. work environment (for example. By assigning a priority to the hazards.2 Company name: Risk Assessor name: Date: Click here to enter a date. RISK ASSESSMENT TEMPLATE EXAMPLE 2. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-1 . injury or illness. workers) • Legislated requirements and/or applicable standards • Industry codes of practice/best practices • Health and safety information about the hazard such as safety data sheets (SDSs) or other manufacturer information • Information from reputable organisations • Results of testing (for example. condition) • Capability. most importantly. layout. 2. ranging from slight to extremely harmful. burns. where applicable. Definition for Risk Level Guidance on necessary action and time scale: 1. Actions to further reduce these risks are assigned low priority. Harmful – For example. Very Low – These risks are considered acceptable. Definitions for Severity of Harm When establishing potential severity of harm. Slightly Harmful – For example. It might be necessary to consider suspending or restricting the activity or to apply interim risk control measures until this has been completed. Very Likely – Typically experienced at least once every six months by an individual. Risk reduction measures should be implemented within a defined time period. Low – No additional controls are required unless they can be implemented at very low cost (in terms of time. 1. Organisations should adjust the design and size of the matrix to suit their needs. occupational cancer. 3. amputations. particularly if the risk levels are associated with harmful consequences. deafness. nuisance and irritation and ill-health leading to temporary discomfort. 4. 4. 3. dermatitis. information about the relevant work activity should be considered. major fractures. Definitions for Likelihood of Harm 1.One option for ranking risk is to use a table similar to the following: Risk Assessment Severity and Likelihood Likelihood of Harm Severity of Harm Slight Harm Moderate Harm Extreme Harm Very unlikely Very low risk Very low risk High risk Unlikely Very low risk Medium risk Very high risk Likely Low risk High risk Very high risk Very likely Low risk Very high risk Very high risk Note: These categorisations and the resulting asymmetry of the matrix arise from the examples of harm and likelihood. Unlikely – Typically experienced once during the working lifetime of an individual. 2. Risk reduction measures should be implemented urgently within a defined time period. Considerable resources might have to be allocated to the additional control measures. to a tolerable level and preferably to an acceptable level. and (b) nature of the harm. but the costs of additional risk reduction measures should be taken into account. minor fractures. Extremely Harmful – For example. eye irritation from dust. multiple injuries. together with (a) part(s) of the body likely to be affected. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-2 . serious sprains. minor cuts and bruises. concussion. lacerations. Likely – Typically experienced once every five years by an individual. superficial injuries. poisonings. Very Unlikely – Less than 1 percent chance of being experienced by an individual during their working lifetime. High – Substantial efforts should be made to reduce the risk. asthma. Medium – Consideration should be as to whether the risks can be lowered. work-related upper limb disorders and ill-health. Arrangements should be made to ensure that the controls are maintained. 2. money and effort). No further action is necessary other than to ensure that the controls are maintained. 3. other severely life shortening diseases and acute fatal diseases. Arrangements should be made to ensure that controls are maintained. fatal injuries. Could Very Likely . Very High – These risks are unacceptable. particularly if the risk levels are associated with extremely harmful or very harmful consequences. Substantial improvements in risk control measures are necessary so that the risk is reduced to a tolerable or acceptable level. 5.Could happen but very happen but probably never happen at any time happen sometime rarely will Kill or cause permanent 1 1 2 3 disability or ill health Long-term illness or 1 2 3 4 serious injury Medical attention and 2 3 4 5 several days off work First aid needed 3 4 5 6 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-3 . The work activity should be halted until risk controls are implemented that reduce the risk so that it is no longer very high. If it is not possible to reduce the risk. Arrangements should be made to ensure that controls are maintained. the work should remain prohibited.Could Very Unlikely . Example of Hazard Priority Setting Unlikely .Could Likely . Appendix E American Apparel and Footwear Association Environmental Standards . • Factories must have in place procedures to safely receive and handle hazardous materials that are delivered to the factory. Hazardous Standards Materials • Handling. product substitution and process modification. regulations and standards must be on file at the factory at all times. Data also must include all electricity use at the factory. The SDSs must be available for review by all employees at the factory. ventilation. Best Practices • Factories should develop and implement energy management and conservation procedures for the factory. particulate matter (PM). • Each factory must have in place all current permits and authorisations required by law for the air discharges. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-1 . All information must be kept on file at the factory for at least 5 years. regulations and standards related to air emissions and activities related to air emissions. heat content and sulfur content information for all fuel types. drying and curing ovens. • Using accepted calculation methodologies. setting goals and plans for improving energy efficiency and should include provisions for comparing actual performance against the goals. Example environmental standards from the American Apparel and Footwear Association (AAFA): Air Standards • All discharges to the air from factories must comply with all permits and applicable laws and regulations. The Programme should address the monitoring and review of energy usage. as defined by the United States Environmental Protection Agency (US EPA). authorisations and applicable laws. chemical and environmental hazard information to transporters for any hazardous materials transported from the factory. ventilating and air conditioning (HVAC) equipment in order to avoid the release of CFCs to the environment. sulfur dioxide (SO2). • Use of chlorofluorocarbons (CFCs) shall be managed as required by the US EPA to ensure proper operation of refrigeration and heating. The factory must use appropriate controls in order to meet the limits and any controls must be properly operated and maintained. laws. The calculation methodology must be available for review by [Company Name] or its designated auditor. as the terms “Scope 1” and “Scope 2” GHG emissions are defined by the World Resources Institute’s GHG Protocol. compressed air systems. in order that any hazardous material spills or releases can be safely and adequately responded to in a timely manner. Type and quantities of fuels used must be summarised and must be kept on file at the factory. including boilers. Energy Standards Management • Factories must have energy usage data available at the factory for the previous 5 full calendar years. lighting. • Factories should identify opportunities to reduce pollutants and toxic chemicals in air discharges product selection. • Safety Data Sheets (SDSs) must be on file at the factory for each and every dye. • Factories should calculate total Scope 1 and Scope 2 greenhouse gas (GHG) emissions for the entire factory. chemical and chemical product used and stored at the factory. The factory must maintain compliance with all permits. • Factories must provide physical. carbon monoxide (CO). and more: nitrogen oxides (NOx). heating. furnaces. • Factories must have in place appropriate and adequate spill response equipment and procedures. storage and transportation of all hazardous materials at each factory must comply with all permits and applicable laws and regulations. Copies of permits. authorisations. volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). and air conditioning systems as well as fuel usage in combustion equipment. • Use of US EPA Class I and Class II as a spot remover is prohibited. • Any wastes or effluents from air pollution control equipment must be managed and disposed of in accordance with applicable rules and regulations. The Programme should include all processes. Best Practices • Open burning of solids wastes is not considered a good practice and should be avoided. factories must calculate total annual air emissions of the following pollutants for the entire factory and for each major process. Data must include quantity. Factories must include emissions from fuel usage and from processes. Records must be maintained for the previous 5 calendar years. regulations and standards must be on file at the factory at all times. soil or water resources. Hazardous waste must be stored so as to prevent or control accident releases to the air. The records must also include used oil. Each factory must maintain a current list of all ASTs and USTs. • Factories must quantify and maintain records of the amounts and types of all materials that are recycled or reused. Best Practices • Factories should develop and implement waste minimisation and source reduction procedures in order to minimise the amount of solid and hazardous waste generated by the factory. cardboard. including size. Each AST and UST must be inspected regularly for integrity and for evidence of leaks. including fabric waste. PCB’s. • Factories must operate aboveground storage tank (AST) and underground storage tank (UST) systems in a manner that minimises the risk for impact to the environment. • Factories must have in place procedures for safe filling of USTs. disposal or other processing. Procedures must be in place for the inspection of any collected precipitation in containment areas prior to discharge. Factories must ensure that transporters and treatment and disposal facilities are properly authorised and permitted to accept the waste or recyclable material and evidence of this must be kept on file at the factory for each waste or recyclable material. The records must include all hazardous wastes. contents. releases or other problems. Best Practices • Secondary containment should be provided for all ASTs and other hazardous material containers in order to minimise the chance of a spill from reaching the environment. solids wastes. including corrective action taken. This standard includes land application of effluents. All hazardous waste containers must be properly labelled. • Hazardous wastes. recyclable materials and special wastes can only be shipped to permitted. ASTs and other containers. • Factories must quantify and maintain records of the amounts and types of all solid and hazardous wastes generated for the entire factory. such that the risk for impact to the environment from the wastes is minimised. scrap metal. authorisations and applicable laws. Waste and Standards Sludge • Handling and disposal of solid and hazardous waste generated by each factory must comply with all permits and applicable laws and regulations. or must be discharged under proper authorisation to an off-site public or private wastewater treatment facility that is operating according to its required permit. Untreated wastewater or sewage discharges to the environment are prohibited. • Regular training must be provided to employees covering all of the standards in this section and records of the training must be maintained for 5 years. Records of any spills or leaks. The procedures must include best practices for preventing and responding to leaks and spills. used batteries and other special wastes. must be kept on file at the factory for 5 years. whichever is more protective. authorised facilities for treatment. Wastewater Standards • All discharges from factories must meet limits prescribed by permits and applicable laws and regulations. all the way to final disposal or reclamation point. • Each factory must have all current permits and authorisations required by law for the discharges. • All wastewater and sewage discharges from factories must be properly treated on-site before being discharged to a receiving stream. yarn waste. Records must be maintained for the previous 2 calendar years. etc. Factories must have detailed information on file at the factory describing the fate of all wastes and recyclable material once the wastes and recyclable material leave the factory. as the term “hazardous waste” is defined by US EPA. • Factories must maintain good housekeeping in all solid and hazardous waste collection and storage areas. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-2 . for proper treatment. • Hazardous waste and solid waste storage and handling areas must be inspected regularly in order to detect potential leaks. Copies of permits. Secondary containment must be provided for all hazardous waste storage areas. including ultimate disposal method for each waste. paper. • Establish a system to properly notify third-party emergency response organisations of chemicals stored on site for planning purposes. location and secondary containment method used. The records must include the name and location of the company that is accepting the material for recycling or reuse. wood. light tubes. • Testing of wastewater and effluent discharges must be performed by capable and properly certified laboratories. • If septic systems are used for the disposal of domestic sewage. product substitution and process modification. Employees must receive regular training on the best management practices. the factory must ensure that the septic systems are properly designed and installed. • Factories should identify opportunities to reduce pollutant loading and toxic chemical loading in discharges by recycling and reuse. product selection. Use the American Apparel and Footwear Association Restricted Substances List (AAFA – RSL) as guidance. • Factories should develop and implement a programme designed to maximise the water use efficiency at the factory. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-3 . Testing results and other operational information must be kept on file at the factory for 5 years. are well maintained and are installed in areas with sufficient soil percolation and stability. • Biosolids generated at factories must be handled and managed in a manner than minimises environmental impact and must be either disposed of or reused under proper permits and authorisations. • Factories must implement best management practices in order to minimise the exposure of pollutants to precipitation. Industrial wastewater disposal through septic systems is prohibited. Best Practices • Factories should develop a water balance across the factory in order to ensure that all wastewater and sewage is being captured and treated to the Recommended Effluent Standards.