General Introduction
The goal of this section is to drive responsible chemical management programs at manufacturing facilities. The use of chemicals in a facility’s production processes and operations can be extremely toxic and hazardous to the environment and human health if not managed systematically and appropriately. Unlike other sections in Higg, chemicals management will touch all parts of your business – from inventory and purchasing, to the production floor, to storage and waste locations. A robust chemical management program should contain basic and advanced practices in the following areas:
- Chemical management policies, compliance procedures, and commitments
- Employee training and communication
- Chemical and raw materials procurement and purchasing practices
- Chemical inventory management
- Chemical storage, transportation, handling and use practices
- Emergency Response Plan (ERP), accidents, incidents and spills remediation plan
- Product traceability, quality and integrity
- Chemicals and process innovation
- Continuous Improvement
The HiggFEM Chemical Management section guides you from basic to advanced practices in each of these categories. Please keep in mind that it may take a few years to fully complete all the necessary requirements in order to launch a robust chemicals management system. One can refer to the ZDHC CMS framework Version 1.0 document for more information, https://www.roadmaptozero.com/process#Guidance
Before answering assessment questions, you will first be asked to define whether your factory has production processes that require chemicals. These selections will direct you to the questions that are most applicable for your facility. Examples of chemicals used in production include dyes, silicone finishes, screen printing, solvents, inks, labels, durable water repellent chemical formulation, adhesives, tanning chemicals, and other chemical enhancements. Other examples include chemical plasticizers added to a plastic product/component, screen printing ink that has pigments and resins, or a solvent used as the carrier for other ingredients that will evaporate from the garment after the printing process is complete. We expect that all Tier 2 and Tier 3 facilities (material suppliers, dyeing and printing facilities, leather tanneries, chemical suppliers, and trim suppliers) will answer “Yes” to using chemicals in production.
Note: The HiggFEM Chemical Management section is the result of a collaboration between Sustainable Apparel Coalition, Outdoor Industry Association, and Zero Discharge of Hazardous Chemicals.
Chemicals Introduction
Every question in this section is written to drive facilities to excel in each of these categories:
- Chemical Management Policies, Compliance Procedures, and Commitments: it is important for facilities to have strong policies and procedures in place as a first step to proper chemicals management. This documentation demonstrates management support and comprehensive planning for chemicals management. While this documentation does not guarantee responsible behavior, it is an important precursor to responsible, systematic chemical management.
- Employee training & communication: in order for chemicals to be managed responsibly, all workers that come into contact with chemicals must be aware of responsible management practices and guidelines.
- Chemical selection, procurement, & purchasing practices: in order to meet basic chemical requirements, a critical first step is to understand what chemicals are coming into the facility. Once you know what is coming in the door, you are better equipped to make responsible decisions about what is purchased and how those purchased chemicals are managed.
- Chemical inventory management: maintaining a chemicals inventory is an important part of good record-keeping to confirm a facility’s understanding of which products are used on-site and whether they meet criteria. Inventories are also important to identify the source of a product failure in the case of a non-compliance.
- Chemical storage, transportation, handling and use, practices: once chemicals are brought onto the premises, workers must be prepared to properly store, transport / dispense, handle and use them responsibly to prevent environmental contamination and/or worker exposure.
- Emergency Response Plan (ERP), accidents & spills remediation plan: in order to protect workers and/or responders from inadvertent exposure, it is critical to have a plan for managing an emergency chemical incident that all workers are prepared to implement.
- Product traceability, quality / integrity: to ensure product quality, it is important for your facility site to confirm the quality of a chemical ordered matches the quality of the chemical received, especially related to environmental criteria and document full traceability. This enables a facility to prevent an unintentional non-compliance or worker/environmental chemical exposure.
- Chemicals & Process Innovation: chemicals management is a complex area where we currently have more environmental challenges than solutions. It is critical that value chain partners work together to innovate in order to shift away from properly managing contaminants towards replacing contaminants with better alternatives and innovations to reduce environmental impacts.
- Continuous Improvement: CMS implementation is a continuous process. As changes happen in organisations, regulations, requirements, Policies, SOPs and processes need continuous review and updates. It is important that the organisation has a process in place to do so. This process may be done internally and/or by external parties.
The above KPI’s were also mapped against the original OIA Chemicals Management Module Primary Objectives 1-7, ensuring all concepts were captured within this newly organized, converged Facility Environment Module 3.0 and allowing the Chemical Management Module (CMM) Primary Objectives to continue to be used as another way to think about and reference the key high-level chemicals management best practices we seek to drive within the industry.
IMPORTANT — HOW TO USE TECHNICAL GUIDANCE LINKS: One of our partner organizations, the Zero Discharge of Hazardous Chemicals (ZDHC) group, has developed an excellent guide for managing chemicals that is referenced throughout the HiggFEM questions. For example, if a question references “ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 5” for more information on the recommended good management practices, you may open this document and find section 5 and get more detail on the corresponding topic.
ZDHC Chemical Management System Framework:
Select all of the processes performed at your facility:
- Dyeing or other wet processing
- Printing
- Laundry or washing
- Cementing or gluing
- Fiber extrusion or yarn spinning
- Slashing during weaving
- Leather tanning
- Lamination
- Extrusion, assembly, finishing of plastic parts
- Metal Finishing (with Chemical use)
- Welding
- Casting (with Chemical use)
- Degreasing with organic solvents
- Painting
- Powder Coating (for non-metal use)
- Soldering
- Printed Circuit Board electronic automation (with Chemical use)
- Other production processes that require chemicals
If any are selected, you are a facility that uses chemicals in production processes.
- This refers to facility processes that use chemicals in processes to make a product (e.g., dyeing or other wet processing, printing, laundry or washing, cementing or gluing, slashing during weaving, fiber extrusion, yard spinning, leather tanning, electroplating, welding or other production process). We expect that all Tier 2 and Tier 3 factories (material suppliers, dyeing and printing facilities, leather tanneries, chemical suppliers, and trim suppliers) will fall into this applicability category.
- Examples of chemicals used in production include dyes, silicone finishes, screen printing, solvents, inks, labels, a durable water repellent chemical formulation, cements, adhesives, tanning chemicals, and other chemical enhancements. Another example is a chemical plasticizer added to a plastic product or component. Some chemical mixtures used to make product don’t stay with the finished product but are included here, such as a screen-printing ink that has pigments and resins, plus a solvent used as the carrier for the other ingredients of the ink and will evaporate (or be driven off) from the garment after the printing process is complete. Facilities that use chemicals in production processes are also required to report on their tooling and operational chemicals as applicable
If none are selected, you are a facility that uses chemicals in facility tooling and/or operations only
- This refers to factories that do not use chemicals in production processes, but uses chemicals in other parts of facility operations, including wastewater treatment. We expect Tier 1 cut and sew factories, that are not vertically integrated, will fall into this applicability category. You will still be asked a subset of Chemicals Management questions because your facility still uses some chemicals for daily operation such as cleaning products, machine lubricants, spot cleaners, paint, and chemicals for wastewater treatment (ETP) where applicable.
Chemical Management – Level 1
Questions
Check all types of chemicals included in the inventory
- All chemicals used in manufacturing processes (including chemicals in production, reactants and additives,and wastewater treatment plant chemicals where applicable)
- All chemicals used in tooling/equipment (spot cleaners, lubricants and grease)
- All chemicals used to operate and maintain the facility (aside from WWT which is captured above).
Suggested upload: a) Chemical Inventory List; b) Permits where applicable for certain sensitive chemicals to be stored or used (e.g. explosive materials, acetic anhydride, urea,ethanol, etc., in some countries are regulated and need special permission to use)
Not all information needs to be in one single document, but it needs to be easily accessible in relevant documents (e.g., first in first out documentation)
- Chemical name and type
- Type examples: dye, cleaning agent, coating material, detergent, softener, etc.
- Supplier/vendor name and type
- Type examples: original manufacturer/formulator, reformulator, agent, distributor, broker, other, unknown.
- Presence of Safety Data Sheet (SDS or MSDS) – should include availability and date of issuance
- Global Harmonization System (GHS) compliant or equivalent
- GHS or its equivalent SDS must include chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, methods and material for containment and cleaning up, safe usage and handling methods, spill handling methods, conditions for safe storage including any incompatibilities, chemical toxicity, stability, reactivity, any potential hazardous reaction or decomposition, disposal and waste treatment methods, transport hazard classes and risks.
- Function
- Hazard classification
- Must include P and H hazard phrases (or S and R phrases)
- Where the chemical is used
- For example, which building/process/machine
- Storage conditions and location
- Quantities of chemicals used
- For example: gallons, grams, kilograms, tons, litre
- CAS number or numbers (when in a mixture)
- Lot numbers
- MRSL compliance
- Purchase date
- Chemical expiration dates (if applicable)
For data not included in your facility’s chemical inventory list, is there an action plan for obtaining this data?
Upload your action plan for obtaining this data.
Not all information needs to be in one single document, but it needs to be easily accessible in relevant documents (e.g., first in first out documentation)
A complete chemical inventory includes: chemical name and type, supplier/vendor name and type, Safety Data Sheet (SDS or MSDS) available and date of issuance, function, hazard classification, where used, storage conditions and location, quantities of chemicals used, CAS number(s) as mentioned in the GHS / equivalent SDS for hazardous chemical substances, lot numbers (may be recorded at any location which can be easily tracked or traced back), MRSL compliance, purchase date, and expiration dates (if applicable).
It is also recommended to indicate whether chemicals in your inventory list is included in a Positive List or Negative List of any industry standard, if applicable.
You will be awarded Full Points if you have a complete inventory for all applicable chemicals in your facility.
If you track all chemicals in a partial inventory, you will be awarded Partial Points. Similarly, if you have a detailed inventory but do not yet track all applicable chemicals, you will be awarded partial points.
Please note: You do not need to upload all SDS documentation to higg.org since this may include a high volume of files; this file upload is optional. You should be able to clearly locate where you store SDS information however, you will be asked for this information during verification.
Additional documentation will be requested during verification: b) Permits where applicable for certain sensitive chemicals to be stored or used e.g. explosive materials, d) Purchase records.
Facilities that do not use chemicals in production should inventory all chemicals that are related to tooling/equipment category, including spot cleaners, machine grease/lubricants, and effluent treatment plant chemicals.
Facilities with only tooling/operations chemicals
If you do not have any chemicals that touch products (e.g. cleaning products) and/or do not use chemicals to maintain or lubricate machines, you may select “not applicable”.
Facilities with only tooling/operations chemicals
Should have an inventory of all chemicals that are related to the manufacturing processes and tooling/equipment category, including spot cleaners, machine grease/lubricants, and ETP chemicals. If you do not have any chemicals that may touch products e.g. cleaning products, and/or do not use chemicals to maintain or lubricate machines, you may select “not applicable”.
Facilities with chemicals in production:
- All chemicals in manufacturing, tooling/equipment, operation and maintenance must be inventoried, with all required information is included, to enable full score
- All chemicals in manufacturing must be inventoried to unlock Level 2.
- All chemicals used in tooling/equipment, operation and maintenance also need to be inventoried, however, the facility can move on to next levels in case these are currently not in place or incomplete.
- All chemicals in manufacturing and tooling/equipment must be inventoried to enable Partial Yes score.
Operational Key Performance Indicator: Chemical Inventory Management
What is the intent of the question?
This question ensures a facility understands which chemicals are present on-site. This is a necessary first step to determine which chemicals are hazardous, how to manage them safely, and to establish a chemical management system.
All of this information doesn’t have to be in one Excel doc but may be easily found in multiple documents. For example, quantities and purchase dates may be in separate docs, each chemical may have hundreds of different purchase dates which can be tracked in separate warehouse documentation.
Chemical management begins with a complete understanding of the chemicals which are stored and utilized within the facility. Most chemicals in the textile and footwear industry fall into several categories such as oxidizers, corrosives, gases under pressure, flammable, toxic and irritant.
Typically, we would find most of these around the workplace. Many chemicals come and go as various recipes use them in each individual work order. A written inventory of all different chemicals at the facility is necessary for monitoring hazard communication, and should be readily available to all employees. The inventory is a living documentation and must be kept up to date at all times.
Some of this data is more advanced to track and will take time to compile, but once compiled this will be valuable to your company as new regulations or more advanced chemical management needs are introduced.
Technical Guidance:
It is necessary to understand the implementation methodology of First In, First Out (FIFO) as a system in the facility to be able to efficiently track the chemical consumption data. There could be two different approaches a facility can adopt. One option is that the facility could maintain the chemical inventory which gets updated monthly. Alternatively, it could maintain stock data to capture the lot numbers of all incoming chemicals and another sheet for chemical information log capturing the hazardous information. In the case where there is a possibility of frequent purchase of chemicals, the second option is required.
While preparing an inventory, create a list including chemicals used in production processes, chemicals used to support production processes, such as chemicals used for cleaning equipment between run changeovers (i.e. chemicals that the organization re-uses, sells or discards), chemicals used for wastewater treatment, chemicals used in laboratory, chemicals used for boilers, chillers, janitorial chemicals, spot removers, solvents to remove paints, table gum, chemicals used to clean screens, screen making and exposing chemicals, etc. Intermediate chemicals created during production do not have to be captured. Written instructions for the proper use of a chemical should be available where chemicals are used. Instructions can be in the form of recipe cards, process adjustment instructions or formulation sheets and should describe major operation, the chemicals and quantities that may be required for those processes. The instruction document for chemical use should include process control parameters and check points. Typically, Technical Data Sheets (TDS) will provide information regarding process and usage. It also may be of benefit to work with chemical supplier(s) to optimize recipes, instructions and processes. Inventories should be updated annually or when a process change occurs.
REF: ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 5
Items to include in your inventory:
Chemical identification data as listed in Question 1b:
- Chemical name and type
- Type examples: dye, cleaning agent, coating material, detergent, softener, etc.
- Supplier/vendor name and type
- Type examples: original manufacturer/formulator, reformulator, agent, distributor, broker, other, unknown.
- Presence of Safety Data Sheet (SDS or MSDS) – should include availability and date of issuance
- Global Harmonization System (GHS) compliant or equivalent
- GHS or its equivalent SDS must include chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, methods and material for containment and cleaning up, safe usage and handling methods, spill handling methods, conditions for safe storage including any incompatibilities, chemical toxicity, stability, reactivity, any potential hazardous reaction or decomposition, disposal and waste treatment methods, transport hazard classes and risks.
- Function
- Hazard classification
- Must include P and H hazard phrases (or S and R phrases)
- Where the chemical is used
- For example, which building/process/machine
- Storage conditions and location
- Quantities of chemicals used
- For example: gallons, grams, kilograms, tons, litre
Additional data listed in Question 1c:
- CAS number or numbers (when in a mixture)
- Lot numbers
- MRSL compliance
- Purchase date
- Chemical expiration dates (if applicable)
Where to go for more info:
For Globally Harmonized System of Classification and Labelling of Chemicals: https://www.unece.org/trans/danger/publi/ghs/ghs_rev08/08files_e.html
ZDHC CIL Template:https://www.roadmaptozero.com/documents
How This Will Be Verified:
Facilities that usechemicals in production processes:
Full Points:
- Chemical Inventory covers all chemicals used for manufacturing, tooling/equipment, operation and maintenance (including chemicals in production, spot cleaners, ETP chemicals, grease and lubricants, where applicable). Please refer to Applicability Guidance
- Facility can provide a full year’s list of purchased chemicals and all chemicals purchased are inventoried.
- A chemical inventory exists with the minimum information that include Chemical identification data and Additional data:
- Chemical identification data – refer to the list listed in Question 1b, and
- Additional data – refer to the list listed in Question 1c
- Chemical inventory needs to record the usage quantity information and the quantity needs to be updated at least monthly
- A real time tracking system (electronic or manual) needs to be in place at the storage/warehouse, production, and temporary storage areas to track usage quantity and amount (in/out log) of chemical
- Facility-wide balance check of chemicals (purchased, used) should to be monitored at least every 6 months
- The chemical inventory is updated whenever a new chemical is purchased. A new chemical addition initiates a worker training, PPE, review of any hazard and storage requirements including secondary containment, emergency planning, and disposal requirements.
- New chemicals are not moved into stock or storage until verification takes place: matched to P.O, added into chemical inventory list, CAS no. screened against MRSL, acceptable for use, assigned to proper storage as per its hazard class and compatibility, and properly labeled.
Partial Points:
- Chemical Inventory covers all chemicals used for (at least) manufacturing and tooling/equipment (including chemicals in production, spot cleaners, ETP chemicals, grease and lubricants, where applicable). Please refer to Applicability Guidance.
- Facility can provide a full year’s list of purchased chemicals and all chemicals purchased at least for manufacturing and tooling/equipment are inventoried.
- A chemical inventory exists with the minimum information on Chemical identification data:
- Chemical identification data – refer to the list listed in Question 1b
- Chemical inventory needs to record the usage quantity information and the quantity needs to be updated no longer than 2 months at a time.
Facilities that usechemicals in facility operations only
Full Points:
- Chemical Inventory covers all chemicals used for manufacturing, tooling/equipment, operation and maintenance (including chemicals in production, spot cleaners, ETP chemicals, grease and lubricants, where applicable). Please refer to Applicability Guidance.
- Facility can provide a full year’s list of purchased chemicals and all chemicals purchased are inventoried.
- A chemical inventory exists with the minimum information:
- Refer to Chemical identification data listed in Q1b and,
- Refer to Additional data listed in Q1c
- The chemical inventory is updated whenever a new chemical is purchased. A new chemical addition initiates a worker training, PPE, review of any hazard and storage requirements including secondary containment, emergency planning, and disposal requirements.
- New receipt(s) of a chemical are not moved into storage until some verification takes place: correct to P.O, added into chemical inventory list, CAS no. screened against MRSL, acceptable for use, assigned to proper storage as per its hazard class and compatibility, and properly labeled.
Partial Points:
- Chemical Inventory covers all chemicals used for (at least) manufacturing and tooling/equipment (including chemicals in production, spot cleaners, ETP chemicals, grease and lubricants, where applicable). Please refer to Applicability Guidance.
- Facility can provide a full year’s list of purchased chemicals and all chemicals purchased at least for manufacturing and tooling/equipment are inventoried.
- A chemical inventory exists with the minimum information:
- Refer to Chemical identification data listed in Q1b
- NA (for non-tooling) Facilities
Documentation Required:(these are not required to be uploaded but will be checked during verification):
- Chemical Inventory List
- Safety Data Sheet (SDS or MSDS) – should include availability and date of issuance
- Global Harmonization System (GHS) compliant or equivalent
- GHS or its equivalent SDS must include chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, methods and material for containment and cleaning up, safe usage and handling methods, spill handling methods, conditions for safe storage including any incompatibilities, chemical toxicity, stability, reactivity, any potential hazardous reaction or decomposition, disposal and waste treatment methods, transport hazard classes and risks.
- Permits where applicable for certain sensitive chemicals to be stored or used e.g. explosive materials (ethanol, acetic anhydride, urea etc., as applicable in some countries)
- List of purchased chemicals and corresponding purchase records for the past full year
Interview Questions to Ask:
- Discuss the process for maintaining an accurate, up to date, and complete chemical inventory.
Inspection – Things to Physically Look For:
- Check the list/record of purchased chemicals for any gap with the chemical inventory
- Check chemical inventory, FIFO records, or other relevant documents that capture required data. Check traceability of the data that may be recorded in other places back to the chemical inventory.
- Walk through the facility with a random check of chemical inventory, permit, and worker compliance with PPE.
- Random check at least 10 chemicals on-site (depending on the total number of chemicals used on-site), covering chemicals for manufacturing, tooling/equipment, operation and maintenance to see whether:
- The chemical was recorded in the chemical inventory; and
- Information in the chemical inventory is consistent with the original labeling and MSDS/SDS.
Are Safety Data Sheets posted where hazardous chemicals are stored?
Are Safety Data Sheets available in languages workers understand (at least sections directly related to operational worker safety and storage requirements, such as first aid, hazard, and flammability information)?
Suggested upload: a) photo images showing that the SDS are available at the workplace and accessible to the employees; b) OPTIONAL Safety Data Sheet (SDS), Global Harmonization System (GHS) compliant or equivalent (skip if previously uploaded. They need not be uploaded but need to be available for review during verification); c) CLP compliant Label in cases where the SDS is not available
Additional documentation will be requested during verification: d) Chemical Inventory List, 3) Emergency Response Plans, f) Documentation of Spill Control/Containment equipment, g) Documentation of Appropriate PPE being utilized by the workforce, h) Training documentation
Safety Data Sheets must be Global Harmonization System (GHS) compliant or equivalent.
Select partial yes if not all chemicals used for production / manufacturing processes, tooling, effluent treatment chemicals have GHS or equivalent directives.
Please note:You do not need to upload all SDS documentation to higg.org since this may include a high volume of files; this file upload is optional. You should be able to clearly locate where you store SDS information however, and you will be asked for this information during verification.
For facilities that do not use chemicals in production: Safety Data Sheets are required for all chemicals that are related to the manufacturing processes and tooling/equipment category, including spot cleaners, machine grease/lubricants, and effluent treatment plant chemicals. If you do not have any chemicals that may touch product (e.g. cleaning products) and/or do not use chemicals to maintain or lubricate machines, select “not applicable”.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices AND Employee Training & Communication
What is the intent of the question?
The facility is expected to have complete Safety Data Sheets (SDS) available for all chemical product used in the facility. Global Harmonization System (GHS) compliant or equivalent Safety Data Sheets (SDS) are widely recognized as a fundamental source of chemical information to identify and control the health and safety impacts from chemicals stored, used and discarded. If facility is located in a region where GHS has not yet been adopted, an equivalent standard needs to be adhered to. Safety Data Sheet (SDS) should be collected, reviewed by the facility before chemical is used, to ensure that all the necessary information contained in the SDS is complete and clear. SDS is a document that contains information on the potential hazards (health, fire, reactivity and environmental) and how to work safely with the chemical product. Having Safety Data Sheets (SDS) is a precursor to forthcoming training and management behaviors in this section.
Safety Data Sheets (SDS) are an essential starting point for the development of a complete chemical hazard, health, and safety program. They are a go-to document for anyone needing to know some information about a chemical product they will be in contact with. Chemicals can be very dangerous, especially if you are repeatedly handling them or if they are improperly stored, transported, or used.
Technical Guidance:
It is important to understand all the necessary information available in SDS and to understand the accuracy and adequacy of the information provided in the SDS for a chemical management responsible person. All information provided in all the sections should be evaluated and checked for the hazard identification and chemical composition information details appropriately. Labelling on chemicals boxes and the information declared in the SDS should be correlated and verified. The labels for all incoming chemicals should be verified and they should be original and compliant to GHS CLP or country specific regulations.
In cases where certain tooling / cleaning chemicals do not have appropriate GHS compliant / equivalent SDS, look for the label on the product which should provide details of ingredients and hazard symbols on the label. In cases, where appropriate label or SDS is not available, facility should try to obtain as much information about the chemical as possible. The original labels should be compliant to GHS CLP or country specific regulations.
For further understanding:
- ZDHC MSDS Training Module.
- ZDHC Academy: https://academy.roadmaptozero.com/
- ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 5 and Chapter 6
- GHS: https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev08/ST-SG-AC10-30-Rev8e.pdf
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes
- Complete and updated MSDS/SDS (request updates to chemical supplier at least every 3 years) is available for allchemicals.
- MSDS/Safety Data Sheets (SDS) are in language workers understand (at least sections directly related to operational worker safety and storage requirements such as first aid, hazard, and flammability information).
- Key hazard and safety information according to the MSDS/SDS are clearly/visibly displayed at each location designated to each specific chemical
- MSDS/SDS are Global Harmonization System (GHS) compliant (or equivalent).
- MSDS/SDS are shared with emergency response team internally and externally so adequate preparation for emergencies are planned.
- Workers (including but not limited to: chemical operations and hazardous waste handling) are trained in how to read and understand MSDS/SDS for personal safety, hygiene, and proper handling of chemicals to which they are exposed and how to properly dispose when necessary.
- Chemical storage areas are properly segregated by physical barriers, by hazard class, and/or CLP label, with appropriate signage at the entrance and with storage and workplace and these spaces have appropriate restricted access.
Partial Yes:
- MSDS/SDS are not in GHS format, however it has all necessary information, including but not limited to: chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, methods and material for containment and cleaning up, safe usage and handling methods, spill handling methods, conditions for safe storage including any incompatibilities, chemical toxicity, stability, reactivity, any potential hazardous reaction or decomposition, disposal and waste treatment methods, transport hazard classes and risks.
- Complete and updated MSDS/SDS (at least every 3 years) is available for allchemicals.
- MSDS/SDS are in language workers understand (at least sections directly related to operational worker safety and storage requirements such as first aid, hazard, and flammability information).
- Key hazard and safety information according to the MSDS/SDS are clearly/visibly displayed at each location designated to each specific chemical
- MSDS/SDS are shared with emergency response team internally and externally so adequate preparation for emergencies are planned.
- Workers are trained in how to read and understand MSDS/SDS for personal safety, hygiene, and proper handling of chemicals to which they are exposed and how to properly dispose when necessary.
Facilities that usechemicals in facility operations only
Yes:
- Complete and updated MSDS/SDS (at least every 3 years) needs to be available for allchemicals.
- MSDS/SDS are in language workers understand (at least sections directly related to operational worker safety and storage requirements such as first aid, hazard, and flammability information).
- Key hazard and safety information according to the MSDS/SDS are clearly/visibly displayed at each location designated to each specific chemical
- MSDS/SDS are Global Harmonization System (GHS) compliant (or equivalent), where applicable i.e. bulk chemicals: oil and lubricants, ETP chemicals, etc. MSDS/SDS in other formats (non GHS format e.g. product instruction manual) may be acceptable for chemicals in small quantities i.e. spot cleaners, spray grease, etc., as long as it has all necessary information, such as: chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, safe usage and handling methods, conditions for safe storage including any incompatibilities, disposal and waste treatment methods.
- MSDS/SDS are shared with emergency response team inside and externally for adequate preparation for emergencies are planned.
- Workers are trained in how to read and understand MSDS/SDS for personal safety, hygiene, and handling of chemicals to which they are exposed and proper disposal.
Partial Yes:
- Complete and updated MSDS/SDS (at least every 3 years) needs to be available for allchemicals.
- MSDS/SDS are in language workers understand (at least sections directly related to operational worker safety and storage requirements such as first aid, hazard, and flammability information).
- Key hazard and safety information according to the MSDS/SDS are clearly/visibly displayed at each location designated to each specific chemical
- MSDS/SDS are not in GHS format, however it has all necessary information, such as: chemical product information and composition, hazard classification and symbols, supplier (manufacturer) information, intended use/specific end use, health and safety potential hazards and risks, personal precautions, protective equipment and emergency procedures, first aid measures, symptoms and medical treatment required, safe usage and handling methods, conditions for safe storage including any incompatibilities, disposal and waste treatment methods.
- MSDS/SDS are shared with emergency response team inside and externally for adequate preparation for emergencies are planned.
- Workers are trained in how to read and understand MSDS/SDS for personal safety, hygiene, and handling of chemicals to which they are exposed and proper disposal.
- NA (for non-tooling) Facilities
Documentation Required: (these are not required to be uploaded but will be checked during verification):
- Chemical Inventory List (CIL)
- Safety Data Sheet (SDS or MSDS), Global Harmonization System (GHS) compliant or equivalent [skip if uploaded in previous question]
- Globally Harmonized System – Classification, Labelling and Packaging (GHS CLP)
- Emergency Response Plans
- Documentation of Spill Control/Containment equipment
- Documentation of Appropriate PPE being utilized by the workforce
- Training documentation
- Accuracies of the above content should be validated
Interview Questions to Ask:
- Check understanding of the supervisor in charge, and workers for familiarity with MSDS/SDS, CLP.
- Can they explain the classification hazards for several chemicals in their work area?
- Check their understanding of compatibility e.g. corrosive and flammable chemicals, etc. How does the facility organize storage for chemicals with different hazard classification?
- Check their understanding of several hazard symbols. Ask when they were last trained on chemical hazards in their job and the appropriate application of PPEs needed when handling chemicals.
Inspection – Things to Physically Look For:
- Check if all chemical containers (in use and in storage) have appropriate labeling: name of chemical, hazard classification matching with the SDS, batch/lot number, date of manufacture.
- Sample/random check at least 5 dyestuffs (if apply) and 5 auxiliaries, or 10 different chemicals found on-site to see whether the MSDS/SDS are complete (including all detailed information and sections) and available on site.
- Review a sample of procedures like chemical storage, separation, and disposal, are they matching with the requirements in MSDS/SDS?
- Are there any special storage conditions required (e.g. compatibility, humidity controlled, temperature sensitive, water reactive, etc.) in the MSDS/SDS? Are these requirements understood by the supervisor/manager and met?
- Check if workers are using appropriate PPE matching the requirement listed in SDS for the chemical types that they are handling
- Spill control/containment equipment is in place as appropriate
- Chemical Storage areas have appropriate signage
Where to go for more info:
- ZDHC Training Academy (http://www.roadmaptozero.com/academy/ )
If yes, select all topics included in your training
How many employees were trained?
How frequently do you train your employees?
Suggested uploads: a) Sample training, content covered during training; b) Training calendar; c) Employee training attendee list
Trainings must be documented and cover chemical hazards and identification; MSDS/SDS; signage; compatibility and risk; proper storage and handling; personal protective equipment (PPE) and procedure in case of emergency, accidents, or spill; access restriction to chemical storage areas; potential environmental impact of the chemicals in tanks; the physical protection provided to employees in the area(s) where the factory uses, stores and transports these containers; and their individual duties associated with monitoring and maintaining this protection.
Reference: ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4
Select Partial Yes if you do not have documentation or you have not covered all topics listed.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices AND Employee Training & Communication
What is the intent of the question?
The intent is for the facility to do one chemicals training on handling/safety prior for workers handling chemicals.
Training materials should have a list of in-house hazardous and non-hazard chemicals, their handling procedures, control measures and emergency plans.
How This Will Be Verified:
Yes:
- Trainings held regularly (at least quarterly or in a frequency that allows training all new employees according to the turnover rate) delivered by competent personnel and are documented.
- Training covers topics including: chemical hazards and identification, MSDS/SDS, signage, compatibility and risk, proper storage and handling, PPEs, and procedure in case of emergency, accidents, or spill, access restriction to chemical storage areas, potential environmental impact of the chemicals in tanks, the physical protection provided to employees in the area(s) where the factory uses, stores and transports these containers, and their individual duties associated with monitoring and maintaining this protection
- All workers responsible for chemical related operations have attended the training.
Partial Yes:
- Scenario 1: Trainings were held but not documented, or do not cover all relevant workers, or not regularly (annually).
- Scenario 2: Trainings were held and documented but does not cover all necessary topics i.e. chemical hazards and identification, MSDS/SDS, signage, compatibility and risk, proper storage and handling, PPEs, and procedure in case of emergency, accidents, or spill.
Documentation Required:
- Documented training covering all required aspects (for full yes response)
- Partial documentation OR documented trainings covering only partial topics (for partial yes)
Interview Questions to Ask:
- Interview workers who handles chemical related operations during the site walkthrough to gain insight on whether they are aware of chemical hazards, risks, proper handling, PPEs, and what to do in case of an emergency or spill.
Inspection – Things to Physically Look For:
- Review training material
- Key employees are able to walk through the training material covered and can follow the procedures outlined in the training.
How many employees were trained on this topic?
How frequently do you train your employees on this topic?
Does your facility keep records of all employee and environmental incidents related to chemical spills and emergency response?
Upload: Emergency response plan/procedure
Chemical spill and emergency response plans must meet detailed requirements as specified in guidance, and all workers must participate in a practice drill twice a year.
Reference: ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3
Select Partial Yes if you have a chemical spill and emergency response plan, but that does not yet meet all requirements or you do not have practice drills.
For facilities that do not use chemicals in production:
Answer Yes if you meet requirements for chemicals and spill response plans, however twice-annual practice drills are not required.
Operational Key Performance Indicator: Emergency Response Plan (ERP), Accidents & Spills Remediation Plan
What is the intent of the question?
The expectation is that the facility can clearly demonstrate that workers will know how to respond in the case of a chemical emergency. All employees must know process to respond in case of incident – simply having safety equipment isn’t enough. Response needs to happen immediately without stopping to review a document or ask someone – which is why periodic practice is important (like fire drills in school).
Having a plan can help prevent workers and community casualties as well as possible financial collapse of the organization in the case of a chemical emergency. Time and circumstances in an emergency mean that normal channels of authority and communication cannot be relied upon to function routinely. The stress of the situation can lead to poor judgment resulting in severe losses. The periodic review of chemical emergency planning can help your facility resolve lack of resources (equipment, trained personnel, supplies) or awareness before an emergency occurs. In addition, an emergency plan promotes safety awareness and shows the organization’s commitment to the safety of workers. Appropriate municipal officials should also be consulted since control may be exercised by the local government in major emergencies and additional resources may be available. Communication, training and periodic drills will ensure adequate performance if the plan must be carried out.
Technical Guidance:
- A written, up-to-date Emergency Response Plan for the facility (covering all workplaces) is essential. It should include detailed instructions on how to evacuate the building, contact names/information for individuals in charge of the evacuation procedure.
- Primary and secondary escape routes with simple instructions should be posted at significant spots, at entrances and near elevators and telephones etc.
- Emergency Response Leaders should be assigned specific duties, such as verifying that all workers have been evacuated.
- Disabled workers and those with a history of certain medical conditions should be assigned an Emergency Response Leader to guide them to safety.
- Stairways should be kept free of materials that could block or hinder an evacuation process.
- Regular fire drills should be conducted to identify problems before an actual fire occurs and based on these identified problematic areas, work a corrective and preventive action and implement them. Drills should be treated as if they were an actual emergency.
- Important telephone numbers such as emergency, fire department and internal Emergency Response Leaders should be posted close to every telephone.
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.
- Keep a first aid kit that is clearly marked, easily accessible and protected against dust and water. The kit should include:
- An inspection tag to document monthly checks
- Written first aid instructions in the local language and a list of all items present with their expiry dates
Reference:
- ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes:
- Emergency response plan/procedure exists on paper containing the minimum guidance provided by referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3 and the steps to be taken to protect the environment if there is an accidental release of these substances.
- Practice/drill is conducted periodically (at least twice a year) and well documented
- All workers are included in the practice/drill
Partial Yes:
- Emergency response plan/procedure exists but does not include the minimum guidance provided by referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3
- Practice/drill is documented and conducted periodically but less than twice a year
Facilities that usechemicals in facility operations only
Yes
- Emergency response plan/procedure exists on paper containing the minimum guidance provided by referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3
Partial Yes:
- Emergency response plan/procedure exists but does not include the minimum guidance provided by the referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3
- NA (for non-tooling) Facilities
Documentation Required:
- Emergency response plan/procedure containing the minimum guidance provided by referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3 (For Full Yes points)
- Emergency response plan/procedure exists but does not include the minimum guidance provided by referencing the ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.3 (For Partial Yes points)
Interview Questions to Ask:
- Senior Manager responsible for Emergency Response Plan
- Managers/workers training and drills knowledge
Inspection – Things to Physically Look For:
- Emergency Response Plan written and practiced
- Emergency Exits clearly marked, unobstructed and unlocked
- Emergency response equipment e.g. spill kits, showers, eyewash stations, fire extinguishers, are available on-site and strategically located to be easily accessible to workers at relevant areas
- Emergency response practice/drill records
- MSDS/SDS
Where to go for more info (e.g., links or websites):
- Federal Emergency Management Agency – Emergency Response Plan: https://www.fema.gov/media-library-data/1388775706419-f977cdebbefcd545dfc7808c3e9385fc/Business_EmergencyResponsePlans_10pg_2014.pdf
Suggested upload: a) Schedule for internal checks/audit for chemical safety that covers relevant chemical exposure risks and safety equipment, with clear designation of responsibilities and outcome of the checks/audits; b) Inventory list of PPEs and safety equipment with schedules of stock replenishments, equipment maintenance or replacements, where applicable (skip if previously uploaded).
Protective and safety equipment may include spill response kits (size, type and location appropriately adapted for the chemical), showers and eyewash tested regularly, fire extinguishers maintained regularly, adapted Personal Protective Equipment (PPE) appropriate for the chemical (based on MSDS/SDS) such as appropriate gloves, protective masks, long handle scoops, etc.
Equipment should follow specifications in the GHS-compliant or equivalent Safety Data Sheet, be clearly visible for all relevant workers (e.g., not stored in a storage cupboard with locks; and in close proximity to the relevant area), well-maintained, and checked regularly for functionality by relevant staff.
For facilities that do not use chemicals in production: This applies to all chemicals that are related to the manufacturing processes, tooling/equipment category, and operating chemicals that do not touch product.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices
What is the intent of the question?
The expectation is that the facility uses the Safety Data Sheet (SDS) to define exposure risks and install preventative/emergency equipment and signage in all areas where necessary.
The main purpose should be to protect workers and/or responders from inadvertent exposure whether it is during normal usage or from an accident or incident despite appropriate management systems and operational procedures. Clear signage is important, so facility workers and emergency responders can know immediately whether the stored substance and/or one they handle could expose them to a hazardous property.
Technical Guidance:
PPE details are given in Section 8 of MSDS/SDS and the details need to be understood and followed appropriately. In case the facility has a very high number of chemicals and the selection of suitable PPE needs to be considered, it is advisable to select the suitable PPE based on severity and adequacy of the PPE for all the chemicals. Study the types of PPE’s needed in the facility and select the PPE types which can cover all the possible chemicals appropriately and ensure that the chemicals are also segregated based on the type of PPE required to handle to make the workers understand the use of appropriate PPE to be used for the chemical. It is also important that the PPEs are reviewed periodically and replaced when necessary. This evaluation is based on the calculation of the time interval where the PPE is being exposed.
- ZDHC Chemical Management System Framework Version 1.0 (May 2020) – Chapter 4.6
- MSDS/SDS
- http://www.labour.gov.hk/eng/public/os/C/equipment.pdf
- http://ehsdailyadvisor.blr.com/2012/04/11-rules-for-safe-handling-of-hazardous-materials/
Other Info:
GIZ Facility Plan
Definitions:
‘appropriate’ – meaning as specified in the Global Harmonization System (GHS) compliant (or equivalent) SDS;
‘functional’ – meaning
- easily accessible for all relevant workers (clearly visible – not stored in a storage cupboard with locks; and in close proximity to the relevant area),
- well maintained,
- checked regularly for its functionality, by relevant staff e.g. area supervisors, EHS personnel.
How This Will Be Verified:
Verified by on-site facility review of work/storage areas for appropriate signage and safe-handling equipment.
Please note that there is no Partial Yes for this question.
Factory that uses chemicals in production processes:
Yes
- A facility plan should detail the physical areas of the facility’s property involved in chemical storage and usage. The pictorial plan includes a quick overview of the most critical areas.
- Receiving and delivery
- Chemical storage areas (centralized warehouse and temporary storage areas)
- Chemical process areas
- Manufacturing/production areas
- Waste chemicals storage (including chemical residues and expired chemicals)
- Laboratories, tool shop, maintenance, etc.
- Protective and safety equipment are available on-site at all times and are strategically located to be easily accessible to workers at relevant areas
- Protective and safety equipment are appropriate and in accordance with the Global Harmonization System (GHS) compliant (or equivalent) MSDS/SDS for each chemical stored/used
- Protective and safety equipment are well maintained and checked regularly for its functionality
Factory that uses chemicals in facility tooling and/or operations only:
Yes
- A facility plan should detail the physical areas of the facility’s property involved in chemical storage and usage. The pictorial plan includes a quick overview of the most critical areas.
- Receiving and delivery
- Chemical storage areas (centralized warehouse and temporary storage areas)
- Chemical process areas
- Manufacturing/production areas
- Waste chemicals storage (including chemical residues and expired chemicals)
- Laboratories, tool shop, maintenance, etc.
- Protective and safety equipment are available on-site at all times and are strategically located to be easily accessible to workers at relevant areas
- Protective and safety equipment are appropriate and in accordance with the Global Harmonization System (GHS) compliant (or equivalent) MSDS/SDS for each chemical stored/used
- Protective and safety equipment are well maintained and checked regularly for its functionality
Documentation Required:(these are not required to be uploaded but will be checked during verification):
- Schedule for internal checks/audit for chemical safety that covers relevant chemical exposure risks and safety equipment, with clear designation of responsibilities and outcome of the checks/audits
- Inventory list of PPEs and safety equipment with schedules of stock replenishments, equipment maintenance or replacements, where applicable
Interview Questions to Ask:
- Senior Management on facility plan/emergency response
- Management/Supervisor walk through of their areas of responsibility
- Employee(s) in charge of checks and maintenance of protective and safety equipment
Inspection – Things to Physically Look For:
- Use facility plan during walk through to verify accuracy/completeness
- General walk through of the facility with review of the availability and appropriate usage of PPEs for workers, and accessibility of safety equipment at relevant areas, matching with hazard classification based on the MSDS/SDS
- Whenever possible, check whether the equipment is functioning e.g. eyewash stations, safety showers
Suggested upload: Schedule for internal checks/audit for chemical safety that covers relevant chemical exposure risks and communication (signage placement and updates), with clear designation of responsibilities and outcome of the checks/audits (skip if previously uploaded)
Your facility should post signage at all areas where chemicals are stored or used. Signage should depict the hazard classification(s) of chemicals. The most critical areas for signage include: receiving and delivery, chemical storage areas (centralized warehouse and temporary storage areas), chemical process areas, manufacturing/production areas, waste chemicals storage (including chemical residues and expired chemicals), and laboratories, tool shop, maintenance areas. Handling equipment should be available at relevant locations and correspond with the safety requirement and hazard communication/signage for each particular chemical.
For facilities that do not use chemicals in production: This applies to all tooling and operations chemicals in your factory.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices
What is the intent of the question?
Employees should know immediately whether a substance / chemical is hazardous. The expectation is that the facility uses the Safety Data Sheet to define exposure risks and install preventative/emergency equipment and signage in all areas where necessary and CLP compliant label in case of tooling chemicals.
The main purpose should be to protect workers and/or responders from inadvertent exposure whether it is during normal usage or from an accident or incident despite appropriate management systems and operational procedures. Clear signage is important so facility workers and emergency responders can know immediately whether the stored substance and/or one they handle could expose them to a hazardous property.
Technical Guidance:
- Chemical hazard signage should be displayed appropriately with respect to the chemicals placed and as per the information given in MSDS/SDS Section 2 or Section 3. The safe handling equipment such as, trolleys, containers must be maintained in proper condition without any worn-out wheels, ungreased wheels or leakages. Conduct thorough walk through and inspect the real scenario on shop floor.
- ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 6
- MSDS/SDS
- Facility Plan
- https://www.osha.gov/dsg/hazcom/pictograms/index.html
- http://www.nfpa.org/Assets/files/AboutTheCodes/704/NFPA704_HC2012_QCard.pdf
- http://www.hse.gov.uk/chemical-classification/labelling-packaging/hazard-symbols-hazard-pictograms.htm
- http://www.safework.sa.gov.au/uploaded_files/CoPManagingRisksHazardousChemicals.pdf
- http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/EMKG/EMKG.html
- GIZ Practical Chemical Management Toolkit
How This Will Be Verified:
Verified by on-site facility review of work/storage areas for appropriate signage and safe-handling equipment.
Please note that there is no Partial Yes for this question.
Factory that uses chemicals in production processes:
Yes
- A facility plan should detail the physical areas of the facility’s property involved in chemical storage and usage. The pictorial plan includes a quick overview of the most critical areas.
- Receiving and delivery
- Chemical storage areas (centralized warehouse and temporary storage areas)
- Chemical process areas
- Manufacturing/production areas
- Waste chemicals storage (including chemical residues and expired chemicals)
- Laboratories, tool shop, maintenance, etc.
- Signage posted at the storage and chemical operations area depicts the hazard(s) classification of chemicals stored
- Signage are clearly visible and understood by relevant employees/workers that are responsible for chemical operations
- Handling equipment is available at relevant locations and corresponds with the safety requirement and hazard communication/signage for each particular chemical
Factory that uses chemicals in facility tooling and/or operations only:
Yes
- A facility plan should detail the physical areas of the facility’s property involved in chemical storage and usage. The pictorial plan includes a quick overview of the most critical areas.
- Receiving and delivery
- Chemical storage areas (centralized warehouse and temporary storage areas)
- Chemical process areas
- Manufacturing/production areas
- Waste chemicals storage (including chemical residues and expired chemicals)
- Laboratories, tool shop, maintenance, etc.
- Signage posted at the storage and chemical operations area depicts the hazard(s) classification of chemicals stored
- Signage are clearly visible and understood by relevant employees/workers that are responsible for chemical usage
Documentation Required:
- Schedule for internal checks/audit for chemical safety that covers relevant chemical exposure risks and communication (signage placement and updates), with clear designation of responsibilities and outcome of the checks/audits
Interview Questions to Ask:
- Senior Management on facility plan/emergency response
- Management/Supervisor walk through of their areas of responsibility
- Employee(s) at relevant areas on their understanding regarding the signage and hazard communications
Inspection – Things to Physically Look For:
- Use facility plan during walk through to verify accuracy/completeness
- General walk through of the facility with review of chemical signage and hazard communication
- Check if signage matches with MSDS/SDS of chemicals stored/used at each area
If yes, do all chemicals purchased and used in production meet the facility’s chemical purchasing policy?
If no, do you have a process or plan for eliminating chemicals that do not meet the facility’s chemical purchasing policy?
(Note: Not all are required to upload, but need to be available for review during verification) Suggested uploadcould include some of the following to demonstrate practice:a) MRSL(s) applicable to the facility e.g. customer’s MRSL, ZDHC MRSL, facility-own MRSL (combined hazard-based and MRSL from all customers); b) Chemical purchasing procedures and standard operating procedures; c) Chemical supplier/vendor criteria; d) Positive lists; e) Chemical Safety Data Sheet and TDS (skip if previously uploaded); f) Certificate of analysis of chemical composition (the test results of the chemical to evaluate the hazardous chemicals presence along with impurity profiles); g) Certificate of MRSL conformance (chemcheck reports from gateway conforming to the ZDHC gateway level) and declaration letters (with proper evidence of conformance towards the MRSL in case if the chemical is not present in ZDHC gateway) stating date of issuance, name of chemical in concern, the MRSL it is declaring compliance against, and chemical test report confirming the conformance; h) MRSL conformance test reports, where applicable
MRSL is a Manufacturing Restricted Substance List. Facilities typically are aware of Restricted Substance Lists (RSL); however, the industry has recently evolved to focus on Manufacturing Restricted Substance Lists (MRSL) to further environmentally-friendly chemical use in addition to Restricted Substance Lists. MRSL is important because a facility that uses compliant chemicals, in accordance with technical specification directions, has better environmental outcomes for the various facility discharges as well as more consistent RSL material compliance.
Answer Yes only if all chemicals purchased meet RSL/MRSL purchasing requirements and you have documentation to support this.
Answer Partial Yes if you purchased chemical(s) that do not have sufficient documentary evidence to prove compliance to MRSL / RSL. and you have clear plan for obtaining the documents from chemical supplier within 6 months or change the chemical supplier who can meet the requirements in order to increase the % of compliant chemicals meeting MRSL/RSLs.
For facilities that do not use chemicals in production: All purchased chemicals must meet these requirements with documentation available that includes certificates of analysis for the composition and MSDS / SDS and technical data sheets where applicable. MRSL should be included in your facility’s purchasing policies to prevent non-conforming chemicals enter the facility and RSL compliance through proper production control and avoid violations to occur accidentally, thus demonstrate a full RSL-compliance program in Higg FEM. For chemicals such as cleaners etc., look for the label for the ingredient information and try to check COA to avoid any non-compliance towards MRSL.
Operational Key Performance Indicator: Chemical Selection, Procurement, & Purchasing Practices
What is the intent of the question?
The intent is to drive the purchase of the compliant chemical / chemical formulation with the least hazard risk for workers, workplace, environment and customer.
This question will be asked of all facilities to ensure purchases do not violate RSL and MRSL. We need to ask non-production facilities if MRSL is included in their purchasing to prevent violations from accidentally occurring, and it relieves this group from having to have a full RSL-compliance program in the upcoming RSL question.
Technical Guidance:
It is important to discuss with chemical suppliers for ZDHC Gateway Level 1-3 compliant and products which are acceptable for RSL/MRSL usage. However, it is important that the facility should not just rely on the declarations or assurances from suppliers alone but ensure to put some validation processes in place to ensure compliance such as test reports from competent ISO 17025 certified laboratories approved for conducting these tests. It is important to discuss with the chemical / material suppliers about their product details with respect the facility’s operating conditions and its limitations on recipe concentrations etc.
ZDHC Gateway – Chemical Module, BLUESIGN®, OEKO-TEX®, ecopassport, certificates of conformance, certificates of analysis
New Guidance for Hardgoods facilities:
In the hardgoods sector MRSL (Manufacturing Restricted Substances List) and RSL (Restricted Substances List) requirements may not be available. However, there is a significant impact from the use of chemicals and therefore Restricted Lists should be used.
All textile components in the hardgoods sector (for example, products such as rucksacks, tents, etc.) should apply the MRSL and RSL requirements as outlined in the Higg FEM.
All other components should be governed at least by a Restricted List regarding their use during manufacturing. The restrictions on the final product, as applied through an RSL, may especially be relevant for the metal processing and electronics industry, and yet again for other sectors not be relevant. With RSLs the management of residual chemicals on the final product is secured, however this may depend on the product and materials used.
For manufacturing, black, grey and white lists are often used. Black lists contain chemicals that are prohibited in manufacturing, grey lists contain chemicals that should be phased out from manufacturing and white lists contain chemicals that may be used. As a summary term we have chosen “Restricted Lists”.
Three examples of “Restricted Lists” are:
1. The RoHS directive of the EU, the European Union. The RoHS directive restricts residual chemicals on electronic products and is strongly linked to the EU WEEE directive mentioned in the waste section guidance. Electronic Products that may be relevant for the hardgoods section includes Consumer equipment, Lighting equipment (including light bulbs, Electronic and electrical tools, Toys, Leisure an Sports equipment, Monitoring and Control instruments). The chemicals that are restricted are:
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent chromium (Cr6+)
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ether (PBDE)
- Bis(2-ethylhexyl) phthalate (DEHP)
- Butyl benzyl phthalate (BBP)
- Dibutyl phthalate (DBP)
- Diisobutyl phthalate (DIBP)
- Maximum Permitted Concentration: 0.1%[5]
- Maximum for Cadmium: 0.01%[5]
2. The GADSL (Global Automotive Declarable Substance list).
3. The ABB List of Prohibited and Restricted Substances.
It is expected that facilities may use either a sector-wide list, a brand-specific restricted list or create their own list.
Beyond the fact that different lists are used in the hardgoods sector, the question about selection and purchasing is also valid for hardgoods facilities.
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes:
- All chemicals meet requirements of MRSL/RSL, and documentation is available to demonstrate this. The ZDHC MRSL conformance levels (1, 2 and 3) from ZDHC Gateway Chemical module should be used for the determination of the conformity of the chemicals and for the development of approved chemicals lists. For more information about the ZDHC MRSL conformance, refer to the ZDHC MRSL Conformance Guidance.
- Facility strategically set up their own chemical MRSL based on their hazards and covering all MRSL and RSL requirements from various brands which they are working with, or alternatively implement a strategy to use compliant chemicals from an active list that covers all MRSL e.g. the bluesign system.
- The facility strategically purchases chemicals that are certified to meet the MRSL and RSL when used appropriately such as bluesign (c) approved chemistry, Ecopassport by OekoTex. These certifications are checked for validity and updated at least annually.
- If above certifications are not available, the facility should purchase chemicals that are declared to meet the MRSL and RSL by the chemical provider, accompanied with analytical/test report to substantiate the declaration conducted at an approved 3rd party laboratory. The declaration and analytical report are checked for validity and updated at least annually.
- The facility has internal purchasing policy that is implemented and includes reference to criteria for the selection and use of dye and chemical suppliers. The purchasing procedures should include (but not limited to): process of communicating MRSL / RSL with the chemical suppliers, process to obtain suppliers’ confirmation/declaration of MRSL / RSL compliance, collection of up-to-date Positive Lists from chemical suppliers, preference to purchase chemicals in Positive Lists, purchase orders with a remark stating that MRSL compliance is mandatory against appropriate version, chemicals technical specifications and acceptance criteria, actions to be taken in case of defects or deviation from requirements are found.
- Purchasing department and management are aware about MRSL and purchasing procedures to ensure requirements are met
- The facility has a certificate of analysis (wherever applicable) from chemical supplier who got the test report from an approved laboratory for MRSL test for the composition including low level contaminants along with an MSDS / SDS andtechnical data sheet. These certificates of analysis are updated at least annually and retained for a year. Technical Data Sheets (TDS) are the documents where the chemical supplier provides the information on how to use the chemical, dosage requirements, conditions required for application process among other information. So it is important that all facilities request the TDS and refer to the information before going for application.
- A tracking / dashboard system to indicate the general level of compliance to the process requirements for the purchasing standard is available to senior executives.
- For chemicals not used in the manufacturing process (example, lubricants, cleaning chemicals…) it might not be feasible to collect certificates of MRSL compliance or certificates of analysis. For those types of chemicals the facility have a process in place to review the list of ingredients against the MRSL / RSL to check if those chemicals are in conformance with those substance lists.
Partial Yes:
- Facility may have non-compliant chemicals, but demonstrate a process for elimination.
- Purchasing department and management are aware about MRSL and purchasing procedures to ensure requirements are met
- The facility generally purchases the chemicals based on the MRSL requirements, which is evidenced by upstream suppliers’ agreement on MRSL, or certificate of conformance, or declaration letters.
- Certificate of MRSL conformance and declaration letters issued by chemical suppliers need to clearly state: date of issuance, name of chemical in concern, the MRSL it is declaring compliance against (attached), and internal chemical test report confirming the conformance.
Facilities that use chemicals in facility tooling and/or operations only:
Yes:
- All chemicals meet requirements MRSL and RSL requirements, and documentation is available to demonstrate this.
- The facility has a process that details the necessary criteria for selection of a chemical / chemical formulation through the use of technical specifications and hazards associated with the purchase.
- Purchasing department and management are aware about MRSL / RSL and purchasing procedures to ensure requirements are met
- For chemicals used in the manufacturing process (example, lubricants, cleaning chemicals…) it might not be feasible to collect certificates of MRSL compliance or certificates of analysis. For these types of chemicals the facility has a process in place to review the list of ingredients against the MRSL / RSL to check if those chemicals are in conformance with those substance lists.
Partial Yes:
- Facility has a process to ensure the compliance of the chemicals against an MRSL / RSL but it is not applied to 100% of the chemicals in the inventory. In such cases the facility must demonstrate a process for obtaining the necessary documentary evidence for MRSL compliance from chemical supplier within a stipulated time frame, or a plan to change to a chemical supplier who comply to the requirement and can submit the necessary documentation/certification.
- Purchasing department and management are aware about MRSL / RSL and purchasing procedures to ensure requirements are met
- The facility generally purchases the chemicals based on the MRSL / RSL requirements, which is evidenced by upstream suppliers’ agreement on MRSL / RSL, or certificate of conformance, or declaration letters.
- Certificate of MRSL / RSL conformance and declaration letters issued by chemical suppliers need to clearly state: date of issuance, name of chemical in concern, the MRSL / RSL it is declaring compliance against (attached), and internal chemical test report confirming the conformance.
Documentation Required:
- Reference requirements for Yes and Partial yes above.
- MRSL(s) applicable to the facility e.g. customer’s MRSL, ZDHC MRSL, facility-own MRSL (either create a combined hazard-based and MRSL from all customers or follow the MRSL which is created to cover all requirements of Brands and Retailers.)
- RSL
- Chemical purchasing procedures and SOPs
- Chemical supplier/vendor criteria
- ZDHC Gateway Chemical module compliance Levels for 1 – 3
- Chemical SDS and TDS
- Certificate of analysis test reports of chemical formulation to check any impurities present in chemical composition
- Certificate of MRSL conformance and declaration letters stating date of issuance, name of chemical in concern, the MRSL it is declaring compliance against (attached), and chemical test report confirming the conformance
- MRSL conformance test reports, where applicable
Interview Questions to Ask:
- Purchasing Manager on knowledge about MRSL and chemical hazards, and purchasing policy and procedures related to MRSL
Inspection – Things to Physically Look For:
- Documents review, e.g. certificates, purchasing policy and procedures, list of chemical suppliers, relevant communications regarding MRSL requirement, purchase agreement with chemical suppliers, vendor criteria, etc.
Where to go for more info (e.g., links or websites):
- https://www.my-aip.com/ZDHCGateway/Login.aspx
- https://uploads-ssl.webflow.com/5c4065f2d6b53e08a1b03de7/5e8de0a3c5077cd5d6846799_Conformance_Guidance_V1_1.pdf
- https://www.roadmaptozero.com/landingpage/chemcheck
- http://www.bluesign.com/
- https://www.oeko-tex.com/de/business/business_home/business_home.xhtml better change into English page as below
- https://www.oeko-tex.com/en/business/business_home/business_home.xhtml
- https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) Letter of appointment, job description, organization chart of the EHS responsible; b) Curriculum Vitae of responsible person/team, experience / training records demonstrating relevant content in chemical management; c) Environmental Health and Safety procedures related to chemical storage, handling, usage, and disposal); d)Chemical Inventory with identified hazards with SDS/ MSDS, technical sheets available to and used by Environmental Health and Safety personnel (skip if previously uploaded); e) Permits with operating limits and relevant laws governing health and safety requirement for chemical storage, operations, and disposal (skip if previously uploaded); f) Chemical incident / accident and spill records (skip if previously uploaded); g) Health and Safety Log (First Aid and health station)
Chemicals health and safety programs must have a designated person or team, meet legal health and safety requirements, and have written procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.
Please select Partial Yes if your chemicals health and safety program is complete, but not yet documented in writing.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices
What is the intent of the question?
This program is intended to protect humans and the environment from exposures. The facility should have a process for identifying and controlling the potential health and safety impact from chemicals stored, used and discarded.
Chemical exposure can occur via many routes. A facility must identify health and safety roles and responsibilities, and appropriate control mechanisms to protect health and safety, and a mechanism to reduce the potential for health and safety impacts. Knowledge of the hazards and routes of exposure from the MSDS/SDS is the starting point for an EHS program.
Technical Guidance:
ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 1 and Chapter 2
Additional Training:
- ZDHC CMS Training
- Chemical management training records with the training content. Chemical management training requirements should be facility specific and cannot be just limited to only few important section elaborations.
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes:
- The facility has a designated person or team dedicated to chemical management with appropriate qualifications to understand and enact appropriate occupational safety and health measures indicated in the MSDS/SDS and/or Technical Data Sheets (TDS) to protect workers, the community and the environment.
- Basic chemical risk assessment has been conducted which involves the identification of the risk and the potential hazard or harm resulting from a specific activity at the facility related to the use of a chemical. For example, using certain chemical in a proposed amount and manner, taken into account the chemical’s possible routes of exposure. The assessment also needs to identify different types of chemical and hazardous waste in production processes that are relevant to the facility that could affect wastewater quality. The chemical risk assessment may be conducted as standalone or as part of environmental assessment report.
- The facility is operating within all permit/law requirements on health and safety related to chemicals with routine monitoring and reporting to senior management.
- There are written procedures for safety and health related to chemical storage, handling, usage, disposal, and basic environmental controls for identified potential environmental impacts from the chemical inventory due to waste or discharge: air, soil, groundwater, noise, waste and sludge, wastewater. The procedures also need to consider the most likely natural disaster in the region, for example, areas prone to heavy rain and flooding, earthquake, typhoon, etc.
- Basic health/wellness process is available on site or through a third party when hazardous chemicals are handled, or exposure occurs.
Partial Yes:
- The facility has a designated person or team dedicated to chemical management with appropriate qualifications to understand and enact appropriate occupational safety and health measures indicated in the MSDS/SDS and/or Technical Data Sheets (SDS) to protect workers, the community and the environment.
- The facility is operating within all permit/law requirements on health and safety related to chemicals with routine monitoring and reporting to senior management.
- The facility has identified potential environmental, health and safety hazards related to its chemical storage, handling, usage, and disposal at some parts of its chemical operation, and the potential hazards are identified correctly based on MSDS and TDS. However, a facility-wide chemical risk assessment has not been conducted.
- There are procedures and followed practices for safety and health related to chemical storage, handling, usage, disposal, and basic environmental controls for the identified potential environmental impacts for chemicals, however it is not written and documented.
Facilities that use chemicals in facility tooling and/or operations only:
Yes:
- The facility has a designated person or team dedicated to chemical management with appropriate qualifications to understand and enact appropriate occupational safety and health measures indicated in the MSDS/SDS and/or Technical Data Sheets (TDS) to protect workers, the community and the environment.
- The facility is operating within all permit/law requirements on health and safety related to chemicals with routine monitoring and reporting to senior management.
- There are written procedures for safety and health related to chemical storage, handling, usage, disposal, and basic environmental controls for identified potential environmental impacts from the chemical inventory due to waste or discharge: air, soil, groundwater, noise, waste and sludge, wastewater. The procedures also need to consider the most likely natural disaster in the region, for example, areas prone to heavy rain and flooding, earthquake, typhoon, etc.
- Basic health/wellness process is available on site or through a third party when hazardous chemicals are handled or exposure occurs.
Partial Yes:
- The facility has a designated person or team dedicated to chemical management with appropriate qualifications to understand and enact appropriate occupational safety and health measures indicated in the MSDS/SDS and/or TechnicalData Sheets (TDS) to protect workers, the community and the environment.
- The facility is operating within all permit/law requirements on health and safety related to chemicals with routine monitoring and reporting to senior management.
- There are procedures and followed practices for safety and health related to chemical storage, handling, usage, disposal, and basic environmental controls for identified potential environmental impacts for chemicals, however it is not written and documented.
Documentation Required:
- Letter of appointment, job description, organization chart
- Curriculum Vitae of responsible person/team
- EHS procedures related to chemical storage, handling, usage, and disposal
- Chemical Inventory with identified hazards with MSDS, technical sheets available to and used by EHS personnel
- Permits with operating limits and relevant laws governing health and safety requirement for chemical storage, operations, and disposal
- Chemical accident and spill records
- Health and Safety Log (First Aid and health station)
Interview Questions to Ask:
- EHS, Chemical Responsible person/team on their understanding of health and safety related to chemical storage, operations, and disposal, and their relevant responsibilities including facility-wide EHS checks/audits, PPEs placements and availability, safety equipment maintenance, emergency response plan, etc. The responsible person also needs to be aware of the most likely natural disaster in the region where the facility is located, for example, areas prone to heavy rain and flooding, earthquake, typhoon, etc., and how these considerations are included in the EHS planning related to chemicals exposure due to natural disasters.
- Health/medical Station, emergency response team (if available)
- Doctor, nurse, health practitioner if available on site
Inspection – Things to Physically Look For:
- Verify responsible person/team is in place and appropriately qualified to manage the EHS program related to chemicals management
- Chemical Inventory with identified hazards with MSDS/SDS, technical sheets are available to the EHS personnel and used as basis of the EHS program e.g. chemical accidents and emergency response plan, safety equipment and PPE placements, workers training, regular check and maintenance of EHS utilities
- Explosion Proof Electrical lights and receptacles available in flammable usage and storage areas
If yes, select all that apply
- The chemical storage area is ventilated, dry and protected from the weather and fire risk.
- The storage area is protected from unauthorized employees (i.e. locked).
- The chemical storage area is clearly marked.
- The chemical storage area has easy entry and exit in case of any emergencies.
- Storage containers are in good condition, appropriate for their contents, closed and clearly labelled with their contents.
- Floor in storage area is solid and non-porous, there are no water drains that the liquid could spill into, and there is no evidence of spilled liquid.
- Secondary containment is available for solid and liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur.
- Incompatible substances (such as strong acids and strong bases) are stored separately.
- Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting.
- Temporary storage containers are closed and labelled with contents, lot, and hazard class.
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) Facility drawing or emergency response plan with local authorities where applicable (skip if previously uploaded); b) Storage/usage permit with restrictions (if applicable); c) Local fire codes; d) MSDS/SDS and technical sheets in local language (skip if previously uploaded); e) Chemical labeling on chemical containers (original labeling, no handwritten labels); f) Floor plan of chemical storage areas, specifying categorization and placements of different types of chemicals; g) Storage in/out log, FIFO records, for each chemical specifying date of arrival at storage, lot number, chemical expiration dates, date of dispatch to production, etc. (skip if previously uploaded); h) Management audits/inspections checklists of chemical storage areas; i) Standard operating procedures for proper chemical storage.
Proper chemical storage is as important to safety as proper chemical handling. Often, seemingly logical storage ideas, such as placing chemicals in alphabetical order, may cause incompatible chemicals to be stored together. Facilities must demonstrate that all storage areas are well-marked and properly managed to prevent contamination and safety risks. Temporary storage happens at the point of work where chemicals are applied, such as a screen-printing station. Temporary storage questions only apply to factories that use chemicals in production processes.
You will be awarded Full Points if you meet all storage criteria.
You will be awarded Partial Points if you meet half of all storage criteria.
Operational Key Performance Indicator: Chemical Handling, Use, & Storage Practices
What is the intent of the question?
The expectation is that a facility can clearly demonstrate that all storage areas are well-marked and properly managed to prevent contamination and safety risks.
Proper chemical storage is as important to safety as proper chemical handling. A facility is home to a considerable range of chemicals requiring safe storage. Chemical storage in a building needs appropriate design to store various hazardous materials in a safe segregated and secure area(s). Often, seemingly logical storage ideas, such as placing chemicals in alphabetical order, may cause incompatible chemicals to be stored together. Storage and quantities must be known to emergency responders, fire brigades, etc. for proper response.
Technical Guidance:
ZDHC Chemical Management System Framework – Version 1.0 (May 2020) – Chapter 3
Templates to Create:
- Emergency Response Plan (template) – available in ZDHC CMS as hyperlink
Where to go for more info (e.g., links or websites):
- ZDHC CMS https://www.roadmaptozero.com/process
- OKOPOL
- German Technical Rules for Hazardous Substances
- GHS
How This Will Be Verified:
Facilities that usechemicals in production processes:
Full Points:
- Chemical storage area (warehouse and temporary storage including underground storage) is ventilated, dry, and protected from the direct exposure of weather (with roof and walls), fire risk, and unauthorized employees i.e. locked. Access permission is clearly defined.
- The chemical storage area has easy entry and exit in case of any emergencies.
- The floor is solid and non-porous, there are no water drains that the chemicals could spill into, and there is no evidence of spilled liquid
- Chemicals are stored to avoid direct contact with floors and walls
- All chemicals at warehouse and temporary storage areas are clearly marked, with each chemical properly identified by visible signage with at least the chemical product name and appropriate hazard warning (Global Harmonization System (GHS) compliant signs, or equivalent) according to the MSDS/SDS
- All chemicals containers in warehouse and temporary storage are in good condition, identified by its original labeling, lot number, product name, supplier/manufacturer name, and hazard class
- Temporary/sub-containers are properly labeled with accurate information consistent with the label on original container
- Different chemicals are properly segregated with appropriate partitions
- Solid and liquid chemicals are properly segregated
- Chemicals are stored in organized manner, categorized by their hazard classifications as shown on its original labels and MSDS/SDS
- Incompatible substances e.g. strong acids, strong bases, corrosives, flammables, etc. are identified and stored separately.
- Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting. All combustible or flammable materials are situated at least ~15 meters (50 feet) from any smoking area
- Expired chemicals are tracked regularly, visibly marked, stored separately, and properly labeled
- MSDS/SDS in language workers understand are readily available at warehouse and temporary storage areas
- Storage conditions such as temperature, moisture, explosion proof fixtures are met according to the MSDS/SDS
- Appropriate PPE and spillage kits are available and easily accessible
- All dyes and chemicals containers in warehouse and temporary storage are properly closed with a lid and are not over stacked
- Secondary containment is available for solid and liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur. The secondary containment is in good condition without cracks or gaps. At a minimum, the capacity of secondary containment should either be at least 110% of the original (primary) container of the chemical, or able to contain at least 10% of the total volume of the original (primary) container.
- Each chemical and dyestuff has individual scoop (or jar, bucket, spoon, etc.) properly labeled specifically for that chemical product.
- Scoops and temporary containers e.g. buckets are made of stable material to avoid corrosion/chemical reaction with the chemical products. It is suggested to avoid containers carrying chemicals which react or leach hazardous chemical residues, i.e. materials consisting of PVC and iron are to be avoided.
- Weighing equipment/tools are placed in a clean, dry, smooth and flat surface
- Facility drawing or emergency response plan is up to date and shared with local authorities where applicable
- There is grounding used where necessary and bonding as needed (fire risk)
- Periodical inspection is in place (weekly recommended)
Partial Points: (meets at least half of the criteria listed below)
- Chemical storage area (warehouse and temporary storage including underground storage) is ventilated, dry, and protected from the direct exposure of weather (with roof and walls), fire risk, and unauthorized employees i.e. locked. Access permission is clearly defined.
- The chemical storage area has easy entry and exit in case of any emergencies.
- The floor is solid and non-porous, there are no water drains that the chemicals could spill into, and there is no evidence of spilled liquid
- Chemicals are stored to avoid direct contact with floors and walls
- All chemicals at warehouse and temporary storage areas are clearly marked, with each chemical properly identified by visible signage with at least the chemical product name and appropriate hazard warning (Global Harmonization System (GHS) compliant signs, or equivalent) according to the MSDS/SDS
- All chemicals containers in warehouse and temporary storage are in good condition, identified by its original labeling, lot number, product name, supplier/manufacturer name, and hazard class
- Temporary/sub-containers are properly labeled with accurate information consistent with the label on original container
- Different chemicals are properly segregated with appropriate partitions
- Solid and liquid chemicals are properly segregated
- Chemicals are stored in organized manner, categorized by their hazard classifications as shown on its original labels and MSDS/SDS
- Incompatible substances e.g. strong acids, strong bases, corrosives, flammables, etc. are identified and stored separately.
- Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting. All combustible or flammable materials are situated at least ~15 meters (50 feet) from any smoking area
- Expired chemicals are tracked regularly, visibly marked, stored separately, and properly labeled
- MSDS/SDS in language workers understand are readily available at warehouse and temporary storage areas
- Storage conditions such as temperature, moisture, explosion proof fixtures are met according to the MSDS/SDS
- Appropriate PPE and spillage kits are available and easily accessible
- All dyes and chemicals containers in warehouse and temporary storage are properly closed with a lid and are not over stacked
- Secondary containment is available for solid and liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur. The secondary containment is in good condition without cracks or gaps. At a minimum, the capacity of secondary containment should either be at least 110% of the original (primary) container of the chemical, or able to contain at least 10% of the total volume of the original (primary) container.
- Each chemical and dyestuff has individual scoop (or jar, bucket, spoon, etc.) properly labeled specifically for that chemical product.
- Scoops and temporary containers e.g. buckets are made of stable material to avoid corrosion/chemical reaction with the chemical products. It is suggested to avoid containers carrying chemicals which react or leach hazardous chemical residues, i.e. materials consisting of PVC and iron are to be avoided.
- Weighing equipment/tools are placed in a clean, dry, smooth and flat surface
- Facility drawing or emergency response plan is up to date and shared with local authorities where applicable
- There is grounding used where necessary and bonding as needed (fire risk)
- Periodical inspection is in place (weekly recommended)
Facilities that use chemicals in facility tooling and/or operations only:
Full Points:
- Chemicals are stored to avoid direct contact with floors and walls
- Chemicals are stored in ventilated, dry condition, and protected from the direct exposure of weather
- Solid and liquid chemicals (where applicable) are properly segregated
- Chemical containers are in good condition, identified by its original labeling and hazard class
- Flammable substances (where applicable) are kept away from sources of heat or ignition. All combustible or flammable materials are situated at least ~15 meters (50 feet) from any smoking area
- Secondary containment is available (where applicable) to ensure no unintended releases occur. The secondary containment is in good condition without cracks or gaps. At a minimum, the capacity of secondary containment should either be at least 110% of the original (primary) container of the chemical, or able to contain at least 10% of the total volume of the original (primary) container.
- MSDS/SDS (where applicable) or other hazard communication in language workers understand are readily available/visible
- Appropriate PPE are available and easily accessible (where applicable)
- Facility drawing or emergency response plan is up to date and shared with local authorities where applicable
- Facility has a monitoring program for their subcontractors’ chemical storage management.
Partial Points:(meets at least half of the criteria listed below)
- Chemicals are stored to avoid direct contact with floors and walls
- Chemicals are stored in ventilated, dry condition, and protected from the direct exposure of weather
- Solid and liquid chemicals (where applicable) are properly segregated
- Chemical containers are in good condition, identified by its original labeling and hazard class
- Flammable substances (where applicable) are kept away from sources of heat or ignition. All combustible or flammable materials are situated at least ~15 meters (50 feet) from any smoking area
- Secondary containment is available (where applicable) to ensure no unintended releases occur. The secondary containment is in good condition without cracks or gaps. At a minimum, the capacity of secondary containment should either be at least 110% of the original (primary) container of the chemical, or able to contain at least 10% of the total volume of the original (primary) container.
- MSDS/SDS (where applicable) or other hazard communication in language workers understand are readily available/visible
- Appropriate PPE are available and easily accessible (where applicable)
- Facility drawing or emergency response plan is up to date and shared with local authorities where applicable
Documentation Required:
- Facility drawing or emergency response plan with local authorities where applicable
- Storage/usage permit with restrictions (if apply)
- Local fire codes
- MSDS/SDS and technical sheets in local language
- Chemical labeling on chemical containers (original labeling, no handwritten labels)
- Floor plan of chemical storage areas, specifying categorization and placements of different types of chemicals
- Storage in/out log, FIFO records, for each chemical specifying date of arrival at storage, lot number, chemical expiration dates, date of dispatch to production, etc.
- Management audits/inspections checklists of chemical storage areas
- Standard Operating procedures for proper chemical storage
Interview Questions to Ask:
- Check understanding of the supervisor in charge, and workers for familiarity with MSDS/SDS, CLP.
- Can they explain the hazard classification for several chemicals in their work area?
- Check their understanding of several hazard symbols and storage compatibility.
Inspection – Things to Physically Look For:
- Facility drawing or emergency response plan is up to date and shared with local authorities where applicable
- Check all relevant areas where chemicals are used and stored, including: warehouse, temporary storage areas, in-house laboratory, chemical recipe mixing areas, workshop/production floor, ETP.
- Chemicals are properly labeled (original labeling, no handwritten labels) and appropriately segregated, stored off floor, etc.
- Storage condition meets requirement (roof, walls, floors, segregation criteria met based on hazard class, risk, compatibility, forms (solid vs. liquid), storage conditions e.g. special storage conditions such as temperature, moisture, explosion proof fixtures, etc.)
- Access permission and hazard warning signage
- MSDS/SDS in language workers understand are readily available, up-to-date, and accurately translated; check if signage is clearly visible and matching with chemicals stored and its MSDS/SDS – check at least 5 at each location
- Secondary containment is available and appropriate
- Check hazardous waste and sludge storage and containment areas
- Check general housekeeping and organization/categorization of chemicals, chemical containers integrity e.g. tank or drum, etc, expiration dates on chemicals
- Containers are not modified to facilitate chemicals dispense
- Containers are appropriately closed with a lid
- All weighing equipment and accessory (is dust being created during handling and weighing procedures?)
- Check scoops and buckets i.e. does it include the name of the product they are used for
- Check PPE usage and availability and maintenance record where applicable
- Ask for a demo of at least 3 different chemicals and check if each chemical has its own handling and weighing accessory labeled with the name of the product they are used for. During that demo, verifier should check if they weigh the different chemicals of a mixture independently.
- Take pictures of storage areas
- Periodical inspection record
Please select all topics included in your training: MRSL ; RSL
Please describe the RSL and MRSL trainings conducted in the last calendar year
How many employees were trained?
How frequently do you train your employees?
Suggested upload: MRSL/RSL training record(s) with names, date, topic of training, brief description of what was trained
MRSL and RSL trainings must be conducted by a knowledgeable employee and come with documentation showing who, when, where, and how they were trained on MRSL and RSL.
Additional documentation will be requested during verification: Job Descriptions.
Select Partial Yes if training has been provided but is not yet well-documented.
Operational Key Performance Indicator: Employee Training & Communication
What is the intent of the question?
Before we jump to requiring compliance with RSL, MRSL, we must first introduce the topic and reasoning to workers so a program can be effectively implemented. The facility should hold trainings to ensure that the personnel responsible for MRSL/RSL compliance are competent through appropriate education, training and/or experience.
All facilities should ban non-compliant hazardous chemicals used in the facility due to legislations, regulations, or customers’ requirements (such as Manufacturing RSL (MRSL) from the ZDHC). However, before we jump to requiring compliance with banned operating chemicals, we must first educate by introducing the topic and reasoning to workers so a program can be effectively implemented.
Chemicals and chemical handling are key essentials of chemical management and workplace safety. MRSL/RSL is just one aspect in a full chemical management process when dealing with chemicals, their proper application for function, and their potential hazardous properties to the worker and in the workplace.
Technical Guidance:
Training of MRSL/RSL in Chemical management should cover the possible source(s) of hazardous chemicals in the facility with complete analysis of risks from the full chemical inventory and available stock. The facility should be in the position to carry out a ROOT Cause analysis in case of any non-compliance detected
Where to go for more info:
https://mrsl.roadmaptozero.com/MRSL2_0
http://afirm-group.com/afirm-rsl/
https://www.aafaglobal.org/AAFA/Solutions_Pages/Restricted_Substance_List
How This Will Be Verified:
Facility that uses chemicals in production processes:
Yes
- There is a designated person(s) responsible for chemical management, MRSL and RSL compliance, identified by formal job description, including but not limited to: purchasing, production line and technical managers.
- There is a formal system of training that documents who, when, where, and how they were trained on MRSL and RSL.
- Designated person(s) responsible for chemical management are knowledgeable regarding MRSL and RSL (through interview)
Partial Yes
- Scenario 1:
- There is a designated person(s) responsible for chemical management, MRSL and RSL compliance, identified by formal job description, including but not limited to: purchasing, production line and technical managers.
- MRSL and RSL training has been provided but not well documented.
- Scenario 2:
- There is a designated person(s) responsible for chemical management identified by formal job description, including but not limited to: purchasing, production line and technical managers.
- Training has been provided and well documented but designated person(s) is still not knowledgeable regarding MRSL and RSL.
Documentation Required:
- Job Descriptions
- Training record(s) with names, date, topic of training, brief description of what was trained
- Interview / dialogue with management or key employees (including but not limited to purchasing, production line and technical managers):
- Check the understanding of the responsible person
- Difference between MRSL and RSL
- Examples of few (minimum of 5) MRSL parameters
- Different MRSL limits for certain parameter (random pick) – what it means and how to manage it
- Which is the main restricted substance derived from dyestuff. (only for printing/dyeing facilities)
- Where would they find information regarding MRSL or RSL compliant information
- Can they provide one example of a recipe card linked to technical sheet for proper usage
- Knowledge of MRSL document, how it works and they understand the consequences of using product included in the list
Inspection – Things to Physically Look For:
- Review Training Material and Logs
- Job description review.
- Conduct interviews with all designated person(s).
- Ensure purchasing, production line and technical managers are trained.
Does your facility have a failure resolution process that is followed in the event of an RSL test failure?
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) Technical Data/Specification sheets (TDS) for all chemicals; b) Recipes for processes where chemicals are used; c) Purchased materials list with Letter of Compliance to RSL for all chemicals and guidance from chemical suppliers on safe limits to use; d) documented procedure to systematically identify, monitor and verify compliance with all product Restricted Substance Lists (RSLs)
Facilities must incorporate an industry standard such as an AFIRM, AAFA, or major customer RSL(s) into their business practices. Please answer Yes if you can verify RSL compliance by providing evidence of your RSL review process and technical data sheets, inventories that meet RSL requirements, and by providing Letters of RSL Conformance, and/or product test results.
Answer Partial Yes if you can prove RSL conformance but do not yet have an internal review process to systematically monitor RSL
Operational Key Performance Indicator: Chemical Management Policies, Compliance Procedures, and Commitments
What is the intent of the question?
The expectation is for facilities to incorporate an industry standard such as an AFIRM, AAFA, or major customer RSL(s) into their business practices. When chemicals are used in a process they should comply to Technical Data Sheet (TDS) requirement(s) that are necessary to achieve the desired RSL outcome. The RSL process should be formally documented in some written form and updated on an annual basis.
RSL compliance is important to ensure that the product being created will protect and consumer’s health and safety as well as comply with relevant chemical regulations in every jurisdiction where products are created or sold. MRSL compliant chemicals must be used in accordance with technical specification directions to meet RSL material compliance outcomes.
Technical Guidance:
A complete document containing the Risk Assessment for RSL and MRSL should be present in the facility and can be prepared on basis of the chemical inventory and the SDS/MSDS information along with the documents provided by the chemical suppliers such as Technical Data Sheets, Certificate of Analysis, Certificate of Conformance, Test reports etc., The risk assessment document should identify the components present in the composition of the chemical formulation and its concentration levels, any unintentional component present due to the process route or source of chemical and also evaluate the possible risks from the process route of production or during the wastewater treatment etc.
Reference lists for RSL and/MRSL include:
- REACH SVHC Level 1
- RoHS
- Prop 65
- ZDHC priority 11
- AFIRM
- AAFA
- BLUESIGN® System Substance List
- OekoTex 100
- ZDHC MRSL (most updated version)
Other References:
- ZDHC Chemical Management System Framework – Version 1;0 (May 2020) – Chapter 3, 5 & 8
- Product technical guidance documents from the chemical supplier
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes
- The facility or its parent/corporate group can provide a written document specifying a review process that monitors, updates and show compliance to a RSL.
- Process recipes should consider the usage of chemicals according to each Technical Data Sheet (TDS) to ensure compliance to RSL i.e. chemicals in process recipe should not exceed the concentrations as suggested by the chemical manufacturer.
- All chemicals in the Chemical Inventory are checked against RSL compliance at least on annual basis.
- The facility or its parent/corporate group can provide Letters of RSL Conformance supported with test/analysis results for all relevant chemicals.
- RSL has been formally communicated to upstream suppliers i.e. chemical suppliers, raw material suppliers, process subcontractors (e.g. washing, finishing, printing)
- Procedure or process to verify the products complies with RSLs such as testing according to customer’s requirement, or having a program to test the products based on factories’ own risk assessment (the focus should be the procedure and process)
- The facility or its parent/corporate group should ensure that all the raw materials (yarn, fabric etc.,) are in compliance with the MRSL / RSL.
Partial Yes
- Process recipes should consider the usage of chemicals according to each Technical Data Sheet (TDS) to ensure compliance to RSL i.e. chemicals in process recipe should not exceed the concentrations as suggested by the chemical manufacturer.
- The facility or its parent/corporate group can provide Letters of RSL Conformance supported with test/analysis result for all relevant chemicals.
- The facility or its parent/corporate group has procedures related to the use of customers RSL in its chemical purchasing and operations, however it does not have a written document specifying a full review process that monitors, updates and show compliance to a RSL.
Documentation Required:
- Technical Data/Specification sheets (TDS) for all chemicals.
- Recipes for processes where chemicals are used.
- Purchased materials list with Letter of Compliance to RSL for all chemicals.
- Chemical inventory – verify all chemicals are covered and checked for RSL compliance at least on annual basis, check the dates of previous check.
Interview Questions to Ask:
- Interviewees demonstrate basic knowledge of RSL and how to perform a compliance check to ensure usage against a Technical Data Sheet (TDS) with linkage to recipe cards.
- Ask relevant employees (e.g. lab manager, production manager, EHS manager, purchasing, etc.) about how the facility is keeping track of RSLs of different customers and the RSL updates, how RSL is communicated and internalized. Check alignment of understanding amongst internal stakeholders across functions.
Inspection – Things to Physically Look For:
- Check RSL(s) the facility is working with, how the facility is keeping track of RSLs and RSL updates, how RSL is communicated and internalized.
- Availability of Technical Data Sheets (TDS) for all relevant chemicals at appropriate areas e.g. lab, chemical mixing.
- Formal communication trail with upstream suppliers regarding RSL i.e. chemical suppliers, raw material suppliers, process subcontractors (e.g. washing, finishing, printing)
- Availability of letter of RSL conformance supported with test/analysis result for relevant chemicals
- Visual observation of work processes for determining chemical composition in recipe cards and / or materials, the process should incorporate the reference of TDS to ensure conformance against RSL. Chemicals e.g. dyestuffs and pigments recipes should not exceed the concentrations suggested by chemical manufacturers with reference to the intended usage/processes and any specific combinations to avoid.
- Check process of at least an annual update for RSL conformance check against all chemicals in Chemical Inventory.
Where to go for more info:
Does your facility require its chemicals suppliers to do the same?
Does your facility require its washing and printing subcontractors to do the same?
Please describe these processes
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) Chemical Inventory (skip if previously uploaded); b) Chemical review policy and process flow; c) List of chemicals which do not have full documentation conforming MRSL compliance; d) Plan for obtaining appropriate documentation for chemicals which currently do not contain documentation e) MRSLs applicable to the facility e.g. own MRSL, customers’ MRSL, or ZDHC MRSL; f) Positive lists from chemical suppliers (skip if previously uploaded); g) Email communication or communication trail between facility and its chemical suppliers and subcontractors (if any) regarding MRSL compliance; h) Letter of compliance to MRSL with chemical name, date of issuance, and test reports; i) Documented periodical screening process against ZDHC Gateway – Chemical Module (where applicable, ZDHC Performance InCheck) and the Level of Conformance of each chemical screened. Dated records of previous screenings and schedule of future screening.
Facilities must incorporate an MRSL into their business practices. Establishing an effective MRSL program is complicated and may take several years to fully implement in your factory.
Operational Key Performance Indicator: Chemical Management Policies, Compliance Procedures, and Commitments
What is the intent of the question?
The intended behavior for this question is for facilities to understand MRSLs, which should be used to enable compliant chemical purchases and chemical inventory within the facility, its contractors and subcontractors. The process should be formally documented in some written form and updated on an annual basis. One example of an MRSL with strong industry support is the ZDHC MRSL, which you can find more information about here: https://mrsl.roadmaptozero.com/MRSL2_0
Facilities typically are aware of Restricted Substance Lists (RSL); however, the industry has recently evolved to focus on Manufacturing Restricted Substance Lists (MRSL) to further environmentally friendly chemical use in addition to Restricted Substance Lists. MRSL is important because a facility that uses compliant chemicals, in accordance with technical specification directions, have better environmental outcomes for the various facility discharges and more consistent RSL material compliance. The objective is important for the full facility supply value chain (contractors, subcontractors, upstream suppliers, etc.).
Technical Guidance:
The ZDHC MRSL (latest version) is the global apparel, footwear, and textile industry recognized chemical MRSL standard for the chemical supply industry and major retail brands. The MRSL must be communicated up and down the supply value chain.
For all products which are considered to be MRSL compliant, there must be appropriate process for validating the MRSL present in the facility.
The process of engaging the subcontractors should involve subcontractor selection, evaluation and management which essentially includes the same processes that the facility is following in order to meet all MRSL compliances and chemical management practices. Hence, communication, evaluation of the performance towards chemical management practices is the responsibility of the facility towards subcontractors.
Glossary:
ZDHC MRSL: The ZDHC MRSL is a list of chemical substances subject to a usage ban (see Usage Ban, page 2). The MRSL applies to chemicals used in facilities that process materials and trim parts for use in apparel and footwear. Chemicals in the ZDHC MRSL include solvents, cleaners, adhesives, paints, inks, detergents, dyes, colorants, auxiliaries, coatings and finishing agents used during raw material production, wet-processing, maintenance, wastewater treatment, sanitation and pest control. Source:https://www.roadmaptozero.com/
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes
- The facility or its parent/corporate group can demonstrate a well-documented (written) chemical review process that monitors, updates and shows compliance to legislations, customer MRSL requirements, or the ZDHC MRSL as a standard for the facility, subcontractors and contractors.
- The chemical review process against MRSL is aligned and managed properly across functions in the facility (management, purchasing, lab, production teams) and external parties (subcontractors, suppliers, testing agency, etc.) and responsibilities are assigned properly
- The process should also demonstrate how chemicals are reviewed / checked against the MRSL prior to purchase.
- Chemical review process/methods are robust, i.e. periodical screening through the ZDHC Gateway – Chemical Module (with ZDHC Performance InCheck when possible), certification/Letter of Compliance to MRSL specific to each chemical product with test data/report to support the claim, or adoption of systems that ensures MRSL conformance e.g. Bluesign, etc. When non-conforming chemicals are found, a phase out plan is developed accordingly. When ZDHC Gateway – Chemical Module is used for screening, the facility tracks and monitors the Level of Conformance of each chemical screened.
- The facility or its parent/corporate group actively communicates the expectations to their dye and chemical suppliers that formulations supplied to the facility need to be compliant with MRSL
- The facility or its parent/corporate group can demonstrate that the expectation of MRSL compliance is actively communicated to the upstream supply base and monitored on at least an annual basis, including subcontracted processing units i.e. washing, printing (if applicable).
- The facility or its parent/corporate group actively asks and monitors MRSL compliance of its suppliers and screen it against Chemical Inventory List (CIL).
Partial Yes
- The facility or its parent/corporate group monitors policies regarding banned chemicals based on legislation, regulation, or customers’ requirements applicable to the facility
- The facility or its parent/corporate group is able to provide a Letters of Compliance to MRSL with test data/report to support the claim, for each manufacturing and tooling/equipment chemicals which is updated on an annual basis, but does not have a formal (documented/written) chemical review process.
- The facility or its parent/corporate group has a formal chemical review process, but it is not well implemented and not aligned/managed properly across functions in the facility
- The facility or its parent/corporate group has a formal chemical review process, but it is not robust e.g. Letters of Compliance only containing a statement/declaration letter without any test report/data to support the claims, or ZDHC Gateway – Chemical Module is used to screen chemicals but level of conformance are not tracked or there is no phase out plan for the non-conforming chemicals found.
- The facility or its parent/corporate group communicates the MRSL compliance expectations to dye and chemical suppliers but not to subcontracted processing units (if applicable)
- The facility or its parent/corporate group can demonstrate that the expectation of MRSL compliance is communicated to the upstream supply base including subcontracted processing units i.e. washing, printing, but not monitored on at least an annual basis (if applicable).
Documentation Required:
Please reference applicability with sections for yes and partial yes for requirements.
- Chemical Inventory List (CIL)
- Chemical review policy and process flow
- List of non-conforming chemicals
- Phase out plan for non-conforming chemicals, if any
- MRSLs applicable to the facility e.g. own MRSL, customers’ MRSL, or ZDHC MRSL
- ZDHC tools for MRSL checks (InCheck Reports, ChemCheck)
- Positive lists from chemical suppliers
- Email communication or communication trail between facility and its chemical suppliers and subcontractors (if any) regarding MRSL compliance
- Letter of compliance to MRSL with chemical name, date of issuance, and test reports
- Documented periodical screening process against ZDHC Gateway – Chemical Module (where applicable) and the Level of Conformance of each chemical screened. Dated records of previous screenings and schedule of future screening.
Interview Questions to Ask:
- Interviewees demonstrate basic knowledge of MRSL and how to perform a compliance check or obtain Letters of Compliance as appropriate.
- Do they understand the consequences of using products not included in the MRSL?
Inspection – Things to Physically Look For:
- A visual verification of several work processes for use of chemicals or materials against the supplied inventory list.
- Check the chemical review process to determine whether the MRSL review and/or Letter of Compliance is robust and performed periodically (at least annual), and is consistent with chemical purchase list and inventory.
Suggested uploads: a) Recipe cards, chemical formulation sheets, and process instructions (where applicable), containing all traceable information (i.e. chemical name and available quantity); b) Chemical Inventory (skip if previously uploaded); c) Chemical mixing process log, lab records (e.g. color lab, washing lab, etc.)
Chemicals traceability is necessary so that a facility can trace the source of a RSL and/or MRSL failure and take action.
Reference: ZDHC Chemical Management System Framework – Version 1 (May 2020) – Chapter 1, 5 & 8
Answer Yes only if your facility can trace all chemicals in production recipes back to the chemical inventory.
Answer Partial Yes if only some of the chemicals in production recipes can be traced back to the chemical inventory
Operational Key Performance Indicator: Product Quality / Integrity
What is the intent of the question?
- The purpose of traceability is determining whether the chemical components involved in the production can be traced “backward” (Pick out a finished product, whether it is possible to trace the chemical components that are used to produce that particular finished product), and “forward” (Pick out a chemical, whether it is possible to identify all the particular finished products that are produced by using that particular chemical)
- Ability to do so, would help support root cause investigations in case any quality or compliance issue occurred due to any particular chemical
- If a recall of a product is needed, it is possible to recall the particular chemical that are involved
In Level 1, the facility should have a traceability of chemicals used in each manufacturing processes up to the chemical inventory. In other words, the facility should track: (1) the chemicals available on-site (inventoried); (2) the production recipe sheets, where each chemical used in every production step that involve chemicals is listed. These will demonstrate that you know how and where chemicals are used in your facility operations (which processes), and these chemicals are properly documented and monitored facility-wide.
Chemicals traceability is necessary to track what chemicals are used and when, so that a facility can assess the source of a RSL (for Product) and/or MRSL (for process input chemicals) failure and take action. Your facility’s ability to track the chemicals used and to trace chemicals through all processes within the facility can start simply with a good coordination of the existing documentation currently used for production, and eventually progress to a more advanced, detailed tracking over time.
The focus of this question is on having documented records of the manufacturing processes, production recipes, the chemical formulations, and amounts (quantity) used to make a product. These records should demonstrate linkage between the information contained in facility’s chemical inventory (i.e. chemical / formulation trade name, lot number, MRSL and RSL compliance) and each chemical that are actually used in every processing step through to a final product.
Technical Guidance:
A recipeis: a record of the chemical formulations used to make the product or material and its quantities/composition (e.g., all formulations used in the making of a blue t-shirt)
A formulation is: a chemical product you purchase from a chemicals supplier (e.g., one colorant for a blue t-shirt).
A substance is: the individual chemicals that makeup that formulation (e.g., the one dye and 3 binding agents in that colorant).
Chemical formulations or “chemicals”: the individual chemical product or ‘ingredients’ listed in Production Recipes and used in manufacturing processes to make a final product/material at the Facility. These chemicals also need to be included in the facility Chemical Inventory. They may be complex formulations, dyestuffs, auxiliaries, finishing chemicals, etc. provided by chemical suppliers that are made up of one or more chemical substances. This is important to clarify as textile mills procure “chemical formulations” which may not have details of what the individual chemical substances are.
Production Recipe or “recipe”: the recipe sheet that documents the chemicals and the process conditions to be used to make Product/Material. A record of the actual chemicals used and process conditions should be kept for all processes and the Product/Material manufactured. Details of “chemical formulation needs” and processing steps/parameters to meet the material/product specification should be tracked. Documented production recipe is needed for consistent reproducibility from batch to batch.
Chemical Inventory: a chemical “formulation” inventory needs to be maintained on-hand and replenished to “match” the recipe needs. Any alteration to the recipe must be noted and reconciled with an update to the inventory requirements. Likewise, any substitution in the inventory must be approved for use to meet the recipe requirements. Any changes to recipe and/or inventory should be noted and communicated to Production and QA Teams to ensure the final commercial product specifications will still be met.
Process Instructions – every process in the facility must have documentation that describes the operating conditions and controls required to successfully make Product/Material – a record of the actual process conditions should be kept for all Product/Material manufactured in the facility
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes
- All processes that a product went through that involves usage of chemical are identified and the corresponding recipe and batch cards at each process are available and retained.
- Wherever chemicals are used there are written instructions for their proper use including recipe cards, process instructions (where applicable), formulation sheets, containing all traceable information i.e. chemical name, lot number, and quantity, which can be linked back to the facility-wide chemical inventory.
- Major production processes and each chemical used and its respective quantities are covered, and the process instruction including control parameters and checkpoints are in place.
- Where internal blending / mixing of chemicals take place the process has been documented.
- Chemicals listed in each production recipe at each manufacturing step can be traced consistently to relevant records, including chemical mixing process log, lab records (e.g. color lab, washing lab) where applicable, and the chemical information is also recorded in the chemical inventory i.e. chemical / formulation name, lot number, MRSL and RSL compliance etc. (please refer to ZDHC CIL and ZDHC CMS Framework version 1.0 – Chapter 5 for expectations related to chemical inventory).
Partial Yes
- All processes that a product went through that involves usage of chemical are identified and the corresponding recipe and batch cards at each process are available and retained.
- Scenario 1: Wherever chemicals are used there are written instructions for their proper use including recipe cards, process instructions (where applicable), formulation sheets, containing all traceable information i.e. chemical name, lot number, and quantity, which can be linked back to the chemical inventory. The information contained in chemical inventory is incomplete or the chemical inventory is not up-to-date (please refer to ZDHC CIL and ZDHC CMS Framework version 1.0 – Chapter 5 for expectations related to chemical inventory).
- Scenario 2: Only some part (not all) of the manufacturing processes/steps where chemicals are used have written instructions for their proper use including recipe cards, process adjustment instructions (where applicable), formulation sheets, containing all traceable information i.e. chemical name, lot number, and quantity, which can be linked back to the chemical inventory.
Documentation Required:
- Recipe cards, chemical formulation sheets, process instructions (where applicable), containing all traceable information i.e. chemical name, available quantity, and lot number
- Chemical Inventory (please refer to ZDHC CIL and ZDHC CMS Framework version 1.0 – Chapter 5 for expectations related to chemical inventory)
- Chemical mixing process log, lab records (e.g. color lab, washing lab, etc.)
Interview Questions to Ask:
- Managers/workers can demonstrate a documented traceable and trackable system back to an MRSL compliant inventory
- Workers understand the content and know the important content for a process recipe, especially for washing, printing, or finishing where applicable
Inspection – Things to Physically Look For:
- Perform a random check of 1-2 products currently in manufacturing line on-site, and find out which processes that the product undergoes that involves usage of chemicals e.g. dyeing, printing, washing, finishing, etc. Check the corresponding recipe and batch cards at each process identified.
- Random pick 3-4 chemicals in the recipe/batch cards identified in each process to trace up to the chemical mixing area (“kitchen”), chemical lab (where applicable), and chemical storage areas (temporary/warehouse), then up to the chemical inventory.
- Check whether the linkage between the chemicals used in the processes and chemical inventory can be established and are properly documented.
- Review of records: process/production records i.e. recipe cards, chemical formulation sheets, process instructions (where applicable), containing all traceable information i.e. chemical name, quantity, and lot number. Check chemical mixing process log, lab records (e.g. color lab, washing lab, etc.) where applicable, for consistent information. Cross check information with chemical Inventory (please refer to ZDHC CIL and ZDHC CMS Framework version 1.0 – Chapter 5 for expectations related to chemical inventory).
Chemical Management – Level 2
Questions
Suggested upload: Documented plan for achieving full completion of Level 1 requirements. This plan should include: a) Which questions were not fully achieved why; b) People responsible and a targeted date for achieving requirements for those questions which were not met.
It may take many facilities years to fully complete all Level 1 requirements for a robust chemicals management program. If you have a plan for achieving full completion of Level 1 requirements, please upload it here.
Operational Key Performance Indicator: all
What is the intent of the question?
Considering that relatively few facilities are expected to meet all level 1 chemical management criteria, the most important behavior that level 2 questions are intended to drive is the development and the implementation of a plan to improve the existing chemical management practices intended to progressively reach the minimum regulatory and industry expectations (Level 1).
This question aims at capturing the ability for facilities to develop an action plan in order to improve the existing chemical management system in place.
Technical Guidance:
The foundation of an effective chemicals management program depends on the establishment of policies and procedures to appropriately manage chemicals throughout their life cycle. For each stage in the life cycle, policies and procedures that define legal and other requirements, responsible persons, and appropriate work practices and controls need to be developed. Chemical management program consistent with the commitment to continual improvement. And in order to sustain continual improvements in overall chemical management performance, it is utmost important to work on the corrective actions /findings by internal /external chemical management assessment.
How This Will Be Verified:
Yes:
Documentation Required:
- Documented plan in place to complete all requirements for every question in level 1
- Documented should include which questions were not achieved with a full yes and why
- Documented plan should include persons responsible and a targeted date for achieving full yes responses for those questions which were not met
Interview Questions to Ask:
- Management and key employees are familiar with the plan and can speak to the various steps for achieving a full yes response to level 1 questions in the chemicals management section
Inspection – Things to Physically Look For:
- Have the facility walk you through the plan to ensure they are implementing the said actions in plan 2-3 items.
- Take photos of any equipment /logs that support the action plan
Suggested upload: a) A hazardous chemical(s) list with an action plan with assigned responsibilities and a timeframe for action; b) Alternative chemical trials in laboratory or pilot facility documents with conclusions to proceed or decline.
Having hazardous chemicals does not mean that you have violated RSL or MRSL; your facility may have hazardous chemicals that are permitted on-site but that must be handled appropriately and eventually phased out.
Operational Key Performance Indicator: Chemicals & Process Innovation
What is the intent of the question?
Removal of hazardous chemicals through the intentional setting of an action plan with targets, assigned responsibilities and a timeframe for action.
This question encourages facilities to be proactive in identifying hazards and working to reduce beyond what is already restricted by MRSL or RSL. This question does not require facilities to have in-house expertise to do detailed hazard assessments. Factories can have hazard implementation plans by relying on lists via guidance. This excludes implementation plans for addressing non-compliances against RSL/MRSL/regulatory – those are captured in Level 1.
For example, if a facility is currently following an industry or brand’s specific MRSL/RSL, this facility may also proactively search to phase out other substances which are listed in candidate list of ZDHC MRSL or SIN LIST etc., that are not included in the list they are following. They can find these substances in other industry list’s and start working on phasing out these substances from production before it is restricted by the MRSL/RSL that they follow. As alternatives to these phased out substances, the facility may look into chemicals products that are identified in available industry databases, such as ZDHC Gateway – Chemical Module or any other brand specific sources.
In scope: All production chemicals, focus on on-product chemicals for a cut and sew operation (the most important behavior is impact on product – should move toward using lists of pre-screened chemicals)
Out of scope: Chemicals which are not focused on the product such as,cleaners, chemicals in cooling tower/boiler excluded.
Technical Guidance:
The facility should identify the hazardous chemicals which are not considered in RSL or MRSL but also consider chemical substances which go beyond these lists. The reference lists and tools that identify hazardous substances and/or chemicals of concern beyond MRSL and RSL include the following but are not limited to:
- ZDHC MRSL Candidate List – https://mrsl.roadmaptozero.com/MRSL2_0
- Stockholm Convention on Persistent Organic Pollutants
- ChemSec SIN list
- Washington State Reporting List of Chemicals of High Concern to Children (CHCC)
- Subsport European platform (http://Subsport.eu)
- SVHC (Substance of very high concern) (https://echa.europa.eu/candidate-list-table)
- Other relevant list for the activity of the facility, such as Bluesign BSSL, GOTS
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes
- Implementation plan includes goals, targets, action plan, and actions taken.
- The facility has identified the list of chemicals currently in use that contains or may contain hazardous chemicals or MRSL substances
- A hazardous chemical(s) list with an action plan with assigned responsibilities and a timeframe for action. The action plan should contain:
- name of the chemical;
- hazardous substance contained;
- exposure assessment involving estimating the intensity, frequency, duration, and route of exposure to a substance;
- action items to phase out usage of such chemical and respective timelines;
- list of alternative/substitute chemicals to be used;
- timeline for phase-out completion;
- monitoring procedure for the alternatives and its performance.
Partial Yes
- Implementation plan with action checklists but not backed up by strategy (goals, targets, plan, etc.)
- No active list; laboratory / pilot production records exist for alternative trials.
Facility that uses chemicals in facility tooling and/or operations only:
Yes
- Implementation plan includes goals, targets, action plan, and actions taken.
- A hazardous chemical(s) list with an action plan with assigned responsibilities and a timeframe for action.
Partial Yes
- Implementation plan with action checklists but not backed up by strategy (goals, targets, plan, etc.)
- No active list; laboratory / pilot production records exist for alternative trials.
Documentation Required:
- A hazardous chemical(s) list with an action plan with assigned responsibilities and a timeframe for action.
- Alternative chemical trials in laboratory or pilot facility documents with conclusions to proceed or decline.
Interview Questions to Ask:
- Senior Management, EHS Manager, Chemical Manager and/or responsible individual(s)
Inspection – Things to Physically Look For:
- Review of active plan or alternative chemical evaluation process i.e. laboratory, pilot facility documents
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) Demonstrate access to a positive list (example: BLUESIGN® bluefinder license); b) Chemical inventory listing the chemical formulations and the corresponding chemical supplier – chemicals sourced from a positive list should be identified in the chemical inventory (skip if previously uploaded); c) Purchasing support documents; d) Purchasing contract language to support sourcing chemicals from positive lists; e) Process documentation to identify internal and external responsibilities
For facilities that use chemicals in production:
Answer Yes only if more than 50% of the chemical formulations in the chemical inventory (% based on the number of chemicals, not the volume) are sourced from a positive list such as ZDHC Chemical Gateway, BLUESIGN®, GOTS, and/or OEKO-TEX® Eco Passport.
Answer Partial Yes if you have chemicals from a positives list that make up less than 50% of your inventory
For facilities that do not use chemicals in production:
Answer Yes only if more than 10% of the chemical formulations in the chemical inventory (% based on the number of chemicals, not the volume) are sourced from a positive list such as ZDHC MRSL Level 3, BLUESIGN®, GOTS, and/or OEKO-TEX® C2C certified, Chem iQ screen allowed chemicals, etc.
Answer Partial Yes if you have chemicals from a positives list that make up less than 10% of your inventory.
Operational Key Performance Indicator: Chemical Selection, Procurement, & Purchasing Practices
What is the intent of the question?
This question is intended to reward manufacturers who proactively seek chemicals with fewer hazards and risks to replace chemistry that poses greater danger to humans and our environment. These programs typically go above and beyond MRSLs and RSLs which are focused around regulatory risk.
Substitution of hazardous chemicals is a fundamental measure to reduce risks to environment, workers, consumers and public health. Several brand-driven and third-party programs exist to identify positive substitutes. Purchasing chemical formulations from reliable positive lists is a cost-effective approach to ensure that chemicals purchased do not contain hazardous substances. Driving demand for these substitutes, and green chemistry innovation as a whole, is an important driver for the overall improvement of the sustainability performance of the textile and footwear industry.
Technical Guidance:
It is important to note that positive lists are developed by screening the composition of specific formulation to identify hazardous substances. Positive lists should consider the assessment of the composition of the chemicals used in the formulation as well as an evaluation of the quality process in place in the facilities that manufacture these chemicals. This second aspect is key to ensure that the composition of the chemical formulation is consistent over time and that the risk of finding unwanted impurities is limited. Information related to the composition of the chemical mixture available in Safety Data Sheets should not be used (only) for the development of positive lists as the level of detail available in SDSs usually do not identify impurities or substances non intentionally added that can often be the source of the non-compliance with an RSL or an MRSL.
Some positive lists to consider are:
References:
- BLUESIGN® bluefinder (Any chemistry that is bluesign® approved may be considered part of a positive list – this includes both blue or grey rated chemistry.)
- ZDHC MRSL Level 3 (with production stewardship)
- Full material disclosure with Tox assessment
- Customer supplier MRSL / positive list for chemicals with ChemiQ screening.
- Other to be documented by the facility
Note: This question can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Priority Chemicals Management Key Performance Indicator asks respondents for priority chemicals information. The facility data can be aggregated by brands to answer TSC’s question.
Where to go for more info:
- ZDHC Gateway – Chemical Module – http://gateway.roadmaptozero.com/
- BLUESIGN® bluefinder – https://www.bluesign.com/industry/bluesign-system/web-applications/bluesign-bluefinder
How This Will Be Verified:
Facilities that usechemicals in production processes:
Yes:
- Demonstrated evidence that more than 50% of the chemical formulations in the chemical inventory (% based on the number of chemicals, not the volume) is sourced from a positive list
- Sourcing preferred chemical list such as ZDHC Gateway – Chemical Module, bluesign, GOTS, OekoTex, etc.
PartialYes
- The chemical formulations in the chemical inventory sourced from a positive list represent less than 50% of the chemical inventory (% based on the number of chemicals, not the volume)
Factory that uses chemicals in facility tooling and/or operations only:
Yes
- Demonstrated evidence that more than 10% of the chemical formulations in the chemical inventory (% based on the number of chemicals, not the volume) is sourced from a positive list
Partial Yes
- The chemical formulations in the chemical inventory sourced from a positive list represent less than 10% of the chemical inventory (% based on the number of chemicals, not the volume)
Documentation Required:
- Demonstrate the access to a positive list (example: bluesignbluefinder license)
- Chemical inventory listing the chemical formulations and the corresponding chemical supplier. Chemicals sources from a positive list should be identified in the chemical inventory
- Purchasing support documents
- Purchasing contract language to support sourcing chemicals from positive lists
- Process documentation to identify internal and external responsibilities
Interview Questions to Ask:
- Senior Management, Chemical Manager, Purchasing Manager
Inspection – Things to Physically Look For:
- Review actual list and practice.
- Verify random purchase and receipts against positive list of a selection of chemicals (at least 2).
Chemical Management – Level 3
Questions
Select what applies:
- All chemicals used in manufacturing processes
- All chemicals used in tooling/equipment (lubricants and grease)
- All chemicals used to operate and maintain the facility
Upload: a) Prioritized list of alternatives for chemicals; b) MRSL/RSL, substances of concern list/candidate list, REACH SVHC List (skip if previously uploaded); c) Minutes from collaborative meeting between facility, customers, and chemical suppliers regarding alternatives.
It’s critical that value chain partners work together on alternatives in order to prevent a regrettable substitution that results in a product failure or non-compliance.
You will be awarded Full Points if you are collaborating on alternatives for all categories of chemicals.
Operational Key Performance Indicator: Chemical Selection, Procurement, & Purchasing Practices
What is the intent of the question?
Collaborate to prioritize a list of alternatives. This question is intended to reward facilities that are engaging with brands and chemical suppliers to identify alternatives for substances of concern or restricted substances. It’s critical that value chain partners work together on alternatives in order to prevent a regrettable substitution that results that results in a product failure or non-compliance.
To prioritize, important analysis to run are: a) toxicity criteria and b) life cycle assessment – forthcoming questions. The behavior to drive here is a commitment to prioritizing collaboratively.
Chemical management of hazardous substances is a complex and demanding process. The more collaboration on substances of concern enables better prioritization, customer satisfaction, and industry improvement.
Technical Guidance:
Collaboration to develop alternatives to the use of chemicals including hazardous substances can take various forms. This criteria measures the ability for facilities to take the ownership of the substitution of hazardous substances by leveraging collaboration.
Reference: ZDHC Chemical Management System Framework – Version 1 (May 2020) – Chapter 3
- This question can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Priority Chemicals Management Key Performance Indicator asks respondents for priority chemicals information. The facility data can be aggregated by brands to answer TSC’s question
The idea can be strongly fortified if facilities engage themselves in collaboration with suppliers, brands and research institutes to come out with possible solutions for new product development or substitution of toxic chemicals through application development, thereby benefiting the society and industry (e.g. DWR finish application with plasma techniques and energy efficient chemicals etc.)
How This Will Be Verified:
Expectation is to produce the prioritized list of alternatives for a chemical.
Facilities that use chemicals in production processes:
Yes
- Facility has a process for collaboration regarding chemical alternatives, substances of concern, and/or restricted substance lists. It is transparent and documented and it includes the following:
- All chemicals used in manufacturing processes
- All chemicals used in tooling/equipment (lubricants and grease)
- All chemicals used to operate and maintain the facility.
- Facility has a prioritized list of alternatives for a chemical through a transparent, science-based, simple and reasonable system that evaluates chemicals and/or chemical products.
Documentation Required:
- Prioritized list of alternatives for chemicals
- MRSL/RSL, substances of concern list/candidate list, REACH SVHC List
- Minutes from collaborative meeting between facility, customers, and chemical suppliers regarding alternatives
Interview Questions to Ask:
- Senior Management can explain process for collaborating with customers and chemical suppliers regarding regional/global chemical requirements
- Ensure management and key employees are aware of updating the prioritized list of alternatives for chemicals
Inspection – Things to Physically Look For:
- Review prioritized list of alternatives for chemicals
- Review MRSL/RSL, substances of concern list/candidate list, REACH SVHC List
- Review minutes from collaborative meeting between facility, customers, and chemical suppliers regarding alternatives
Suggested Upload: a) Hazardous Chemicals assessment report, such as Screened Chemistry or Cradle2Cradle assessment; b) Evidence the facility has evaluated the alternatives against hazard criteria.
Answer Yes if a hazardous chemicals assessment has been conducted in the facility and you are using this information to prioritize action and encourage chemical use towards safer alternatives. The assessment must include an evaluation of the hazard associated with a hazardous substance and an assessment of the exposure.
Answer Partial Yes if you have conducted an assessment but have not prioritized further action.
Operational Key Performance Indicator: Product Quality / Integrity
What is the intent of the question?
The alternative process referred in this question is a process done by the facility to identify the chemical products they are using based on its hazards, and then use this knowledge to make a selective decision to reduce, substitute or ultimately phase out this hazardous chemical. It takes technical knowledge to be able to identify hazards outside of lists like in Level 2. If this is done, it is done with the intent to replace existing or proposed chemicals. Facilities should be rewarded for this behavior within the context of alternatives assessment. The choice for banning or substituting the use of identified hazardous substances should be made by combining the hazard associated with an estimation of the potential exposure to this substance. Ignoring exposure can lead to very inaccurate estimates of product risk, resulting in misdirected product stewardship efforts. We will discuss the estimation of exposures via the evaluation of scenarios, where scenarios are dependent upon the use of the substance.
This helps determine exposure risk categorization (i.e. BLUESIGN® levels 1, 2, 3) which relate to end-use (i.e. children’s product, next to skin, outer layer with no skin exposure, etc.). This helps a supplier choose which formulation may best support the end use functional requirements plus the chemical exposure risk.
Technical Guidance:
Chemical hazard assessment is used to identify and prioritize chemical substances for possible replacement with safer alternatives is increasingly required by retailers, brands, and material suppliers in response to both consumer pressure and regulatory requirements.
Hazardous chemicals are those that show intrinsically hazardous properties—persistent, bio-accumulative, and toxic (PBT); very persistent and very bio-accumulative (vPvB); carcinogenic, mutagenic, and toxic for reproduction (CMR); endocrine disruptors (ED); or chemicals of equivalent concern—not just those that have been regulated or restricted in other jurisdictions.
Reference: ZDHC Chemical Management System Framework – Version 1 (May 2020) – Chapter 3
The benefits of conducting a hazard assessment are as follows:
- The approach can be used to assess and compare alternatives to an incumbent chemical substance. The goal is to identify alternative chemicals that are inherently less hazardous, thereby preventing substitutions that may increase risk to human health and the environment.
- The approach is adaptable to information technology tools, making it capable of screening a large number of chemicals in a relatively short period of time, and providing guidance for more comprehensive profiling of chemicals and materials.
- The approach is readily adaptable to multiple industry sectors and provides a science-based approach to evaluating chemical hazards so that less hazardous alternatives may be identified.
Reference: This question can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Priority Chemicals Management Key Performance Indicator asks respondents for priority chemicals information. The facility data can be aggregated by brands to answer TSC’s question.
Glossary:
Hazardous chemicals: Hazardous chemicals are those that show intrinsically hazardous properties—persistent, bio-accumulative, and toxic (PBT); very persistent and very bio-accumulative (vPvB); carcinogenic, mutagenic, and toxic for reproduction (CMR); endocrine disruptors (ED); or chemicals of equivalent concern—not just those that have been regulated or restricted in other jurisdictions.
To get started with chemical hazard assessment please download this guide: https://outdoorindustry.org/wp-content/uploads/2015/05/Haz_Assessment-2.pdf
How This Will Be Verified:
Guidance: Expectation is evidence that you have evaluated the alternatives against hazard criteria.
Facilities that uses chemicals in production processes:
Yes
- A hazardous chemicals assessment has been conducted in the facility and the facility is using this information to prioritize and create an action plan with clear implementation towards safer alternatives. The assessment shall include an evaluation of the hazard associated with a hazardous substance together with an assessment of the exposure.
Partial Yes
- A hazardous chemicals assessment has been conducted in the facility however no further actions have been taken to prioritize further action.
Facilities that use chemicals in facility tooling and/or operations only:
Yes
- A hazardous chemicals assessment has been conducted in the facility and the facility is using this information to prioritize and action and encourage chemical use towards safer alternatives. The assessment shall include an evaluation of the hazard associated with a hazardous substance together with an assessment of the exposure.
Partial Yes
- A hazardous chemicals assessment has been conducted in the facility however no further actions have been taken to prioritize further action.
Documentation Required:
- Hazardous Chemicals assessment report
- Evidence the facility has evaluated the alternatives against hazard criteria.
Interview Questions to Ask:
- Do key employees understand how to use this information to prioritize and action and encourage chemical use towards safer alternatives?
Inspection – Things to Physically Look For:
- Review the Hazardous Chemicals report.
- Review evidences that the facility has evaluated alternatives against hazard criteria
Suggested Upload (if applicable): a) BLUESIGN® BlueXpert assessment; b) Lifecycle Assessment studies; c) Documented metrics for water, energy, waste, etc.; d) Third party assessments; e) MFCA (Material Flow Cost Accounting)
Your facility should optimize chemicals used, manufacturing processes, and machinery to reduce energy and water consumption associated with a production step. An example would be choosing a different dyestuff in order to reduce water consumption during a dyeing process.
This question focuses on the other resource consumption or production (such as water, energy and waste), as opposed to chemical assessment based on the hazardous properties as referred in Question 18.
Answer Yes if you have evaluated the environmental impacts (e.g., impacts on water usage, energy usage, waste, wastewater, and disposal) of replacing chemicals in your factory.
Operational Key Performance Indicator: Chemicals & Process Innovation
What is the intent of the question?
This action is beyond just chemical management and a more encompassing approach of sustainability which looks at a product life-cycle within and beyond the facility e.g. water usage, energy usage, waste, wastewater, disposal, etc.
The objective of product and chemical life-cycle reviews are to support the product’s and chemical’s environmental footprint. There are frameworks to establish life cycle metrics which can assist in the development and measurement. The efficiency of the manufacturing process is highly dependent on the optimization of the use of the chemicals together with the manufacturing process and the machineries. The optimization of these three elements can generate significant savings by reducing the amount of chemicals used, reducing the energy and water consumption associated with the process and therefore significantly reduce the life cycle impacts of the system.
Technical Guidance:
Where to go for more info:
- http://wbcsdservers.org/wbcsdpublications/cd_files/datas/business-solutions/reaching-full-potential/pdf/Chemical%20Sector%20Life%20Cycle%20Metrics%20Guidance.pdf
- http://www.ecoinvent.org/
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes
- Evaluation using the BLUESIGN® BlueXpert: https://www.bluesign.com/sites/bluexpert/about
- PLCA/LCA studies.
- Documented metrics for water, energy, waste, etc.
- 3rd Party assessments
Documentation Required:
- BLUESIGN® BlueXpert assessment
- PLCA/LCA studies
- Documented metrics for water, energy, waste, etc.
- MFCA (Material Flow Cost Accounting)
- 3rd Party assessments
Interview Questions to Ask:
- Senior Management, Environmental Steward
Inspection – Things to Physically Look For:
- Review facility for implementation of strategies.
Suggested Uploads: a) Product batch card including batch number, dates and production quantity; b) Recipe cards, formulation sheets, process instructions (where applicable), containing all traceable information i.e. chemical name, lot number, and quantity; c) Chemical mixing/blending process log, lab records (e.g. color lab, washing lab, etc.), including relevant information e.g. chemical name and quantity used in mixtures; d) Chemical storage log, including temporary/working storage and main warehouse with consistent records i.e. storage in/out log with chemical lot number, quantity, and dates (stored and dispatched for usage).
Answer Yes only if ALL chemicals used in processes or in mixtures can be traced to the temporary/working storage and main warehouse where consistent records are available and maintained to the lot number.
Answer Partial Yes if you can trace some but not all chemicals back to the lot number
Operational Key Performance Indicator: Chemicals & Process Innovation
What is the intent of the question?
The purpose of traceability is determining whether the chemical components involved in the production can be traced “backward” (Pick out a finished product, whether it is possible to trace the chemical components that are used to produce that particular finished product), and “forward” (Pick out a chemical, whether it is possible to identify all the particular finished products that are produced by using that particular chemical).
Ability to do so, would help support root cause investigations in case any quality or compliance issue occurred due to any particular chemical.
If a recall of a product is needed, it is possible to recall the particular chemical products that are involved.
In Level 3, the facility should have a traceability of chemicals used in each manufacturing process of each batch number of finished product, up to the lot number of the chemical. In other words, the facility should maintain consistent linkage of information as follows: (1) the product batch number (2) the production processes that the particular product underwent (3) the recipe sheets in relation with each process that involves chemical use (4) the corresponding records of the chemicals used in these recipes at the chemical mixing or lab, e.g. name and quantity (5) consistent record of these particular chemicals at the storage (temporary and warehouse/bulk storage) e.g. storage log, in/out records (6) the corresponding chemical lot number (7) consistent information in the facility-wide chemical inventory. These will demonstrate that you know how and where chemicals are used in your facility operations, are stored in the facility, and all information are consistently documented and monitored facility-wide.
Technical Guidance:
This level of traceability is only possible when we ask chemical suppliers to provide the lot number of chemicals with every delivery and facilities to track against PO upon receipt of these chemicals. Facilities should record this information in their inventory or chemical log by product name and lot number, date of receipt and subsequently when the product is opened to use in the recipe and the date of use to ensure full traceability of the chemical product being used.
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes
All requirements below are met:
- Batch cards are available for all product specifying batch number and other relevant information e.g. dates and production quantity
- All processes that the product has gone through that involves usage of chemical are identified and the corresponding recipes and batch cards at each process are available and maintained. Process instructions and checkpoints are established and documented.
- All chemicals listed in recipes can be traced to the chemical mixing/blending or lab (where applicable), including relevant information e.g. chemical name and quantity used in mixtures
- All chemicals used in processes or in mixtures can be traced to the temporary/working storage and main warehouse where consistent records are available and maintained, e.g. storage in/out log with chemical lot number, quantity, and dates (stored and dispatched for usage).
- Linkage between the lot number of chemicals used and the product batch number is established for any given product manufactured at the facility
Partial Yes
- Batch cards are available for all product specifying batch number and other relevant information e.g. dates and production quantity
- All processes that the product has gone through that involves usage of chemical are identified and the corresponding recipes and batch cards at each process are available and maintained. Process instructions and checkpoints are established and documented.
- Some of the chemicals (not all) listed in recipes can be traced to the chemical mixing/blending or lab (where applicable), including relevant information e.g. chemical name and quantity used in mixtures
- Some of the chemicals (not all) used in processes or in mixtures can be traced to the temporary/working storage and main warehouse where consistent records are available and maintained, e.g. storage in/out log with chemical lot number, quantity, and dates (stored and dispatched for usage).
- Linkage between the lot number of chemicals used and the product batch number is established for some of the product (not all) manufactured at the facility
Documentation Required:
- Product batch card including batch number, dates and production quantity
- Recipe cards, formulation sheets, process instructions (where applicable), containing all traceable information i.e. chemical name, lot number, and quantity
- Chemical mixing/blending process log, lab records (e.g. color lab, washing lab, etc.), including relevant information e.g. chemical name and quantity used in mixtures
- Chemical storage log, including temporary/working storage and main warehouse with consistent records i.e. storage in/out log with chemical lot number, quantity, and dates (stored and dispatched for usage)
Interview Questions to Ask:
- Managers/workers can demonstrate a documented traceable and trackable system back from each product batch to each chemical lot
- Workers understand the content and know the importance of product batch records, process instructions, recipe, usage records, storage records, especially for processes that involves chemical use e.g. dyeing, washing, printing, or finishing where applicable
Inspection – Things to Physically Look For:
- Review of records (refer to above requirements)
- Perform a random check of 1-2 products currently in manufacturing line on-site, and trace back to the processes that the product went through and the corresponding recipe and batch cards at each process
- Random check 3-4 chemicals in the recipe/batch cards identified in each process to trace up documentation from final product to mixing area and storage warehouse. Check if linkage between product batch number and chemical lot number can be established and whether documentation is available and maintained.
(Note: Not all are required to upload, but need to be available for review during verification) Suggested upload could include some of the following to demonstrate practice: a) SOP for purchasing chemicals from qualified suppliers (skip if previously uploaded); b) Quality department with associated records such as customer test reports, analytical laboratory test reports by chemical by lot; c) Chemical supplier analytical test report; d) Quality reports to senior management; e) In-house records of the analysis performed during last season; f) Test reports records from external ZDHC MRSL accepted labs of the analysis performed during last season and check that they are in accordance with MRSL requirements; g) Analysis results traceable to their corresponding internal orders and finished good batch
Answer Yes only if you have a process in place to randomly select and verify a chemical’s compliance to a known standard such as an MRSL or RSL via an organoleptic and chemical analysis on at least an annual basis. This QA program should include: 1) the evaluation of the quality and performance efficacy of each chemical formulation used, 2) ensuring the process recipes of how each chemical formulation are to be used are strictly followed, 3) process controls are strictly followed, and 4) ongoing assessment of production quality with supporting records.
Answer Partial Yes if your facility utilizes customer testing reports traceable to work orders and recipes to verify chemical supplier conformance.
Operational Key Performance Indicator: Product Quality / Integrity
What is the intent of the question?
The focus should be on whether the chemical being purchased is performing according to its technical data sheet. It is very leading practice for a facility that purchases chemicals to setup a process to really verify the chemical compliance on its own (e.g., screening laboratory test).
The expectation is that the facility will have a quality management program that ensures chemicals are evaluated against and meet standards for achieving MRSL and RSL requirements.
Why is this question important? The chemical supply chain is a many tiered value-added process, including traders, distributors, etc. Understanding the quality of a chemical ordered versus the chemical received is crucial to ensure the upstream creation and distribution of chemicals delivers chemicals that will meet RSL and/or your own (or your customers’) responsible input chemistry requirements. Factual data collected should be used in a process to add/remove chemical suppliers for future purchases.
Technical Guidance:
Reference: ZDHC Chemical Management System Framework – Version 1 (May 2020) – Chapter 1 and Chapter 3
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes
- Facility has a process in place to randomly select and verify a chemical’s compliance to a known standard such as an MRSL or RSL via an organoleptic and chemical analysis on at least an annual basis.
- QA program should include: 1) the evaluation of the quality and performance efficacy of each chemical formulation used, 2) ensuring the process recipes of how each chemical formulation are to be used are strictly followed, 3) process controls are strictly followed, and 4) ongoing assessment of production quality with supporting records.
Partial Yes
- Facility utilizes customer testing reports traceable to work orders and recipes to verify chemical supplier conformance.
- Chemical supplier analytical test report.
Documentation Required:
- Quality department with associated records such as customer test reports, analytical laboratory test reports by chemical by lot.
- Chemical supplier analytical test report.
- SOP for purchasing chemicals from qualified suppliers
- Quality reports to senior management
- In-house records of the analysis performed during last season
- Test reports records from external labs of the analysis performed during last season and check that they are in accordance with MRSL requirements
- Analysis results traceable to their corresponding internal orders and finished good batch
- Does the facility send internal results to external lab for accuracy checking?
- All records kept for one year
Interview Questions to Ask:
- QA Manager, Lab Manager, do they know what the parameters are, and whether they know which ones have to be performed in-house and which are outsourced.
- Is the facility aware of which labs can perform which tests.
- Laboratories should have certifications or accreditations for the tests to be carried out.
- Laboratories should inform their customers in case one of the tests is being outsourced to any other laboratory.
- Laboratories should regularly participate in correlation studies (“round robin” or blind samples) for the tests they are performing for their customers
- Laboratories should be able to offer reasonable analysis times
Inspection – Things to Physically Look For:
- Minimum parameters that have to be considered for production control are the following:
- Analysis to be performed in-house:
- pH (except for tanneries where this test is excluded).
- Color fastness:
- To perspiration
- To water
- To rubbing (dry and wet).
- To saliva (only for baby garments).
- Analysis to be outsourced:
- Arylamines
- Formaldehyde
- Composition
- APEO´s and PFC´s
- Take pictures as evidence if the facility has a PH meter with temperature control, an adequate shaker for PH analysis, an appropriate crockmeter to perform rubbing fastness analysis, Monofiber species for color fastness analysis (if apply), Balance, Oven (if applies), A grey scale to provide the result of color fastness analysis (if applies), Light box –not applicable for positional printing mills and laundries where not dyeing processes are carried out, Performing pH analysis according to legislation: ask for a demo
- Check if the in-house lab has all the necessary equipment to perform a good quality chemical performance
- Review process for sample/testing of a chemical receipt
- Review process for chemical supplier analytical test report
- Review process for add/remove of a chemical supplier based on quality
Suggested Upload: a) Description of the procedures; b) Communications with the contractors and subcontractors showing confirming the practice of sourcing chemicals from positive lists; c) Higg verification report from contractors / subcontractors showing that they meet the criteria.
Answer Yes if your facility has a system in place that requires all contractors and subcontractors to have a preferred chemicals list and verify its use.
Answer Partial Yes if you have an action plan to engage contractors and subcontractors by requesting the selection of chemicals from a positive list.
Note: Contractors/Subcontractors include all production material or chemical suppliers and/or other contracted business partners that support the manufacturing process of final
products(e.g. screen printing, washing/dyeing, or other product embellishments).
Operational Key Performance Indicator: Chemical Selection, Procurement, & Purchasing Practices
What is the intent of the question?
Facilities should proactively seek chemicals with fewer hazards and risks to replace chemistry that poses greater danger to humans and our environment (beyond MRSLs and RSLs). This question is intended to reward facilities that have gone above and beyond to also require their contractors and subcontractors to use preferred chemicals lists.
Substitution of hazardous chemicals is a fundamental measure to reduce risks to environment, workers, consumers and public health. Several brand-driven and third-party programs exist to identify positive substitutes. Driving demand for these substitutes, and green chemistry innovation as a whole, will improve the sustainability of the textile and footwear industry.
Technical Guidance:
It is important to note that positive lists are developed by screening the composition of specific formulation to identify hazardous substances. Positive lists should consider the assessment of the composition of the chemicals used in the formulation as well as an evaluation of the quality process in place in the facilities that manufacture these chemicals. This second aspect is key to ensure that the composition of the chemical formulation is consistent over time and that the risk of finding unwanted impurities is limited. Information related to the composition of the chemical mixture available in Safety Data Sheets should not be used (only) for the development of positive lists as the level of detail available in SDSs usually do not identify impurities or substances non-intentionally added that can often be the source of the noncompliance with an RSL or an MRSL.
- ZDHC Chemical Management System Framework – Version 1 (May 2020) – Chapter 2
- BLUESIGN® bluefinder
- Customer supplier MRSL / positive list for chemicals.
- ZDHC MRSL Level 3, BLUESIGN®, GOTS, OEKO-TEX®, others.
Where to go for more info:
- https://www.osha.gov/dte/library/industrial_hygiene/industrial_hygiene.pdf
- http://www.hse.gov.uk/opsunit/perfmeas.pdf
- http://www.whss.ca/default/assets/File/ohsa_guide.pdf
- http://www.kznhealth.gov.za/occhealth/policyocc.pdf
- National, local, regional regulations on workplace safety and health
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes
- A system in place that requires all contractors and subcontractors to have a preferred chemicals list and verify their use.
Partial Yes
- Action plan to engage contractors and subcontractors by requesting the selection of chemicals from a positive list
Documentation Required:
- Description of the procedures.
- Communications with the contractors and subcontractors showing confirming the practice of sourcing chemicals from positive lists
- If available, Higg verification report from contractors / subcontractors showing that they meet the criteria on Higg FEM Chemicals Question 16.
Interview Questions to Ask:
- Do key employees understand these procedures?
Inspection – Things to Physically Look For:
- An observation of how these procedures are put into practice
Does your facility communicate its goals, processes and actions to Brands and Suppliers?
Suggested Upload: a) Description or examples of current chemistry R&D projects/investments; b) Examples of how you have incorporated responsible chemistry into your own business agreements.
Answer Yes only if you can demonstrate that business decisions take responsible chemical management and innovation into consideration by incorporating responsible chemicals into its own business agreements and documented business goals.
Answer Partial Yes if you can otherwise demonstrate that business decisions take responsible chemical management and innovation into consideration.
Operational Key Performance Indicator: Chemicals & Process Innovation
What is the intent of the question?
In this question, we expect that your facility can demonstrate that business decisions take responsible chemical management and innovation into consideration. This means you aren’t just writing policies, but you are actively incorporating responsible chemicals into your own business agreements. Behavior will really change once there are business incentives incorporated. Facilities with documented business goals supporting chemicals management should also be communicating your intention to supply chain partners.
Real sustainability improvement will only occur when sustainability is incorporated into business decisions.
Technical Guidance:
Innovation in process changes such as salt free dyeing, solvent free processing, water less dyeing, use of plasma technology for finishing or electrochemical dyeing process, recovery/reusing of various chemicals like Potassium permanganate, Alkali etc. machine modification to improve water and energy conservations or develop new process route to establish radical change and improvement in overall environmental impact.
Glossary:
- SMART is a best practice framework for setting goals. A SMART goal should be specific, measurable, achievable, realistic and time-bound
Templates to Create: SMART Template
Where to go for more info:
- http://www.smart-goals-guide.com/smart-goal.html
- http://www.hr.virginia.edu/uploads/documents/media/Writing_SMART_Goals.pdf
How This Will Be Verified:
Facilities that use chemicals in production processes:
Yes
- Facility can demonstrate that business decisions take responsible chemical management and innovation into consideration.
- Facility is actively incorporating responsible chemicals into its own business agreements.
- Facility has a plan on finding new sustainable chemicals.
- Facilities with documented business goals supporting chemicals management should also be communicating their intention to supply chain partners.
Partial Yes
- Facility can demonstrate that business decisions take responsible chemical management and innovation into consideration.
Documentation Required:
- Description or examples of current chemistry R&D projects/investments
- Examples of how the facility has incorporated responsible chemistry into your own business agreements.
Interview Questions to Ask:
- Senior Management, Responsible Manager regarding business decisions made that take responsible chemicals management and innovation into consideration.
Inspection – Things to Physically Look For:
- Review of documented plans and actions regarding business decisions made that take responsible chemicals management and innovation into consideration.