Chemical Management 2024

Higg FEM How to Higg Guide 2024

1. General Introduction

2. Chemical Use At Your Facility

3. ZDHC Partnership and Resources

4. Applicability Questions

5. Chemical Management – Level 1

6. Chemical Management – Level 2

7. Chemical Management- Level 3

General Introduction

The use of chemicals in a facility’s production processes and operations can pose significant risks to the environment and human health if not managed systematically and responsibly.

As governments and industry stakeholders continue to focus on responsible chemicals management, more stringent requirements and regulations may be imposed. New chemistries and technologies are also constantly being developed to support the reduction of hazardous chemicals in the supply chain. By proactively managing and striving to eliminate or reduce the use of hazardous chemicals, you can reduce impacts on the environment, exposure to regulatory risks or new requirements from business partners and contribute to a more sustainable future.

In general, the Higg FEM Chemicals Management section encourages you to:

Establish an effective Chemicals Management System (CMS) with appropriate policies, procedures, and commitments that drive continuous improvements.

Understand all chemicals used in the facility for production and operations through good chemical inventorying practices.
Establish responsible chemical purchasing practices that focus on the reduction of hazardous chemical use.
Ensure staff are appropriately trained and qualified to work with and/or manage chemicals in the workplace.
Ensure the proper facilities and protections are in place for safe chemical storage, handling, and use.
Establish procedures for chemical/product traceability, quality, and integrity.
Establish procedures to promote responsible chemical use supplier and contractor facilities.
Align with industry leading practices for chemicals management, the reduction of hazardous chemical use, and process innovation.

Additional details on the intent and criteria for each Higg FEM Chemicals Management question is provided in the guidance below along with useful technical guidance and resources to support your facility in managing chemicals responsibly.

Note: The Higg FEM Chemical Management section is the result of a collaboration between Sustainable Apparel Coalition, Outdoor Industry Association, and Zero Discharge of Hazardous Chemicals (ZDHC).

Chemical Use At Your Facility

Chemicals are used for a wide variety of applications and processes. In the FEM, chemicals are categorized as follows:

Chemicals used in Production: This refers to chemicals used in processes to make a product (e.g., chemicals used for dyeing or other wet processing, printing, laundry or washing, cementing or gluing, slashing during weaving, fibre extrusion, yarn spinning, leather tanning, electroplating, welding or other production process).
Chemicals used in Operations or Maintenance/Tooling/Equipment: This refers to chemicals that are not used in production process and are used to operate the facility (e.g., chemicals used for fuels for boilers/generators, general facility/equipment maintenance, lubrication of facility equipment or tools, wastewater treatment, etc.)

ZDHC Partnership and Resources

One of our partner organizations, the Zero Discharge of Hazardous Chemicals (ZDHC) group, has developed a variety of excellent resources for managing chemicals that are referenced throughout the Higg FEM Guidance. For more information on the ZDHC, its initiatives, and resources, we encourage you to visit the links throughout this guidance and/or visit their website here: https://www.roadmaptozero.com/?locale=en.

Applicability Questions

To determine which questions you will need to complete in the Chemicals section, you will need to complete the applicability questions listed below. You will be asked to select which processes you have on-site, whether you use commodity chemicals, and if your facility currently implements an MRSL. Your selections will direct you to complete the questions that are most applicable for your facility.

Based on your responses to the applicability questions, your facility will be classified in the Higg FEM as one (or a combination) of the facility types listed below:

Facility that uses Chemicals in Production.
- This refers to chemicals used in processes to make a product (e.g., chemicals used for dyeing or other wet processing, printing, laundry or washing, cementing or gluing, slashing during weaving, fibre extrusion, yarn spinning, leather tanning, electroplating, welding or other production process).

Facility that uses Chemicals in Operation only.
- This refers to chemicals that are not used directly in the production process but are used in equipment or processes utilized to operate basic energy conversion or wastewater management within the facility (e.g., Chemicals used in onsite wastewater treatment, Cooling Tower, Boilers (exclude small scale electricity boilers that are used for ironing/Mini Boilers))

Facility that uses Chemicals in Maintenance/Tooling/Equipment only.
- This refers to chemicals that are not used directly in the production process but are used for regular upkeep and maintenance of facility equipment. (e.g., chemicals used in general facility/equipment maintenance, lubrication of facility equipment or tools (Machine Oil), sourced in Industrial scale or in large quantities)

Facility that only uses Spot Cleaner in production.
- This refers to chemicals used to remove contaminated spots or nonpermanent stains from materials or final products (e.g., Garment Spot Cleaning, Fabric Stain Removal)

Facility that has minimal chemical use only.
- This refers to facilities that use only liquid and gaseous fuels (e.g., Diesel, LPG, for vehicles or cooking) and /or over the counter chemicals for cleaning and factory maintenance/up-keep (e.g., detergent, kitchen supplies, paint, thinner), and does not belong to any other chemical use types listed here.

1. 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
Welding
Casting/Foundry
Degreasing with organic solvents
Laser cutting
Metal plating (anodization, electroplating, electroless plating)
Painting
Powder Coating
Soldering
Printed Circuit Board (PCB) electronic automation
Other production processes that require chemicals
Spot cleaners – Spot cleaners are chemicals used to remove contaminated spots from final products such as garments, bed covers, shoes etc.

2. Does your facility use commodity chemicals?

Note: The Higg FEM aligns with the definition of a commodity chemical that is published in the most recent ZDHC Performance InCheck Guidelines, which defined a commodity chemical as “single substances or chemical compounds whose chemical structure is well-known, and their use is to create conditions for a process (such as acid, alkaline, oxidizing, reducing, solubilizing conditions). They are produced in high volumes with low prices and do not have a brand name but are known by their common chemical names (for example, Acetic Acid). The chemical structure and purity of two commodity chemicals produced by different manufacturers can be the same and can be interchangeable. They are generally sold on technical specifications (such as purity) and are not designed for a unique/special property or effect nor require any scientific research in their development. Usually, commodity chemicals either get reacted in the process (for example Sodium Hydroxide or Sodium Hydrosulphite) or remain in the effluent after the process (for example Common Salt or Glauber’s Salt used in reactive dyeing of cotton)”

3. Does your facility only use Minimal Chemicals (liquid and gaseous fuels, over the counter chemicals, maintenance chemicals for factory up-keep) onsite?

Yes
- Note: Yes should be selected if your facility ONLY uses minimal chemicals such as those listed above onsite. If your facility has other chemical use onsite for production or facility operations, you should select No to this question.
No

4. Does your facility implement an MRSL?

Note: This question will only be asked if you select Yes to the applicability question “Does your facility only use Minimal Chemicals (liquid and gaseous fuels, over the counter chemicals, maintenance chemicals for factory up-keep) onsite?” AND/OR when your facility falls under the Industry sectors “Home Furnishing (Non Textile)”, “Outdoor Sporting Goods – Hard Goods”, or “Other” Industry sector categories.

Yes – If yes is selected you will be asked to select from the following options:
Customer’s MRSL
ZDHC MRSL
bluesign BSSL
Other (If Other, please specify)
No

What kind of chemicals does your facility use? (Select all that apply)

Notes:

This question will only be asked if you select No to the applicability question “Does your facility only use Minimal Chemicals (liquid and gaseous fuels, over the counter chemicals, maintenance chemicals for factory up-keep) onsite?”.
Please refer to the definitions above for examples of chemical use classifications.
Production Chemicals
Operations Chemicals
Maintenances/Tooling/Equipment Chemicals
Spot Cleaner Chemicals

Chemical Management – Level 1

1. Does your facility have a written Chemical Management System (CMS) policy? (Ref ID: chemcmspolicynonprod / chemcmspolicyprod)

For facilities that do not use Chemicals in Production:(Ref ID: chemcmspolicynonprod)

Answer Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers all of the following elements:

Comply with all applicable laws and regulations.
The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
Capacity building and training of staff on CMS.

For facilities that use Chemicals in Production:(Ref ID:chemcmspolicyprod)

Answer Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers all of the following elements:

Comply with all applicable laws and regulations.
The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
Capacity building and training of staff on CMS.
Incorporating traceability and transparency into your facility’s operations.
Incorporating sustainable chemical management practices in production processes
Commitment to continuously improve CMS effectiveness.

Answer Partial Yes if: Your facility has a documented Chemical Management System (CMS) policy that covers the three (3) elements listed below, but not all of the three (3) additional elements listed above:

Comply with all applicable laws and regulations.
The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
Capacity building and training of staff on CMS.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Which of the following has been included in the policy (Select all that apply):
- Comply with all applicable laws and regulations.
- Ensuring the safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
- Capacity building and training of staff on CMS.

Suggested Uploads:

A copy of the facility’s Chemical Management System policy.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a formal policy is in place for managing chemicals safely and effectively.

Technical Guidance

A chemical management system policy is the foundation for a facility’s chemical management system. A policy is important to make sure all stakeholders (internal and external) are aware of the goals of the facility with respect to chemicals management. A CMS policy should include a clear statement that outlines a facility’s commitments to chemicals management. and provide details on the practices and procedures followed by the facility.

The specific content of a chemical management system policy may vary based on the nature of chemicals used at a facility. For example, a facility that only uses chemicals in facility operations (e.g., machine maintenance and lubrication) versus a facility with chemical intensive manufacturing processes. However, there are some key basics elements that should be included such as commitments to:

Comply with all applicable laws and regulations.
Reduce risks to workers and the environment.
Training and capacity building for staff
Communicate the policy and associated CMS procedures to all relevant parties (e.g., staff, external stakeholders, etc.)

For facilities that use chemicals in production additional policy elements should be included such as commitments to:

Continuous improvement of the CMS effectiveness.
Incorporate sustainable chemical management practices in its production processes.
Incorporate traceability and transparency into its operations.

A CMS policy should also be regularly reviewed and updated as needed. To ensure it provides a framework for continuous improvement, allowing facilities to identify areas where they can improve their chemical management practices and reduce risks.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS policy and CMS, which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Documentation Required:

For facilities that use do not use Chemicals in Production, Documented Chemical Management System policy that clearly includes the following elements:
- Comply with all applicable laws and regulations.
- The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
- Capacity building and training of staff on CMS.

For facilities that use Chemicals in Production, Documented Chemical Management System policy that clearly includes the following elements:

Comply with all applicable laws and regulations.
The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
Capacity building and training of staff on CMS
Incorporating traceability and transparency into your facility’s operations.
Incorporating sustainable chemical management practices in production processes
Commitment to continuously improve CMS effectiveness.
Other supporting documentation that shows the facility’s practices and procedures align with the CMS policy. This may include:
- Communication and/or training records on the facility’s CMS policy
- CMS procedures
- Records of management review of CMS policy.

Interview Questions to Ask:

Staff responsible for chemicals management at the facility, including top management, and employees are aware of the facility’s CMS policy and can describe the facility’s efforts to meet its stated objectives.

Inspection – Things to Physically Look For:

Observations onsite are consistent with the facility’s CMS policy (i.e., the policy is relevant to the facility operations and chemical use onsite).
Posting of the CMS policy at the site or other forms of communication to staff.

Partial Points (Facilities that use Chemicals in Production only):

For facilities that use Chemicals in Production, partial points will be awarded to facilities that have a documented Chemical Management System (CMS) policy that covers the three (3) elements listed below, but not all of the three (3) additional elements listed above:

a. Comply with all applicable laws and regulations.
b. The safe use of chemicals, to ensure Health and Safety for workers and minimizing environmental impact.
c. Capacity building and training of staff on CMS.

chemcmspolicygroup

Answer

2. Have you assigned the responsibility of implementing and maintaining the Chemical Management System (CMS) to a team/staff member? (Ref ID: chemcmstraining)

Answer Yes if: Your facility has assigned the responsibility of implementing and maintaining the Chemical Management System (CMS) to a team or staff member and there are documented responsibilities for the implementing and maintaining the facility’s CMS (e.g., job description).

Note: This responsibility may be assigned to a single person/role at the facility or spread across multiple staff members/roles.

If you select Yes, you will be asked the following sub question(s):

Which competence(s) does your CMS team have: (Select all that apply)
- Ability to read and interpret SDS.
- Competency in RSL
- Competency in MRSL
- Knowledge of GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

Note: Competency means that the individual has received formal qualification, education, training, and/or has professional experience that allows the person to understand and manage the noted aspect in relation to the facility’s CMS.

Suggested Uploads:

List of staff responsible for implementing and maintaining the CMS and their responsibilities (e.g., documented job description).
Documented CMS procedures that include responsibilities of staff related to CMS implementation.
If applicable, documentation that demonstrates the competencies of staff assigned to implement the CMS (e.g., certification, training records, curriculum vitae (CV)).

What is the intent of the question?

The intent of this question is for facilities to demonstrate they have dedicated roles and responsibilities established and staff assigned for the implementation and maintenance of the facility’s CMS.

Technical Guidance

Assigning a team/staff member and having defined roles and responsibilities for implementing and maintaining the facility’s CMS creates a clear chain of accountability for chemicals management within the facility. This is the foundation to effective implementation of a facility’s CMS.

Based on the size and scope of operations, a facility can decide on the number of staff required for CMS implementation. It is good practice to have a Chemical Responsible Person or a Core Team, composed of trained, capable, and experienced personnel to oversee the implementation and monitoring of a CMS.

Implementing and maintaining a CMS at a facility requires an in-depth understanding of chemicals management principles. One of the major barriers to effective implementation of a CMS is the lack of technical competencies in chemicals management. A team with appropriate competencies in chemicals management, helps facilities better understand the risks and impacts of chemicals in use, and helps to identify and implement appropriate measures to mitigate those risks and make improvements. Also, it helps ensure compliance with relevant regulations and other requirements, which are constantly evolving and becoming more complex.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have assigned the responsibility of implementing and maintaining the CMS to a team or staff member and the team is comprised of individuals that are competent in the following chemicals management aspects:

Ability to read and interpret SDS.
RSL
MRSL
GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

Note: Team members do not need to be competent in all aspects noted above, however there must be at least one (1) team member who is competent in each of the aspects.

Documentation Required:

Documentation that shows the facility has assigned the responsibility of implementing and maintaining the CMS to a team or staff member and there are documented responsibilities for the team member(s). This may include:
- List of staff responsible for implementing and maintaining the CMS and their responsibilities (e.g., documented job description).
- Documented CMS procedures that include responsibilities of staff related to CMS implementation.
- If applicable, documentation that demonstrates the competencies of staff assigned to implement the CMS (e.g., certification, training records, curriculum vitae (CV)).

Interview Questions to Ask:

Staff responsible for chemicals management are able to explain the roles and responsibilities of staff or team members related to the CMS.
Relevant staff responsible for the implementation and maintenance of CMS are able to demonstrate their competency in SDS, RSL, MRSL, GHS for classifications and labelling or equivalent.

Inspection – Things to Physically Look For:

Observations indicate that CMS are being managed by staff with appropriate technical competency and the facility’s chemicals management practices are in line with the CMS.

Partial Points:

Partial points will be awarded to facilities that have assigned the responsibility of implementing and maintaining the CMS to a team or staff member, but the team member(s) have at least one, but not all of the competencies listed below:

Ability to read and interpret SDS.
RSL
MRSL
GHS of classification and labelling or equivalent as well as local and international regulations on chemical restrictions

3. Does your facility have a chemical purchasing policy? (Ref ID: chempurchasingpolicy)

Answer Yes if: Your facility has established a formal documented chemical purchasing policy.

If you select Yes, you will be asked the following sub question(s):

Which of the following criteria are being included into consideration in your chemical purchasing policy: (Select all that apply):
- Legal requirements
- Health and Safety requirements
- RSL and/or MRSL requirements

Note: RSL and MRSL requirements refers to both brand specific requirements and the requirements of other industry programs (e.g., ZDHC, bluesign, etc)

Suggested Uploads:

A copy of the facility’s chemical purchasing policy

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a chemical purchasing policy is in place to ensure that chemicals are screened against established criteria before being purchased.

Technical Guidance

Establishing a formal chemical purchasing policy helps ensure chemicals are appropriately screened before being purchased. A chemical purchasing policy should clearly define the criteria for chemicals that can and cannot be purchased (e.g., specific legal or other requirements, health and safety considerations, etc.) The goal of the policy should be to reduce risk of hazardous or non-compliant chemicals entering the facility.

When developing a chemical purchasing policy, facilities should consider the following key elements of an effective chemical purchasing policy:

Developing specific criteria (e.g., legal or other requirements) for selecting chemicals to purchase.
Detailed procedures and responsibilities for the review and approval of chemicals before they are purchased.
Procedures to communicate the policy and purchasing criteria to chemical suppliers (e.g., including terms and conditions in contracts and/or purchase agreements).
Requirements for suppliers to provide sufficient chemical information for review, such as providing safety data sheets (SDS), labelling requirements, lot numbers, expiry dates, and other information on the environmental and health impact of their products.
Procedures to ensure that staff are trained on the policy and understand the importance of selecting appropriate chemicals for use at the facility.

Resources:

The ZDHC CMS and Technical Industry Guide framework sets out the principles and practices that should be included in a CMS including chemicals purchasing which are designed to help companies establish a robust and effective CMS that meets the ZDHC framework requirements and reduces the environmental and health impacts associated with chemical use in the supply chain.

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Documentation Required:

Documentation that shows the facility has an established chemical purchasing policy. This may include:
- Chemical purchasing policy that outlines how chemicals are screened against established criteria before being purchased.
- Chemical purchasing records that demonstrate chemicals are being purchased in line with the established chemical purchasing policy.
Other supporting documentation that shows the facility’s practices and procedures align with the chemical purchasing policy. This may include:
- Communication and/or training records on the facility’s purchasing policy.
- Chemical procurement procedures.

Interview Questions to Ask:

Staff responsible for chemical purchasing at the facility are aware of the facility’s policy and can describe their process screening and purchasing chemicals in line with the established policy.

Inspection – Things to Physically Look For:

Observations onsite indicate the chemicals are being purchased in line with the purchasing policy (e.g., all chemicals onsite are covered in the purchasing policy

Partial Points: N/A

4. Does your facility keep a Chemical Inventory List (CIL) and the suppliers of each chemical product? (Ref ID: chemtrack)

Answer Yes if: Your facility has an up-to-date chemical inventory list (CIL) that includes all chemicals used at the facility.

Answer Partial Yes if: Your facility has an up-to-date chemical inventory list (CIL) that includes some, but not all chemicals at the facility.

Note: Up-to-date means that the information in the inventory includes all chemicals currently in use and accurately reflects chemical use at the facility (e.g., chemicals that are not currently onsite, but are commonly used within and by the facility).

If you select Yes, you will be asked the following sub question(s):

Does your facility include the following types of chemicals in the inventory?
- All chemicals used in manufacturing processes (including chemicals in production, reactants and additives.
- All chemicals used in tooling/equipment (lubricants and grease).
- All chemicals used to operate and maintain the facility, and wastewater treatment plant chemicals where applicable.
- Spot cleaner(s).
Please upload documentation, if available.

Note: To be able to answer Yes to the main question all responses to the sub question must be either Yes or Not Applicable. If any of the responses to the sub questions above are no, the response for the main question must be Partial Yes

If you select Partial Yes or No, you will be asked the following sub questions:

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.
- If you don’t have a document to upload, describe your plan.

Suggested Uploads:

A copy of the facility’s Chemical Inventory List
If applicable, documentation action plan to obtain missing information in the inventory.

What is the intent of the question?

The intent of this question is to ensure that facilities have identified and created an inventory of all chemicals onsite.

Technical Guidance

Understanding which chemicals are used within a facility is a necessary first step in building a chemical management system. Identifying all chemicals used and their properties allows a facility to understand and manage regulatory and customer requirements, and ensure appropriate controls are in place to protect workers and the environment. A chemical inventory can also help facilities with purchasing decisions, increase transparency and traceability, and promote responsible chemical use.

Facilities should have a robust process for creating and updating their chemical inventory and have dedicated staff, in charge of maintaining the inventory.

While preparing an inventory, there are some important considerations that should be reviewed including:

How to ensure that all chemicals are covered including production and non-production chemicals.
- An inventory should contain all chemicals used and stored in the facility and may cover, but is not limited to, cleaners, adhesives, paints, inks, detergents, dyes, colourants, auxiliaries, coatings and finishing agents, and commodity chemicals, as well as those used for ETP, sanitary, laboratory and utility purposes.
What information is needed in the inventory to manage the chemicals effectively and safely and how this information will be obtained (e.g., from chemical suppliers, SDS, other sources, etc). Key information that should be included, but is not limited to, the following:
- Chemical name and type
- Supplier/Vendor name and type
- Manufacturer/Formulator name
- Safety Data Sheet (SDS), Global Harmonization System (GHS) compliant or equivalent
- Function
- Hazard classification
- Where it is used
- Storage conditions and location
- Quantities (quantity of chemicals used)
- CAS number or numbers (when in a mixture)
- Lot numbers (if applicable)
- MRSL conformance
- Purchase date
- Expiration dates (if applicable)
How the inventory will be updated (e.g., addition/removal of new/old chemicals, review frequency and responsible staff).
How the inventory may be used to support monitoring of chemical consumption and purchasing to reduce risks of expiry or storage of excessive quantities of chemicals onsite.

Resources:

The resources below provide example templates and reference information that can support a facility in creating or updating their chemical inventory.

Note: The resources provided below are for reference only and facilities should ensure their chemical inventory complies with any applicable law or regulations.

Examples of CIL templates can be downloaded from the ZDHC Resources page here: https://www.roadmaptozero.com/documents
The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
UNECE Globally Harmonized System of Classification and Labelling of Chemicals (GHS) https://unece.org/about-ghs

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes all chemicals used at the facility.

Documentation Required:

Documentation that shows the facility has a chemical inventory list (CIL) and this the list is up-to-to-date and accurate. This may include:
- The chemical inventory list (CIL)
- Purchase records of chemicals

Interview Questions to Ask:

Staff responsible for the chemical inventory list are able to explain how the facility ensures that the list is maintained and updated.

Inspection – Things to Physically Look For:

Observations onsite indicate that the inventory is up-to-date and accurate (e.g., chemicals observed to be in use at the facility are included on the inventory)

Partial Points:

Partial points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes some, but not all chemicals at the facility.

chemtrackdatagroup

Answer

5. Does your facility's Chemical Inventory List (CIL) include the following data? Select all that apply. (Ref ID:chemtrackdatahtml)

Chemical name and type
Supplier/Vendor name and type
Manufacturer/Formulator name
Safety Data Sheet (SDS), Global Harmonization System (GHS) compliant or equivalent
Function
Hazard classification
Where it is used
Storage conditions and location
Quantities (quantity of chemicals used)
CAS number or numbers (when in a mixture)
Lot numbers (if applicable)
MRSL conformance
Purchase date
Expiration dates (if applicable)

Notes:

Exception for lot numbers: Facilities that do not use chemicals in production, (e.g., spot cleaning or ETP chemicals) that would not lead to RSL, MRSL, ZDHC Wastewater testing failures do not need to include the lot numbers for these chemicals and should check the box for lot number if these are the only types of chemicals used onsite.
If a chemical does not conform to specific MRSL requirements, it does not mean the facility does not have a CIL or the required information if the MRSL conformance status is listed.

Suggested Uploads:

A copy of the facility’s Chemical Inventory List (CIL)
Examples of supporting information for the data that is included in the CIL (e.g., SDS, chemical usage records, purchase records, MRSL conformance tests or declarations, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that their chemical inventory contains the necessary information for each chemical.

Technical Guidance:

An effective chemical inventory should include all information needed to manage the chemicals effectively and safely. For the Higg FEM, the list of information included in this question is considered important to include in an inventory, however there may be additional information that is valuable to support a facility’s management of chemicals. For example, it is also recommended as a good practice to indicate whether chemicals in your inventory are included in a positive list or negative list of any industry standard, if applicable.

The guidance below provides additional details on the type of information to include for the key items in the inventory:

Chemical Product and Chemical Formulator name
- This can be obtained from Section 1 of the SDS where the Chemical Product name and Chemical Formulator name are detailed. This should also be confirmed with the GHS-label on the chemical container.
Supplier name
- In case this is different from Chemical Formulator, such as a trader or distributor.
Safety Data Sheet (SDS) Information
- The date of issue of the SDS should be inputted, only if the SDS for the chemical product is available in the manufacturing facility. In case the SDS is not available or is found to be outdated, a follow-up should be made with the Chemical Formulator to obtain the latest SDS and then the date of issue should be input.
Function
- Indicates the use or application of the chemical.
Hazard classification
- Hazard Statements for the three Hazard Types – Physical, Health and Environmental- should be inputted, as listed in Section 2 of the SDS.
- Storage, handling and discharge precautions: Refer to the P-Statements given in Section 2 and Section 7.2 of the SDS
Where it is used
- Input the locations/areas the chemical is used.
Storage conditions and location
- The location such as the main store, sub-store or a specific storage place can be described here to quickly understand the place of storage.
Quantities (quantity of chemicals used)
- For example, actual monthly/annual usage amount and unit
CAS number or numbers
- Input the CAS (Chemical Abstract Service) numbers of the hazardous substances as listed under Section 3 of the SDS.
- Input the CAS number and % of the substance for mixtures.
Lot numbers (if applicable)
- The batch or lot number(s) of the chemical product purchased in the month can be inputted to establish traceability in case of Root Cause Analysis.
MRSL conformance
- Input the conformance status with any applicable MRSL.

Resources:

The resources below provide example templates and reference information that can support a facility in creating or updating their chemical inventory.

Note: The resources provided below are for reference only and facilities should ensure their chemical inventory complies with any applicable law or regulations.

Examples of CIL templates can be downloaded from the ZDHC Resources page here: https://www.roadmaptozero.com/documents
The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
UNECE Globally Harmonized System of Classification and Labelling of Chemicals (GHS) https://unece.org/about-ghs

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes all of the data points listed in the FEM.

Documentation Required:

Documentation that shows the facilities chemical inventory list (CIL) up-to-to-date and includes accurate information on chemicals in the list. This may include:
- The chemical inventory list (CIL)
- Safety Data Sheets (SDS) or Technical Data Sheets (TDS)
- Chemical usage records
- Purchase records of chemicals
- MRSL conformance tests or declarations

Interview Questions to Ask:

Staff responsible for the chemical inventory list are able to explain how the facility obtains information in the inventory and ensures that the list is maintained and updated.

Inspection – Things to Physically Look For:

Observations onsite indicate that the inventory is up-to-date and the associated information in the inventory is accurate (e.g., chemicals observed to be in use at the facility are included on the inventory)

Partial Points:

Partial points will be awarded for facilities that have an up-to-date chemical inventory list (CIL) that includes some, but not all data points listed in the FEM.

Note: Partial points are calculated automatically in the FEM based on the items that are included in the CIL.

6. Does your facility make Safety Data Sheets (SDS) available to employees for all chemicals used? (Ref ID: chemsds)

Answer Yes if: Your facility has up-to-date SDS information available to employees for all chemicals used and the SDS is at minimum, compliant with country specific regulations and the facility has an established process to ensure that SDS information is kept up-to-date.

Answer Partial Yes if: Your facility has up-to-date SDS information available to employees for some, but not all chemicals used and the available SDS are at minimum, compliant with country specific regulations.

Note: Up-to-date means that the SDS has been updated at the frequency defined by local law and/or if any of the following have occurred:

An ingredient used in the formulation is changed due to which there is an impact on the hazard classification of the formulation.
New toxicological/legislative information is applicable to any ingredient used in the formulation that may impact the overall hazard classification of the formulation.
Any type of new restriction or authorisation has been imposed on a substance or mixture (e.g., under EU- REACH regulation or other legislation).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Are Safety Data Sheets posted readily accessible where hazardous chemicals are stored/used?
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)?
Please upload documentation, if available

Notes:

- Readily accessible means that SDS information is easily accessed in areas of use. For example, this could be achieved by posting of SDS and/or maintaining SDS information in a folder at a nearby work areas.

It is not required to translate all SDS information into the language of workers in its entirety. It is acceptable to create translated simplified data sheets that contain translation of necessary information for workers related to their job function and chemical hazards/safety (e.g., appropriate handling, use, and storage of the chemical, personal protection, proper first aid/emergency response and disposal precautions).

Suggested Uploads:

Photo images showing the SDS information available in applicable work areas and accessible to the employees.
Copies of SDS
- Note: Copies of all SDS do not need to be uploaded but should be available for review during verification.
Procedures for ensuring SDS information is up-to-date.

What is the intent of the question?

The intent of this question is for facilities to ensure that up-to-date SDS information is available for all chemicals used in the facility.

Technical Guidance:

Safety Data Sheets (SDS) are a fundamental source of information on the hazards associated with a chemical. SDS provide crucial information on how to manage chemicals in a responsible manner including how chemicals should be stored, used, handled, and disposed of as well as information on health, safety, and environmental hazards.

An SDS (either as hard or soft copy) for every chemical used in a facility should be kept at a central location and also in areas where the chemical is stored and/or used so that it is readily accessible by staff. Staff should also be trained on how to read and understand SDS information.

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS/CLP) is an internationally recognized system for the classification and labelling of chemicals. The GHS was developed to replace individual sets of classification and labelling standards used in different countries with a single, standardized set of criteria for the classification and labelling of chemicals and standardized requirements for the information required on SDS.

Country specific levels of GHS adoption may vary, however it is recommended that facilities request GHS compliant SDS form chemical suppliers when available, but at minimum facilities should follow applicable country specific regulations relating to SDS content.

It is also important that SDS information be provided in the language of all workers so that it is easily understood. It is not required to translate all SDS information into the language of workers in its entirety. It is acceptable to create translated simplified data sheets that contain translation of necessary information for workers related to their job function and chemical hazards/safety (e.g., appropriate handling, use, and storage of the chemical, personal protection, proper first aid/emergency response and disposal precautions) or as legally required.

The date of issue of SDS and its version number should be carefully monitored. An SDS needs to be updated by a chemical supplier when:

Any ingredient(s) are changed that results in a change to the hazard classification of the chemical.
New toxicological/legislative information is applicable to any ingredient(s) that may impact the hazard classification of the chemical.
Any type of restriction or authorisation has been imposed on chemical or its ingredient(s) (e.g., under EU- REACH regulation or other legislation).

It is considered a good practice for facilities to monitor the validity of the SDS for each chemical product by checking regularly with the supplier for any potential updates. (Note that the FEM does not define a required frequency for this.)

In cases where certain SDS information is not available at the point of purchase (e.g., tooling or cleaning chemicals) Facility should strive to obtain as much information about the chemical as possible (e.g., by contacting manufacturers or suppliers provided on the product). Facilities should also ensure these products have appropriate labels which should provide details of ingredients and hazards. In cases where appropriate labels or SDS are not available, the original labels should be compliant to GHS/CLP or country specific regulations.

Resources:

The resources below provide helpful information on SDS management.

Note: The resources provided below are for reference only and facilities should ensure that their SDS management program complies with any applicable laws or regulations.

UNECE Globally Harmonized System of Classification and Labelling of Chemicals (GHS) https://unece.org/about-ghs
GHS implementation status by country – https://unece.org/transportdangerous-goods/regionalcountry-level?accordion=0#accordion_1
Examples of CIL templates can be downloaded from the ZDHC Resources page here: https://www.roadmaptozero.com/documents
The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have up-to-date SDS information available to employees for all chemicals used and the SDS is at minimum compliant with country specific regulations and the facility has an established process to ensure that SDS information is kept up-to-date.

Note: Up-to-date means that the SDS has been updated at the frequency defined by local law and/or if any of the following have occurred:

An ingredient used in the formulation is changed due to which there is an impact on the hazard classification of the formulation.
New toxicological/legislative information is applicable to any ingredient used in the formulation that may impact the overall hazard classification of the formulation.
Any type of new restriction or authorisation has been imposed on a substance or mixture (e.g., under EU- REACH regulation or other legislation).

Documentation Required:

Documentation that demonstrates the facility has up-to-date SDS information available in the workplace and that SDS information is available to workers. This may include:
- Copies of up-to-date SDS that are at minimum compliant with legal requirements for SDS.
- Copies SDS information translated into the language of workers.
- SDS Training records for workers.
- Procedures that demonstrate the facility has processes in place to ensure SDS information is kept up-to-date.

Interview Questions to Ask:

Staff responsible for SDS management at the facility are able to explain the facility’s procedures for Managing SDS information and how the facility ensures up-to-date SDS information for chemicals is obtained and communicated and made accessible to workers.
Relevant employees understand the facility’s SDS program and can explain how SDS information is accessed when needed.

Inspection – Things to Physically Look For:

Observations that indicate up-to-date SDS information is available at the facility and made accessible to workers (e.g., SDS are available for chemicals observed onsite, SDS are stored (in hard or soft copy) in work areas)

Partial Points:

Partial Points will be awarded to facilities that have up-to-date SDS information available to employees for some, but not all chemicals used and the available SDS are at minimum compliant with country specific regulations.

chemsdsgroup

Answer

7. Does your facility train all employees who handle chemicals on chemical hazards, risk, proper handling, and what to do in case of emergency or spill? (Ref ID:chemtraining)

Answer Yes if: Your facility has provided training to employees and the training meets all of the following criteria:

Training has been delivered to all employees who handle chemicals.
The Training covers all of the topics listed in the sub question below.
The training is documented (with training records and/or material)
Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Answer Partial Yes if: Your facility has provided training, but one (1) or more of the following criteria is not met:

Training has been delivered to all employees who handle chemicals.
The Training covers all of the topics listed in the sub question below.
The training is documented (with training records and/or material)
Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Note: If your facility has not provided training to any employees on chemicals, you should answer No to this question.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please select all topics included in your training:
- Chemical hazards and identification
- MSDS/SDS
- Signage
- Compatibility and risk
- Proper storage and handling
- PPEs
- 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.
- Individual duties associated with monitoring and maintaining this protection here.
How many employees were trained?
How frequently do you train your employees?
Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
Please upload documentation.

Suggested Uploads:

Documentation that demonstrates the facility has conducted training on chemicals for employees (e.g., Training plan/schedule, training records, training material used for training, post-training evaluation procedures and/or records)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that procedures are in place to train employees who handle chemicals on chemicals hazards and safety, and that trainings have been conducted.

Technical Guidance:

It is important that all levels of employees are aware of chemical hazards, risks, safety precautions and emergency response for chemicals in use at the facility. Facilities should have formal documented training processes to ensure awareness and knowledge is shared with all employees who handle chemicals.

Effective training programs ensure that all levels of employees understand the potential hazards, risks, and controls associated with chemicals in the workplace. Various levels and types of training may be required to ensure training is appropriate for employees in different positions or with responsibilities and directly relates to the types of chemicals they may come into contact with during regular operations or emergency situations.

Having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of training and knowledge retention.

Resources:

The ZDHC Academy offers trainings to create awareness, learn and develop skills on sustainable chemical management – https://www.implementation-hub.org/academy

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have provided training to employees and the training meets all of the following criteria:

Training has been delivered to all employees who handle chemicals.
The training covers all of the topics listed in the sub question.
The training is documented (with training records and/or material)
Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

Documentation Required:

Documentation that shows the facility has provided chemicals related training employees. This may include:
- Training plan that identifies training schedule(s), topics covered, and type of training for employees.
- Training attendance records
- Training material used for environmental training,
- Training evaluation procedures and/or records

Interview Questions to Ask:

Staff responsible for the facility’s chemical training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
Employees who have received the training are aware of the content of the training.

Inspection – Things to Physically Look For

Supporting evidence of the facility’s environmental training program (e.g., awareness posters, informational postings related to the facility’s chemical management/safety programs, if available)

Partial Points:

Partial point will be awarded for facilities that have provided training, but one (1) or more of the following criteria is not met:
- Training has been delivered to all employees who handle chemicals.
- The Training covers all of the topics listed in the sub question below.
- The training is documented (with training records and/or material)
- Training is conducted at least annually or at a frequency that allows training all new employees according to the turnover rate.

chemtraininggroup

Answer

8. Does your facility have a chemical spill and emergency response plan that is practiced periodically? (Ref ID: chememergplan)

For facilities that use chemicals in production:

Answer Yes if: Your facility has a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework and practice drills are conducted at least twice per year for all relevant staff.

Answer Partial Yes if: Your facility has a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework or practice drills are not conducted at least twice per year for all relevant staff.

Note: For this question, relevant staff means any employee or manager that handles chemicals, works in areas where chemicals are used, and/or has defined responsibilities in the facility’s chemical spill and emergency response plan/procedures.

For facilities that only use chemicals for operations or tooling/equipment:

Note: The ZDHC Chemical Management System (CMS) Framework can be downloaded here: https://www.roadmaptozero.com/process#Guidance

If you select Yes or Partial Yes, you will be asked the following sub question(s):

- How many employees were trained on this topic?
- How frequently do you train your employees on this topic?
- Do you evaluate your employees after the training?

How do you evaluate the knowledge of your employees after the training?

Does your facility keep records of all employee and environmental incidents related to chemical spills and emergency response?
Please upload documentation, if available

Suggested Uploads:

Documentation that demonstrates the facility has an emergency response plan in place and that practice drills are conducted, when required (e.g., copy of emergency response plan/procedures, records of practice drills, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that emergency response procedures are in place and that employees are trained on how to respond in the event of a chemical emergency.

Technical Guidance:

The FEM aligns with the ZDHC criteria for emergency response plan content and procedures contained in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. These criteria are summarized below:

At minimum, facilities need to have:

A procedure to identify and respond to potential chemical and natural incidents related but not limited to spills, fires, accidents, injuries to employees and damage to buildings and equipment.
Detailed instructions on how to evacuate the building and contain contact names/ information for individuals in charge of the evacuation.
Twice per year testing of procedures which shall include all employees, sub-contractors, EMS teams, and depending on the size and scope of the drill, and the outside community EMS team.
Consultation of appropriate municipal officials since control may be exercised by the local government in major emergencies and additional resources may be available.
Communication and training to ensure adequate performance in times of an emergency.
Methods to update procedures where necessary after practice drills and actual emergencies. All drills and follow-up should be documented.

Resources:

The ZDHC Chemical Management System (CMS) Framework can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

For facilities that use chemicals in production:

Full Points will be awarded for facilities that have a documented chemical spill and emergency response plan that meets the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework and practice drills are conducted at least twice per year for all relevant staff.

For facilities that only use chemicals for operations or tooling/equipment:

Documentation Required:

Documentation that shows the facility has a documented emergency response plan in place and that practice drills are conducted, when required. This may include:
- Emergency response plan/procedures,
- Documentation of practice drills (e.g., drill practice/training records)

Interview Questions to Ask:

Staff responsible for managing the facility’s emergency response plan and procedures can explain the facility’s procedures for responding to emergencies and how drills are practiced.
Relevant staff understand the facility’s emergency response procedures and have participated in drill, if applicable.

Inspection – Things to Physically Look For:

Observations indicate that the facility has the necessary procedures and equipment in place to respond to chemical emergencies per their developed plan. (e.g., Availability of emergency response equipment e.g., spill kits, showers, eyewash stations, fire extinguishers, SDS, emergency exits clearly marked, unobstructed and unlocked, etc.)

Partial Points:

For facilities that use chemicals in production:
- Partial Points will be awarded for facilities that have a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework or practice drills are not conducted at least twice per year for all relevant staff.

For facilities that only use chemicals for operations or tooling/equipment:
- Partial points will be awarded for facilities that have a documented chemical spill and emergency response plan, but the plan does not meet the requirements listed in Section 4.3 of the ZDHC Chemical Management System (CMS) Framework. Practice drills are not required.

chememergplangroup

Answer

9. Does your facility have appropriate and operable protective and safety equipment, as recommended by the Global Harmonization System compliant (or equivalent) Safety Data Sheet, in all areas where chemicals are stored and used? (Ref Id: chemsafetyequip)

Answer Yes if: Your facility has appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in all areas where chemicals are stored and used.

Answer Partial Yes if: Your facility has appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in some, but not all areas where chemicals are stored and used.

Notes:

This question applies to all production and non-production related chemicals.
For this question the terms appropriate and operable are defined as follows:
- Appropriate – refers to protective and safety equipment recommended for use on the SDS of each chemical or as required by a health and safety risk assessment conducted by a qualified safety professional.
- Operable – refers to the protective and safety equipment being readily accessible to employees and maintained in good repair and/or working order (e.g., per the equipment manufacturer’s specifications).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Documentation that shows the facility has identified appropriate protective and safety equipment required and that the equipment is regularly replenished and/or maintained (e.g., health and safety risk assessment showing the required controls, inventory list of PPE and safety equipment with schedules of stock replenishment/replacement, equipment maintenance, etc.).

What is the intent of the question?

The intent of this question is to ensure facilities understand and provide appropriate protective and safety equipment to reduce worker exposure to health and safety risks of chemicals in the workplace.

Technical Guidance:

Ensuring appropriate personal protective equipment (PPE) (e.g., gloves, respirators, protective clothing, etc. and other safety equipment (e.g., spill kits, eye wash stations, emergency showers, fire extinguishers, etc) is available in areas where chemicals are stored and used is crucial to protecting workers from chemical exposure risks.

Information on the recommended safety and protective equipment may be found in the following sections of a GHS compliant SDS (note that SDS sections and content may vary by jurisdiction)

Section 4: First-Aid Measures
Section 5: Fire-Fighting Measures
Section 8: Exposure Controls/Personal Protection

The selection of the most suitable PPE and safety equipment should be evaluated by an accredited health and safety professional to determine the most effective equipment and any limitations. This is particularly important for facilities that use a high number of chemicals where workers are potentially exposed to multiple chemicals and chemical mixtures.

For all PPE and safety equipment, appropriate replacement and maintenance schedules should be defined and be based on available information such as manufacturer recommendations, onsite conditions, the level and duration of potential exposures to chemicals.

It is also important for facilities to remember that PPE should only be used as a last resort if no other control methods are available or are sufficient. For tasks where PPE is needed, it should be selected based on a formal job hazard review that identifies the specific chemical or physical hazards and the most effective type of PPE.

Resources:

U.S. OSHA – Personal Protective Equipment – https://www.osha.gov/sites/default/files/publications/osha3151.pdf
Chemical Safety in the Workplace Guidance Notes on Personal Protective Equipment (PPE) for Use and Handling of Chemicals – http://www.labour.gov.hk/eng/public/os/C/equipment.pdf

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in all areas where chemicals are stored and used.

Documentation Required:

Documentation that shows the facility has identified appropriate protective and safety equipment required and that the equipment is regularly replenished and/or maintained. This may include:
- Documented health and safety risk assessment and/or SDS showing the required protective/safety equipment.
- Inventory list of PPE with schedules for stock replenishment/replacement
- Inspection and maintenance schedules for safety equipment (e.g., eyewash, emergency showers, etc)

Interview Questions to Ask:

Staff responsible for health and safety at the facility can explain how the facility identifies the required type of PPE and safety equipment needed.
Staff responsible for providing or maintaining protective and/or safety can explain the facility’s procedures for ensuring equipment is available and in good working order.

Inspection – Things to Physically Look For:

Observations onsite indicate that appropriate PPEs and safety equipment is available in relevant areas and are consistent with hazard classification on chemical SDS and safety equipment is accessible and functioning.

Partial Points:

Partial points will be awarded for facilities that have appropriate and operable protective and safety equipment as recommended chemical safety data sheets (SDS) in some, but not all areas where chemicals are stored and used.

chemsafetyequipgroup

Answer

10. Does your facility have chemical hazard signage and safe handling equipment in the areas of the facility where chemicals are used? (Ref ID: chemhazardsign)

Answer Yes if: Your facility has chemical hazard signage and safe handling equipment is available in all areas where chemicals are used.

Answer Partial Yes if: Your facility has chemical hazard signage and safe handling equipment in some, but not all areas where chemicals are used.

Note: This question applies to all production and non-production related chemicals.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Documentation that demonstrates the facility has appropriate practices and procedures to ensure that chemical hazard signage and safe handling equipment are available in areas where chemicals are used (e.g., chemical labelling/signage procedures, examples of chemical signage, inspection schedule/procedures that cover chemical hazard signage and handling equipment, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that practices and procedures are in place to ensure chemical hazard signage and safe handling equipment is in place in all areas where chemicals are stored.

Technical Guidance:

It is important that the presence of chemical hazards in the workplace are clearly communicated and visible to employees. This helps employees understand where chemical hazards are present as well as the type of hazards that exist (e.g., flammable, toxic, corrosive, etc.). Facilities should post signage at all areas where chemicals are stored or used. Signage should depict the hazard classification(s) of chemicals as provided on the SDS (Section 2: Hazard(s) Identification) and/or other hazard identifiers required by local law.

Areas in the facility that may require chemical hazard signage include, but are not limited to:

Receiving and delivery areas
Chemical storage areas (centralized warehouse and temporary storage areas)
Chemical process areas (e.g., manufacturing/production areas)
Waste chemicals storage (including chemical residues and expired chemicals)
Laboratories
Maintenance areas

Safe handling and transfer equipment (e.g., trolleys, carts, pumps) should be available at relevant locations to ensure safe handling which can reduce the potential for spills, which can result in negative impacts to workers’ health or the environment. These tools can also result in cost savings by reducing chemical loss.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

U.S. Occupational Safety and Health Administration (OSHA) Hazcom website – https://www.osha.gov/hazcom

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have chemical hazard signage and safe handling equipment is available in all areas where chemicals are used.

Documentation Required:

Documentation that demonstrates the facility has appropriate practices and procedures to ensure that chemical hazard signage and safe handling equipment are available in areas where chemicals are used. This may include:
- Chemical labelling/signage procedures with requirements for chemical hazard signage
- Inspection schedule/procedures that cover chemical hazard signage and handling equipment.
- SDS that shows the hazard classes of chemicals onsite.

Interview Questions to Ask:

Staff responsible for the facility’s chemical management and/or safety programs can explain the facilities procedures to ensure appropriate hazard signage is available in areas where chemicals are stored and used.
Relevant employees understand the facility’s chemical hazard signage and how to use the provided safe handling equipment.

Inspection – Things to Physically Look For:

Observations onsite indicate that chemical hazard signage is in place in all areas where chemicals are used, and the signage is consistent with the hazards indicated on SDS.
Observations that indicate safe handling equipment is available and in being used.

Partial Points:

Partial points will be awarded for facilities that have chemical hazard signage and safe handling equipment is available in some, but not all areas where chemicals are used.

chemhazardsigngroup

Answer

11. Does your facility select and purchase chemicals based on their hazards and MRSL requirements? (Ref Id: chempurchasereqmrsl)

Answer Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements;

and all chemicals meet the requirements of MRSL and the facility’s purchasing policy;

and MRSL conformance is confirmed annually (e.g., through certificates/declarations of MRSL conformance, certificates of analysis, etc).

Answer Partial Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance to MRSL, and your facility has a clear plan for obtaining the documents from chemical suppliers within 6 months or changing to a chemical supplier who can meet the requirements in order to increase the % of compliant chemicals meeting MRSL.

Non-production chemicals and spot cleaners:

For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals, etc.) or spot cleaners, it might not be feasible to obtain third party certificates/declarations of MRSL compliance or certificates of analysis. For these types of chemicals, this documentation is not required, but facilities must have an established process in place to review the chemical ingredients against the MRSL to check for conformance.

Notes:

The ZDHC MRSL conformance levels (1, 2 and 3) from the ZDHC Gateway- Chemical Module should be used for the determination of the conformity with the ZDHC MRSL. For more information about the ZDHC MRSL conformance, refer to the ZDHC MRSL Conformance Guidance here: https://downloads.roadmaptozero.com/input/ZDHC-MRSL-Conformance-Guidance
Tools to check your chemical inventory to the ZDHC MRSL are the InCheck Solutions https://www.roadmaptozero.com/process#Incheck-guidelines

If you select Yes or Partial Yes, you will be asked the following sub question(s):

If yes, do all chemicals purchased and used in production meet the facility’s chemical purchasing policy?

If you select No, you will be asked the following sub question(s):

If no, do you have a process or plan for eliminating chemicals that do not meet the facility’s chemical purchasing policy?

Suggested Uploads:

Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and MRSL requirements such as:

MRSL(s) applicable to the facility (e.g., customer’s MRSL, ZDHC MRSL, combined facility MRSL).
Chemical purchasing policy and procedure(s).
Positive lists used for chemical purchasing.
Third party MRSL conformance certification/test reports/declarations and/or certificate of analysis of chemical composition.
Chemical inventory showing MRSL compliance status of all chemicals.

What is the intent of the question?

The intent is to ensure facilities have an established process to evaluate chemical hazards and MRSL conformance during procurement and that only compliant chemicals are purchased for use at the facility.

Technical Guidance:

MRSL is a Manufacturing Restricted Substance List which can be defined as a list of chemicals that are banned from use in manufacturing. The goal of an MRSL is to ensure facilities are using the environmentally preferred chemicals that result in less harm to the environment and human health. Using an MRSL in chemicals procurement can also help ensure more consistent material compliance.

To ensure that chemicals are appropriately evaluated before purchase, facilities should:

Establish their own chemical MRSL that covers all MRSL requirements from clients (e.g., brands) they work with or industry initiatives they are a part of or implement a strategy to use compliant chemicals from an active list that covers all MRSL (e.g., the bluesign system).
Establish a process to communicate MRSL requirements to all chemical suppliers including the required evidence from suppliers to confirm compliance (e.g., positive lists, certificates/declarations of MRSL conformance, certificates of analysis, or other relevant documentation)
Include MRSL compliance as a purchasing requirement for all chemicals.
- This should include procedures to verify chemicals conform to MRSL requirements through documentation provided by chemical suppliers.
- Where applicable, facilities should purchase chemicals that are certified to meet MRSL requirements such as bluesign approved chemistry, Ecopassport by OekoTex.
Ensure all chemical procurement staff are aware of MRSL requirements and the facility’s purchasing policy and procedure.
For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals) ensure there is a process in place to, at minimum, review the list of ingredients and SDS if available against the facility’s MRSL to confirm MRSL conformance.

It is critical that facilities discuss MRSL requirements with their chemical suppliers to determine which chemical products are MRSL compliant and the requirements for chemical suppliers to be able to demonstrate their products comply with the facility’s MRSL requirements.

It is also important that facilities not only rely on simple declarations or assurances from suppliers alone, but ensure there is a validation processes in place to ensure compliance such as chemical composition test reports from ISO 17025 certified laboratories approved for conducting the required chemical testing or use of established positive lists that confirm compliance with applicable MRSL (e.g., ZDHC, bluesign, OEKO-TEX, etc.)

Guidance for Hardgoods facilities:

In the hardgoods sector MRSL (Manufacturing 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.

For hardgoods 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”. Beyond the fact that different lists are used in the hardgoods sector, the question about selection and purchasing is also valid for hardgoods facilities.

It is expected that facilities may use either a sector-wide list, a brand-specific restricted list or create their own list.

All textile components in the hardgoods sector (for example, products such as rucksacks, tents, etc.) should apply the MRSL criteria 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 are not relevant. With RSLs the management of residual chemicals on the final product is secured, however this may depend on the product and materials used.

Three examples of “Restricted Lists” are:

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 and Sports equipment, Monitoring and Control instruments). The chemicals that are restricted are:
1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent chromium (Cr6+)
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)
7. Bis(2-ethylhexyl) phthalate (DEHP)
8. Butyl benzyl phthalate (BBP)
9. Dibutyl phthalate (DBP)
10. Diisobutyl phthalate (DIBP)
  1. Maximum Permitted Concentration: 0.1%[5]
  2. Maximum for Cadmium: 0.01%[5]
The GADSL (Global Automotive Declarable Substance list).
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.

For the time being, it has been decided by the Hardgoods FEM working group, that the facilities that have not yet been exposed to the concept of MRSL or received an MRSL from one of their Brand/ Retail buyers, will not need to respond to the questions related to MRSL.

Please observe that this provision is an interim compromise in order to support hardgoods facilities that have not yet been exposed to the MRSL concept. However, we expect that these facilities as well strive for solutions related to MRSL.

Resources:

ZDHC Gateway- Chemical Module https://www.my-aip.com/ZDHCGateway/Login.aspx
ZDHC MRSL Conformance Guidance https://downloads.roadmaptozero.com/input/ZDHC-MRSL-Conformance-Guidance
ZDHC InCheck Solutions https://www.roadmaptozero.com/process#Incheck-guidelines

ZDHC ChemCheck https://www.zdhc-gateway.com/reports/chemcheck
bluesign https://www.bluesign.com/en

OEKO-TEX https://www.oeko-tex.com/en/

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements and all chemicals meet the requirements of MRSL and the facility’s purchasing policy and MRSL conformance is confirmed annually (e.g., through certificates/declarations of MRSL conformance, certificates of analysis, etc).

Documentation Required:

Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and MRSL requirements. This may include:
- MRSL(s) applicable to the facility (e.g., customer’s MRSL, ZDHC MRSL, combined facility MRSL).
- Chemical purchasing policy and procedure(s) that include, but are not limited to:
  - Process of communicating MRSL with the chemical suppliers,
  - Process to obtain suppliers’ confirmation/declaration of MRSL compliance,
  - Collection of up-to-date positive lists from chemical suppliers.
  - Preference/requirements for purchasing chemicals on positive lists.
- Positive lists used for chemical purchasing.
- Annual third party MRSL conformance certification/test reports/declarations and/or certificate of analysis of chemical composition.
- Chemical inventory showing MRSL compliance status of all chemicals.
For chemicals not used in the manufacturing process documentation that the facility has a process in place to review chemical ingredients against the facility’s MRSL. This may include:
- SDS or TDS
- Ingredient lists from consumer labels.

Interview Questions to Ask:

Staff responsible for the facility’s chemical management program can explain how the facility established its MRSL and MRSL requirements of the facility’s chemical purchasing policy and procedure.
Staff responsible for chemical procurement understand and can explain how chemicals are evaluated and approved for purchase in relation to the facility’s MRSL and purchasing policy and procedure..

Inspection – Things to Physically Look For:

Observations onsite indicate that all chemicals in use comply with the facility’s MRSL and chemical purchasing policy and procedure (e.g., observed chemicals have been appropriately screened and there is documentary evidence to confirm MRSL conformance).

Partial Points:

Partial points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and MRSL requirements, but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance to MRSL and your facility has clear plan for obtaining the documents from chemical supplier within 6 months or changing to a chemical supplier who can meet the requirements in order to increase the % of compliant chemicals meeting MRSL.

chempurchasereqmrslgroup

Answer

12. Does your facility select and purchase chemicals based on their hazards and RSL requirements? (Ref ID: chempurchasereqrsl)

Answer Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and RSL requirements and all chemicals meet the requirements of RSL and the facility’s purchasing policy and there is documentation to support this.

Answer Partial Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and RSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance with the facility’s purchasing policy and your facility has clear plan for obtaining the supporting this documentation.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

If yes, do all chemicals purchased and used in production meet the facility’s chemical purchasing policy?

If you select No, you will be asked the following sub question(s):

If no, do you have a process or plan for eliminating chemicals that do not meet the facility’s chemical purchasing policy?

Suggested Uploads:

Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and RSL requirements such as:

RSL(s) applicable to the facility (e.g., customer’s RSL, combined facility RSL).
Chemical purchasing policy and procedure(s).
Positive lists used for chemical purchasing.
Third party RSL conformance certification/test reports.
Chemical inventory showing compliance status of all chemicals with the facility’s purchasing policy.

What is the intent of the question?

The intent is to ensure facilities have an established process to evaluate chemical hazards and RSL conformance risk during procurement and chemicals purchased are compliant with the facility’s chemical purchasing policy.

Technical Guidance:

Restricted Substance List (RSL) is a list of chemicals that are regulated via limiting or restricting the allowable concentration of chemicals in final products due to their potential harmful impact on human health and the environment. RSLs are typically developed by industry associations, governments, or individual companies to ensure that products and materials used in manufacturing processes meet specific safety and environmental standards.

RSLs are one way to identify chemicals that are potentially hazardous which can be used to establish chemical purchasing practices to minimize the risk of hazardous chemicals entering a facility and products.

To ensure that chemicals are appropriately evaluated before purchase, facilities should:

Establish their own chemical RSL that covers all RSL requirements from clients (e.g., brands) they work with or industry initiatives they are a part of
- For facilities that have more than one customer RSL, a policy should be in place to use the most stringent RSL limits for each chemical and then establish their RSL to meet all customer requirements.
Establish a process to communicate RSL requirements to all chemical suppliers including the evidence needed from suppliers to confirm compliance (e.g., positive lists, certificates/declarations of RSL conformance, certificates of analysis, or other relevant documentation)
Include RSL compliance as a purchasing requirement for all chemicals.
- This should include procedures to verify chemicals conform to RSL requirements through documentation provided by chemical suppliers.
Ensure all chemical procurement staff are aware of RSL requirements and the facility’s purchasing policy and procedure.
For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals) ensure there is a process in place to, at minimum, review the list of ingredients and SDS if available against the facility’s purchasing policy requirements.

Resources:

bluesign system substance list which can be downloaded here: https://www.bluesign.com/en/downloads
AFIRM RSL Toolkit https://afirm-group.com/toolkit/
AFIRM Chemical Information Sheets https://afirm-group.com/english-information-sheets/

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and RSL requirements and all chemicals meet the requirements of RSL and the facility’s purchasing policy and there is documentation to support this.

Documentation Required:

Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and RSL requirements. This may include:
- RSL(s) applicable to the facility (e.g., customer’s RSL, combined facility RSL).
- Chemical purchasing policy and procedure(s) that include, but are not limited to:
  - Process of communicating RSL with the chemical suppliers,
  - Process to obtain suppliers’ confirmation/declaration of RSL compliance,
  - Collection of up-to-date positive lists from chemical suppliers.
  - Preference/requirements for purchasing chemicals on positive lists.
- Positive lists used for chemical purchasing.
- Annual third party RSL conformance certification/test reports/declarations.
- Chemical inventory showing RSL compliance status of all chemicals.

Interview Questions to Ask:

Staff responsible for the facility’s chemical management program can explain how the facility established its RSL and RSL requirements of the facility’s chemical purchasing policy and procedure.
Staff responsible for chemical procurement understand and can explain how chemicals are evaluated and approved for purchase in relation to the facility’s RSL and purchasing policy and procedure.

Inspection – Things to Physically Look For:

Observations onsite indicate that all chemicals in use comply with the facility’s RSL ,chemical purchasing policy and procedure.(e.g., observed chemicals have been appropriately screened and there is documentary evidence to confirm RSL conformance).

Partial Points:

Partial points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and RSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance with the facility’s purchasing policy and procedure and your facility has clear plan for obtaining the supporting this documentation.

chempurchasereqrslgroup

Answer

13. Does your facility have an environmental and occupational health and safety program specific to chemicals management? (Ref ID: chemhealthprogram)

Answer Yes if: Your facility has a documented program and procedures specific to the environmental and occupational health and safety risks of chemical use at the facility and the program minimally includes the following:

A designated person or team responsible for environmental and health and safety related to chemicals.
A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
The program meets all legal health and safety requirements related to chemicals management.
Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Answer Partial Yes if: Your facility has established practices specific to the environmental and occupational health and safety risks of chemical use at the facility, but the program does not include one (1) or more of the following:

A designated person or team responsible for environmental and health and safety related to chemicals.
A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
The program meets all legal health and safety requirements related to chemicals management.
Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Note: The environmental and occupational health and safety procedures related to chemicals management may be included as part of the facility’s overall environmental health and safety management program.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Environmental and health and safety management team organization chart and/or job descriptions.
Chemicals risk assessment.
Environmental health and safety procedures related to chemical storage, handling, usage, and disposal.
Permits governing health and safety requirements for chemical storage, use, and disposal if applicable.

What is the intent of the question?

The intent of this question is to ensure facilities have established procedures in place to manage and control environmental and health and safety risks associated with chemical use at the facility.

Technical Guidance:

An environmental and occupational health and safety (ESH) program aims to minimize environmental impacts, reduce workplace hazards, and protect the health and well-being of employees. The scope and complexity of a facility’s EHS program will vary depending on the type of facility, types and quantities of chemicals used as well as other specific risks related to facility production and operations.

It is crucial that a facility’s EHS program be developed and managed by qualified staff and be based on the formal evaluation of risks and hazards in the workplace with the goal of protecting workers and the environment.

In the FEM, facilities are expected to have EHS practices related to chemicals management that, at minimum, cover the following:

Designated roles and responsibilities for environmental and health and safety related to chemicals.
An assessment of risks associated with the storage, handling, use and disposal of chemicals used onsite including potential worker exposures to chemicals.
Procedures to ensure compliance with all legal health and safety requirements related to chemicals management.
Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Resources:

ZDHC Chemical Management System Framework – Version 1.0 (May 2020) which can be downloaded here: https://www.roadmaptozero.com/process#Guidance
International labour Organization Occupational Safety and Health Management Systems https://www.ilo.org/safework/areasofwork/occupational-safety-and-health-management-systems/lang–en/index.htm
The National Institute for Occupational Safety and Health (NIOSH) Managing Chemical Safety in the Workplace https://www.cdc.gov/niosh/chemicals/default.html

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented program and procedures specific to the environmental and occupational health and safety risks of chemical in use at the facility and the program minimally includes the following:

A designated person or team responsible for environmental and health and safety related to chemicals.
A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
The program meets all legal health and safety requirements related to chemicals management.
Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Documentation Required:

Documentation that demonstrates the facility has practices and/or procedures in place to manage environmental and health and safety risks of chemicals in use at the facility. This may include:
- Environmental and health and safety management team organization chart and/or job descriptions.
- Chemicals risk assessment.
- Environmental health and safety procedures related to chemical storage, handling, usage, and disposal.
- Required Permits governing health and safety requirements for chemical storage, use, and disposal.

Interview Questions to Ask:

Staff responsible for EHS management and/or chemical safety management at the facility understand their roles and responsibilities and can explain how the facility manages risks related to the storage, handling, use, and disposal of chemicals.

Inspection – Things to Physically Look For:

Observations onsite indicate the EHS program related to chemicals management is being implemented per the facility’s established practices or procedures.

Partial Points:

Partial points will be awarded for facilities that have established practices specific to the environmental and occupational health and safety risks of chemical in use at the facility, but the program does not include one (1) or more of the following:

A designated person or team responsible for environmental and health and safety related to chemicals.
A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
The program meets all legal health and safety requirements related to chemicals management.
Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment

chemhealthprogramgroup

Answer

14. Does your facility have well marked, designated chemical storage areas? (Ref ID: chemstorage)

Answer Yes if: Your facility has well marked, designated chemical storage areas for all chemicals stored onsite.

If you select Yes, you will be asked the following sub question(s) to indicate which storage practices are in place at the facility:

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 areas are 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 liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur.
- Note: The need for secondary containment must be based on a formal risk assessment that considers the risk and potential impact of spills and must also meet applicable legal requirements based on chemical volume and container size.
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,hazard class, and lot number (if applicable)
First Expiry, First Out (FEFO).
Health and safety measures are in place (such as PPE, etc).

Suggested Uploads:

Facility map showing the location of chemical storage areas.
Floor layout plan of chemical storage areas, specifying categorization and storage location of different types of chemicals.
Standard operating procedures for chemical storage and labelling.
Example photos of chemical storage areas and controls
Examples of storage in/out logs, FEFO records, specifying date of arrival at storage, lot number, and date of dispatch to production, etc.)
Audits/inspections checklists or reports of chemical storage areas.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that all storage areas are well-marked and have sufficient controls to prevent contamination and safety risks.

Technical Guidance:

Proper chemical storage with appropriate controls is important to reduce and prevent health & safety and environment risks. A well-planned storage area allows easy movement and protection of chemicals during handling and use. Storage conditions should be based on the recommended storage practices listed on safety data sheets (SDS) and/or storage practices recommended by chemical suppliers. Additionally, all legal requirements related to the storage of chemicals should be complied with.

Chemical storage areas and controls should be designed and appropriate for the specific types, quantities, and hazards of chemicals used on site. The list below provides recommended good practices for chemical storage that should be considered and implemented when appropriate:

Separate chemical products based on their physical state and inherent properties. Solid and liquid chemicals should be stored separately.
Ensure proper compatibility of chemicals as per information in the SDS (section 10).
Provide proper ventilation, lighting and controlled temperature and humidity wherever required for storage of chemical products sensitive to these parameters.
Make floors of storage area impermeable to liquids and non-slippery. They should be easy to clean and resistant to acids and organic solvents.
Plan the layout to accommodate all chemical containers with enough space for movement and easy accessibility to the containers.
Use color markings on the floor for designated walk areas and exit glow signs.
If required, ensure emergency exits are available and kept clear of obstacles, and that the exit door opens outwards with a push-bar handle.
Do a regular clean-out of expired chemical products, spill wastage and used containers.
Mark a designated area with a red (or the local required color) border for non-conformant chemical products that are to be returned to the chemical supplier. Keep relevant documents in the vicinity.
Keep the requisite amount of compatible fire- extinguishers in the stores and install smoke-detection alarms or sprinkler systems.
Ensure secondary containment for containers. At a minimum, the capacity of secondary containment must meet applicable legal requirements based on chemical volume and container size and should be 110% of the original (primary) container(s).

Gas cylinders should be stored in an upright position and in a separate location. The stored cylinders should be secured. LPG cylinders should be protected from direct sunlight and separated from flammable, combustible or oxidizing chemicals or other compressed gas cylinders.
Chemical products stored outdoors should have a proper cover to protect them from sun and rain and high temperatures. The area should be fenced to prevent unauthorized access. The flooring of such storage areas should be secured to prevent any leakages from contaminating the soil or water.
Access to chemical stores should be given only to authorized staff and their names and photographs should be displayed near the main entrance door.
Keep a spill control kit to contain spillages.
Keep a box file of all the SDS of chemical products stored near the Stores main entrance door. The file should be indexed properly with the names of the Chemical Formulator and products. The SDS file should be accessible to all staff. SDS can also be put in plastic folders and displayed on a notice board near the stores.
Install warning signage at key locations of stores to keep staff informed of risks.
Prepare “Chemical Safety Cards” to convey important information on hazards and First-Aid/emergency response measures in a pictorial manner for a quick understanding by staff handling chemical products.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have well marked, designated chemical storage areas for all chemicals stored onsite and the storage areas have all of the controls listed in the sub question.

Documentation Required:

Documentation that demonstrates the facility controls in place in chemical storage areas and these are appropriately maintained. This may include:
- Facility map showing the location of chemical storage areas.
- Floor layout plan of chemical storage areas, specifying categorization and storage location of different types of chemicals.
- Standard operating procedures for chemical storage and labelling.
- Examples of storage in/out logs, FEFO records, specifying date of arrival at storage, lot number, and date of dispatch to production, etc.)
- Audits/inspections checklists or reports of chemical storage areas.

Interview Questions to Ask:

Staff responsible for chemicals management understand the hazards and controls associated with chemical storage areas and can explain the facility’s procedures to ensure controls are in place and properly maintained.
Relevant staff (management and employees) understand the controls in place and their responsibilities for maintaining chemical storage areas.

Inspection – Things to Physically Look For:

Observations onsite indicate that the listed controls are in place and being properly maintained (e.g., incompatible chemicals are stored separately or at safe distances, stored chemicals have appropriate labels, secondary containment is in place and of sufficient size, protections are in place for flammable chemicals, required PPE is present and being used, etc.)

Partial Points:

Partial points will be awarded for facilities that have well marked, designated chemical storage areas for all chemicals stored onsite and the storage areas have some, but not all of the controls listed in the sub question.

chemstoragegroup

Answer

15. Does your facility have well marked sub-storage areas? (Ref ID: chemsubstorage)

Answer Yes if: Your facility has designated, well marked sub-storage areas for chemicals.

Answer Not Applicable if: Your facility does not have sub-storage areas.

Note: Sub-storage areas are defined as temporary or permanent areas used for storage and handling of chemicals during their use in production processes that are separate from the facility’s main bulk chemical storage area(s). This includes temporary storage areas used for loading, QA inspections, etc.

If you select Yes, you will be asked the following sub question(s) to indicate which practices are in place in chemical sub-storage areas at the facility:

The chemical storage area is ventilated, dry and protected from the weather.
Temporary storage containers are closed and labelled with contents, lot, and hazard class.
The chemical storage area is clearly marked.
Floor in the 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 liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur.
- Note: The need for secondary containment must be based on a formal risk assessment that considers the risk and potential impact of spills and must also meet applicable legal requirements based on chemical volume and container size.
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.
First Expiry, First Out (FEFO).
Health and safety measures are in place (such as PPE, etc).

Suggested Uploads:

Facility map showing the location of chemical sub-storage areas.
Floor layout plan of chemical sub-storage areas, specifying categorization and storage location of different types of chemicals.
Standard operating procedures for chemical storage and labelling (including sub-storage areas).
Example photos of chemical sub-storage areas and controls
Examples of storage in/out logs, FEFO records, specifying date of arrival at sub-storage, lot number, and date of dispatch to production, etc.)
Audits/inspections checklists or reports of chemical sub-storage areas.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that all sub-storage areas are well-marked and have sufficient controls to prevent contamination and safety risks.

Technical Guidance:

Proper chemical storage with appropriate controls is important to reduce and prevent health & safety and environment risks. This also applies to sub-storage areas which are defined as temporary or permanent areas used for storage and handling of chemicals during their use in production processes that are separate from the facility’s main bulk chemical storage area(s). This includes temporary storage areas used for loading, QA inspections, etc.

Implementing effective chemical storage practices in sub-storage areas can contribute to minimizing the risk of environmental contamination and maintaining a safe work environment. Storage conditions should be based on the recommended storage practices listed on safety data sheets (SDS) and/or storage practices recommended by chemical suppliers. Additionally, all legal requirements related to the storage of chemicals should be complied with.

Chemical sub-storage areas and controls should be designed and appropriate for the specific types, quantities, and hazards of chemicals used on site. For a detailed list of recommended good practices for chemical storage that should be considered and implemented when appropriate, refer to the Technical Guidance section for the FEM question above on chemical storage.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have well marked chemical sub-storage areas for all sub-storage areas onsite and the sub-storage areas have all of the controls listed in the sub question.

Documentation Required:

Documentation that demonstrates the facility controls in place in chemical sub-storage areas and these are appropriately maintained. This may include:
- Facility map showing the location of chemical sub-storage areas.
- Floor layout plan of chemical sub-storage areas, specifying categorization and storage location of different types of chemicals.
- Standard operating procedures for chemical storage and labelling (including sub-storage).
- Examples of storage in/out logs, FEFO records, specifying date of arrival at sub-storage, lot number, and date of dispatch to production, etc.)
- Audits/inspections checklists or reports of chemical sub-storage areas.

Interview Questions to Ask:

Staff responsible for chemicals management understand the hazards and controls associated with chemical sub-storage areas and can explain the facility’s procedures to ensure controls are in place and properly maintained.
Relevant staff (management and employees) understand the controls in place and their responsibilities for maintaining chemical sub-storage areas.

Inspection – Things to Physically Look For:

Observations onsite indicate that the listed controls are in place and being properly maintained (e.g., incompatible chemicals are stored separately or at safe distances, stored chemicals have appropriate labels, secondary containment is in place and of sufficient size, protections are in place for flammable chemicals, required PPE is present and being used, etc.)

Partial Points:

Partial points will be awarded for facilities that have well marked chemical sub-storage areas in all sub-storage areas onsite and the sub-storage areas have some, but not all of the controls listed in the sub question.

chemsubstoragegroup

Answer

16. Does your facility train employees responsible for the chemical management system on Restricted Substance Lists (RSLs)? (Ref ID: chemtrainingr)

Answer Yes if: Your facility has a designated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees with training records and/or material.

Answer Partial Yes if: Your facility has a designated person(s) responsible for RSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on RSL.

Note: RSL training must be provided by a knowledgeable and qualified person (internally or externally) who understands RSL requirements and procedures in place at the facility.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please describe the RSL trainings conducted in the reporting year.

If yes, how many employees were trained?

If yes, how frequently do you train your employees?

- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
Please upload documentation, if available

Suggested Uploads:

Documentation that demonstrates the facility has conducted training on RSL for relevant employees (e.g., RSL training records, training material, post-training evaluation records)
Documented job description for staff responsible for RSL management and compliance.

What is the intent of the question?

The intent of this question is to ensure that facilities have knowledgeable staff that are trained on RSL management and compliance.

Technical Guidance:

To effectively manage and implement RSL compliance programs, it is important to ensure that staff have the appropriate knowledge and training on RSL management and compliance. RSL management requires specific knowledge about applicable RSL requirements and procedures to ensure compliance.

Facilities should ensure that there are dedicated roles and responsibilities for staff who manage RSL compliance. This provides facilities with the needed resources to oversee RSL program implementation and ensure that relevant staff are trained on RSL requirements and procedures at the facility.

RSL training requirements can vary based on facility type and operations or products, however there are some key aspects that should be include in RSL training including, but not limited to:

All applicable RSL requirements at the facility
The facilities RSL management policy and procedures including procedures to investigate the root cause of RSL failures.
Chemical procurement and screening with respect to RSL
Areas of specific risks to RSL compliance at the facility.

Resources:

AFIRM Group RSL Toolkit https://afirm-group.com/Toolkit-EN/
AAFA Product Safety Guidance: Restricted Substances List (RSL) https://www.aafaglobal.org/AAFA/Solutions_Pages/Restricted_Substance_List

How This Will Be Verified:

Full Points:

Full points will be rewarded to facilities that have a designated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees with training records and/or material.

Documentation Required:

Documentation that demonstrates the facility has a dedicated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees.
- Documented job description and qualifications for staff responsible for RSL management and compliance
- RSL training records and/or training material
- Post-training evaluation records
- RSL management policy and procedures

Interview Questions to Ask:

Staff responsible for managing RSL at the facility can demonstrate appropriate knowledge of RSL.
Staff responsible for the facility’s RSL training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
Employees who have received the trainings are aware of the content of the training.

Inspection – Things to Physically Look For

Observations onsite indicate that the facility’s RSL program is being managed by trained and knowledgeable staff.

Partial Points:

Partial points will be awarded to facilities that have a designated person(s) responsible for RSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on RSL.

chemtrainingrgroup

Answer

17. Does your facility train employees responsible for the chemical management system on Manufacturing Restricted Substance Lists (MRSLs)? (Ref ID: chemtrainingm)

Answer Yes if: Your facility has a designated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees with training records and/or material.

Answer Partial Yes if: Your facility designated a person(s) responsible for MRSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on MRSL.

Note: MRSL training must be provided by a knowledgeable and qualified person (internally or externally) who understands MRSL requirements and procedures in place at the facility.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please describe the MRSL trainings conducted in the reporting year.

If yes, how many employees were trained?

If yes, how frequently do you train your employees?

- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
Please upload documentation, if available

Suggested Uploads:

Documentation that demonstrates the facility has conducted training on MRSL for relevant employees (e.g., MRSL training records, training material, post-training evaluation records)
Documented job description for staff responsible for MRSL management and compliance.

What is the intent of the question?

The intent of this question is to ensure that facilities have knowledgeable staff that are trained on MRSL management and compliance.

Technical Guidance:

All facilities should ban non-compliant hazardous chemicals from use in the facility as required by laws and regulations and/or customers’ requirements (e.g., the ZDHC Manufacturing Restricted Substance List (MRSL)).

To effectively manage and implement MRSL compliance programs, it is important to ensure that staff have the appropriate knowledge and training on MRSL management and compliance. MRSL management requires specific knowledge about applicable MRSL requirements and procedures to ensure compliance.

Facilities should ensure that there are dedicated roles and responsibilities for staff who manage MRSL compliance. This provides facilities with the needed resources to oversee MRSL program implementation and ensure that relevant staff are trained on MRSL requirements and procedures at the facility.

MRSL training requirements can vary based on facility type and operations or products for example facilities that use chemicals in production processes typically use a larger number of chemicals on-site and may require a more complex MRSL manage program that staff need be trained on as opposed to facilities that only use chemicals for facility operations or tooling. However, there are some key aspects that should be include in MRSL training including, but not limited to:

All applicable MRSL requirements at the facility
The facilities MRSL management policy and procedures including procedures to investigate the root cause of MRSL non-conformances that are identified.
Chemical procurement and screening with respect to MRSL
Areas of specific risks to MRSL compliance at the facility.

Resources:

ZDHC MRSL https://mrsl.roadmaptozero.com/
ZDHC Academy https://academy.roadmaptozero.com/

How This Will Be Verified:

Full Points:

Full points will be rewarded to facilities that have a designated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees with training records and/or material.

Documentation Required:

Documentation that demonstrates the facility has a dedicated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees.
- Documented job description and qualifications for staff responsible for MRSL management and compliance
- MRSL training records and/or training material
- Post-training evaluation records
- MRSL management policy and procedures

Interview Questions to Ask:

Staff responsible for managing MRSL at the facility can demonstrate appropriate knowledge of MRSL.
Staff responsible for the facility’s MRSL training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
Employees who have received the trainings are aware of the content of the training.

Inspection – Things to Physically Look For

Observations onsite indicate that the facility’s MRSL program is being managed by trained and knowledgeable staff.

Partial Points:

Partial points will be awarded to facilities that have a designated person(s) responsible for MRSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on MRSL.

chemtrainingmgroup

Answer

18. Does your facility have an established process to investigate and resolve a potential RSL failure? (Ref ID: chemfailresolution)

Answer Yes if: Your facility has a documented process for investigating and resolving RSL failures.

If you select Yes, you will be asked the following sub question(s):

If yes, does this process cover steps such as a root cause analysis, steps for a corrective action plan and documentation procedure of such activities?

If yes, does your facility have a Standard Operating Procedure (SOP) to resolve or prevent such a failure?

- Please upload your SOP

Suggested Uploads:

RSL management procedures that include the RSL failure investigation process.
Examples of documentation from past RSL failure investigations (e.g., failure investigation/resolution form)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that a process is in place to investigate and resolve any RSL failures.

Technical Guidance:

The goal of an RSL compliance program should focus on ensuring that chemicals and/or materials that are not RSL compliant or could result in RSL failures are not permitted to be used at the facility, however, if an RSL failure does occur, it is important to have a formal process to investigate and resolve RSL failures.

The cause of individual RSL failures can vary and having procedures to conduct a systematic investigation will help facilities identify the cause of the failure and address any gaps in their RSL management program. The investigation process should also include procedures for conducting a root cause analysis of the failure to prevent failures in the future.

When failures do occur, facilities should initiate an investigation and resolution process that includes, but is not limited to the key aspects listed below:

Stop production of the noncompliant material/product and quarantine and potentially non-compliance materials/products.
Ensure that any non-compliant material/products are not shipped from the facility.
Evaluate the scope of the issue and the current materials/processes that produced the failure.
Conduct a root cause investigation to identify the cause of the failure.
- Engage with material/chemical suppliers as needed to help identify the root causes.
Evaluate the need to update RSL management procedures to ensure the issue does not happen again.

Resources:

AFIRM Group RSL Toolkit https://afirm-group.com/Toolkit-EN/ (Note: Appendix D contains examples of RSL failures and corrective actions)

How This Will Be Verified:

Full Points:

Documentation Required:

Documentation that shows the facility has documented procedures to investigate and resolve RSL failures. This may include:
- RSL policy and/or management procedures that include RSL failure investigation process.
- Records of historical RSL failure investigations (e.g., failure investigation/resolution form)

Interview Questions to Ask:

Staff responsible for RSL management can explain the facility’s RSL failure investigation and resolution procedures.

Inspection – Things to Physically Look For:

Staff responsible for RSL failure investigation demonstrate sufficient knowledge of RSL and RSL failure investigation/resolution.

Partial Points: N/A

Chemicals Management – Level 2

Higg FEM Level Progression

If your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:

Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?

If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.

If you Answer No: Level 2 and 3 questions will not be available in this section.

Notes:

If your facility did not achieve Level 1 in this section, answering Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.
Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3

chemfailresolutiongroup

Answer

19. Does your facility engage contractor(s) or subcontractor(s) on MRSL / RSL? (Ref Id: chememgagecontractors)

Answer Yes if: Your facility has engaged contractor(s) or subcontractor(s) on MRSL/RSL, and this engagement includes:

Formal process to communicate the facility’s MRSL/RSL policy and requirements to contractors.
Procedures to evaluate and improve MRSL/RSL management programs at contractor/subcontractor facilities. This may include any of the following:
- Assessment or audit of MRSL/RSL management programs at the contractor/subcontractor.
- Requirements to complete and share Higg FEM.
- Requirements to purchase chemicals from positive lists.
- Where applicable, documented support to help contactors/subcontractors improve MRSL/RSL management (e.g., training, improvement plans).

Answer Not Applicable if: Your facility does not use any contractors or subcontractors.

Note: Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).

If you select Yes, you will be asked the following sub question(s):

Please describe how you engage your contractor or subcontractor in the process.
Please upload documentation, if available

Suggested Uploads:

Documentation that shows how the facility engages with contractors or subcontractors on MRSL/RSL (e.g., contracts/agreements that cover MRSL/RSL engagement and requirements, records of MRSL/RSL communication, assessments/audit reports and/or improvement plans from contractor/subcontractor engagement, records of Higg FEM completion and sharing, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they proactively engage contractors or subcontractors on MRSL/RSL.

Technical Guidance:

Manufacturing processes performed at contractor or subcontractor facilities can present risks related to a facility’s MRSL/RSL compliance program as they have the potential to use banned or restricted substances if they are not aware or negligent with the requirements of the facility’s MRSL/RSL policy and programs. Facilities should seek to proactively engage with any contractors or subcontractors to communicate and promote responsible MRSL/RSL management.

When engaging with contractors or subcontractors on MRSL/RSL management, facilities should communicate clear expectations and guidance to ensure compliance and adherence to MRSL/RSL requirements and good practices for MRSL/RSL management. This can be achieved through contractual agreements, ongoing communication to ensure all parties are aware of their roles and responsibilities in maintaining MRSL/RSL compliance.

Facilities should have procedures to outline the specific activities and responsibilities related to MRSL/RSL for contractor or subcontractor. This may include:

Assessment or audit of contractor/subcontractors MRSL/RSL management programs.
Requirements for contractor/subcontractors to complete and share Higg FEM.
Requirements for contractor/subcontractors to purchase chemicals from positive lists.

Facilities can also engage contractor/subcontractors by providing any necessary support to help contractor/subcontractors improve their MRSL/RSL management such as training/capacity building and/or support on developing or implementing improvement plans.

Resources:

- ZDHC MRSL https://mrsl.roadmaptozero.com/
- ZDHC MRSL Conformance Guidancehttps://downloads.roadmaptozero.com/input/ZDHC-MRSL-Conformance-Guidance

AFIRM Group RSL Toolkit https://afirm-group.com/Toolkit-EN/

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:
Full points will be awarded to facilities that have engaged with contractor(s) or subcontractor(s) on MRSL/RSL and this engagement includes:

Formal process to communicate the facilities MRSL/RSL policy and requirements to contractors.
Procedures to evaluate and improve MRSL/RSL management programs at contractor/subcontractor facilities. This may include any of the following:
- Assessment or audit of MRSL/RSL management programs at the contractor/subcontractor.
- Requirements to complete and share Higg FEM.
- Requirements to purchase chemicals from positive lists.
- Where applicable, documented support to help contractors/subcontractors improve MRSL/RSL management (e.g., training, improvement plans).

Documentation Required:

Documentation that shows the facility has engaged with contractors or subcontractors on MRSL/RSL. This may include.
- Contracts/agreements that cover MRSL/RSL engagement and requirements.
- Records of MRSL/RSL communication.
- Assessments/audit reports or improvement plans from contractor or subcontractor engagement.
- Records of Higg FEM completion and sharing by contractors/subcontractors.
- Records of training or capacity building with contractors/subcontractors.

Interview Questions to Ask:

Staff responsible for the MRSL/RSL engagement activities can describe how the facility engages with contractors/subcontractors on MRSL/RSL.

Inspection – Things to Physically Look For:

Where applicable, observations onsite are consistent with any reported contractor/subcontractor use and engagement.

Partial Points: N/A

chememgagecontractorsgroup

Answer

20. Does your facility engage upstream supplier(s) on MRSL / RSL? (Ref ID: chemengagesuppliers)

Answer Yes if: Your facility has engaged upstream suppliers on MRSL/RSL, and this engagement includes:

Formal process to communicate the facility’s MRSL/RSL policy and requirements to upstream suppliers.
Procedures to evaluate and improve MRSL/RSL management programs at upstream supplier facilities. This may include any of the following:
- Assessment or audit of MRSL/RSL management programs at the upstream supplier.
- Requirements to complete and share Higg FEM.
- Requirements to develop/provide positive lists (for chemical suppliers).
- Requirements to source chemicals from positive lists (for material suppliers)
- Where applicable, documented support to help upstream suppliers improve MRSL/RSL management (e.g., training, improvement plans).

Note: Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes, you will be asked the following sub question(s):

If yes, please describe which upstream supplier(s) you engage with.
Please describe how you engage your upstream supplier in the process.
Please upload documentation, if available.

Suggested Uploads:

Documentation that shows how the facility engages with upstream suppliers on MRSL/RSL (e.g., contracts/agreements that cover MRSL/RSL engagement and requirements, records of MRSL/RSL communication, assessments/audit reports and/or improvement plans from upstream supplier engagement, records of Higg FEM completion and sharing, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they proactively engage upstream suppliers on MRSL/RSL.

Technical Guidance:

Materials provided by upstream suppliers can present risks related to a facility’s MRSL/RSL compliance program as they have the potential to supply materials that contain banned or restricted substances if they are not aware or negligent with the requirements of the facility’s MRSL/RSL policy and programs. Facilities should seek to proactively engage with any contractors or subcontractors to communicate and promote responsible MRSL/RSL management.

When engaging with upstream suppliers on MRSL/RSL management, facilities should communicate clear expectations and guidance to ensure compliance and adherence to MRSL/RSL requirements and good practices for MRSL/RSL management. This can be achieved through contractual agreements, ongoing communication to ensure all parties are aware of their roles and responsibilities in maintaining MRSL/RSL compliance.

Facilities should have procedures to outline the specific activities and responsibilities related to MRSL/RSL for upstream suppliers. This may include:

Assessment or audit of upstream supplier MRSL/RSL management programs.
Requirements to complete and share Higg FEM.
Requirements to develop/provide positive lists (for chemical suppliers).
Requirements to source chemicals from positive lists (for material suppliers).

Facilities can also engage upstream suppliers by providing any necessary support to help them improve their MRSL/RSL management such as training/capacity building and/or support on developing or implementing improvement plans.

Resources:

- ZDHC MRSL https://mrsl.roadmaptozero.com/
- ZDHC MRSL Conformance Guidance https://downloads.roadmaptozero.com/input/ZDHC-MRSL-Conformance-Guidance

AFIRM Group RSL Toolkit https://afirm-group.com/Toolkit-EN/

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:
Full points will be awarded to facilities that have engaged with upstream suppliers on MRSL/RSL and this engagement includes:

Formal process to communicate the facility’s MRSL/RSL policy and requirements to upstream suppliers.
Procedures to evaluate and improve MRSL/RSL management programs at upstream supplier facilities. This may include any of the following:
- Assessment or audit of MRSL/RSL management programs at the upstream supplier.
- Requirements to complete and share Higg FEM.
- Requirements to develop/provide positive lists (for chemical suppliers).
- Requirements to source chemicals from positive lists (for material suppliers)
- Where applicable, documented support to help upstream suppliers improve MRSL/RSL management (e.g., training, improvement plans).

Documentation Required:

Documentation that shows the facility has engaged with upstream suppliers on MRSL/RSL. This may include.
- Contracts/agreements that cover MRSL/RSL engagement and requirements.
- Records of MRSL/RSL communication.
- Assessments/audit reports or improvement plans from contractor or subcontractor engagement.
- Positive lists from chemical suppliers.
- Records of Higg FEM completion and sharing by contractors/subcontractors.
- Records of training or capacity building with contractors/subcontractors.

Interview Questions to Ask:

Staff responsible for the MRSL/RSL engagement activities can describe how the facility engages with upstream suppliers on MRSL/RSL.

Inspection – Things to Physically Look For:

Where applicable, observations onsite are consistent with any reported upstream supplier use and engagement.

Partial Points: N/A

chemengagesuppliersgroup

Answer

21. Does your facility have the following capabilities and authority in your Chemical Management System (CMS) team? Select all that apply. (Ref ID: chemcmsteam)

Knowledgeable of chemical products, production processes and applications
You or your team have the requisite authority from the leadership to drive the CMS.
Has access to In-House Testing (pH Testing, Color Fastness).

Suggested Uploads:

Documentation that demonstrates the chemical management system (CMS) team has demonstrable knowledge of chemical products, production processes and applications (e.g., proof of tertiary education, certification/accreditation, training records/certificates).
Management system documentation (e.g., policies and procedures) that demonstrates CMS team members have the necessary authorization to manage the CMS effectively.

What is the intent of the question?

The intent of the question is for facilities to confirm that staff responsible for chemicals management have the technical capabilities and knowledge related to chemicals used in the facility and have sufficient authorization from the facility management to allow them to effectively manage the facility’s chemical management system (CMS).

Technical Guidance:

To manage a chemical management system effectively, responsible staff must have sufficient technical knowledge on chemicals and the facility’s production processes that utilize chemicals. Ensuring staff have the right capabilities and knowledge ensures that decisions related to chemicals management are made by qualified individuals. Knowledge is typically demonstrated through one or more of the following:

Tertiary education specific to chemicals (e.g., a degree in chemistry, chemical engineering or another related field).
Professional accreditation/certification or work experience related to chemicals and/or chemicals management.
Training from qualified training providers on topics specific to chemicals and/or chemicals management.

It is equally important the staff have the requisite authority from facility leadership to effectively implement and maintain the facility’s CMS. This means that staff are provided with the necessary resources (e.g., financial resources and time) and authority to carry out and/or manage all aspects of the CMS. This is typically demonstrated through job descriptions and/or documented accountabilities in management system documentation (e.g., policies and procedures), however actual implementation of effective chemical management system processes and procedures is also a good measure of this.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
The ZDHC Academy offers trainings to create awareness, learn and develop skills on sustainable chemical management – https://www.implementation-hub.org/academy

How This Will Be Verified:

Full Points:

Full points will be awarded if the facility’s chemical management system team has all of the following:

Knowledgeable of chemical products, production processes and applications

Requisite authority from the leadership to drive the CMS.

Access to In-House Testing (pH Testing, Color Fastness).

Documentation Required:

Documentation that demonstrates the chemical management system (CMS) team has demonstrable knowledge of chemical products, production processes and applications. This may include:
- Proof of tertiary education (e.g., copy of degree).
- Copies of professional accreditation or certifications related to chemicals and/or chemicals management.
- Records or certificate training on chemicals and/or chemicals management.
Management system documentation that demonstrates CMS team members have the necessary authorization to manage the CMS (e.g., job descriptions, policies and procedures).

Records of in-house testing.

Interview Questions to Ask:

Staff responsible for the facility’s CMS can demonstrate an understanding of chemicals, production processes and application throughout verification and can describe how they are authorized to effectively manage the CMS.
Facility leadership can explain how they ensure and facilitate the required authority for the CMS team.

Inspection – Things to Physically Look For:

Observations onsite indicate that CMS practices and procedures are being implemented by knowledgeable and qualified staff and that the CMS team has sufficient authority to effectively manage the CMS.
In-house testing equipment is available onsite.

Partial Points:

- Partial points will be awarded if the facility’s chemical management system team has one (1) or more, but not all of following:

Knowledgeable of chemical products, production processes and applications

Requisite authority from the leadership to drive the CMS.

- Access to In-House Testing (pH Testing, Color Fastness).

chemcmsteamgroup

Answer

22. Does your facility have an implementation plan to improve your chemicals management system? (Ref ID: chemimproveplan)

Answer Yes if: Your facility has one of the following:

A documented improvement plan to achieve a Yes response for all Higg FEM Level 1 Chemicals Management questions (Note: this applies to facilities that have one or more partial yes responses in level 1); or
A documented plan to further improve your chemicals management system (CMS) if your facility has already achieved a Yes response for all Higg FEM Level 1 Chemicals Management questions.

If you select Yes, you will be asked the following sub question(s):

Does your implementation plan include the following?

Goals based on your priorities and scope for the Chemical Management System

- Continuously improve the effectiveness of the Chemical Management System
- A hazardous chemicals use reduction plan.
Please upload documentation.

Suggested Uploads:

Documented improvement plan for achieving a Yes response for Level 1 Chemicals Management questions. This plan should include which Level 1 questions were not fully achieved, and defined actions to achieve a Yes response; or
If all Level 1 responses are Yes, a documented improvement plan to further improve chemicals management.

What is the intent of the question?

The intention of this question is for facilities to demonstrate that they are proactively working to continually improve chemicals management regardless of how advanced their current CMS is, and the amount or type of chemicals used onsite.

Technical Guidance:

Like any other management system, the goal of a chemicals management system should be to drive continuous improvement. This can and should be done regardless of how advanced a facility’s current CMS is, and the amount or type of chemicals used.

Note: For facilities that have not achieved a Yes response for all Level 1 questions in the FEM, these should be prioritized as the Level 1 questions focus on the foundational aspects of chemicals management.

The scope of improvements may depend on the extent (e.g., type and quantity) of chemicals used onsite and the status of the facility’s current CMS. For example, the scope of improvements for a facility that uses few chemicals or chemicals only for tooling or operation may be limited compared to a facility with more complex chemical use, however in both cases, facilities should have a structured process to review their CMS and chemical management procedures to identify and prioritize improvements. This can include, but is not limited to:

Review of the CMS policy, strategy, and chemicals management procedures at a specified frequency (e.g., annually) by the CMS Team or by external experts to identify areas for improvement.
- For example, conducting regular internal or external audits to identify areas for improvement.
Once areas for improvement have been identified, prioritize the improvements, and create improvement plans with defined timelines, actions, and responsibilities.
- Areas of improvement may consist of action to increase the effectiveness of the chemicals management system and/or reduction of hazardous chemical use.
Establish a process to monitor the improvement plan to ensure actions are implemented or updated as per the developed plan.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
ZDHC Supplier to Zero Program https://www.implementation-hub.org/supplier-to-zero
Implementation plan template: https://howtohigg.org/resources/resources-library/#templates

How This Will Be Verified:

Full Points:

Documentation Required:

An implementation plan that includes details of the specific actions the facility plans to take to improve the chemicals management system. This may include:
- If applicable, a list of Level 1 questions which were not fully achieved, and defined actions to achieve a Yes response for all Level 1 questions.
- If all Level 1 responses are already Yes, a plan with defined actions to further improve chemicals management.
- Implementation timelines (i.e., the planned start and completion dates for actions listed in the plan).

Note: If the facility has completed all actions in the plan prior to reporting year and does not have an implementation for improving chemicals management in the reporting year and beyond, a No response should be selected (i.e., points are not awarded for historical plans that were implemented prior to the reporting year).

Interview Questions to Ask:

Staff responsible for the implementation plan can explain the facility’s plan to achieve a Yes response to all Level 1 questions or further improve their chemicals management systems, as applicable.

Inspection – Things to Physically Look For:

The actions listed in the implementation plan directly relate to the observed chemical management practices and chemical use at the facility.

Partial Points: N/A

chemimproveplangroup

Answer

23. Does your facility have a traceability procedure in place which can track chemicals and raw materials used back from the product to the inventory? (Ref ID: chemtracelotnumber)

Answer Yes if: Your facility has documented traceability procedures that allows you to trace all chemicals and raw materials used back from the final product to the chemical or material inventory.

Answer Partial Yes if: Your facility has documented traceability procedures that allows you to trace some, but not all chemicals and raw materials used back from the final product to the chemical or material inventory.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Do you include the following practices in your traceability practice?

A clear overview of the source of your raw materials and chemical products and their suppliers.

- Record lot/batch number on the purchase order of every chemical.
- Record the lot/batch number of these chemicals on each colour/product batch.
- Record the lot/batch number of these chemicals on each article type/order.
- Do you record the lot/batch number of your raw materials (fabric, yarn, garment etc.) on each article type/order?
Please upload documentation.

Suggested Uploads:

Chemical/material traceability procedures.
Product batch cards including lot/batch number, dates, and production quantity.
Recipe cards, formulation sheets, process instructions (where applicable), containing all traceability information (e.g., chemical/material name, lot/batch number, quantity, etc.)
Chemical mixing/blending process records including relevant information (e.g., chemical name, lot/batch numbers and quantity used in mixtures).
Chemical/material inventory and/or usage logs with chemical/material lot/batch numbers, quantity, and dates of usage, etc.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that procedures are in place that allow for chemicals and materials used in a final product to be traced back to the chemical/material inventory.

Technical Guidance:

The purpose of traceability is to understand which chemicals and materials are used to make products. Traceability refers to the ability to select a final product and trace “backwards” to know the specific chemicals and raw materials that were used to produce that product (i.e., lots and batch numbers of chemicals/raw materials). This allows a facility to know all the components used to make each product. This also helps support investigations in case of any quality or material compliance issues or product recalls.

An effective traceability program will require facilities work with chemical and material suppliers, and any subcontractors to ensure that they provide traceable information on all chemicals/materials supplied to the facility (e.g., chemical name, ingredients, lot/batch number, production dates, etc.), and this information is recorded and tracked as part of the facility’s traceability program.

A traceability program should also maintain a traceable linkage of information throughout the entire production process including, but not limited to:

The product batch number.
The production processes that a particular product underwent.
The chemical recipe(s) in relation to each chemical process used to produce the material/product.
Information on chemicals used in these recipes at the chemical mixing (e.g., name, lot number, and quantity)
Linkage back to the chemical/material inventory and purchase records for information on the supplier and material composition and/or chemical ingredients.

Resources:

The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
ZDHC Supplier to Zero Program https://www.implementation-hub.org/supplier-to-zero

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have documented traceability procedures that allow the facility to trace all chemicals and raw materials used back from the final product to the chemical or material inventory and the facility’s traceability program includes all of the practices listed in the sub question.

Documentation Required:

Documentation that shows the facility has documented traceability procedures that allows the facility to trace all chemicals and raw materials used back from the final product to the chemical or material inventory. This may include:
- Chemical/material traceability procedures.
- Product batch cards including lot/batch number, dates, and production quantity.
- Recipe cards, formulation sheets, process instructions (where applicable), containing all traceability information (e.g., chemical/material name, lot/batch number, quantity, etc.)
- Chemical mixing/blending process records including relevant information (e.g., chemical name, lot/batch numbers and quantity used in mixtures).
- Chemical/material inventory and/or usage logs with chemical/material lot/batch numbers, quantity, and dates of usage, etc.
- Historical production records that show chemicals/material traceability.

Interview Questions to Ask:

Staff responsible for the facility’s traceability program can describe the procedures in place to track relevant information on chemicals and raw materials.
Relevant staff responsible for recording and/processing chemical or material information understand the facility’s traceability program and procedures.

Inspection – Things to Physically Look For:

Observations on site indicate that the facility’s traceability program is being implemented appropriately (e.g., chemical/material information such as batch/lot numbers, production recipes are appropriately documented, etc.)

Partial Points:

Partial point will be awarded to facilities that have documented traceability procedures that allows you to trace some, but not all chemicals and raw materials used back from the final product to the chemical or material inventory and/or the facility’s traceability program includes some, but not all of the practices listed in the sub question.

chemtracelotnumbergroup

Answer

24. Does your facility source already approved or preferred chemicals from a positive list? (Ref ID: chemsourcelist)

Answer Yes if: 50% or more of the chemical formulations in your facility’s chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway- Chemical Module(ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Answer Partial Yes if: If 49% or less of the chemical formulations in your facility’s chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Note: The percentage is based on the number of chemicals, not the volume (e.g., 50 out of 100 chemicals equals 50%).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Chemical purchasing policy.
Chemical inventory that indicates which chemicals are sourced from a positive list (skip if previously uploaded).
Copies of positive lists, or demonstrated access to positives list (e.g., bluesign FINDER).
Purchasing contracts/records that indicate sourcing of chemicals from positive lists.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they source chemicals from established positive lists to reduce impacts to human health and the environment.

Technical Guidance:

Positive lists are designed to provide facilities with a list of chemical products that have been screened and determined to be preferred options for use in manufacturing due to their reduced impacts on human health and the environment. Positive lists also consider the quality process in place at the facilities that manufacture these chemicals to ensure the composition of the chemical formulation is consistent over time and that the risk of unwanted impurities is limited.

Purchasing chemical formulations from reliable positive lists is an effective strategy 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 in the industry. Several brand-driven and third-party initiatives exist to identify positive chemistry such as the ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3) or bluesign FINDER.

Note: Information on chemical composition available in Safety Data Sheets (SDS) only should not be used for the development of positive lists as the level of detail available in SDSs usually does not identify impurities or substances non intentionally added that can often be the source of the non-compliance with an RSL or an MRSL.

Resources:

ZDHC Gateway- Chemical Module https://www.zdhc-gateway.com/
ZDHC InCheck Solutions https://www.roadmaptozero.com/process#Incheck-guidelines
bluesign FINDER https://finder.bluesign.com/index.html#

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities if 50% or more of the chemical formulations in their chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Documentation Required:

Documentation that demonstrates the facility sources and has purchased chemicals from positive lists. This may include:
- Chemical purchasing policy.
- Chemical inventory that indicates which chemicals are sourced from a positive list (skip if previously uploaded).
- Copies of positive lists, or demonstrated access to positives list (e.g., bluesign FINDER).
- Purchasing contracts/records that indicate sourcing of chemicals from positive lists.

Interview Questions to Ask:

Staff responsible for chemicals management and/or purchasing can explain the facility’s process to source chemicals from positive lists.

Inspection – Things to Physically Look For:

Observations onsite indicate that the facility is sourcing chemicals from positive lists (e.g., chemicals in use at the facility are listed on the positives lists used by the facility for sourcing).

Partial Points:

Partial points will be awarded for facilities if 49% or less of the chemical formulations in their chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway Chemical Modules (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Chemical Management – Level 3

chemsourcelistgroup

Answer

25. Have you adopted and implemented the ZDHC Roadmap to Zero (or the Supplier to Zero) programme on sustainable chemical management and its impact areas or other chemical management related industry programs? (Ref Id: chemzdhcroadtozero)

Answer Yes if: Your facility has formally adopted and implemented the ZDHC Roadmap to Zero (or the Supplier to Zero) programme on sustainable chemical management and its impact areas or other chemical management related industry programs.

Note:

Adoption is the decision to use the ZDHC MRSL or other guidelines for your business, as evident by changes in company’s internal and external policies and its communication
Implementation means steps are taken (beyond adoption) to put these decisions into action. Implementation could be, but is not limited to: training, change in purchasing / manufacturing practices to align with the programme, or adopting and monitoring metrics to track compliance with the policy.

If you select Yes, you will be asked the following sub question(s) to indicate which programs your facility has adopted and are implementing:

ZDHC Manufacturing Restricted Substances List (MRSL) & InCheck Solutions
ZDHC Wastewater Guidelines (for Leather & Textile) (WWG) & ClearStream report
ZDHC Chemical Management System (CMS) Framework & Technical Industry Guide & Supplier to Zero Certificate
ZDHC Man-Made Cellulosic Fibres (MMCF) Certificate (MMCF ONLY) / ZDHC MMCF Guidelines
ZDHC Air Emissions Guideline
ZDHC Waste Guidelines
Other
- If Other, please specify.

Suggested Uploads:

Documentation that demonstrates the facility has adopted and is implementing the selected programs (e.g., company policies/procedures showing commitment to and alignment with program requirements, adoption/use of program MRSL or positive lists).

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they have adopted AND implemented procedures to align with the ZDHC Roadmap to Zero (or Supplier to Zero) programme, or any similar initiatives, to improve sustainable chemical management and address related environmental and health impacts within their operations.

Technical Guidance:

The adoption of industry programs such as the ZDHC Roadmap to Zero (or the Supplier to Zero) programme provide a framework and resources for facilities to focus efforts on sustainable chemical management and reducing hazardous chemicals in the supply chain. This also facilitates further industry collaboration efforts to improve sustainability performance in the industry and reduce impacts to human health and the environment.

Adoption refers to the decision made by a facility to integrate the ZDHC Roadmap to Zero programme or other similar guidelines into its business operations, as demonstrated by incorporating the program guidelines and requirements into the facility’s internal policies and practices, and any relevant external policies and communication (e.g., chemical purchasing policy, CMS/EMS procedures, training of staff, communication with stakeholders, etc.)

Implementation goes beyond adoption where facilities need to demonstrate that they are taking concrete actions to implement practices that align with the program guidance and requirements. Such actions can include, but are not limited to, modifications in chemical procurement practices, staff training and capacity building, and the establishment of systems to monitor and ensure compliance with the program requirements.

Resources:

The ZDHC Roadmap to Zero (or the Supplier to Zero) programme are initiatives aimed at promoting sustainable chemical management practices within the textile and footwear industry, with a focus on eliminating hazardous chemicals in production processes.

ZDHC Roadmap to Zero https://www.roadmaptozero.com/?locale=en
ZDHC Supplier to Zero https://www.implementation-hub.org/supplier-to-zero

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have formally adopted and implemented one (1) or more of the programs listed in the sub question.

Documentation Required:

Documentation that demonstrates the facility has adopted and is implementing the selected program(s). This may include:
- Company policies/procedures showing commitment to the programme (e.g., chemical purchasing policy).
- Demonstrated adoption/use of ZDHC MRSL or ZDHC Gateway- Chemical Module where applicable (e.g., chemical purchasing records, access to positive lists/databases)
- Training records on policies/procedures related to program adoption.
- Records of capacity building for staff on technical competencies needed to manage chemical programs in accordance with the adopted programs.

Interview Questions to Ask:

Staff responsible for program adoption are knowledgeable on the programme requirements and can explain the facility’s procedures for aligning with the program and how implementation/compliance with the program is monitored.

Inspection – Things to Physically Look For:

Observations on site are consistent with the facility’s policies and procedures in place to align with the adopted program(s).

Partial Points: N/A

chemzdhcroadtozerogroup

Answer

26. Do you have a transparency policy or procedure in which you share information regarding chemical products, chemical waste, and wastewater with stakeholders (For example: with ZDHC, chemical formulators, brands/retailers, authorities, NGOs)? (Ref ID: chemtransparency )

Answer Yes if: Your facility has a documented transparency policy or procedure in place and you share information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders.

Suggested Uploads:

Copy of the facility’s transparency policy
Examples of documented communications with stakeholders (email, report submittal, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate they have a transparency policy in place and are actively communicating information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders.

Technical Guidance:

Having a documented transparency policy or procedure demonstrates a facility’s commitment to openness, collaboration, and accountability in addressing environmental and health impacts associated with chemical management in their operations.

A transparency policy should focus on sharing relevant information with specific groups of stakeholders such as customers, industry associations, local government, NGOs and supply chain partners. The transparency policy should include, but is not limited to:

A list of stakeholders that the facility communicates with.
The type of documents and information shared with each type of stakeholder.
Frequency of sharing the documents and information
Process of sharing

The list below provides some examples of the information that may be shared with relevant stakeholders as part of a transparency program.

Chemical Formulators and Raw Material Suppliers:
- MRSL/ Sustainable chemistry requirements
- SDS requirements
- Chemical Management Policy
- Specification for chemical compliance and quality requirements

Authorities/Local Government:
- Wastewater test reports
- Permit renewals
- ETP design

Brands/Retailers/Industry Groups:
- Wastewater test report (e.g., ZDHC ClearStream)
- Chemical Management Policy
- Chemical/hazardous waste data
- Permit renewals

NGOs:
- Corporate sustainability report
- Proof of participation in industry program (e.g., ZDHC)

Resources:

The ZDHC Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance

How This Will Be Verified:

Full Points:

Documentation Required:

Documentation that shows the facility has a documented transparency policy or procedure in place and they have shared information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders. This may include:
- The facility’s transparency policy/procedure.
- A list of stakeholders the facility communicates with.
- Examples of documented communications with stakeholders (email, report/information submittals, etc.)

Interview Questions to Ask:

Staff responsible for the facility’s transparency policy and communicating to stakeholders can explain the facility’s transparency policy and how information is communicated to stakeholders.

Inspection – Things to Physically Look For:

Observations indicate the information provided in the transparency policy and any stakeholder communications is accurate and relevant to the facility’s operations.

Partial Points: N/A

27. Does your facility collaborate with brands and/or chemical suppliers to select chemicals for alternatives assessment? (Ref Id: chemcollabalternatives)

Answer Yes If: Your facility has collaborated with brands and/or chemical suppliers to nominate and assess chemicals used in the manufacturing process for alternatives assessment and has established the following:

A list of prioritized chemicals used in production processes and proposed alternatives that was developed through a transparent, science-based approach that evaluates chemicals and/or chemical products.
A documented process for collaboration with brands or chemical suppliers regarding chemical alternatives, substances of concern.

Notes:

This assessment must cover chemicals/substances that are not already restricted through regulation.
If your facility does not actively participate in identifying and assessing chemicals/substances of concern and/or alternative chemicals, you should answer No to this question.

If you select Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Prioritized list of substances of concern and alternatives for chemicals in use at the facility
Records from collaborative meetings between facility, brand customers, and/or chemical suppliers regarding alternative chemicals (e.g., meeting minutes)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have an established process in place to collaborate with brands and/or chemical suppliers to identify and assess chemical alternatives for chemicals used in the manufacturing process.

Technical Guidance:

It’s critical that value chain partners work together to identify substances of concern and evaluate less hazardous alternatives.

An alternative assessment for chemicals is a process to minimise chemicals of concern while considering performance and economic viability through identifying, comparing and selecting safer alternatives. A primary goal of an alternatives assessment is to reduce risk to property, humans and the environment by identifying less hazardous materials.

A chemical alternatives assessment may be used to prioritise replacement of hazardous chemicals or chemical products. To avoid regrettable substitutions, a thorough assessment of the proposed alternative should follow a transparent, science-based, simple and reasonable system that evaluates chemicals and/or chemical products.

Collaboration to identify and develop alternatives can take various forms which may consist of formal processes to:

Identify hazards associated with chemicals and/or substances of concern currently in use.
Identify alternatives (e.g., public database/internet searches or collaborative meetings to identify alternative chemicals and suppliers)
Compare alternatives including potential changes required to production processes (e.g., technical/hazard review, pilot testing, etc.)

Resources:

The ZDHC Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
US OSHA Transitioning to Safer Chemicals: A Toolkit for Employers and Workers https://www.osha.gov/safer-chemicals/basics
BizNGO Chemical Alternatives Assessment Protocol https://www.bizngo.org/alternatives-assessment/chemical-alternatives-assessment-protocol

How This Will Be Verified:

Full Points:

Documentation Required:

Documentation that demonstrates the facility has collaborated with brands and/or chemical suppliers to nominate and assess chemicals used in the manufacturing process for alternatives assessment. This must include:
- A list of prioritized chemicals used in production processes and proposed alternatives that was developed through a transparent, science-based approach that evaluates chemicals and/or chemical products.
- A documented process for collaboration with brands or chemical suppliers regarding chemical alternatives, substances of concern.
Records from collaborative meetings between facility, brand customers, and/or chemical suppliers regarding alternative chemicals (e.g., meeting minutes)

Interview Questions to Ask:

Staff responsible for evaluating alternatives can describe the facility’s process to collaborate with stakeholders to identify and assess chemicals or substances of concerns and alternatives.

Inspection – Things to Physically Look For:

Observations on site are consistent with the facility’s reported work to identify and assess alternatives (e.g., the facility’s priority list of hazardous chemicals or substances of concern is consistent with chemicals used in production processes at the facility).

Partial Points: N/A

chemcollabalternativesgroup

Answer

28. Does your facility contribute to a chemical analysis against human and environmental hazard criteria (e.g., persistent, bio-accumulative, and toxic) for selecting alternative processes? (Ref Id: chemanalysishumanenv)

Answer Yes if: Your facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria and have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.

Answer Partial Yes if: Your facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria, but do not have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Hazardous chemicals risk assessment report such as a Screened Chemistry or Cradle2Cradle assessment report for chemicals in use and/or proposed alternatives.
Evidence the facility has evaluated chemicals used in manufacturing and their alternatives against established human health and environmental hazard criteria.
Prioritized list of chemical substitutions based on the hazard assessment.

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they actively participate in the alternative assessment process by conducting or contributing to a chemical hazard assessment that evaluates human and environmental hazards.

Technical Guidance:

For this question in the FEM, the alternative assessment/selection process refers to an evaluation of human health and environmental hazards and risks of chemicals in use or proposed as alternatives to ensure all hazards/risks are fully evaluated to avoid chemical substitutions that could result in unintended risk or impacts. This should be done to prioritize action to reduce, substitute or ultimately phase out hazardous chemical use.

This level of evaluation requires specific technical expertise to ensure all risks (e.g., hazards and exposure potentials) are appropriately identified and evaluated using systematic approach. This should include consideration of all intrinsically hazardous properties and risks (e.g., persistent, bio-accumulative, and toxic (PBT); very persistent and very bio-accumulative (vPvB); carcinogenic, mutagenic, and toxic for reproduction (CMR); endocrine disruptors (ED), etc.)

Benefits of conducting a systematic hazard/risk assessment include:

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 can be adapted and input into information technology tools, making it possible to screen 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 can readily be adaptable to multiple industry sectors and provides a science-based approach to evaluating chemical hazards so that less hazardous alternatives may be identified.

Resources:

Outdoor Industry Association (OIA) Guidance for Using Chemical Hazard Assessment for Alternative Chemical Assessment and Prioritization https://oia.outdoorindustry.org/OIAZDHCHazardAssessment
The ZDHC Chemical Management System (CMS) framework and Chemicals Management System Technical Industry Guide can be downloaded here: https://www.roadmaptozero.com/process#Guidance
TOXFMD Screened Chemistry https://www.screenedchemistry.com/

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria and have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.

Documentation Required:

Documentation that demonstrates the facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria. This may include:
- Hazardous chemicals risk assessment report such as a Screened Chemistry or Cradle2Cradle assessment report for chemicals in use and/or proposed alternatives.
- Evidence the facility has evaluated chemicals used in manufacturing and their alternatives against established human health and environmental hazard criteria.
- If applicable, a prioritized list of chemical substitutions/actions based on the hazard assessment.

Interview Questions to Ask:

Staff involved in the chemical hazard assessment process can describe how the facility evaluates human health and environmental hazards and risks of chemicals in use or proposed as alternatives to ensure all hazards/risks are fully evaluated to avoid chemical substitutions that could result in unintended risk or impacts.

Inspection – Things to Physically Look For:

Observations on site are consistent with the facility’s reported work to identify and assess alternatives (e.g., the facility’s hazard assessment is consistent with chemicals used in production processes at the facility).

Partial Points:

Partial points will be awarded to facilities that have conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria, but do not have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.

chemanalysishumanenvgroup

Answer

29. Does your facility contribute to an analysis of lifecycle impacts for selecting alternative processes? (Ref ID: chemanalysislifecycle)

Answer Yes if: Your facility has evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on all of the following aspects:

Water usage
Energy usage
Waste generation/disposal
Wastewater generation and quality
Resource depletion
Air emissions
Human health hazards

Answer Partial Yes if: Your facility has evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on some, but not all of the following aspects:

Water usage
Energy usage
Waste generation/disposal
Wastewater generation and quality
Resource depletion
Air emissions
Human health hazards

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Please upload documentation.

Suggested Uploads:

Evidence the facility has evaluated chemicals used in manufacturing and their alternatives to determine life cycle impacts in addition to chemical hazard and risk.

- Lifecycle studies or other third-party assessments.

bluesign Xpert assessment.

- Documented metrics for water, energy, waste, etc.

MFCA (Material Flow Cost Accounting).

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they have evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives.

Technical Guidance:

Facilities should strive to optimize chemical use and manufacturing processes to minimize all environmental impacts associated with production (e.g., energy and water consumption, waste generation, wastewater quality, etc). An example would be choosing a different dyestuff or recipe that results in reduced water or energy consumption during a dyeing process. The efficiency of a manufacturing process can be highly dependent on the optimization chemical use along with the manufacturing equipment/process. The optimization of these elements can generate significant benefits by reducing the amount of chemicals used, reducing resource consumption, and waste associated with the process and therefore reducing the life cycle impacts of the system.

A life cycle assessment (LCA) is a systematic approach to evaluate the environmental footprint of a product. This evaluation goes beyond just assessing chemical hazards and risk and is a more comprehensive approach to sustainability which looks at the life cycle impacts within and beyond the facility. LCAs should be conducted by qualified individuals in accordance with a recognized LCA framework such as ISO14040:2006.

Resources:

American Center for Life Cycle Assessment https://lcacenter.org/
Ecochain – Life Cycle Assessment (LCA) – Complete Beginner’s Guide https://ecochain.com/knowledge/life-cycle-assessment-lca-guide/
World Business Council for Sustainable Development – Life Cycle Metrics for Chemical Products http://wbcsdservers.org/wbcsdpublications/cd_files/datas/business-solutions/reaching-full-potential/pdf/Chemical%20Sector%20Life%20Cycle%20Metrics%20Guidance.pdf
ISO 14040:2006 Life cycle assessment – Principles and framework https://www.iso.org/standard/37456.html
ZDHC MMCF Guidelines https://www.roadmaptozero.com/process#materials

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on all of the following aspects:

Water usage
Energy usage
Waste generation/disposal
Wastewater generation and quality
Resource depletion
Air emissions
Human health hazards

Documentation Required:

Documentation that shows the facility has evaluated chemicals used in manufacturing and their alternatives to determine life cycle impacts in addition to chemical hazard and risk. This may include:

- Lifecycle studies or other third-party assessments.

bluesign Xpert Assessment.

- Documented metrics for water, energy, waste, etc.

MFCA (Material Flow Cost Accounting).

Interview Questions to Ask:

Staff responsible for managing the assessment process can describe how the facility tracks and evaluates life cycle impacts of chemicals used in manufacturing processes and proposed alternatives.

Inspection – Things to Physically Look For:

Observations on site are consistent with the facility’s reported work to identify and assess the life cycle impacts of chemicals in use and alternatives (e.g., the facility’s life cycle impact assessment is consistent with chemicals used in production processes at the facility).

Partial Points:

Partial points will be awarded to facilities that evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on some, but not all of the following aspects:

Water usage
Energy usage
Waste generation/disposal
Wastewater generation and quality
Resource depletion
Air emissions
Human health hazards

chemanalysislifecyclegroup

Answer

30. Does your contractor(s)/subcontractor(s)/upstream supplier(s) source already approved or preferred chemicals from a positive list to replace chemicals not already included in RSL? (Ref ID: chemcontractorsr)

Answer Yes if: Your facility has a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements.

Answer Partial Yes if: Your facility has a documented policy/ agreement in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements, however you are unsure or cannot demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements.

Notes:

Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).
Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or Restricted Substance Lists with your contractor(s)/subcontractor(s)/upstream supplier(s)?
Please upload documentation.

Suggested Upload:

Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists.
- List of contractors, subcontractors, and upstream suppliers.
- Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence).
- Higg FEM verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
- Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers.
- Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.
- Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or RSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a process or plan is in place to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists that go beyond RSL requirements.

Technical Guidance:

Facilities should proactively engage with their supply chain partners (i.e., contractors and upstream suppliers) to require the use of chemicals that are less hazardous and reduce impacts to human health and the environment. This can be done by requiring contractors and upstream suppliers to source chemicals from recognized positive lists (e.g., ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3) or bluesign FINDER, etc.)

Facilities should work with contractors and upstream suppliers to understand the chemicals used at their facilities with the goal of identifying and prioritizing hazardous chemicals for substitution that are not already regulated by legislation or existing RSL with a focus on reducing risk as much as possible. For example, if a facility is currently following an industry or brand specific RSL, the facility can also proactively search to identify and require the phase out of hazardous chemicals not listed in the RSL by using available databases or other sources of information on safer alternative chemistry (e.g., ZDHC Gateway- Chemical Module, ECHA SVHC List, ChemSec SIN list).

It is also important to ensure that these expectations and requirements are clearly communicated with contractors and upstream suppliers. For example, facilities may include requirements to restrict chemicals and/or source from positive lists in the terms and conditions of contractual agreements.

Resources:

Note: Some resources provided below may include reference to legal requirements that may not apply to your facility. Facilities are expected to comply with applicable legal requirements related to chemicals management.

ZDHC Gateway- Chemical Module https://www.zdhc-gateway.com/
bluesign FINDER https://finder.bluesign.com/index.html#
ChemSec SIN list https://sinlist.chemsec.org/
European Chemical Agency (ECHA) SVHC (Substance of very high concern) (https://echa.europa.eu/candidate-list-table)
Substitution Support Portal https://www.subsportplus.eu/subsportplus/EN/Home/Home_node.html
Washington State Reporting List of Chemicals of High Concern to Children (CHCC) https://ecology.wa.gov/Regulations-Permits/Reporting-requirements/Childrens-Safe-Products-Act-Reporting/Chemicals-of-high-concern-to-children

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream supplier replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements.

Documentation Required:

Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. This may include:
- List of contractors, subcontractors, and upstream suppliers that the facility engages with.
- Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence)
- Higg FEM verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
- Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers.
- Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.
- Records of chemical substitution at contractors, subcontractors, and upstream suppliers, if applicable.
- Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or RSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

Interview Questions to Ask:

Staff responsible for engaging with contractors, subcontractors, and upstream suppliers can explain the facilities procedures or plan to require suppliers to source chemicals from positive lists.

Inspection – Things to Physically Look For:

Where applicable, observations onsite indicate that the facility has, or is planning to engage with contractors, subcontractors, and upstream suppliers (e.g., observed supplier/contractor material or activities is consistent with the facility’s reported list of suppliers/contractors and type of engagement.)

Partial Points:

Partial points will be awarded to facilities that have a documented policy/agreement in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that goes beyond RSL requirements.

chemcontractorsrgroup

Answer

31. Does your contractor(s)/subcontractor(s)/upstream supplier(s) source already approved or preferred chemicals from a positive list to replace chemicals not already included in MRSL? (Ref Id: chemcontractorsm)

Answer Yes if: Your facility has a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond manufacturing restricted substances list (MRSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements.

Answer Partial Yes if: Your facility has a documented policy/agreement in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements, however you are unsure or cannot demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements.

Notes:

Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).
Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or Manufacturing Restricted Substance Lists with your contractor(s)/subcontractor(s)/upstream supplier(s)?
Please upload documentation.

Suggested Upload:

Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists.
- List of contractors, subcontractors, and upstream suppliers.
- Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence).
- Higg verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
- Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers.
- Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.
- Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or MRSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

What is the intent of the question?

Technical Guidance:

Facilities should proactively engage with their supply chain partners (i.e., contractors and upstream suppliers) to require the use of chemicals that are less hazardous and reduce impacts to human health and the environment. This can be done by requiring contractors and upstream suppliers to source chemicals from recognized positive lists (e.g., ZDHC Gateway- Chemical Module(ZDHC MRSL Conformance Level 3) or bluesign FINDER, etc.)

Facilities should work with contractors and upstream suppliers to understand the chemicals used at their facilities with the goal of identifying and prioritizing hazardous chemicals for substitution that are not already regulated by legislation or existing MRSL with a focus on reducing risk as much as possible. For example, if a facility is currently following an industry or brand specific MRSL, the facility can also proactively search to identify and require the phase out of other hazardous chemicals not listed in the MRSL by using available databases or other sources of information on safer alternative chemistry (e.g., ZDHC Gateway- Chemical Module, ZDHC MRSL Candidate List, ECHA SVHC List, ChemSec SIN list).

Resources:

ZDHC Gateway- Chemical Module https://www.zdhc-gateway.com/
ZDHC MRSL (refer to MRSL Candidate List) https://mrsl.roadmaptozero.com/
bluesign FINDER https://finder.bluesign.com/index.html#
ChemSec SIN list https://sinlist.chemsec.org/
European Chemical Agency (ECHA) SVHC (Substance of very high concern) (https://echa.europa.eu/candidate-list-table)
Substitution Support Portal https://www.subsportplus.eu/subsportplus/EN/Home/Home_node.html
Washington State Reporting List of Chemicals of High Concern to Children (CHCC) https://ecology.wa.gov/Regulations-Permits/Reporting-requirements/Childrens-Safe-Products-Act-Reporting/Chemicals-of-high-concern-to-children

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream supplier replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements.

Documentation Required:

Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. This may include:
- List of contractors, subcontractors, and upstream suppliers that the facility engages with.
- Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence)
- Higg verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
- Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers.
- Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.
- Records of chemical substitution at contractors, subcontractors, and upstream suppliers, if applicable.
- Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or MRSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

Interview Questions to Ask:

Staff responsible for engaging with contractors, subcontractors, and upstream suppliers can explain the facilities procedures or plan to require suppliers to source chemicals from positive lists.

Inspection – Things to Physically Look For:

Where applicable, observations onsite indicate that the facility has, or is planning to engage with contractors, subcontractors, and upstream suppliers (e.g., observed supplier/contractor material or activities is consistent with the facilities reported list of suppliers/contractors and type of engagement.)

Partial Points:

Partial points will be awarded to facilities that have a documented policy/agreement in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements.

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Answer

Higg FEM How to Higg Guide 2024

Table of Contents

General Introduction

Chemical Use At Your Facility

ZDHC Partnership and Resources

Applicability Questions

Chemical Management – Level 1

Chemicals Management – Level 2

Chemical Management – Level 3