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Conformity in FEM 3.0: Chemical
Management
Workshop
06.02.2018
Disclaimer
“Any opinions, findings, conclusions or recommendation expressed in this material/event(or by member of the Project team) do not reflect the
views of the Government of the Hong Kong Special Administrative Region, Trade and Industry Department of the Vetting Committee of the
SME Development Fund”
Organizer Implementation Agent Funded by SME Development Fund
1
Sustainable Apparel Coalition
Agenda
Time Content
14:30-14:40 Welcome Remark and Introduction of SAC
14:40-15:50 Higg Index 3.0 - Chemical Management
Section Quick Overview
15:50-16:20 Application on Chemical Management E-
learning Platform and Exercise
16:20-16:30 Q&A
2
Introduction of Chemical Management System
Sustainable Apparel Coalition 4
FEM Structure
Management Sections 1. Have right staff in place
2. Adhere to the rules (regulations, laws, brand
requirements)
3. Have long-term, holistic strategies and
action plans in place
4. Take specific management actions (e.g.,
storage, handling, maintain equipment, etc)
5. Demonstrate leading practice (e.g., engage
upstream and with community, innovation,
deep traceability)
One module per factory site (account) per year
Facility Information + 7 impact areas
Level 1-3 structure remains
Sustainable Apparel Coalition 5
Converged Chemicals Management Section
Every question in this section is written to drive facilities to excel in each of these categories:
• Chemical Management Policies, Compliance Procedures,
and Commitments:
• Employee Training & Communication
• Chemical Selection, Procurement, & Purchasing Practices
• Chemical Handling, Use, & Storage Practices
• Chemical Inventory Management
• Emergency Response Plan (ERP), Accidents & Spills
Remediation Plan
• Product Quality / Integrity
• Chemicals & Process Innovation
Yes = 23 questions
No = 13 questions
Sustainable Apparel Coalition
Results of applicability test
• If any processes are selected, you are using chemicals in production process.
Most likely all the Tier 2 and Tier 3 and garment facilities with washing will fall into this category.
6
Sustainable Apparel Coalition
Results of applicability test
• If none are selected, you are using chemicals in facility tooling and/or operations only. This category refers to facility uses chemicals in
other parts of daily operations such as: Cleaning product Machine lubricant Spot cleaners Paint Chemicals for wastewater treatment plant
(if any). Most likely Tier 1 cut and sew facility without
vertical integrated will fall into this category. 7
Sustainable Apparel Coalition
Level 1 Question Question Uses chemicals
in production
Uses chemicals in
operations / tooling
1. Does your facility keep an inventory of chemicals
used and the suppliers of each chemical product?
X X (NA for non-tooling)*
2. Does your facility make Safety Data Sheets (SDS)
available to employees for all chemicals used?
X X (NA for non-tooling)*
3. Does your facility train all employees who use
chemicals on chemical hazards, risk, proper
handling, and what to do in case of emergency or
spill?
X X
4. Does your facility have a chemical spill and
emergency response plan that is practiced
periodically?
X X or NA (for non-
tooling)*
8
*If you do not have any chemicals that may touch product (e.g. cleaning products) and/or do
not use chemicals to maintain or lubricate machines, you may select “NA”.
Sustainable Apparel Coalition
Level 1 Question Question Uses chemicals in
production
Uses chemicals in
operations / tooling
5. 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?
X X
6. Does your facility have chemical hazard signage
and safe handling equipment in the areas of the
facility where chemicals are used?
X X
7. Does your facility select and purchase chemicals
based on their hazards and MRSL / RSL
requirements?
X X
8. Does your facility have an environmental and
occupational health and safety program specific to
chemicals management?
X X
9
Sustainable Apparel Coalition
Level 1 Question Question Uses chemicals
in production
Uses chemicals in
operations / tooling
9. Does your facility have well marked, designated
chemical storage and temporary storage areas?
X X
10. Does your facility train employees responsible for
the chemical management system on Restricted
Substance Lists (RSLs) and Manufacturing Restricted
Substance Lists (MRSLs)?
X
11. Does your facility have a documented process to
systematically identify, monitor and verify compliance
with all product Restricted Substance Lists (RSLs)?
X
12. Does your facility have a documented process to
systematically monitor, update and demonstrate
compliance with Manufacturing Restricted Substance
Lists (MRSLs)?
X
13. Can all of your production chemicals be traced
from the manufacturing process back to chemical
inventory?
X
10
Sustainable Apparel Coalition
Level 2 Question Question Uses chemicals in
production
Uses chemicals in
operations / tooling
14. Does your facility have an implementation plan
to improve your chemicals management program?
X X
15. Does your facility have an implementation plan
to reduce the use of hazardous chemicals beyond
chemicals specified by regulations and/or Restricted
Substance Lists / Manufacturing Restricted
Substance Lists?
X X
16. Does your facility source already-approved or
preferred chemicals from a positives list beyond
chemicals specified by regulations and/or Restricted
Substance Lists / Manufacturing Restricted
Substance Lists?
X X
11
Sustainable Apparel Coalition
Level 3 Question Question Uses chemicals in
production
Uses chemicals in
operations / tooling
17. Does your facility collaborate with brands and/or
chemical suppliers to select chemicals for
alternatives assessment?
X X
18. Can your manufacturing process chemicals be
traced from product lot number back to chemical lot
number?
X
19. Does your facility contribute a chemical analysis
against human and environmental hazard criteria
(e.g., persistent, bio-accumulative, and toxic) to this
alternatives process?
X
20. Does your facility contribute an analysis of
lifecycle impacts to this alternatives process?
X
12
Sustainable Apparel Coalition
Level 3 Question Question Uses chemicals in
production
Uses chemicals in
operations / tooling
21. Does your facility have a documented Quality
Assurance (QA) Program that includes performance
of chemicals?
X
22. Do your contractors/subcontractors source
already-approved or preferred chemicals from a
positives list to replace chemicals not already
included in RSL/MRSL?
X
23. Does your facility have documented business
goals, processes and actions showing commitment
(e.g., equipment, process, choice of substitute
chemicals) to new sustainable chemistry innovation?
X
13
What is Chemical Management System?
CHEMICAL MANAGEMENT SYSTEM
Taking full control of all operations and activities where chemicals are
involved in the facility.
Resource:
Know Assess Decide Source : OIA
OBJECTIVES FOR A CHEMICAL MANAGEMENT SYSTEM
Primary Objectives Outputs
Chemical Hazard
Assessment (low, med, high)
Safer Alternatives
Assessment & Preferred
Substances
Chemical Safety & Risk Management
Restricted Substances / Substances of
Concern
Insufficient data?
Regular re-evaluation
Regulatory Awareness & Compliance
Process & Product Chemicals Knowledge
Sustainable Chemistry
Innovation & Continuous
Improvement
Substances of Concern List
Preferred Substances List
Restricted Substances List
Innovate
Keep
Substitute
Manage
BENEFITS OF A CHEMICAL MANAGEMENT SYSTEM AND RESOURCE EFFICENCY
Maintain a license to operate
Traceability of chemicals in the
supply chain
Stop potential hazards
Minimise excessive or replicative
chemical purchases
Helps facilities ensure that RSL compliant materials are being
produced
creating a safer work environment
Reduce cost
KEEP IT SIMPLE AND PRACTICAL
What should
you do?
Set up inventory
Track chemical use
Risk assessment and safety measures
Understanding regulation, RSL/MRSL
Continual improvement
Inventory and SDS
CHEMICAL INVENTORY
A Chemical Inventory is a structured base of information to:
• Demonstrate compliance with existing regulations (legal, brands).
• Conduct risk assessment of each chemical and rank chemicals accordingly.
• Comprehensive chemical list to assess chemical hazards.
• Improved access to safety information.
• Selection of appropriate personal protective equipment (PPE) for workers.
• Eliminate duplication of chemicals ordered.
• Provide for surplus chemical used on-site.
• Correct storage of hazardous chemicals.
• Assess alternatives to hazardous chemicals in use.
• Basis to define training content.
• Decrease disposal cost.
Reference: Based on ZDHC Chemical Management Systems Guidance Manual
WHAT A CHEMICAL INVENTORY SHOULD COVER
Your system might look different to others – there is not “one system”.
Reference: Based on ZDHC Chemical Management Systems Guidance Manual
All the information necessary to track and control all chemicals in the facility
Identify every chemical in the facility
Amount of chemical received, where these are stored and any special safety concerns.
SDS sheets should be linked to each chemical on hand.
CHEMICAL INVENTORY FORMATS: EXAMPLE ZDHC TEMPLATE (1/3)
Depart./ location/ building
Product name Chemical name Chemical supplier CAS Quantity Units SDS on file …….
Dye house 1 Hydrochloric acid (37%)
Hydrochloric acid XYZ Company 7647-01-0 2 Litres YES …….
Dye house 1 Glauber‘s salt Sodium sulphate ABC Cooperation 7757-82-6 1000 Kg YES
……
Chemicals that MUST be included: • Process chemicals, bulk chemicals, machine cleaning chemicals, maintenance
chemicals, chemicals used in boilers, wastewater treatment plants with hazard indication or pictogram on container label.
• All chemical materials used in laboratory, pilot facilities and other locations. • All compressed gases. • Any flammable paints, solvents, glues, fuels and other petroleum product. • Materials that create an explosive or toxic vapour, hazardous to unprotected
personnel during fire emergencies.
Reference: ZDHC Chemical Management Systems Guidance Manual
Draft version, not finalised yet.
Physical hazard (P)
• R phrases R1 - R19
• Hazard statements H200 - H290
Health hazard (H)
• R phrases R20 - R49 and R 60 - R68
• R 60 - R 64 specific for human reproduction
• R 68 and its combinations specific for irreversible processes
• Hazard statements H300 – H373
Environmental Hazard (E)
• R phrases R50 – R59
• Hazard statements H400 – H413
Outdated
CHEMICAL INVENTORY FORMATS: EXAMPLE ZDHC TEMPLATE (2/3)
Product name Chemical name … SDS on file
Hazard class R-phrases/ H-
statements
11 ZDHC Priority
Chemical Class
On factory/
ZDHC MRSL
On brand‘s
RLS
Shelf life ……
Hydrochloric acid (37%)
Hydrochloric acid
… Yes Class 8 H290 H314 H335
N/A No No May.xx
Glauber‘s salt Sodium sulphate
… Yes Non-hazardous
H317 N/A No No Jun.xx
…
CHEMICAL INVENTORY FORMATS: EXAMPLE ZDHC TEMPLATE (3/3)
Product name Chemical name … SDS on file
Hazard class R-phrases/ H-
statements
11 ZDHC Priority
Chemical Class
On factory/
ZDHC MRSL
On brand‘s
RLS
Shelf life ……
Hydrochloric acid (37%)
Hydrochloric acid
… Yes Class 8 H290 H314 H335
N/A No No May.xx
Glauber‘s salt Sodium sulphate
… Yes Non-hazardous
H317 N/A No No Jun.xx
…
Change or add columns depending on
which lists Your Facility is referring to e.g.
REACH Substance of very High Concern or
High Concern, ZDHC MRSL and RSL,
bluesign, Oekotex 100, etc.
Safety Data Sheets
SAFETY DATA SHEETS
A Safety Data Sheet (SDS) must be: • Prepared in the local/ national language.
• Provided for each chemical substance/ mixture.
• Filed at the production site.
• Available in the production for each chemical input to provide information about
safe handling of the chemical input.
• Prepared according to one of the accepted norms by a competent person or a competent service provider, such as: • ANSI Z400.1-2004 - used in USA. • ISO 11014-1 - few countries follow this system. • 1907/2006 EEC (REACH) - most countries are now revising their SDS according to
this system. • 2001/54/EC 2001/58/EEC - used in EU countries from 2001. • GHS (Global Harmonized System) - every country has a specific target date to
implement this system. 26
SDS is intended to SDS is not intended to
Provide guidance for chemical safety management
Give a detailed composition of the product with % levels for each constituent and their CAS numbers
Provide basis of chemical registration and management
Communicate about levels of impurities - unless they are hazardous
Provide technical guide for emergency response
Ensure RSL compliance
Act as an important part of safety education Act as a tool to compare relative properties of products
SAFETY DATA SHEETS
Used by:
• Any employee potentially exposed to workplace chemicals.
• Safety committees.
• Department managers.
• First line supervisors.
• Accident investigation team members.
27
ELEMENTS OF SDS – GHS FORMAT
Section 1: Chemical Product and Company Identification Section 2: Hazard Identification Section 3: Composition, Information or Ingredients Section 4: First Aid Measures Section 5: Fire-Fighting Measures Section 6: Accidental Release Measures Section 7: Handling and Storage Section 8: Exposure Controls and Personal Protection Section 9: Physical and Chemical Properties Section 10: Stability and Reactivity Section 11: Toxicological Information Section 12: Ecological Information Section 13: Disposal Considerations Section 14: Transport Information Section 15: Regulatory Information Section 16: Other Information
GHS LABELS
Source: UNECE
SDS SECTION 1 – HAZARD IDENTIFICATION
Identifies the chemical on the SDS as well as the recommended uses:
• Product identifier used on the label and any other common names or synonyms by which the substance is known.
• Recommended use of the chemical and any restrictions on use, including recommendations given by the supplier.
Provides essential contact information of supplier:
• Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
Resource:
SDS SECTION 1 – EXAMPLE
Emergency numbers
Contact details
Chemical producer
Use of product
Chemical name (commercial or generic)
Resource:
SDS SECTION 2 – HAZARD IDENTIFICATION
Hazards of the chemical and appropriate warning information associated with those hazards:
• Hazard statement(s) – H Phrases - describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
• Precautionary statement(s) – P Phrases - describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling.
For further details: https://www.osha.gov/Publications/OSHA3636.pdf
H Phrases P Phrases
Resource:
SDS SECTION 2 – EXAMPLE
Resource:
SDS SECTION 3 - COMPOSITION, INFORMATION OR INGREDIENTS
Substance:
Chemical identity, common name / synonyms, CAS No. and other unique identifiers and impurities or other additives which are classified and can contribute to classification of substance.
Mixture:
The chemical identity and concentration range of all hazardous ingredients as per the definition of GHS presented above the cut off levels.
Resource:
CAS NUMBERS
CAS number: Unique numerical identifier assigned by Chemical Abstracts Service (CAS).
www.cas.org
Example
Reactive Black 5 dye – CAS 17095-24-8
CAS numbers are formatted as three numbers separated by hyphens [nnnnn-nn-n].
In tables of data they are sometimes listed in square brackets without any other.
Resource:
SDS SECTION 3 - EXAMPLE
Resource:
Tracking chemical use In Your Company
CONCEPT OF CHEMICAL TRACKING
• Understanding process and chemical flows.
• Understand where chemicals and chemical (containing) waste are present and stored within your site.
• Set boundaries regarding external operations that your company can/should/wants to influence, e.g.:
- Procurement of chemicals and products containing chemicals.
- Transport/shipment and delivery of products and chemicals to/from the company.
- Disposal of waste products (air emissions, solid waste, wastewater).
65
PRACTICAL MAPPING TOOL – FLOOR PLAN
• Simple, practical tool for visualisation of chemical location
• Identify storage location and its hazard
• Identify hotspot for improvement
• Auditing and reporting
CHEMICAL TRACKING BY PROCESS FLOW CHART
Input
•Chemical purchased
•Material involve
Process
•The process gone through
•The storage area gone through
Output
•Product
•Non-product (Waste)
CHEMICAL TRACKING BY PROCESS FLOW CHART
• Inputs (raw materials, chemicals, water and energy).
• Product and non-product outputs.
• Sources of non-product outputs.
• Inputs and outputs are quantifiable.
• Costs are assigned to different types of waste. (Advance)
Chemical material flow diagrams should be reviewed annually and updated as needed due to operational changes.
Reference: ZDHC Chemical Management Systems Guidance Manual 68
EXAMPLE: USING YOUR FLOWCHART INFORMATION
Grey Fabric
Dyestuff 30g Auxiliary 30g
Softening agent 10g
Dyeing
Finishing
Dyed Fabric
Chemical in stock: Dyestuff 100g Auxiliary 80g Softening agent 40g
Chemical in stock: Dyestuff 70g Auxiliary 50g Softening agent 30g
GET STARTED
• Use existing ground and floor plans to facilitate identification and visualisation of environmental problems (“critical situations/ hot spots”) within a company.
• Consider using different maps to create a useful multi layer set of graphical information (e.g. for chemicals, water, energy, air, wastes).
• Prepare or verify during an initial company/site walk-through.
• Collect and fill in additional information, using guiding questions and observations on site.
• Decide and agree on your own standard symbols beforehand and use consistently in all maps.
• Indicate gravity of observed “hotspots”:
• Hatched lines: small problem (area to be monitored, problem to be studied).
• Circle: large problem (stop, corrective action).
• The more serious the problem, the thicker or larger the circle or symbol.
Resource:
Risk Assessment
HAZARDS, RISKS, EXPOSURES, EFFECTS
HAZARD
RISK
A hazard is an intrinsic property of a chemical that is independent of usage, exposure or other criteria. Property examples: • Gasoline is flammable. • PCBs are persistent in the environment. • Some uranium isotopes are radioactive.
The risk also considers the exposure potential when using a chemical, the engineering controls in place, PPE, etc.
Thus, in general terms: Risk is a function of:
HAZARD EXPOSURE RISK
Tiger in a cage
Tiger in a city
Reference: ZDHC Chemical Management for the Textile Industry, Module 2
EXAMPLE: WORKER TRANSFERING HOT CHEMICAL
Hazards:
• Irritant to skin and eyes.
• Irritant to lungs.
• Extremely hot
Exposure:
• Eye and skin contact with hot chemical.
• Inhalation of hot air.
Effects:
• Burning of skins and eye.
• Lung function impairment / burning to
lung.
73
EXPOSURE PATHWAYS
Exposure is the process of coming in
contact with a hazard.
EXPOSURE PATHWAYS
Sale and use-phase Consumer and environment exposure (air, water, soil).
Production Factory personnel exposure (manager, supervisor, worker, contractors).
Transportation Interim handling personnel (transporters, customs officials, point of sale staff, etc.).
Post-use Society exposure (neighbourhood, downstream population). Resource:
EFFECTS
Effects, also known as hazard end-points, are the possible result of exposure to the hazard.
EFFECTS Environmental Toxicity Human Toxicity
Examples of hazard end-points:
• Irritation of skin, eyes and respiratory tract. • Narcosis and anesthesia. • Systemic poisoning of liver, kidneys, nervous
system and reproductive system. • Cancer. • Damage to the fetus. • Genetic damage to following generations.
Resource:
INFLUENCING FACTORS
CHEMICAL
HAZARD EXPOSURE EFFECT
Hazard level of substance
Dose / concentration
Duration Probability
severity
Once / several times
Short / long term
Resource:
Risk Assessment Methods
RISK ASSESSMENT OF HAZARDOUS CHEMICALS
When carrying out chemical risk assessment, several questions need to be asked: 1. What potential exposure may occur? • Use chemical inventory, consider all persons who may be affected. • Review PPE in use to make sure it is appropriate. • Review environmental controls to ensure they are adequate. 2. What hazards are indicated for the chemicals? • Information can be found on packaging labels, from SDS, supplier or a
specialist in your factory.
3. What activities can give rise to exposure? • When is it possible for spills or splashes to occur? • Are there steps in a process that increase the potential for exposure?
Can these steps be eliminated or changed? 4. What risks need to be controlled? • The significance may depend on duration and frequency of exposure
as well as the concentration of the substances involved.
Reference: ZDHC Chemical Management for the Textile Industry, Module 2
THE 4-STEP RISK ASSESSMENT PROCESS
Reference: ZDHC Chemical Management for the Textile Industry, Module 2
Hazard Identification What health problems are caused by the pollutant?
Dose-Response Assessment What are the health problems at
different exposures?
Risk Characterisation What is the extra risk of health problems in the
exposed population?
Exposure Assessment How much of the pollutant do people inhale during a specific
time period? How many people are exposed?
RISK ASSESSMENT USING RISK MATRIX (1/2)
Step 1 - Establish Severity:
Assign a ‘severity’ (importance) factor.
Discuss and agree in risk assessment team.
Scale should be adapted to both the country and the local context.
Consider impact on:
• Health of community and workers. • Water resources and quality of air. • Site facilities and transport infrastructure. • Community and social infrastructures. • Company image.
Slight harm Moderate harm Extreme harm
RISK ASSESSMENT USING RISK MATRIX (2/2)
Risk Assessment Severity and Likelihood
Likelihood of Harm
Severity of Harm Slight Harm Moderate Harm Extreme Harm
Very Unlikely Very low risk Very low risk Very low risk
Unlikely Very low risk Medium risk Very high risk
Likely Low risk High risk Very high risk
Very likely
Low risk Very high risk Very high risk
Step 2 - Estimate likelihood of each of the identified hazardous
situations taking place:
Reference: ZDHC Chemical Management Systems Guidance Manual
ZDHC RISK ASSESSMENT TEMPLATE
Reference: ZDHC Chemical Management Systems Guidance Manual
Chemical Storage
MODEL LAYOUT OF A CHEMICAL STORE
GOOD CHEMICAL STORAGE PRACTICES
• Information provided in the SDS.
• SOPs and checklists.
• Ventilation and grounding.
• Separation of incompatible chemicals.
• Handling spillages and leaking containers.
• Provision for a draining system connected to the effluent treatment plant.
• Adequate storage of halogenated solvents.
• Adequate storage of flammable liquids.
• Fire protection measures.
Source: Based on ZDHC Chemical Management System Guidance Manual 85
Resource:
STORE ROOM MANAGEMENT
Ventilation: • Reduction of accumulation of dust or vapours. • Controlled temperature and humidity. • Combination of roof and wall ventilation.
Floors: • Impermeable to liquids. • Made from concrete and sealed with resin. • Resistance against organic solvents. • Smooth surface, but not slippery. • Free from cracks to allow for easy cleaning.
Layout • Plan storage layout. • Assign areas for storage and movement. • Use colour markings. • Allow for storage on pallets for easier
rearrangement . • Use secondary container.
Consult the SDS or chemical suppliers for recommended storage conditions.
86
STORE ROOM MANAGEMENT
Regular clean-out:
• Dispose of expired chemicals in timely manner.
• Remove spills immediately.
Separate incompatible chemicals:
• Materials should always be segregated and stored according to their chemical family or hazard classification.
87
EXAMPLES OF GOOD PRACTICES
88
Resource:
PERSONAL PROTECTION EQUIPMENT
Provision and use of personal protection equipment by all staff as per safety instructions and specific for each chemical substance:
• Chemical resistant overalls.
• Eye protection (safety goggles).
• Dust or fume masks.
• Chemical resistant rubber or plastic gloves according to each chemical.
• Rubber or plastic apron.
• Safety or work boots with protective caps.
Resource:
OUTDOOR STORAGE
• Products stored outdoors must be protected from sun and rain.
• Store upright on palettes.
• Outdoor storage, especially in tropical areas, exposes product to high temperatures, therefore fast degradation, shorter shelf life.
• Avoid contamination of soil and water:
• Heat and water resistant material.
• Equipped with controlled drain system.
• Storage area clearly marked and secured/fenced to prevent unauthorised access.
• Flammable liquids and solvents shouldn’t be stored outdoors.
90
Resource:
PREVENTION OF SPILLAGES AND LEAKING CONTAINERS
• Check containers on delivery.
• Use good quality containers.
• Ensure good and careful handling practices.
• Bad handling and long storage under bad conditions might result in risk of spills and leaks.
• Inform yourself in advance on measures and provisions in case of spillages or leakages: Material Safety Data Sheet and Manufacturer’s instructions for corrective action.
91
Resource:
Emergency Management
DEALING WITH CHEMICAL EMERGENCIES
Prevention is always better than cure!
1. Prevention
2. Preparation
3. Response
4. Recovery
Resource:
EMERGENCY RESPONSE PLAN
Reference: ZDHC Chemical Management Guidance System Manual
Procurement practice
GOOD CHEMICAL PROCUREMENT PRACTICES
• All chemicals adhere to regulatory requirements.
• Chemical is on the facility system’s list of approved chemicals and checked against any MRSL/RSL in effect in Your Facility.
• Personnel is trained to assess chemical hazards.
• Chemical supplier and personnel who receive chemical ensure correct labelling as per GHS for chemical containers.
• Chemical supplier is knowledgeable of hazardous chemicals and can be consulted.
Resource:
MEET ALL REGULATORY AND BRANDS‘ REQUIREMENTS
Some important regulations in your territory might include:
• The amount of chemicals that can be stored at the facility.
• Worker safety protocols and engineering controls.
• Storage requirements.
• Effluent, sludge, or hazardous waste storage and disposal rules. Brands’ requirement may involve MRSL/RSL:
• Verify the compliance of chemical use. • Communicate these requirements with chemical supplier. • Require chemical supplier to provide Letter of compliance if
needed. • Chemical inventory and SDS is a useful tool.
Regulatory inventory
Check your regulatory requirements inventory and ensure you adhere to all aspects when procuring chemicals.
KNOW YOUR CHEMICAL SUPPLIERS AND ESTABLISH AN APPROVAL / REMOVAL PROCESS
• Identify and document suppliers for each of the chemicals listed in the chemical inventory.
• For urgent technical support or other emergencies, document their relevant contact information such as point-of-contact name, phone number and address.
• Establish, document and implement a process for using preferred suppliers and also for removing them.
• Minimum Requirements on suppliers: Provide SDS in local language in line with GHS Labelling standard in order to adhere to relevant regulations and brands requirements.
Reference: ZDHC Chemical Management System Guidance Manual 99
Please ensure the competence of responsible person who handle
regulatory and MRSL/RSL requirements.
Performance Management
EFFECTIVE IMPLEMENTATION OF MANAGEMENT ACTION PLAN
Steps for the effective implementation of a Management Action Plan:
Monitor and review MAP ___________ Systematically monitor the progress on implementing the MAs, monitor effectiveness of implemented actions and review the MAP in case any modification is required.
Document the improvement area ___________ Identification of improvement areas for your facility at the point of assessment in order to control input of chemicals and substitute hazardous chemicals in production processes.
Analyse the improvement area ___________ Analyse the root cause of an improvement area to develop the most appropriate MA.
Define the MA ___________ Formulate the most appropriate MA to an improvement area.
Create ownership to MA ___________ Assign the responsible persons and deadlines to each MA.
Implement the MAP ___________ Implement the MAP with the help of your Chemical Management System Team.
1. 2. 3. 4. 5. 6.
Resource:
ACCURATE INDICATORS
• Assessable or measurable.
• Controllable - able to be changed by
what you do in chemical
management.
• Central and relevant to what you are
trying to achieve.
• Understandable and clear.
• Reliable - providing the same
measures when assessed by
different people.
• Acceptable to the users as true
indicators of performance.
• Timely and
• Efficient to monitor.
Resource:
PERFORMANCE INDICATORS AND MANAGEMENT ACTION PLAN
Improvement Area Target Objective of proposed measure
Management Actions
Person Responsible
Deadline KPIs to be monitored
Several chemicals cannot be clearly identified due to missing labels
Reduce the number of unlabelled containers to 0%
To improve the company internal hazard communication on chemicals used
Follow procurement policy and store check points to ensure all chemicals to be allowed only if they have proper labels and ensure to protect original label or replace label before it gets deteriorated
% of unlabelled containers
The measurable
result of the
interventions
The larger context
or purpose of the
interventions
The selected
performance
indicator
Issues to be
addressed ref.
Eco-map
Risk assessment
Checklist results
Audit reports
…. Resource:
TYPES OF PERFORMANCE INDICTATORS
• Operational performance indicators (OPI)
• 2.1 – 2.23, 3.1
• Environmental condition indicators (ECI)
• 3.2 – 3.18
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
OPERATIONAL PERFORMANCE INDICATORS (OPIs)
Chemical Management
Number KPI Unit Tracking process (Source) Calculation
2.1 Quantity of chemicals used in year
Tons Total chemicals purchased – total current stock in tons.
2.8 Quantity of hazardous chemicals stored
Kgs Chemical inventory. Total quantity of hazardous chemicals in stock
2.9 No. of unlabelled or label deteriorated due to operation of chemicals
No.
Internal audits or hot spots identified. Record of the log of hot spots and reviews
2.10 No. of ecotoxic chemicals stored in year
No. Chemical inventory. No. of chemicals stored in store having label of ecotoxic
2.11 No. of ecotoxic chemicals stored without proper secondary containment
No. Hot spots identification visits and internal or external audits
2.12 No. of injuries reported due to chemicals
No. Accidents or incidents log book
2.13 No. of relevant staff trained on risk assessment
No. HR training data
2.14 No. of staff trained for emergency response
No. HR training data
Resource:
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
OPERATIONAL PERFORMANCE INDICATORS (OPIs)
Chemical Management
Number KPI Unit Tracking process (Source) Calculation
2.18 Ratio of chemicals used vs hazardous chemicals stored or used in year
% Hazardous chemicals identified from inventory, Chemicals from inventory.
Hazardous chemicals/Total chemicals
2.19 Quantity of chemicals which were expired or disposed off
Tons Chemicals quantity disposed due to expiry from gate pass, invoices etc.
2.20 Quantity of non-product outputs (NPO) generated against annual production
Tons Quantity of NPO recorded from all activities.
2.21 Cost of wastewater treatment per year
€ Cost of waste water treatment per year from accounts information. Invoices and costs on WWT.
2.22 Cost of m3 waste water treatment per ton of production
€ Wastewater treatment cost from invoices
Wastewater treatment cost/total production [ton]
2.23 Cost of NPO per ton of production
€ Cost of non-product output against the ton of production
Cost of non-product output/ total production [ton]
3.1 No. of incidents of RSL per year
No. Register all complaints or test reports failed for RSL
Resource:
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
OPERATIONAL PERFORMANCE INDICATORS (OPIs)
Wastewater and Solid Waste
Number KPI Unit Tracking process (Source) Calculation
2.4 Quantity of waste water
generated in year M3
Flow meters or estimates or invoices.
Quantity entering Equalization tank.
2.5 Quantity of waste generated
in year
Ton
s
WWTP records or the waste disposed
from contractor invoices
2.6 Quantity of hazardous waste
generated in year kgs Hazardous waste inventory
2.7 Quantity of solid sludge
generated in year tons
WWTP records. Total solid sludge (with
or without moisture) recorded
Resource:
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
ENVIRONMENTAL CONDITION INDICATORS (ECI)
Number KPI Unit Tracking process (Source) Calculation
3.2
% reduction of incidents of
non-compliance to RSL and
ZDHC MRSL
% Incidents of RSL and MRSL
from the production record
(No. of past incidents – no. of current incidents)/ no. of past incidentsX100
3.3
% reduction of WWTP
ZDHC parameters non-
conformance
% Test results and their data
of WWTP
(No. of past incidents – no. of current incidents)/ no. of past incidents X100
3.4 % reduction of hazardous
waste % WWTP waste inventory
(Qty haz. waste past – current qty) / past qty X100
3.5 % solid waste reduction % Waste inventory
(Qty of solid waste – current qty) / past qty X100
3.6 % reduction of hazardous
chemicals use %
Chemical inventory and
stock data
(Qty haz. chemicals past- current qty) /
past qty X100
3.7
% reduction of incidents of
priority chemicals detections
in waste water reports
% Test results of waste water (No. of detections of priority chemicals in
past – current no.)/ past No. X100
3.8 % reduction of gaps in
information of SDS %
SDS and record during
assessments
(No. gaps past – gaps current) / past gaps X100
3.9 % reduction in engineering
control related issues %
Evaluation during the
assessments
(No. of past issues of engineering controls – current issues) /past no.X100
3.10 % reduction of hazardous
substances handling time %
Hot spot walk through and
also from assessment visits
(Time spent on handling of haz. substance past – current time)/ past time X100
Resource:
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
ENVIRONMENTAL CONDITION INDICATORS (ECI)
Number KPI Unit Tracking process (Source) Calculation
3.11 % reduction in accidents % measure from accident logs (No. Past accidents – current record)/previous no. X100
3.12 % reduction of spill
containment %
measure from the record of accidents
from HR
(Qty. lost due to spill past – current qty) / past qty X100
3.13 % Productivity increase % measure from the production data
and MRM minutes
(Current production qty – past production qty) / current production X 100
3.14 % reduction of normalised
energy use %
measure from energy bills and
invoices and production data
(Past KWh consumed for Kg of production – Current KWh)/ previous KWh X100
3.15 % hazardous chemicals
replaced or substituted % measure from the chemical inventory
(No. of hazardous chemicals past – current number) / past no. X100
3.16 % reduction of solid waste % measure from the solid waste
inventory
(Qty of solid waste past – current qty)/ past qty X100
3.17 % reduction of hazardous
waste % measure from waste inventory
(Qty of hazardous waste past - current qty)/past qty X100
3.18
% reduction in incidents of
waste water discharge
parameters
% measure from the test reports of
waste water
(No. of parameters exceeding limits of WWTP past – current no.) / past no. X100
Resource:
Source: ISO 14031: Guidelines for Environmental Performance Evaluation
Conclusion
What you need to do…
1. Establish an chemical inventory
2. Trace where you used chemicals
• Floor plan
• Flow chart
3. Risk assessment
4. Safety programme
5. Emergency response plan
6. Good procurement practice
7. Performance evaluation
Sustainable Apparel Coalition
Next step A chemical management system with sufficient procedures and records can be very helpful in responding Higg FEM 3.0 questions.
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I have limited knowledge on
setting up system. How do I
getting start?
Our CMS e-
platform can
help.
CMS E-Platform
CMS E-platform
Sustainable Apparel Coalition
CMS E-Platform
E-learning platform for clothing & textile industry
Assist to develop your own Chemical Management System
Learn more:
National regulations on hazardous chemicals
Restricted Substance List (RSL) from fashion brands
Manufacturing Restricted Substance List (MRSL) from ZDHC
Material Safety Data Sheet (MSDS) from chemicals manufacturers / importers
Self-assessment on chemical management performance
Action plan report with recommendations for improvement
Step-by-step implementation manual
What is CMS E-platform?
The Federation of Hong Kong
Garment Manufacturers
Objectives:
To promote and protect the interests of Hong Kong garment manufacturers and merchants;
To research into all matters affecting the interests of the trade;
To promote unity and friendship among garment manufacturers and merchants and to protect the reputation of the trade;
To make representations to governments and authorities on matters affecting our members.
Organizer
Established in the early
1950s
Incorporated in
1964
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Sustainable Apparel Coalition
Implementation Agent
Roles
Trainer
Promoter
Assistant
E-platform Developer
116
CMS E-Platform
CMS Assessment
CMS Video
Events
Resources
E-Platform features
CMS E-Platform
Self-assessment
Action Plan Report
Tailor-made
Implementation
Manual
CMS assessment
CMS E-Platform
10 Animations
Basic Concepts
Technical Terms
Chemical Management System
CMS Video
Sustainable Apparel Coalition
CMS E-Platform
Seminar
Workshop
Photo Gallery
Update Schedule
Seat Reservation
Online (CMS Registered Users ONLY)
Paper Enrolment Form
Presentation / Training Materials
Events
Sustainable Apparel Coalition
CMS E-Platform
Implementation Manual
Fashion Brands Requirements
Other Useful Resources
Useful Websites
Government Regulations
Case Studies
Resources
Sustainable Apparel Coalition
CMS step by step assessment
122
Start using the
E-platform and
experience
how it help
factory to find
out solution.
Sustainable Apparel Coalition
Assessment Procedures
3. CMS Performance Score
4. Tailor-made Action Report & CMS Implementation
Manual
5. Improvement in CMS
1. Register Site/Company
Name
2. Assessment
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Sustainable Apparel Coalition
Content Implementation Manual
124
Commitments
to CMS
Regulation
Compliance
Risk
Assessment
Chemical
Inventory
Chemical
Storage and
Handling
Chemical
Contingency
Planning
Brand
Requirements
Compliance
(Advanced
Level)
Supplier and
Sub-contractor
Management
(Advanced
Level)
Sustainable Apparel Coalition
Exercise
• Register your own account on the E-platform.
• For manufacturer, use the self-assessment to evaluate your existing performance.
• For others participates, check out the self-assessment questions and manual to understand what should be include in the system.
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CMS E-Platform
CMS assessment demonstration
CMS E-Platform
CMS assessment demonstration
CMS E-Platform
CMS assessment demonstration
CMS E-Platform
CMS assessment demonstration
Sustainable Apparel Coalition
Contact Us
The Federation of Hong Kong Garment Manufacturers
Mr. Michael Leung Tel: (852) 2721 1383 Fax: (852) 2311 1062
Email: [email protected]
Website: www.garment.org.hk
Address:
Room 401-3, 4/F, Cheung Lee Commercial Building
25 Kimberley Road
Tsim Sha Tsui, Kowloon
Clothing Industry Training Authority Ms. Kit Li
Tel: (852) 2263 6342 Fax: (852) 2795 0452
CMS email: [email protected]
Website: www.cita.org.hk
Address: 63 Tai Yip Street, Kowloon Bay, Kowloon
131
Sustainable Apparel Coalition
Q & A SESSION
132