Plan and allocate resources to implement the chemical management strategy
In order to successfully implement the chemical management strategy It is important a supplier ensures they have the correct resources available.
Chemical responsible person or team
A supplier should appoint a person or team with relevant experience and training in chemical management to oversee the implementation and monitoring of the chemical management strategy.
This person or team should be directly supervised by the top management of the facility in order to expedite decisions on implementing the strategy.
Their skill set should include, but not limited to:
- Knowledge in:
- Chemistry and textile/leather processes and applications.
- Globally Harmonised System (GHS) of classification/labelling (or equivalent).
- Local and global regulations on chemical restrictions.
- The ability to:
- Read and interpret Safety Data Sheets (SDS).
- Use online tools such as the ZDHC Gateway.
- Communicate effectively.
- Track and analyse data.
- An understanding of:
- Brands’ Restricted Substances Lists (RSL) and ZDHC MRSL.
Roles and responsibilities
The chemical responsible person or team responsibilities are:
- To manage and implement the chemical management actions required for environmental and chemical compliance and the ZDHC Roadmap to Zero Programme.
- To Maintain access to and using ZDHC platforms.
- To Document and understand all chemical conformance requirements such as, but not limited to:
- Brand RSLs
- ZDHC MRSL ZDHC
- ZDHC Wastewater requirements
- Safety Data Sheets (SDS)
- Technical Data Sheets
- Global and local legislation
- ZDHC InCheck/ChemCheck Reports
- Eco-labels/certifications
4. Conducting risk assessment of chemical inventory and planning precautionary actions for storage, handling and disposal for hazardous chemicals.
5. Developing and maintaining the chemical management strategy document.
6. Assessing new chemical product purchases for ZDHC MRSL conformance and other regulatory chemical restriction risks. Authorising their purchase prior to procurement and usage in bulk production.
7. Maintaining the Chemical Inventory List (CIL) and ensuring all data is up-to-date and complete.
8. Tracking global chemical regulations on restrictions relating to chemicals, end-products and ZDHC guidelines updates.
9. Conducting internal audits and facilitating external audits (wherever required) for review and continuous improvement of the chemical management strategy
10. Performing Root Cause Analysis (RCA) and preparing Corrective Action Plan (CAP) for non-conformities such as, but not limited to:
- RSL failures
- Non-conformity in the ZDHC ClearStream Report
- Chemical-related accidents
11. Conducting a waste audit and plan actions to reduce chemical-related waste at source.
12. Maintaining all required licence copies of third-party authorised waste contractors and a logbook on all chemical-related waste.
Support by department
The chemical responsible person or team should be supported by other staff or departments by assigning specific responsibilities to them for chemical management.
Responsibilities that can be assigned:
- Ensuring proper storage, internal transportation and handling of chemical products at sub-stores and workplace (such as weighing and auto-dosing) in the production department.
- Ensuring that input chemical products are applied as per specifications and limitations given in Technical Data Sheets (TDS) and supplier declarations.
- Ensuring that functional first-aid boxes and eye/body showers are installed at risk areas in the production area for emergency response to chemical accidents.
- Monitoring that workers are provided with and wear appropriate PPE during the handling of chemicals on the shop floor, as per labelling guidelines.
- Maintaining data of chemical products in recipe/process sheets such as chemical name and lot numbers to ensure traceability.
- Using the ZDHC Gateway to check ZDHC MRSL conformance when purchasing chemicals.
- Providing information on the chemical inventory to the Chemical Responsible Person/Team, including new chemical purchases.
- Generating the Performance InCheck Report and plan follow-up actions jointly with Chemical Responsible Person/Team to improve ZDHC MRSL conformance for the input chemical inventory in line with the strategy goals.
- Requesting ChemCheck Reports from formulators, when required and maintaining a record of these.
- Communicating ZDHC MRSL conformance requirements via the Purchase Order issued to formulators.
- Requesting authorisation from the Chemical Responsible Person/Team before procurement when purchasing a new chemical product.
- Testing purchased chemical products against quality specifications as per the purchasing policy.
- Ensuring that test reports for finished articles (for RSLs) and chemicals (for ZDHC MRSL) are properly recorded, in case internal or external testing is completed.
- Communicating any ZDHC MRSL and Brand RSL non-conformance to the Chemical Responsible Person/Team for them to do an RCA/CAP.
- Arranging training on chemical management topics and safe chemical handling for staff, supervisors and workers at all levels.
- Organising training and mock-drills on emergency procedures, fire safety and first aid measures as well as maintaining proper records.
- Displaying names, photos and emergency contact numbers of employees trained in fire safety and first aid at key locations of the plant.
- Ensuing that First-In-First Out (FIFO) method is implemented and monitored.
- Planning safe stacking of chemical containers (for ease of access) and ensuring their storage at the designated place.
- Maintaining a spill kit at the stores. Ensuring that labels on all chemical containers are clearly displayed.
- Checking that internal transportation of chemical containers is done in an efficient way to minimise risk of accident.
- Ensuring that hazard communication and safety signage is displayed at all storage locations and workers understand the signs.
- Ensuring that workers in the stores are supplied with and use the correct personal protective equipment (PPE) when handling chemicals, in accordance with hazard signage and the labels on drums, and appropriate to the task being performed.
- Disposing of used chemical containers and other chemical-related waste as per local legal requirements or best practices.
- Maintaining a file of Safety Data Sheets (SDS) of the chemicals stored and updating when storing new chemicals, ensuring it accessible. Ensuring that non-compatible chemicals are not stored together or close, as per compatibility chart.
- Maintaining appropriate and adequate secondary containment for liquid chemical containers.
- Planning proper segregation, storage, handling and transportation for all hazardous and non- hazardous waste.
- Ensuring cleanliness and good housekeeping at all areas of the main and sub-store.
- Monitoring daily effluent for regulatory compliance as per local permits and laws and conduct RCA for non-conformities.
- Ensuring proper storage and disposal of sludge as per local laws or best practice not conflicting with local laws.
- Ensuring sampling and testing of wastewater and sludge for the ZDHC wastewater requirements and support the Chemical Responsible Person/Team in Root Cause Analysis (RCA) and preparing Corrective Action Plan (CAP) for discrepancies found in the ClearStream Report.
- Maintain proper storage & handling of chemical products used in ETP operation.