conformity in fem 3.0: chemical management...

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


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


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


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”.


Level 1 Question Question Uses chemicals in

production

Uses chemicals in


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


Level 1 Question Question Uses chemicals

in production

Uses chemicals in


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



production

Uses chemicals in


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



production

Uses chemicals in


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



production

Uses chemicals in


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


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

…


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:

http://www.cas.org/

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.


THE 4-STEP RISK ASSESSMENT PROCESS


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:


ZDHC RISK ASSESSMENT TEMPLATE


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:



Chemical Management


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:



Wastewater and Solid Waste


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:


ENVIRONMENTAL CONDITION INDICATORS (ECI)


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


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


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:


ENVIRONMENTAL CONDITION INDICATORS (ECI)


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


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:


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


Next step A chemical management system with sufficient procedures and records can be very helpful in responding Higg FEM 3.0 questions.

112

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


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

115


Implementation Agent

Roles

Trainer

Promoter

Assistant

E-platform Developer

116

CMS E-Platform

CMS Assessment

CMS Video

Events

Resources

E-Platform features

http://chemicals.cita.org.hk/?lang=zh_tw

CMS E-Platform

Self-assessment

Action Plan Report

Tailor-made

Implementation

Manual

CMS assessment

http://chemicals.cita.org.hk/login/index.php?anchor=1

CMS E-Platform

10 Animations

Basic Concepts

Technical Terms

Chemical Management System

CMS Video

http://chemicals.cita.org.hk/mod/mediagallery/cita_video_view.php?g=10006&page=0&lang=en


CMS E-Platform

Seminar

Workshop

Photo Gallery

Update Schedule

Seat Reservation

Online (CMS Registered Users ONLY)

Paper Enrolment Form

Presentation / Training Materials

Events

http://chemicals.cita.org.hk/calendar/view.php?course=2


CMS E-Platform

Implementation Manual

Fashion Brands Requirements

Other Useful Resources

Useful Websites

Government Regulations

Case Studies

Resources

http://chemicals.cita.org.hk/mod/page/view.php?p=6


CMS step by step assessment

122

Start using the

E-platform and

experience

how it help

factory to find

out solution.


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

123


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)


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.

125

CMS E-Platform

CMS assessment demonstration


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

mailto:[email protected]





http://www.garment.org.hk/












http://www.cita.org.hk/








Q & A SESSION

132

conformity in fem 3.0: chemical management...

Documents