Chemical Management System Manual 2015

CHEMICAL
2015 MANAGEMENT
SYSTEM GUIDANCE
MANUAL JOINT ROADMAP
DELIVERABLE
ZERO DISCHARGE
OF HAZARDOUS
CHEMICALS PROGRAMME
I N A S S O C I AT I O N W I T H
ES121114083500GNV
Contents
Section Page
Acronyms and Abbreviations........................................................................................................ v
Introduction ..................................................................................................................... INTRO-1
Overview......................................................................................................................... INTRO-1
ZDHC Goal....................................................................................................................... INTRO-1
Objective ........................................................................................................................ INTRO-1
ZDHC CMS Goals ............................................................................................................. INTRO-2
Engagement with ZDHC Stakeholders ............................................................................ INTRO-2
Structure of the CMS Manual ......................................................................................... INTRO-3
1 Commitments to CMS ................................................................................................... 1-1
1.1 Management Statement ........................................................................................... 1-1
1.1.1 Requirements ............................................................................................... 1-1
1.2 Scope of CMS............................................................................................................. 1-1
1.2.1 Requirements ............................................................................................... 1-1
2 Assessment, Planning and Prioritisation ........................................................................ 2-1
2.1 Systematically Identify and Document Chemicals Used and Stored in Your
Organisation .............................................................................................................. 2-1
2.1.1 Purpose......................................................................................................... 2-1
2.1.2 Facility Plan and Walk Through .................................................................... 2-1
2.1.3 Chemical Material Flow Diagrams (Element 2.1.2) ...................................... 2-2
2.1.4 Creating a Comprehensive Chemical List ..................................................... 2-2
2.2 Regulatory Assessment ............................................................................................. 2-5
2.2.1 Monitoring Regulations and Permits ........................................................... 2-5
2.2.2 Verification of Compliance ........................................................................... 2-6
2.3 Procurement/Supplier Practices ............................................................................... 2-6
2.3.1 Chemical Purchasing Policy Considerations ................................................. 2-7
2.3.2 Identify Chemical suppliers .......................................................................... 2-8
2.3.3 Supplier Approval/Removal Process ............................................................ 2-9
2.4 Chemical Risk Assessment......................................................................................... 2-9
2.4.1 Hazard and Risk Assessment ........................................................................ 2-9
2.4.2 Environmental ............................................................................................ 2-10
2.4.3 Health and Safety ....................................................................................... 2-11
2.5 Chemicals and Processes of Concern ...................................................................... 2-12
2.5.1 Identify Gaps and Losses in Current Processes .......................................... 2-12
2.5.2 RSL and MRSL Process ................................................................................ 2-13
2.6 Performance Goals and Action Plans ...................................................................... 2-14
2.6.1 MRSL Compliant Formulations ................................................................... 2-14
2.6.2 Alternatives Assessment ............................................................................ 2-14
3 Chemicals Management ................................................................................................ 3-1
3.1 Organisational Structure ........................................................................................... 3-1
3.1.1 Roles and Responsibilities ............................................................................ 3-1
3.1.2 Communication ............................................................................................ 3-2
3.2 Training ...................................................................................................................... 3-2
3.2.1 Management ................................................................................................ 3-2
3.2.2 Regulatory .................................................................................................... 3-2
3.2.3 Work Practices.............................................................................................. 3-2
3.2.4 ZDHC Training ............................................................................................... 3-3
3.3 Document Development ........................................................................................... 3-3
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY III

CONTENTS, CONTINUED
Section Page
3.4 Document and Record Control.................................................................................. 3-3
3.5 Chemical Management Work Practices .................................................................... 3-4
3.5.1 Exposure Control Measures ......................................................................... 3-4
3.5.2 Safety Data Sheet Management .................................................................. 3-5
3.5.3 Chemical Handling ........................................................................................ 3-6
3.5.4 Chemical Storage.......................................................................................... 3-6
3.5.5 Chemical Transportation .............................................................................. 3-6
3.5.6 Chemical Labelling ........................................................................................ 3-7
3.5.7 Chemical Use – Regular and Optimisation ................................................... 3-7
3.5.8 Personal Protective Equipment.................................................................... 3-7
3.5.9 Laboratory Practices..................................................................................... 3-8
3.5.10 Maintenance and Housekeeping ................................................................. 3-8
3.5.11 Waste and Disposal ...................................................................................... 3-9
3.6 Emergency Procedures.............................................................................................. 3-9
4 Monitor ........................................................................................................................ 4-1
4.1 Monitor and Measurement (Continuous Improvement) .......................................... 4-1
4.1.1 Goal Progress................................................................................................ 4-1
4.1.2 Regulatory Compliance ................................................................................ 4-1
4.1.3 Work Practice and Customer Requirements Implementation..................... 4-1
4.2 Internal Audit ............................................................................................................ 4-2
4.3 External Audit ............................................................................................................ 4-2
4.4 Change Management and Corrective Action ............................................................ 4-2
4.4.1 Change Management ................................................................................... 4-2
4.4.2 Corrective Action .......................................................................................... 4-3
5 Management Review .................................................................................................... 5-1
5.1 Disclosure of Substance in Use.................................................................................. 5-1
5.2 Stakeholder Review ................................................................................................... 5-1
5.3 Management Review ................................................................................................ 5-2
6 CMS Resources ............................................................................................................. 6-1
7 Glossary........................................................................................................................ 7-1
Appendixes
A Assessing Status
B Tables
C Chemical Inventory
D Risk Assessment Template Example
E AAFA Environmental standards
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY IV

Acronyms and Abbreviations
AAFA American Apparel and Footwear Association
AHA activity hazard analysis
AST aboveground storage tank
CFC chlorofluorocarbon
CMO chemical management officer
CMR carcinogenic, mutagenic or toxic for reproduction
CMS chemical management system
CMWG Chemicals Management Working Group
CO carbon monoxide
CoA certificate of analysis
CPSIA Consumer Product Safety Improvement Act
DTSC Department of Toxic Substances Control (California)
ED endocrine disruptor
GHG greenhouse gas
GHS Globally Harmonized System of Classification and Labelling of Chemicals
GIZ Gesellschaft für Internationale Zusammenarbeit
GPSD General Product Safety Directive
HAP hazardous air pollutants
HVAC heating, ventilating and air conditioning
JHA job hazard analysis
JSA job safety analysis
KPI key performance indicator
LEV local exhaust ventilation
MRSL manufacturing restricted substances list
NIOSH National Institute for Occupational Safety and Health
NOx nitrogen oxides
NRDC Natural Resources Defense Council
O&M operations and maintenance
OIA Outdoor Industry Association
OSHA Occupational Safety and Health Administration
PBT persistent, bioaccumulative and toxic
PM particulate matter
REACH Registration, Evaluation, Authorization and Restriction of Chemicals
RSL restricted substances list
SAC Sustainable Apparel Coalition
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY V

ACRONYMS AND ABBREVIATIONS
SDS safety data sheet(s)

SO2 sulfur dioxide
SVHC REACH substances of very high concern
THA task hazard analysis
US EPA United States Environmental Protection Agency
UST underground storage tank
VOC volatile organic chemical(s)
ZDHC zero discharge of hazardous chemicals
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY VI

Chemical Management System
Guidance Manual
Zero Discharge of Hazardous Chemicals Group
Introduction
Overview
This Chemical Management System (CMS) Guidance Manual focuses on the approach, structure and
documentation needed to create and support a Zero Discharge of Hazardous Chemicals (ZDHC)
Programme CMS. Information provided in this manual should be easily internalised by retailers,
brands and their supply chain partners while accommodating the complexities of the ZDHC roadmap
work and the textile supply chain chemistry applications. This framework will build on ISO
management standards and other applicable frameworks, such as the Deutsche Gesellschaft für
Internationale Zusammenarbeit (GIZ) Practical Chemical Management Toolkit and the Outdoor
Industry Association (OIA) Chemicals Management Working Group (CMWG) Framework. A sound
chemical management system is paramount to worker safety and will reduce environmental impacts
on the community and the broader environment. A CMS is therefore one of the cornerstones for
ensuring continuous improvement towards our 2020 goal of zero discharge of hazardous chemicals
throughout the life cycle of our products.
A CMS provides the ZDHC Group, its suppliers and other stakeholders a well‐defined structure to
move toward zero discharge. A management system is a framework that allows inclusion of all
projects introduced in the Joint Roadmap, Version 2.
Specifically, the ZDHC Group affirms that:
• A CMS is an effective framework for improving overall environmental and chemical performance
while achieving the goal of zero discharge.
• A management approach allows continuous chemical management improvement and
minimisation of environmental impact.
• A management approach can provide the structure for current roadmap projects.
• A management approach allows an entry point for different actors in the supply chain, including
the chemical industry, brands, Tier 1 and 2 suppliers and other stakeholders who wish to
contribute to the success of the ZDHC Group’s commitment.
The CMS Guidance Manual is intended to be a living document that will be periodically updated. This
first version of this manual focuses mainly on foundational matter. Later versions will include more
detailed content on progressive and aspirational matters.
ZDHC Goal
The ZDHC Group’s goal is to achieve zero discharge of hazardous chemicals across supply chains and
product life cycles in the production of apparel, footwear and accessory goods by 2020. The group
has developed tools like the Manufacturing Restricted Substances List (MRSL) and chemical guidance
sheets to improve chemical management and to assist facilities in achieving or maintaining
compliance with retailer, brand and government regulations. These tools fit within the CMS
framework in this guidance manual.
Objective
The ZDHC CMS objective is to develop a management framework that assists brands, retailers, Tier 1
and 2 suppliers and chemical suppliers in understanding their roles, by developing clear guidelines
that allow all committed supply chain stakeholders to participate and take responsibility for their part
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-1

INTRODUCTION
of the value chain. This level of alignment and harmonisation will be key to delivering on the ZDHC
vision, mission and 2020 goal. Documentation in this manual includes outcomes of the ZDHC Group’s
work activities and thereby creates a comprehensive, yet pragmatic management system.
By developing a CMS structure for the apparel and footwear supply chain that includes all our existing
and future work activities, we provide the ZDHC programme with a sound structure that is
recognised, understood and easy to communicate to the textile industry.
ZDHC CMS Goals

The adoption of a CMS should be a strategic decision of an organisation. Design and implementation
of an organisation's CMS is influenced by its:
1. Organisational environment, changes in that environment and risks associated with that
environment
2. Varying needs
3. Specific objectives
4. Products provided
5. Processes employed
6. Size and organisational structure
The CMS requirements specified in this manual are complementary to product requirements and can
be used by internal and external parties to assess an organisation's ability to meet customer,
statutory and regulatory chemical and product requirements.
The ZDHC Group’s commitment for a CMS is:
• Adoption of the overall management framework by ZDHC members and stakeholders that serves
as a structure for delivering environmental improvements and systematic change in the supply
chain
• Alignment and coupling of the overall management framework and the ZDHC Audit Protocol(s) in
an effective manner
• Use of the framework as a holding structure for the ZDHC Group collaboration for the benefit of
ZDHC members and their stakeholders
• Alignment of the tools and processes with industry and organisation stakeholders such as the
Sustainable Apparel Coalition (SAC), OIA, Global Social Compliance Program and OEKO-TEX®
• Perception of the framework as an effective mechanism for driving change and delivering
improvements by the supply chain partners in all tiers, but especially for Tiers 2 and 3 suppliers
Engagement with ZDHC Stakeholders

As stated in the ZDHC CMS goals, the creation of a CMS is intended to be applicable for brands,
retailers, Tier 1, 2, and 3 suppliers and chemical suppliers. The ZDHC Group goals cannot be
effectively accomplished without the support of a variety of stakeholders throughout the life cycle of
apparel and footwear products.

INTRODUCTION
Structure of the CMS Manual

The CMS Manual is structured in five sections that follow the Plan-Do-Check-Act framework used in
all management systems:
1. Commitment to CMS (Plan Phase)
2. Assessment, Planning and Prioritisation (Plan Phase)
3. Chemicals Management (Do Phase)
4. Monitoring (Check Phase)
5. Management Review (Act Phase)
Each phase consists of a number of elements designed as a stepwise framework that an organisation
can follow to create a systematic and thorough process for managing hazardous chemicals. The
ultimate goal for a CMS is to create an organisation that is committed to the safe, sustainable and
environmentally-responsible management of chemicals and chemical discharge.
The framework presented here is not intended to be prescriptive – it was designed to create
minimum requirements with flexibility in the implementation details. Throughout, the framework is
marked with symbols indicating the suggested attainment of organisational skills. If you are uncertain
about how to categorise your facility please consult the checklists in Appendix A. These checklists
reflect the efforts of CMWG to harmonise the collective knowledge of key stakeholders and brands
around chemical management.
Organisational skill symbols used in this manual:

Symbol Organisational Skill Skill Definition
Foundational Foundational (beginning) chemical management
Progressive (started but with room to grow) chemical

Progressive
management
Aspirational Aspirational (advanced) chemical management

SECTION 1
Commitments to CMS
The first step in implementing any chemical management system is for an organisation to clearly and
publicly commit to the system. Such commitments clearly indicate an organisation’s overarching
strategy and intentions.
1.1 Management Statement

1.1.1 Requirements
Expected CMS Deliverable: Management Policy Statement
Management statements are written endorsements from
senior leadership that clearly communicate goals and ZDHC Audit Question
aspirations regarding chemical management. The goal of Is there a policy for monitoring and
management statements is to clearly communicate those controlling banned and restricted
organisational goals to internal and external stakeholders. substances that is applied to all
Organisations adopting CMS should draft a management chemicals used at the facility?
(CRS 1.1.1)
statement that:
1. Includes a goal of zero discharge of hazardous chemicals throughout a product’s life cycle
2. Is documented, implemented and maintained
3. Is communicated widely inside and outside the organisation
4. Endorses sustainable chemistry practices
5. Includes a commitment to comply with requirements ZDHC Audit Question
and continually improve the CMS effectiveness
Does the facility have a third-party
6. Is appropriate to the organisation’s purpose certified system, relevant to any element
7. Is reviewed for continuing suitability of a chemicals management programme,
to improve their environmental
An organisation participating in the process of adopting an performance? (CRS 1.3.1)
ISO standard (such as 9000 or 14000) or that already has Does your facility have current
made a commitment to attain one of these levels of certification for ISO 14000?
excellence is typically required to develop a management Does the facility’s management
statement. This statement can be expanded to become a statement address chemical
CMS policy statement that is appropriate to its operations. management?
1.2 Scope of CMS

1.2.1 Requirements
Expected CMS Deliverable: Statement Indicating Where the CMS Is Applicable
Each organisation implementing a CMS needs to define the scope of the system by describing and
documenting the boundaries of the organisation to which ZDHC Audit Question
the CMS applies. The scope may include either the entire
Are there Standard Operating
organisation or specific operating units. At a minimum it is
Procedures (SOPs) that cover chemical
recommended that all production facilities or units are management such as approved
included in the CMS. For organisations that are starting to chemical list, chemical classification,
implement a CMS, a stepwise approach might be the most safe chemical handling, chemical
suitable. Facilities should note that while there is flexibility disposal and more? (CRS 1.1.2)
in choosing the scope, the credibility of the management
system is dependent on logical system boundaries.
The ZDHC system map can be a useful tool in making your scope determinations.
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 1-1

SECTION 2
Assessment, Planning and Prioritisation

2.1 Systematically Identify and Document Chemicals
Used and Stored in Your Organisation
2.1.1 Purpose
An organisation should have a robust process for creating and updating chemical inventories. This
process should provide a clear understanding of the chemicals stored and used in a facility and
promote responsible usage and pollution prevention.
Your team may have many elements of a CMS in place, but coordination and communication may be
lacking. A questionnaire will help your team gather information about how your system is working
(Appendix B Table 1: Facility Chemical Management Assessment Questionnaire). If most questions
are answered with Yes, the facility should focus on Sections 3 to 5 to gauge improvement
opportunities. The following information provides tools for resolving any questions answered
with No.
Elements 2.1.1, 2.1.2, and 2.1.3 take a stepwise approach in ZDHC Audit Question
reviewing and documenting chemicals in an organisation. Does the facility have an up-to-date
chemical inventory
2.1.2 Facility Plan and Walk Through (on paper, electronic)? (CRS 1.1.3)
2.1.2.1 Requirements
Expected CMS Deliverable: Factory Plan
Create a Facility Plan that details the physical areas of the property involved in chemical storage and
usage. A pictorial Facility Plan is recommended with each of the following areas individually labelled
on the plan:
1. Purchasing and delivery areas
2. Product storage areas ZDHC Audit Question
− Chemical storage areas Does the facility have basic
− Non-chemical storage areas documentation for the production and
chemical operations performance in the
3. Process areas
facility? (CRS 1.1.5)
4. Manufacturing areas
5. Waste storage areas Are closed loop (circular)
− Chemical waste storage areas cooling/heating lines identified on
industrial piping drawings? (CRS 1.1.8)
− Wastewater storage
− Non-chemical waste storage areas Are discharge pipes shown on the
6. Other areas with chemicals, such as laboratories and facility map? (CRS 1.1.9)
maintenance areas
The Factory Plan should be reviewed annually with a physical walk through and updated as needed.
The GIZ Practical Chemical Management Toolkit includes an example Factory/Ground Plan in their
Company Handbook Module 1.
Initially conduct a safety pre-screening walk through to identify and resolve any imminent hazards
and follow this with a more detailed inspection. It may be beneficial to have senior leadership
participate in the initial walk through. To assist you in planning, a walkthrough inspection checklist is
located in Appendix B Table 2: Walk-through Inspection Sheet for your use. The checklist is a simple
tool that should aid in identifying areas that may need immediate and overall improvement.
As part of the pre-screen and walk through, consider how waste and waste disposal are managed for
chemicals and off-specification materials.

ASSESSMENT, PLANNING AND PRIORITISATION
2.1.3 Chemical Material Flow Diagrams (Element 2.1.2)

Expected CMS Deliverable: Chemical Material Flow Diagrams
Create chemical material flow diagrams to assess where the main processes and material streams
and wastes occur. A chemical material flow diagram indicates the general flow of chemicals through
the organisation’s processes and equipment. This diagram should indicate the flow of chemicals
through purchasing, delivery, storage, handling, processing and disposal. Each diagram should include
inputs (such as raw materials, chemicals, water and energy) and product and non-product outputs.
When preparing a flow diagram, do not forget to ZDHC Audit Questions
indicate storage and transfer activities. Flow streams
Does the facility have a flow diagram of the
can be further refined as you gather additional production processes to identify hazardous
information, for example, by breaking down raw chemical release points? (CRS 1.2.3)
materials into more specific categories such as raw
Does the facility regularly conduct
materials, chemical groups or individual substances and
verification of the process flow(s)?
auxiliary material.
(CRS 1.2.4)
To determine if your flow chart contains all relevant Does the verification include following the
information, ask yourself the following questions: flow of chemicals through purchasing steps?
• Can/do you recognise the sources of your non- (CRS 1.2.4a)
product outputs? Does the verification include following the
flow of chemicals through receiving?
• Have all important inputs in each production (CRS 1.2.4b)
process been considered?
Does the verification include following the
• Have all intermediary products been identified? flow of chemicals through storage?
(CRS 1.2.4c)
• Have you been able to quantify inputs and outputs?
Does the verification include following the
• Can you clearly assign costs to the different wastes? flow of chemicals through dispensing?
• Are there information gaps, for which you may need (CRS 1.2.4d)
to collect further information? Does the verification include following the
flow of chemicals through
Chemical material flow diagrams should be reviewed
processing/production? (CRS 1.2.4e)
annually and updated as needed due to operational
changes. The GIZ Practical Chemical Management Does the verification include following the
Toolkit has example material flow diagrams in their flow of chemicals through disposal?
(CRS 1.2.4f)
Company Handbook Module 1.
Is there a corrective action procedure(s)
2.1.4 Creating a Comprehensive when inefficiencies /inaccuracies are
Chemical List identified during process flow reviews or are
Expected CMS Deliverable: Chemical Inventory they updated on a planned schedule or as
needed? (CRS 1.2.4g)
Inventory all chemicals in the facility to identify the
name of the chemical, hazard class, container size, locations of containers and dates on which
solutions were prepared or expire, if applicable. Identify chemicals of concern for your customers.
To track your inventory, you may select an electronic inventory system that can be used and
maintained for long-term tracking, your vendor may have an electronic system available for your use,
you can develop your own database (Appendix C) or the GIZ Practical Chemical Management Toolkit
includes example material chemical inventories for your use (Company Handbook Module 1).
The systematic identification of all chemicals at your organisation will allow you to conduct a risk
assessment of each chemical and rank the chemicals according to their hazard potential. Additionally,
comprehensive chemical lists will help assess chemical hazards, personal protective equipment (PPE),
inventory controls and environmental risks and improve an organisation’s management of chemical
use and disposal. The Chemical Inventory will be used in upcoming sections to build further
information and enable better chemical management.

2.1.4.1 Chemicals in Process

Expected CMS Deliverable: Chemical Process Control Documents
While conducting your inventory, create a list of chemicals used both in production processes and to
support production processes, such as chemicals used for cleaning equipment between run
changeovers (i.e., chemicals that the organisation re-uses, sells or discards). Intermediate chemicals
created during production do not have to be captured.
ZDHC Audit Questions
Written instructions for the proper use of a chemical
should be available where chemicals are used. Does the facility record quantities of
Instructions can be in the form of recipe cards, process chemical products used for each work
order/production order? (CRS 1.1.6)
adjustment instructions or formulation sheets and
should describe major operations and the chemicals Does the facility regularly identify the
and quantities that may be required for those quantity of chemicals lost due to accidents
processes. (e.g., spillages, poor labelling, accidental
mixtures)? (CRS 1.1.10)
Written chemical use instructions should include
process control parameters and check points. Typically, technical data sheets will provide information
regarding process and usage. It also may be of benefit to work with chemical supplier(s) to optimise
recipes, instructions and processes. Inventories should be updated annually or as process changes occur.
2.1.4.1.1 Accurate Chemical Inventory Using Mass Balance
The concept of mass balance can help with creating a chemical inventory. Mass balance, also called
a material balance, is an application of the law of conservation of mass that states that a system will
remain constant over time if nothing is added or removed from it. So, if the amount of a material that
enters a series of processes is recorded and accounted for in the process pathways, then the
quantities of these materials can be calculated. By accounting for material entering and leaving
a system with this technique, mass flows can be identified which may have been previously unknown
or difficult to measure. Mass balances are used widely in engineering and environmental analyses.
Mathematically the mass balance for a system, in the absence of a chemical reaction, is as follows:
Input = Output + Accumulation

The above equation also holds for systems with chemical reactions if the terms in the balance equation
are understood to refer to total mass (i.e., the sum of all the chemical species of the system). In the
absence of a chemical reaction, the amount of any chemical species flowing in and out will be the
same; this gives rise to an equation for each species present in the system. If this is not the case, then
the mass balance equation must be amended to allow for the generation or depletion (consumption) of
each chemical species. Sometimes one term in this equation is used to account for chemical reactions,
this will be negative for depletion and positive for generation. However, the conventional form of this
equation is written to account for both a positive generation term (product of reaction) and a negative
consumption term (the reactants used to produce the products). Although overall one term will
account for the total balance on the system, if this balance equation is to be applied to an individual
species and then the entire process, both terms are necessary. This modified equation can be used not
only for reactive systems, but for population balances that arise in particle mechanics problems. The
equation provided below simplifies to earlier equation when the generation term is zero.
Input + Generation = Output + Accumulation + Consumption

A helpful understanding of the above equation may be to confirm theoretical mass balance equations
against the effluent discharge and sludge analysis from ZDHC Audit Questions
all the processes. Work with your chemical suppliers.
Does the facility calculate the amount of
They may assist you in optimising usage of chemicals in chemicals used in its facility by mass
your process(es), including processes that support balance? (CRS 1.2.6)
production processes (e.g., such as cleaning
equipment).

2.1.4.2 Chemicals in Final Products

Expected CMS Deliverable: Factory MRSL and RSL ZDHC Audit Questions
in addition to a compliant chemical inventory to the
MRSL and RSL Is there a policy for monitoring and
controlling banned and restricted
Final products must conform to industry and substances that is applied to all chemicals
government regulations. These are typically used at the facility? (CRS 1.1.1)
communicated via a MRSL for the apparel and footwear
Is the facility able to demonstrate
industry. The MRSL addresses hazardous substances
knowledge of volatile organic chemicals
potentially used and discharged into the environment (VOCs)? (CRS 1.1.12)
during manufacturing and related processes, not just
those substances that could be present in finished Does the facility require its suppliers to
follow a MRSL/RSL? (CRC 1.1.1)
products. The MRSL is a list of chemical substances
banned from intentional use in facilities that process
textile materials and trim parts in apparel and footwear. The MRSL establishes acceptable
concentration limits for substances in chemical formulations used within manufacturing facilities.
MRSL limits are designed to eliminate the possibility of intentional use of listed substances.
Additionally, the industry has also established RSL limits for finished products. A typical RSL sets
concentration limits for substances in materials or finished products to comply with product
regulation and safety standards. The MRSL establishes concentration limits for substances in chemical
formulations used within manufacturing facilities.
Your facility may have several customer MRSLs and RSLs. Your team should harmonise these lists into
one (1) factory MRSL and RSL using the most stringent standard of those available. This harmonised
list should be communicated and distributed to all chemical suppliers to ensure that the chemicals
supplied meet all the facility needs to operate more safely and in conformance with regulations.
The ZDHC MRSL is accessible at the ZDHC Roadmap to Zero web site.
2.1.4.3 Chemicals as Discharge
Expected CMS Deliverable: Chemical Inventory with Hazardous Identification
There are many environmental regulations designed to protect human health and the environment
by placing limits on the quantity and chemical make-up of waste streams (e.g., air, water) released
from manufacturing processes. For example, one statute places restrictions on how hazardous waste
from industry is stored, transported and treated. Many companies have Health, Safety and
Environment staff
that can help
determine chemical
waste stream
regulatory
requirements. It is
important to
understand that
chemicals
discharged from the
facility can impact
the health and
safety of
employees, local Source: GIZ, 2014
residents and our
eco-systems. The basic chemical inventory can serve to quickly identify chemicals which will need
special handling and disposal. Understanding the processes and chemical reactions taking place also
will aid in establishing best practices for disposal.

2.1.4.4 Chemical Waste

Expected CMS Deliverable: Factory Plan for How and Where to Safely Store Chemical
Waste, Where it is Generated and How it Will be Disposed
Optimised processes will still result in waste generation from, for example, production runs and spent
cleaning liquids. This waste may not be able to be discharged to air, water or soil but needs to be
collected onsite and disposed of as chemical waste in accordance with relevant rules and regulations.
For details on which chemicals cannot simply be discharged to the environment, consult the SDS for
each compound.
2.2 Regulatory Assessment ZDHC Audit Questions

Are there SOPs that cover chemical
2.2.1 Monitoring Regulations and management, such as an approved chemical
Permits list, chemical classification system, safe
Expected CMS Deliverables: Regulatory Monitoring chemical handling procedures or chemical
SOP and Legal Requirement Permits Inventory disposal? (CRS 1.1.2)
Establish, document and implement a process for Does the facility have programmes in place
identifying and monitoring regulations applicable to to phase out the intentional use of the 11
chemical management permits. The process for priority chemical groups, as defined by the
ZDHC Group, with clear target dates?
identifying and monitoring regulations applicable to
(CRC 1.1.2)
chemical management should:
Are permits required for the collection,
1. State the applicable regulatory jurisdictions, transportation, storage and disposal of all
regulations and permits necessary to operate wastes such as chemical, chemical
(e.g., city, state/province, country). hazardous waste and recycled wastes?
(CRR 1.1.3)
2. Assign the initial regulatory identification to a
specific position(s) or team.
3. Assign the ongoing regulatory monitoring and
applicability determinations to a specific position(s)
or team. Does the facility have a system of tracking
changes in laws and regulations governing
4. Describe how management will be informed of environmental management and reporting
significant regulatory changes and/or when permit to management? (EPP 1.1.1)
constraints or operational limits are being Is there a process for monitoring the validity
approached. of the permits required for their facility?
The process should result in regulatory monitoring and (EPP 1.1.2)I
legal inventory (regulations and permits) standard
operating procedures (SOPs) that are updated at least annually.
Source: GIZ, 2014

2.2.2 Verification of Compliance ZDHC Audit Questions

Expected CMS Deliverable: Senior Management Is there a process that verifies that all
Compliance Report and Internal Audit chemicals used in manufacturing the
(CMS Element 4.2) product(s) meet applicable permit
Develop, document and implement a process for requirements? (CRR 1.1.1)
reviewing regulations and verifying compliance during In the past 3 years, has the facility received
implementation and maintenance of the CMS. an official notice or prosecution for
Compliance verification could be part of the audit non-compliance with respect to
process in CMS Element 4.2. Documents and records environmental legislation or regulation?
must be maintained that indicate how verification was (CRR 1.1.2)
conducted and the compliance results. These If the facility has U.S. or EU customers, is a
documents and records should be maintained according process in place to comply with the USA
to local regulations or a minimum of 3 years. Consumer Product Safety Improvement Act
(CPSIA) legislation and EU General Product
2.3 Procurement/Supplier Safety Directive (GPSD)? (CRR 1.1.5)
Practices Does the facility have procedures in place to
comply with Registration, Evaluation,
Does your facility have a purchasing and disposal policy Authorization and Restriction of Chemicals
for chemicals? Do you know what you can and cannot (REACH) regulations? (CRR 1.1.6)
order? Are there any guidelines on accepting chemical
donations? Creating an approved chemical list and a tracking system can assist with purchasing
decisions and help control future disposal costs. For example, tracking chemical storage may indicate
that there are excess chemicals in another facility that would allow you to avoid additional purchases.
The goal of a purchasing policy is to reduce the risk, liability and cost to workers and staff by
eliminating the purchase of unnecessary hazardous products. Careful consideration of the legal,
safety, ZDHC MRSL and brand MRSL and RSL requirements prior to the purchase of chemicals will
help your organisation reduce hazardous chemical storage, handling and use.
Steps to Developing a Chemical Purchasing Policy

1. Identify a Purchasing Coordinator
Ideally this should be a designated administrator or someone from the business office who
can oversee budget issues and approve purchases across all departments and who has an
understanding of chemical issues. To reduce costs, chemicals could be purchased at the
facility level. This allows greater purchasing power than purchases made by individual
departments.
2. Identify Department Representatives to Participate in the Review Process
This group will participate in the development and implementation of the purchasing policy
and purchase review criteria. Identify a representative from all departments that purchase
chemicals. This representative must have the requisite skills and authority to review their
department’s purchase requests.
3. Review Current Purchasing Procedures
Identify how chemical purchasing is currently done within each department, individual
buildings and complexes with multiple buildings. Explore how to integrate the chemical
purchase request review within the existing purchasing system.
4. Assess Chemical Inventory System
If there is no existing chemical inventory system in the facility, initiate the development of a
facility-wide system. This will enable departments to screen purchase orders against what
already is in stock across the facility.

2.3.1 Chemical Purchasing Policy Considerations

Expected CMS Deliverables: Chemical Purchasing Policy
Tracking of chemicals in facilities is easier if there are purchasing policies in place. Things that should
be considered:
1. Tighten purchasing controls: Institute procedures that are designed to restrict hazardous
chemical purchases to those needed for current business or research programmes and in minimal
amounts for short term use. Chemicals should be ordered in quantities consistent with the rate
of use.
Do not buy extra chemicals in bulk for anticipated savings. A centralised purchasing system can
be used to monitor requests for chemicals, implement policies such as staggered deliveries,
ensure sharing of chemicals among common users and develop plans for leftover chemicals.
2. Consider disposal cost at time of purchase: Many
chemicals deteriorate with time. When they must
be removed, the disposal cost may be 20 to 50 Is there a procedure on how to select and
times the original purchase price. The real cost of purchase chemicals? (CRP 1.1.1)
chemicals should be regarded as the initial purchase Are chemicals purchased against a
price plus any ultimate disposal costs. Disposal costs specification? (CRP 1.1.2)
often offset savings from buying in quantity. Are chemicals sampled and tested when
3. Consider handling and disposal requirements: If the received for approval against specifications?
facility does not have adequate storage and safety (CRP 1.1.3)
provisions for a chemical, its purchase should be Do large quantity deliveries have additional
discouraged. Try to use non-hazardous chemicals or controls to assure chemical purity and
those that are suitable for reuse. freedom from contamination/substitution
prior to off-loading to storage? (CRP 1.1.4)
4. Reduce expired stock: Negotiate expiration dates of
chemicals with suppliers based on their intended Is there a written contract or agreement
established, mutually confirmed and
use. Order reagents in amounts needed and stock
controlled between the factory and its
smaller containers of chemicals. This helps prevent contractors/subcontractors covering
waste due to surplus or shelf-life expiration. subcontracted activities? (CRP 1.1.6)
5. Use older stock first: Rotate chemical stocks to Are subcontracted activities identified and
avoid expiration of their shelf life. Note expiration monitored?(CRP 1.1.7)
dates. Use a first in, first out policy to keep
Does the organisation document receipt of
chemicals from becoming outdated. purchased chemicals? (CMD 2.1.5)
6. Avoid chemical donations: Do not accept donated Has the organisation documented and
chemicals or free samples unless they meet a implemented procedures to ensure that the
specific need. These can become a future waste identification of raw chemicals includes
disposal problem. Create a policy for acceptance of appropriate labelling, supplier name, receipt
donations. tracking information, matching supplier
documentation and quantity tracking?
Before ordering chemicals, staff and other personnel (CMD 2.1.9)
should:
• Make sure the chemical is on the facility system’s list of approved chemicals and check against
any MRSL/RSL in effect in the facility.
• Train personnel so that they are capable of assessing chemical hazards.
• Train personnel to be sufficiently knowledgeable in recognising requests from others for non-
essential chemicals.
• Develop a current inventory of existing chemicals.

• For each chemical used, ask the following questions:

− Can the supplier provide a Safety Data Sheet (SDS) in the local language containing the
relevant sections on proper handling, hazards, transport and safe disposal?
− Can proper storage be provided for the chemical?
− Are the facilities appropriate for the use of this chemical?
− Will the chemical or its end products require disposal as hazardous waste?
− Is appropriate PPE available for safe use of the chemical or its end product?
− Have persons who will handle and use the chemical been trained in handling these
chemicals? Are they aware of the hazards?
Before making a request to use a chemical not on the facility’s system approved list or if there is
doubt about its value, the requestor should read and research the appropriate SDS to determine
whether the chemical under consideration can be safely used with workers and the system process.
The requestor also should consider the:
• Relative hazard level of the chemical
• Research value of using the chemical
• Staff experience or lack of experience in using the substance
• Degree to which the laboratory/factory is equipped for safe use of the chemical
A requestor who wishes to use a substance not on the appropriate list should seek the permission of
the designated chemical administrative supervisor by submitting a written request. The request
should include the following:
1. A copy of the proposed trial/pilot or research exercise
2. Information supporting the following assertions:
a. Use of the substance is necessary
b. The trial/pilot project using the substance is a way to demonstrate an important property,
process or concept
c. No satisfactory substitute for the substance is readily available
d. Adequate safeguards are in place to ensure proper use of the substance
e. Workers are instructed in the proper handling of the substance
3. Information on the extent of staff and worker exposure to the chemical to enable the supervisor
to make an informed decision.
These general guidelines can be modified for chemicals used in the maintenance department, auto
shop, office area and other areas of the facility.
Tables 3 and 4 in Appendix B provide tools for making chemical ordering decisions. Additional
information can be found in Appendix A and B as well.
2.3.2 Identify Chemical suppliers
Does the facility have signed and dated
Expected CMS Deliverable: Chemical Inventory with declarations from their dye and chemical
Chemical Suppliers suppliers confirming that the formulations
Identify and document suppliers for each of the supplied to the facility are compliant with
chemicals listed in the Chemical Inventory. For urgent the relevant retailers' or the facility's own
RSL and/or MRSL? (CRP 1.1.5)
technical support or other emergencies, identify each
supplier and document their relevant contact Does the facility require its suppliers to
information such as point-of-contact name, phone follow a MRSL/RSL? (CRC 1.1.1)
number and address. Does the facility actively monitor RSL/REACH
supplier certificates and track against their
inventory? (CRG 1.1.1)

2.3.3 Supplier Approval/Removal Process

Expected CMS Deliverables: SOP for Supplier Approval and Removal
Establish, document and implement a process for identifying and using preferred suppliers and
removing suppliers from the preferred list when appropriate. An organisation should communicate
expectations to their dye and chemical suppliers to confirm that formulations supplied to the facility
are compliant with facility RSL/MRSL. At a minimum, preferred suppliers should be those that provide
an SDS in the local language that contains all the relevant information according to the Globally
Harmonized System of Classification and Labelling of Chemicals (GHS) standards (and adhere to the
appropriate portions of CMS Element 2.5.2 RSL and MRSL Process (CMS Element 2.5.2). The ZDHC
MRSL can be accessed at the ZDHC web site publications page.
2.4 Chemical Risk Assessment

2.4.1 Hazard and Risk Assessment
Expected CMS Deliverable: Hazard and Risk Assessment Inventory
Establish, document and implement a process for assessing the hazards and risks associated with
chemicals identified in the chemical inventory and update those inventories annually. Hazardous
chemicals are those that have an inherent property that can cause harm to humans or the
environment and/or cause damage through fire, explosion, corrosivity or toxicity. Hazard and risk
information can be obtained from container labels, SDSs, the internet, staff chemists and chemical
suppliers.
When carrying out a chemical hazards risk assessment, ZDHC Audit Questions
a number of key questions need to be asked:
Is the facility able to demonstrate
• Has the local supplier provided a proper SDS with knowledge of VOCs? (CRS 1.1.12)
relevant information? Are hazardous chemicals categorised by
─ If not provided, contact the supplier for their GHS classification as shown on its label
and/or SDS? (CRR 1.1.4)
assistance.
Has a chemical risk assessment of all the
• To what substances are workers exposed? chemicals used on the facility been
− Use the chemical inventory to consider all undertaken and available? (CRA 1.1.1)
persons who may have contact or exposure. Have worker exposure routes or possible
releases been identified for the facilities
• What harm can the chemical cause?
chemical list? (CRA 1.1.2)
− Chemical information can be found on Does the facility use or produce highly
packaging labels, from SDS, your chemical sensitising or toxic substances during its
supplier, a specialist in your factory or the processes? (CMW 2.1.7)
internet.
• What activities can increase exposure risk?
− Removal of a chemical from the original packaging for weighing or dispensing can increase risk.
− Pouring a chemical can result in exposure by spills or splashes.
• What risks need to be controlled?
− The risk significance may depend on the duration and frequency of exposure as well as the
concentration of the substance involved.

The SDS is the first place to look for hazardous and risk exposure information. Using information from
any of the above sources, the facility should create a hazard and risk assessment inventory that includes:
1. Chemical names: From inventory created in CMS Element 2.1
a. Common
b. CAS number
2. Process: Production, final product, laboratory, maintenance, discharge and other relevant
information
3. Area: Examples include dye kitchen, storage and printing
4. Supplier: Emergency contact information
5. SDS: Availability of SDS, Yes or No
6. Hazard statement: R-phrases from the SDS
7. Hazard type: Physical (flammability, explosivity), health (carcinogenicity, toxic to reproduction)
and environmental (bioaccumulative, persistency, eco-toxicity)
8. RSL/MRSL: Compliant chemical, yes or no
9. Amount per usage/batch/process: Estimate of how much of the chemical is used at one time
10. Amount lost to the environment: Use of information developed from mass balance and waste
records; estimate of the quantities of chemicals lost to the environment
11. Hazard Prioritisation: Prioritisation and ranking of the overall risks of the chemicals. See
Appendix D for Risk Assessment Template example
All work areas must at all times maintain an inventory of the hazardous chemicals according to the
following guidelines:
• When new hazardous chemicals are acquired, they must promptly be added to the inventory.
• When hazardous chemicals are expended or disposed, they must be removed from the inventory
or a single line shall be drawn through them.
• The inventory must be examined and updated periodically (at least annually).
• The inventory must be readily available to anyone entering the work area.
Safe Work Australia maintains a document on their web site called Managing Risks of Hazardous
Chemicals in the Workplace Code of Practice. This document includes good reference materials.
Appendix F (Overview of a Risk Assessment Process) and Appendix G (Risk Assessment Checklist) at
this web site also are useful hazard and risk management tools.
2.4.2 Environmental
Has the organisation established procedures
Expected CMS Deliverable: Process/Plan for to ensure that all wastes are collected and
Reducing Environmental Impacts handled in a timely and environmentally
Establish, document and implement a process for responsible manner and in accordance with
identifying and controlling the potential environmental any applicable legal/regulatory
impacts from use of their chemical inventory. For each requirements? (CMD 2.1.14)
of the below areas, the organisation should identify Do maintenance shops, laboratory and
environmental roles and responsibilities, where wastes other ancillary spaces practice proper
or discharges occur, appropriate control mechanisms chemical waste disposal? (CMW 2.1.12)
for discharges and how to monitor the control
mechanisms. The organisation also should set goals to reduce chemical wastes or discharges.
Environmental media that could be impacted are:
• Air • Noise and nuisance
• Soil • Waste and sludge
• Groundwater • Wastewater

An organisation also should establish, document and implement a process for monitoring and setting
goals to reduce their environmental impact. See Appendix E for example environmental standards
from the American Apparel and Footwear Association (AAFA).
Creating a Waste Action Plan

An action plan for managing chemical waste should contain the
following:
• Names of persons in charge
• Waste generation data that must be collected
• Investment (capital) and running cost associated with waste
• Measures for reducing waste
• Timeframe to reduce waste
• Expected environmental benefits/results (for monitoring and
later evaluation)
• How to train and qualify personnel involved in handling
hazardous waste about:
− Presence of the specific materials
− Potential physical and health hazards associated with these
materials
− Proper procedures for handling and use of these materials,
including the use of PPE (e.g., gloves and protective
goggles)
− Location and appropriate use of the chemical SDSs
Procedures to be followed in the event of an emergency
2.4.3 Health and Safety

Expected CMS Deliverable: Process for Reducing Health and Safety Impacts
(such as Action Plans)
Expected CMS Deliverable: JSA with PPE for Chemical Handling/Exposure
Establish, document and implement a process for
identifying and controlling the potential health and ZDHC Audit Questions
safety impact from chemicals stored, used and Does the facility have and maintain PPE,
discarded at your site. The chemical inventory safety showers, laboratory/factory eye wash
previously developed (Section 2.1.4) should be bottles or stations, fire extinguishers, and
more that are appropriate for the chemical
supplemented with this information.
hazards identified? (CMW 2.1.4)
An organisation should identify health and safety roles
Has management established procedures
and responsibilities and appropriate control that clearly define and communicate the
mechanisms to protect health and safety, develop areas in which authorised personnel are
monitoring steps for the control mechanisms and set allowed to enter? (CMW 2.1.5)
goals to reduce the potential for health and safety
impacts. This information can be found in the SDS for each chemical. If an SDS is not currently
available or does not contain information on health and safety, the chemical should not be used.
Chemicals without a proper SDS pose a risk to the workers, facility and environment. Contact the
chemical supplier for all appropriate information (CMS Element 2.3.3).

Ensure Good Personal Hygiene Properly Use and Maintain PPE

• Provide suitable eating and smoking areas • Select the correct type (for the chemical
• Provide washing facilities near the work in question) and fit of PPE, considering
areas where skin exposure may occur potential exposure (use guidance from
• Advise workers to remove splashes/spills the SDS)
on skin immediately • Provide clear instruction to workers on
• Advise workers to thoroughly wash the proper use of PPE (when, where,
exposed parts of the body after work is how)
completed • Ensure proper PPE is worn for as needed
• Prevent contaminated items from being • Provide storage, cleaning and
moved around the facility maintenance of PPE
• Remove and wash separately any • Plan and budget for PPE replacement at
contaminated item of work clothing after recommended intervals
using chemicals
A Job Safety Analysis (JSA) is one of the risk assessment tools used to identify and control workplace
hazards. The aim of a JSA is prevention of personal injury to a person or their colleagues and
workplace. A JSA is also known as an Activity Hazard Analysis (AHA), Job Hazard Analysis (JHA) and
Task Hazard Analysis (THA).
The JSA should be created by the work group performing the task. If available, it can be expedient to
review a prepared JSA that has been performed before. When conducting this type of JSA, the work
group must review all of the steps thoroughly to ensure that they are controlling all of the hazards for
this job. A JSA is usually completed on a form with the most common configuration a three column
table (although many companies include additional columns). Typical three column headings include:
1. Job step
2. Hazard
3. Controls
A hazard is any factor that can cause damage to personnel, property or the environment. Some
companies include loss of production or downtime in the definition as well. A control is any process in
place for controlling a hazard.
The work group should initially breakdown the task into its component steps and then identify
hazards for each step. Controls should be recorded in column three of the JSA for each hazard
identified.
2.5 Chemicals and Processes of Concern

2.5.1 Identify Gaps and Losses in Current Processes
Expected CMS Deliverable: Chemical Inventory ZDHC Audit Questions
Reconciliation, Material Balances and Material
Does the facility regularly identify the
Incident Report/Log
quantity of chemicals lost due to accidents
Using the chemical inventory chemical flow diagram(s) (e.g., spillages, poor labelling, accidental
developed in CMS Element 2.1.1 and CMS Element mixtures)? (CRS 1.1.10)
2.1.3, establish, document and implement a process for Is there a documented procedure to deal
creating chemical inventory and material balances to with spills and leaks? (CMD 2.1.13)
determine where there are potential chemical
knowledge and safety gaps and chemical losses not accounted for in the mass balance. An
organisation also should consistently maintain records of the chemical inventory and material
inventory balances and update the organisation’s hazard and risk assessment inventory
(CMS Element 2.4.1) accordingly. The GIZ Practical Chemical Management Toolkit Company
Handbook Module 1 includes examples on how to identify these gaps and losses.

2.5.2 RSL and MRSL Process

2.5.2.1 Verification of Compliance
Expected CMS Deliverable: Chemical Inventory ZDHC Audit Questions
with Column Identifying ZDHC MRSL Compliant
Formulations Does the facility have signed and dated
declarations from dye and chemical
Establish, document and implement a process for suppliers confirming that formulations
verifying compliance with RSLs, associated with supplied to the facility are compliant with
companies to which they sell products, and the ZDHC the relevant retailers' or facility's own RSLs
MRSL. Compliance verification can be part of the and/or MRSLs? (CRP 1.1.5)
purchase and audit process in CMS Element 4.2. Does the facility require its suppliers to
Maintain documents and records indicating how the follow a MRSL/RSL? (CRC 1.1.1)
verification was conducted and the results obtained. An
Does the facility actively monitor RSL/REACH
in-stock chemical found to be non-compliant to the supplier certificates and track against their
ZDHC MRSL, brand MRSL or brand RSL should not be inventory? (CRG 1.1.1)
used, instead it should be properly disposed of
according to local and regional regulations and safety information.
2.5.2.2 RSL and MRSL Update and ZDHC Audit Questions

Maintenance
Does the facility have programmes in place
Expected CMS Deliverable: Hazard and Risk to phase out the intentional use of the 11
Assessment Inventory (CMS Element 2.4.1 ) priority chemical groups, as defined by the
At a minimum, an organisation should annually review ZDHC MRSL, with clear target dates?
(CRC 1.1.2)
RSLs, associated with the companies to which they sell
products, and the ZDHC MRSL to determine if the Does the facility have a control
hazard and risk assessment inventory needs to be policy/procedure for the use of durable
updated. This assessment can be combined with the water repellent finishes based on
review in CMS Element 2.4.1. fluorinated chemistry? (CRC 1.13)
2.5.2.3 Integration with Contracts of Suppliers

Expected CMS Deliverable: Inventory of Chemical Suppliers (CMS Element 2.3.1 )
Establish, document and implement a process for ZDHC Audit Questions
monitoring supplier compliance with the organisation’s
Has the organisation documented and
chemical purchasing policy, RSL and MRSL. Contracts
implemented procedures for situations in
with suppliers should include language that requires which chemical(s) can be accepted on the
compliance with these elements. Suppliers who fail to basis of the supplier's certificate?
meet the standards laid out in the organisational RSL, (CMD 2.1.6)
MRSL or chemical purchasing policy or should be
removed from the approved supplier list (CMS Element 2.3.1).
2.5.2.4 Business Process Compliance with Contracts
Expected CMS Deliverable: Business Process Hazard and Risk Assessment Inventory (CMS
Element 2.4.1 )
Establish, document and implement a process to encourage suppliers to use the organisation’s MRSL
compliant formulation list (CMS Element 2.6.1). Maintain records of suppliers that are willing to use
your organisation’s MRSL compliant formulation list (CMS Element 2.6.1).

2.5.2.5 Going Beyond Regulatory

Expected CMS Deliverable: Target Goals and ZDHC Audit Questions
Metrics Does the facility have a hazardous chemical
Establish, document and implement a process that goes reduction plan beyond the 11 priority
beyond legal compliance. Document best practices chemical groups with clearly set targets?
regarding the use of greener materials, chemistry or (CRG 1.3.1)
procedures that assess leading green practices and Does the facility use a process to examine,
innovations. Also, document training classes, categorise and rank chemicals/formulations
conversations with suppliers or customers, conference to be purchased against impact(s) such as
attendance, research and other relevant activities. human or environmental risk? (CRG 1.3.5)
2.6 Performance Goals and Action Plans

2.6.1 MRSL Compliant Formulations
Expected CMS Deliverable: Chemical Inventory with
MRSL Compliant Formulations ZDHC Audit Questions
Expected CMS Deliverable: Phase Out Target Is the facility using suppliers’ ZDHC MRSL
Dates and Action Plan for 1 1 Priority Chemical compliant formulations to purchase
Groups chemicals? (CRG 1.1.2)
Create (and maintain a chemical inventory list which references MRSL compliant formulations and
their suppliers and update this list annually. Set an annual chemical inventory goal for the percentage
of formulations that are MRSL compliant and work towards that goal through the development of
action plans, assigned responsibilities, timeframes for actions and an estimate of resource needs
(e.g., financial, human). This list of substances should represent chemicals that score well on the
hazard and risk assessment inventory (CMS Element 2.4.1) and that have low to near zero discharges
to the environment. The ZDHC Group has set a high priority for eliminating or substituting hazardous
chemicals in our members’ products and their manufacture by 2020.
Develop a process to phase out the intentional use of ZDHC Audit Questions
priority hazardous chemicals using clear target dates. Does the facility have programmes in place
A chemical inventory with a hazard assessment and to phase out the intentional use of the 11
MRSL compliant formulations is a great starting point priority chemical groups, as defined by the
for review and goal setting. Discussions and action plans ZDHC Group, with clear target dates?
should be formed with the chemical supplier to ensure (CRC 1.1.2)
a successful target completion date without impacting
the facility’s process efficiency and product performance.
For guidance on the industry’s best management practices, regarding chemical management, see
additional CMS Resources in Section 6.
2.6.2 Alternatives Assessment
Expected CMS Deliverable: Best Practice Alternative Assessment
Establish, document and implement a process for assessing alternatives for chemicals that are found
to have significant hazards, risks or discharges and set an annual goal for the number of alternatives it
will assess. The process for assessing alternatives should include the development of action plans,
assigned responsibilities, timeframes for actions and an estimate of resource needs (e.g., financial,
human) to conduct the assessment.

SECTION 3
Chemicals Management
3.1 Organisational Structure

3.1.1 Roles and Responsibilities
Expected CMS Deliverable: CMS Organisational ZDHC Audit Questions
Chart Does the factory have an individual or team
responsible for chemical management?
For a successful CMS, senior leadership must commit
(CMO 2.1.1)
and ensure (see Section 1) the availability of resources
essential to establish, implement, maintain and improve Does the facility have procedures to ensure
CMS and customer satisfaction. Resources include that the approval for use of purchased
human resources and specialised skills, organisational chemicals is carried out by the authorised
personnel responsible for quality?
infrastructure, technology and financial resources.
(CMD 2.1.11)
Incorporate the following roles and responsibilities into
a CMS. Each role should include a named point of contact and that contact name should be
communicated to applicable supply chain partners. The CMS organisational chart and roles and
responsibility should be updated annually and as the organisation changes.
Role Responsibility
Reports to senior leadership

CMS Oversight Responsible for day-to-day management of CMS
Responsible for tracking progress on key performance indicators (KPIs) and goals
Systematically monitors applicable regulations on a regular schedule for each applicable

Regulatory Compliance legal jurisdiction
Identifies new or changing compliance requirements
Responsible for RSL and MRSL compliance and communication with supply chain
RSL and MRSL Oversight
partners
Responsible for process and product chemical knowledge

Chemical Application and
Management Responsible for knowing the contact names of individuals at supply chain partner
organisations with the same duties
Responsible for activities related to chemical hazard assessment

Hazard Assessment and Risk
Management Responsible for knowing the contact names of individuals at supply chain partner
organisations with the same duties
Responsible for activities related to safer alternative assessment and communicating

Alternatives Assessment
information to supply chain partners
Community of Practice and Acts as organisation’s representative for Chemical Management Community of Practice
Sustainable Chemistry Responsible for chemicals management and sustainable chemistry metrics

CHEMICALS MANAGEMENT
3.1.2 Communication
Expected CMS Deliverable: Safety Communication/ ZDHC Audit Questions
Hazardous Chemical Placards/Posted PPE Does the facility have a current (chemical)
Warnings SDS for each chemical, provided in the local
language and placed in chemical handling
Establish, document and implement a process for
and storage areas? (CMW 2.1.2)
communicating about the CMS amongst all of levels of
the organisation. An organisation also should establish, Has management established procedures
document and implement a process for receiving and that clearly define and communicate the
areas in which authorised personnel are
responding to external stakeholders, including
allowed to enter? (Primary focus is
documenting communications.
chemicals.) (CMW 2.1.5)
3.2 Training Is there a chemical emergency response
plan in place and practiced on a planned
To achieve a goal of zero discharge of hazardous schedule? (CME 2.1.1)
chemicals, organisations should:
1. Ensure that personnel are competent through appropriate education, training or experience.
Train employees about:
a. Preventive environmental and work safety practices
b. Saving resources
c. Proper use of goggles and face shields to avoid eye and skin contact
d. Use of protective clothing to avoid skin contact with chemicals
e. Selecting suitable gloves and removing gloves to avoid skin contact with chemicals
f. Proper hand washing
2. Retain associated chemical records ZDHC Audit Questions
3. Establish, document and implement a process to Are training records maintained to
conduct and track training demonstrate that facility personnel handling
chemicals have the required education,
4. Assess training effectiveness with a quiz or by training and skills to perform their assigned
monitoring an appropriate activity to demonstrate responsibilities and activities? (CMT 2.1.1)
learning
5. Ensure that personnel are aware of the relevance and importance of their activities and how they
contribute to achieving chemical objectives
3.2.1 Management
Establish, document and implement a process for informing top management of their roles in
managing chemicals. Include information about the hazards and risks associated with the existing
chemical inventory, the improvement goals of the organisation and the human and financial resource
needs for CMS implementation.
3.2.2 Regulatory
Establish, document and implement a training process for making appropriate staff knowledgeable
about the legal requirements (CMS Element 2.2) associated with chemicals in the organisation’s
inventory (CMS Element 2.1.3).
3.2.3 Work Practices
Establish, document and implement a process for making chemical-handling staff aware of
appropriate work practices. At a minimum, appropriate staff should be trained on the SOPs created
to fulfil CMS Element 3.5.

3.2.4 ZDHC Training

Expected CMS Deliverables: Training Matrix Outlining Training Needs, Training Content and
a Roster of Training Attendees
Establish, document and implement a process for appropriate staff to participate in the ZDHC Group’s
sponsored training on chemicals management, the ZDHC MRSL and future training modules to be
developed. ZDHC materials can be found at http://www.roadmaptozero.com.
3.3 Document Development

Expected CMS Deliverable: CMS Manual
Create a CMS Manual that describes the main elements Have procedures documenting the proper
of the CMS and references related documents. The CMS handling, use, storage and disposal of
manual should include: chemicals and hazardous chemicals
• Documented statements of a chemical policy and according to the SDS/technical sheets been
written and implemented at the facility?
chemical objectives
(CMD 2.1.1)
• Documented procedures and records required by Does the organisation have a written
this manual chemical safe handling plan to ensure that
• Documents, including records, determined by the storage and conditions are appropriate for
organisation to be necessary to ensure the effective the chemical hazard class? (CMD 2.1.7)
planning, operation and control of its processes
Review the CMS manual annually and update as needed.
3.4 Document and Record Control

Expected CMS Deliverable: Procedure to Control
Documents and Records ZDHC Audit Questions
Establish, document and implement a process for Does the facility have a document retention
controlling documents and records associated with the procedure that requires retention of key
CMS. The document control process should ensure that: chemical inventory records for at least one
year? (CMD 2.1.2)
• Documents are approved for adequacy prior to use
Are records available and retained which
• Correct versions are available at points of use and show chemical usage and traceability within
versions are tracked the factory? (CMD 2.1.3)
• Documents are legible, updated and re-approved as
needed
Examples of documentation include SDS, PPE safety, JSA, MRSL, RSL, supplier certificates of
compliance and chemical spill logs.
Records required by the CMS are a special type of document and require strict control procedures.
The record control process should address record protection, retrieval, retention and disposal.
An ISO-certified facility may have an existing system for control of records and record keeping.
This can be used to develop a CMS record-keeping procedure.
Establish a documented record keeping procedure to:
1. Approve documents for adequacy prior to issue
2. Review, update and re-approve documents
3. Ensure that changes and the current revision status of documents are identified
4. Ensure that the most up to date versions of documents are available at the appropriate points of use
5. Ensure that documents are legible and readily identifiable
6. Ensure that documents of external origin, determined by the organisation to be necessary
for the planning and operation of the CMS, are identified and their distribution controlled
7. Prevent the unintended use of obsolete documents and apply suitable identification to the files

3.5 Chemical Management Work Practices

Establish, document and implement a processes for
chemical management work practices. Specifically, an ZDHC Audit Questions
organisation must establish documented SOPs for each Are there SOPs that cover chemical
of the topics discussed in this section. management such as an approved chemical
list, chemical classification, safe chemical
3.5.1 Exposure Control Measures handling, chemical disposal?
(CRS 1.1.2)
Expected CMS Deliverable: Procedure to Control
Exposure Do personnel have access to and comply
with the documents needed to do their
A control approach, control strategy or control level of
work and related to their responsibilities?
exposure is the sum of the control measures required to
(Primary Focus – Chemicals) (CMT 2.1.2)
reduce risk from a specific chemical. The best practice
for controlling chemical exposure is through the use of technical protection measures. Substance
releases should/can be prevented through containment systems, such as suitable mechanical barriers
(e.g., enclosures) and air dynamic barriers (e.g., local exhaust ventilation [LEV] as an integrated part
of the containment and differential pressure). The physico-chemical properties of a substance are
another factor to consider when determining the right design to achieve the necessary control
precautions and process conditions.
Control examples:
• A highly volatile organic solvent requires a higher precaution level than a water-based chemical
product that doesn’t contain volatile components.
• A chemical with a high hazard level should be controlled by a higher protection level than the
level needed for a non-hazardous chemical.
PPE can only be part, though a necessary action, of a safety concept. The intent of PPE use should be
protection during accidents and incidents that may occur despite appropriate management systems
and operational procedures.
Exposure control measures for skin contact include preventive activities such as:
• General occupational controls to prevent and reduce release of dust and splashes
• Selection and use of personal protective gloves, ZDHC Audit Questions
protective clothing and other required PPE (specific Does the facility have procedures in place to
for the types of chemicals in use) to protect workers document the proper handling, use, storage
• Maintenance and replacement of equipment so and disposal of chemicals and hazardous
chemicals according to the SDS/technical
that control measures remain effective
sheets been written and implemented at
Safe Work Australia maintains a good reference the facility? (CMD 2.1.1)
document on their web site called Managing Risks of Does the facility have a current (chemical)
Hazardous Chemicals in the Workplace Code of Practice. SDS for each chemical that is available in the
Chapter 4 and Appendix J also are applicable to local language for chemical handling and
controlling chemical risks. storage areas? (CMW 2.1.2)

3.5.2 Safety Data Sheet Management

Expected CMS Deliverable: Procedure to Make SDSs Readily Available for Every Chemical
SDSs can be obtained from your chemical suppliers. The
sheets provide valuable information that you can use to
optimise chemical use and improve workplace health If portable equipment and utensils are not
dedicated to specific chemicals or classes of
and safety standards. At a minimum, preferred
chemicals, are the chemicals of construction
suppliers should be those that provide a SDS in the local
appropriate to prevent cross
language and that information should contain all contamination? (CRS 1.1.7)
relevant GHS standards.
Does the organisation have a written,
SDSs: chemical safe handling plan to ensure that
storage and conditions are appropriate for
• Indicate characteristics, properties and quality of the chemical hazard class? (CMD 2.1.7)
the chemical that influences the end product. Does the facility have appropriate controls
• Allow determination of chemical compatibility for in place for batch/continuous chemical
proper mixing. processes? (CMW 2.1.1)
Does the organisation have a written
• Provide information about proper storage and chemical change management process?
handling (e.g., ventilation). (CAC 3.1.1)
• Indicate appropriate security precautions and Does the facility have chemical hazard
needed controls, including PPE. signage and safe handling equipment
available in the facility areas where
• Provide written emergency procedures in case of exposure may occur? (CD 4.1.1)
spills, fire or explosion.
• Indicate steps for first aid.
• Specify the hazard level, which gives clues about the possible effects on water, soil and human
health.
• Specify the flashpoint (the lowest temperature at which a chemical releases flammable vapour).
The lower the flashpoint, the more hazardous the chemical is as a source of fuel for fire or
explosion.
• Specify the boiling point, which is used to determine volatility. The lower the boiling point, the
higher the volatility.
• Specify the vapour pressure which also is used to determine volatility.
The information provided on SDSs serve as the basis for providing oral and written instructions to
workers in the safe use of chemicals. An SDS for every chemical substance used in your operation
should be kept in a central location and also at the point of use so that it is readily available for
consultation by workers and supervisors.

3.5.3 Chemical Handling

Expected CMS Deliverable:
Has the facility identified and documented any types of
Procedures for Safe Chemical
installation/processes that have a potential to leak and cause
Handling
significant environmental degradation (e.g., aboveground
Procedures should be provided for storage tanks, underground storage tanks, wastewater
handling chemicals in the safest way treatment plant bulk storage)? (CRS 1.1.13)
possible, as outlined in the SDS. The Is there secondary containment at all locations where
ÖKOPOL document, Checklist Based on chemicals are stored and an emergency response plan in
Best Available Techniques in the Textile place for those critical areas? (CRS 1.1.14)
Industry, includes useful checklists and Has the organisation documented and implemented a
guidance on the storage and handling of procedure to re-evaluate chemicals after a defined period of
chemicals. storage to determine their suitability for use? (CRS 1.1.15)
Are special storage conditions identified and followed from
3.5.4 Chemical Storage chemical specifications or SDS? (CMW 2.1.3)
CMS Deliverable: Procedure for Are chemicals stored in a well-ventilated space designated
Chemical Storage only for this purpose? (CMW 2.1.6)
Improve the storage of chemicals with Is there adequate space in and around weigh areas,
the help of: machinery and storage and appropriate environmental
controls to preclude mix ups or contamination? (CMW 2.1.8)
• Information provided in the SDS Are incompatible chemicals stored separately to ensure that
• SOPs and checklists no dangerous chemical reactions can occur? (CMW 2.1.9)
• Ventilation and grounding Are flammable chemicals stored separately and securely?
(CMW 2.1.10)
• Separation of incompatible
chemicals
• Handling spillages and leaking containers
• Provision for a drainage system connected to the effluent treatment plant
• Adequate storage of halogenated solvents
• Adequate storage of flammable liquids
• Fire protection measures
The ÖKOPOL document, Checklist Based on Best Available Techniques in The Textile Industry, has
useful checklists and guidance on the storage and handling of chemicals. Another good storage
reference is the German Technical Rules for Hazardous Substances.
3.5.5 Chemical Transportation
CMS Deliverable: Procedure for Chemical Transportation and Training on Transport of a
Chemical
Chemicals may be transferred to or from work areas through pipelines or conveyors or by using
forklift trucks, trolleys or wheelbarrows. Before transport, check the SDS, labels and replace all
broken, torn or incorrectly located labels. During the transport of a chemical, ensure the proper PPE
safeguards are available in case of leakage or the unexpected spill or rupture of a container.
During transport the following should be considered:
• Chemicals transported by forklift truck should travel on clearly marked passageways, of adequate
width, to reduce the possibility of collision and spillage.
• Containers for flammable liquids should be specially constructed with spring-located caps and
flame arresters in their spouts. The transfer of flammable liquids should only be conducted in
well-ventilated areas with the containers earthed and bonded.
• Avoid shaking hazardous chemicals to prevent leaking due to over volatilisation.
• Leak-proof equipment should be used when transporting small amounts of hazardous chemicals.

3.5.6 Chemical Labelling

CMS Deliverable: Procedure for Chemical Labelling ZDHC Audit Questions
Chemical containers and packaging should allow for Are intermediate and/or chemical transfer
containers properly labelled?
clear identification of chemical substances. A
(CMW 2.1.11)
manufacturer should indicate whether the substance
you are using may be hazardous and pose a risk to humans or the environment through contact or
accidental release. Internationally standardised labels (like GHS), markings, symbols, risk-phrases or
hazard statements are commonly used by chemical manufacturers and suppliers to indicate a
chemical’s hazard risk.
Best labelling practices include:
• Adopting a standard labelling procedure for chemicals and waste, using colourfast, permanent
labels
• Designating a responsible person or team for labelling and inventory control
• Using tags, bar codes or some other system to establish tracking of chemicals
• Reviewing all areas of the facility, such as laboratories, workshops and waste effluent treatment,
for labelling compliance
3.5.7 Chemical Use – Regular and Optimisation
The following rules, regarding use of chemicals, should be followed at all times.
• Use a first-in/first-out policy. ZDHC Audit Questions
• Perform regular inventory audits to identify Does the facility have established
procedures or alternative systems to ensure
chemicals that are not being used.
that only quality-control approved
• Provide a simple, regular listing to chemical users chemicals are used? (CMD 2.1.8)
that includes available chemical stocks, location and Are incoming chemicals segregated from
point(s) of contact. working stock prior to acceptance for use?
• Read chemical labels before using. (CMD 2.1.10)
Keep SDS up to date and review regularly for new Has the organisation established and
implemented procedures to ensure
content (at least annually).
chemicals used are from oldest to newest
• Do not mix unknown chemicals. receipt date? (CMD 2.1.12)
• Do not use food containers for chemicals and do not eat near chemicals.
• Use ventilation systems to reduce chemical inhalation of dust/fumes.
• Do not smoke near chemical storage areas.
• Wash hands after handling chemicals.
3.5.8 Personal Protective Equipment
Is there an internal audit group that reviews,
CMS Deliverable: Procedure for PPE Use audits and verifies chemical hazards and
The main purpose of PPE should be to protect inventory? (CAA 3.1.1)
employees should an accident or incident occur despite Is there adequate space in and around
appropriate management systems and operational weigh areas, machinery and storage along
procedures. with appropriate environmental controls to
preclude mix ups or contamination?
Information on appropriate PPE can be found in the SDS (CMW 2.1.8)
for each chemical. PPE includes the following:
Have boiler and effluent treatment
• Eyes: Wear appropriate protective eyeglasses or chemicals been inventoried and
chemical safety goggles as described by the U.S. categorized? (CMW 2.1.15)
Occupational Safety and Health Administration’s
(OSHA’s) eye and face protection regulations in 29CFR 1910.133 or European Standard EN166.

• Skin: Wear appropriate protective gloves to prevent skin exposure.

• Clothing: Wear appropriate protective clothing to prevent skin exposure.
• Respirators: Follow the OSHA respirator regulations found in 29CFR 1910.134 or European
Standard EN149. Always use the U.S. National Institute for Occupational Safety and Health
(NIOSH) or European Standard EN149 approved respirator when one is necessary.
3.5.9 Laboratory Practices
CMS Deliverable: Procedure for Safe Work in the Laboratory
Develop safe laboratory practices procedures and make them accessible. Many resources for
developing safe lab programmes are available, including a checklist at
http://www.ors.od.nih.gov/sr/dohs/BioSafety/Pages/student_goodlab.aspx.
3.5.10 Maintenance and Housekeeping
CMS Deliverable: Procedure for Maintenance and Housekeeping
Regularly conduct maintenance and housekeeping activities.
• Ask employees to determine and record which chemical containers are:
─ Unlabelled
─ In poor condition
─ Expired
─ Not essential
• Chemicals that meet one of these conditions are candidates for disposal. To determine if disposal
is appropriate, also consider:
─ Approximately how much of each chemical is used every year?
─ How many months/years of supply of a chemical are currently on hand?
• If the team determines that disposal is in order, then there are four activities to consider:
─ Create a list of chemicals for disposal (Disposal List)
─ Identify a qualified professional to assist in the chemical cleanout and disposal process
─ Prepare for the chemical cleanout and disposal
─ Take steps to reduce the need for future chemical cleanouts (for example, purchasing
controls, inventory management)
EXAMPLE: Completed Disposal List
Storage Chemical CAS Conc Exp. Amt. or Cont. Amount Storage
Date/ Initial Name Date container size Type (est.) Location
4/2/08 1-Propanol 71-23-8 100% N/A 2 x 500 Poly 750 mL Flammable

JS mL cabinet Room 202
6/5/08 Aluminium 7429-90-5 100% N/A 500 g Glass 200 g Chemical Storage
MA Room 110

3.5.11 Waste and Disposal

CMS Deliverable: Procedure for Proper Waste Collection, Handling, Storing and Disposal
No process will run without generating waste that cannot be discharged to air, water or soil but
needs to be collected and disposed of as chemical waste in accordance with local regulations.
3.6 Emergency Procedures

CMS Deliverable: Emergency Response Plan
Establish, document and implement a process to identify and respond to potential chemical
accidents. Test emergency procedures periodically. These procedures should be updated as
appropriate after practice drills and actual emergencies.
Emergency Response Plan

A written, up-to-date Emergency Response Plan for your company (covering all
workplaces) is essential. It should include detailed instructions on how to evacuate the
building and contain contact names/information for individuals in charge of the
evacuation.
• Primary and secondary escape routes with simple instructions should be posted at
significant spots, at entrances and near elevators and telephones.
• Emergency Response Leaders should be assigned specific duties, such as verifying that
all workers have been evacuated.
• Disabled workers and those with a history of certain medical conditions should be
assigned an Emergency Response Leader to guide them to safety.
• Stairways should be kept free of materials that could block or hinder an evacuation.
• Regular fire drills should be conducted to identify problems before an actual fire
occurs. Treat the drills as if they were an actual emergency.
• Important telephone numbers such as emergency, fire department and internal
Emergency Response Leaders should be posted close to every telephone.
In addition to the Emergency Response Plan:
• Maintain an emergency shower and eye wash station for removing chemicals that may
contact the skin or eyes.
• Keep a first aid kit that is clearly marked, easily accessible and protected against dust
and water. The kit should include:
− An inspection tag to document monthly checks
− Written first aid instructions in the local language

SECTION 4
Monitor
4.1 Monitor and Measurement ZDHC Audit Questions

(Continuous Improvement) Is there secondary containment at all
locations where chemicals are stored and an
CMS Deliverable: Process to Monitor Goal Progress emergency response plan in place for those
General Requirements: critical areas? (CRS 1.1.14)
Has the organisation documented and
• Plan and implement the monitoring,
implemented procedures to re-evaluate
measurement, analysis and improvement chemicals after a defined period of storage
processes needed to: to determine their suitability for use?
─ Ensure conformity of the CMS (CRS 1.1.15)
─ Continually improve the effectiveness of the Is there a corrective action plan in place for
the facility non-compliance? (CRR 1.1.2a)
CMS
Is there a documented procedure to deal
• Include determination of applicable methods, with chemical spills and leaks? (CMD 1.1.13)
including statistical techniques, and the extent of
their use in the plan. Does the facility maintain appropriate spill
containment kits in use and storage areas?
4.1.1 Goal Progress (CMW 2.1.13)
Establish, document and implement a process to Is there a chemical emergency response
monitor progress towards the goals created in CMS plan in place and practiced on a regular
Element 2.6. Make sure to document information used schedule? (CME 2.1.1)
to monitor performance and maintain associated Is management aware of the ZDHC 11
records. priority chemical groups and ZDHC goal of
4.1.2 Regulatory Compliance zero discharge? (CAG 3.1.1)
Does the facility have targets in place to
CMS Deliverable: Process to Monitor Regulatory
reduce or eliminate the use of hazardous
Conditions
chemicals in the facility? (CAG 3.2.1)
Establish, document and implement a process to
Does the facility set and review, at least
monitor progress towards regulatory conditions annually, formal targets to reduce the
identified in CMS Element 2.2. These could include amount of hazardous substances used?
MRSL, RSL, wastewater discharge limits, air emission (CAG 3.2.2)
restrictions or other qualitative or quantitative
conditions set through regulation or permits. Make sure to document performance and maintain
associated records. Equipment needed to conduct the measurements should be calibrated and
associated records maintained as well.
4.1.3 Work Practice and Customer ZDHC Audit Questions

Requirements Implementation Does the facility have a system of tracking
changes in laws and regulations governing
CMS Deliverable: Monitor Operating Conditions and environmental management and reporting
Customer Satisfaction to management? (EP 1.1.1)
Organisations should establish, document and Is there a process for monitoring the validity
implement a process to monitor operating conditions of permits required for their facility?
needed to prevent the potential for adverse impacts to (EP 1.1.2)
health or the environment. The organisation should
Is there a process in place that verifies all
document performance against the operating criteria
chemicals used in producing the product(s)
and maintain associated records. meet applicable permit requirements?
(CRR 1.1.1)

MONITOR
As one of the measurements of CMS performance, the

organisation should monitor customer perception ZDHC Audit Questions
regarding whether the organisation has met customer Does the facility have a process to monitor
requirements. Methods for obtaining and using this and review its business registration and
customer information should be gathered and regulatory permits? (CRR 1.2.1)
documented. Does the facility have a process to follow
and update legal requirements as they apply
4.2 Internal Audit to facility operating permits and customer's
products? (CRR 1.2.2)
CMS Deliverable: Process for Internal Audits
Establish, document and implement a process to ZDHC Audit Questions
periodically audit performance against the CMS Is there an internal audit group that reviews,
Elements and associated processes. The audits should audits and verifies chemical hazards and
determine if the CMS is properly implemented and inventory? (CAA 3.1.1)
maintained and is contributing to the overall goal of
reducing the discharge of hazardous chemicals.
Documents and records associated with the audit,
including an audit plan, audit checklist and audit results, ZDHC Audit Questions
should be maintained. The ZDHC audit checklist may be Does the facility periodically audit or
a useful recording tool. otherwise verify suppliers? (CAA 3.2.1)
4.3 External Audit

CMS Deliverable: Participate in External Audits
Establish, document and implement a process to periodically audit the organisation against the ZDHC
audit criteria. Documents and records associated with the audit, including an audit plan, audit
checklist, and the results, should be maintained. The ZDHC audit checklist maybe a useful tool for
maintaining this information.
Best practices for chemical management suggest that ZDHC Audit Questions
even suppliers should practice and audit chemical
management. Facilities may send quality and technical Does the facility require a ZDHC audit or a
certified third-party audit regarding
staff to observe or review their practices as well. These
chemical management? (CAA 3.3.1)
practices are especially useful for verification of
certificates of compliance or other certification letters regarding MRSL/RSL compliance.
4.4 Change Management and Corrective Action

4.4.1 Change Management
Most businesses routinely receive change orders or
new/revised specifications. A good CMS should ZDHC Audit Questions
establish a system to handle internal and customer Does the organization have a written
chemical inventory changes. Establish, document and chemical change management process?
implement a process for reviewing planned or actual (CAC 3.1.1)
process, engineering/operational or regulatory changes
for impacts on the CMS. Process, engineering/operational or regulatory changes need to be reviewed
to determine if updates are needed to work practices, audits, the hazard and risk assessment
inventory and other CMS elements.

MONITOR
4.4.2 Corrective Action

CMS Deliverable: Procedure for Change Is there a corrective action procedure(s)
Management and Corrective Action when inaccuracies are identified in the
Establish, document and implement a process for chemical inventory reconciliation?
dealing with actual and potential non-conformity(ies) or (CRS 1.1.11)
non-compliance. This process should include taking Is there a corrective action plan in place for
corrective and preventive actions, documenting the facility non-compliances? (CRR 1.1.2a)
actions taken and verifying the effectiveness of the
Is there a corrective action plan
actions taken. implemented and monitored in case of
chemical non-compliance by chemical
supplier(s) when identified by the facility?
(CRS 1.2.5)

SECTION 5
Management Review
5.1 Disclosure of Substance in Use
CMS Deliverable: Process for Disclosing
Substances in Use ZDHC Audit Questions
Does the facility have chemical hazard
Establish, document and implement a process for signage and safe handling equipment
disclosing the substances in use. An organisation should available in areas of the facility where
determine and document which stakeholders will be exposure could occur? (CD 4.1.1)
provided the substance in use information and how the
Is the annual usage (volume) of each
information will be communicated. The chemical risk
chemical monitored and recorded?
assessment information gathered in Section 2.4 can (CRS 1.1.4)
provide the basis for an organisation’s disclosure
practices.
5.2 Stakeholder Review

CMS Deliverable: Process for Engaging Stakeholders
Establish, document and implement a process for periodically engaging with stakeholders to
determine the suitability and effectiveness of the CMS. Stakeholders should be given data on the
status of the CMS that includes:
1. Progress toward goals
2. Audit results
3. Status of change management and corrective actions
4. Regulatory changes
Stakeholders are responsible for providing feedback on how ZDHC Audit Questions
to improve the system and guide the organisation closer to Does the facility have a current (chemical)
achieving the goal of zero discharge of hazardous chemicals. SDS for each chemical, available in the local
Documents and records, including meeting minutes, language, located in areas where chemicals
indicating performance of this element shall be maintained. are handled or stored?
(CMW 2.1.2)
Information regarding chemical inventory and hazardous
Is there a chemical emergency response
chemicals should be shared with local public officials in case
plan in place and practiced periodically?
of needed emergency response (for example, for fires and (CME 2.1.1)
spills). Establish a channel of communication to disclose
hazardous chemicals, control plans and future phase out plans for hazardous chemicals. This
communication channel also should permit enquiries and acknowledgements in response to the
communicated plan.
Facilities should publicly disclosure their sustainability ZDHC Audit Questions
efforts. This may include providing effluent discharge reports Are chemical management efforts shared
to Pollutant Release and Transfer Register sites and the with the public? (CD 4.2.1)
efforts taken to control water usage, carbon footprint and Is the facility a chemical/product steward?
energy conservation. (CD 4.3.1)
Organisational best practices are those in which the facility
becomes an environment or product steward through participation in a programme such as
Responsible Care or other universally recognised programme. When those programme requirements
are meet, the placement of a logo or label may be allowed for use on the product.

MANAGEMENT REVIEW
5.3 Management Review

CMS Deliverable: Process for Engaging Senior Management
Establish, document and implement a process for periodically engaging with top management to
determine the suitability and effectiveness of the CMS. Top management should be given data on the
status of the CMS that includes:
1. Progress toward goals
2. Audit results Is management aware of the ZDHC 11
3. Status of change management and corrective priority chemical groups and ZDHC goal of
actions zero discharge? (CAG 3.1.1)
4. Regulatory changes
5. Input from stakeholders
6. Follow-up actions from previous management reviews
7. Changes that could affect the CMS
8. Recommendations for improvement
Senior management should be responsible for providing feedback on how to improve the system and
guide the organisation closer to the goal of zero discharge of hazardous chemicals.
Documents and records, including meeting minutes, indicating performance of this element shall be
maintained.

SECTION 6
CMS Resources
Organisational Skill CMS Manual Section Title & Description Hyperlink
Level (Symbol) Reference
Foundational
1.1.1 ISO 9001 for Small Business – what to do advice http://www.iso.org/iso/home/news_index/news_archive/news.htm?refid=Ref1669
1.2.1 Workplace Safety and Health Guidelines – https://www.wshc.sg/files/wshc/upload/cms/file/WSH_Guidelines_MHCP.pdf

Management of Hazardous Chemicals Programme
1.2.1 Code of Practice on Safety Management – basic http://www.labour.gov.hk/eng/public/os/manage.pdf

expectations of a Safety Management System
2.1 Chemical Management Guide for Small and Medium http://www.mtpinnacle.com/pdfs/Guide_E_300708.pdf

Sized Enterprises
2.1 OIA Chemical Management Module – toolkit http://outdoorindustry.org/responsibility/chemicals/cmpilot.html
2.1.2 EMAS “easy” for Small and Medium Enterprises – in 10 http://www.emas-easy.eu/

days with 10 people on 10 pages in 30 steps
2.1.4 AFIRM Chemical Guidance Document –provide an http://www.afirm-group.com/PDF12/AppendixF-ChemicalGuidance.pdf

overview to types of chemicals used in textiles and
leather goods
2.1.4 Guidance for creating mass balances http://serc.carleton.edu/introgeo/mathstatmodels/examples/MassBalance.html

http://www.ce.utexas.edu/bmeb/resources/mass.html
2.1.4.3 Waste Minimisation Guide for the Textile Industry – http://www.tex.tuiasi.ro/biblioteca/carti/Articole/Waste_Minimisation_Guide_for_t

steps to cleaner production he_Textile_Industry_A_Step_Towards.pdf
2.1.4.3 Florida Guide to Writing a Waste Minimization Plan http://www.dep.state.fl.us/waste/quick_topics/publications/shw/HWRegulation/Bi

nder1_waste_min_guide.pdf
2.4.1 Example COSHH risk assessment – Warehouse: Use it http://www.hse.gov.uk/coshh/riskassess/warehouse.htm

as a guide to think through some of the hazards in
your business and the steps you need to take to
control the risks.

CMS RESOURCES

2.4.1 Identifying and Evaluating Hazards in Research http://www.acs.org/content/dam/acsorg/about/governance/committees/chemicals

Laboratories – while oriented to the lab many factors afety/identifying-and-evaluating-hazards-in-research-laboratories-draft.pdf
can be adapted to the factory.
2.4.3 Safety in the use of chemicals at work – basic guidance http://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/---

to protect workers from the hazards of chemicals safework/documents/normativeinstrument/wcms_107823.pdf
2.2.1 ZDHC Research List – 2014: Chemical Substance www.roadmaptozero.com/df.php?file=pdf/ResearchList.pdf

Resource Links provide more regulatory information.
2.5.2 Meeting Customers’ Needs for Chemical Data – a http://greenchemistryandcommerce.org/downloads/GC3_guidance_final_031011.p

guidance document for suppliers df
2.6.2 Transitioning to Safer Chemicals – a toolkit for https://www.osha.gov/dsg/safer_chemicals/index.html

employers and workers
2.6.2 The Guide to Safer Chemicals – implementing the http://www.bizngo.org/safer-chemicals/guide-to-safer-chemicals

BizNGO principles for safer chemicals
2.6.2 Interstate Chemicals Clearinghouse – Alternatives http://theic2.org/article/download-pdf/file_name/IC2_AA_Guide_Version_1.0.pdf

Assessment Guide Version 1.0 – collection of
alternative assessment guides
2.6.2 A Framework to Guide Selection of Chemical https://download.nap.edu/login.php?record_id=18872&page=http%3A%2F%2Fww

Alternatives – 13 step framework to support decision w.nap.edu%2Fdownload.php%3Frecord_id%3D18872
making about alternatives to chemicals of concern.
3.5 An Employer’s Guide to Developing an Employee http://www.dli.mn.gov/OSHA/PDF/ertk_gi.pdf

Right-to-Know Program – basic steps in developing a
training program
3.5.1 International Chemical Control Toolkit – list of http://www.ilo.org/legacy/english/protection/safework/ctrl_banding/toolkit/icct/sh

guidance sheets on various exposures eets.htm
3.5.2 Accessing SDSs for chemicals http://www.ghs-msds.com/ghs-msds/format-and-sections-of-the-ghs-sds/

http://msdssearchengine.com/engine/search.php?query=red+27&search=1
3.5.3 Easy-to-use workplace control scheme for hazardous http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/workplace-

substances – practical guide for small and medium size control-scheme.pdf?__blob=publicationFile
businesses
3.5.4 Chemical Storage Guidelines from the CDC – guidelines http://www.ehso.com/ChemicalStorageGuidelines.htm

for safe chemical storage

CMS RESOURCES

3.5.6 Globally Harmonized System of Classification and http://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev05/English/

Labelling of Chemicals (GHS) ST-SG-AC10-30-Rev5e.pdf
3.6 Emergency Response Plan Template http://www.fema.gov/media-library-data/1388775706419-

f977cdebbefcd545dfc7808c3e9385fc/Business_EmergencyResponsePlans_10pg_20
14.pdf
4.1 SAC Higg Index – sustainability tools http://www.apparelcoalition.org/higgindex/
4.2 The Internal Auditing Pocket Guide – prepare, http://asq.org/quality-press/display-item/index.html?item=H1300

perform, report and follow up of internal audits
4.4.2 ZDHC Audit – Tool 8 CAPA Worksheet Template – http://www.roadmaptozero.com/programme-documents.php

factory tool for corrective actions
Progressive
2.4.1 Chemical Agent Risk Assessment Sheet – template http://www2.ul.ie/web/WWW/Faculties/Science_%26_Engineering/Departments/C

hemical_%26_Environmental_Science/Resources/Chemical%20Risk%20Assessment
%20Template
2.5.2.4 AAFA – Voluntary Product Environmental Profile - a https://www.wewear.org/assets/1/7/AAFA_VPEP_12-20-12_final.pdf

supplier disclosure form that allows suppliers and
buyers to easily exchange vital information on the
chemical makeup of products and the environmental
impact of apparel and textile products and processes.
2.5.1 The Lean and Chemicals Toolkit – addressing chemical http://www.epa.gov/lean/environment/toolkits/chemicals/index.htm

use and waste via Lean strategies
2.4.3 NIOSH Pocket Guide to Chemical Hazards – source of http://www.cdc.gov/niosh/docs/2005-149/pdfs/2005-149.pdf

general industrial hygiene information on industry
chemicals.
4.2 International Standards for the Professional Practice of https://na.theiia.org/standards-guidance/mandatory-

Internal Auditing – multiple language versions guidance/Pages/Standards.aspx
available.

CMS RESOURCES

Aspirational
2.4.3 Guidance for creating Job Safety Analysis http://www.ccohs.ca/oshanswers/hsprograms/job-haz.htm and

https://www.osha.gov/Publications/osha3071.pdf.
2.6.2 Guide on Sustainable Chemicals – a guide that can be http://www.umweltbundesamt.de/en/publikationen/guide-on-sustainable-

applied by enterprises for the selection of substances chemicals
and mixtures.
2.6.2 OECD Substitution and Alternatives Assessment http://www.oecdsaatoolbox.org/

Toolbox — a compilation of resources relevant to
chemical substitution and alternatives assessments
4.1.1 Life Cycle Metrics for Chemical Products – guideline http://www.wbcsd.org/Pages/EDocument/EDocumentDetails.aspx?ID=16329

for chemical sector to assess and report on
environmental footprint of products
BEST Practices International Finance Corporation: Environmental, http://www.ifc.org/wps/wcm/connect/2a66470048865981b96efb6a6515bb18/Fina

Health, and Safety Guidelines for Textile l%2B-%2BTextiles%2BManufacturing.pdf?MOD=AJPERES&id=1323162617789
Manufacturing
Environmental Standard in the Textile and Shoe Sector http://www.umweltbundesamt.de/sites/default/files/medien/publikation/long/428

– Best Available Techniques Reference Document 9.pdf
Global Social Compliance Programme – Environmental http://gscpnet.com/gscpfiles/GSCP_Environmental_Reference_Requirements.pdf

Reference Requirements: provides a common
understanding of good environmental practice.
Profile of the Textile Industry – EPA 1997 – general http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebo

industry report with several case studies. oks/textilsn.pdf
Best Management Practices for Pollution Prevention in http://nepis.epa.gov/Exe/ZyNET.exe/30004Q2U.txt?ZyActionD=ZyDocument&Client

the Textile Industry – U.S. EPA: best management of =EPA&Index=1995%20Thru%201999&Docs=&Query=&Time=&EndTime=&SearchM
pollution prevention ethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&Q
FieldDay=&UseQField=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5
CZYFILES%5CINDEX%20DATA%5C95THRU99%5CTXT%5C00000006%5C30004Q2U.tx
t&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C-
&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g1
6/i425&Display=p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&B
ackDesc=Results%20page&MaximumPages=1&ZyEntry=1

CMS RESOURCES

Evaluating the Chemical Footprint of Plastics – a http://www.bizngo.org/sustainable-materials/plastics-scorecard

plastics scorecard
Natural Resources Defense Council’s (NRDC’s) 10 Best http://www.nrdc.org/international/cleanbydesign/files/responsible-sourcing-

Practices for Textile Mills to Save Money and Reduce guide.pdf
Pollution = a practical guide to responsible sourcing
version 2.0 – showcases 22 mills
NRDC Guide to Metering in Textile Mills – overview of http://www.nrdc.org/international/cleanbydesign/files/CBD-Metering-Guide.pdf

metering for water and energy
Reference Document on Best Available Techniques for http://eippcb.jrc.ec.europa.eu/reference/txt.html

Textile Industry – July 2003 – This BREF addresses
installations for the pretreatment (operations such as
washing, bleaching, mercerisation) or dyeing of fibres
or textiles.
Checklist based on best available techniques in the http://www.umweltbundesamt.de/sites/default/files/medien/publikation/long/429

textile industry – Good summary of the BREF – July 5.pdf
2003 (above)
Best Practices in Product Chemicals Management in http://www.greenbiz.com/research/report/2009/12/09/best-practices-product-

the Retail Industry – examples of how retailers are chemicals-management-retail-industry
moving to better chemical practices
Chemical Laboratory Safety and Security – a guide to http://dels.nas.edu/resources/static-assets/bcst/miscellaneous/Chemical-

prudent chemical management Laboratory-Safety-and-Security.pdf
Process Safety Leadership in the Chemicals Industry http://www.cefic.org/Documents/IndustrySupport/CIA%20Process%20Safety%20-

%20Best%20Practice%20Guide.pdf
Guidance for Best Environmental Practices for the http://fluorocouncil.com/PDFs/Guidance-for-Best-Environmental-Practices-BEP-for-

Global Apparel Industry – focus on fluorinated the-Global-Apparel-Industry.pdf
repellent products

SECTION 7
Glossary
alignment agreement
analytics lab reports from air, soil and water chemical testing
audit an inspection or review
best practices processes and procedures exceeding requirements to achieve
best results
brand a trademark or distinctive name identifying a product, service
or organisation
downstream pertains to the latter part of a process or system
framework organisational structure used to manage or create
key performance indicator unit of measure to mark whether or not wanted progress is
being made
law/regulation statements from states and countries requiring adherence to
specific standards and protocols
life cycle from initial creation to final disposition
Manufacturing Restricted Substances list of substances banned from intentional use in processing
List (MRSL)
metrics type of measurement used to gauge some
measurable/quantifiable component of performance
milestone critical project/deliverable/performance date or
accomplishment
prioritisation determining level of importance relative to others
Restricted Substances List (RSL) information related to regulations and laws that restrict or ban
certain chemicals and substances in finished home textile,
apparel and footwear products around the world
retailer the business which sells goods or commodities directly to
consumers
stakeholder individual or organisation with an interest in the outcome or
status
supply chain system of activities, information and resources involved in
moving a product or service from supplier to customer
tier 1 suppliers tier 1 suppliers sell their product directly to major brands
tier 2 suppliers tier 2 suppliers sell their product to a company that then sells
product directly to the major corporation
training providing knowledge to improve competency and overall
capabilities
zero discharge of hazardous chemicals non-detectable limit based on best available testing capability
ZDHC MRSL compliance formulations list of chemicals/chemical formulas that comply with the
facility’s MRSL/RSL

Appendix A
Assessing Status
What Chemical Management Means in Practical Terms – Foundational Level
For the Retailer/Brand:
Assessment YES NO Remarks
Do you have written statements from your company’s senior level

leadership that clearly communicate goals and aspirations around
Corporate Social Responsibility and that also include chemical
management?
Does your company publish a RSL/MRSL or do you reference existing,
publicly available documents?
Do you have a process to regularly implement updates and changes
for:
a. Applicable chemical use regulations?
b. Your MRSL/RSL at least annually?
Does your company offer RSL education and training to your
employees and your suppliers?
Does your company have a named point of contact for chemical
management (this includes activities related to process chemicals and
products used, chemical hazard [assessment], chemical safety and
risk management, MRSL/RSL compliance, safer alternatives and
sustainable chemistry) and have you shared that name with your
supply chain partners?
Has your company’s chemical management point of contact
documented the names and addresses of his/her counterparts at all
your final product suppliers?
Does your company know and document all manufacturing locations
of your final product suppliers?
Does your company require – by contract –all of your suppliers to
comply with regulatory requirements in the legal jurisdictions where
you operate and where you sell your final product?
Does your company have an occupational and environmental health
and safety programme with documented procedures to protect
workers, the community and the environment (including
communicating the chemical hazards and training on how to safely
handle, use and dispose of chemicals that are used)?
Does your company require your suppliers to have an occupational
and environmental, health and safety programme with documented
procedures to protect workers, the community and the environment
(including communicating the chemical hazards and training on how
to safely handle, use and dispose of chemicals that are used)?
Has your company implemented a process to communicate to your
suppliers the desire to know more about chemicals used in
manufacturing processes and/or residing in:
a. The final product?
b. Select product(s) on which to gather data?
Do you engage with other communities of practice to share
information and knowledge about chemical management,
sustainable chemistry, business management systems, continuous
improvement and public reporting best practices?
Does your senior level management support the integration of
chemical management into voluntary sustainability initiatives and
trade association practices and do you use chemical management as
an internal benchmarking tool?
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-1

What Chemical Management Means in Practical Terms – Foundational Level
For the Supplier:
Does your facility have written statements from the senior level
leadership of your company clearly communicating the
organisation’s goals and aspirations around Corporate Social
Responsibility?
Does your facility have a named point of contact for chemical

management (this includes activities related to process chemicals
and products used, chemical hazard [assessment], chemical safety
and risk management, MRSL/RSL compliance, safer alternatives and
sustainable chemistry) and have you shared that contact name with
your supply chain partners?
Has your facility’s chemicals management point of contact

documented the names and addresses of his/her counterparts for:
a. All of your chemical suppliers?
b. All of your brand/retail customers?
Does your facility have a purchasing policy for chemicals (list of

approved chemicals that are allowed on site)? Does your
procurement department know what it can and cannot order?
Does your facility have a documented inventory of chemicals

purchased (including your supplier’s manufacturing locations),
stored (including their location) and used at your facility?
Does your facility maintain an archive of current SDS of all currently

stored and used chemicals (in English and the local language in the
GHS format)?
Does your facility maintain a database that includes the functional

use of chemicals at your facility?
Are you able to verify that your facility only utilises chemicals that
are in compliance with:
a. Regulations where your products are manufactured and sold?
b. Your customer’s MRSL/RSL?
c. Contract obligations?
Do you have a process to regularly implement updates and changes

for:
a. Applicable chemical use regulations?
b. Retailer/brand RSLs?
Does your facility have a communication process to timely respond

to information requests related to chemicals used at your facility
and potentially present in your products from:
a. Brands/retailers
b. Suppliers?
Do representatives from your facility participate in RSL/MRSL

education and training opportunities provided by brands/retailers?
Does your facility have an occupational and environmental health

and safety programme with documented procedures to protect
workers, the community and the environment (including
communicating the chemical hazards and training on how to safely
handle, use and dispose of chemicals that are used)?

Does your facility require your chemical suppliers to have an

occupational and environmental, health and safety programme with
documented procedures to protect workers, the community and the
environment (including communicating the chemical hazards and
training on how to safely handle, use and dispose of chemicals that
are used)?
Do you engage with other communities of practice to share

information and knowledge about chemical management,
sustainable chemistry, business management systems, continuous
improvement and public reporting best practices?
Does your senior level management support the integration of

chemical management into voluntary sustainability initiatives and
trade association practices and do you use chemical management as
an internal benchmarking tool?

What Chemical Management Means in Practical Terms – Progressive Level
Have you completed the Foundational Level assessment and

answered all (most?) questions with YES?
Can you verify that you have a business process to ensure

compliance (including to monitor and verify) with your RSL/MRSL
and do you have a process to implement corrective actions in case
of non-compliance?
Can you verify that you have an established procurement process

that makes MRSL/RSL compliance part of contractual obligations
with all your suppliers?
Can you verify that all chemicals in use and products you
manufacture are in compliance with the most stringent global
regulatory requirements?
Do you monitor and can you verify that all your suppliers meet
their contractual obligation to comply with final product regulatory
requirements?
Do you have an established business process to report chemicals in

products to meet regulatory requirements to certify, label and
report “chemicals in consumer products” (e.g., CA Prop 65, US
CPSIA, State of Washington’s Children’s Safe Products Act)?
Does your company build/maintain a Bill of Chemical Substances

used in manufacturing and/or residing in the final product to verify
compliance and to identify opportunities for substitution?
Do you collaborate with your suppliers to share the Bill of Chemical

Substances (directly or via a third party) with your other suppliers
and retail customers?
Do you collaborate with all of your suppliers to maintain a list of

chemicals present in your final products?
Can you verify that you follow a process in which you regularly
review the chemicals used in processes, and/or that can be found
in your products, against published lists to identify chemicals of
concern [e.g., REACH Substance of Very High concern (SVHC),
California Department of Toxic Substances Control DTSC)]?
Does your company go beyond compliance with regulations and

MRSLs/RSLs and has it implemented further restrictions on
chemicals in use or chemicals in products? Do you have a
documented business process for this?
Have you provided your supplier with consumer use information

for your products, including (un)intended use and disposal? Have
you asked your retailer for this information?
Do you follow a process in which you collaborate with your

suppliers to use chemical hazard assessment data to assess the
potential risk of relevant human (i.e., worker, community and
consumer) exposure through the product life cycle before you use
a certain chemical (i.e., in the product design and development
phase)?
Do you follow a process in which you collaborate with your

suppliers to use chemical hazard assessment data to assess the
potential environmental exposure through the product life cycle
before you use a certain chemical (i.e., in the product design and
development phase)?

Do you collaborate with your suppliers and customers to prioritise

and select chemicals from substances of concern and/or restricted
substances lists for alternatives assessment?
Do you collect information on alternatives to selected chemicals

from your suppliers?
Do you work with government agencies and/or advocate for

chemical management framework implementation along supply
chains (this includes advocating for policies and initiatives to know
product and process chemistry, assess hazards or risks of
chemicals, conduct safer alternatives assessments and identify
preferred substances)?
Do you make your alternative assessments (including the resources

you used) publicly available?
Do you promote transparency of sustainable chemistry information

on an equal basis with the performance attributes of the material
you purchase?

What Chemical Management Means in Practical Terms – Progressive Level
For the Supplier:
Have you completed the Foundational Level assessment and answered

all (most?) questions with YES?
Can you verify that all chemicals in use and products you manufacture
are in compliance with the most stringent global regulatory
requirements?
Can you verify that you have an established procurement process that
makes MRSL/RSL compliance part of contractual obligations with all
your chemical suppliers?
Can you verify that your facility is in compliance with all of your
customers’ RSLs and do you have a process to implement corrective
actions in case of non-compliance?
Does your facility go beyond compliance with regulations and RSLs and
has it implemented further restrictions on chemicals in use or
chemicals in products? Do you have a documented business process
for this implementation?
Can you verify that you have a valid Certificate of Analysis for each
chemical you use in your facility?
Does your facility maintain a Bill of Chemical Substances to verify

compliance and to identify opportunities for substitution?
Have you shared the Bill of Chemical Substances (directly or via a third
party) with your customers?
Does your facility maintain a list of chemicals present in your final

products?
Can you verify that you have a process in place in which you regularly
review the chemicals you use in your processes, and/or that can be
found in your products, against published lists to identify chemicals of
concern (e.g., REACH, SVHC, DTSC)?
Have you provided your suppliers and your customers with consumer
use information about your products, including (un)intended use and
disposal?
Do you follow a process in which you use chemical hazard assessment

data to assess the potential risk of relevant human (i.e., worker,
community and consumer) exposure through the product life cycle
before you use a certain chemical?
Do you follow a process in which you use chemical hazard assessment

data to assess the potential environmental exposure through the
product life cycle before you use a certain chemical?
Do you collaborate with your suppliers and customers to prioritise and

select chemicals from substances of concern and/or restricted
substances lists for alternative’s assessment?
Do you provide information on potential safer chemical alternatives to

your customer’s list of prioritised chemical substances?
Do you work with government agencies and/or advocate for chemical

management framework implementation along supply chains (this
includes advocating for policies and initiatives to understand product
and process chemistry, assess hazards or risks of chemicals, conduct
safer alternatives assessments and identify preferred substances)?

Do you make your alternative assessments (including the resources

you used) publicly available?
Do you promote transparency of sustainable chemistry information on

an equal basis with the performance attributes of the material you
purchase and the products you manufacture?

What Chemical Management Means in Practical Terms – Aspirational Level

Have you completed the Progressive Level assessment and

Do you have a business process to fully disclose (upon request to

any interested party) the Bill of Chemical Substances for all your
products, beginning with substances of concern?
Do you have a business process to verify your suppliers are

accurately reporting all chemicals in your products?
Do you have a process that is part of your selection and

procurement decisions that requires from your suppliers a Bill of
Chemical Substances?
Can you verify that you practice a process to assess all chemicals
used to make your products against a defined and transparent set
of human and environmental hazard criteria (e.g., carcinogenic,
mutagenic or toxic for reproduction [CMR], persistent,
bioaccumulative and toxic [PBT], endocrine disruptor [ED]) that
helps to prioritise actions and encourages use of chemicals towards
safer alternatives?
Can you verify that you have a business process that factors hazard
assessments into chemical supplier and procurement decisions?
Can you verify that you have a business process to collaborate with
your supplier to use chemical hazard assessment data combined
with your knowledge of the manufacturing processes to assess the
potential risk of relevant human (worker and consumer) and
environmental exposure routes in your product’s life cycle?
Can you verify that you collaborate with your suppliers to

implement risk management actions as a result of the hazard,
exposure and risk assessments conducted earlier?
Can you verify that you have a business process in place that factors
your supplier’s risk management actions into supplier selection and
procurement decisions?
Can you verify that you have a business process in place to

communicate your alternatives assessment process (including
criteria for identifying preferred substances) to retailers, suppliers
and chemical suppliers?
Can you verify that you have a business process in place to evaluate
alternatives to determine which are most preferable and to decide
on substitutions or other actions and communicate your decision to
your suppliers and chemical suppliers?
Can you verify that you have a business process in place to use
alternatives assessments to develop and maintain a preferred
substances list?
Can you verify that you have a business process in place to verify
your suppliers’ compliance with your preferred substances list?
Do you collaborate with your suppliers to evaluate and document

the impacts of existing and proposed alternatives on the product
life cycle (e.g., water usage, energy usage, wastewater treatment
requirements and disposal) on a functional unit level?

Can you verify that you have a business process in place to:
a. Score the sustainability of the chemicals and intermediates
used to make your products?
b. Give priority to those chemicals scoring higher as more
preferable?
Do you publicly engage in advocacy to encourage programmes to

provide better information about product and process chemistry,
how to assess the hazards and risks of chemicals and how to best
provide information on safer alternatives?
Can you verify that you have a business process in place to reward
suppliers who employ sustainable chemistry in the design and
manufacture of their products?
Can you verify that you have a business process in place to score
materials and intermediate products made with more sustainable
production processes (documented and validated)?
Can you verify that you have business goals, metrics and an audit
programme to document the performance and continuous
improvement of your chemicals management and sustainable
chemistry efforts, including public reporting that communicates
progress?

What Chemical Management Means in Practical Terms – Aspirational Level
For the Supplier:

Have you completed the Progressive Level assessment and

Do you have a business process to verify all chemicals in your

processes and in the products you manufacture?
Do you have a process, that is part of your selection and

procurement decisions, which requires from your suppliers a Bill of
Chemical Substances?
Can you verify that you follow a process to assess all chemicals
used against a defined and transparent set of human and
environmental hazard criteria (e.g., CMR, PBT, ED) that helps to
prioritise actions and encourages use of chemicals towards safer
alternatives?
Can you verify that you have a business process that factors hazard
assessments into chemical supplier and procurement decisions?
Can you verify that you have a business process that uses chemical
hazard assessment data combined with your knowledge of the
manufacturing processes to assess the potential risk of relevant
human (worker and consumer) and environmental exposure
routes in your product’s life cycle?
Do you collaborate with your customers (brands and/or retailers)

and your suppliers to review the results if the chemical hazard
assessment data to jointly identify opportunities for safer
alternatives and to a build a preferred substances list?
Can you verify that you have implemented risk management

actions as a result of the hazard, exposure and risk assessments
conducted?
Can you verify that you have a business process in place that
factors your chemical supplier’s risk management actions into
chemical supplier selection and procurement decisions?

evaluate alternatives (using the alternatives assessment process,
including criteria for identifying preferred substances) in-line with
your customer’s (brand/retailer) expectations?

collaborate with your customers (brands/retailers) and your
chemical suppliers to implement substitutions or other actions
agreed upon from the alternatives assessment?

maintain and implement site-specific lists of preferred substances?
Can you verify that you have a business process in place to verify
the use of preferred substances and compliance from all your
suppliers and communication to your customers
(brands/retailers)?
Do you collaborate with your suppliers and your customers

(brands/retailers) to evaluate and document the impacts of
existing and proposed alternatives on the product life cycle (e.g.,
water usage, energy usage, wastewater treatment requirements
and disposal) at a functional unit level?

Can you verify that you have a business process in place to:
a. Score the sustainability of the chemicals and intermediates
you purchase?
b. Give priority to those scoring higher as more preferable?
Do you proactively share the results of the sustainability scoring

with your customers (brands/retailers) and suppliers?
Do you publicly engage in advocacy to encourage programmes to

provide better information about product and process chemistry,
how to assess the hazards and risks of chemicals and how to best
provide information on safer alternatives?
Can you verify that you have a business process in place to reward
suppliers who employ sustainable chemistry in the design and
manufacture of their products?
Can you verify that you have a business process in place to score
materials and intermediate products made with more sustainable
production processes (documented and validated)?
Can you verify that you have business goals, metrics and an audit
programme to document the performance and continuous
improvement of your chemicals management and sustainable
chemistry efforts, including public reporting that communicates
progress?

Appendix B
Tables
Table 1. Facility Chemical Management Assessment Questionnaire
Conditions Yes No
1. Does your facility have a chemical management plan or system?
2. Does your facility have an individual or team responsible for chemical management or
environmental health and safety?
If so, who?
Do department heads know their responsibilities?
3. Does the facility have an inventory of the hazardous materials used in the facility?
If so, is the inventory electronic or paper? Where is it kept? How often is it updated and by
whom?
4. Are chemicals stored separated by hazard class and compatibility in a uniform storage
system?
Is there sufficient storage area?
5. Has the facility had a comprehensive facility-wide hazardous materials clean out to rid the
business of old, unwanted chemicals? If so, when was the last clean out?
6. Do laboratories have a Chemical Hygiene Plan, if required?
7. Is chemical management or safety training available to staff?

Is Right-To-Know training for all staff handling hazardous materials conducted annually?
8. Does the facility have Safety Data Sheet (SDS) for the hazardous materials used in the
facility?
Where are these sheets kept? Are they current within the last 3 years?
9. Does the facility have a chemical emergency response plan?

Is the staff trained in chemical emergency response?
10. Does the facility have a chemical purchasing policy?

Who is responsible for chemical purchasing?
11. Is the facility properly registered under its applicable generator status of hazardous waste
with the local or regional government?
12. Does the facility have a proper waste management system in place to assure proper
management and disposal of chemicals?
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-1

Table 2: Walkthrough Inspection Sheet
Location: Date: Evaluated by:
General Items to Evaluate 

The types, conditions, quantities and storage locations of chemicals.
Comments:
The types, conditions, quantities and storage locations of hazardous waste.

Comments:
The condition and appropriateness of the chemical storage area, equipment and environmental controls, such as
ventilation systems.
Comments:
Any chemical inventories for these storage areas, the status of these inventories and who maintains them.
Comments:
The location, condition, amount and appropriateness of personal protective equipment (PPE).
Comments:
The location, condition, amount and appropriateness of the emergency response supplies and equipment (e.g.,
fire extinguisher, fire host) for the amount and type of chemicals stored.
Comments:
An effective system in place for chemical emergency response.

Comments:
The location, completeness and availability of Safety Data Sheets (SDSs) in each department using chemicals.
Comments:
Designation of the staff responsible for each of these locations.

Comments:

Table 3: Checklist for Purchasing Chemicals
Purchasing Yes No
1. Chemicals purchased in a manner consistent with the facility's purchasing policy.
2. One person or department designated with the responsibility of purchasing chemicals (i.e., basic
knowledge of chemistry required).
3. Purchasing procedure for personnel in place (e.g., purchase request forms).
4. Chemicals purchased in quantities needed for current year only. Rate of use and shelf life considered in
order to minimise purchase quantity.
5. Chemicals not purchased if hazardous properties exceed business value.
6. Proper storage and ventilation requirements of chemical confirmed/met before purchase.
7. Appropriate means of chemical disposal determined before purchase (i.e., Is disposal as a hazardous waste
required?).
8. Adequate funds for appropriate and legal disposal of the chemical, or its end product, confirmed before
purchase.
9. Required safety precautions associated with chemical known before purchase.
10. Proper protective/safety equipment necessary for chemical on hand before purchase.
11. Environmental impact of chemical considered before purchase, (including manufacturing, use and disposal).
Alternatives considered if warranted.
12. Reagents ordered in polyethylene (PE) bottles or plastic coated glass bottles to minimise breakage,
corrosion and rust.
13. A check is made of the chemical inventories in other locations for duplication or excess.

Table 4: Request to Procure and Use a High Hazard Chemical
Please complete this form and submit it to the Chemical Management Officer (CMO) for review. The
CMO with the assistance of the Chemical Management Committee will make a final determination
about whether the chemical requested may be purchased. An incomplete response will automatically
be denied.
Name Department_____________________________
Name of chemical requested_______________________________________________________
Common name, if any ______________ _____
Is this chemical on the MRSL?  Yes  No
Quantity requested
Name of supplier _____
Purpose of ordering this chemical:
Special handling or storage requirement (list)
Chemical will be used completely by:
 End of current order  End of current year
What type of waste will be produced by this chemical?
 Hazardous waste: amount by volume ___

(to be stored for proper disposal)
 Non-hazardous waste (to be disposed of in trash)
 Non-hazardous waste (to be disposed of down the drain)
Signature: _______________________ CMO Signature (if approved):______________________
Date_____________________ Date_____________________

Appendix C
Chemical Inventory
CHEMICAL INVENTORY
Responsible for Area and Title
Person Completing Inventory and Title
Date Inventory Completed and Reviewed
11 ZDHC
Priority On Catalogue Order
Room Chemical Factory/ZDHC On Brand's Number/Supplier
Department Building # Product name Chemical Name Chemical Supplier CAS # Quantity Units SDS on file? Hazard Class R Phrase Classes MRSL? RSL? Shelf Life Order Number
Use drop
down arrow Use drop down Use drop down Use drop down Use drop down
to select arrow to select arrow to select arrow to select arrow to select
XYZ Chemical
Dye Weigh House #1 12 Hydrochloric acid (37%) Hydrochloric Acid Company 7647-01-0 2 litres YES Class 8 R 35 N/A No No Jun-15 xxx-xx-xx
ABC Chemical
Dyeing #3 - Glauber's salt Sodium sulfate Company 7757-82-6 1000 kg YES Non-hazardous N/A N/A No No Jun-15 xxx-xx-xx
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-1

CHEMICAL INVENTORY INSTRUCTIONS
These are the instructions for completing the Chemical Inventory Form. If you have any questions, please contact: Fill in name.
Step 1: Save the blank Chemical Inventory Form to your computer. It is in Microsoft Excel format.
Step 2: Review the chemicals at each of the locations in your facility. If you have not used a chemical in the past 3 years and do not plan to use it in the future, consider disposing the chemical according to all applicable
regulations.
Chemicals that must be included in the inventory:
• All chemicals with a hazard indication or pictogram on the container label (warning, caution, danger, etc.)
• All chemicals and materials used in laboratories, pilot facilities and other locations such as tool shops
• All compressed gases
• Any flammable paints, solvents, glues, fuels and other petroleum products
• Materials that would create an explosive or toxic vapour hazard to unprotected personnel during fire emergencies (lead, mercury, magnesium, etc.)
Step 3: Complete the columns on the form as outlined below:
Column A - *REQUIRED FIELD* DEPARTMENT: Indicate the name of the department or area that controls the chemical inventory.
Column B - *REQUIRED FIELD* BUILDING: Indicate the building where the chemical is located.
Column C - *OPTIONAL FIELD* ROOM: Indicate the room number where the chemical is located. Do not put a dash (-) between numbers or letters. Example: S106, not S-106. This includes tanks, rail cars, silos and
more.
Note: The three preceding fields can be copied and pasted for the whole inventory.
Colum D - *REQUIRED FIELD* PRODUCT NAME: Indicate the common name listed on the label or packing. If there is a concentration listed or if the substance is anhydrous, please indicate that in this column. Example:
Formaldehyde, 10%.
Column E - *SUGGESTED FIELD* CHEMICAL NAME: Indicate the proper chemical name of the chemical/chemical mixture, if available. Be sure to include any prefixes, (e.g., n-butanol). DO NOT USE abbreviations or
chemical formulas.
Column F - *SUGGESTED FIELD* CHEMICAL SUPPLIER: Indicate the name of the company or supplier that manufactures or sales the chemical listed. If you have more than one supplier for an item, enter names of all
suppliers. If you buy the chemical from the trading company, enter "manufacturer" (if known) also in brackets.
Column G - *REQUIRED FIELD* CAS No.: The Chemical Abstracts Service (CAS) Registry Number may be found for specific chemicals on the chemical container, safety data sheets (SDSs) or at online search sites that are
available below. This information is critical to the effectiveness of the database. Please include dashes in the CAS number. Example: 7768-77-0
Note: Paints, chemical mixtures, and many prepared solutions/cleaners do not have a CAS Number.
Column H - *SUGGESTED FIELD* QUANTITY: Indicate the total amount of the chemical using a numerical value ONLY. Example: 2 and 1/2 litres containers of toluene would be recorded as 2.5 in the QUANTITY column
and litres in the UNITS column. Completion of this section will aid in Environmental Health and Safety assessment.
Column I - *REQUIRED FIELD* UNITS: Indicate liquid chemicals in gallons or litres, solid chemicals in pounds or grams, and gases by indicating the size of the tank.
Column J - *REQUIRED FIELD* SDS On File: Please use drop down arrow: Check your Safety Data Sheet file and ensure that you have an SDS for each chemical that you use. The SDS can be obtained from the chemical
manufacturer or distributor.
Column K - *REQUIRED FIELD* HAZARD CLASS: Please use drop down arrow: Review the label on the container and the SDS. From the choices listed on the spreadsheet, choose the appropriate hazard class(es). If you
cannot determine the correct class, choose “Cannot Be Determined” and submit an SDS for this chemical with your inventory. Hazard classification provides information concerning adverse reactions of the chemical
and proper storage.
Column L - *SUGGESTED FIELD* R-phrases (short form for Risk Phrases): defined in Annex III of the European Union Directive 67/548/EEC: Nature of special risks attributed to dangerous substances and preparations.
Column M - *REQUIRED FIELD* 11 ZDHC priority chemical groups: Please use drop down arrow: If the information is unknown, please consider using the Chemical Inventory Transparency form (separate resource from
brands) to ask your supplier for any missing 11 ZDHC priority chemical group information.
Column N - *REQUIRED FIELD* On Factory/ZDHC Manufacturing Restricted Substances List (MRSL): Compare chemical inventory you have obtained to all MRSLs available. If none available, visit
http://www.roadmaptozero.com/
Column O - *REQUIRED FIELD* On Brand's Restricted Substances List (RSL): Compare inventory you have obtained to all brands'/retailers' RSLs available. If the RSL is not available, contact your customer(s).
Column P - *REQUIRED FIELD* SHELF LIFE: Indicate the expiration date of the chemical by month and/or year for time sensitive chemicals. Leave this field blank for chemicals that are not time sensitive. It is very
important that hazardous chemicals are properly disposed before they become shock sensitive or explosive.
Column Q - *SUGGESTED FIELD* CATALOGUE NUMBER: Indicate the catalogue number for the chemical listed. Chemical suppliers often have unique numbers assigned to the chemicals they sell.
Columns R-U: DO NOT CHANGE - the information here populates the drop down lists.
Step 4: Save the newly updated file.

Glossary
11 priority chemical groups: These are alkylphenol ethoxylates/alkylphenols (APEOs/APs), brominated and chlorinated flame retardants, chlorinated solvents, chlorobenzenes, chlorophenols, heavy metals, organotin
compounds (e.g., TBT), per‐ and polyfluorinated chemicals (PFCs), phthalates (ortho‐phthalates), short‐chain chlorinated paraffins (SCCPs), and azo dyes that may release carcinogenic amines as defined in Annex XVII
of REACH.
11 chemical group: see 11 priority chemical groups.
APEOs: Alkylphenol ethoxylates
NPEO: Nonylphenol ethoxylates
APs: Alkylphenols
Brand: As used in this document, represents the retail members of ZDHC.
CAS: Chemical Abstracts Service (CAS) Registry number.
EH&S: Environmental, Health and Safety
Hazard Class: A chemical material is generally assigned to a class based upon the characteristic that poses the highest degree of danger in transportation.
MRSL: Manufacturing Restricted Substances List - a list of chemicals and substances which are not to be used in customer manufacturing facilities.
Pictogram: in this document, hazard pictograms are one of the key elements for the labelling of containers under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Pilot: In this document, this is a small scale production line(s) which represents a full scale production line(s).
R phrase: R-phrases (short form for Risk Phrases): defined in Annex III of the European Union Directive 67/548/EEC: Nature of special risks attributed to dangerous substances and preparations.
RSL: Restricted Substances List - a list of chemicals and material which have specific limits or restrictions of use in a manufacturing facility or as residuals after processing in a brand’s product.
REACH: REACH is the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals. It entered into force on 1st June 2007. It streamlines and improves the former legislative framework on
chemicals of the European Union (EU).
SDS: Safety Data Sheet; cataloguing information on chemicals, chemical compounds and chemical mixtures. SDS information may include instructions for the safe use and potential hazards associated with a particular
material or product.
Shelf Life: Indicates the expiration date of the chemical by month and/or year for time sensitive chemicals.
Units: in this document, units of measure gallons, litres, kilograms, grams.
ZDHC: Zero Discharge of Hazardous Chemicals - www.roadmaptozero.com

Appendix D
Risk Assessment Template Example
RISK ASSESSMENT TEMPLATE EXAMPLE
2.1.2 Company name: Risk Assessor name:
Date: Click here to enter a date.
Hazard Who Is Risk Controls In Further Priority Action Date Action

Involved (Severity and Place Action By
Likelihood)
Example: 3 process Splashing – PPE only face Consider 1 Immediate Mgt.

Pouring sodium employees skin/eye burns shield and eliminating
hydroxide Very likely and gloves pouring.
solution from extreme harm Restructure
bulk tank process.
Very high risk
*This template is for illustrative purposes only. Competent persons undertaking chemical risk assessments may amend this
template to suit site-specific work activities.
How do you know if the hazard is serious?

Each hazard should be studied to determine its' level of risk:
• Product information/manufacturer documentation
• Past experience (e.g., workers)
• Legislated requirements and/or applicable standards
• Industry codes of practice/best practices
• Health and safety information about the hazard such as safety data sheets (SDSs) or other
manufacturer information
• Information from reputable organisations
• Results of testing (for example, atmospheric, air sampling of workplace, biological)
• The expertise of an occupational health and safety professional
• Information about previous injuries, illnesses, near misses, accident reports, work environment
(for example, layout, condition)
• Capability, skill or experience of workers who do the work
• Systems of work being used
• Range of foreseeable conditions
How do you rank or prioritise the risks?
Ranking or prioritising hazards is one way to help determine which hazard is the most serious and thus
which hazard to control first. Priority is usually established by considering the employee exposure and
the potential for accident, injury or illness. By assigning a priority to the hazards, you are creating a
ranking or an action list. The following factors play an important role:
• Percentage of workforce exposed
• Frequency of exposure
• Degree of harm likely to result from the exposure
• Probability of occurrence
There is no simple or single way to determine the level of risk. Ranking hazards requires the knowledge
of the workplace activities, urgency of situations and, most importantly, objective judgement.
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-1
One option for ranking risk is to use a table similar to the following:
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 High 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
Note: These categorisations and the resulting asymmetry of the matrix arise from the examples of harm and likelihood.
Organisations should adjust the design and size of the matrix to suit their needs.
Definitions for Likelihood of Harm

1. Very Likely – Typically experienced at least once every six months by an individual.
2. Likely – Typically experienced once every five years by an individual.
3. Unlikely – Typically experienced once during the working lifetime of an individual.
4. Very Unlikely – Less than 1 percent chance of being experienced by an individual during their
working lifetime.
Definitions for Severity of Harm
When establishing potential severity of harm, information about the relevant work activity should be
considered, together with (a) part(s) of the body likely to be affected, and (b) nature of the harm,
ranging from slight to extremely harmful.
1. Slightly Harmful – For example, superficial injuries, minor cuts and bruises, eye irritation from dust,
nuisance and irritation and ill-health leading to temporary discomfort.
2. Harmful – For example, lacerations, burns, concussion, serious sprains, minor fractures, deafness,
dermatitis, asthma, work-related upper limb disorders and ill-health.
3. Extremely Harmful – For example, amputations, major fractures, poisonings, multiple injuries, fatal
injuries, occupational cancer, other severely life shortening diseases and acute fatal diseases.
Definition for Risk Level
Guidance on necessary action and time scale:
1. Very Low – These risks are considered acceptable. No further action is necessary other than to
ensure that the controls are maintained.
2. Low – No additional controls are required unless they can be implemented at very low cost (in terms
of time, money and effort). Actions to further reduce these risks are assigned low priority.
Arrangements should be made to ensure that the controls are maintained.
3. Medium – Consideration should be as to whether the risks can be lowered, where applicable, to a
tolerable level and preferably to an acceptable level, but the costs of additional risk reduction
measures should be taken into account. Risk reduction measures should be implemented within a
defined time period. Arrangements should be made to ensure that controls are maintained,
particularly if the risk levels are associated with harmful consequences.
4. High – Substantial efforts should be made to reduce the risk. Risk reduction measures should be
implemented urgently within a defined time period. It might be necessary to consider suspending or
restricting the activity or to apply interim risk control measures until this has been completed.
Considerable resources might have to be allocated to the additional control measures.

Arrangements should be made to ensure that controls are maintained, particularly if the risk levels
are associated with extremely harmful or very harmful consequences.
5. Very High – These risks are unacceptable. Substantial improvements in risk control measures are
necessary so that the risk is reduced to a tolerable or acceptable level. The work activity should be
halted until risk controls are implemented that reduce the risk so that it is no longer very high. If it is
not possible to reduce the risk, the work should remain prohibited.
Example of Hazard Priority Setting
Unlikely - Could Very Unlikely - Could

Very Likely - Could Likely - Could
happen but very happen but probably never
happen at any time happen sometime
rarely will
Kill or cause permanent

1 1 2 3
disability or ill health
Long-term illness or
1 2 3 4
serious injury
Medical attention and

2 3 4 5
several days off work
First aid needed 3 4 5 6

Appendix E
American Apparel and Footwear Association
Environmental Standards
Example environmental standards from the American Apparel and Footwear Association (AAFA):
Air Standards
• All discharges to the air from factories must comply with all permits and applicable laws and
regulations. The factory must use appropriate controls in order to meet the limits and any
controls must be properly operated and maintained.
• Each factory must have in place all current permits and authorisations required by law for the air
discharges. Copies of permits, authorisations and applicable laws, regulations and standards
must be on file at the factory at all times. The factory must maintain compliance with all permits,
authorisations, laws, regulations and standards related to air emissions and activities related to
air emissions.
• Using accepted calculation methodologies, factories must calculate total annual air emissions of
the following pollutants for the entire factory and for each major process, including boilers,
furnaces, drying and curing ovens, and more: nitrogen oxides (NOx), sulfur dioxide (SO2), carbon
monoxide (CO), particulate matter (PM), volatile organic compounds (VOCs) and hazardous air
pollutants (HAPs), as defined by the United States Environmental Protection Agency (US EPA).
Factories must include emissions from fuel usage and from processes. Type and quantities of
fuels used must be summarised and must be kept on file at the factory. All information must be
kept on file at the factory for at least 5 years. The calculation methodology must be available for
review by [Company Name] or its designated auditor.
• Any wastes or effluents from air pollution control equipment must be managed and disposed of
in accordance with applicable rules and regulations.
• Use of chlorofluorocarbons (CFCs) shall be managed as required by the US EPA to ensure proper
operation of refrigeration and heating, ventilating and air conditioning (HVAC) equipment in
order to avoid the release of CFCs to the environment.
• Use of US EPA Class I and Class II as a spot remover is prohibited.
Best Practices
• Open burning of solids wastes is not considered a good practice and should be avoided.
• Factories should calculate total Scope 1 and Scope 2 greenhouse gas (GHG) emissions for the
entire factory, as the terms “Scope 1” and “Scope 2” GHG emissions are defined by the World
Resources Institute’s GHG Protocol.
• Factories should identify opportunities to reduce pollutants and toxic chemicals in air discharges
product selection, product substitution and process modification.
Energy Standards
Management • Factories must have energy usage data available at the factory for the previous 5 full calendar
years. Data must include quantity, heat content and sulfur content information for all fuel types.
Data also must include all electricity use at the factory.
Best Practices
• Factories should develop and implement energy management and conservation procedures for
the factory. The Programme should address the monitoring and review of energy usage, setting
goals and plans for improving energy efficiency and should include provisions for comparing
actual performance against the goals. The Programme should include all processes, lighting,
compressed air systems, heating, ventilation, and air conditioning systems as well as fuel usage
in combustion equipment.
Hazardous Standards
Materials
• Handling, storage and transportation of all hazardous materials at each factory must comply
with all permits and applicable laws and regulations.
• Safety Data Sheets (SDSs) must be on file at the factory for each and every dye, chemical and
chemical product used and stored at the factory. The SDSs must be available for review by all
employees at the factory.
• Factories must have in place procedures to safely receive and handle hazardous materials that
are delivered to the factory.
• Factories must provide physical, chemical and environmental hazard information to transporters
for any hazardous materials transported from the factory.
• Factories must have in place appropriate and adequate spill response equipment and
procedures, in order that any hazardous material spills or releases can be safely and adequately
responded to in a timely manner.
JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-1

• Factories must operate aboveground storage tank (AST) and underground storage tank (UST)
systems in a manner that minimises the risk for impact to the environment. Each factory must
maintain a current list of all ASTs and USTs, including size, contents, location and secondary
containment method used. Each AST and UST must be inspected regularly for integrity and for
evidence of leaks. Procedures must be in place for the inspection of any collected precipitation
in containment areas prior to discharge. Records of any spills or leaks, including corrective action
taken, must be kept on file at the factory for 5 years.
• Factories must have in place procedures for safe filling of USTs, ASTs and other containers. The
procedures must include best practices for preventing and responding to leaks and spills.
• Regular training must be provided to employees covering all of the standards in this section and
records of the training must be maintained for 5 years.
• Establish a system to properly notify third-party emergency response organisations of chemicals
stored on site for planning purposes.
Best Practices
• Secondary containment should be provided for all ASTs and other hazardous material containers
in order to minimise the chance of a spill from reaching the environment.
Waste and Standards

Sludge • Handling and disposal of solid and hazardous waste generated by each factory must comply with
all permits and applicable laws and regulations.
• Factories must quantify and maintain records of the amounts and types of all solid and
hazardous wastes generated for the entire factory, including ultimate disposal method for each
waste. The records must include all hazardous wastes, as the term “hazardous waste” is defined
by US EPA. The records must also include used oil, light tubes, PCB’s, used batteries and other
special wastes. Records must be maintained for the previous 5 calendar years.
• Factories must quantify and maintain records of the amounts and types of all materials that are
recycled or reused, including fabric waste, yarn waste, cardboard, paper, scrap metal, wood, etc.
The records must include the name and location of the company that is accepting the material
for recycling or reuse. Records must be maintained for the previous 2 calendar years.
• Hazardous wastes, solids wastes, recyclable materials and special wastes can only be shipped to
permitted, authorised facilities for treatment, disposal or other processing. Factories must have
detailed information on file at the factory describing the fate of all wastes and recyclable
material once the wastes and recyclable material leave the factory, all the way to final disposal
or reclamation point. Factories must ensure that transporters and treatment and disposal
facilities are properly authorised and permitted to accept the waste or recyclable material and
evidence of this must be kept on file at the factory for each waste or recyclable material.
• Factories must maintain good housekeeping in all solid and hazardous waste collection and
storage areas, such that the risk for impact to the environment from the wastes is minimised.
Hazardous waste must be stored so as to prevent or control accident releases to the air, soil or
water resources. Secondary containment must be provided for all hazardous waste storage
areas. All hazardous waste containers must be properly labelled.
• Hazardous waste and solid waste storage and handling areas must be inspected regularly in
order to detect potential leaks, releases or other problems.
Best Practices
• Factories should develop and implement waste minimisation and source reduction procedures in
order to minimise the amount of solid and hazardous waste generated by the factory.
Wastewater Standards
• All discharges from factories must meet limits prescribed by permits and applicable laws and
regulations, whichever is more protective. This standard includes land application of effluents.
• All wastewater and sewage discharges from factories must be properly treated on-site before
being discharged to a receiving stream, or must be discharged under proper authorisation to an
off-site public or private wastewater treatment facility that is operating according to its required
permit, for proper treatment. Untreated wastewater or sewage discharges to the environment
are prohibited.
• Each factory must have all current permits and authorisations required by law for the discharges.
Copies of permits, authorisations and applicable laws, regulations and standards must be on file
at the factory at all times.

• If septic systems are used for the disposal of domestic sewage, the factory must ensure that the
septic systems are properly designed and installed, are well maintained and are installed in areas
with sufficient soil percolation and stability. Industrial wastewater disposal through septic
systems is prohibited.
• Biosolids generated at factories must be handled and managed in a manner than minimises
environmental impact and must be either disposed of or reused under proper permits and
authorisations.
• Testing of wastewater and effluent discharges must be performed by capable and properly
certified laboratories. Testing results and other operational information must be kept on file at
the factory for 5 years.
• Factories must implement best management practices in order to minimise the exposure of
pollutants to precipitation. Employees must receive regular training on the best management
practices.
Best Practices
• Factories should develop a water balance across the factory in order to ensure that all
wastewater and sewage is being captured and treated to the Recommended Effluent Standards.
• Factories should develop and implement a programme designed to maximise the water use
efficiency at the factory.
• Factories should identify opportunities to reduce pollutant loading and toxic chemical loading in
discharges by recycling and reuse, product selection, product substitution and process
modification. Use the American Apparel and Footwear Association Restricted Substances List
(AAFA – RSL) as guidance.

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CHEMICAL

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY III

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY IV

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY V

SDS safety data sheet(s)

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY VI

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-1

ZDHC CMS Goals

Engagement with ZDHC Stakeholders

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-2

Structure of the CMS Manual

Organisational skill symbols used in this manual:

Foundational Foundational (beginning) chemical management

Progressive (started but with room to grow) chemical

Aspirational Aspirational (advanced) chemical management

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-3

1.1 Management Statement

1.2 Scope of CMS

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 1-1

Assessment, Planning and Prioritisation

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-1

2.1.3 Chemical Material Flow Diagrams (Element 2.1.2)

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-2

2.1.4.1 Chemicals in Process

Input = Output + Accumulation

Input + Generation = Output + Accumulation + Consumption

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-3

2.1.4.2 Chemicals in Final Products

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-4

2.1.4.4 Chemical Waste

2.2 Regulatory Assessment ZDHC Audit Questions

Source: GIZ, 2014

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-5

2.2.2 Verification of Compliance ZDHC Audit Questions

Steps to Developing a Chemical Purchasing Policy

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-6

2.3.1 Chemical Purchasing Policy Considerations

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-7

• For each chemical used, ask the following questions:

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-8

2.3.3 Supplier Approval/Removal Process

2.4 Chemical Risk Assessment

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-9

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-10

Creating a Waste Action Plan

2.4.3 Health and Safety

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-11

Ensure Good Personal Hygiene Properly Use and Maintain PPE

2.5 Chemicals and Processes of Concern

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-12

2.5.2 RSL and MRSL Process

2.5.2.2 RSL and MRSL Update and ZDHC Audit Questions

2.5.2.3 Integration with Contracts of Suppliers

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-13

2.5.2.5 Going Beyond Regulatory

2.6 Performance Goals and Action Plans

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-14

3.1 Organisational Structure

Reports to senior leadership

Systematically monitors applicable regulations on a regular schedule for each applicable

Responsible for process and product chemical knowledge

Responsible for activities related to chemical hazard assessment

Responsible for activities related to safer alternative assessment and communicating

JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-1