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2015 CHEMICAL 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 1.11 Requirements 1-1 1.2 Scope of CMS. 1-1 1.21 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 2.11 Purpose 2-1 2.12 Facility Plan and Walk Through 2-1 2.13 Chemical Material Flow Diagrams (Element 212) 2-2 2.14 Creating a Comprehensive Chemical List 2-2 2.2 Regulatory Assessment . 2-5 2.21 Monitoring Regulations and Permits 2-5 2.22 Verification of Compliance 2-6 2.3 Procurement/Supplier

Practices . 2-6 2.31 Chemical Purchasing Policy Considerations 2-7 2.32 Identify Chemical suppliers 2-8 2.33 Supplier Approval/Removal Process 2-9 2.4 Chemical Risk Assessment. 2-9 2.41 Hazard and Risk Assessment 2-9 2.42 Environmental 2-10 2.43 Health and Safety 2-11 2.5 Chemicals and Processes of Concern . 2-12 2.51 Identify Gaps and Losses in Current Processes 2-12 2.52 RSL and MRSL Process 2-13 2.6 Performance Goals and Action Plans . 2-14 2.61 MRSL Compliant Formulations 2-14 2.62 Alternatives Assessment 2-14 3 Chemicals Management . 3-1 3.1 Organisational Structure . 3-1 3.11 Roles and Responsibilities 3-1 3.12 Communication 3-2 3.2 Training . 3-2 3.21 Management 3-2 3.22 Regulatory 3-2 3.23 Work Practices 3-2 3.24 ZDHC Training 3-3 3.3 Document Development . 3-3 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY III CONTENTS, CONTINUED Section 3.4 3.5 3.6 Page Document and Record Control. 3-3 Chemical Management Work Practices . 3-4 3.51

Exposure Control Measures 3-4 3.52 Safety Data Sheet Management 3-5 3.53 Chemical Handling 3-6 3.54 Chemical Storage 3-6 3.55 Chemical Transportation 3-6 3.56 Chemical Labelling 3-7 3.57 Chemical Use – Regular and Optimisation 3-7 3.58 Personal Protective Equipment 3-7 3.59 Laboratory Practices 3-8 3.510 Maintenance and Housekeeping 3-8 3.511 Waste and Disposal 3-9 Emergency Procedures. 3-9 4 Monitor . 4-1 4.1 Monitor and Measurement (Continuous Improvement) . 4-1 4.11 Goal Progress 4-1 4.12 Regulatory Compliance 4-1 4.13 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 4.41 Change Management 4-2 4.42 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 B C D E Assessing Status Tables Chemical Inventory Risk

Assessment Template Example 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 organisations 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 organisations 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-2 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 JUNE 2015 Organisational Skill Skill Definition Foundational Foundational (beginning) chemical management Progressive Progressive (started but with room to grow) chemical management Aspirational Aspirational (advanced) chemical management LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY INTRO-3 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 1.11 Requirements Expected CMS Deliverable: Management Policy Statement Management statements are written endorsements from senior leadership that clearly communicate goals and aspirations regarding chemical management. The goal of management statements is to clearly communicate those organisational goals to internal and external stakeholders.

Organisations adopting CMS should draft a management statement that: ZDHC Audit Question Is there a policy for monitoring and controlling banned and restricted substances that is applied to all chemicals used at the facility? (CRS 1.11) 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 and continually improve the CMS effectiveness 6. Is appropriate to the organisation’s purpose 7. Is reviewed for continuing suitability An organisation participating in the process of adopting an ISO standard (such as 9000 or 14000) or that already has made a commitment to attain one of these levels of excellence is typically required to develop a management statement. This statement can be expanded to become a CMS policy statement that is appropriate to

its operations. 1.2 Scope of CMS 1.21 ZDHC Audit Question Does the facility have a third-party certified system, relevant to any element of a chemicals management programme, to improve their environmental performance? (CRS 1.31) Does your facility have current certification for ISO 14000? Does the facility’s management statement address chemical management? 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 1.12) 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 2.11 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 2.11, 212, and 213 take a stepwise approach in reviewing and documenting chemicals in an organisation. 2.12 Facility Plan and Walk Through 2.121 Requirements Expected CMS Deliverable: Factory Plan ZDHC Audit Question Does the facility have an up-to-date chemical inventory (on paper, electronic)? (CRS 1.13) 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 − Chemical storage areas − Non-chemical storage areas 3. Process areas 4.

Manufacturing areas 5. Waste storage areas − Chemical waste storage areas − Wastewater storage − Non-chemical waste storage areas 6. Other areas with chemicals, such as laboratories and maintenance areas ZDHC Audit Question Does the facility have basic documentation for the production and chemical operations performance in the facility? (CRS 1.15) Are closed loop (circular) cooling/heating lines identified on industrial piping drawings? (CRS 1.18) Are discharge pipes shown on the facility map? (CRS 1.19) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-1 ASSESSMENT, PLANNING AND PRIORITISATION 2.13 Chemical Material Flow Diagrams (Element 2.12) 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 indicate storage and transfer activities. Flow streams can be further refined as you gather additional information, for example, by breaking down raw materials into more specific categories such as raw materials, chemical groups or individual substances and auxiliary material. To determine if your flow chart contains all relevant information, ask yourself the following questions: • Can/do you recognise the sources of your nonproduct outputs? • Have all important inputs in each production process been considered? • Have all intermediary products been identified? • Have you been able to quantify inputs and outputs? • Can you clearly assign costs to the different wastes? • Are there information gaps, for which you may need to collect further information? Chemical material flow diagrams should be reviewed annually and updated as needed

due to operational changes. The GIZ Practical Chemical Management Toolkit has example material flow diagrams in their Company Handbook Module 1. 2.14 Creating a Comprehensive Chemical List Expected CMS Deliverable: Chemical Inventory ZDHC Audit Questions Does the facility have a flow diagram of the production processes to identify hazardous chemical release points? (CRS 1.23) Does the facility regularly conduct verification of the process flow(s)? (CRS 1.24) Does the verification include following the flow of chemicals through purchasing steps? (CRS 1.24a) Does the verification include following the flow of chemicals through receiving? (CRS 1.24b) Does the verification include following the flow of chemicals through storage? (CRS 1.24c) Does the verification include following the flow of chemicals through dispensing? (CRS 1.24d) Does the verification include following the flow of chemicals through processing/production? (CRS 1.24e) Does the verification include following the flow

of chemicals through disposal? (CRS 1.24f) Is there a corrective action procedure(s) when inefficiencies /inaccuracies are identified during process flow reviews or are they updated on a planned schedule or as needed? (CRS 1.24g) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-2 ASSESSMENT, PLANNING AND PRIORITISATION 2.141 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 Does the facility record quantities of should be available where chemicals are used. chemical products used for each work Instructions can be in the form of recipe cards, process order/production order? (CRS 1.16) adjustment instructions or formulation sheets and Does the facility regularly identify the should describe major operations and the chemicals quantity of chemicals lost due to accidents and quantities that may be required for those (e.g, spillages, poor labelling, accidental processes. mixtures)? (CRS 1.110) 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 2.1411 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 1.26) production processes (e.g, such as cleaning equipment). JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-3 ASSESSMENT, PLANNING AND PRIORITISATION 2.142 Chemicals in Final Products Expected CMS Deliverable: Factory MRSL and RSL in addition to a compliant chemical inventory to the MRSL and RSL ZDHC Audit Questions Is there a policy for monitoring and controlling banned and

restricted substances that is applied to all chemicals used at the facility? (CRS 1.11) Final products must conform to industry and government regulations. These are typically 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 1.112) during manufacturing and related processes, not just Does the facility require its suppliers to those substances that could be present in finished follow a MRSL/RSL? (CRC 1.11) 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. 2.143 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 Source: GIZ, 2014 employees, local 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-4 ASSESSMENT, PLANNING AND PRIORITISATION 2.144 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 2.21 Monitoring Regulations and Permits Expected CMS Deliverables: Regulatory Monitoring SOP and Legal Requirement Permits Inventory Establish, document and implement a process for identifying and monitoring regulations applicable to chemical management permits. The process for identifying and monitoring regulations applicable to chemical management should: 1. State the applicable regulatory jurisdictions, regulations and permits necessary to operate (e.g, city,

state/province, country) 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. 4. Describe how management will be informed of significant regulatory changes and/or when permit constraints or operational limits are being approached. ZDHC Audit Questions Are there SOPs that cover chemical management, such as an approved chemical list, chemical classification system, safe chemical handling procedures or chemical disposal? (CRS 1.12) Does the facility have programmes in place to phase out the intentional use of the 11 priority chemical groups, as defined by the ZDHC Group, with clear target dates? (CRC 1.12) Are permits required for the collection, transportation, storage and disposal of all wastes such as chemical, chemical hazardous waste and recycled wastes? (CRR 1.13) ZDHC Audit Questions Does the facility have a system of tracking changes in

laws and regulations governing environmental management and reporting to management? (EPP 1.11) Is there a process for monitoring the validity of the permits required for their facility? (EPP 1.12)I The process should result in regulatory monitoring and legal inventory (regulations and permits) standard operating procedures (SOPs) that are updated at least annually. Source: GIZ, 2014 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-5 ASSESSMENT, PLANNING AND PRIORITISATION 2.22 Verification of Compliance Expected CMS Deliverable: Senior Management Compliance Report and Internal Audit (CMS Element 4.2) Develop, document and implement a process for reviewing regulations and verifying compliance during implementation and maintenance of the CMS. Compliance verification could be part of the audit process in CMS Element 4.2 Documents and records must be maintained that indicate how verification was conducted and the compliance results. These documents and records

should be maintained according to local regulations or a minimum of 3 years. 2.3 Procurement/Supplier Practices ZDHC Audit Questions Is there a process that verifies that all chemicals used in manufacturing the product(s) meet applicable permit requirements? (CRR 1.11) In the past 3 years, has the facility received an official notice or prosecution for non-compliance with respect to environmental legislation or regulation? (CRR 1.12) If the facility has U.S or EU customers, is a process in place to comply with the USA Consumer Product Safety Improvement Act (CPSIA) legislation and EU General Product Safety Directive (GPSD)? (CRR 1.15) Does the facility have procedures in place to comply with Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations? (CRR 1.16) Does your facility have a purchasing and disposal policy for chemicals? Do you know what you can and cannot 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-6 ASSESSMENT, PLANNING AND PRIORITISATION 2.31 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 times the original purchase price. The real cost of chemicals should be regarded as the initial purchase price plus any ultimate disposal costs. Disposal costs often offset savings from buying in quantity. 3. Consider handling and disposal requirements: If the facility does not have adequate storage and safety provisions for a chemical, its purchase should be discouraged. Try to use non-hazardous chemicals or those that are suitable for reuse. 4. Reduce expired stock: Negotiate expiration dates of chemicals with suppliers based on their intended use. Order reagents in amounts needed and stock smaller containers of chemicals. This helps prevent waste due to surplus or shelf-life expiration. 5. Use older stock first: Rotate chemical stocks to avoid expiration of their shelf life. Note expiration dates. Use a first in, first out policy to keep chemicals from becoming outdated. 6. Avoid chemical donations: Do not accept donated

chemicals or free samples unless they meet a specific need. These can become a future waste disposal problem. Create a policy for acceptance of donations. Before ordering chemicals, staff and other personnel should: ZDHC Audit Questions Is there a procedure on how to select and purchase chemicals? (CRP 1.11) Are chemicals purchased against a specification? (CRP 1.12) Are chemicals sampled and tested when received for approval against specifications? (CRP 1.13) Do large quantity deliveries have additional controls to assure chemical purity and freedom from contamination/substitution prior to off-loading to storage? (CRP 1.14) Is there a written contract or agreement established, mutually confirmed and controlled between the factory and its contractors/subcontractors covering subcontracted activities? (CRP 1.16) Are subcontracted activities identified and monitored?(CRP 1.17) Does the organisation document receipt of purchased chemicals? (CMD 2.15) Has the organisation documented and

implemented procedures to ensure that the identification of raw chemicals includes appropriate labelling, supplier name, receipt tracking information, matching supplier documentation and quantity tracking? (CMD 2.19) • 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 nonessential chemicals. • Develop a current inventory of existing chemicals. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-7 ASSESSMENT, PLANNING AND PRIORITISATION • 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. ZDHC Audit Questions 2.32 Identify Chemical suppliers Expected CMS Deliverable: Chemical Inventory with Chemical Suppliers Identify and document suppliers for each of the chemicals listed in the Chemical Inventory. For urgent technical support or other emergencies, identify each supplier and document their relevant contact information such as point-of-contact name, phone number and address. JUNE 2015 Does the facility have signed and dated declarations from their dye and chemical suppliers confirming that the formulations supplied to the facility are compliant with the relevant retailers or the facilitys own RSL and/or MRSL? (CRP 1.15) Does the facility require its suppliers to follow a MRSL/RSL? (CRC 1.11) Does the facility actively monitor RSL/REACH supplier certificates and track against their inventory? (CRG 1.11) LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-8 ASSESSMENT, PLANNING AND PRIORITISATION

2.33 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 2.52 RSL and MRSL Process (CMS Element 252) The ZDHC MRSL can be accessed at the ZDHC web site publications page. 2.4 Chemical Risk Assessment 2.41 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, a number of key questions need to be asked: • Has the local supplier provided a proper SDS with relevant information? ─ • To what substances are workers exposed? − • • Use the chemical inventory to consider all persons who may have contact or exposure. What harm can the chemical cause? − • If not provided, contact the supplier for assistance. Chemical information can be found on packaging labels, from SDS, your chemical supplier, a specialist in your

factory or the internet. ZDHC Audit Questions Is the facility able to demonstrate knowledge of VOCs? (CRS 1.112) Are hazardous chemicals categorised by their GHS classification as shown on its label and/or SDS? (CRR 1.14) Has a chemical risk assessment of all the chemicals used on the facility been undertaken and available? (CRA 1.11) Have worker exposure routes or possible releases been identified for the facilities chemical list? (CRA 1.12) Does the facility use or produce highly sensitising or toxic substances during its processes? (CMW 2.17) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL

RESPONSIBILITY 2-9 ASSESSMENT, PLANNING AND PRIORITISATION 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 21 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. 2.42 ZDHC Audit Questions Environmental Expected CMS Deliverable: Process/Plan for Reducing Environmental Impacts Has the organisation established procedures to ensure that all wastes are collected and handled in a timely and environmentally responsible manner and in accordance with any applicable legal/regulatory requirements? (CMD 2.114) Establish, document and implement a process for identifying and controlling the potential environmental impacts from use of their chemical inventory. For each of the below areas, the organisation should identify Do maintenance shops, laboratory and other ancillary spaces practice proper environmental roles and responsibilities, where wastes chemical waste disposal? (CMW 2.112) or discharges occur, appropriate control mechanisms 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 Soil Groundwater JUNE 2015 • • • Noise and nuisance Waste and sludge Wastewater LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-10 ASSESSMENT, PLANNING AND PRIORITISATION 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 2.43 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 safety impact from chemicals stored, used and discarded at your site. The chemical inventory previously developed (Section 2.14) should be supplemented with this information. ZDHC Audit Questions Does the facility have and maintain PPE, safety showers, laboratory/factory eye wash bottles or stations,

fire extinguishers, and more that are appropriate for the chemical hazards identified? (CMW 2.14) 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 2.15) 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 2.33) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-11 ASSESSMENT, PLANNING AND PRIORITISATION Ensure Good Personal Hygiene

• • • • • • Provide suitable eating and smoking areas Provide washing facilities near the work areas where skin exposure may occur Advise workers to remove splashes/spills on skin immediately Advise workers to thoroughly wash exposed parts of the body after work is completed Prevent contaminated items from being moved around the facility Remove and wash separately any contaminated item of work clothing after using chemicals Properly Use and Maintain PPE • • • • • Select the correct type (for the chemical in question) and fit of PPE, considering potential exposure (use guidance from the SDS) Provide clear instruction to workers on the proper use of PPE (when, where, how) Ensure proper PPE is worn for as needed Provide storage, cleaning and maintenance of PPE Plan and budget for PPE replacement at recommended intervals 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 2.51 Identify Gaps and Losses in Current Processes Expected CMS Deliverable: Chemical Inventory Reconciliation, Material Balances and Material Incident Report/Log ZDHC Audit Questions Does the facility regularly identify the quantity of chemicals lost due to accidents (e.g, spillages, poor labelling, accidental mixtures)? (CRS 1.110) Using the chemical inventory chemical flow diagram(s) developed in CMS Element 2.11 and CMS Element 2.13, 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 2.113) 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 2.41) accordingly The GIZ Practical Chemical Management Toolkit Company Handbook Module 1 includes examples on how to identify these gaps and losses. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-12 ASSESSMENT, PLANNING AND PRIORITISATION 2.52 RSL and MRSL Process 2.521 Verification of Compliance Expected CMS Deliverable: Chemical Inventory with Column Identifying ZDHC MRSL Compliant Formulations ZDHC Audit Questions Does the facility have signed and dated declarations from dye and chemical suppliers confirming that formulations supplied to the facility are compliant with the relevant retailers or facilitys own RSLs and/or MRSLs? (CRP 1.15) Establish, document and implement a process for verifying compliance with RSLs, associated with companies to which they sell products, and the ZDHC MRSL. Compliance verification can be part

of the 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 1.11) 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 1.11) used, instead it should be properly disposed of according to local and regional regulations and safety information. 2.522 RSL and MRSL Update and Maintenance Expected CMS Deliverable: Hazard and Risk Assessment Inventory (CMS Element 2.41 ) At a minimum, an organisation should annually review RSLs, associated with the companies to which they sell products, and the ZDHC MRSL to determine if the hazard and risk assessment inventory needs to be updated. This assessment can be combined with the review in CMS Element 2.41 ZDHC Audit Questions Does the

facility have programmes in place to phase out the intentional use of the 11 priority chemical groups, as defined by the ZDHC MRSL, with clear target dates? (CRC 1.12) Does the facility have a control policy/procedure for the use of durable water repellent finishes based on fluorinated chemistry? (CRC 1.13) 2.523 Integration with Contracts of Suppliers Expected CMS Deliverable: Inventory of Chemical Suppliers (CMS Element 2.31 ) 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 suppliers certificate? meet the standards laid out in the organisational RSL, (CMD 2.16) MRSL or chemical purchasing policy or should be removed from

the approved supplier list (CMS Element 2.31) 2.524 Business Process Compliance with Contracts Expected CMS Deliverable: Business Process Hazard and Risk Assessment Inventory (CMS Element 2.41 ) Establish, document and implement a process to encourage suppliers to use the organisation’s MRSL compliant formulation list (CMS Element 2.61) Maintain records of suppliers that are willing to use your organisation’s MRSL compliant formulation list (CMS Element 2.61) JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-13 ASSESSMENT, PLANNING AND PRIORITISATION 2.525 Going Beyond Regulatory Expected CMS Deliverable: Target Goals and Metrics Establish, document and implement a process that goes beyond legal compliance. Document best practices regarding the use of greener materials, chemistry or procedures that assess leading green practices and innovations. Also, document training classes, conversations with suppliers or customers, conference attendance, research and other

relevant activities. 2.6 2.61 ZDHC Audit Questions Does the facility have a hazardous chemical reduction plan beyond the 11 priority chemical groups with clearly set targets? (CRG 1.31) Does the facility use a process to examine, categorise and rank chemicals/formulations to be purchased against impact(s) such as human or environmental risk? (CRG 1.35) Performance Goals and Action Plans MRSL Compliant Formulations Expected CMS Deliverable: Chemical Inventory with MRSL Compliant Formulations Expected CMS Deliverable: Phase Out Target Dates and Action Plan for 1 1 Priority Chemical Groups ZDHC Audit Questions Is the facility using suppliers’ ZDHC MRSL compliant formulations to purchase chemicals? (CRG 1.12) 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 2.41) 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 priority hazardous chemicals using clear target dates. A chemical inventory with a hazard assessment and MRSL compliant formulations is a great starting point for review and goal setting. Discussions and action plans should be formed with the chemical supplier to ensure a successful target completion date without impacting the facility’s process efficiency and product performance. ZDHC Audit Questions Does the facility have programmes in place to phase out

the intentional use of the 11 priority chemical groups, as defined by the ZDHC Group, with clear target dates? (CRC 1.12) For guidance on the industry’s best management practices, regarding chemical management, see additional CMS Resources in Section 6. 2.62 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 2-14 SECTION 3 Chemicals Management 3.1 Organisational Structure 3.11 Roles and Responsibilities Expected CMS Deliverable: CMS

Organisational Chart For a successful CMS, senior leadership must commit and ensure (see Section 1) the availability of resources essential to establish, implement, maintain and improve CMS and customer satisfaction. Resources include human resources and specialised skills, organisational infrastructure, technology and financial resources. ZDHC Audit Questions Does the factory have an individual or team responsible for chemical management? (CMO 2.11) Does the facility have procedures to ensure that the approval for use of purchased chemicals is carried out by the authorised personnel responsible for quality? (CMD 2.111) 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 legal jurisdiction Regulatory Compliance Identifies new or changing compliance requirements Responsible for RSL and MRSL compliance and communication with supply chain partners RSL and MRSL Oversight 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 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 information to supply chain partners Alternatives Assessment Community of Practice and Sustainable Chemistry JUNE 2015

Responsible for activities related to chemical hazard assessment Acts as organisation’s representative for Chemical Management Community of Practice Responsible for chemicals management and sustainable chemistry metrics LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-1 CHEMICALS MANAGEMENT 3.12 Communication ZDHC Audit Questions Expected CMS Deliverable: Safety Communication/ Hazardous Chemical Placards/Posted PPE Warnings Does the facility have a current (chemical) SDS for each chemical, provided in the local language and placed in chemical handling and storage areas? (CMW 2.12) Establish, document and implement a process for communicating about the CMS amongst all of levels of the organisation. An organisation also should establish, document and implement a process for receiving and responding to external stakeholders, including documenting communications. Has management established procedures that clearly define and communicate the areas in which authorised

personnel are allowed to enter? (Primary focus is chemicals.) (CMW 215) 3.2 Training Is there a chemical emergency response plan in place and practiced on a planned schedule? (CME 2.11) To achieve a goal of zero discharge of hazardous 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. 2. Proper hand washing Retain associated chemical records 3. Establish, document and implement a process to conduct and track training 4. Assess training effectiveness with a quiz or by monitoring an appropriate activity to demonstrate learning ZDHC Audit Questions Are training records maintained to

demonstrate that facility personnel handling chemicals have the required education, training and skills to perform their assigned responsibilities and activities? (CMT 2.11) 5. Ensure that personnel are aware of the relevance and importance of their activities and how they contribute to achieving chemical objectives 3.21 Management 3.22 Regulatory 3.23 Work Practices 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. 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 2.13) 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 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-2 CHEMICALS MANAGEMENT 3.24 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://wwwroadmaptozerocom 3.3 Document Development Expected CMS Deliverable: CMS Manual Create a CMS Manual that describes the main elements of the CMS and references related documents. The CMS manual should include: • Documented statements of a chemical policy and chemical objectives • Documented procedures and records required by this manual • Documents, including records,

determined by the organisation to be necessary to ensure the effective planning, operation and control of its processes ZDHC Audit Questions Have procedures documenting the proper handling, use, storage and disposal of chemicals and hazardous chemicals according to the SDS/technical sheets been written and implemented at the facility? (CMD 2.11) Does the organisation have a written chemical safe handling plan to ensure that storage and conditions are appropriate for the chemical hazard class? (CMD 2.17) Review the CMS manual annually and update as needed. 3.4 Document and Record Control Expected CMS Deliverable: Procedure to Control Documents and Records Establish, document and implement a process for controlling documents and records associated with the CMS. The document control process should ensure that: • Documents are approved for adequacy prior to use • Correct versions are available at points of use and versions are tracked • Documents are legible, updated and

re-approved as needed ZDHC Audit Questions Does the facility have a document retention procedure that requires retention of key chemical inventory records for at least one year? (CMD 2.12) Are records available and retained which show chemical usage and traceability within the factory? (CMD 2.13) 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. 2. 3. 4. 5. 6. Approve documents for adequacy prior to issue Review, update and re-approve documents Ensure that changes and the current revision status of documents

are identified Ensure that the most up to date versions of documents are available at the appropriate points of use Ensure that documents are legible and readily identifiable 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 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-3 CHEMICALS MANAGEMENT 3.5 Chemical Management Work Practices Establish, document and implement a processes for chemical management work practices. Specifically, an organisation must establish documented SOPs for each of the topics discussed in this section. 3.51 Exposure Control Measures Expected CMS Deliverable: Procedure to Control Exposure ZDHC Audit Questions Are there SOPs that cover chemical management such as an approved chemical list, chemical classification,

safe chemical handling, chemical disposal? (CRS 1.12) Do personnel have access to and comply with the documents needed to do their work and related to their responsibilities? (Primary Focus – Chemicals) (CMT 2.12) A control approach, control strategy or control level of exposure is the sum of the control measures required to 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 (eg, 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, protective clothing and other required PPE (specific for the types of chemicals in use) to protect workers • Maintenance and replacement of equipment so that control measures remain effective Safe Work Australia maintains a good reference document on their web site called Managing Risks of Hazardous Chemicals in

the Workplace Code of Practice. Chapter 4 and Appendix J also are applicable to controlling chemical risks. JUNE 2015 ZDHC Audit Questions Does the facility have procedures in place to document the proper handling, use, storage and disposal of chemicals and hazardous chemicals according to the SDS/technical sheets been written and implemented at the facility? (CMD 2.11) Does the facility have a current (chemical) SDS for each chemical that is available in the local language for chemical handling and storage areas? (CMW 2.12) LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-4 CHEMICALS MANAGEMENT 3.52 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 and safety standards. At a minimum, preferred suppliers should be those that provide a SDS in the

local language and that information should contain all relevant GHS standards. SDSs: ZDHC Audit Questions If portable equipment and utensils are not dedicated to specific chemicals or classes of chemicals, are the chemicals of construction appropriate to prevent cross contamination? (CRS 1.17) Does the organisation have a written, chemical safe handling plan to ensure that storage and conditions are appropriate for the chemical hazard class? (CMD 2.17) • Indicate characteristics, properties and quality of the chemical that influences the end product. • Allow determination of chemical compatibility for proper mixing. • Provide information about proper storage and handling (e.g, ventilation) • Indicate appropriate security precautions and needed controls, including PPE. • Provide written emergency procedures in case of 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. Does the facility have appropriate controls in place for batch/continuous chemical processes? (CMW 2.11) Does the organisation have a written chemical change management process? (CAC 3.11) Does the facility have chemical hazard signage and safe handling equipment available in the facility areas where exposure may occur? (CD 4.11) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-5 CHEMICALS MANAGEMENT 3.53 Chemical Handling Expected CMS Deliverable: Procedures for Safe Chemical Handling Procedures should be provided for handling chemicals in the safest way possible, as outlined in the SDS. The ÖKOPOL document, Checklist Based on Best Available Techniques in the Textile Industry, includes useful checklists and guidance on the storage and handling of chemicals. 3.54 ZDHC Audit Questions Has the facility identified and documented any types of installation/processes that have a potential to leak and cause significant environmental degradation (e.g, aboveground storage tanks, underground storage tanks, wastewater treatment plant bulk storage)? (CRS 1.113) Is there secondary containment at all locations where chemicals are stored and an emergency response plan in place for those critical

areas? (CRS 1.114) Has the organisation documented and implemented a procedure to re-evaluate chemicals after a defined period of storage to determine their suitability for use? (CRS 1.115) Are special storage conditions identified and followed from chemical specifications or SDS? (CMW 2.13) Chemical Storage CMS Deliverable: Procedure for Chemical Storage Improve the storage of chemicals with the help of: Are chemicals stored in a well-ventilated space designated only for this purpose? (CMW 2.16) Is there adequate space in and around weigh areas, machinery and storage and appropriate environmental controls to preclude mix ups or contamination? (CMW 2.18) • Information provided in the SDS • SOPs and checklists • Ventilation and grounding • 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 Are incompatible chemicals stored separately to ensure that no dangerous chemical reactions can occur? (CMW 2.19) Are flammable chemicals stored separately and securely? (CMW 2.110) 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. 3.55 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-6 CHEMICALS MANAGEMENT 3.56 Chemical Labelling ZDHC Audit Questions CMS Deliverable: Procedure for Chemical Labelling Are intermediate and/or chemical transfer Chemical containers and packaging should allow for containers properly labelled? clear

identification of chemical substances. A (CMW 2.111) 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 3.57 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. • Perform regular inventory audits to identify chemicals that are not being used. • Provide a simple, regular listing to chemical users that includes available chemical stocks, location and point(s) of contact. • Read chemical labels before using. Keep SDS up to date and review regularly for new content (at least annually). ZDHC Audit Questions Does the facility have established procedures or alternative systems to ensure that only quality-control approved chemicals are used? (CMD 2.18) Are incoming chemicals segregated from working stock prior to acceptance for use? (CMD 2.110) Has the organisation established and implemented procedures to ensure chemicals used are from oldest to newest receipt date? (CMD 2.112) • Do not mix unknown chemicals. • 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. 3.58 Personal Protective Equipment CMS Deliverable: Procedure for PPE Use The main purpose of PPE should be to protect employees should an accident or incident occur despite appropriate management systems and operational procedures. Information on appropriate PPE can be found in the SDS for each chemical. PPE includes the following: • ZDHC Audit Questions Is there an internal audit group that reviews, audits and verifies chemical hazards and inventory? (CAA 3.11) Is there adequate space in and around weigh areas, machinery and storage along with appropriate environmental controls to preclude mix ups or contamination? (CMW 2.18) 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 2.115) Occupational Safety and Health Administration’s (OSHA’s) eye and face protection regulations in 29CFR 1910.133 or

European Standard EN166 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-7 CHEMICALS MANAGEMENT • 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 US National Institute for Occupational Safety and Health (NIOSH) or European Standard EN149 approved respirator when one is necessary. 3.59 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.orsodnihgov/sr/dohs/BioSafety/Pages/student goodlabaspx 3.510 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 Date/ Initial Chemical Name CAS Conc Exp. Date Amt. or container size Cont. Type Amount (est.) Storage

Location 4/2/08 JS 1-Propanol 71-23-8 100% N/A 2 x 500 mL Poly 750 mL Flammable cabinet Room 202 6/5/08 Aluminium 7429-90-5 100% N/A 500 g Glass 200 g Chemical Storage Room 110 MA JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-8 CHEMICALS MANAGEMENT 3.511 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: − − JUNE 2015 An inspection tag to document monthly checks Written first aid instructions in the local language LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 3-9 SECTION 4 Monitor 4.1 Monitor and Measurement (Continuous Improvement) CMS Deliverable: Process to Monitor Goal Progress General Requirements: • • Plan and implement the monitoring, measurement, analysis and improvement processes needed to: ─ Ensure conformity of the CMS ─ Continually improve the effectiveness of the CMS Include determination of applicable methods, including statistical techniques, and the extent of their use in the plan. 4.11 Goal Progress Establish, document and implement a

process to monitor progress towards the goals created in CMS Element 2.6 Make sure to document information used to monitor performance and maintain associated records. 4.12 Regulatory Compliance CMS Deliverable: Process to Monitor Regulatory Conditions ZDHC Audit Questions Is there secondary containment at all locations where chemicals are stored and an emergency response plan in place for those critical areas? (CRS 1.114) Has the organisation documented and implemented procedures to re-evaluate chemicals after a defined period of storage to determine their suitability for use? (CRS 1.115) Is there a corrective action plan in place for the facility non-compliance? (CRR 1.12a) Is there a documented procedure to deal with chemical spills and leaks? (CMD 1.113) Does the facility maintain appropriate spill containment kits in use and storage areas? (CMW 2.113) Is there a chemical emergency response plan in place and practiced on a regular schedule? (CME 2.11) Is management aware of the

ZDHC 11 priority chemical groups and ZDHC goal of zero discharge? (CAG 3.11) Does the facility have targets in place to reduce or eliminate the use of hazardous chemicals in the facility? (CAG 3.21) 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 3.22) 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. 4.13 Work Practice and Customer Requirements Implementation CMS Deliverable: Monitor Operating Conditions and Customer Satisfaction Organisations should establish, document and implement a process

to monitor operating conditions needed to prevent the potential for adverse impacts to health or the environment. The organisation should document performance against the operating criteria and maintain associated records. JUNE 2015 ZDHC Audit Questions Does the facility have a system of tracking changes in laws and regulations governing environmental management and reporting to management? (EP 1.11) Is there a process for monitoring the validity of permits required for their facility? (EP 1.12) Is there a process in place that verifies all chemicals used in producing the product(s) meet applicable permit requirements? (CRR 1.11) LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-1 MONITOR As one of the measurements of CMS performance, the organisation should monitor customer perception regarding whether the organisation has met customer requirements. Methods for obtaining and using this customer information should be gathered and documented. 4.2 Internal Audit CMS

Deliverable: Process for Internal Audits Establish, document and implement a process to periodically audit performance against the CMS Elements and associated processes. The audits should determine if the CMS is properly implemented and 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, should be maintained. The ZDHC audit checklist may be a useful recording tool. ZDHC Audit Questions Does the facility have a process to monitor and review its business registration and regulatory permits? (CRR 1.21) Does the facility have a process to follow and update legal requirements as they apply to facility operating permits and customers products? (CRR 1.22) ZDHC Audit Questions Is there an internal audit group that reviews, audits and verifies chemical hazards and inventory? (CAA 3.11) ZDHC Audit Questions Does the facility periodically

audit or otherwise verify suppliers? (CAA 3.21) 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 Does the facility require a ZDHC audit or a management. Facilities may send quality and technical certified third-party audit regarding staff to observe or review their practices as well. These chemical management? (CAA 3.31) 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 4.41 Change Management

Most businesses routinely receive change orders or ZDHC Audit Questions new/revised specifications. A good CMS should Does the organization have a written establish a system to handle internal and customer chemical change management process? chemical inventory changes. Establish, document and (CAC 3.11) implement a process for reviewing planned or actual 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-2 MONITOR 4.42 Corrective Action CMS Deliverable: Procedure for Change Management and Corrective Action Establish, document and implement a process for dealing with actual and potential non-conformity(ies) or non-compliance. This process should include taking corrective and preventive

actions, documenting the actions taken and verifying the effectiveness of the actions taken. JUNE 2015 ZDHC Audit Questions Is there a corrective action procedure(s) when inaccuracies are identified in the chemical inventory reconciliation? (CRS 1.111) Is there a corrective action plan in place for facility non-compliances? (CRR 1.12a) Is there a corrective action plan implemented and monitored in case of chemical non-compliance by chemical supplier(s) when identified by the facility? (CRS 1.25) LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 4-3 SECTION 5 Management Review 5.1 Disclosure of Substance in Use CMS Deliverable: Process for Disclosing Substances in Use Establish, document and implement a process for disclosing the substances in use. An organisation should determine and document which stakeholders will be provided the substance in use information and how the information will be communicated. The chemical risk assessment information gathered in Section 2.4 can

provide the basis for an organisation’s disclosure practices. ZDHC Audit Questions Does the facility have chemical hazard signage and safe handling equipment available in areas of the facility where exposure could occur? (CD 4.11) Is the annual usage (volume) of each chemical monitored and recorded? (CRS 1.14) 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 to improve the system and guide the organisation closer to achieving the goal of zero discharge of hazardous chemicals. Documents and records, including meeting minutes, indicating performance of this element

shall be maintained. ZDHC Audit Questions Does the facility have a current (chemical) SDS for each chemical, available in the local language, located in areas where chemicals are handled or stored? (CMW 2.12) 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 2.11) 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 efforts. This may include providing effluent discharge reports to Pollutant Release and Transfer Register sites and the efforts taken to control water usage, carbon footprint and energy conservation.

ZDHC Audit Questions Are chemical management efforts shared with the public? (CD 4.21) Is the facility a chemical/product steward? (CD 4.31) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 5-1 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 3. Status of change management and corrective actions ZDHC Audit Questions Is management aware of

the ZDHC 11 priority chemical groups and ZDHC goal of zero discharge? (CAG 3.11) 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 5-2 SECTION 6 CMS Resources Organisational Skill Level (Symbol) CMS Manual Section Reference Title & Description Hyperlink Foundational 1.11 ISO 9001 for Small Business – what to do advice http://www.isoorg/iso/home/news index/news archive/newshtm?refid=Ref1669 1.21 Workplace Safety and Health Guidelines – Management of Hazardous Chemicals Programme

https://www.wshcsg/files/wshc/upload/cms/file/WSH Guidelines MHCPpdf 1.21 Code of Practice on Safety Management – basic expectations of a Safety Management System http://www.labourgovhk/eng/public/os/managepdf 2.1 Chemical Management Guide for Small and Medium Sized Enterprises http://www.mtpinnaclecom/pdfs/Guide E 300708pdf 2.1 OIA Chemical Management Module – toolkit http://outdoorindustry.org/responsibility/chemicals/cmpilothtml 2.12 EMAS “easy” for Small and Medium Enterprises – in 10 days with 10 people on 10 pages in 30 steps http://www.emas-easyeu/ 2.14 AFIRM Chemical Guidance Document –provide an overview to types of chemicals used in textiles and leather goods http://www.afirm-groupcom/PDF12/AppendixF-ChemicalGuidancepdf 2.14 Guidance for creating mass balances http://serc.carletonedu/introgeo/mathstatmodels/examples/MassBalancehtml http://www.ceutexasedu/bmeb/resources/masshtml 2.143 Waste Minimisation Guide for the Textile Industry – steps

to cleaner production http://www.textuiasiro/biblioteca/carti/Articole/Waste Minimisation Guide for t he Textile Industry A Step Towards.pdf 2.143 Florida Guide to Writing a Waste Minimization Plan http://www.depstateflus/waste/quick topics/publications/shw/HWRegulation/Bi nder1 waste min guide.pdf Example COSHH risk assessment – Warehouse: Use it as a guide to think through some of the hazards in your business and the steps you need to take to control the risks. http://www.hsegovuk/coshh/riskassess/warehousehtm 2.41 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-1 CMS RESOURCES Organisational Skill Level (Symbol) CMS Manual Section Reference Title & Description Hyperlink 2.41 Identifying and Evaluating Hazards in Research Laboratories – while oriented to the lab many factors can be adapted to the factory. http://www.acsorg/content/dam/acsorg/about/governance/committees/chemicals

afety/identifying-and-evaluating-hazards-in-research-laboratories-draft.pdf 2.43 Safety in the use of chemicals at work – basic guidance to protect workers from the hazards of chemicals http://www.iloorg/wcmsp5/groups/public/---ed protect/---protrav/--safework/documents/normativeinstrument/wcms 107823pdf 2.21 ZDHC Research List – 2014: Chemical Substance Resource Links provide more regulatory information. www.roadmaptozerocom/dfphp?file=pdf/ResearchListpdf 2.52 Meeting Customers’ Needs for Chemical Data – a guidance document for suppliers http://greenchemistryandcommerce.org/downloads/GC3 guidance final 031011p df 2.62 Transitioning to Safer Chemicals – a toolkit for employers and workers https://www.oshagov/dsg/safer chemicals/indexhtml 2.62 The Guide to Safer Chemicals – implementing the BizNGO principles for safer chemicals http://www.bizngoorg/safer-chemicals/guide-to-safer-chemicals 2.62 Interstate Chemicals Clearinghouse – Alternatives Assessment

Guide Version 1.0 – collection of alternative assessment guides http://theic2.org/article/download-pdf/file name/IC2 AA Guide Version 10pdf 2.62 A Framework to Guide Selection of Chemical Alternatives – 13 step framework to support decision making about alternatives to chemicals of concern. https://download.napedu/loginphp?record id=18872&page=http%3A%2F%2Fww w.napedu%2Fdownloadphp%3Frecord id%3D18872 3.5 An Employer’s Guide to Developing an Employee Right-to-Know Program – basic steps in developing a training program http://www.dlimngov/OSHA/PDF/ertk gipdf 3.51 International Chemical Control Toolkit – list of guidance sheets on various exposures http://www.iloorg/legacy/english/protection/safework/ctrl banding/toolkit/icct/sh eets.htm 3.52 Accessing SDSs for chemicals http://www.ghs-msdscom/ghs-msds/format-and-sections-of-the-ghs-sds/ http://msdssearchengine.com/engine/searchphp?query=red+27&search=1 JUNE 2015 3.53 Easy-to-use workplace control scheme

for hazardous substances – practical guide for small and medium size businesses http://www.bauade/en/Topics-from-A-to-Z/Hazardous-Substances/workplacecontrol-schemepdf? blob=publicationFile 3.54 Chemical Storage Guidelines from the CDC – guidelines for safe chemical storage http://www.ehsocom/ChemicalStorageGuidelineshtm LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-2 CMS RESOURCES Organisational Skill Level (Symbol) CMS Manual Section Reference Title & Description Hyperlink Globally Harmonized System of Classification and Labelling of Chemicals (GHS) http://www.uneceorg/fileadmin/DAM/trans/danger/publi/ghs/ghs rev05/English/ ST-SG-AC10-30-Rev5e.pdf 3.6 Emergency Response Plan Template http://www.femagov/media-library-data/1388775706419f977cdebbefcd545dfc7808c3e9385fc/Business EmergencyResponsePlans 10pg 20 14.pdf 4.1 SAC Higg Index – sustainability tools http://www.apparelcoalitionorg/higgindex/ 4.2 The Internal Auditing Pocket Guide –

prepare, perform, report and follow up of internal audits http://asq.org/quality-press/display-item/indexhtml?item=H1300 ZDHC Audit – Tool 8 CAPA Worksheet Template – factory tool for corrective actions http://www.roadmaptozerocom/programme-documentsphp Chemical Agent Risk Assessment Sheet – template http://www2.ulie/web/WWW/Faculties/Science %26 Engineering/Departments/C hemical %26 Environmental Science/Resources/Chemical%20Risk%20Assessment %20Template 2.524 AAFA – Voluntary Product Environmental Profile - a 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. https://www.wewearorg/assets/1/7/AAFA VPEP 12-20-12 finalpdf 2.51 The Lean and Chemicals Toolkit – addressing chemical use and waste via Lean strategies http://www.epagov/lean/environment/toolkits/chemicals/indexhtm 2.43 NIOSH Pocket Guide to Chemical

Hazards – source of general industrial hygiene information on industry chemicals. http://www.cdcgov/niosh/docs/2005-149/pdfs/2005-149pdf International Standards for the Professional Practice of Internal Auditing – multiple language versions available. https://na.theiiaorg/standards-guidance/mandatoryguidance/Pages/Standardsaspx 3.56 4.42 Progressive 2.41 4.2 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-3 CMS RESOURCES Organisational Skill Level (Symbol) CMS Manual Section Reference Title & Description Hyperlink Aspirational BEST Practices JUNE 2015 2.43 Guidance for creating Job Safety Analysis http://www.ccohsca/oshanswers/hsprograms/job-hazhtm and https://www.oshagov/Publications/osha3071pdf 2.62 Guide on Sustainable Chemicals – a guide that can be applied by enterprises for the selection of substances and mixtures. http://www.umweltbundesamtde/en/publikationen/guide-on-sustainablechemicals 2.62 OECD Substitution and Alternatives

Assessment Toolbox a compilation of resources relevant to chemical substitution and alternatives assessments http://www.oecdsaatoolboxorg/ 4.11 Life Cycle Metrics for Chemical Products – guideline for chemical sector to assess and report on environmental footprint of products http://www.wbcsdorg/Pages/EDocument/EDocumentDetailsaspx?ID=16329 International Finance Corporation: Environmental, Health, and Safety Guidelines for Textile Manufacturing http://www.ifcorg/wps/wcm/connect/2a66470048865981b96efb6a6515bb18/Fina l%2B-%2BTextiles%2BManufacturing.pdf?MOD=AJPERES&id=1323162617789 Environmental Standard in the Textile and Shoe Sector – Best Available Techniques Reference Document http://www.umweltbundesamtde/sites/default/files/medien/publikation/long/428 9.pdf Global Social Compliance Programme – Environmental Reference Requirements: provides a common understanding of good environmental practice. http://gscpnet.com/gscpfiles/GSCP Environmental Reference

Requirementspdf Profile of the Textile Industry – EPA 1997 – general industry report with several case studies. http://www.epagov/compliance/resources/publications/assistance/sectors/notebo oks/textilsn.pdf Best Management Practices for Pollution Prevention in the Textile Industry – U.S EPA: best management of pollution prevention http://nepis.epagov/Exe/ZyNETexe/30004Q2Utxt?ZyActionD=ZyDocument&Client =EPA&Index=1995%20Thru%201999&Docs=&Query=&Time=&EndTime=&SearchM 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 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-4 CMS RESOURCES Organisational Skill Level (Symbol) JUNE 2015 CMS Manual Section Reference Title & Description Hyperlink Evaluating the Chemical Footprint of Plastics – a plastics scorecard http://www.bizngoorg/sustainable-materials/plastics-scorecard Natural Resources Defense Council’s (NRDC’s) 10 Best Practices for Textile Mills to Save Money and Reduce Pollution = a practical guide to responsible sourcing version 2.0 – showcases 22 mills http://www.nrdcorg/international/cleanbydesign/files/responsible-sourcingguidepdf NRDC Guide to Metering in Textile Mills – overview of metering for water and energy http://www.nrdcorg/international/cleanbydesign/files/CBD-Metering-Guidepdf Reference Document on Best Available Techniques for Textile Industry – July 2003

– This BREF addresses installations for the pretreatment (operations such as washing, bleaching, mercerisation) or dyeing of fibres or textiles. http://eippcb.jrceceuropaeu/reference/txthtml Checklist based on best available techniques in the textile industry – Good summary of the BREF – July 2003 (above) http://www.umweltbundesamtde/sites/default/files/medien/publikation/long/429 5.pdf Best Practices in Product Chemicals Management in the Retail Industry – examples of how retailers are moving to better chemical practices http://www.greenbizcom/research/report/2009/12/09/best-practices-productchemicals-management-retail-industry Chemical Laboratory Safety and Security – a guide to prudent chemical management http://dels.nasedu/resources/static-assets/bcst/miscellaneous/ChemicalLaboratory-Safety-and-Securitypdf Process Safety Leadership in the Chemicals Industry http://www.ceficorg/Documents/IndustrySupport/CIA%20Process%20Safety%20%20Best%20Practice%20Guidepdf

Guidance for Best Environmental Practices for the Global Apparel Industry – focus on fluorinated repellent products http://fluorocouncil.com/PDFs/Guidance-for-Best-Environmental-Practices-BEP-forthe-Global-Apparel-Industrypdf LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 6-5 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 (MRSL) list of substances banned from intentional use in processing 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 JUNE 2015 list of chemicals/chemical formulas that comply with the facility’s MRSL/RSL LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY 7-1 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: Assessment YES NO Remarks 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)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-2 Assessment YES NO Remarks 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-3 What Chemical Management Means in Practical Terms – Progressive Level For the Retailer/Brand: Assessment YES NO Remarks 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)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-4 Assessment YES NO Remarks 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-5 What Chemical Management Means in Practical Terms – Progressive Level For the Supplier: Assessment YES NO Remarks 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)? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-6 Assessment YES NO Remarks 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-7 What Chemical Management Means in Practical Terms – Aspirational Level For the Retailer/Brand: Assessment YES NO Remarks Have you completed the

Foundational Level assessment and answered all (most?) questions with YES? Have you completed the Progressive Level assessment and answered all (most?) questions with YES? 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-8 Assessment YES NO Remarks 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-9 What

Chemical Management Means in Practical Terms – Aspirational Level For the Supplier: Assessment YES NO Remarks Have you completed the Foundational Level assessment and answered all (most?) questions with YES? Have you completed the Progressive Level assessment and answered all (most?) questions with YES? 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? Can you verify that you have a business process in place to evaluate alternatives (using the alternatives assessment process, including criteria for identifying preferred substances)

in-line with your customer’s (brand/retailer) expectations? Can you verify that you have a business process in place to collaborate with your customers (brands/retailers) and your chemical suppliers to implement substitutions or other actions agreed upon from the alternatives assessment? Can you verify that you have a business process in place to 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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-10 Assessment YES NO Remarks

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? JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY A-11 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: JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-2 Table 3: Checklist for Purchasing Chemicals Purchasing Yes No 1. Chemicals purchased in a manner consistent with the facilitys purchasing policy 2. One person or department designated with the responsibility of purchasing chemicals (ie, basic knowledge of chemistry required). 3. Purchasing procedure for personnel in place (eg, 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 (ie, 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 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-3 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 JUNE 2015 Date LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY B-4 Appendix C Chemical Inventory CHEMICAL INVENTORY Responsible for Area and Title

Person Completing Inventory and Title Date Inventory Completed and Reviewed Department Building Room # Dye Weigh House #1 12 Dyeing #3 - JUNE 2015 Product name Chemical Name Chemical Supplier CAS # Quantity Units SDS on file? Hazard Class Use drop down arrow to select Use drop down arrow to select R Phrase 11 ZDHC Priority Chemical Classes On Factory/ZDHC MRSL? On Brands RSL? Use drop down arrow to select Use drop down arrow to select Use drop down arrow to select Shelf Life Catalogue Order Number/Supplier Order Number Hydrochloric acid (37%) Hydrochloric Acid XYZ Chemical Company 7647-01-0 2 litres YES Class 8 R 35 N/A No No Jun-15 xxx-xx-xx Glaubers salt Sodium sulfate ABC Chemical Company 7757-82-6 1000 kg YES Non-hazardous N/A N/A No No Jun-15 xxx-xx-xx 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, (eg, 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 25 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.roadmaptozerocom/ Column O - *REQUIRED FIELD On Brands 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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-2 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.roadmaptozerocom JUNE

2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY C-3 Appendix D Risk Assessment Template Example RISK ASSESSMENT TEMPLATE EXAMPLE 2.12 Company name: Risk Assessor name: Date: Click here to enter a date. Hazard Example: Pouring sodium hydroxide solution from bulk tank Who Is Involved Risk (Severity and Likelihood) Controls In Place 3 process employees Splashing – skin/eye burns PPE only face shield and gloves Very likely and extreme harm Very high risk Further Action Consider eliminating pouring. Restructure process. Priority 1 Action Date Immediate Action By Mgt. *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. JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-2 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 Very Likely - Could happen at any time Likely - Could happen sometime Unlikely - Could happen but very rarely Very Unlikely - Could happen but probably never will Kill or cause permanent disability or ill health 1 1 2 3 Long-term illness or serious injury 1 2 3 4 Medical attention and several days off work 2 3 4 5 First aid needed 3 4 5 6 JUNE 2015 LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY D-3 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 Energy Management • 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. Standards • 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 • Hazardous Materials JUNE 2015 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. Standards • 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. 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 • Waste and Sludge 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. Standards • 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 • Wastewater JUNE 2015 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. 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. LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-2 • 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 JUNE 2015 • 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. LEADERS IN ADVANCING ENVIRONMENTAL RESPONSIBILITY E-3