Can you share some best practices for the Level 3 question, “Does your facility contribute to an analysis of lifecycle impacts for selecting alternative processes?”
Some best practices are listed in the Chemical Management section of the How to Higg guidance, however, the following are additional suggestions:
- Hazardous chemicals risk assessment report such as a Screened Chemistry or Cradle2Cradle assessment report for chemicals in use and/or proposed alternatives.
- Evidence that the facility has evaluated chemicals used in manufacturing and their alternatives against established human health and environmental hazard criteria.
- If applicable, a prioritized list of chemical substitutions/actions based on the hazard assessment.
If we have a Chemical Management System (CMS) at an organizational level, can we extend that documentation to all facilities or does each facility need its own version?
Master CMS documentation can be used for all the facilities, but facility specific documentation and management team employees responsible for chemical management should be available during verification at any of the main or sub-facilities.
This is similar to multiple facilities being certified under an EMS (ISO 14001) certification.
Is sewing machine lubricating oil a chemical in production or in operation?
Sewing machine lubrication oil (such as white petroleum oil), would be considered as chemicals used in operation, as the chemical (oil) does not touch the product.
In some circumstances, if the oil is applied on the thread and ends up in the product, then it would be a chemical used in production.
What is the difference between 'Empty chemical drums and containers (without proper cleaning)' and 'Empty containers (cleaning, sanitizing, pesticides, etc.)'?
Empty chemical containers without cleaning are relevant to facilities that use industrial chemicals and return the chemical containers to their suppliers or authorized disposal facilities.
Empty containers (cleaning, sanitizing, pesticides, etc.), are relevant to facilities that may not use these containers in production but in facility operations, where they do not wash or clean the containers but dispose of them as is (which is not recommended).