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FEM 2025 - Chemical Management Level 1 (Part 2)

  • Updated

Table of Contents

Chempurchasereqrsl

Does your facility select and purchase chemicals based on their hazards and RSL requirements?  (Ref ID: chempurchasereqrsl)

Answer Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and RSL requirements and all chemicals meet the requirements of RSL and the facility’s purchasing policy and there is documentation to support this.

Answer Partial Yes if: Your facility has a documented process in place to select and purchase chemicals based on their hazards and RSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance with the facility’s purchasing policy and your facility has clear plan for obtaining the supporting this documentation.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • If yes, do all chemicals purchased and used in production meet the facility's chemical purchasing policy?

If you select No, you will be asked the following sub question(s):

  • If no, do you have a process or plan for eliminating chemicals that do not meet the facility's chemical purchasing policy?

Suggested Uploads:

  • Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and RSL requirements such as:
  • RSL(s) applicable to the facility (e.g., customer’s RSL, combined facility RSL).
  • Chemical purchasing policy and procedure(s).
  • Positive lists used for chemical purchasing. 
  • Third party RSL conformance certification/test reports.
  • Chemical inventory showing compliance status of all chemicals with the facility’s purchasing policy.

What is the intent of the question?

The intent is to ensure facilities have an established process to evaluate chemical hazards and RSL conformance risk during procurement and chemicals purchased are compliant with the facility’s chemical purchasing policy.

Technical Guidance:

Restricted Substance List (RSL) is a list of chemicals that are regulated via limiting or restricting the allowable concentration of chemicals in final products due to their potential harmful impact on human health and the environment. RSLs are typically developed by industry associations, governments, or individual companies to ensure that products and materials used in manufacturing processes meet specific safety and environmental standards. 

RSLs are one way to identify chemicals that are potentially hazardous which can be used to establish chemical purchasing practices to minimize the risk of hazardous chemicals entering a facility and products.  

To ensure that chemicals are appropriately evaluated before purchase, facilities should:

  • Establish their own chemical RSL that covers all RSL requirements from clients (e.g., brands) they work with or industry initiatives they are a part of 
    • For facilities that have more than one customer RSL, a policy should be in place to use the most stringent RSL limits for each chemical and then establish their RSL to meet all customer requirements.
  • Establish a process to communicate RSL requirements to all chemical suppliers including the  evidence needed from suppliers  to confirm compliance (e.g., positive lists, certificates/declarations of RSL conformance, certificates of analysis, or other relevant documentation)
  • Include RSL compliance as a purchasing requirement for all chemicals.
    • This should include procedures to verify chemicals conform to RSL requirements through documentation provided by chemical suppliers.
  • Ensure all chemical procurement staff are aware of RSL requirements and the facility’s purchasing policy and procedure. 
  • For chemicals not used in the manufacturing process (e.g., lubricants, cleaning chemicals) ensure there is a process in place to, at minimum, review the list of ingredients and SDS if available against the facility’s purchasing policy requirements.

Resources:

Chempurchasereqrsl Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and RSL requirements and all chemicals meet the requirements of RSL and the facility’s purchasing policy and there is documentation to support this.

Documentation Required: 

  • Documentation that demonstrates the facility selects and purchases chemicals based on their hazards and RSL requirements. This may include:
    • RSL(s) applicable to the facility (e.g., customer’s RSL, combined facility RSL).
    • Chemical purchasing policy and procedure(s) that include, but are not limited to:  
      • Process of communicating RSL with the chemical suppliers,
      • Process to obtain suppliers' confirmation/declaration of RSL compliance, 
      • Collection of up-to-date positive lists from chemical suppliers.
      • Preference/requirements for purchasing chemicals on positive lists.
    • Positive lists used for chemical purchasing. 
    • Annual third party RSL conformance certification/test reports/declarations.
    • Chemical inventory showing RSL compliance status of all chemicals.

Interview Questions to Ask:

  • Staff responsible for the facility’s chemical management program can explain how the facility established its RSL and RSL requirements of the facility’s chemical purchasing policy and procedure. 
  • Staff responsible for chemical procurement understand and can explain how chemicals are evaluated and approved for purchase in relation to the facility’s RSL and purchasing policy and procedure. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that all chemicals in use comply with the facility’s RSL ,chemical purchasing policy and procedure.(e.g., observed chemicals have been appropriately screened and there is documentary evidence to confirm RSL conformance).

Partial Points:

  • Partial points will be awarded for facilities that have a documented process in place to select and purchase chemicals based on their hazards and RSL requirements but have purchased chemical(s) that do not have sufficient documentary evidence to prove compliance with the facility’s purchasing policy and procedure and your facility has clear plan for obtaining the supporting this documentation.

Chemhealthprogram

Does your facility have an environmental and occupational health and safety program specific to chemicals management?  (Ref ID: chemhealthprogram)

Answer Yes if: Your facility has a documented program and procedures specific to the environmental and occupational health and safety risks of chemical use at the facility and the program minimally includes the following:  

  • A designated person or team responsible for environmental and health and safety related to chemicals.
  • A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
  • The program meets all legal health and safety requirements related to chemicals management.
  • Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Answer Partial Yes if:  Your facility has established practices specific to the environmental and occupational health and safety risks of chemical use at the facility, but the program does not include one (1) or more of the following:  

  • A designated person or team responsible for environmental and health and safety related to chemicals.
  • A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite.
  • The program meets all legal health and safety requirements related to chemicals management.
  • Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Note: The environmental and occupational health and safety procedures related to chemicals management may be included as part of the facility’s overall environmental health and safety management program.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads:

  • Environmental and health and safety management team organization chart and/or job descriptions.
  • Chemicals risk assessment.
  • Environmental health and safety procedures related to chemical storage, handling, usage, and disposal.
  • Permits governing health and safety requirements for chemical storage, use, and disposal if applicable.

What is the intent of the question?

The intent of this question is to ensure facilities have established procedures in place to manage and control environmental and health and safety risks associated with chemical use at the facility.

Technical Guidance:

An environmental and occupational health and safety (ESH) program aims to minimize environmental impacts, reduce workplace hazards, and protect the health and well-being of employees. The scope and complexity of a facility’s EHS program will vary depending on the type of facility, types and quantities of chemicals used as well as other specific risks related to facility production and operations.

It is crucial that a facility’s EHS program be developed and managed by qualified staff and be based on the formal evaluation of risks and hazards in the workplace with the goal of protecting workers and the environment. 

In the FEM, facilities are expected to have EHS practices related to chemicals management that, at minimum, cover the following:  

  • Designated roles and responsibilities for environmental and health and safety related to chemicals.
  • An assessment of risks associated with the storage, handling, use and disposal of chemicals used onsite including potential worker exposures to chemicals.
  • Procedures to ensure compliance with all legal health and safety requirements related to chemicals management.
  • Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Resources:

Chemhealthprogram Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have a documented program and procedures specific to the environmental and occupational health and safety risks of chemical in use at the facility and the program minimally includes the following:  

  • A designated person or team responsible for environmental and health and safety related to chemicals.
  • A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite. 
  • The program meets all legal health and safety requirements related to chemicals management.
  • Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment.

Documentation Required:

  • Documentation that demonstrates the facility has practices and/or procedures in place to manage environmental and health and safety risks of chemicals in use at the facility. This may include:
    • Environmental and health and safety management team organization chart and/or job descriptions.
    • Chemicals risk assessment.
    • Environmental health and safety procedures related to chemical storage, handling, usage, and disposal.
    • Required Permits governing health and safety requirements for chemical storage, use, and disposal.

Interview Questions to Ask:

  • Staff responsible for EHS management and/or chemical safety management at the facility understand their roles and responsibilities and can explain how the facility manages risks related to the storage, handling, use, and disposal of chemicals.

Inspection - Things to Physically Look For:

  • Observations onsite indicate the EHS program related to chemicals management is being implemented per the facility’s established practices or procedures.   

Partial Points:

  • Partial points will be awarded for facilities that have established practices specific to the environmental and occupational health and safety risks of chemical in use at the facility, but the program does not include one (1) or more of the following:  
  • A designated person or team responsible for environmental and health and safety related to chemicals.
  • A documented chemicals risk assessment that covers environmental and health and safety risks of chemicals used onsite. 
  • The program meets all legal health and safety requirements related to chemicals management.
  • Documented procedures for chemical storage, handling, usage, disposal, and environmental controls for waste or discharge to the environment

Chemstorage

Does your facility have well marked, designated chemical storage areas?  (Ref ID: chemstorage)

Answer Yes if: Your facility has well marked, designated chemical storage areas for all chemicals stored onsite.

If you select Yes, you will be asked the following sub question(s) to indicate which storage practices are in place at the facility:

  • The chemical storage area is ventilated, dry and protected from the weather and fire risk.
  • The storage area is protected from unauthorized employees (i.e., locked).
  • The chemical storage area is clearly marked.
  • The chemical storage area has easy entry and exit in case of any emergencies. 
  • Storage containers are in good condition, appropriate for their contents, closed and clearly labelled with their contents. 
  • Floor in storage areas are solid and non-porous, there are no water drains that the liquid could spill into, and there is no evidence of spilled liquid. 
  • Secondary containment is available for liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur. 
    • Note: The need for secondary containment must be based on a formal risk assessment that considers the risk and potential impact of spills and must also meet applicable legal requirements based on chemical volume and container size. 
  • Incompatible substances (such as strong acids and strong bases) are stored separately. 
  • Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting.
  • Temporary storage containers are closed and labelled with contents,hazard class, and lot number (if applicable) 
  • First Expiry, First Out (FEFO). 
  • Health and safety measures are in place (such as PPE, etc).

Suggested Uploads:

  • Facility map showing the location of chemical storage areas. 
  • Floor layout plan of chemical storage areas, specifying categorization and storage location of different types of chemicals. 
  • Standard operating procedures for chemical storage and labelling. 
  • Example photos of chemical storage areas and controls
  • Examples of storage in/out logs, FEFO records, specifying date of arrival at storage, lot number, and date of dispatch to production, etc.)
  • Audits/inspections checklists or reports of chemical storage areas. 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that all storage areas are well-marked and have sufficient controls to prevent contamination and safety risks.

Technical Guidance:

Proper chemical storage with appropriate controls is important to reduce and prevent health & safety and environment risks. A well-planned storage area allows easy movement and protection of chemicals during handling and use. Storage conditions should be based on the recommended storage practices listed on safety data sheets (SDS) and/or storage practices recommended by chemical suppliers. Additionally, all legal requirements related to the storage of chemicals should be complied with. 

Chemical storage areas and controls should be designed and appropriate for the specific types, quantities, and hazards of chemicals used on site. The list below provides recommended good practices for chemical storage that should be considered and implemented when appropriate: 

  • Separate chemical products based on their physical state and inherent properties. Solid and liquid chemicals should be stored separately. 
  • Ensure proper compatibility of chemicals as per information in the SDS (section 10). 
  • Provide proper ventilation, lighting and controlled temperature and humidity wherever required for storage of chemical products sensitive to these parameters.
  • Make floors of storage area impermeable to liquids and non-slippery. They should be easy to clean and resistant to acids and organic solvents.
  • Plan the layout to accommodate all chemical containers with enough space for movement and easy accessibility to the containers. 
  • Use color markings on the floor for designated walk areas and exit glow signs. 
  • If required, ensure emergency exits are available and kept clear of obstacles, and that the exit door opens outwards with a push-bar handle. 
  • Do a regular clean-out of expired chemical products, spill wastage and used containers. 
  • Mark a designated area with a red (or the local required color) border for non-conformant chemical products that are to be returned to the chemical supplier. Keep relevant documents in the vicinity. 
  • Keep the requisite amount of compatible fire- extinguishers in the stores and install smoke-detection alarms or sprinkler systems. 
  • Ensure secondary containment for containers. At a minimum, the capacity of secondary containment must meet applicable legal requirements based on chemical volume and container size and should be 110% of the original (primary) container(s).
  • Gas cylinders should be stored in an upright position and in a separate location. The stored cylinders should be secured. LPG cylinders should be protected from direct sunlight and separated from flammable, combustible or oxidizing chemicals or other compressed gas cylinders. 
  • Chemical products stored outdoors should have a proper cover to protect them from sun and rain and high temperatures. The area should be fenced to prevent unauthorized access. The flooring of such storage areas should be secured to prevent any leakages from contaminating the soil or water. 
  • Access to chemical stores should be given only to authorized staff and their names and photographs should be displayed near the main entrance door. 
  • Keep a spill control kit to contain spillages. 
  • Keep a box file of all the SDS of chemical products stored near the Stores main entrance door. The file should be indexed properly with the names of the Chemical Formulator and products. The SDS file should be accessible to all staff. SDS can also be put in plastic folders and displayed on a notice board near the stores. 
  • Install warning signage at key locations of stores to keep staff informed of risks. 
  • Prepare “Chemical Safety Cards” to convey important information on hazards and First-Aid/emergency response measures in a pictorial manner for a quick understanding by staff handling chemical products. 

Resources:

Chemstorage Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have well marked, designated chemical storage areas for all chemicals stored onsite and the storage areas have all of the controls listed in the sub question. 

Documentation Required:

  • Documentation that demonstrates the facility controls in place in chemical storage areas and these are appropriately maintained. This may include: 
    • Facility map showing the location of chemical storage areas. 
    • Floor layout plan of chemical storage areas, specifying categorization and storage location of different types of chemicals. 
    • Standard operating procedures for chemical storage and labelling. 
    • Examples of storage in/out logs, FEFO records, specifying date of arrival at storage, lot number, and date of dispatch to production, etc.)
    • Audits/inspections checklists or reports of chemical storage areas. 

Interview Questions to Ask:

  • Staff responsible for chemicals management understand the hazards and controls associated with chemical storage areas and can explain the facility’s procedures to ensure controls are in place and properly maintained.  
  • Relevant staff (management and employees) understand the controls in place and their responsibilities for maintaining chemical storage areas. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that the listed controls are in place and being properly maintained (e.g., incompatible chemicals are stored separately or at safe distances, stored chemicals have appropriate labels, secondary containment is in place and of sufficient size, protections are in place for flammable chemicals, required PPE is present and being used, etc.)

Partial Points:

  • Partial points will be awarded for facilities that have well marked, designated chemical storage areas for all chemicals stored onsite and the storage areas have some, but not all of the controls listed in the sub question. 

Chemsubstorage

Does your facility have well marked sub-storage areas? (Ref ID: chemsubstorage)

Answer Yes if: Your facility has designated, well marked sub-storage areas for chemicals.

Answer Not Applicable if: Your facility does not have sub-storage areas.

Note: Sub-storage areas are defined as temporary or permanent areas used for storage and handling of chemicals during their use in production processes that are separate from the facility’s main bulk chemical storage area(s). This includes temporary storage areas used for loading, QA inspections, etc.

If you select Yes, you will be asked the following sub question(s) to indicate which practices are in place in chemical sub-storage areas at the facility:

  • The chemical storage area is ventilated, dry and protected from the weather.
  • Temporary storage containers are closed and labelled with contents, lot, and hazard class.
  • The chemical storage area is clearly marked.
  • Floor in the storage area is solid and non-porous, there are no water drains that the liquid could spill into, and there is no evidence of spilled liquid. 
  • Secondary containment is available for liquid chemicals in tanks, drums, and temporary containers (where applicable) to ensure no unintended releases occur.
    • Note: The need for secondary containment must be based on a formal risk assessment that considers the risk and potential impact of spills and must also meet applicable legal requirements based on chemical volume and container size. 
  • Incompatible substances (such as strong acids and strong bases) are stored separately. 
  • Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting.
  • First Expiry, First Out (FEFO). 
  • Health and safety measures are in place (such as PPE, etc).

Suggested Uploads:

  • Facility map showing the location of chemical sub-storage areas. 
  • Floor layout plan of chemical sub-storage areas, specifying categorization and storage location of different types of chemicals. 
  • Standard operating procedures for chemical storage and labelling (including sub-storage areas). 
  • Example photos of chemical sub-storage areas and controls
  • Examples of storage in/out logs, FEFO records, specifying date of arrival at sub-storage, lot number, and date of dispatch to production, etc.)
  • Audits/inspections checklists or reports of chemical sub-storage areas. 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that all sub-storage areas are well-marked and have sufficient controls to prevent contamination and safety risks.

Technical Guidance:

Proper chemical storage with appropriate controls is important to reduce and prevent health & safety and environment risks. This also applies to sub-storage areas which are defined as temporary or permanent areas used for storage and handling of chemicals during their use in production processes that are separate from the facility’s main bulk chemical storage area(s). This includes temporary storage areas used for loading, QA inspections, etc. 

Implementing effective chemical storage practices in sub-storage areas can contribute to minimizing the risk of environmental contamination and maintaining a safe work environment. Storage conditions should be based on the recommended storage practices listed on safety data sheets (SDS) and/or storage practices recommended by chemical suppliers. Additionally, all legal requirements related to the storage of chemicals should be complied with. 

Chemical sub-storage areas and controls should be designed and appropriate for the specific types, quantities, and hazards of chemicals used on site. For a detailed list of recommended good practices for chemical storage that should be considered and implemented when appropriate, refer to the Technical Guidance section for the FEM question above on chemical storage. 

Resources:

Chemsubstorage Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have well marked chemical sub-storage areas for all sub-storage areas onsite and the sub-storage areas have all of the controls listed in the sub question. 

Documentation Required:

  • Documentation that demonstrates the facility controls in place in chemical sub-storage areas and these are appropriately maintained. This may include: 
    • Facility map showing the location of chemical sub-storage areas. 
    • Floor layout plan of chemical sub-storage areas, specifying categorization and storage location of different types of chemicals. 
    • Standard operating procedures for chemical storage and labelling (including sub-storage). 
    • Examples of storage in/out logs, FEFO records, specifying date of arrival at sub-storage, lot number, and date of dispatch to production, etc.)
    • Audits/inspections checklists or reports of chemical sub-storage areas. 

Interview Questions to Ask:

  • Staff responsible for chemicals management understand the hazards and controls associated with chemical sub-storage areas and can explain the facility’s procedures to ensure controls are in place and properly maintained.  
  • Relevant staff (management and employees) understand the controls in place and their responsibilities for maintaining chemical sub-storage areas. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that the listed controls are in place and being properly maintained (e.g., incompatible chemicals are stored separately or at safe distances, stored chemicals have appropriate labels, secondary containment is in place and of sufficient size, protections are in place for flammable chemicals, required PPE is present and being used, etc.)

Partial Points:

  • Partial points will be awarded for facilities that have well marked chemical sub-storage areas in all sub-storage areas onsite and the sub-storage areas have some, but not all of the controls listed in the sub question. 

Chemtrainingr

Does your facility train employees responsible for the chemical management system on Restricted Substance Lists (RSLs)?  (Ref ID: chemtrainingr)

Answer Yes if: Your facility has a designated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees with training records and/or material.

Answer Partial Yes if: Your facility has a designated person(s) responsible for RSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on RSL.

Note: RSL training must be provided by a knowledgeable and qualified person (internally or externally) who understands RSL requirements and procedures in place at the facility.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please describe the RSL trainings conducted in the reporting year.
  • If yes, how many employees were trained?
  • If yes, how frequently do you train your employees?
    • Do you evaluate your employees after the training?
    • How do you evaluate the knowledge of your employees after the training?
  • Please upload documentation, if available

Suggested Uploads:

  • Documentation that demonstrates the facility has conducted training on RSL for relevant employees (e.g., RSL training records, training material, post-training evaluation records)
  • Documented job description for staff responsible for RSL management and compliance.

What is the intent of the question?

The intent of this question is to ensure that facilities have knowledgeable staff that are trained on RSL management and compliance. 

Technical Guidance:

To effectively manage and implement RSL compliance programs, it is important to ensure that staff have the appropriate knowledge and training on RSL management and compliance. RSL management requires specific knowledge about applicable RSL requirements and procedures to ensure compliance. 

Facilities should ensure that there are dedicated roles and responsibilities for staff who manage RSL compliance. This provides facilities with the needed resources to oversee RSL program implementation and ensure that relevant staff are trained on RSL requirements and procedures at the facility. 

RSL training requirements can vary based on facility type and operations or products, however there are some key aspects that should be include in RSL training including, but not limited to:

  • All applicable RSL requirements at the facility
  • The facilities RSL management policy and procedures including procedures to investigate the root cause of RSL failures.
  • Chemical procurement and screening with respect to RSL
  • Areas of specific risks to RSL compliance at the facility.

Having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of RSL trainings and knowledge retention.

Resources:

Chemtrainingr Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be rewarded to facilities that have a designated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees with training records and/or material.

Documentation Required:

  • Documentation that demonstrates the facility has a dedicated person(s) responsible for RSL compliance who is knowledgeable on RSL, and documented training is provided to relevant employees. 
    • Documented job description and qualifications for staff responsible for RSL management and compliance 
    • RSL training records and/or training material
    • Post-training evaluation records
    • RSL management policy and procedures

Interview Questions to Ask:

  • Staff responsible for managing RSL at the facility can demonstrate appropriate knowledge of RSL.
  • Staff responsible for the facility’s RSL training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
  • Employees who have received the trainings are aware of the content of the training.

Inspection - Things to Physically Look For 

  • Observations onsite indicate that the facility’s RSL program is being managed by trained and knowledgeable staff.

Partial Points:

Partial points will be awarded to facilities that have a designated person(s) responsible for RSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on RSL.

Chemtrainingm

Does your facility train employees responsible for the chemical management system on Manufacturing Restricted Substance Lists (MRSLs)? (Ref ID: chemtrainingm)

Answer Yes if: Your facility has a designated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees with training records and/or material.

Answer Partial Yes if: Your facility designated a person(s) responsible for MRSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on MRSL.

Note: MRSL training must be provided by a knowledgeable and qualified person (internally or externally) who understands MRSL requirements and procedures in place at the facility.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please describe the MRSL trainings conducted in the reporting year.
  • If yes, how many employees were trained?
  • If yes, how frequently do you train your employees?
    • Do you evaluate your employees after the training?
    • How do you evaluate the knowledge of your employees after the training?
  • Please upload documentation, if available

Suggested Uploads:

  • Documentation that demonstrates the facility has conducted training on MRSL for relevant employees (e.g., MRSL training records, training material, post-training evaluation records)
  • Documented job description for staff responsible for MRSL management and compliance.

What is the intent of the question?

The intent of this question is to ensure that facilities have knowledgeable staff that are trained on MRSL management and compliance. 

Technical Guidance:

All facilities should ban non-compliant hazardous chemicals from use in the facility as required by laws and regulations and/or customers’ requirements (e.g., the ZDHC Manufacturing Restricted Substance List (MRSL)). 

To effectively manage and implement MRSL compliance programs, it is important to ensure that staff have the appropriate knowledge and training on MRSL management and compliance. MRSL management requires specific knowledge about applicable MRSL requirements and procedures to ensure compliance. 

Facilities should ensure that there are dedicated roles and responsibilities for staff who manage MRSL compliance. This provides facilities with the needed resources to oversee MRSL program implementation and ensure that relevant staff are trained on MRSL requirements and procedures at the facility. 

MRSL training requirements can vary based on facility type and operations or products for example facilities that use chemicals in production processes typically use a larger number of chemicals on-site and may require a more complex MRSL manage program that staff need be trained on as opposed to facilities that only use chemicals for facility operations or tooling.  However, there are some key aspects that should be include in MRSL training including, but not limited to:

  • All applicable MRSL requirements at the facility
  • The facilities MRSL management policy and procedures including procedures to investigate the root cause of MRSL non-conformances that are identified.
  • Chemical procurement and screening with respect to MRSL
  • Areas of specific risks to MRSL compliance at the facility.

Having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of MRSL trainings and knowledge retention.

Resources:

Chemtrainingm Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be rewarded to facilities that have a designated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees with training records and/or material.

Documentation Required:

  • Documentation that demonstrates the facility has a dedicated person(s) responsible for MRSL compliance who is knowledgeable on MRSL, and documented training is provided to relevant employees. 
    • Documented job description and qualifications for staff responsible for MRSL management and compliance 
    • MRSL training records and/or training material
    • Post-training evaluation records
    • MRSL management policy and procedures

Interview Questions to Ask:

  • Staff responsible for managing MRSL at the facility can demonstrate appropriate knowledge of MRSL.
  • Staff responsible for the facility’s MRSL training program can explain how training is provided and if applicable, how the effectiveness of training is evaluated.
  • Employees who have received the trainings are aware of the content of the training.

Inspection - Things to Physically Look For 

  • Observations onsite indicate that the facility’s MRSL program is being managed by trained and knowledgeable staff.

Partial Points:

  • Partial points will be awarded to facilities that have a designated person(s) responsible for MRSL compliance and training is provided to relevant employees, but it is not documented with training records and/or material or responsible staff are not knowledgeable on MRSL.

Chemfailresolution

Does your facility have an established process to investigate and resolve a potential RSL failure? (Ref ID: chemfailresolution)

Answer Yes if: Your facility has a documented process for investigating and resolving RSL failures.

If you select Yes, you will be asked the following sub question(s):

  • If yes, does this process cover steps such as a root cause analysis, steps for a corrective action plan and documentation procedure of such activities?
  • If yes, does your facility have a Standard Operating Procedure (SOP) to resolve or prevent such a failure?
    • Please upload your SOP

Suggested Uploads:

  • RSL management procedures that include the RSL failure investigation process.
  • Examples of documentation from past RSL failure investigations (e.g., failure investigation/resolution form)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that a process is in place to investigate and resolve any RSL failures.

Technical Guidance:

The goal of an RSL compliance program should focus on ensuring that chemicals and/or materials that are not RSL compliant or could result in RSL failures are not permitted to be used at the facility, however, if an RSL failure does occur, it is important to have a formal process to investigate and resolve RSL failures. 

The cause of individual RSL failures can vary and having procedures to conduct a systematic investigation will help facilities identify the cause of the failure and address any gaps in their RSL management program.  The investigation process should also include procedures for conducting a root cause analysis of the failure to prevent failures in the future.  

When failures do occur, facilities should initiate an investigation and resolution process that includes, but is not limited to the key aspects listed below:    

  • Stop production of the noncompliant material/product and quarantine and potentially non-compliance materials/products. 
  • Ensure that any non-compliant material/products are not shipped from the facility.
  • Evaluate the scope of the issue and the current materials/processes that produced the failure. 
  • Conduct a root cause investigation to identify the cause of the failure. 
    • Engage with material/chemical suppliers as needed to help identify the root causes. 
  • Evaluate the need to update RSL management procedures to ensure the issue does not happen again. 

Resources:

Chemfailresolution Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required: 

  • Documentation that shows the facility has documented procedures to investigate and resolve RSL failures. This may include:
    • RSL policy and/or management procedures that include RSL failure investigation process.
    • Records of historical RSL failure investigations (e.g., failure investigation/resolution form)

Interview Questions to Ask: 

  • Staff responsible for RSL management can explain the facility’s RSL failure investigation and resolution procedures. 

Inspection - Things to Physically Look For:

  • Staff responsible for RSL failure investigation demonstrate sufficient knowledge of RSL and RSL failure investigation/resolution.

Partial Points: N/A

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