Higg FEM 2025: Get to know the Chemical Management section webinar (1 hr 44m)

Hello, and welcome to today's Higg FEM twenty twenty five chemicals management session. My name is Leah Jaggars, and I am the senior education manager here at Worldly. Today, we are going to discuss the chemicals section and how to report your data. Before we get started, here are some logistics for the session. All attendees are muted for the duration of the webinar. There will be time for questions at the end of the presentation, so please submit your questions into the Q and A box as you think of them so that they are captured. Any questions that we cannot get to during the session will be answered in a follow-up email as long as they are submitted through the Q and A box. This session is being recorded, and I will share the recording with all registrants afterwards along with the Q and A report. We have simultaneous interpretation available in Chinese and Vietnamese today, so please select your preferred language through the interpretation icon. There are also machine generated captions in multiple languages available through the CC icon. Here is the agenda for today. First, we'll review a quick overview of the Higg FEM. Then we'll review key definitions in the chemical section. Then we'll go over all of the questions in this section, so there's a lot to get through. Then we'll introduce the Beehive and how it can help you manage your chemical inventory. Finally, we'll review additional resources available to you and have time for questions and answers. With that, let's get into it. Before we get into the details of Higg FEM and the and the chemical section, it's helpful to understand who Cascale and Worldly are and our relationship to the Higg Index, which includes the Higg FEM assessment. Cascale is the global nonprofit alliance for the consumer goods industry who owns and develops the Higg Index, which is exclusively available on the Worldly platform, the industry's leading sustainability data insights platform. The Higg Index is a set of tools that assess social and environmental performance across various aspects, such as water use, carbon emissions, and labor conditions. There is a network of over forty thousand Higg index users today, which includes brands, retailers, manufacturers, governments, and NGOs. Together, Cascale and Worldly provide regular updates to the Higg index to ensure they evolve to meet your needs. In short, Cascale develops the underpinning logic and questions of the Higg FEM, and Worldly is the software platform that supports data collection and analysis for the assessment. One of Cascale's partner organizations, the Zero Discharge of Hazardous Chemicals Group, or ZDHC, leads the fashion industry to eliminate harmful chemicals from its global supply chain by building the foundation for more sustainable manufacturing to protect workers, consumers, and our planet's ecosystems. ZDHC has developed a variety of chemical guidelines and resources that are referenced throughout the Higg FEM guidance. For more information on ZDHC, its initiatives, and resources, we encourage you to visit the links throughout the guidance or visit their website linked in the resources section. So this should be available to you. I just wanna make sure that you guys can access that really quick. So I'm just linking that right now. All of the links are available in this resources section that I'm speaking to during this session today. However, I will also be sending all of these links to you via email afterwards. So don't worry if you miss anything, but that resources section also has the slides. So if you would like to see the slides and follow along today, there's also the HowtoHigg guidance and a few other helpful links as well. Now let's review the FEM overall briefly before we dive into the chemicals section. The Higg FEM is a transformative tool developed by our partners at Cascale used to assess the environmental impact of product manufacturing at facilities. The Higg FEM paints a clear picture of a facility's environmental impacts. The FEM is an assessment or questionnaire that covers the following topics, environmental management systems, energy use and greenhouse gas, water use, wastewater, air emissions, waste management, and chemical management. Cascale provides detailed guidance on each section and question in the assessment where you can learn more. Each of these sections helps you understand how your facility impacts your environment and also provides ideas for improvements in different programs you can implement or participate in to improve your performance and engagement with sustainable practices. The link to the updated PDF, how to Higg guides in multiple languages are linked in the resources where you can read more about each section, guidance for each question, and more. The Higg FEM is a combination of qualitative and quantitative data for a comprehensive overview of your environmental performance. Qualitative data in the FEM includes the environmental management systems and, today's section, chemical management section, along with qualitative questions in the other sections. Quantitative data includes numerical values for energy, water, waste, wastewater, and air emissions, as well as baselines and targets that you may have. Within each section of the FEM, there are applicability questions and then three levels of questions. Applicability questions are questions you answer before the main section before the main section questions so that the assessment configures the questions to those that are relevant to your facility. For example, if you do not use production chemicals, you won't be asked questions related to that. After you answer applicability questions, you move into level one questions. Level one contains questions around awareness and basic systems. Level two contains questions around baselines, targets, and improvements. Level three contains questions around leading aspirational practices. If you do not achieve level one, you are not required to answer level two and three, but you may optionally open those levels if you wish to answer additional questions voluntarily or as a requirement of a business partner. The chemical management section is divided into three levels. Level one has eighteen questions and focuses on the basics, inventory and safety data sheets. Level two has six questions and asks you to assess chemical hazards and look for safer substitutes. Level three has seven questions and asks you if you have a full substitution program and demonstrate leadership. All questions may have additional sub questions associated with them. We will get more into what the levels contain further in the session. Now that we have learned a little bit more about what the FEM contains and the general components of the assessment, here is an overview of the FEM process. First, you will review the assessment questions and gather data from various sources. This is something that you can start now, especially if this is your first time completing the assessment. Also, during this time, you can identify any gaps in data or processes that you can mitigate and optionally arrange additional training. The Higg FEM training bodies is also linked in the resources. Then step two is completing the self assessment in the Worldly platform. If you if you previously completed an FEM, you can roll forward previous responses to questions that don't really change like your site information. If you use facility data manager, you can also import twelve months of quant quantitative data into your FEM to save time. Either way, you can review your data for accuracy and update anything you import if you identify errors. Once you have completed the assessment, you will post it in the platform. Please note that posting is not available until January as you need the full twelve months of data from twenty twenty five. The next step would be if you are getting your assessment verified to arrange verification with an approved verification body. The link to a verification body list is also linked in the resources. Then you can share your self assessment or verified assessment with your business partners on the platform. Check with your business partners for requirements and deadlines. Finally, use Insights Hub to understand where your facility is doing well and where you can improve. Then during the year, you can use this information and analysis to plan changes and improvements and repeat the cycle. Now that we have reviewed what the Higg FEM includes, let's discuss some key concepts and definitions that will help you understand the questions being asked in this section. The first definition is the global harmonized system. The United Nations Economic Commission for Europe, or UNECE, developed the global harmonized system of classification and labeling of chemicals, or GHS. The GHS is an international system for classifying and labeling chemicals in a consistent and clear way. It helps ensure that people all over the world understand chemical hazards through standard symbols, warning labels, and safety information, no matter what country they are in. Some key features of the GHS include standard pictograms or symbols for hazards, signal words like danger or warning, hazard statements that explain the risk, for example, causes skin irritation, safety data sheets or SDSs with clear chemical safety details. An example of use in facilities is a factory using cleaning chemicals will label the containers with GHS symbols so all workers know the hazards and how to stay safe. To learn more about the GHS, please see the link that I'm sharing in the chat now. I don't think I ended up actually sharing that in the resources, so that's in the chat. The next concept is a safety data sheet or SDS is a detailed document that provides important safety information about a chemical. It explains what the chemical is, the hazards it may pose, and how to use, store, and handle it safely. Why does this matter? SDSs help workers and emergency responders protect themselves and others when using chemicals. They are essential for preventing accidents and ensuring workplace safety. Some key contents of an SDS is the chemical name and ingredients, hazard identification, safe handling and storage instructions, what to do in an emergency, personal protective equipment or PPE recommendations. Please note, SDSs must be available in local language of workers. They are required by laws in many countries and must follow formats such as those defined by GHS. An example for use in a facility would be before using a cleaning solvent, a worker reads the SDS to learn about wearing gloves, working in a ventilated area, and what to do if it spills. Manufactured, Manufacturing Restricted Substances Lists, or MRSL. An MRSL is a list of chemical substances that should not be used at any stage of manufacturing, from spinning and dying to finishing, because they are harmful to people or the environment. This applies to all chemical inputs, not just what ends up in the final product. Typically, these are not issued by governments and are voluntary industry standards developed by organizations or brand coalitions. For example, ZDHC or BlueSign. There is no universal legal MRSL. They support compliance with environmental and occupational safety laws by promoting safer manufacturing. An example of use in a facility would be before buying a new dye or detergent, a facility checks whether it meets MRSL requirements to ensure it won't introduce hazardous chemicals into the process. On the other hand, a restricted substances list, or RSL, is a list of chemical substances that are not allowed to be present in the final product because they can be harmful to people or the environment. The focus is on ensuring the end product is safe for consumers. Many RSLs are directly based on government laws and regulations. They translate translate legal limits from legislation such as EU's REACH, the US's CPSIA, South Korea's K REACH, Turkey's KKDIK, and India's ICMSR, as well as China's GB into actionable lists used by brands to control chemical content and final products. Private or brand specific often combine several of these laws into one global list to help their suppliers comply across regions. For example, I'm sharing a couple of options in the chat. These are also in the guidance as well, but I don't think I listed those in the resources section. I had a little bit of a limit. So there's two option two examples is the Affirm RSL. This is created by a coalition of apparel and footwear brands based on global legal limits or OEKO-TEX standard one hundred, which is a voluntary certification with chemical restrictions tied to legal frameworks along with ZDHC and l among others. So an example for use in facilities is before shipping garments, a brand test samples to make sure they meet RSL requirements and are free of restricted substances. The next concept is chemical use types. So the first option is facilities that use chemicals in production refers to chemicals used in processes to make a product. For example, chemicals used for dyeing fabric. A facility that uses chemicals in operations only refers to chemicals that are not used directly in the production processes, but are used in equipment or processes utilized to operate basic energy conversion or wastewater management within the facility. For example, chemicals used in on-site wastewater treatment. Facility that uses chemicals in maintenance, tooling, or equipment refers to chemicals that are not used directly in the production process but are used for regular maintenance of facility equipment. For example, chemicals used for equipment maintenance, such as machine oil. And finally, a facility that uses spot cleaners. This refers to chemicals used to remove contaminated spots or nonpermanent stains from materials or final products. For example, garment spot cleaning, solvents to remove grease stains, etcetera. Now that we have reviewed key definitions and concepts, let's review applicability questions in the chemical section. A reminder about applicability questions. These are designed to help the assessment narrow down the questions that you are required to answer based on if they are applicable to your facility. These questions also help guide you in answering subsequent questions. The first applicability question is, select all of the processes performed at your facility. You will answer yes or no to having the following processes at your facility. In the interest of time, I'm not going to read all of them, but you can find the full list in the guidance, as well as when you are completing the assessment. These questions help the system determine which questions need to be asked in this section. Some examples of processes include dyeing, printing, fiber extrusion, leather tanning, plastic work, metal work, laser cutting, powder coating, soldering, spot cleaners, etcetera. But, again, you can find it in the full guidance, which is in the resources, as well as, the list that you see here is in the slides. The next applicability question is a yes/no question. Does your facility use commodity chemicals? Commodity chemicals are defined in the FEM as single substances or chemical compounds whose chemical structure is well known, and their use is to create conditions for a process, such as acid, alkaline, etcetera. They are produced in high volumes with low price and do not have a brand name, but are known by their common chemical names. Examples of commodity chemicals include, but are not limited to, sulfuric acid, acetone, hydrogen peroxide, sodium hydroxide, also known as lye or caustic soda, common salt, or salt, etcetera. The next applicability question is, does your facility only use minimal chemicals? For example, liquid and gaseous fuels, over the counter chemicals, or maintenance chemicals for factory upkeep on-site. A facility is considered to have minimal chemical use if it only uses a small set of basic chemicals that are not related to production processes. These include liquid fuels like diesel or gasoline, gaseous fuels like natural gas or LPG, over the counter chemicals like common surface cleaners or disinfectants, cooking oil, dish detergent, paint for main, facility maintenance, for example, for walls or floors, etcetera, or floor cleaners. When to select yes in the Higg FEM is only if your facility uses exclusively the types of minimal chemicals listed above and no others for daily operations. So when to select no is if your facility uses any additional chemicals such as dyes, solvents, spot cleaners, finishing agents, or wastewater treatment chemicals, etcetera, for production or facility systems, then you must select no. The system will also warn you if you select no to this question, but have indicated that you have processes at your facility that inherently require chemicals use. Please note that the amount of chemicals does not matter here. If you use any amount of chemicals outside these specific parameters, you would answer no to this question. This question was also the highest marked and accurate last year during verification. Read the guidance for this question carefully to ensure that you are answering correctly. Incorrectly answering this question can have downstream consequences to your scoring because it is an applicability question. To reinforce this concept, let's do a quick knowledge check, and let me launch a quick poll. So you should see one question on your screen. The question is, a facility dyes garments, has on-site wastewater treatment, uses machine oil to maintain some equipment. Can this facility claim minimal chemical use? The options are yes, no, or not enough information. Alright. Little bit of a mixed bag. I'm gonna go ahead and end the quiz. So the correct answer is no. So the facility dyes garments that inherently has some chemicals that are related to production processes. They have on-site wastewater treatment, which inherently has chemicals related to operations, and they also use machine oil to maintain equipment. So those that's going to be maintenance and equipment chemicals. So if you answered yes, no worries. Now you know. But just know that unless it falls into that very specific narrow box for minimal chemical use, if there's any other chemicals outside of that box, you would answer no to minimal chemical use. Alright. Hopefully, that helps to kind of reinforce that, and thank you for participating. Alright. The next applicability question is, does your facility implement an MRSL? This applicability questions asks if you currently implement an MRSL. We defined MRSL earlier. If you answer yes, you'll be able to choose from the following options, a customer's MRSL, ZDHC MRSL, or blue sign at BSSL, or other. And then you'll have the option to fill in the blank. The next applicability question is, what kind of chemicals does your facility use? This applicability question is asked if minimal chemical use is answered no. As we previously defined, you will have the option to select all that apply from the following options. Use production chemicals, operation chemicals, maintenance, tooling, equipment chemicals, or spot cleaner chemicals. This was the second most marked and accurate question in the chemical section last year, so make sure you review the definitions carefully when answering this question. And, again, I'm gonna quiz you. So I'm launching a quick quiz. So you should see on screen, I listed the definitions of the different segments or or the different options that you can select. And the question is, a facility uses solvents to spot clean stains on garments before packaging and uses machine oil for their sewing machines and other equipment along with over the counter cleaners for facility maintenance. Which option or options should the facility choose when responding to the chemical use type question? One option is production chemicals, minimal chemical use, operations chemicals, or spot cleaners and maintenance slash tooling slash equipment chemicals. And I'm gonna go ahead and end the poll in the interest of time. So excellent. Let me go ahead and share those results. So you should see the correct answer was spot cleaners and maintenance slash tooling slash equipment chemicals. Obviously, given the minimal information I gave you, you know, maybe they do also have production chemicals or other operations chemicals just depending on, you know, other information about them. They would not fall into the minimal chemical use category in this situation because they do have those other chemical categories and use types that they're using. So, hopefully, that helps. And excellent. Thank you so much for participating. Alright. So now let us go over all of the questions in the chemical management section starting with level one. Level one is worth twenty five percent of the total section points. Throughout this portion of the session, I will also highlight the top questions marked inaccurate during verification in last year's cadence. These will be marked with yellow warning icon, and I will also point them out as we go. So the first question sets the foundation for the entire chemical management section. Does your facility have a written chemical management system or CMS policy? From the FEM's perspective, this policy shows whether chemical management at your facility is intentional and structured. The CMS policy does not need to be long or complex. A one or two page document is sufficient as long as it clearly commits to legal compliance, safe chemical use, and training. Facilities that use chemicals in production have additional expectations. In those cases, the policy must also address traceability, sustainable chemical management practices, and continuous improvement. Excuse me. A common verification issue is that a policy exists but does not match reality. For example, it only covers production chemicals when maintenance and operation chemicals are clearly used on-site. If you're not at yes yet, start simple. Assign responsibility, draft a basic policy using existing EHS or EMS language, and get it approved. This single document supports many other chemicals questions later in the assessment. The next question is, have you assigned the responsibility of implementing and maintaining the CMS to a team member or staff member? This question moves from policy to people. From the FEM's perspective, a CMS policy without clear ownership is a major weakness. The FEM does not require a specific job title. What matters is that responsibility for implementing and maintaining the CMS is clearly assigned and documented. Verifiers will look for two things here. First, that responsibility is written down, for example, in a job description, procedure, or policy. And second, that the assigned staff have the competency and authority to manage chemicals. A common issue during verification is that responsibility is understood informally, but not documented. If it is not written, verifiers cannot confirm it. Another issue is assigning responsibility to someone without training or decision making authority. Chemical management often requires coordination with purchasing, production, and EHS teams. If you cannot answer yes today, the fastest step forward is to name a CMS owner, document their role, and ensure they receive basic chemical management training. The next question is, does your facility have a chemical purchasing policy? This question is about preventing risk at the source. A chemical purchasing policy shows whether your facility controls which chemicals are allowed on-site before they are bought and used. The FEM does not require a standalone document. This policy can be part of an existing procurement, EHS, or EMS procedure, as long as chemical approval requirements are clearly documented. At minimum, the policy should explain how chemicals are reviewed before purchase, including legal compliance, health and safety considerations, and any customer or industry requirements. A common verification issue is facilities saying we only buy approved chemicals, but having no written policy explaining how approval happens. Without documentation, that is usually marked as no or partial yes. If you're not at yes yet, start by adding basic chemical screening requirements to your existing purchasing process and requiring approval before new chemicals are introduced. The next question is about visibility. You cannot effectively manage chemical risk if you don't know exactly which chemicals are used at your facility and where they come from. The FEM does not require a specific format for the chemical inventory list. A simple Excel file is acceptable as long as it is complete and up to date. The inventory must include all chemicals used on-site, not just production chemicals. This includes maintenance chemicals, cleaning agents, lubricants, spot cleaners, and any other chemicals present at the facility. A common verification issue is that the inventory lists chemical names but not suppliers. Supplier information is important because it supports traceability and MRSL or RSL checks later in the assessment. Verifiers will often cross check your inventory against purchasing records and what they physically observe on-site. If you cannot answer yes today, start by walking the facility, listing all chemicals currently on-site, and recording the supplier for each product. Assign one person to keep the list updated when chemicals change. And I'm listing a, link as well as a note just for some specific guidance, in the chat. So there's a link to a couple different templates for chemical inventory lists as well as the GHS classification for labeling. And then there's a note about if your facility uses subcontractors, so be sure to read that. That's also in the guidance as well in the translated guidance. But if you do use subcontractors, there's a little bit of nuance included in that question. The next question builds directly on the previous one. So it's not just about having chemical inventory list. It's about whether that list contains enough information to actually manage risk. The FEM asks you to confirm which data points are included in your CIL, such as chemical product name, supplier, intended use, storage location, and hazard information. These details are typically available from the safety data sheet. A common verification issue is partially completed inventories. For example, facilities may list chemical names and suppliers, but omit hazard classification or usage information. In those cases, verifiers often mark this question as partial yes. Verifiers will also check whether the information in the CIL aligns with SDS and what they observe on-site. Inconsistencies raise questions about whether the CMS is being actively maintained. If you cannot answer yes today, the easiest place to start is reviewing your existing inventory and filling in missing fields using information already available in the safety data sheet. Completing these fields strengthens multiple chemical questions at once. The next question is, does your facility make safety data sheet or SDSs available to all employees for all chemicals used? This question focuses on access, not just possession. The FEM requires that safety data sheets are available to employees for all chemicals used on-site. This includes production, maintenance, cleaning, and other operational chemicals. SGS can be stored digitally or physically, but they must be easy for workers to access in their work areas. They should also be provided in a language that workers can understand. Verifiers may ask employees where SDS are cap kept and how they would find one in an emergency. A common verification issue is missing SDS for maintenance or secondary chemicals or SDS that are outdated and no longer match the chemicals, the chemical products on-site. If you cannot answer yes today, start by requesting SDS from all chemical suppliers, organize them in a clear system, and make sure employees know where and how to access them. The next question focuses on worker competency. It's not enough to have procedures. Employees must understand the chemical risks they face and how to work safely. The FEM expects that all employees who handle chemicals are trained. This includes production workers, maintenance staff, cleaners, and any contractors who directly handle chemicals on-site. Training should cover chemical hazards, safe handling, and PPE requirements, and what to do in case of a spill or emergency. It does not need to be highly technical, but it must be relevant to the chemicals actually used at your facility. A common verification issue is incomplete coverage. For example, training production workers, but not maintenance or cleaning staff. Another issue is undocumented training. If there are no attendance records, verifiers cannot confirm that training occurred. If you cannot answer yes today, start by identifying which roles handle chemicals, delivering basic training using SDS and facility procedures, and documenting who attended and when. The next question is, does your facility have a chemical spill, an emergency response plan that is practiced periodically? This question is about preparedness. The FEM is not asking whether spills occur. It's asking whether your facility is ready if one does. The FEM expects a documented chemical spill and emergency response plan that is relevant to the chemicals used on-site. A generic emergency plan is not sufficient unless chemical spills are clearly included. Verifiers often look for evidence that the plan is practiced, not just written. This can be drills, training sessions, or documented reviews of response procedures. A common verification issue is that a plan exists, but employees who handle chemicals are not aware of it or cannot explain what to do during a spill. Another issue is missing records. Even if drills are informal, some record of training or review helps demonstrate implementation. If you cannot answer yes today, start by documenting simple spill response steps, identifying who to contact in an emergency, and training staff most likely to respond. You can formalize drills over time. The next question is, does your facility have appropriate and operable protective and safety equipment as recommended by the SDS in all areas where chemicals are stored and used? This question focuses on physical controls, whether the right protective equipment and safety equipment is actually in place where chemicals are stored and used. The FEM ties this directly to SDS. Verifiers will check whether the PPE and safety equipment on-site match what is recommended in the SDS for the chemicals on-site. This includes items like gloves, goggles, face shields, aprons, ventilation, spill kits, eye wash stations, and emergency showers, depending on chemical hazards. A common verification issue is that equipment exists, but it is not operable. For example, eyewash stations that are blocked, not functional, or not maintained. Another issue is mismatch. For example, the gloves provided on-site do not meet the SDS requirements for chemical resistance. If you cannot answer yes today, start by reviewing SDS requirements for your chemicals and check that the appropriate equipment is available, functional, and accessible in all relevant areas. The next question is, does your facility have chemical hazard signage and safe handling equipment in the areas of the facility where chemicals are used? This question is about visual communication. This is the assessment looks for clear, visible information that helps workers understand chemical hazards and safe handling practices. Signage should reflect the hazards of chemicals used in each area. For example, flammability, corrosivity, or health hazards. Labels on containers should also be clear and consistent with the SDS. Safe handling equipment includes items like dispensing tools, secondary containment, ventilation, or other controls that reduce exposure during use. A common verification issue is signage that is missing, faded, or not specific to the chemicals used in that area. Another issue is unlabeled secondary containers, such as bottles or buckets that have been filled from larger containers. If you cannot answer yes today, start by posting basic hazard signage in chemical use areas, ensure all containers are labeled, and provide simple handling instructions where chemicals are used. The next question builds on your chemical purchasing policy and focuses specifically on MRSL implementation. Again, an MRSL restricts hazardous substances from being used in any point in the manufacturing process, even if they're not present in the final product. The FEM allows facilities to use different arm MRSLs, such as a customer's MRSL or industry program like ZDHC. What matters is that you show how it is used in purchasing decisions. A common verification issue is facilities answering yes because they are aware of an MRSL but cannot show evidence that chemicals are actually screened before purchase. Verifiers will look for documentation showing MRSL requirements are part of a chemical approval or purchasing process, not just a reference document. If you cannot answer yes today, start by selecting one MRSL and use it consistently for all new production chemicals. Document how screening is done and communicate requirements to chemical suppliers. This question is very similar to the previous MRSL question, but it serves a different purpose. While MRSL focus on chemicals used during manufacturing, RSLs focus on substances restricted in the final product. So, again, the common issues are the same. So in the interest of time, you have this slide and the presentation slides. But just know that the same kind of issues as well as documentation examples apply here. And then for this, the FEM expects that the requirements are considered when selecting and purchasing chemicals that could affect finishing products such as finishing, washing, printing, or coating chemicals. The next question is, does your facility have occupational health and safety programs specific to chemical management? So this question looks at whether chemical risks are explicitly managed within your environmental and occupational health and safety program. The FEM does not require a completely separate system for chemicals, but chemical hazards must be clearly addressed within your EHS program, including risk assessment, controls, and compliance obligations. Verifiers will typically look for evidence that chemical risks have been identified and that procedures exist to manage those risks, such as safe handling, storage, waste management, and emergency response. A common verification issue is having a general EHS program that does not specifically reference chemicals or chemical hazards. In those cases, they may mark this question as partial yes. Another issue is that procedures exist on paper but are not implemented consistently on-site. If you cannot answer yes today, start by identifying the main chemical risks at your facility and incorporate them into existing EHS procedures. Clearly documenting chemical specific risks and controls is often enough to strengthen this response. The next question focuses on where chemicals are stored and whether those locations are clearly defined and appropriate. The FEM expects chemical storage areas to be designated and well marked. This helps prevent improper storage, reduce the risk of spills or exposure, and support emergency response. Verifiers will look for clean signage, defined boundaries, and appropriate storage conditions based on chemical hazards. For example, segregation of incompatible chemicals and secondary containment when needed. A common verification issue is chemicals stored in multiple locations without clear designation, such as chemicals kept in production areas, hallways, or temporary spaces without marking. Another issue is storage areas that exist but are clear not clearly identified or controlled. If you cannot answer yes today, start by identifying all places where chemicals are currently stored, designate them formally, and clearly mark those areas. Even simple signage can significantly improve compliance. This question builds on previous one and focuses on sub storage areas, places where chemicals are kept outside the main chemical storage room. Sub storage areas are commonly found near production lines, printing or dying areas, maintenance workshops, or cleaning supply rooms. Because they are closer to daily operations, they often present higher risk if not properly controlled. So these are also very similar in issue to the last question, except for also another issue is storing excessive quantities in sub storage areas, which increase spill exposure and risk. So the solution again is clear marking and signage. The next question focuses on knowledge and competency within your chemical management system team. The FEM expects that employees responsible for chemical management understand restricted substances lists, especially those tied to customer or regulatory requirements. Verifiers typically will look for evidence that CMS staff have been trained on which RSLs apply, what substances are restricted, and how those requirements affect chemical selection and purchasing. A common verification issue is assuming that RSL knowledge sits only with management or corporate teams while facility staff responsible for chemicals are not trained. Another facility or another issue is informal knowledge without documentation. If there are no training records, verifiers cannot confirm that training occurred. If you cannot answer yes today, start by identifying which RSLs apply to your facility, provide targeted training to CMS staff, and document attendance. This directly supports earlier purchasing and screening questions. This question is closely related to the previous one, but it focuses specifically on MRSL knowledge. We've previously defined MRSLs and the requirements and problems seen in the last question closely mirror this question. Again, you'll have this slide in the presentation for reference, but has very similar content to the last question, but focuses on MRSLs. So let's move on to the next question. The final level one question focuses on response, not prevention. Even strong chemical management systems can experience RSL failures, and the FEM wants to know whether your facility is prepared to respond effectively. The FEM expects a documented process that explains how potential RSL failures are investigated, resolved, and prevented from recurring. This does not require past failures. It requires preparedness. Verifiers will look for a clear process, how issues are identified, who is responsible for investigating them, how root causes are determined, and how corrective actions are tracked. A common verification issue is that facilities say we've never had an RSL failure, but cannot show a process for handling one if it were to occur. Another issue is informal handling of incidents without documentation. Without records, verifiers cannot confirm that issues are properly managed. If you cannot answer yes today, start by documenting a simple investigation and corrective action process. This strengthens your overall CMS and supports readiness for customer or regulatory inquiries. Alright. So that is a lot of information. That's all of level one. So let's get into level two. If you achieve level one, you will automatically move to level two and three. If you did not achieve level one, you may optionally answer level two or three questions if you would like for your own tracking or if requested by a business partner that you shared data with. Please note that if you voluntarily answer additional questions in level two or three without achieving level one, these questions will not contribute to your self assessed score. Now, let us review the questions in level two. Level two is worth fifty percent of the total section points. Also, I do wanna note that because level two and three have not been included in verification yet, I can't include the kind of, like, top missed questions and verification issues, but I do kind of give additional guidance. So the first question in level two, starts to expand chemical management beyond your facilities for walls. The FEM asks whether you engage your subcontractors or contractors on MRSL and RSL requirements when they perform activities that could impact chemical compliance. For example, printing, washing, finishing, or chemical handling on-site. Engagement does not mean full control, but it does mean clear communication and expectations. Verifiers may typically look for evidence that MRSL and RSL requirements are shared and understood, such as contract clauses, written instructions, or training records. If you cannot answer yes today, start by listing contractors that use or handle chemicals, sharing MRSL and RSL requirements with them, and document that communication. Even simple written acknowledgment can support this question. This question shifts the focus upstream, asking whether your facility actively engages chemical suppliers on MRSL and RSL requirements. The requirements and challenges are very similar to the last question, but for your upstream suppliers, so we'll move on for time. But you also have this slide in the presentation file. The next question looks at whether your CMS team has the capability and authority to actually manage chemicals, not just coordinate paperwork. The FEM lists specific capabilities such as improving or rejecting chemicals, stopping unsafe practices, and escalating issues. You should select only this you should only select the options that truly reflect what your CMS team can do in practice. A common issue is over selecting options when authority exists on paper but not in reality. For example, when CMS staff are responsible for chemicals, they cannot stop production or reject a chemical. If you cannot confidently answer yes to all applicable options, start by clarifying who has decision making authority, document those roles, and align responsibility with that authority. Clear escalation pathways strengthen both compliance and day to day operations. The next question is looks for whether the the next question is where the FEM looks for planned improvement, not just compliance. The implementation plan should be practical and connected to your current CMS performance. If you particularly have any partial yes or no answers in level one, those gaps should appear clearly in your plan. The plan doesn't need to be super complex, and I'm sharing a link to a template that Cascale provides for an implementation plan if you need a place to get started. And if you cannot answer yes, start by identifying your biggest CMS gaps, defining a few achievable actions, and assign owners. This demonstrates maturity and readiness for continuous improvement. The next question focuses on traceability, which becomes critical if there is a suspected RSL failure or customer inquiry. The FEM does not require full digital traceability systems. What matters is that your facility can reasonably trace what chemicals were used for a given product, batch, or production run, and link that back to your chemical inventory. If you cannot answer yes today, start by mapping what records you already keep and identifying how production batches can be linked to chemicals used. Even a basic documented process can begin to meet expectations. The next question looks at whether your facility has moved from screening chemicals one by one to proactively sourcing from a positive list or a list of chemicals that are already approved for use. The intent is risk reduction and efficiency. By using a positive list, you reduce the chance of introducing noncompliant or high risk chemicals and make purchasing decisions easier and more consistent. The FEM looks for evidence that the positive list is actually used in practice, not just created. For example, purchasing records should align with the approved list. For example if you cannot answer yes today, start by identifying your most commonly used chemicals, confirm that they meet MRSL and RSL requirements, and document them as an approved list for future purse purchases. And I'm sharing a link to a few different examples of positive lists that you can source from. So that was all of level two questions. So let's move on to level three. Level three is worth twenty five percent of your total section points. This is the first level three question, and it represents a clear step into industry leadership practices. The FEM is asking whether your facility has not only adopted but also implemented an industry recognized chemical management program, most commonly the ZDHC roadmap to zero or supplier to zero program. If you cannot answer yes today, a strong starting point is reviewing the requirements of ZDHC or other programs, assessing your current gaps, and planning a phased approach towards participation. You can also find ZDHC links in the resources section. The next question focuses on how information is shared, not just how it is managed internally. The FDA is asking whether your facility has a documented approach for sharing information about chemical products, chemical waste, and wastewater with relevant stakeholders. This could include brands, chemical formulators, industry initiatives like ZDHC, authorities, or other partners. If you cannot answer yes today, start by identifying which stakeholders you already share information with, for example, sharing FEM with, and documenting a simple process that defines what is shared and under what conditions. The next question looks at collaboration, not just internal decision making. The FEM is asking whether your facility works together with brands or chemical suppliers to evaluate and select safer alternatives to existing chemicals. This often applies to dyes, auxiliaries, finishes, or other chemicals with well known hazards. This question looks for evidence that this assessment is done jointly, not in isolation. This can include supplier led alternative assessments, brand supported trials, or shared evaluation criteria. If you cannot answer yes today, start by identifying one or two priority chemicals of concern and reach out to suppliers or brands to discuss alternatives. Documenting even early stage trials or discussions can support future progress. The next question builds on collaboration and focuses on hazard based analysis, not just substitution. The FEM is asking whether your facility contributes information to evaluations that consider human health and environmental hazards when selecting alternative processes or chemicals. Contribution does not mean leading the analysis. Facilities can contribute by providing data on chemical use, process conditions, exposure, or performance during trials. If you can answer yes today, start by identifying high risk chemicals or processes and begin to participate in discussions or assessments with partners. Sharing operational data is often a strong first step. This question extends the previous one by looking beyond chemical hazards to life cycle impacts, such as energy use, water consumption, waste generation, and emissions associated with alternative practices. So the FEM is not expecting facilities to conduct full life cycle assessments on their own. Instead, it asks whether facilities contribute data or insights that support life cycle based decision making. If you cannot answer yes today, start by identifying what data you already collect and consider how it could support life cycle discussion with partners. This question builds on directly on two earlier concepts, positive lists and supplier engagement, but now implies them across the value chain. The FEM is asking whether your contractors, subcontractors, or upstream suppliers apply source chemicals or actively source chemicals from approved or preferred lists to replace chemicals restricted by RSL requirements. So, again, it's looking for evidence and communication. If you can't answer yes today, start by identifying which contractors or suppliers are relevant, share approved lists with them, and request written confirmation that those lists are being used. The final question extends MRSL control beyond your facility to contractors, subcontractors, and upstream suppliers. The FEM is asking whether these external parties source chemicals from approved or preferred lists that align with MRSL requirements specifically to replace chemicals that are restricted during manufacturing. So very similar to the last question, but around MRSL. So again, if you cannot answer yes, start by focusing on the most critical outsourced processes, share your MRSL based approved list, and request confirmation. That was a lot of information. So now that we've covered the chemical section in-depth, I'd like to introduce our new partners at the BHive. The BHive is a fast, simple, and accurate solution to seamlessly seamless chemical traceability. Smart chemical inventory management, digital data input, and automatic analytics are at your fingertips. The BHive allows you to scan your chemical inventory and automatically compare against different lists and add it to your inventory tracking. Facilities can use the BHive to understand and improve chemical performance to fulfill customer and industry requirements. It's a super easy way to get your chemical inventory list started and compare against different compliance standards. With over three hundred and ten thousand chemicals in the database from five thousand suppliers used in seventy countries and fifteen plus industry partners, such as ZDHC and OEKO-TEX, the BHive combines the strength of a global network with a precision of local expertise, delivering tailored solutions wherever our partners need us. So Worldly and the BHive. The BHive is designed for facilities to achieve best practices in chemical management. While the Beehive is not yet directly integrated into Worldly, it covers all critical elements assessed within the FEM chemical section. And using the BHive helps facilities demonstrate maturity and compliance. This includes, but not limited to, managing robust chemical inventories, managing SDSs, and checking compliance with MRSLs. So the vision for Worldly and the BHive is to build a unified data platform that delivers seamless management intelligence and risk insights for the entire consumer goods value chain. Please reach out to learn more to hello@worldly.io, and I've also linked, BHive, website in the, resources as well. And I'm actually gonna go ahead and skip this section in the interest of time because we are at time, and I want to get to some questions. We are at time. So if my, interpreters have to hop off, I do understand, and I do apologize for folks relying on the interpretation. If we do have those folks hop off, just know that the recording will also have translated subtitles available. What you should be seeing on screen is the platform. So I'm gonna go through Q and A. Just a couple things before I get into that, though. In the upper right hand corner, you can translate the platform into multiple languages. You can also access all of those help resources, here. So the help center has a bunch of resources, written documentation, recordings, videos, learning centers where you can access elearning courses for free. You can chat with our support team, or you can submit a support request. I'm going to go ahead and hop into, my FEM. Just know if you do need to check your subscription, you can do so here. I'll open that in a new tab, actually. So subscriptions for FEM, you'll either want to choose standard or complete. If you choose standard, just make sure you choose FEM twenty twenty five. Also, if you chose to purchase a two year, subscription last year, you may see that you already have it, and then you're good to go. You don't have to purchase it again. So just know that. But then you just make your selection, and then you're good to go. So I'm gonna go ahead and pop into my twenty twenty twenty five assessment and start to answer some questions. Alright. I'll go ahead and answer some questions. And if folks do have to hop off because they have their own, meetings, I will also be sending the recording out as well. So the first question is regarding textile fabrics, what are the relevant standards for fluorinated substances in the new European standards? That is going to be a very specific question that I do not know off the top of my head. So I'm gonna check the guidance and also check with our partners at Cascale for more information on that one and include that in the Q and A report. Alright. The next question is, are all the processes in the applicability section processes that use chemicals? For example, process, laser cutting, welding, etcetera. They did clarify this year. So for example, in some cases, there's specified where it says with chemical use. So if you do happen to do a specific process within here that does not use chemicals, then you can say no. But, typically, those particular actions do use chemical use, so you would say yes to, you know, that process. However, just know that the applicability section is not scored. So this is not something that counts for or against you. It's just used to kind of help cater the the relevant questions to you. Alright. The next question is, do all chemicals like laundry detergent, floor cleaner, dishwashing liquid, and toilet bowl cleaner require an MSDS or material safety data sheet? If it is over the counter, like you buy it at a grocery store or, you know, like a general supply store, you do not necessarily need to have a safety data sheet. I will say a lot of those do come with it, though. For example, toilet bowl cleaner has bleach in it. It will usually have kind of, like, an attached thing on the back of it that pulls out, or it might come in the package. So you might actually have it without knowing it. Best practice would be to keep those so that they're there because those things can be dangerous and if they get in your eyes. But generally speaking, if it falls into that minimal use category, you're not necessarily required to, have, like, that full safety data sheet. But generally speaking, it will probably come with it if it does have any hazards. So if you do receive them, go ahead and keep them. So, hopefully, that answers your question. But, yeah, over the counter stuff just kind of depends on what you receive. Alright. The next question is, do the chemicals used in the fabric testing lab need to be included in a list of chemicals? If your fabric testing lab is on-site, then yes. It does. The next question is, if we share the module to the brand, can they see our CIL? Since the CIL showing all suppliers slash formulators, which we don't want to show the public. So that depends on if you upload it. If you upload the actual list, that will be visible to the verifier. I'm trying to think. I know in FDM, the option is to share attachments. I I believe I want to say that it would be visible to whoever you share data with if they choose to go in there and actually, like, download it. I will double check that, though. I'm not one hundred percent positive, and I don't I don't wanna lead you astray on that. I do believe that is the case, but I will double check because I understand why that would be difficult. It would be shared with the verifier so that they when they're verifying, they can go through, but I'll have to double check on that. Good question. I'll I'll get back to you on that. So I know this is an an anonymous question, but if you registered with your email, you should get the Q and A as a response. So alright. The next question is, if the customer MRSL is the same as ZDHC MRSL, do we still select both options or ZDHC MRSL only? I would select both options because that indicates that, you know, you're using ZDHC and then that you also have a customer request. And so you can just you know, when you answer that question, you get to it. So I'll say yes. So I've got those two. It doesn't ask, like, additional questions related to that. It's just indicating what you currently follow. So it's not like there's additional requirements there. It's just asking, you know, about the MRSL. Do you train people in that? That sort of thing. So, hopefully, that helps. The next question is, can you give an example of chemical risk assessment? So often that chemical risk is indicated in the safety data sheet. So it'll be like, oh, this is a hazard to eyes, that sort of thing. It has different safety standards, like, don't stack these, don't sort these things near this other type of solvent or what have you. So those pieces can go into that. I think there is also in the guidance, if we just pop into there. So this is linked in the resources, and then it's also linked on their website. And it's also in multiple languages as well as they added new languages. So there's Indonesian now for anybody who's on the call that that might be relevant to. And then I think they're also adding another another one. Let me actually look. I believe they got Indonesian up, which was great. Let's see. Oh, and traditional Chinese as well. So those are now all linked here, and they're fully translated for the full guidance. So I'm trying to find this section around, like, risk assessment. Probably search for risk assessment. Handy tip is control F or Apple icon or command F to search for specific sections within the long form guidance. So that's super helpful. So yeah. So appropriate appropriate and operable. What is this question? Yeah. So as recommended by the safety data sheet and and compliance. So it has that. Basically, if you have somebody who manages, like, your health and safety, that should probably be sufficient. And then, generally speaking, that would also follow fall under, like, your EMS or EHS assessments and having, the SDSs and doing training and and things of that nature. So yeah. So it just covers the chemical and health and safety risks of chemicals used on-site. So all of that information is going to be really, really helpful and then also inform all of your signage, all of your labeling, all of the documentation you provide in language, etcetera. So hopefully that helps. Alright. The next question is the chemical traceability only required to track chemicals inside the factory, not necessary to the chemical supplier and upstream suppliers. So if you mean by traceability, the chemical inventory list, the CIL requires things used on-site. However, if you're there are those questions about subcontractors and upstream suppliers on whether they follow, like, RSL or MRSL requirements. So it just kinda depends on which question you're asking about. But for the CIL, that's really all about, like, what happens within your organization. And then upstream suppliers and chemical suppliers would be, like, sourcing from positive lists or using RSLs or MRSLs that you also follow. So, hopefully, that helps, but let me know if if that's not clear. The next question is should spot removing chemicals need to comply with ZDHC MRSL chem chemical conformance? Not necessarily. I mean, like, generally, probably, I would recommend it. Right? Like, ZDHC, the conformance is all about, like, reducing hazards. So if you can, that's excellent. That would be ideal. However, this question, does your facility implement an MRSL? Is an applicability question. So it's not scored. It's just to filter the assessment for the rest of the questions. So it's not something that you have to do. If folks are concerned about that, it is, a best practice. But if you only use spot cleaners, it's not like you answer yes to spot cleaners, then it's like, oh, do you use an MRSL if that makes sense? So, obviously, I always recommend looking at the ZDHC guidance, looking at the different if you have any customers that offer MRSLs, those are gonna be very helpful to start to conform to. And you might already be conforming to it without knowing. So just double check that, and then and then go from there. Alright. The next question is, what is the frequency for the chemical training and spillage drill training supposed to be conducted? So this is actually an excellent question for me to showcase a new feature, in the assessment. So this little question mark icon here with a little sparkle, this is where you can ask, questions to an AI assistant. The AI assistant is trained on all of our documentation, all of Cascale's documentation, all of CDHC's documentation, and all of that good stuff. So you can ask it pretty complex questions and get kind of a a summary. I do wanna say with any AI assistant, it can make mistakes. So if you're like, ugh, that doesn't sound right, you can always say bad answer, and that helps to keep training it. But in this case, I asked what is the frequency, and it says must be conducted at least annually or at a frequency that ensures all new employees are trained according to the facility's turnover rate. So for that's, for employees who handle chemicals. And then for spill or emergency response drills, practice drills must be conducted at least twice per year for facilities that use chemicals in production. For facilities that only use chemicals for operation or tooling equipment, emergency response plan is required, but practice drills are not required for full points. So that is coming directly from the guidance. You can see all the guidance links here if you wanna dig into where they're actually getting that information from. But, hopefully, that helps to answer your question, and also kind of show how you can use the Worldly Assistant. Awesome. So the next question is if the facility evaluates the employees for through verbal interview without proper documentation, then what would be the answer of the below questions for yes or no? Do you evaluate your employees after the training? So in that case, for the training question let me see if I can find it. And evaluate. So when you answer yes to that question, it does ask how do you evaluate the knowledge of your employees after this training? And I will say that, sure, you can say verbal indication, but how are you gonna prove that? Is it in your training materials? Does it show that, you know, you gave this training and then you have these questions that you're asking people afterwards? Maybe you issue a written quiz instead so that you have the documentation, and it's a little bit easier to gather. Maybe you record it, right, if you're doing it virtually. So, ideally, documentation is gonna support that. If you don't have the documentation, it's really going to be on you to kinda prove it. The other thing is that your employees may be asked by the verifier. And if they can't go, oh, yeah. We did this training and blah blah blah blah blah, then you won't really have evidence of that. So, ideally, always provide documentation. Over-document when you're not sure. So, hopefully, that helps to answer your question. The next question is in level three that mentions life cycle assessment. Can we conduct internally by our own company team? Yeah. So it does let me find that question. It can be done by your team. It doesn't have to be. But if you, you know, are manufacturing, oh, it might not be showing up yet. But if you are, like, manufacturing materials and also, you know, making your own products and and what have you, or if you just want to do that specifically sorry. I'm trying to find where that question is. So I haven't answered all the questions just so I can show you, like, the full guidance for that. Okay. So the life cycle assessment. So with every question, you can click on view guidance, and it will give you more information. So it can be that your facility has evaluated the environmental life cycle impacts other than chemical hazards of chemicals used in manufacturing processes and alternatives, and this includes impacts of replacing chemicals in your factory on all of the following aspects. And then there's a list. And then answer partial yes if you did some but not all. And there's more examples here. So an example would be choosing a different dye stuff or recipe that results in reduced water or energy consumption during a dyeing process. So if you have someone on staff that can conduct a life cycle assessment, then perfect. You can go for it, especially if you have someone who's a qualified individual within the framework as, like, ISO fourteen thousand and forty. So a lot more guidance in the long form guidance, but there's kind of a short version here. And yeah. So there's not, like, a restriction from that as long as they have qualifications. The next question is, can you share chemical risk assessment template and CIL template? Those are linked in the ZDHC website section. So if you go to the ZDHC website, there's a process section, and I can show you how to get to that. There is some extra links that I'll also be sending you afterwards. But you can come in here, and there's, like, all of these different options here. And then there's all these, like, different documentation and then supporting documents. So if you go to learn more here, there's a ton in here as well as, like, different templates. So CIL templates right here. So I'll just link this to everyone in the chat. I'll also include this in the follow-up. But yeah, just go to the templates tab. It doesn't let me, like, link directly to that tab, but, hopefully, that helps. And there's a bunch of other things in there as well too that are helpful. The next question is, does chemical containers stored in sub store need label on container in local language? Ideally, yes. So especially if there's hazards, you want to make sure that the hazard label is there. Any of the, like, other labeling information is there. Generally speaking, the local language requirement is for the SGS, so it's for the safety data sheet. So as long as that's accessible to someone in the area of which they're doing the work with the chemical, that's helpful and can identify that that chemical, you know, corresponds to that safety data sheet. And then, of of course, there's additional guidance on that question below it as well for the sub storage information. The next question is, can you please share the updated chemical compatibility chart? I'm not familiar with that, but it may be in here. Maybe if you clarify where that comes from. I haven't heard that that particular resource in the past, but doesn't mean it doesn't exist. But let me know a little bit more about that, and I might be able to find it for you. The next question is we are textile finishing chemical formulators. Does Higg FEM cover us in this applicability questions? Yeah. So for chemical formulators, you might have kind of a different experience. Right? Because you're like, well, I don't mix stuff. I make chemicals. You're almost like a raw material provider. So you would still answer the questions in a similar way except for, like, your chemical formulation would probably be considered, like, a production process. So if you're not finding your processes in the list that you're seeing on screen, for example, there is kind of a catchall if you're just not really, you know, seeing your things represented, but other production processes that resemble chemicals. So you would probably select that and then, you know, go on moving forward. So, hopefully, that helps to answer your question, but let me know if it does not. Alright. Let's see. I think I already showed folks where you can find this. Can you please show the chemical risk assessment sample and guidelines? So any of that kind of guidance might be here, as well as in the, long form guidance here. So I didn't see, like, a specific template for risk assessment as far as chemicals were concerned, unlike, like, the wastewater or water section. Let's see. There's, like, the equipment. Yeah. I'm not seeing a specific, like, list for that. There's this might be helpful just as far as, like, different, like, hazard signage and things like that. So that might be helpful to check out. But I would just take a look at some of the links that you can see in the long form guidance here or, you know, take a look at your safety data sheets because those often will have, like, a section for that risk information. The next question is FEM chemical management section is very similar to the new ZDHC supplier to zero program. Why ZDHC is not recognizing FEM and chemical management section as one of the other recognized schemes? That, I don't know. You'd have to ask ZDHC. I'm not sure. Sometimes those things just take time to, like, get through approval. I can pass that information on to Cascale, though, to work with ZDHC. I know that most of the chemical questions here are based on ZDHC programming. So I'm not quite sure, but I'll I'll try to find out for you. The next question is, what should we do if the supplier cannot provide the testing certification such as OEKO-TEX due to the high cost of conducting the test? Since our consumption is low, the cost does not justify the investment. We've already encountered another supplier with the same issue. Additionally, changing the process is not straightforward and requires confirmation from the buyer first. That's a great question. So often, it's a trade off. Right? Like, is it worth the time, money, and investment that is necessary to become, you know, OEKO-TEX approved, or is the consumption so low that it really doesn't drive business? That's honestly, like, a a trade off that you need to make. An argument that you could make is that with those OEKO-TEX approval, you can attract new business based on different sustainable brands, sustainable manufacturers, people that want to show leadership in that capacity. And I think really speaking to reputational things and and things like that can really drive a lot of that interest. If you're like, hey. We've gotten this approval. We're following these standards. We're a really, really, really, really high performing facility, or manufacturing group or what have you that can be a way that you can drive business. So it is investment, and I'm not saying it's not. So there is kind of, you know, trade offs there. The other thing is that there's some coalitions, like government coalitions, industry coalitions that might also sponsor different things. So for example, like, the apparel AII, for example, sometimes sponsors different things and different projects and and things like that. So maybe if you, you know, if you're working at, like, a vendor or a a sourcing agent or something like that, You can work with different coalition groups like that, or you can work with a brand and go like, hey, brands. Like, if this is important to you, this is very expensive, but we want to meet you where you want us to be. How can we get this, you know, off the ground and and kind of work it that way? So a lot of it is going to be collaboration and and just kind of making a business case for it. I also recommend reaching out to. I'm sure they would have, you know, a lot of of ways that they could probably help with that and and how they would recommend supporting that as well. So, hopefully, that helps. I know that's not a perfect answer, but, hopefully, that helps in some way. The next question is, in the chemical section of the Higg FEM, there's a requirement for worker training on MRSL. For footwear facilities, most workers only apply chemicals directly to shoes and do not engage in chemical selection or procurement. Because of this, MRSL training often contains technical terms that are not relevant to their daily tasks. Would it be acceptable for facilities to focus worker training on safe chemical handling and application practices instead of full MRSL technical training while ensuring that management and responsible staff receive the detailed MRSL training? That's an excellent question. So let's go ahead and find the guidance or the question specifically. So does it do you implement it is the first kind of part of that. And then the second part of that, so this is asking specifically about your CMS team. So generally speaking, that's going to be your chemical management team. So those are gonna be the people or person who is kind of overseeing the chemical management process. So to clarify, the question isn't saying all staff necessarily, and let's just double check. So there is competency for the team question. I just don't wanna speak out of turn. This is also for the team question. How many employees were trained? Just wanna make sure I'm not leading you guys astray. So the purchasing question is a little different, and it's specific to, you know, making those purchasing decisions. And so that would only apply to people who actually are, like, responsible for that. And I just wanna make sure I'm not missing anything. Yeah. So generally speaking, what you're describing sounds accurate as far as, like, what you need to be doing. So think of it as kind of tiered levels and, like, for people who are handling chemicals, they're going to need to know what you're describing. Right? The things that they need to know. Like, do I need to work gloves? Do I need to have a mask? Do I need to be doing this in a ventilated area? How do I apply this safely? What happens if I get it on my skin? What happens if I get it in my mouth and my eyes, etcetera? They need to have that type of training, and then the people who are responsible for purchasing need to have that full MRSL technical training. The one thing, though, to look out for, though, is part of your RSL failure, like, plan or, like, prevention may be training on RSL information for all staff because it's restricted substances list, has compliance risks, legislation, you know, might be operating in your area that restricts things legally, and so you wanna make sure everybody has a shared understanding. But I would also say, you know, there's no harm in overtraining even if it's a newsletter or an email or you know what I mean? Or just recording the training that you provide to the purchasing folks. So, you know, if you can't get everybody in a room, at least saying, hey. For all the chemical folks that, you know, work with these things, this is just an FYI for your information, not directly applicable to your day to day, but this is how we go about doing this because transparency is helpful. Right? It helps everybody stay on the same page. That way, they can also look out for different things themselves as well. But they wouldn't need to have, like, the MRS all, you know, memorized or anything like that because it's not relevant. So, hopefully, that helps, Rose, but let me know if if not. So the next question is level two question nineteen. Would it only include production process subcontractors or others not related to production processes? For example, machine maintenance, pest control, window cleaning. So let's go ahead and take a look. And I wish I could just search question nineteen. Question seventeen. There we go. So does your facility engage contractors or subcontractors on MRSL or RSL? So the way that it defines this here is for your contractors and subcontractors that support the manufacturing process of final products. So, like, screen printing, washing, dyeing, or other product embellishments. So that would be specifically there. For things like pest control, right, like, generally speaking, hopefully, that's not ending up on your product. Maybe you do want to, you know, discuss that with those additional vendors just to be extra safe. But what this question is asking is specifically those types of business partners that support manufacturing of finished products. So, hopefully, that helps. The next question is how does the facility answer if the facility does not have any test report on RSL, like product and MRSL chemical use as no test is requested by brands? So for the RSL, which is the finished product. Right? So RSL is only what's in the final product. MRSL is, like, during the the production. If no test is product requested by brands, that doesn't mean that you can't test it. Right? They might not ask you. You would answer no if you're not currently doing that, and that's okay. You know, that's just just be honest about, you know, what you're currently doing. But that doesn't mean that the that you couldn't test it to make sure that your final products aren't having those chemicals and that sort of thing. So there's not a limit to that. It's not like you can't do that yourself or, you know, have a third party come in. But yeah. But if not, then just answer no to that question. That's okay. Alright. The next question is, if our company has been implementing MRSL, is it still mandatory to implement RSL? So RSLs, again, are about that finished process or finished product and what's still on it as it, like, leaves your facility. So they serve different purposes. And the FEM isn't saying that, like, these things are required necessarily in, like, that kind of language. But if you want to improve, the recommendation would be to follow both r an MRSL and an RSL. The other thing to be aware of is often your government may have something that's similar to an RSL. RSLs usually follow, like, regulatory legal limits of of different items. So, like, hey. You can't have this much lead in makeup products. Hey. You can't have lead on baby toys. Like, those sorts of things are pretty common in in government schemes. So look out for that as well because you might already be following it and not really know that that's technically an RSL. Alright. The next question is if any questions are answered partially yes and verified partially yes, has this reached level one? Yeah. So you can achieve level one with partial yes answers. That does mean that there is room for improvement in the question. Usually, it's just a completeness thing, but that would technically open up the next, levels. And then if you don't achieve level one, then you can optionally open up the additional levels to answer additional questions, whether that's for your own purposes, for continuous improvement, or because a brand is requesting specific information. Alright. The next question is for process chemicals. If we source all ZDHC level three chemicals, then is it necessary to collect any other certificates from suppliers? I don't know that off the top of my head. I would check the the limits or not the limits, the levels information. I do know that in some of these let me see if I can find it. ZDHC level. I don't know if it'll if it's listed exactly that. Okay. So oh, that's for wastewater. So it's a little different. But ZDHC is kind of, like, all over this document, so I don't think searching that's gonna be helpful. I'll have to check on that and get back to you. Generally speaking, you would wanna have, like, SDSs for any chemicals used at your facility if that's what you're asking. And then as far as, like oh, if you are asking about, like, certificates from, like, your upstream suppliers, for example, then I don't know. I'll I'll find out, and I'll get back to you on that. So, hopefully, if you registered for with your email, then I'll be able to include that in the q and a report. Okay. The next question oh, so this is a clarifier. The verifier looked for workers MRSL training. Okay. Interesting. So I'll I'll double check with m r with, not with MSL, with Cascale on that and then add a qualify or, like, a clarifying information in the q and a report in the follow-up rows. So look be on the lookout for that. I'll double check with Cascale for for guidance there because I don't wanna lead you astray. So alright. And the next question is, as a chemical formulator, what are the ways possible to source our chemicals from a positive list? This is question thirty. This is because we procure chemicals, which are mostly pure synthetic chemicals such as glycol, silicones, etcetera. So yeah. So for positive list for so for chemical formulators, you are in a unique place. So I would say if you have any chemicals that you as a formulator know pose more risk than others that there are potentially safer alternatives for, you can create your own positive list and source alternatives. So it it feels a little weird because you're kind of not in that, like, finished goods manufacturing point of view. But if you think of your chemical as your finished good, then anybody who's providing, like, your glycols, your silicones, you know, maybe there's this type of dimethicone that's new that's I mean, that's a pretty inert material. But, anyway, you know what I'm saying? Like, maybe there's a different type of material that's newer that has better health hazard ratings and and things like that that you could start to shift to and start to build out your new chemical formulations. Thinking like I don't know why I keep going to skincare, but just, like, thinking about skincare, like, shifting from really, really strong retinoids and vitamin a's to more natural things like Bakuchiol and and, like, things like that. So I don't know if that resonates with anybody, but that's my background that I'm interested in. So, hopefully, that kind of helps. I know that's not probably a perfect answer, but, hopefully, that kind of helps you make sense of that. And then the other thing is, you know, you can always talk to different people at ZDHC or, like, these different groups like BlueSign and some of those organizations as well. So, hopefully, that helps. Alright. Okay. So couple more questions. So one question is, I'm still confused about the difference between RSL and MRSL training. Can you give a detailed example? You know what? Let's make this easier on me. Just gonna go in here. So this is another way that you can access guidance. There is question by question guidance for twenty twenty four. The guidance did not drastically change. I believe Cascale is probably going to update this as well, but they they didn't change that drastically. So this is just a little bit easier to find kind of each numbered list. So there is chemical training, like hazards risk, proper handling, etcetera, and then all of that. So that's a little bit different. So MRSL. And then if you select yes sorry. I just wanna make sure that this is in. So ensure all chemical procurement staff are aware of r s MRSL requirements. So this is specific to procurement. That's why, Rose, I'm like, I would maybe argue with the verifier on on the way that they push back on, like, MRSL training because it it's not relevant to floor staff. So if you, you know, do still have that open, I would say, like, that's a good time to kinda push back and, like, you know, use that time for review help in a way. So let's see. I don't wanna just search all the guidance while we're here. But, basically, for MRSL and RSL training, it's my understanding. And how I'm understanding this is that it's purchasing and staff responsible for the facility's chemical management program can explain how the facility establishes RSL and RSL requirements as well as MRSL requirements. So there's not a difference between RSL and MRSL training. They're both lists about purchasing. So the training should cover the things listed in these questions, and I would just double check the full list of what's required. But it's really about the people who are buying and and responsible for that or, like, managing the chemicals. If they're just floor staff, I would say they don't need that level of training, but I will double check on that with Cascale for sure and get back to you. So, hopefully, that helps. But be on the lookout for my email. The next question is regarding to the positive list. Can we say we try to select the chemicals following the ZDHC MRSL requirement? So sort of, but what you would want to do is establish a list of, like, approved chemicals so that it's a positive list. There are positive lists that are provided, like, by ZDHC itself. So let me get to that question. I don't know why it's not highlighting this. There we go. So for example, there's a customer's positive list, ZDHC, MRSL, conformance level three, blue sign finder. So these things are positive list, and that would be available for you to select. So as long as you're kind of in this bucket, then you should be good. And then it has some additional technical guidance there as well. Alright. The next question is if a facility answered partial yes and the verifier marked it accurate, then verifier comments are required for this situation. You might have to clarify that. Generally speaking, if they answered partial yes and you're saying it's accurate, you would a verifier would just say accurate, and you wouldn't necessarily need to add additional comments. But it I don't know what this question is regarding. So let me know if I'm being confusing. Okay. The next question is if all documents are verified on-site by the auditor, please advise whether the auditor must mandatory upload the documents on the system. Can we request some documents which are confidential without upload on this system? Yeah. That could that that is an option. So if there are certain things that you are not uploading, for example and that's actually a good question for that CIL question that I got earlier. So you always have the option to upload. There are some questions where there will be, like, more of a, like, please upload, like, intentionally. I'm trying to find one there. But, usually, there's always an option to upload. Or if you cannot upload a document, there's an op an option to, like, fill in the blank. I can't find one right now. But in the fill in the blank yeah. So here, you can be like, please upload documentation. You'll notice it doesn't have a star. It's not a required field. But what I would do is in these notes sections, like, where you can explain a little bit more, just say, we have documentation for this. You know, please see during on-site review or, you know, something like that if you're concerned about confidentiality. So, hopefully, that helps. Alright. And then we've got another question. If we don't have chemicals and the lubricants are regularly brought by external mechanics, how can this be filled? So you would still indicate that you have those equipment lubrication chemicals, and then just indicate, you know, in, like, the CIL or something like that where they're coming from, and then answer the rest of the questions. So you would still answer that question, and then your chemical use type, you would use these maintenance tooling equipment chemicals. Most of the kind of, like, additional questions that come up is if you have production chemicals. So and, again, this is just a applicability question. So alright. Finally, regarding the chemical inventory, should wastewater treatment chemicals be classified under production chemical use? Our previous verifier recommended recommended combining them in our CIL. Those would technically be operations chemicals. So anything to do with, like, wastewater or on-site energy generation is an operation chemical, and that's defined here. So you would choose operation chemical. You would have them in your CIL. You would still wanna include them because they are used on-site, but that would be considered an operations chemical. So alright. That is all the questions. Thank you, everyone, for oh, we got one last one. Okay. This is the last one, and then anybody else, I'll have to respond separately. So the last question is we are using spot cleaning machine for removing stains. However, no chemical is used. Is it marked under this question? I would be curious on how your spot cleaning machine cleans the stains. If it's just using water or, you know, something like that, sure. But if it uses a solvent, if it uses, you know, something that you hook up to it and scrub in or something like that, there's probably a chemical in there, and you just choose spot cleaner. So, again, if it's not a production chemical, there's not quite as many questions there. But yeah. Okay. Yeah. If it's only water and air and there's no actual chemicals going on with that thing, then you would not say that you use spot cleaner chemicals because there's not chemicals in that tool. So awesome. Alright. That is all of the questions. So thank you so, so much for sticking with me. Thank you to my interpreter for staying with me. I'm very, very, very happy for you staying on. And thank you, everyone. You will get the recording of this session along with the q and a report, all those helpful links, all that good stuff. And I hope you have a good rest of your day. And if you celebrate upcoming holidays, happy holidays. So with that, have a great one, and see you next time. Thank you. Bye.