Modelama Exports Pvt Ltd

Chemical Management Systems Manual

1.0 Purpose

This document contains a set of guidelines for all MODELAMA EXPORTS PVT LTD facilities to
effectively manage their chemical usage and disposal practices to minimize exposure of hazardous
chemicals to human life and the environment.

2.0 Strategy

The MODELAMA EXPORTS PVT LTD strategy for chemical management will be based on the three
pillars Input, process, and output.
• The use of safe chemicals at all facilities will be ensured by aligning to the input stream
management protocols. All facilities must commit to use the ZDHC chemical gateway whenever
applicable.
• Facilities will ensure that the safe chemical inputs are used in the process as recommended and
align to the standards set by the MODELAMA EXPORTS PVT LTD Environmental Calibration tool
and Higg FEM whenever applicable.
• All facilities will align with global and local regulatory requirements and customer product
requirements to ensure the safety of our customers, employees, and the environment. This will
be done though testing finished products for RSLs as per the brand requirements and testing
wastewater outputs as per the ZDHC Wastewater Guideline whenever applicable.

The progress of alignment to the strategy will be continuously monitored by the relevant sustainability
and/or compliance officials which also extends up to the senior management in the structured
hierarchy of the company.

The same strategy will be used to benchmark our supply chain partners and subcontractors whenever
applicable.

3.0 Scope

This is applicable to all employees of MODELAMA EXPORTS PVT LTD specifically to all those
responsible for and in the use of chemicals. Chemicals used for dyeing a finishing, stain removing,
printing, Quality control, waste water treatment, maintenance, janitorial purposes and commodity
chemicals are covered under this policy.

The following areas are covered under this policy:

5. Chemical Purchasing
6. Chemical Inventory
7. Health and Safety
 8. Chemical Labelling
9. Chemical Handling and Use
10. Chemical Storage
11. Output Management
12. Process Control
13. Continuous Improvement

4.0 Definitions

• Chemical/Chemical Substance refers to a solid or liquid (gases like refrigerants excluded) that has
constant chemical composition of its component atoms, molecules, or other entities, that results
in physical properties (melting point, density, etc.) which can be measured to characterize it.
• Hazardous Chemicals are the substances that can cause a physical or a health hazard to humans
and the environment1. Hazardous chemicals are dangerous to people, wildlife and the
environment at any stage of their lifecycle, from production to use to disposal.
• The Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List
(MRSL) is a list of chemical substances subject to a usage ban. The MRSL applies to chemicals used
in facilities that process materials and trim parts for use in apparel and footwear.
• A Brand Restricted Substances List (RSL/PRSL) sets concentration limits for substances in materials
or finished products to comply with product regulation andsafety standards.
• The Certificate of Analysis (COA) is a document generated for each run or batch of a product
shipped. This may contain a list and percent composition of active ingredients, and results of
analytical tests that were performed on the product, such as tests forcontaminants.
• GHS labelling System is the Globally Harmonized System of Classification and Labeling of
chemicals developed by the United Nations
• Air Changes per Hour (ACH) is a measure of the air volume added to or removed from space
divided by the volume of the space.
• Chemical Abstracts Service (CAS) Registry number is a unique numerical identifier to chemicals.
• The Safety Data Sheet (SDS) is a document provided with a chemical product that contains
information about the hazards of a product and advice on safety precautions.
• The Technical Data Sheet (TDS) is a document provided with a product that lists various pieces of
information about the product such as product composition, methods of use, operating
requirements, common applications, and warnings.
 5.0 Chemical Purchasing

• The person raising the requisition must ensure the availability of all the following documents
From the chemical supplier (Refer Annexure A).

For process chemicals,

1) A Safety Data Sheet (SDS) (should meet the requirements in Section 6.1)
2) A Technical Data Sheet (TDS) or Technical Information (TI) sheet whenever applicable
3) A Level 1 or above certification conforming to the ZDHC MRSL current version
➢ Blue sign blue finder confirmation
➢ ZDHC Gateway In Check Report
➢ A Test report or certificate from a ZDHC recognized Indicator (certifying
body)
List of indicators: https://www.roadmaptozero.com/input#Indicators

Note: It is not necessary collect all the above documents, instead facility should collect only the
highest confidence supporting document like blue sign confirmation or ZDHC Gateway Level 3
products.

Declarations and Positive lists will not qualify as a ZDHC MRSL certification, and each facility will
have to internally test those chemicals obtained with declarations.

For embellishment SBUs, ZDHC MRSL declarations / Positive lists will not be considered after 31
December 2022.

4) Supporting document to conform the customer Restricted Substances List (RSL)

requirements

For non‐process chemicals,

1) Material Safety Data Sheet (MSDS) or SDS (Refer Section6.1)

2) TDS should be available whenever applicable

3) ZDHC MRSL declaration letter if directly purchase from chemical formulator/ if chemical
formulator information available (Refer the Annexure A – 3 whenever required)

• A requisition should be raised to the Purchasing Officer or other authorized person for purchasing
chemical when a need arises to purchase chemical(s).

[Type here]
 • The purchasing officer or other authorized person for purchasing chemical should verify whether
the chemical falls under the ‘Approved Chemical List’1.

If the chemical is not stated in the approved chemical list;

This is applicable to bulk chemicals newly introduced to the operation including non‐process
chemicals.
• The purchasing officer or other authorized person for purchasing chemical should refer such
purchase requisition to the Authorized Point Person.
• The Authorized Point Person should go through the SDS (Refer SDS criteria specified in the
Section 6.1) and verify the ZDHC MRSL compliance. If there is any non‐compliance, the chemical
will not be used.
• If the new chemical introduced for a production process, the Authorized Point Person should
ensure that the chemical does not contain any of the substances specified in the Customer
finished Product Restricted Substances List (PRSL/RSL). If so, the chemical will not be used.
• The Authorized Point Person should review the supporting document to further conform the
ZDHC MRSL and Customer RSL compliance. If supporting documents have any issue, the chemical
will not be used.
• It is recommended for facilities to test the chemical against the ZDHC MRSL if the chemical is
newly introduced to the operation (Refer MODELAMA EXPORTS PVT LTD RSL Policy for testing
of chemicals: Refer Annexure I).
• The Authorized Point Person should approve the new chemical upon meeting all the above
requirements.

• It is recommended to collect Certificate of Analysis (CoA) for chemicals wheneverapplicable.

• The purchasing officer or other authorized person for purchasing should order chemicals based
on Reorder levels.
• It is recommended to consider the Chemical Disposal cost at the time of purchase (disposal cost
might be 20 to 50 times the original purchaseprice).
• It is the responsibility of the Department Head to ensure the required quality of ordered
chemicals (ex: pH, Color, Viscosity, Expiry date, etc. based on the requirement). If chemical is not
meeting the minimum quality standard, chemical should not beused.

1Approved Chemical List is a facility specific list. This list contains list of chemicals that are
compliant to both Manufacturing RSL and Customer finished Product RSL.

[Type here]
 • The Authorized point person should ensure the worker training, PPE, review of any hazard and
storage requirements, emergency planning, and disposal requirements whenever a new chemical
is added.
• The Authorized point person should update the inventory when new chemical is added to the
process & updated inventory should be shared among the relevant departments
• It is the responsibility of the respective Department Head to follow the Chemical Handling,
Storage and Labelling guidelines as per the instructions specified in the SDS (or MSDS) before the
chemical is implemented to the process.
• A copy of the SDS (or MSDS) should be handed over to the relevant persons in the department
and it must be maintained in a file.
• The Authorized Point Person should update the Approved Chemical List whenever a chemical is
added or deleted (two weeks after the revision) and a copy of this list must be placed at the Guard
Room.

Note: The person responsible for issuing chemicals from the warehouse must follow the “First In, First
Out” procedure to keep chemicals from becoming outdated.

5.1 Chemicalsfor trials andresearch/innovationpurpose

• Each facility must not accept ‘donated chemicals’ or ‘free samples’ unless they meet a specific
need, as they can become a future wasteproblem.
• Following requirements should meet at a minimum when ordering chemicals for trials and
research/innovation purpose.
1. A Safety Data Sheet (should meet the requirements in Section 6.1)
2. A Technical Data Sheet (TDS) or Technical Information (TI) sheet whenever applicable
3. Declaration letter from Chemical supplier to conform the ZDHC MRSL (Refer the
Annexure A – 3 whenever needed)
4. Declaration letter to conform the Customer RSL whenever applicable
5. Chemical should have a class appropriate chemicalcontainer
6. Chemical container should contain product name and hazard warningsymbol

• It is the responsibility of the Department Head to refer such chemicals to the Authorized Point
Person.
• The Authorized Point Person should follow the instructions specified in Section 5.0.
• It is the responsibility of the Department Head to order sufficient quantities for the trial.
• Department Head should agree with the Chemical Supplier to take any excess chemicals after the
trial.

[Type here]
• After performance evaluation, facility should request ZDHC Level 1 or above certificates from the
supplier before bulk purchasing. Or else, it is recommended facility to internally test performance
evaluated chemicals

6.0 Chemical Inventory

• A Chemical Inventory is a comprehensive list of chemicals/dyes used in a facility including:

➢ Dye house
➢ Printing
➢ Production
➢ Research and Innovation
➢ Maintenance (thinners, coolants, machine oil, etc.)
➢ Effluent Treatment Plant
➢ Quality Assurance Laboratory
➢ Janitorial services (soap, detergents, etc.)

• This enables facilities to easily respond to request on any use of hazardous chemicals for
production.
• Maintaining a chemical inventory should be a continuous process. Therefore, the chemical
inventory should be revised/updated due to,
➢ Addition or removal of chemicals or
➢ Changes in SDS (or MSDS) information
➢ Changes of information in supporting document

• Information of all chemicals used in the facility should be filled as per the ‘MODELAMA
EXPORTS PVT LTD Chemical Inventory template’ (Refer Annexure B).
• It is the responsibility of the Head of Department to maintain and update the Chemical Inventory.
• The Authorized Point Person should have the master list of Chemical Inventory.

• Facilities should share the Chemical Inventory having all process chemicals and its consumption
data with the Chemical Management Work Stream (CMWS) or upload to the Bhive Chemical
Management System every month. Deadline to share inventories will be the 10 th of the following
month, and the 15th of the following month for sharing of chemical consumption data.
6.2 Safety Data Sheet (SDS)

• Facility should only accept Safety Data Sheet (SDS) prepared as per ANSI Z400.1 (2004), ISO
11014(1), EC 1907/2006 (REACH), EC 2001/58, Global Harmonized System (GHS), or JIS Z
7250:2005(Part 1) for process chemicals2.
• Although MSDS can vary in format for non‐process chemicals, the facility should require their
chemical suppliers to provide MSDS like the preferred examples in the Annexure A.
• SDS or MSDS of all chemicals must be less than of 3‐year‐old.
• If the existing SDS (or MSDS) does not meet the criteria, the facility must obtain a verification
letter from the supplier to confirm that it is the most up‐to‐date version.
• The Authorized Point Person must ensure the availability of below information on the SDS (or
MSDS). Facility should get information from supplier if sufficient data are notavailable.
➢ Information on ingredients and CAS numbers of hazardous ingredients
➢ Hazard Warning
➢ Hazard statement or Risk Phrase
➢ Personal Protective Equipment (PPE)
➢ Storage instructions
➢ Flash point
➢ First aid measures
➢ Firefighting measures
• SDS (or MSDS) should be available with the Safety Officer so that adequate preparations for
emergencies are planned.
• SDS (or MSDS) should be available in languages workers understand (at least sections directly
related to operational worker safety and storage requirements, such as first aid,
compositions/Ingredients, hazard, and flammability information) in relevant areas where
chemicals are used.

7.0 Health and Safety

Each facility will be responsible for maintaining safe practices when chemical products are stored,
handled, transported internally, and disposed.

2 As per the ZDHC MRSL Conformance Guidance

7.1 Controlling exposure

• Recommended protocols must be followed when labelling, handling, storing, transporting,

and disposing of chemicals used at all MODELAMA EXPORTS PVT LTD facilities to control
exposure and minimize the risk to human life and the environment.
• The main modes of exposure of chemicals are identified as inhalation exposure, oral
exposure, and dermal exposure. Caution must be taken during all times to protect staff
from intentional and inadvertent exposure during normal usage or during an emergency.
• Appropriate PPE must be worn by employees while handling chemicals or being in the
vicinity when chemicals are being used.
• Training must be conducted for employees that handle chemicals periodically to highlight
the importance of health and safety and best practices to follow to minimize accidents.

7.2 Personal Protective Equipment (PPE)

• All PPE should be maintained in a clean and reliable fashion.

• The facility should conduct a suitability assessment considering the modes of exposure and the
types of chemicals used when selecting the appropriate PPE for use.
• Refer Annexure E for more information aboutPPE.
• It is the responsibility of the Head of the Department to mandate employees those who handle
chemicals to wear suitable PPE.

7.3 Spill Response Kit

Each Spill Control Kit should contain the following at a minimum as appropriate.

• Suitable absorbent material (Refer Annexure C for more information).

• Coir brush or broom
• Dust pan
• Empty container or bag
• Chemical resistant gloves
• Suitable respirator
• Safety goggle
• Other PPEs as required

In case of a spillage of chemical, it should be wiped out using suitable absorbent and contaminated
absorbent should be disposed as per the Waste Disposal Plan.
8.0 Chemical Labelling

This is applicable to all chemical containers including temporary or secondary containers.

• The Original Label should be available and legible on main dye or chemical barrel/drum/box which
include the name of the chemical, hazard warning symbol(s), manufacturer name, etc. Otherwise
request supplier to provide chemicals/dyes barrels along with the original label.
• All chemical containers should be labelled as per the format developed by the MODELAMA
EXPORTS PVT LTD Chemical Management Work Stream (Please refer Annexure G). This label
communicates following key aspects to those who handle chemicals.
Note: (Exceptions will be made when IP or policy concerns exist at a certain facility)
➢ Hazard Pictograms
➢ Hazard Statements
➢ Precautionary measures
➢ Personal Protective Equipment
➢ Fire Extinguisher
➢ First Aid Measures
➢ Manufacturer details

• At a minimum, all temporary or secondary/small containers should contain the label developed
by the MODELAMA EXPORTS PVT LTD Chemical Management Work Stream (Please refer
Annexure H). This label communicates following key aspects to those who handlechemicals.
➢ Hazard Pictograms
➢ Hazard Statements
➢ Personal Protective Equipment
➢ Fire Extinguisher
➢ Manufacturer details

• Chemical labels should be available in a language understood by the workers at the respective
facility.
• It is recommended to label all the acid solutions prepared for quality assurance purposes with
relevant hazard warning symbols.
9.0 Chemical Handling and Use

• Chemicals must be used in designated areas which should be formally established by developing
Standard Operating Procedures and posting appropriate signage.
• Areas where chemicals are used should be adequately ventilated. It is recommended to maintain
at least four air changes/hour.
• Emergency eyewash station and/or shower should be easily accessible (Refer Annexure D for
more information).
• Departments should print the storage and the expiry date of the flushing fluid in the case of
eyewash bottles.
• Fire extinguisher should be available in areas of chemical use if applicable.
• “No Food and No Smoking” signs should be posted at the areas of chemical usage.
• Chemicals should be used only by ‘Authorized People’ who are specially trained for chemical use
and their names should be communicated at the areas of chemicals usage.
• The required Personal Protective Equipment (PPE) should be provided to those using chemicals.
• Written chemical safe handling plan or Standard Operating Procedure should be available to
employees.
• Chemical containers should be capped and sealed except when adding or removing chemicals.
• Originally food/beverage containers should not be used for transferring and storage of chemicals.
• Each chemical should have an individual scoop (or jar, bucket, spoon, etc.) properly labelled
specifically for that chemical product.
• Excess chemicals should be returned to the original chemical container soon after the addition
especially if jars/jugs are used to transfer chemicals.
• Chemical Spill Control kits should be located at the areas ofchemical usage.
• Maintenance records should be available for eyewash stations, fire extinguishers, safety showers
and for PPEs where applicable.
• Written spillage control practices with guidelines should be available toemployees.
• Spill records should be available with the SafetyOfficer.

9.1 Transportation

• Special care must be taken when transporting chemicals from main stores to sub‐stores and the
factory floor.
• Chemicals may be transferred to or from work areas through pipelines or conveyors, or by using
a forklift truck, trolley or other approved means. Vehicles must be in good repair to avoid
damaging containers and to reduce tip over orspills.
• Prior to transferring a chemical, check its label and replace all broken, torn, or incorrect labelling.
• Always refer SDS to check transport information to see if any special consideration must be made
• Reduce the possibility of collision and spillage of chemicals transported by a forklift truck by
clearly marking passageways and making them an adequatewidth.
• Do not shake chemicals. Over volatilization can causeleaking.
• While transporting chemicals, even small amounts, use leak proof equipment

10.0 Chemical Storage

Facility should have a designated chemical storage area and designated temporary chemical storage
area. Following guidelines are applicable to main warehouse and other chemical storage areas.

• Chemicals should be stored away from the main production area and off limited to visitors.
• Chemical storage area should be clearly marked
• Storage area should have easy entry and exit in case of any emergencies
• Storage floor should be solid and non‐porous
• Chemical storage room(s) should be ventilated via appropriate exhaust systems. It is
recommended to maintain at least four airchanges/hour.
• Chemical storage area should be equipped with suitable fire detection system and fire
extinguisher should be easily accessible.
• Emergency eyewash station and/or shower should be easily accessible (Refer Annexure D for
more information).
• The location of each emergency shower or eyewash station should be identified with a highly
visible sign.
• “No Food and No Smoking” signs should be posted at chemical storage areas.
• Safety Data Sheet (or Material Safety Data Sheet) of all chemicals should be available at chemical
storages.
• Sources of ignition such as sparks, open flame torch, cigarettes, etc. should be kept away from
chemical storage area.
• It is recommended to use explosion proof electrical lights in main storage and temporary storage
areas.
• Chemicals in the main warehouse should be stored to avoid direct contact with floors and walls.
• Storage shelving and/or cabinets should be anchored to a fixed entity.
• Chemicals should be stored in class appropriate containers designed for chemicalstorage.
• It is recommended to store liquid chemicals at or below eye level, unless securely stored.
• Chemical storage areas (including chemical handling areas, warehouse and fuel storage areas)
should have secondary containment which has a minimum capacity of 110% of the primary
container (or the volume of the largest container) or any other arrangement which does the same
purpose of secondary containment.
• It is recommended to have an engineering verification to the secondary containment capacity.
• Chemicals should be stored as per the Chemically Compatible families (chemical class or reactive
group). Compatibility on shelves should be vertical as well as horizontal (Please refer Annexure
F).
• Solid and liquid chemicals should be properly segregated.
• It is recommended to follow SDS (or MSDS) instructions on storage conditions such as
temperature, moisture, and explosion proof fixtures.
• Chemical containers should be checked regularly for rust, corrosion, and leakage.
• Suitable Spill Control Kit and Personal Protective Equipment should be located at chemical
storages.

11.0 Output Management

Chemicals that are used and applied in a facility can find their way out in the form of four output
streams:

1. End‐Product
2. Solid waste
3. Wastewater and sludge
4. Air emissions

11.1 End‐Product Chemical Management and Compliance

• End‐Products from a facility which could be in the form of finished products or garments, trims or
accessories should meet the legal and Brand requirements for chemical restrictions covered
under their respective RSL or PRSL.

11.2 Chemical Disposal

• Chemicals that are no longer being used, outdated, in poor condition, or otherwise in line for
disposal should be included into the Chemical Disposal List (Please refer Annexure I).
• Safety Data Sheet (or Material Safety Data Sheet) should be available for chemicals those listed
in the Chemical Disposal List.
• Chemicals mentioned in the above list should be isolated from the Chemical Storageareas.
• The facility should follow the Chemical Storage guidelines specified in the Section 9.0 for
disposing chemicals until finding a proper disposal routine.
11.3 Management of Wastewater and Sludge

• A large quantity of water is consumed during the manufacturing process and at the end of the
production line, wastewater is discharged, and it should be treated properly before its releaseto
the environment. Sludge is the residual solid or semi‐solid or slurry material that is produced as a
by‐product of wastewater treatment processes.

The two main modes of discharge of wastewater are:

1. Indirect discharge
2. Direct discharge

• The wastewater and sludge management at each facility should be in line with the current version
of the MODELAMA EXPORTS PVT LTD water use and wastewater management policy’, which is in
accordance with the ZDHC Wastewater Guideline and local regulations on discharge of
wastewater and sludge.

11.4 Air Emission Control

• Each facility should identify possible sources for the generation and release of air pollutants.

Note: Workplace air emissions can occur from print screen making, engraving, stenter finishing,
drying, curing, spraying, spot cleaning, chemical mixing, gluing, coating etc. and from manufacturing
facility operations such as boilers, generators, fuel burning and refrigeration operations etc.

• Track air emissions from processes that use of volatile chemicals and manufacturing operations
leading to the possible generation of VOCs and take measures to control them.
• Do regular maintenance on control measures to ensure theirworking order
• Meet or exceed requirements for compliance made by local regulators.

12.0 Process Control

A facility should control all the documents and processes to ensure proper implementation of CMS
and thereby monitor traceability, transparency, and strive towards continual improvement.

12.1 Document and Record Control

• All control documents and records related to CMS should be maintained and stored a minimum
of 12 months.
• Quality assurance and quality control protocols practiced internally by each facility must be
maintained.
• These documents should extend to cover all control documents and records related to ZDHC CMS
framework
• Employees responsible for chemical usage and supervision should be aware of the availability of
these documents and have access to them
These documents include:
• Regulatory‐ Local legislation and compliance requirement, RSL requirements of certain countries
and organizations)
• Policy and strategy ‐ Chemical Management Policy document which includes set guidelines
related to purchasing, transparency and Traceability, Chemical Strategy document, Production
traceability documents (recipe sheets, process logs)
• ZDHC related ‐ ZDHC solution documents (MRSL, WWG etc), ZDHC In Check reports, Chem
Check reports from formulators,
• Chemical inventory related ‐ Chemical inventory list, Supplier declaration for Brand RSL
requirements or MRSL (when required), third party certifications from RM suppliers and
formulators, SDS, TDS (when applicable),
• Supply chain related Latest RSL documents of brands serviced, Sub supplier and subcontractor
evaluation documents
• Training related ‐ Training records and mock drillsconducted
• Health and Safety related ‐ PPE requirements and assessment, emergency response plan, incident
register
• Continuous improvement ‐ Internal and external test reports and CAPs, Internal and external audit
reports, management review meeting (MRM) minutes, follow up actions, Root cause analysis for
production and non‐production nonconformities, corrective and preventive actions.

12.2 Incident and noncompliance management

MAIC Incident management approach:

Measure: Understand the problem and its magnitude
Analyze: Identify the root cause using different techniques
Improve: Determine the best solution, pilot, and verify
Control: Set up a control plan or KPI to measure the effectiveness of the corrective action.
• All incidents related to chemicals, including chemical accidents, RSL rejections, Health and Safety
issues, and other non‐compliances will be recorded along with a corrective action plan (CAP) to
detect the root cause, eliminate it, and prevent any reoccurrence of the incident. The MAIC
incident approach will be followed when documenting any incident or noncompliance.

12.3 General maintenance and house keeping

• General maintenance and housekeeping include the following: which machines related to
chemical operations mentioned in Section ‘3.0’ require maintenance, which chemicals are
unlabeled, which first aid boxes need restocking, which eye wash station is not working,
containers not stacked properly etc.
• Follow general maintenance according to the Maintenance and housekeeping protocols followed
by the facility.
• Maintenance will be done accordingly under the following three requirements:
1. Corrective maintenance (To eliminate the source offailure to prevent recurrence.
2. Preventive maintenance (done periodically to reduce the probability of failure)
3. Planned Improvement maintenance (Making changes to the process/layout when upgrading
machinery)

13.0 Continuous Improvement

Once CMS is set in place, the following mechanism will be followed to attain continual improvement:

1. Periodic training in chemical management

2. Periodic internal/external assessments – Review CMS Policy, strategy and implementation of
CMS at specified time periods by a chemical responsible team or external expert body
followed by a review by leadership
3. Identify areas of improvement/change – identify improvement or pending actions or
inconsistencies with the new requirements in the existing CMS
4. Make improvements – Revise the CMS to include changes and improvements
5. Implement Revised CMS

13.1 Training on Chemical Management

• A ‘training‐need’ assessment should be conducted annually to come up with an annual training

plan and thereby assess the areas that require to be covered, the personnel.
• All the members of departments that handle chemicals should be trained bi‐annually on Chemical
Management. Training topics should include and may not be limited to thefollowing:
 1. Safe handling, transportation, use and storing ofchemicals
2. Chemical hazards
3. Toxicities of chemicals
4. Training on Safety Data Sheet (or Material Safety Data Sheet) handling
5. Spillage prevention practices
6. First aidmeasures
7. Chemical Disposal
8. Knowledge in Standard Operating Procedures
9. Use of Personal Protective Equipment(PPE)
10. ZDHC prioritized chemical groups (Facility could use five ZDHC training modules)
11. Importance of ZDHC MRSL and Customer RSLs

All trainings must be documented including following:

1. Photographs with a date and time stamp

2. Signature sheets
3. Training materials, etc.
4. Training evaluation and feedback form.

13.2 Assessments

This section addresses the methodologies to assess the implementation of the policies related to
chemical purchasing, use, documentation control, storage, handling and disposal in a facility.

13.2.1 Chemical hazard and risk assessment & Health and Safety requirements

13.2.1.1 Input Management and Assessment

Chemical inventory should be assessed to ensure thefollowing:

• Align to ZDHC MRSL requirements through gateway or any ZDHC recognized certifiers.
• Physical, health and environmental hazards should be identified through the SDS
• Possible MRSL and RSL risks should be identified and phasedout

13.2.1.2 Process Management and Assessment

The process of a facility should be evaluated using the MODELAMA EXPORTS PVT LTD Calibration tool to
ensure proper Chemical management and usage practices.
• Handling, Storage and Labelling of chemicals to be reviewed
• Monitor consumption of all chemicals and reduce the usage of identified hazard and work
towards elimination.
• Align to the respective facilities Health and Safety protocols, and identify what chemicals the staff
are exposed to and what activities increase exposurerisk
• Adherence to TDS and Process instructions whenever applicable.
• Monitor the quality of chemicals and track recipes used to achieve traceability down to the Lot
number of the chemicals used for each operation whenever applicable.

13.2.1.3 Output Management and Assessment

• Conduct wastewater testing once a year from a ZDHC recognized testing body whenever it is
applicable to the facility.
• Align to limits for both MRSL and Conventional Parameters as defined in the ZDHC waste water
guidelines.
• Focus on beyond compliance by adhering to the MODELAMA EXPORTS PVT LTD water use and
wastewater management policy

13.2.2 Regulatory assessments

All processors performed at a facility should comply with local laws, international regulations, and
obtaining the required permits/licenses issued by local/provincial authority will be mandatory.

13.2.3 Supply chain assessment

Raw material suppliers and subcontractors will be assessed to cover risk of chemical compliance by
monitoring their inputs, process and output using a similar strategy to that employed at all
MODELAMA EXPORTS PVT LTD facilities.

Note: Evaluation of the process pillar of the supply chain will be covered by aligning to the Higg FEM

13.2.4 Alternative chemical assessment

Periodic assessments will be conducted to find safer alternatives to replace potentially hazardous
chemicals while maintaining performance and economic viability based on a transparent and scientific
approach.
 Annexure A: MSDS, TDS and ZDHC MRSL declaration letter

1) Material Safety Data Sheet (MSDS)

Preferred MSDS

This should be according to GHS (Globally Harmonized System) & should have all information required
2) Technical Data Sheet (TDS)

Preferred TDS

This should be according to GHS (Globally Harmonized System) & should have all information
required
 3) ZDHC MRSL declaration letter/Positive List

Acknowledgement and Agreement to the ZDHC MRSL

To: MODELAMA EXPORTS PVT LTD

Chemical Supplier Name:

Address:

The undersigned, a duly appointed officer of the Supplier, hereby acknowledges that it has reviewed
the most current version of the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing
Restricted Substances List (MRSL) and acknowledges it is responsible to continue to review and
comply with the most current version of the ZDHC MRSL.

We certify that all products produced and shipped to MODELAMA EXPORTS PVT LTD which listed
below do not contain any of the substances or group of substances;
I. as intentionally added raw materials or
II. as impuritiesabove the limit specified in the MRSL (current version: V2.0,December 2019) of
ZDHC.

Chemical products ship to MODELAMA EXPORTS PVT LTD:

We further comply with all applicable laws, codes, rules and regulations including laws relating to
occupational health and safety, waste management and the environment, all as may be amended
from time to time.
We confirm and certify that we have received, read, fully understand and will comply with the ZDHC
MRSL.
Certified this day of , 20
 Priority Substance Disclosure (PSD) Form

Please indicate if the shipped chemical products contain one or more of the substances specified in
the ZDHC MRSL (current version: December, 2019) and lists these substances in the below table.

Product Name Substance Name CAS number Concentration Availability of

(from the ZDHC MRSL) alternatives
4) Declaration letter from supplier for customer RSLcompliance
 Annexure B: Chemical Inventory

• The Chemical Inventory format is available on Document Lab & can be obtained by putting request to
arvind.rai@modelama.com

• It is the responsibility of the facility to submit the completed Chemical inventory to carry out the Hazard
Assessment3.

• If information readily not available on the SDS (or MSDS), leave the particular cell as a blank (ex: sometimes CAS
no, Toxicological / Ecological information, etc. may not be available on the SDS).
 Annexure C: Suitable absorbent material

Types Absorbent Advantages Disadvantages

Low absorption efficiency,

Inorganic Clay Chemical inertness, Cheap incompressible, dirty, will
cause secondarypollution

Low absorption rate, dirty,

Rag cuttings, Rice husk, Higher absorption efficiency
Organic will cause secondary
cotton than inorganic, cheap, light
pollution
High adsorption efficiency,
chemical inertness, can be Expensive, some liquid
Complex Polypropylene
used repeatedly, residue will stay in surface
compressible
 Annexure D: Emergency Showers and Eyewash Stations4

• Flushing fluid

➢ A person should be able to reach the equipment in no more than 10 seconds.

Use only potable (drinking) water, preserved water, preserved buffered saline solution or
other medically acceptable solutions as flushing fluid in the eyewash stations and
emergency showers.
➢ Equipment installed per the standard should be capable of providing flushing fluid fora
minimum of 15 minutes.

• Emergency Showers
➢ The emergency shower should deliver a pattern of water with a diameter of at least 50.8
cm (20 inches) at 152.4 cm (60 inches). This diameter ensures that the water will come
into contact with the entire body ‐ not just the top of the person's head. American
National Standards Institute (ANSI) also recommends the shower head be between 208.3
and 243.8 cm (82‐96 inches) from the floor. The minimum volume of spray should be 75.7
litres/minute (20 gallons/minute) for a minimum time of 15 minutes.

4American National Standards Institute (ANSI) standard Z358.1‐2014 "Emergency Eyewash and
Shower Equipment
• Eyewash and Eye/Face wash stations
➢ Eyewash stations should be designed to deliver fluid to both eyes simultaneously at a
volume of not less than 1.5 litres/minute (0.4 gallons/minute) for 15 minutes. The
combination eye and face wash stations require 11.4 litres per minute (3.0 gallons per
minute). However, in either case, the volume should not be at a velocity which may injure
the eyes. The unit should be between 83.8 and 134.6 cm (33 to 53 inches) from the floor,
and a minimum of 15.3 cm (6 inches) from the wall or nearest obstruction.
 Annexure E: Personal Protective Equipment (PPE)

• Eye Protection

➢ Splash proof chemical goggles should be used when handling potentially hazardous liquid
chemicals.
➢ If potential splashes or sprays of hazardous liquids are likely to occur, wear Face Shields.

• Respiratory Protection
➢ Only use Respiratory Protection that conforms to international/national standards.
➢ Appropriate Personal Protective Equipment should be worn when using volatile
chemicals (ex: solvents). Fabric masks are not allowed.
➢ Self‐contained breathing apparatus should be used where applicable in case of
emergency situations (air contamination/large uncontrolled emissions/insufficient
oxygen supply)
➢ Annual fit testing should be done for those who use Respirators.
➢ Filter Cartridges must be equipped with an end‐of‐service indicator or must be changed
according to a schedule that will ensure that the capacity has not beenexhausted.

Fit Test
A “fit test” tests the seal between the respirator's face piece and face. It is performed at
least annually or due to following reasons.
o Whenever a change in respirator style
o Whenever change in facial structure that may affect it (e.g. facial surgery and
significant scarring)
o Large weight gain or loss, etc.

There are two types of fit tests, qualitative (normally for N95 respirators) and quantitative.
Qualitative fit testing is a pass/fail test method that uses sense of taste or smell, or reaction
to an irritant in order to detect leakage into the respirator face piece. Qualitative fit
testing does not measure the actual amount of leakage. There are four qualitative fit test
methods accepted by OSHA (USA).
o Isoamyl acetate, which smells like bananas;
o Saccharin, which leaves a sweet taste in yourmouth;
o Bitrex, which leaves a bitter taste in your mouth; and
o Irritant smoke, which can cause coughing.

Quantitative fit testing uses a machine to measure the actual amount of leakage into the
facepiece. There are three quantitative fit test methods accepted by OSHA:
 • Hand Protection

➢ Use Chemical resistant gloves as per the requirement.

o Generated aerosol;
o Ambient aerosol; and
o Controlled Negative Pressure.

Table: Chemical Resistant gloves and types of use

Type of Glove Types of use

Protect against a wide variety of chemicals, such as peroxide, highly
corrosive acids (nitric acid, sulfuric acid, hydrofluoric acid and red‐
Butyl gloves
fuming nitric acid), strong bases, alcohols, aldehydes, ketones, esters
and nitro compounds.
Natural (latex)
Protect from most water solutions of acids, alkalis, salts and ketones.
rubber gloves
Protect against hydraulic fluids, gasoline, alcohols, organic acids and
Neoprene gloves
alkalis.
Provide protection from chlorinated solvents such as
trichloroethylene and perchloroethylene. Also protect against oils,
Nitrile gloves
greases, acids, caustics and alcohols. Not recommended for use with
strong oxidizing agents, aromatic solvents, ketones and acetates.

• Skin and Body Protection

➢ If are likely to occur, wear apron, boots, etc. as per MSDS instructions
 Annexure F: Chemical Storage Compatibility

Self‐ Reactive and Solid

Dangerous When Wet

(Readily Combustible,

(Liquids/Solids/Gases)
Oxidizing Substances
Flammable Liquids
Flammable Gases

Flammable Solids

Spontaneously
Desensitised

Combustible
Flammable Gases ⬟ ⬟ ⬟ ⬟ ▲
Flammable Liquids ⬟ ▲ ⬟ ⬟ ⬟
Flammable Solids (Readily
Combustible,
Self‐Reactive and Solid ⬟ ▲ ▲ ⬟ ▲
Desensitised Explosives)

Spontaneously Combustible ⬟ ⬟ ▲ ⬟ ⬟
Dangerous When Wet ⬟ ⬟ ⬟ ⬟ ⬟
Oxidizing Substances
(Liquids/Solids/Gases) ▲ ⬟ ▲ ⬟ ⬟
Organic Peroxides G G G G G G

❒ Allowed to be store together ▲ Separate packages by at least 3 m

G Do not store together ⬟ Separate packages by at least 5 m
 Annexure G: Example of GHS label

Annexure H: Label for Sub/Small Containers

Annexure I : Chemical Disposal List