CMS - Trg. Material

Chemical Management System (CMS)
1/22/2021 Sai Consulting Services ,Chennai -117 1

▪ Organisation Introduction
▪ Trainers Introduction
▪
Intro session Purpose of this assembly
▪ Delegate Introduction
▪ What is CMS
Agenda ▪ Core elements of CMS
▪ Q&A
SAI Consulting services

Why: The Importance of Chemical Management
– Regulatory compliance /stakeholders requirements
– Environmental Reasons
– People Safety
– Sustainability
– It’s the right thing to do

What is a Chemical Management System?
A Chemical Management System is a process that ensures proper

compliance with safety, environmental , compliance requirements and
sustainability.
The process includes:
❖ A compliance adherence
❖ A system to manage Material Safety Data Sheets (MSDS)
❖ Understand the chemical risk and chemical management
❖ An approval process for procurement, use, storage, identification and introducing new
chemicals to the site
❖ Proper waste disposal.
Employee training on all aspectsSaiof

1/22/2021 the Services
Consulting program is critical to its success.
,Chennai -117 4
KEY OBJECTIVES OF CHEMICAL MANAGEMENT
❖ Understand the intrinsic hazards of chemicals

❖ Ensure workers/stake holders are given
sufficient information,
❖ Maintain an up-to-date inventory of all
chemicals used in the facility
❖ Minimize adverse effects of chemicals on the
health and safety of the workforce

To achieve the safe use of chemicals and to control the
hazards that they present to workers, the community and the
environment, a factory must be organized in its approach to
the various aspects of chemical use.
❖❖Chemical inventory management procedures advises on
➢ How to comply with global chemical legislation,

➢ Retailer & Brand Restricted Substance Lists (RSL’s) and
➢ Manufacturing Restricted Substance List (MSRL’s)
➢ Restriction of Hazardous Substances (RoHS)
➢ Other requirements from industries & stakeholders

P-D-C-A Cycle

P-D-C-A Cycle
➢ Plan
❖ Develop a commitment to CMS
❖ Appoint a liaison
❖ Understand internal operation, supplier/sub-contractor &
procurement process comply
❖ Develop a risk assessment program
➢ DO
❖ Review national regulation and brands requirements

Understand all the chemical input for the operation
❖ Document the risk assessment for internal operation and
Supplier/sub s contractor.
❖ Develop and document & Implement standard operational
controls & measures based on risks identified
❖ Develop and maintain the communication system (Eg:MSDS)
❖ Provide Trainings
P-D-C-A Cycle
➢ Check
❖ Review the variables on regular basis.
❖ Perform testing on chemical input/inprocess or final product.
➢ Act
❖ Implement corrective actions and review the effectiveness of

the system on regular basis.

❑ Key Pillers of CMS
❑ Regulatory Compliance requirements

(REACH,RSLZDHC,CLP,RoHS etc)
❑ Customer specific requirements & Compliance Evaluation
❑ Chemical Risk Assessment
❑ Chemical Inventory Management
❑ Chemical Storage,Identification,Labelling and Handling
❑ Supplier and sub-contractor management
❑ Competency development
❑ Typical CMS Committee
Chemcial -
Director
Chemical
Complaince
Manager
Development
Production
Supply chain
Compliance review
❑ Facility may have several customer /regulatory compliance requirements (REACH,MRSLs and RSLs)
❑ Harmonise these lists into one using the most stringent standard of those available

❑ Compliance review
The process for identifying and monitoring regulations /other compliances

applicable to chemical management should:
1. Identify the applicable regulatory jurisdictions, regulations and other

compliances necessary.
2. Assign the initial regulatory identification to a specific position(s) or
team.
3. Prepare the compliance matrix
4. Review the existing compliance of products
5. Assign the ongoing regulatory/compliance monitoring and Updation
6. Describe how management will be informed of significant regulatory
changes

❑ Compliance review
Screen the
Check for the Develop an
regulation one by
most updated Compliance
one to identify Check if
regulation / matrix as result
applicability & the
complaince of screening products
stringent one meets the
compliance
requireme
nts
No Yes
Regularly review Identify the Changes in

the regulations
-Prepare a
Regulation/ corrective
complaince action plan for
improvement
-
No Yes
Update the matrix

as necessary? Record the
Internally communicate the
comparison result
result with top
and keep this
management and staff
record

❑ Product Compliance review
❑ Prepare the product testing plan based on regulatory/compliance matrix

/stake holders requriments/internal system
❑ Identify and select the testing labs (Define the criteria for labs)
❑ Test the products as per plan
❑ Evaluvate the test results against the requirments and identify the
improvement required

❑ Procurement Practices
❑ Develop purchasing policy
❑ Identify a Purchasing Coordinator - issues and approve purchases across all departments and who
has an understanding of chemical issues.
❑ Tighten purchasing controls: restrict chemical purchases to those needed for current business or
research programmes and in minimal amounts for short term use
❑ Supplier Selection :Establish, document and implement a controls for identifying and using
preferred suppliers and removing suppliers from the preferred list when appropriate
❑ Communication :Effective communication system to all suppliers regarding compliance

requirements.
❑ Before ordering chemicals, staff and other personnel should:
❑ Make sure the chemical is on the facility system’s list of approved chemicals and check against
any MRSL/RSL in effect in the facility.
❑ Train personnel so that they are capable of assessing chemical hazards, handling,storage &
use.
❑ Develop a current inventory of existing chemicals.

❑ Procurement Practices
For each chemical used, ask the following questions:
❑ −Can the supplier provide a Safety Data Sheet (SDS) in the local language containing the relevant
sections on proper handling, hazards, transport and safe disposal?
❑ − Can proper storage be provided for the chemical?
❑ − Are the facilities appropriate for the use of this chemical?
❑ − Will the chemical or its end products require disposal as hazardous waste?
❑ − Is appropriate PPE available for safe use of the chemical or its end product?
❑ −Have persons who will handle and use the chemical been trained in handling these chemicals?
Are they aware of the hazards?
❑ Are the suppliers/sub-contrctors aware of compliance requirments and able to demonstrate

compliance periodically

❑ Supplier/Sub-Contractor Management
❖ Establish and improve collaboration with your supply chain partners
❖ Establish a formal review process to evaluate the supply chain partners’ chemical performance
Existing Evaluate past

New /Existing
Chemical Supplier performance &
Suppliers Accepted List
New
Assessment based
on criteria
Satisfactory
Result
Unsatisfactory
On-site Inspection
Evaluvation
Unsatisfactory
1/22/2021 Reject
Sai Consulting Services ,Chennai -117 18
❑ New Chemical Review and Approval System
What needs to be reviewed?
Environmental Review
- Regulatory requirements
- Handling Issues
- Product environmental compliance
- Chemical end fate destination
Emergency Release
- Concerns/reporting requirements review
Safety Review
- OSHA requirements
- Toxicity issues
- Handling issues
Quality assurance review, where appropriate

❑ Chemical Risk assessment
❑ Step 1 – Define the risk assessment Methodology

❑ Step 2 - Decide who will do the risk assessment
❑ Step 3 - Identify chemicals and obtain the informations -referring to labels, MSDS, stock lists, manifests,
inventoriesand registers.
❑ Step 4 - Inspect workplace, operations and evaluate exposure
❑ Step 5 - Evaluate the risk and determine conclusions about the risk
❑ Step 6 - Implement control measures to address actions required from risk management
❑ Step 7 - Record the assessment and create a risk management plan
❑ Step 8 - Review the Control Measures



❑ Safety Data Sheets (MSDS)
❖ Safety data sheet (MSDS) is useful for managing the safety of chemical use in workplaces
as well as information to stake holders.
❖ Each chemical should be handled with its MSDS that should be:
- free of charge;
- provided no later than the first delivery or whenever there is any update / revision
to all personnel who received the chemical in the previous 12 months;
- prepared by a competent person/authority;
- be specific to the chemical;
- provided with 16 headings* for chemicals classified as hazardous; and
- be clear and understandable with the date and pages numbered.

❑ Safety Data Sheets (MSDS)
*16 Headings in Safety Data Sheets
1. Identification of the substance/preparation 9. Physical and chemical properties

and of the company/ undertaking. 10. Stability and reactivity
2. Hazards identification 11. Toxicological information
3. Composition/ information on ingredients 12. Ecological information
4. First aid measures 13. Disposal consideration
5. Fire-fighting measures 14. Transport information
6. Accidental release measures 15. Regulatory information
7. Handling and storage 16. Other information
8. Exposure controls/ personal protection
Maintained in an archive with the chemical information clearly documented/updated for all
-
chemicals and final products
-Identify the owner for maintenance and Updation
-Provide
1/22/2021
corresponding trainings to all responsible employees before handling the chemicals
❑ Chemical Storage
Regarding their properties, hazardous chemicals should be stored under
proper conditions. Relevant instructions and advices can be referred to
Section 7 and 10 of the Safety Data Sheet (MSDS).
Consideration taken when storing chemicals

•Types of chemicals under controls
•Max & Min inventory levels
•Compatibility of chemicals
•Appropriate construction, nature and integrity of storage containers
•Appropriate Temperature, humidity and ventilation arrangements
•Adequate security of and access to storage areas
•Prohibition or control of any potential ignition source
•Safe location for storage areas
•Safe transport around the workplace
•Adequate precautions and procedures in case of spillage
The1/22/2021
Operating Control Procedures should be written and comunicated
❑ Chemical Use
The following rules, regarding use of chemicals, should be followed at all times.
❖ Use a first-in/first-out policy.
❖ Perform regular inventory audits to identify chemicals that are not being used.
❖ Provide a simple chemical stocks, location and point(s) of contact.
❖ Read chemical labels before using.
❖ Keep SDS up to date and review regularly for new content (at least annually).
❖ Do not mix unknown chemicals.
The Operating Control Procedures should be written and comunicated

❑ Labelling
❖ All containers and packaging for chemical handling should be presented with:
- A clear identification of the corresponding chemical substances
- Indication whether the substance is hazardous and has risk to humans or the
environment by means of contact or accidental release.
❖ Information of proper labelling should be referred to hazard information on the

label or Section 2 and 3 of the MSDS
❖ Manufacturer can use labels standardized by local regulation or internationally

standard, markings, symbols, risk-phrases or hazard statements.
❖ The following labelling practices are for references:

- Adopt a labelling procedure standard for chemicals and waste
- Use labels that prevents fade-out
- Designate a team to handle the labelling and inventory control
- Review all facility areas to ensure labelling compliance

❑ Waste Disposal
No process will run without generating waste that cannot be

discharged to air, water or soil but needs to be collected and
disposed of as chemical waste in accordance with local
regulations.
The Operating Control Procedures should be written and

communicated Procedure for Proper Waste Collection,
Handling, Storing and Disposal

❑ Change Management
❖ Most businesses routinely receive change orders or new/revised

specifications.
❖ A good CMS should establish a system to handle internal and

customer chemical inventory changes.
❖ Establish, document and implement a process for reviewing

planned or actual process, engineering/operational or regulatory
changes

❑ Training Identify & Set Up the Training Plan
Conduct Training
Evaluate Attendees Fail

Randomly by Quizzes
Pass
Document Training Record

(e.g. attendance list, photo and training
materials)
Evaluate Training Effectiveness by

Responsible Team (at least quarterly)
Any Update on
Yes
Training system
No
❑ Emergency Plan
❖ A written and up-to-date Emergency plan should cover all workplaces,

which aims to minimize the potential influences of any dangerous accidents
caused by improper hazardous chemical storage and handling.
❖ Emergency procedures must be reviewed regularly and kept updated after

practice drills and actual emergencies.


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Chemical Management System (CMS)

1/22/2021 Sai Consulting Services ,Chennai -117 1

Agenda ▪ Core elements of CMS

SAI Consulting services

– Regulatory compliance /stakeholders requirements

– It’s the right thing to do

1/22/2021 Sai Consulting Services ,Chennai -117 3

A Chemical Management System is a process that ensures proper

The process includes:

❖ A system to manage Material Safety Data Sheets (MSDS)

❖ Understand the chemical risk and chemical management

❖ Proper waste disposal.

Employee training on all aspectsSaiof

❖ Understand the intrinsic hazards of chemicals

1/22/2021 Sai Consulting Services ,Chennai -117 5

❖❖Chemical inventory management procedures advises on

➢ How to comply with global chemical legislation,

1/22/2021 Sai Consulting Services ,Chennai -117 6

1/22/2021 Sai Consulting Services ,Chennai -117 7

❖ Review national regulation and brands requirements

❖ Implement corrective actions and review the effectiveness of

1/22/2021 Sai Consulting Services ,Chennai -117 9

❑ Regulatory Compliance requirements

❑ Customer specific requirements & Compliance Evaluation

❑ Chemical Risk Assessment

❑ Chemical Inventory Management

❑ Chemical Storage,Identification,Labelling and Handling

❑ Supplier and sub-contractor management

1/22/2021 Sai Consulting Services ,Chennai -117 12

The process for identifying and monitoring regulations /other compliances

1. Identify the applicable regulatory jurisdictions, regulations and other

1/22/2021 Sai Consulting Services ,Chennai -117 13

Regularly review Identify the Changes in

Update the matrix

1/22/2021 Sai Consulting Services ,Chennai -117 14

❑ Prepare the product testing plan based on regulatory/compliance matrix

1/22/2021 Sai Consulting Services ,Chennai -117 15

❑ Communication :Effective communication system to all suppliers regarding compliance

❑ Before ordering chemicals, staff and other personnel should:

❑ Develop a current inventory of existing chemicals.

1/22/2021 Sai Consulting Services ,Chennai -117 16

❑ − Can proper storage be provided for the chemical?

❑ − Are the facilities appropriate for the use of this chemical?

❑ Are the suppliers/sub-contrctors aware of compliance requirments and able to demonstrate

1/22/2021 Sai Consulting Services ,Chennai -117 17

Existing Evaluate past

1/22/2021 Sai Consulting Services ,Chennai -117 19

❑ Step 1 – Define the risk assessment Methodology

1/22/2021 Sai Consulting Services ,Chennai -117 20

1/22/2021 Sai Consulting Services ,Chennai -117 21

1/22/2021 Sai Consulting Services ,Chennai -117 22

1/22/2021 Sai Consulting Services ,Chennai -117 23

1. Identification of the substance/preparation 9. Physical and chemical properties

chemicals and final products

-Identify the owner for maintenance and Updation

Consideration taken when storing chemicals

❖ Use a first-in/first-out policy.

❖ Provide a simple chemical stocks, location and point(s) of contact.

❖ Read chemical labels before using.

❖ Do not mix unknown chemicals.

The Operating Control Procedures should be written and comunicated

1/22/2021 Sai Consulting Services ,Chennai -117 26