00 Implementation of CMS (Micro Colour Makers)

IImmppllementation of
CChheemmiical Management

System

Project Report

M/s Micro Colour Makers, Tirupur - India

Implemented by : Takko Holding GmbH - India
in association with

M/s Center for Research and Excellence

(Developed by : Dr. C. Deena - Takko India)

Section Index
Part - 1
Part - 2 Implementation Documents - M/s Micro Colour Makers
Part - 3
Part - 4 Description
Part - 5 Chemical Management System (CMS) - Manual
Part - 6 Risk Assessment Training
CMS Implementation Visit Reports
Management Review Meeting (MRM) Report
Improvements observed after Implementation
Chemical Inventory Details



MICRO COLOUR MAKERS
CHEMICAL MANAGEMENT SYSTEM

MICRO COLOUR
MAKERS

CHEMICAL MANAGEMENT
SYSTEM

Issue: 01 9th March 2019
In line with Takko – MRSL
Requirements

Centre For Research & Excellence

MICRO COLOUR MAKERS
CHEMICAL MANAGEMENT SYSTEM

Contents

1. Chemical Management System Policy (CMS Policy) ...........................................................................3
2. CMS Objectives ..................................................................................................................................5
3. Floor Plan & Material Flow.................................................................................................................6
3. Floor Plan & Material Flow.................................................................................................................7
4. Manufacturing Restricted Substances List.........................................................................................8
5. Chemical Inventorization .................................................................................................................10
6. Purchase Policy .................................................................................................................................14
7. Chemical Safety.................................................................................................................................17
8. Chemical Storage and Handling .......................................................................................................28
9. Common Effluent Treatment Plant..................................................................................................37
10. Chemical Disposal ..........................................................................................................................40
11. Chemical Management System Monitoring ..................................................................................47
12. Chemical Management System Review.........................................................................................51
13. Abbreviation...................................................................................................................................54

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1. Chemical Management System Policy (CMS Policy)

We at Micro Colour Makers are committed to implement a chemical management system
that enables us to monitor and control banned and restricted substances in all chemicals used
in our facility, optimal use of the chemicals, safe handling and disposal.

1. We shall take steps to progressively identify and eliminate use of chemicals and dyes
that are part of the banned and restricted substances in the MRSL. (Manufacturing
Restricted Substances List).

We shall have procedures in place to keep updated with changes across the globe in
MRSL by interacting and engaging with our customers and the brands they are asso-
ciated with. In this process, we have initiated and committed to adapt Takko – MRSL
requirements. We further commit to add any other MRSL requirements that we come
across if they are found to be stricter than the adapted MRSL.

2. We shall establish practices to manage an approved chemicals and dyes list, Chemical
classification, safe chemical handling and chemical disposal.

We shall establish Standard Operating Procedures to include new / alternate chemi-
cals in the approved list after due approval of the chemicals / dyes for its application,
quality and its compliance to MRSL requirements.

Procedures are established for identifying hazard classification of chemicals, safe
chemical handling and disposal through chemical manufacturers Safety Data Sheet
(SDS) and their disclosure / agreement / Certificate of analysis with respect to MRSL.

3. All our efforts will be towards continuously explore the possibility to reduce the use
of chemical, dyes, water, energy so as to reduce the impact on the environment.

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We have policies established for purchasing of chemicals from the approved manu-
facturer whose supply are in line with our CMS policy. Our focus is to regularly engage
with our chemical manufacturers / suppliers to communicate to them our chemical
management policy and any update on MRSL requirements and also encourage them
to share the application / use / hazards and safety of the chemicals supplied by them
and any alternate chemicals / dyes that is less hazardous and less usage.

We ensure that the chemicals are stored in an appropriate storage method and deploy
method for handling, transporting and dispensing for production to reduce/ eliminate
risks to physical well-being, health and environment.

4. As member of the Central effluent treatment plant (CETP) we ensure that the effluent
water is stored properly and transferred to CETP and shall positively engage with the
administration of CETP for continually improving the efficiency of the CETP and im-
prove the quantity of treated water for reuse and salt recovery.

5. We shall ensure that we comply with statutory and regulatory requirements at all
times with regards to plant establishment, operations, safety, disposal and environ-
mental requirements.

6. In pursuit of the goals established in this policy
• We shall endorse sustainable chemistry practices
• We shall periodically carry out Risk assessment of the Chemical management
system and initiate action for mitigating / eliminating the risks.
• We shall communicate this policy widely inside the organization and to all our
customers, suppliers and stakeholders.
• We shall review the continuing suitability and effectiveness of the established
chemical management system periodically once a year.

M. Somasundaram
9th March 2019

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2. CMS Objectives Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

1. Establishing Approved chemical List
2. Establishing Approved list of chemical suppliers and manufacturers
3. Establishing Chemical inventory control table with SDS and hazard details
4. Reorganizing stores with storage of compatible and incompatible chemicals sepa-

rately and identification and storage.
5. Implementing Restricted substances Log.
6. Obtaining declaration from Chemical manufacturers for MRSL.
7. Implementation of CMS purchase policy
8. Review of adequacy of the applicable statutory and regulatory requirements
9. To start the first CMS review in April 2019

Target Time: April 2019

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3. Floor Plan & Material Flow Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

FABRIC GODOWN
Receipts of Grey Fabric

GREY FABRIC PREPARA- WET PRO- DYES STORE
TION CESSING UNIT
Dyeing, Washing CHEMICALS
EFFULENT TANK STORE
Collection of Effluent
WASTE GO-
Water DOWN

EFULENT TREAT- FINISHING SECTION Collection of
MENT PLANT Drying, Squeezing, Sten- waste

tering Recycle

DELIVERY SECTION
Fabric Delivery

TREATED Brine So-
WATER lution

(RO)

SLUDGE COL- Land Fill / Re-
LECTION use

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3. Floor Plan & Material Flow Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

Washing Grey fabric Dyeing
Reversing Natural Dyeing
Bleaching Wet Delivery
Padding

Drier
Reversing
Delivery

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4. Manufacturing Restricted Substances List

Issue 1 - 9th March 2019 Rev 0 - 9th March 2019

4.1 Policy

As a wet processing facility, we are aware that any process carried out has an environmental and / or
health impact and that there is a possibility of consumer exposures to hazardous chemicals. Many
markets where our processed fabrics are being exported as garments have their respective govern-
ments issuing regulations restricting or prohibiting harmful substances. In addition, being an organi-
zation implementing good chemical management system, we are aware that our customers (who are
supplying to brands In Europe (Takko)and other countries have subscribed to various instruments or
has established requirements to restrict or prohibiting harmful substances in usage. This procedure is
established to identify those banned and restricted substances and increase awareness in the work-
place.

4.2 Objectives

To define procedures including authority and responsibilities thereof in such a way that will
facilitate the Banned and Restricted substances are not being used and to meet following
objectives: -

• To identify the Banned and restricted substances and list them.
• To confirm with the manufacturer that banned and restricted substances are

not available in their supplied product

4.3 Procedure:

4.3.1 Identification of Banned and Restricted substances list

We, as given by the input from the brand (Takko) our customer is working with, have
adapted the Banned & restricted substances list as given by Takko in Takko MRSL Require-
ments.

1. Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs): including all isomers
2. Chlorbenzenes and Chlorotoluenes (COC)
3. Chlorophenols
4. Dyes – Azo (Forming Restricted Amines)
5. Dyes - Navy Blue Colourant
6. Dyes – Carcinogenic or equivalent concern
7. Dyes – Disperse (sensitizing)
8. Dyes – Banned other
9. Flame retardants

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10. Glycols
11. Halogenated Solvents
12. Organotin Compounds
13. Polycyclic Aromatic Hydrocarbons (PAHs)
14. Perfluorinated and Polyfluorinated Chemicals (PFCs)
15. Pthalates – including all other esters of orthophthalic acid
16. Total Heavy Metals
17. Volatile Organic Compounds (VOC)
4.3.2 Control of supplied Chemicals
The Banned and restricted lists are communicated to our suppliers / manufacturers and they
are made aware and updated with the list as and when an update is received from the brands
or through any other instrument to which we subscribe. Further procedures in this manual
addresses the procedures for obtaining commitment from the suppliers on the non-use of
banned and restricted substances. In the event that the supplied chemicals are not complying
to the requirements, the supplier / manufacturer is expected to disclose the chemicals and
committing to phase out with in a targeted time limit.
4.4 Forms & Records
1) Takko MRSL List

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5. Chemical Inventorization Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

5.1 Policy

The Chemical Inventory System involves establishing, documenting and implementing a pro-
cess for material balances where there are potential chemical knowledge and safety gaps and
chemical losses not accounted for in the mass balance.

5.2 Objectives

To define procedures including authority and responsibilities thereof in such a way that will
facilitate the Chemical Inventory System to meet following objectives: -

• To identify and list the chemicals which are in current use
• Any new addition and or Deletion of existing chemicals is done systemically

with prior approval of the Technical Coordinator / Dyeing Manager
• Preventive action to meet the national and international instruments such as

MRSL etc., and to establish Safety Practices with “R” and “S” Phrases etc.,
• To ensure the workers are working within the sphere of known chemicals
• Periodical review of inventory and updates to meet the customer / market

needs with MRSL compliance
• Maintain register and accounts of the chemicals and meeting the audit re-

quirements

5.3 Procedure:

5.3.1 Identification of Gaps in Current Processes

Dyeing Manager & Purchase Manager are responsible for the identification of Gaps in cur-
rent processes.

The List of Approved Dyes and Chemicals is maintained by Purchase Manager which is duly
signed by Dyeing Manager.

At any point of time it is advised to Purchase manager to buy the approved chemicals only.

In the event any new chemicals to buy it must meet the purchase policy and procedure re-
quirements (Refer Sec. No 07 of this manual)

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The register of the chemical inventory is maintained by Purchase Manager and reported to
Dyeing Manager on weekly basis.
Monthly once the stock audit will be performed by Purchase Manager and or other person
(who is allotted by management time to time) and report to Dyeing Manager and MD.
Based on the report the necessary Corrective action if any needed shall be initiated.
5.3.2 Integration with chemical suppliers / manufacturer
The list of chemicals purchased from a supplier is listed and forwarded to the supplier re-
questing the supplier to submit MRSL declaration and / or submit a copy of the Certificate of
Analysis (CoA).
Technical coordinator / Purchase Manager is responsible for follow up with the supplier to
obtain the requisite declaration.
In the event the MRSL declaration is not received or not meeting the requirements it shall
be reviewed by Dyeing Manager and the chemicals shall be removed from the approved list.
The removed chemicals shall be isolated and phased out with in a span of time approved by
Dyeing manager and Management (preferably 3 Months)
Where the chemical manufacturer discloses that any of the chemical is not complying to the
MRSL requirement, the manufacturer is expected to include the details of the chemicals in
the prescribed “Disclosure “list with the target date of elimination.
Such disclosure forms are consolidated in the Phase out chemical list and followed for its
phasing out.
The chemical shall be run out from our inventory list maximum of 90 days from the Phase
out date committed by the manufacturer.

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5.3.3 MRSL Process

5.3.3.1 Verification of Compliance

The Chemical Inventory List with MRSL compliance is updated by Dyeing Manager and Pur-
chase Manager periodically once a month or as and when new chemicals are added.

An Action Plan is developed to meet the MRSL compliance which will be reviewed periodi-
cally for the effectiveness.

Dyeing Manager & Purchase Manager are responsible for the verification of MRSL compli-
ance.

Purchase Manager maintain the Chemical inventory list. The list has an indication of the
availability of SDS (Safety Data Sheet), TDS (technical Data Sheet), MRSL or Certificate of
Conformance (CoA)

Periodically Purchase Manager checks the purchased chemical is correct by verifying the fol-
lowing key points

1. Chemical Name on the product pack, Delivery Challan / Invoice, MSDS
and MRSL declaration are the same.

2. CAS. No / CI No are correct
3. Hazard Codes are properly marked
4. Any new instructions are given in the package for store or handling etc.,

The In-stock materials if found to be non-compliant, shall be identified and phased out with
in span of time approved by Dyeing Manager and Management (Preferably 3 months) or the
chemical shall be disposed of suitably as per the local regulations

5.3.3.2 MRSL Update and Maintenance

As a minimum, annually once an internal audit is performed to verify if the MRSL are up-
dated.

In case any changes or updates is needed the same shall be reviewed and approved by Dye-
ing Manager.

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5.4 Forms & Records
1) Approved Chemical Supplier & Product List
2) Chemical Inventory Register
3) Restricted Substance Log

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6. Purchase Policy Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

6.1 Policy

The purchasing policy involves the procurement of goods (raw materials, dyes & chemicals)
and services that meet our dyeing and finishing process needs at the lowest possible cost
consistent with the quality needs, complying with MRSL and statutory requirement for the
proper operation & business sustainability.

6.2 Objectives

To define procedures including authority and responsibilities thereof in such a way that will
facilitate the purchasing authority to meet following objectives: -

• To purchase materials only from the approved suppliers / manufacturers.
• To purchase only pre-approved materials.
• Approval of materials shall in addition to the quality of the materials be on the

basis of availability of Safety Data Sheet (SDS), Technical Data Sheet (TDS) and
the declaration by the manufacturer that the products comply with the MRSL
requirements and / or the certificate of analysis (CoA).
• To ensure proper delegation of responsibility and accountability to bring in re-
quired efficiency, economy and transparency in procurement.
• To continuously explore possibilities of identifying and using new/ alternate
materials that has lesser impact on the environment.
• To ensure that the chemicals / dyes that are given by the supplier / manufac-
ture for trial usage purpose have the necessary SDS, TDS and MRSL compli-
ance.

6.3 Procedure:

6.3.1 Chemicals / Dyes for trials

When supplier / Manufacturer approaches for supply of chemicals / dyes or when new / al-
ternate chemicals are sought by us for trials , care shall be taken to ensure that such chemi-
cals / dyes are supplied along with Safety data Sheet ( SDS ) , Technical data Sheet ( TDS )
and CoA for MRSL or declaration that the product complies to MRSL requirement.

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When the supplier / Manufacturer is not able to submit the mentioned documents the
chemicals / Dyes supplied by them for trial purpose shall be duly returned to them.

All such chemicals / dyes that are received for trial purpose are entered in the Trial Register
and the products are stored are identified as “Trial “on the containers / bottles / packages.

If the Chemical / Dye is approved for use, then they are moved to the location that is allot-
ted for them. This shall happen after the approved list of Chemicals / dyes is updated and
the manufacture / supplier is brought inside the approved list.

6.3.2 Approved List of dyes and chemicals

All dyes and chemicals that are approved for use is brought into this list (Approved list of
chemicals and Approved list of Dyes) and approved for use. Any addition or removal of dyes
/ chemicals are done only on the authorization of Dyeing Manager and Managing Director.
This list is prepared by technical officer.

From this list the List of approved suppliers is extracted, and the materials supplied by them
are listed for establishing purchase control.

6.3.3 Compliance to MRSL requirements

All Approved dyes and chemicals are necessarily to have the SDS and MRSL compliance dec-
laration from the manufacturer.

During establishment of the CMS if it is observed that the materials are not supplied with
SDS and MRSL compliance declaration, the supplier / Manufacturer is contacted to supply
the same. In the absence of the supplier / manufacturer not supplying these documents, the
materials will be identified for “Phase Out “and time for Phasing out is decided by the dye-
ing manager.

Any dyes / chemical at any time during the usage, are found not as per the declaration by
the supplier / manufacturer then these materials shall also be identified for “phase out “.
Necessary action shall be initiated to discuss with the manufacturer or supplier for the er-
rors and proceed to black list if suitable corrective measures are not initiated by them.

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6.3.4 Purchase control
Based on the stock, purchase requirements are identified by the Stores In charge and ap-
proved by Dyeing Manager.
The procedure is controlled that the purchase order is raised on the approved supplier and
the approved manufacturer on the approved products in the list. All Purchase Orders shall
additionally carry the information on the SDS and MRSL declaration references and request
to supplier / Manufacturer to inform in case there is a revision or modification of the SDS or
MRSL Declaration.
On Receipt, the materials and the documents accompanying the materials are checked for
the correct name as per the Purchase Order and the approved list before proceeding to the
stores for further quality check and use.
All products are identified with the Manufacturer batch Number / Lot number and where it
is not available the stores department shall initiate a Lot number for following “First in First
out “FIFO system in stores for material issue.
Based on the verification, Goods Received Note GRN is raised and approved for further pro-
cessing at Finance department for payment.
Any goods that does not meet the criteria shall be returned to the suppler.

6.4 Forms & Records
1) Approved Chemical Supplier & Product List

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7. Chemical Safety Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

7.1 Policy

The Chemical Safety policy involves establishing, documenting and implementing a process
for assessing the hazards and risks associated with chemicals identified in the chemical inven-
tory and update those inventories annually. Hazardous chemicals are those that have an in-
herent property that can cause harm to humans or the environment and/or cause damage
through fire, explosion, corrosivity or toxicity. Hazard and risk information are obtained from
container labels, SDS, the internet and chemical suppliers.

7.2 Objectives

To define procedures including authority and responsibilities thereof in such a way that will
facilitate the Risk Analysis to meet following objectives: -

• To identify the potential hazard, risk associated with materials with respect to
health, safety and environment.

• Addressing the concerns and take actions to eliminate, mitigate the risk and
keep it under control.

• Periodical evaluation of risk and taking action on continuous basis.
• Undergo training to update the knowledge and keep update.

7.3 Procedure

7.3.1 Risk Assessment

Purchase Manager is responsible for the collection of SDS for the Chemicals & Dyes pur-
chase.

In case the Chemical & Dye Manufacturer or Agent is unable to supply the SDS such cases
shall be addressed with Dyeing Manager and Managing Director for further decisions.

Where ever the Manufacturer / Agents can provide the SDS shall be collect and update in
the Inventory control table and SDS shall be filed for further study and reference.
By using the Inventory control table the exposure possibility shall be identified and listed,
which covered the dyes / chemicals in usage and its nature, handling process, persons who

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handle or transfer the chemicals are listed and ensure the PPE’s are used appropriately to
avoid or minimize the effect of spillage and exposure effects on human.
Removal of Chemical from original packaging for weighing and dispensing will cause high
risk and pouring chemicals may result in exposure by spills or splashes. The PPE’s and Chem-
ical transfer kits shall be used to prevent from hazard and spill / splash to human.
The risk significance depends on the duration and frequency of exposure as well as the con-
centration of the substance involved.
Identification of Hazardous Chemicals Risks:

1. Hazard, risk and the probability of a chemical causing harm are reflected in an inter-
nationally accepted system of risk phrases (R-Phrases) and safety phrases (S-Phrases).

2. Many R-Phrases refer to health effects on humans (e.g. R34 means that the chemical
‘causes burns’). Other R-Phrases describe environmental effects (e.g. R50 means
that a substance is very toxic to aquatic organisms).

3. Certain R-Phrases also indicate that chemicals can be explosive or flammable or re-
act violently with water or oxidizing substances. It is important to know this and
take special care duringhandling or storage of these chemicals.

4. S-Phrases provide first advice for the safe handling of hazardous chemical sub-
stances and formulations (e.g. S34 means ‘avoid shock and friction ‘’)

5. R-Phrases and S-Phrases can appear alone orin combination. This is indicated by a ‘/’
between the numbers; e.g. R36/37 means that the chemical is both ‘irritating to eyes’
and ‘irritating to respiratory system’.

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GHS – Pictograms and their meaning

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Symbol Related to Health Risks and Different Level of Protection

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7.3.2 Risk Identification and Actions

The Safety Data Sheet (SDS or MSDS) is the first place to look for hazardous and risk expo-
sure information.

The Hazard and risk assessment inventory shall include the information regarding the fol-
lowing aspects

1. Chemical Name (To be referred to inventory list)
• Chemical Abstracts Service CAS Number

2. Process (Where the chemical is used) – such as Production, final product, labora-
tory, maintenance, discharge and other relevant information

3. Area (Where chemical is stores and used) - dye kitchen, storage.
4. Emergency Contact Information
5. SDS / MSDS Availability – Yes or No
6. Hazard Statement – R Phrases or S Phrases (Refer to the SDS/ MSDS)
7. Hazard Type –

• Physical (Flammability, Explosivity)
• Health (carcinogenicity, toxic to reproduction)
• Environmental (bio accumulative, persistency, eco-toxicity)
8. RSL / MRSL Compliance Chemical – Yes or NO
9. Amount Used per Batch / Process
10. Amount lost to the environment (Mass Balance)
11. Hazard Prioritization - Prioritization and ranking of the overall risks of the chemi-
cals

Risk Assessment Template

Hazard Who is Risk (Severity & Control Further Priority Action Action
Involved Likelihood) in Place Action 1 Date By
Example: 3 pro- Splashing – PPE only Consider Immedi- Manage-
Pouring so- cess em- skin/eye burns face eliminat- ate ment
dium hy- ployees Very likely and shield ing pour-
droxide so- extreme harm and ing. Re-
lution from Very high risk gloves struc-
bulk tank ture pro-
cess

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7.3.2.1 How to Determine the Hazard is Serious

The Hazard is studied to determine its level of risk based on

1. Product Information / Manufacturer Documents
2. Past Experience (Example: Workers information)
3. Legislated Requirements and / or applicable standards
4. Industry Coded of practices / best practices
5. Health and Safety Information about the hazard (Refer to MSDS)
6. Information from reputed organizations.
7. Results of testing (for example, atmospheric, air sampling of workplace, biologi-

cal)
8. Information about previous injuries, illnesses, near misses, accident reports,

work environment (Building / Storage area conditions)
9. Capability, skill or experience of workers who do the work
10. Working methods / systems
11. Range of foreseeable conditions

7.3.2.2 How to Prioritize the Risks?

The Hazard prioritize is one way to help in determine which hazard is most serious and thus
which hazard to control first.

Priority is established by considering the employee exposure and the potential for accident,
injury or illness. By assigning priority of hazard we shall rank in the action list for effective
control.

The following factors are considered to prioritize the risk:
1. Percentage of workforce exposed
2. Frequency of exposure
3. Degree of harm likely to result from the exposure
4. Probability of occurrence

The prioritization requires the knowledge of workplace activities and urgency or situations
and most importantly, objective judgement is followed to minimize the risk.

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Risk Assessment Severity and Likelihood

Severity of Harm

Slight Harm Moderate Harm Extreme Harm
Very low risk High risk
Very Unlikely Very low risk Medium risk Very high risk
High risk Very high risk
Unlikely Very low risk Very high risk Very high risk

Likely Low risk

Very Likely Low risk

7.3.2.3 Definitions for Likelihood of Harm

1. Very Likely – Typically experienced at least once every six months by an individual.
2. Likely – Typically experienced once every five years by an individual.
3. Unlikely – Typically experienced once during the working lifetime of an individual.
4. Very Unlikely – Less than 1 percent chance of being experienced by an individual
during their working lifetime.

7.3.2.4 Definitions for Severity of Harm

When establishing potential severity of harm, information about the relevant work activity
should be considered, together with (a) part(s) of the body likely to be affected, and (b) na-
ture of the harm, ranging from slight to extremely harmful.

1. Slightly Harmful – For example, superficial injuries, minor cuts and bruises, eye ir-
ritation from dust, nuisance and irritation and ill-health leading to temporary dis-
comfort.

2. Harmful – For example, lacerations, burns, concussion, serious sprains, minor frac-
tures, deafness, dermatitis, asthma, work-related upper limb disorders and ill-health.

3. Extremely Harmful – For example, amputations, major fractures, poisonings, mul-
tiple injuries, fatal injuries, occupational cancer, other severely life shortening dis-
eases and acute fatal diseases.

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7.3.2.5 Definition for Risk Level

Guidance on necessary action and time scale:

1. Very Low – These risks are considered acceptable. No further action is necessary
other than to ensure that the controls are maintained.

2. Low – No additional controls are required unless they can be implemented at very
low cost (in terms of time, money and effort). Actions to further reduce these risks
are assigned low priority. Arrangements should be made to ensure that the controls
are maintained.

3. Medium – Consideration should be as to whether the risks can be lowered, where
applicable, to a tolerable level and preferably to an acceptable level, but the costs of
additional risk reduction measures should be taken into account. Risk reduction
measures should be implemented within a defined time period. Arrangements
should be made to ensure that controls are maintained, particularly if the risk levels
are associated with harmful consequences.

4. High – Substantial efforts should be made to reduce the risk. Risk reduction
measures should be implemented urgently within a defined time period. It might be
necessary to consider suspending or restricting the activity or to apply interim risk
control measures until this has been completed. Considerable resources might have
to be allocated to the additional control measures. Arrangements should be made to
ensure that controls are maintained, particularly if the risk levels are associated with
extremely harmful or very harmful consequences.

5. Very High – These risks are unacceptable. Substantial improvements in risk control
measures are necessary so that the risk is reduced to a tolerable or acceptable level.
The work activity should be halted until risk controls are implemented that reduce
the risk so that it is no longer very high. If it is not possible to reduce the risk, the
work should remain prohibited.

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Example of Hazard Priority Setting Likely - Could Unlikely - Could Very Unlikely -
happen some- happen but Could happen
Very Likely - time very rarely but probably
Could happen never will
at any time 1

Kill or cause permanent 1 23
disability or ill health 1
2 234
Long-term illness or se- 3
rious injury 345

Medical attention and 456
several days off work

First aid needed

7.3.3 Environmental Impact

The Dyeing Manger is responsible for the Assessment and actions to be taken on the Chemi-
cal use and its environmental impact caused by dyeing factory

The discharge of effluent is monitored on daily basis and records are updated.

The effluent water is collected and tested for the base test like TDS, PPM

Once in a year, the effluent water is sent to external laboratory to check the contamination
level

The Effluent water is collected in the prescribed area and ensure there is no pilferage that
could lead to contamination of soil, water etc.,

Annually environmental tests are performed as per TNPCB norms to ensure there is no im-
pact on

1. Air
2. Soil
3. Ground Water
4. Noise and Nuisance
5. Waste and Sludge (from CETP)
6. Waste Water (from (CETP)

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7.3.4 Health & Safety

The Dyeing Manager is responsible for the Health & Safety of the entire facility.

Department wise in charges are responsible locally in their respective area of work.

Based on the outcome of risk assessment, recommendations in the SDS and experiences,
the PPE’s are purchased and deployed for use.

The PPE’s are issued to the workers who are exposed to the chemicals while storage, trans-
fer, dye kitchen and discharge of the effluent and handling process.
Periodical training is provided by External Agency / Internally by Dyeing Manager to all em-
ployees to ensure the PPE’s are used effectively and work place safety.

Periodical internal assessment (at least once in a year) on the Health & Safety requirements
carried out by the Technical Co Ordinator and reporting to Dyeing Manager for the actions
as necessary.

Display of the Health & Safety precautions and PPE’s usage at prominent places

The Chemicals which are without MSDS shall not be used. Chemicals without a proper MSDS
pose a risk to the workers.

The fire extinguishers as per the chemical manufacturer recommendations shall always in-
stall and maintain in working conditions.

To ensure Good Personal Hygiene the following facilities are provided
1. Separate Eating and Smoking area
2. Eye Wash and Shower facilities near the work areas where skin exposure may oc-
cur
3. Advise frequency and Training to workers to remove splashes / spills on skin im-
mediately
4. Advise workers to thoroughly was exposed parts of the body after work is com-
pleted
5. Prevention of contaminated items from being moved around the facility
6. Contaminated item such as work clothing after using chemical work to remove
and wash separately.

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Proper Use and Maintain PPE
1. Selection of PPE as per National Standard or Chemical Manufacturer recommenda-
tions.
2. Clear Instructions to workers to use PPE covering points like When, Where and
How.
3. Ensure the workers are wearing the PPE’s during work as needed
4. Place to store the PPE’s and clean properly and frequently inspected for its suitabil-
ity to use.
5. Management Plan and Budget for PPE replacement at recommended intervals (as
required)

7.4 Forms and Records
1) Risk Assessment Form – Chemicals
2) Risk Assessment Form - Process

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8. Chemical Storage and Handling Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

8.1 Policy

The storage policy involves the materials receipt, identification based on the hazard category
and ensure the traceability and safe work environment consistently with the quality needs,
complying with MRSL and statutory requirements for the proper operation & business sus-
tainability.

8.2 Objectives

To define procedures including authority and responsibilities thereof in such a way, that will
facilitate the stores activity to meet following objectives: -

• To identify chemicals based on the hazardous category.
• Storage of chemicals in the respective area safely.
• Display of the hazard category and instructions to handle the chemicals
• Waste Minimization in handling the chemicals
• Ensure the shelf life of the chemicals and disposal of the expired chemicals
• To prevent from the fire and or other accidents and minimize the hazard effect

to the environment.

8.3 Procedure:

8.3.1 Safe storage of hazardous chemicals

This topic provides guidelines to help us to meet storage standards.

The following points are taken into consideration and incorporated for guaranteed safe stor-
age of chemicals

1. Keeping an up-to-date chemical inventory
2. Proper chemical labeling
3. Allotting assigned space and necessary infrastructure for storage.
4. Segregation of incompatible chemicals
5. Keeping the storage area clean, avoid leaks spreading to the work environment
6. Avoid storing chemicals directly on the floor (we use cabinets, pallets, etc.)
7. Building a bund around storage unit

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8.3.2 Lay out of Chemical Store

The Chemicals store is physically separated from production area, office work area, product
storage (lot section), maintenance cabin which will consist of potential sources of ignition
such as Diesel Generator, Electrical panels and or Transformers.

The Dyes and Chemicals are stored separately for easy and safe handling and quality pur-
poses.

The chemicals are stored in flat (To allow easy handling of chemical containers) and non-
permeable to prevent contamination of soil and ground-water from chemical spillage.

The store is equipped with emergency drain method and connected to the Effluent Treat-
ment Plant.

The Chemical store is provided with clearly marked emergency exits routes with openable
windows for ventilation.

The Access to the exits is kept free at all times to allow easy escape of the personnel
trapped inside the stores room in an emergency situation.

At all time, unauthorized personnel are prevented from entering the chemical store. The
main doors are locked always. Any audit or customer’s visit to chemical store is allowed with
the safety precaution and Personal Protective Equipment (PPE’s) with the authorised person
guidance. The display of “PROHIBITING UNAUTHORIZED ENTRY” is made available at Entry
point.

The Stores Evacuation plan is displayed at the entry / exits points.

The fire extinguishers are installed with markings in the stores to access easily at all times.
One fire extinguisher is kept always outside the stores as a safety precaution.

The Chemical Stores is equipped with “explosion proof” switches, switchboards, light fittings
and cables. The Electrical switches are placed outside the chemicals store.

The chemicals are stored in the allotted location / area to facilitate access and trolleys for
easy transfer and movement of chemical containers.

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A washbasin, eye / face rinsing station is installed and available for use near the chemical
store for personal hygiene and emergencies.
8.3.3 Right storage for each chemical
Before storing the chemicals in the chemical store, an inventory of all chemicals is kept in
the store.
Identifying the hazardous chemicals (with the help of the safety data sheets - SDS). The SDS
contain specific guidelines for storage (e.g. temperature, humidity) as well as information on
compatibilities with other chemicals.
The Chemicals can react together and form hazardous mixtures which may possibly gener-
ate poisonous gas or heat. The latter can result in ignition of fire or explosion are identified
and kept separately to prevent from accidents.
Based on the quantity consumed by production and inventory plan, the area required for
chemicals are identified and any additional location required is provided by Dyeing man-
ager.
8.3.4 Basic rules and principles in the chemical store
Strictly it is followed NO SMOKING and NO USE OF OPEN FIRE in chemical stores.
The chemicals are stored based on the group and compatibility. Each group is stored inside
the floor yellow markings. Sufficient width of the aisle is given to ensure the movement of
person and materials. (Approximately 1 meter of width for movement of materials and
person movement).

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The Chemicals are identified with a tag indicating the following information

Identification Tag

• Chemical Name
• C.I./ C.A.S Number
• Physical Status

• Compatible with
• Remarks

The passageways are clearly marked with Yellow band and maintained to prevent from de-
terioration.

1. Heavier Chemical Containers – Mainly liquid chemicals (e.g. Acetic Acid) are
stored on wooden / plastic pallets at the floor level.

2. The small chemical containers (e.g. samples of dyes, fat-liquors) are stored in the
shelves for effective utilization of the storage space.

3. The powdered chemicals are NOT STORED directly on floor, as the humidity from
the ground can quickly spoil the quality of powdered chemicals.

4. Lighter Chemical Containers and Powdered chemicals are stored in the upper
shelves.

5. Barrels containing hazardous liquid chemicals are stored on catch-pits (TRAYS).
All the chemicals SDS are displayed in the storage rack for quick reference and a master
copy is maintained in the file at administration office. In case of emergency the SDS infor-
mation provide value and often life-saving clues on rescuing personnel and emergency situ-
ation

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8.3.5 Storage

8.3.5.1 Chemical Storage area requirements are identified

1. The storage area is labelled according to the type of chemical family or hazard
classification as given below:
• Flammables
• Corrosive acids
• Corrosive bases
• Toxics and highly toxics
• Oxidizing agents
• Compressed gases
• Water reactive
• Explosives

2. Peroxide forming chemical
3. The Storage area is inspected every 6 months once.
4. The aisles, doorways, exits and enter ways are always kept clean and clear for

uninterrupted access.
5. Storage area is well lit, appropriately ventilated.
6. Stores is prevented from open flames, heat sources or direct sunlight.
7. The emergency equipment – fire extinguisher is kept always in good working

condition.
8. The chemical store is confined so that leaks or spills are controlled, it is pre-

vented from running down sinks, floors or storm water drains.
9. Spill Control Kit for cleaning of spills.

8.3.5.2 Stores Don’t

1. Don’t store chemicals in a sink or fume hood.
2. Don’t store chemicals on dirt or grass, near a creek or storm drain entrance,

where they could contaminate the environment.
3. Don’t store chemical on the floor, window ledges or balconies

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8.3.5.3 Storage Cabinets

1. Label the cabinets according the group / hazard classification.
2. Always store the chemicals in the approved /allotted identified group wise cabi-

nets
3. Do not shift the flammable storage cabinet in any situation without authoriza-

tion

8.3.5.4 Storage Shelves

1. All the shelves are leveled, stable and secured to the wall or another stable sur-
face.

2. Shelves are raised with edges or rim guards to prevent containers from falling.
3. Shelves are always kept clean and free from chemical contamination and dust.
4. Shelves are kept away from the direct sun light, flames and hear sources.
5. The containers are stored in shelves such that it does not protrude over shelf

edges.
6. The large bottles/ containers are stored safely not higher than 60 cm from the

floor.
7. The corrosives category chemicals are always stored on lower shelves.

8.3.5.5 Storage Containers

1. The Containers are always kept closed unless there is dispensing or adding to the
container.

2. Containers are never kept open with a funnel in it.
3. Liquid Chemicals with more than 5 liters in size is kept in secondary containment.
4. For Flammable solvents the approved containers are used (as per the recommen-

dations of the manufacturer)

8.3.5.6 Chemical with Single Hazard Classes - Storage

1. The chemicals are not stored alphabetically unless they are compatible.
2. The flammable liquids are stored in the approved safety containers.

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3. Identify and segregate the acid and base category chemicals and stored sepa-
rately.

4. Identify and segregate the organic acids from mineral acids.
5. Keeping oxidizers away from other chemicals, especially flammable or combusti-

bles chemicals.
6. Keeping corrosive chemicals away from substance that they may react with the

release of corrosive, toxic, or flammable vapors.

8.3.5.7 Chemical with Multiple Hazard Classes - Storage

1. The chemicals belong to more than one chemical family or hazard class are iden-
tified and all storage rules are adhered strictly.

For example: acetic acid is both a corrosive acid and a combustible liquid. It must
be stored away from corrosive bases, such as sodium hydroxide and also from
oxidizing acids, such as nitric acid.

2. For more information we use the storage guidelines given in the SDS from the
manufacturer.

8.3.5.8 Storage precautions for flammable chemicals

1. The chemicals are kept away from all ignition sources:
• Open Flames
• Hot Surfaces
• Direct Sunlight and spark sources
• The oxidizers and toxic chemicals are stored separately
• Separating flammable gases from oxidizing gases with an approved non-
combustible partition or by a distance of 7 meters.
• Storing flammable liquids in approved safety containers or cabinets.
• Fire extinguisher (appropriate for the hazard) readily available and
trained person are available for operation.

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8.3.5.9 Storage precautions for corrosives acids and bases
1. The chemicals are segregated as Acids and Bases.
2. The inorganic oxidizing acids (e.g., nitric acid) from organic acids (e.g., acetic
acid), flammables and combustibles are segregated.
3. The acids are segregated from chemicals that could generate toxic gases upon
contact (e.g., sodium cyanide and iron supplied)

8.4 Forms and Records
1) Chemical Compatibility Chart
2) Identification Tag

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Table for chemical compatibility check

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MICRO COLOUR MAKERS
CHEMICAL MANAGEMENT SYSTEM

9. Common Effluent Treatment Plant Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

9.1 Policy

The Organisation enrolled to Common Effluent Treatment Plant with the vision of the sewage
water is treated and reused back to production process and eliminate or reduce the impact
of water pollution and protect the environment natural resources.

9.2 Objectives

To define procedures including authority and responsibilities thereof in such a way, that will
facilitate the collection of Effluent and sending to CETP to meet following objectives: -

• To store the Effluent generated in a safe place
• Communicate to CETP about the Effluent quantity and record the details
• Participate in CETP meeting and programs for the improvement
• Safe disposal of Sludge through CETP as per Government Norms

9.3 Procedure

9.3.1 CETP Process flow
The process flow is shown in the next page of this section.

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CHEMICAL M

Raw Effluent Filtrate / Supernatant
Re circulation
Storage & Homogenization Tank
Back Wash Stream Sludge Return Sump Sludge T
Biological Treatment System - Fil-
trate

Secondary Clarifier

Hypo Treatment System Regeneration HDTRF Treatmen
Liquor
Filtration System
RO Reject MVR Evapora
Reverse Osmosis System
Permeate Condensate Brine Treatmen
Recovered Water from
Brine Solution Rec
RO & Evaporator

To Member Units for Reuse

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MANAGEMENT SYSTEM

Thickener Filter Press Biological Sludge Storage Shed

Filtrate
nt System

Filter Press Chemical Sludge Storage Shed

ators MVR Reject

ME Evaporator / Crystallizer / Mother Liq-
FFE uor Final Re-
ject
nt System
covered Salt / Glauber Recovered Salt

Solar Fans / ATFD

Mixed Salt Storage
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MICRO COLOUR MAKERS
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9.4 Forms and Records
1) CETP Register

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10. Chemical Disposal Rev 0 - 9th March 2019

Issue 1 - 9th March 2019

10.1 Policy

The chemical disposal policy involves the materials which are to be disposed are based on the
hazard category and ensure the traceability of disposal are meeting the statutory requirements
and safe to environment with less effect.

10.2 Objectives

To define procedures including authority and responsibilities thereof in such a way that will facil-
itate the disposal of chemicals to meet following objectives: -

• To identify chemicals waste based on hazard category
• Store in the safe place to prevent pollution to environment
• Disposal of chemical waste with approved recyclers
• Traceability of disposal of chemical waste and
• Complying to national law / statutory requirements

10.3 Procedure:

10.3.1 Safe storage & identification of chemical waste

The Chemical which cannot be used are identified and separated from the stores.
The non-useable chemicals are stores in a separate place which is away from hot surface or di-
rect sunlight.
The packing materials of chemicals are stored separately.

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The identification of chemical waste is as follows

HAZARDOUS
WASTE

Contents: Paint and Varnish Sludge (08 01 13*)
Hazardous property: Flammable!
Department: _ABC Date: 01/12/2008

HANDLE WITH CARE!

CONTAINS HAZARDOUS OR TOXIC WASTE
Contact: Dep. HAZ or ___________________ for disposal

Sample of a hazardous waste label

Containers for Waste Storage

Sample of containers, 60-litre poly-ethylene canisters

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Samples of containers, 200-litre steel drums

Separation of incompatible wastes/materials

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Compatibility check for

C Corrosive
Xi Irritant

Xn Harmful
T, T+ toxic, highly toxic

F, F+ flammable, highly flammable
O Oxidizing

E Explosive

C Xi, Xn

C ✓✓

Xi

✓ ✓Xn

C Xi, Xn

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hazardous substances

Are allowed to be stored together

✓

Are allowed to be stored together, subject to special precau-

o tions

Are not allowed to be stored together



n T, T+ F, F+ O E

o  
✓✓ o 

n T, T+ F, F+ O E

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T,

o ✓T+

F,

 ✓F+
O o
E