C2. Hazardous Substances

Code 8.0

Chemicals, waste, and other materials posing a hazard to humans, or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Hazardous waste data shall be tracked and documented.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure the facility's environmental policy includes hazardous substances elements including:

• a. Hazardous substances including wastes are properly categorized, labeled, handled, stored, and transported and disposed of using government-approved and/or licensed vendors.
• b. Ensuring workers understand what hazardous substances they are working with, the risks involved and how to protect themselves.
• c. Hazardous waste is safely disposed of including a disposal Supplier(s) assessment.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. The facility has an up-to-date inventory of chemicals and hazardous materials on site.
• b. Hazardous substances are adequately and effectively: Categorized, Handled, Stored, Moved
  • i. All chemicals are stored in properly designed and maintained cabinets or storerooms.
  • ii. All chemicals are stored in appropriate containers that are properly labeled.
  • iii. Chemicals and other hazardous materials are properly handled, transported, used, and stored by appropriately trained personnel.
  • iv. Adequate control of temperature, security, ventilation, and fire risk is maintained in chemical use and storage areas.
• c. Worker education and protection
  • i. Hazardous material information [labels and safety data sheet (SDS formally MSDS)] or characterization in the case of hazardous waste) is available at the points of use and storage in a language understood by the worker.
  • ii. Personal protective equipment appropriate to the materials being handled is provided to workers.
  • iii. Workers are trained on the proper use, maintenance, and storage of personal protective equipment.
  • iv. Workers have the freedom to refuse tasks that the worker believes to be hazardous without penalty or termination.
  • v. Emergency eyewash and shower stations are available to workers in areas where chemicals and hazardous materials are used or stored.
• d. Disposal
  • i. Chemical and hazardous wastes are disposed of onsite in accordance with local environmental laws or the supplier uses a licensed hazardous waste transporter to ship waste offsite to a licensed waste disposal facility.
  • ii. Where practical, waste chemicals are processed for re-use or recycling.
• e. Disposal vendor assessment
  • i. A periodic assessment and corrective action plan process to evaluate whether the vendor (hazardous waste handler AND transporter) is complying with contract terms and conditions.
  • ii. Assessments should occur at least every 3 years or when there is a significant change
  • iii. The assessment must occur before a new vendor (hazardous waste handler AND transporter) is selected.
• f. The facility has written and practiced emergency response plans in the event of a release of a chemical or material that poses a hazard to the environment. The plan includes the following elements:
  • i. Identification and assessment of release hazards (e.g. spills and leaks).
  • ii. Qualification and training of emergency responders (e.g. spill response teams).
  • iii. Who to contact in the event of a release.
  • iv. List of emergency response equipment.
  • v. Evacuation procedures.
  • vi. Procedures for proper clean-up and disposal of released materials,
  • vii. Decontamination procedures.
  • viii. Reporting requirements.
• g. An adequate and effective reduction/replacement program with
  • i. Annual objectives
  • ii. Regular objective tracking
  • iii. Progress monitoring
  • iv. Adjustments made if off track.

NOTE: Reduction programs should not harm workers and the expectation is not something that is done at "any cost"/excessive cost such that the operations are uncompetitive.

• h. Engineering and administrative systems for improved resource efficiency adhere to the hierarchy of resource efficiency, reducing the use of hazardous substances, when feasible, showing preference (in order) for the following functions:
  • i. Prevention: unnecessary consumptive processes are eliminated
  • ii. Minimization: Process efficiency is improved
  • iii. Substitution: Using a more environmentally benign or renewable resource
  • iv. Reuse, recycling, recovery: In that order, in order to maximize the benefit of resource consumption.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Engineering and administrative systems intended to improve resource efficiency; reducing use/volume of hazardous substances, are in good repair or operating at high capacity.
• b. Access to hazardous substances is controlled.
• c. Potential employee exposure methods are adequate and effective such as
  • i. Segregation
  • ii. Secondary containment
  • iii. Ventilation
  • iv. Fire protection
  • v. Appropriate storage cabinets
• d. A preventive maintenance process for all treatment equipment for each environmental medium.
• e. Adequate and effective processes to track, review, and approve the use of all hazardous chemicals and obtain approvals for all new purchases of hazardous chemicals prior to use.
• f. Selection processes for all new hazardous chemicals include a thorough evaluation of less hazardous or non-hazardous alternatives.
• g. Adequate and effective emergency response process with clearly defined steps and roles/responsibilities
• h. Investigation of each environmental incident (e.g., spill, etc.) resulting in a preventive and corrective action plan.

4. Records

Records are maintained including:

• a. Risk assessment results
• b. Mitigation plans for all significant actual and potential risks identified, through the Hierarchy of controls and improvement objectives in a documented gated process, demonstrating that each hierarchy level has been fully evaluated and reasons why it could not address the risk fully before proceeding to the next hierarchal level, indicating the status of implementation, and resulting impact reduction including feedback of the affected internal and external stakeholders.
• c. Inspection records of hazardous substances and their points of storage and use are maintained and available for review.
• d. Hazardous waste inventory records are maintained, tracked and accurate.
• e. Inspection records of hazardous substances and their storage points (including wastewater) are maintained, and accurate.
• f. Copies of hazardous waste shipping papers are maintained and accurate.
• g. All non-government transport and disposal vendors have approved, current certificates and/or are licensed by the local regulatory authorities.
• h. Assessments, visit minutes, or assessment reports, with possible areas for improvement, are maintained for each non-government transport and disposal vendor.
• i. Investigation reports of each environmental incident (e.g., spill, etc.) resulting in preventive and corrective action plans including evidence of review by management.
• j. Annual reduction targets, progress monitoring and corrective actions plans if applicable.

5. Serious conditions to ensure do not occur include

• Disposing of or handing off hazardous waste to non-licensed transport or disposal vendors.

1.0.0 (2024-01-01)

Changed

• Initial release for RBA Code of Conduct 8.0: Comprehensive criterion covering hazardous substances identification, labeling, management, disposal, and emergency response aligned with ISO 14001 and Basel Convention requirements.