Inventory - the first step in the substitution work
To make an inventory means that your company makes a list of all chemicals that are handled in your business. Chemicals have many important functions and are, in principle, found in everything we produce in society. Chemicals occur in liquid form such as oils and liquids; in solid form in various materials and articles, for example plastic, cardboard and textiles; and in powder or gaseous form in, for example, aerosol products. There may be hazardous chemicals used in the manufacture of your products, regardless of whether you trade in chemical products, materials or articles. This applies both if you manufacture the products yourself or if you purchase or import them.
Establish a list of chemicals
Anyone who places a chemical product or an article on the market is responsible for ensuring that it does not pose a risk to humans or the environment. For chemical products there are requirements that a list of chemicals must exist both in the Self-Control Ordinance in the Environmental Code and in the Swedish Work Environment Authority's regulations. The purpose of a list of chemicals is to map which chemicals are handled in the business and whether they constitute a risk. Minimum requirements for a list of chemicals are among others that it must contain the name of the chemical product and the classification of the product in accordance with the CLP Regulation. The Swedish Chemicals Agency recommends that the list of chemicals also contains information about the product's substance content and the substances' classifications. That makes it easier to ensure that you are compliant with the laws and regulations in the chemical area. Similar to the use of lists for chemical products, digital logbooks can be used for articles and materials.
A simple list of chemicals can be created in an Excel file, but there are also chemical management systems that help you to document and keep track of your substances. Various systems for documenting information on substances and chemical risks are available on the market, covering both chemical products and articles. Many companies choose to include additional information to their lists and logbooks, to be able to use them as documentation and as a foundation for their chemicals management work. This makes it easier to work proactively and to replace hazardous chemicals with safer alternatives.
What chemicals are handled in the business?
To find out which chemicals are handled in your business, you may need to retrieve information from both internal and external sources. It may be a good idea to start the overview with a physical inventory of cabinets, storage and similar.
Here are examples of questions that can be of assistance:
- Is there a list of all chemical products used in our processes? For example, raw materials, catalysts, hardeners and similar.
- Is there a list of other chemical products that exist or are used in our business for various reasons? It can be refrigerants, pesticides, technical oils, detergents, fuels and more.
- What does the flow of chemical substances in the business look like? How large volumes do we buy in and where from? How much is stored on a single occasion? Where do the chemicals go?
- You need to have access to the safety data sheets (article available in Swedish only) for the chemical products that require it by law. If you have questions about the safety data sheets, contact your supplier.
- Find out which substances are included in articles and materials. You may need to ask the supplier for information on this.
- Are there any so-called SVHC substances (substances on the Candidate List (article available in Swedish only), which are included in articles handled by the business?
- Use the search function in PRIO to fill in the list of chemicals with information about the substances' hazardous properties and priority level and whether the substance is covered by any legislation.
Do you know the legislation?
Substances in chemical products and articles are regulated in several different regulations, both at national level and at EU level. As a company you are responsible for complying with the laws and for ensuring that the requirements of the legislation are met.
The EUCLEF (European Union Chemical Legislation Finder) is a tool that compiles legislation concerning chemicals within the EU.
More information about relevant legislation can be found on the Swedish Chemicals Agency's website under rules and regulations. Also keep in mind that the rules of consideration in the Environmental Code apply. They include among other things the knowledge requirement, the product selection principle, and the precautionary principle. Read more about the rules of consideration in Chapter 2 of the Environmental Code.