Chemicals Management (within an EMS context):
A systematic, lifecycle-based approach integrated into the Plan-Do-Check-Act (PDCA) cycle that identifies, assesses, and monitors hazardous substances - specifically focusing on legal compliance and the substitution of substances of high concern - to eliminate or minimize negative impacts on human health and the environment.
Chemicals management and environmental management systems
Management of chemicals means a systematic approach to the identification and assessment of used hazardous chemicals as well as decision making and implementation of actions to ensure they are used safely along their lifecycle and to prevent any potentially negative effects from these hazards. The chemicals management process includes:
- identification of all chemicals used, including collecting information about related hazards, amounts, processes and products in which they are used,
- identification of legal requirements applicable to chemicals used,
- identification of activities aimed at preventing potential non-compliance with these requirements,
- identification of necessary operational activities, taking into account:
- hazards assessment,
- exposure assessment (where it is useful for decision making),
- decision making and implementation of necessary actions,
- monitoring and checking whether implemented measures have minimised or eliminated hazards
- implementation of additional activities (if needed).
This coincides with the approach of environmental management systems (EMS) based on the 4 continual improvement cycle called PDCA cycle, which involves:
- planning activities aimed at a specific effect,
- implementation of the adopted plan,
- checking whether the implementation took place as planned,
- elimination of deficiencies (and in principle the reasons for their occurrence) identified in the checking phase.
The management of chemicals will be most effective if it is integrated into an overall management system. This enables comprehensive solving of problems related to the use of chemicals.
One of the basis for the EMS is concept of ‘significant environmental aspects’. If significant environmental aspects determined by the organisation are related to hazardous chemicals the system should address them automatically. An organisation shall define the criteria for assessing the significance of the environmental aspects of its activities, products and services and apply these to determine which environmental aspects have a significant environmental impact considering a life cycle perspective. The criteria developed by an organisation shall take into account the legislation. Being aware of legal requirements, including upcoming changes and new policies, is one of the conditions for ensuring compliance.
Review of Industrial Emissions Directive (IED) is one of the upcoming changes related both to EMS and chemicals management. By July 2026 Member States must transpose in national legislations changes in IED, published in July 2024 (Directive (EU) 2024/1785). These changes include following:
- IED installation operators shall have certified EMS in place, the EMS shall be externally audited for the first time by 1 July 2027 (except for the ‘new’ activities in IED like manufacture of batteries, extraction of mineral resources);
- Chemicals are part of EMS: it shall include a chemicals inventory of the hazardous substances present in or emitted from the installation (Art 14a.2d) with special regard given to substances of very high concern (SVHC) and others fulfilling the criteria referred to in Article 57 of REACH and restricted substances in Annex XVII of REACH – in this case specific risk assessments and analysis of substitution options are obligatory (i.e. use of a SCVH or a restricted substance is automatically a significant environmental aspect).
- There should be a transformation plan in place by 2030: how the operator will transform the installation during the 2030-2050 period to contribute to the emergence of a sustainable, clean, circular, resource-efficient and climate-neutral economy by 2050 (Article 27d).
- The EMS should be in line with relevant BAT guidances-conclusions. There will be new generation of BAT documentation, as achieving climate neutrality is also in focus besides chemicals, and there is need to consider strictest emission limit values, if a range is given.
A guide based on the ISO 14001 standard or EMAS Regulation has been elaborated in the framework of Interreg NonHazCity2 project in June 2021.
FFR2 project is providing further guidance how to address chemicals in EMAS scheme.