C3. Hazardous Substances

Code 7.0

Chemical, waste and other materials posing a hazard to humans or to the environment are to be identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure the facility's environmental policy provides that:

• a. Hazardous substances including wastes are properly categorized, labeled, handled, stored and transported and disposed using government-approved and/or licensed vendors.
• b. Adequate and effective procedures are in place for the reception, storage, dispensing, and use of hazardous substances.
• c. Hazardous waste is safely disposed of, including a disposal supplier(s) assessment.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. Hazardous substances are adequately and effectively categorized, handled, stored, and moved within a single facility or between multiple facilities.
• b. 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.
• c. An adequate and effective reduction program is maintained with:
  • i. Annual objectives
  • ii. Regular objective tracking
  • iii. Progress monitoring
  • iv. Adjustments made if off track.
• d. A periodic assessment and corrective action plan process evaluates whether the vendor (hazardous waste handler AND transporter) is complying with contract terms and conditions.
  • i. Assessments should occur at least every 3 years or when there is a significant change.
  • ii. The assessment must occur before a new vendor (hazardous waste handler AND transporter) is selected.
• e. Engineering and administrative systems for improved resource efficiency adhere to the hierarchy of resource efficiency 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. Access to hazardous substances is controlled.
• b. Potential employee exposure methods are adequate and effective such as:
  • i. Segregation
  • ii. Secondary containment
  • iii. Ventilation
  • iv. Fire protection
  • v. Appropriate storage cabinets
• c. Adequate and effective process to track, review, and approve the use of all hazardous chemicals, obtaining approvals for all new purchases of hazardous chemicals prior to use.
• d. Selection processes for all new hazardous chemicals include a thorough evaluation of less hazardous or non-hazardous alternatives.
• e. Engineering and administrative systems intended to improve resource efficiency are in good repair or operating at high capacity.

4. Records

Records are maintained including:

• a. Accurate chemical inventory records are maintained and available for review.
• b. Inspection records of hazardous substances and their points of storage and use are maintained and available for review.
• c. Copies of hazardous substances inventory, manifests and shipping papers are maintained and available for review.
• d. Documents confirming that only vendors approved and/or licensed by the local regulatory authorities for transporting and disposing of hazardous waste are used.
• e. Assessment visit minutes or audit reports, with possible areas for improvement, are available for review.
• f. Annual reduction targets, progress monitoring and corrective action plans if applicable.

5. Serious conditions to ensure do not occur include

• Hazardous substances (including wastes) are used, handled or stored in a manner that could result in imminent loss of facility, life or cause severe bodily damage.

Not Applicable: No hazardous substances (including wastes) used or stored on site.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Hazardous Substances (RBA Code of Conduct 7.0, code C3): Earliest imported version (published as C3 in VAP 7.0.0). Covered proper categorization, labeling, handling, storage, transport and disposal of hazardous substances including wastes using government-approved/licensed vendors; controlled access and exposure controls (segregation, secondary containment, ventilation, fire protection, storage cabinets); chemical approval and evaluation of less/non-hazardous alternatives; a hazardous-waste reduction program with annual objectives and a vendor assessment at least every three years; the hierarchy of resource efficiency; and the associated inventory, inspection, manifest and assessment records.