University-wide procedure for chemical product management

PROCEDURE
Policymaker: Sustainability Manager
Valid from: 29 March 2019
Amended as of: March 2023
Registration number: V-2023-0004-17
Responsible division: KTH Sustainability Office

1. Purpose

The purpose of this procedure is to minimise the negative impact on the environment (emissions to air, water and soil) by means of through safe handling of chemicals on the basis of binding requirements and KTH’s activities.

2. Scope/delimitation

The procedure is applicable to all schools at KTH and Operational Support (OS) that handle chemicals with an impact on the external environment. The supervisory authority is the environmental administration. The HR division at OS provides administrative support for the working environment aspects of chemical product management.

3. Definitions

The following definitions are used for chemical product management at KTH:

Handling

An activity or action that involves the manufacture, processing, treatment, packaging, storage, transportation, use, disposal, destruction, conversion, marketing, transfer or any other comparable process for a chemical product or biotechnical organism.

Chemical/chemical product

A chemical substance or a preparation of chemical substances that is not an article. (Environmental Code Chapter 14, Section 2)

Biotechnical organism

A product that is produced specifically as a control agent or for any other technical purpose and which, wholly or in part, consists of or contains living microorganisms, including viruses, or nematodes, insects or arachnids. (Environmental Code Chapter 14, Section 2)

Chemical waste

A chemical substance or preparation of chemical substances that is not an article and is intended to be disposed of.

KLARA

Web-based chemical product management system used by KTH. An annual administration plan is established regarding the system.

CMR substances

Substances that are carcinogenic, mutagenic and reprotoxic. The hazard statements for CMR-classified products are H340, H350, H360.

4. Responsibilities

The Sustainability Manager is responsible for:

• regularly reviewing the general organisation for chemical product management with regard to impact on the external environment and creating networks and dialogue with the parties responsible for chemical product management.
• providing a legal monitoring system so that the schools and OS are able to monitor and ensure compliance with the law.
• monitoring binding requirements in respect of chemicals in respect of the environment and ensuring that the information is made available to the schools.
• acting as KTH’s KLARA system owner.
• cooperating with the KLARA system administrator and working to ensure that the necessary support is provided so that KTH can fulfil legal requirements and internal requirements in respect of chemicals.

The KTH Sustainability Office is the system owner of the KLARA system.

The system administrator for KLARA in Operational Support (OS) is responsible for:

• monitoring KTH’s use of the KLARA system in order to maintain the quality of the system.
• ensuring that chemical product inventories are conducted annually in the KLARA system.
• acting as a system administrator and supporting KTH’s schools in the KLARA system and arranging regular information meetings and training courses on the use of KLARA.

The Head of School is responsible for:

• ensuring that documented procedures are available that include job descriptions and that there is a clear division of responsibilities for chemical product management at the school, including the purchase of chemicals and emergency preparedness.
• that chemicals are handled at the school in accordance with established procedures.
• ensuring that people who handle chemicals have sufficient expertise.
• ensuring compliance with legal requirements in respect of chemicals.

Users of chemicals are responsible for:

• participating in relevant training courses.
• performing proper risk assessment of all handling of chemicals in accordance with applicable laws before starting work.
• ensuring that if a CMR substance is to be used, a CMR investigation has been conducted as part of the risk assessment process.
• knowing where current safety data sheets (SDSs) and risk assessments are available and to read them prior to use. If there is no SDS, the user must ensure that an SDS is added to KLARA, with the help of the school’s KLARA administrator if necessary.
• checking with the line manager to ensure that a licence/exemption exists or is being applied for if this is required for the chemicals.

Other KLARA functions such as system administrators, the schools’ KLARA administrators, quality reviewers and chemical stocktakers are described in the administration plan for the KLARA chemical product management system.

5. Implementation

Purchasing

The purchasing officer or equivalent is responsible for ensuring that chemicals are primarily purchased via established framework agreements, or otherwise via the correct procurement procedure.

The responsible function is responsible for ensuring that safety data sheets, formulated in accordance with European legislation (REACH Regulation (EC) No 1907/2006) and with classification according to CLP (Regulation (EC) No 1272/2008), is obtained by the supplier upon purchase. The safety data sheet must be entered in KLARA for the product unless it is already there.

When updated safety data sheets are received for an already audited product, these are sent to the school’s KLARA reviewer or the KLARA system administrator at OS, who is able to add them to the product and re-audit the product.

Products that are not subject to labelling requirements under CLP are not required to have safety data sheets, but the supplier needs to certify this in writing, e.g. in a certificate, email or safety data sheet. Written certification must be uploaded for the product in KLARA.

The responsible function is responsible for ensuring that registration takes place upon delivery, before the product is used in the organisation. Indicating the country of import is mandatory, all chemicals purchased via framework agreements are registered as “not imported”. When “new” chemicals need to be registered in KLARA, i.e. when they are not already included in the database, the person entering the chemicals must be appointed by the school/division and be qualified for the task. All chemical products used in KTH activities must be registered in KLARA.

The responsible function must ensure that a specific CMR investigation is conducted before purchasing CMR-classified substances. A CMR investigation or reference to a CMR investigation is added to the risk assessment in KLARA. Chemicals requiring licences and substances on the Candidate List (candidates for inclusion on the Authorisation List) should also be assessed to see whether they could be replaced with less hazardous chemicals.

If a chemical requiring a licence is to be used, the responsible function must ensure that a licence is obtained prior to purchase. Licences must be entered in the legal monitoring system. There are functions in both the legal monitoring system and KLARA to help monitor the validity period of the licence.

Use

The responsible function is responsible for ensuring that chemicals are used in a manner that minimises damage to the external environment and the working environment.

The responsible function is responsible for ensuring that a risk assessment is performed for all work with hazardous substances and that any actions to mitigate the risks are conducted before work begins. Safety data sheets constitute an important basis for risk assessment. Risk assessments must be documented and stored.

More information on risk assessment, CMR investigation and exposure  can be found on the KTH intranet.

If the use of mercury is considered necessary, the responsible function must ensure that an exemption has been applied for and obtained from the Swedish Chemicals Agency. Contact KTH’s lab safety coordinator, who will make the application.

The system administrator for KLARA is responsible for requesting and compiling the annual consumption of organic solvents and reporting KTH’s total annual consumption to the environmental administration by 31 March each year. The responsible function at the schools/OS reports the school’s annual consumption to the system administrator for KLARA. Reporting must take place no later than one week before reporting to the environmental administration takes place.  

Refrigerants are reported by the responsible function at the school. This is done directly to the environmental administration by 31 March each year.

Storage

The parties responsible for chemical product management ensure that procedures are in place to ensure that chemicals are stored in a manner that provides a safe environment and a safe working environment. Information on storage is taken from safety data sheets.

Information about flammable and explosive products  can be found on the KTH intranet.

Stocktaking

The responsible function at the schools and OS must ensure that an inventory of all chemicals used in the activities is conducted in January and February each year. The school’s KLARA administrator is responsible for ensuring that an up-to-date list of the school’s stocktakers can be found in KLARA. The KLARA system administrator is responsible for ensuring that training sessions for stocktakers are offered before the inventory period, and also for sending out information prior to an inventory.

Waste

Chemical waste must be managed in a manner that provides a safe environment and a safe working environment according to legal requirements. Information is taken from safety data sheets and local procedures. Laboratories must be designed to ensure that waste is managed safely and does not enter the municipal drains. The waste must be placed in appropriate packaging/containers that are clearly labelled with their contents.

Volumes of chemical waste and hazardous waste, biological waste and other hazardous waste sent away must be noted, transport documents must be established and volumes must be reported to the Swedish Environmental Protection Agency.

For more information regarding waste management, please see the general waste procedure  and the guidance on the KTH intranet, hazardous waste management .

6. Appendices

No appendices.

7. Documents

• Administration plan for the KLARA chemical product management system, and other information relating to KLARA  on the KTH intranet.
• KTH’s general waste procedure
• Information on exposure registers, risk assessments and CMR substances  and related forms.
• Information on flammable and explosive products  on the KTH intranet

 8. Change log