Article
How to manage your raw materials and chemicals
In brief
ENV3522 asks: "What actions has your company implemented to manage raw materials and chemicals?" — nine sub-actions. As with waste (ENV3549), most of the evidence already exists in an industrial file: procedures, safety information sheets, collector registers, certificates. The work consists of linking each document to the right sub-action, identifying the real gaps, and not wasting evidence that is expected elsewhere in the questionnaire.
What are the nine sub-actions and their evidence?
1. Reducing material consumption through process optimisation. Invoices and installation records for high-efficiency equipment, presentation of improvements, before/after consumption comparison. Examples: lean production techniques, computer-aided manufacturing, process digitalisation.
2. Recovery and reuse of materials from the company's activities. Recovery reports, plans for the use of scrap and by-products, case studies. The document must demonstrate the regeneration of materials (offcuts, shavings, remnants) generated in manufacturing, their recycling into new items or their repurposing — used internally or sold to third parties.
3. Ecological or bio-based processing materials. Invoices, ingredient lists, material specifications, R&D documentation. Mind the scope: materials consumed in the process (plant-based lubricants, low-toxicity degreasers, biodegradable consumables for internal logistics), not the finished product or primary packaging.
4. Measures to respond to environmental emergencies. Emergency response procedure, drill and inspection records, equipment installation records. The document must cover contamination of soil, water or air (solvent or chemical-additive spills), testing of procedures and evaluation of response effectiveness.
5. Labelling, storage, handling and transport of hazardous substances. Detailed instructions, equipment invoices, inspection reports, incident registers. Examples: CLP/GHS-compliant labels, sealed containers and non-tipping packaging, mechanical lifting devices and protective barriers, safety signage. Scope: hazardous substances as processing materials, excluding hazardous waste.
6. Employee training on safe management of hazardous substances. Training material and proof of delivery (reports, certificates). Same scope as sub-action 5.
7. Specialised treatment and safe disposal of hazardous substances or waste. Hazardous-waste management plan, permits and licences, service contracts, disposal certificates — neutralisation or treatment compliant with regulation.
8. Less hazardous alternative substances in operations. Chemical-use reports, substitution tests, formulation-change reports, composition labels. Examples: biodegradable surfactants, enzyme-based processes, natural dyes.
9. Other actions not covered elsewhere in the question.
What does a real file look like at a Walloon printer of size S?
Of the ~70 documents in the file, 9 are directly usable and 6 more are exploitable with adaptation. Seven of the nine sub-actions are covered or adaptable; two remain real gaps.
| ENV3522 sub-action | Evidence | Status |
|---|---|---|
| 1. Material-consumption reduction | 2023-2025 environmental-indicator synthesis + compliance and commissioning file for the new presses | ⚠️ To build — a "before/after" note linking the new machines to reduced waste-run |
| 2. Recovery / reuse | Waste-treatment procedure — cores re-sorted and reused, ink buckets recovered by the colourists, plastic plates and cores returned to the supplier, wood/pallets taken back + Valipac recycled-wood certificates | ✅ Direct, the best evidence in the set |
| 3. Bio-based materials | Nothing conclusive | ❌ Gap |
| 4. Environmental emergency | 2025 internal emergency plan + 2026 pollution-prevention file (+ analysis annex) + groundwater analysis report | ⚠️ Adaptable — the plan is people-oriented; add a solvent/ink spill section (absorbent kit, soil/water alert) |
| 5. Labelling, storage, handling | SIS n-propyl acetate (CLP/GHS pictograms, H225/H319/H336, storage instructions, PPE, fire) + Kinney risk analysis + PPE safety flash | ✅ Direct — extend the SIS model to the other solvents/inks |
| 6. Hazardous-substances training | The same SIS as material + post-training operator evaluation sheet + 2025/2026 annual training plan (ink traceability, colour/ink-station upskilling) | ⚠️ Missing: the signed attendance list of a "chemical risk" session — reuse the attendance format of an existing toolbox |
| 7. Hazardous-waste disposal | Licensed collector's 2024-2025 register (11 quantified hazardous streams: paints in 200 L drums, contaminated packaging, inorganic acids, IBCs) + waste procedure + WEEE certificate | ✅ Direct — add the collector's contract and licence |
| 8. Alternative substances | Ink supplier's EU 2025/40 compliance sheet: ~60 inks/varnishes without intentional heavy metals (<100 ppm Pb+Hg+Cr+Cd) and without PFAS/PTFE waxes | ✅ Direct, but it is compliance, not substitution — strengthen with evidence of a formulation change |
| 9. Other | FSSC 22000/ISO 22000 certificate (control of incoming materials), supplier VACCP analysis | ✅ Supporting |
What are the two real gaps — and the trap?
Action 3 (bio-based) and action 6 (training evidence). Number 6 is the most profitable: a half-day on the solvent safety sheets with a signed attendance list, and it turns green. Number 3 requires a real fact — a plant-based lubricant, a low-VOC cleaner, a bio-based washing solvent — to verify with procurement before attempting anything.
The trap: do not recycle supplier documents (VACCP, code of conduct) in ENV3522. EcoVadis expects them under Sustainable Procurement; counting them twice adds nothing.
Key takeaways
- Nine sub-actions; in a typical industrial file, most are already covered by existing documents (procedures, safety sheets, registers, certificates).
- CLP/GHS-format safety information sheets are triple-use evidence: labelling-storage (5), training material (6), and the template for extending to other substances.
- A supplier compliance sheet is usable under sub-action 8, but evidence of actual substitution is worth more.
- The two recurring gaps: bio-based materials (requires a real fact) and training attendance (a half-day is enough).
- Never count supplier documents twice: ENV3522 for your operations, Sustainable Procurement for your chain.