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Who is responsible?

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Who is responsible?

Clear responsibilities define who handles what CRM tasks and ensure that everyone understands their role. Procedures standardise how tasks are carried out and increase transparency. Adequate resources must be provided so that staff have enough time to fulfil their responsibilities.

What are the benefits of clear responsibilities, procedures, and resources?

In regard to clear responsibilities, the benefits are that:

  • Everyone knows who can be asked or made responsible in case of problems,

  • Staff feels more dedicated to tasks

  • Ensures that all tasks are implemented, and nothing is omitted simply because nobody feels responsible,

  • Should be linked to decision power, i.e. staff can act regardless of their place within the hierarchy. This increases work satisfaction and supports lean management.

In regard to clear procedures, the benefits are that:

  • Routine processes and harmonised actions are implemented,

  • (New) staff can be supported during the transfer of tasks,

  • Updating of routines informed by experience ensures institutional learning.

In regard to clearly allocated resources, the benefits are that:

  • Tasks are done and not sacrificed for other tasks. Overall workload is well-managed,

  • Increases the predictability of workloads at managerial level and staff are given guidance about how much time they can spend on implementing their tasks,

  • If resource spending is monitored, better information is available on the efforts of risk management within the company.

What are the legal requirements?

There is no legal requirement to define responsibilities and procedures for CRM chemicals risk management (CRM) in companies. However, there are some requirements stipulated by the EU and national legislation regarding the competences of staff working on specific CRM tasks.

Employers are responsible for:

  • Carrying out workplace risk assessments for chemical agents and keeping them up to date,
  • Implementing prevention and exposure reduction measures according to the hierarchy of control (substitution, engineering controls, administrative measures, PPE),
  • Providing workers with information and training regarding the safe use of chemicals,
  • Ensuring appropriate health surveillance where indicated by the risk or required by law (particularly for CMR exposures),
  • (If the company supplies substances/mixtures) ensuring that SDSs are compiled by a competent, trained person and maintained in compliance with REACH Annex II.

The employer may appoint internal or external specialists, but legal responsibility resides with the employer.

Estonia

General competence required for anyone handling chemicals — the handler must possess the necessary information, knowledge, skills, experience and attitudes (“competence”), set out in the Chemicals Act § 8(2); the Act also lists what this competence includes in § 8(3).

Latvia

Specific education/competence is required for OSH specialists, who perform workplace risk assessment (internal supervision of the work environment). See Cabinet Regulation No. 723 on competent specialists and VDI guidance on required training routes for labour‑protection specialists.

Lithuania

Staff working with “poisonous substances” must meet established competence requirements (permit + competency certification process). “Poisonous substances” are defined as Acute Toxicity Cat. 1–3; CMR 1A/1B; STOT SE/RE Cat. 1 under CLP. Competence certificates are issued by the NVSC. IX-456 Republic of Lithuania Law Amending Law No IX-456 on Control of Poisonous Substances

Poland

No additional national, chemical‑specific competence requirements beyond EU law; employers must ensure OSH training and can use an internal or external OSH service for the performance of risk assessments under the Labour Code framework.

What should be considered and defined?

Responsibilities

Designate a specific owner for each of the responsibilities:

  • Overseeing the overall CRMS, including tasks like progress monitoring, initiating reviews of policy and goals, being the contact person for all involved staff to discuss and assess challenges and new ideas, 
  • Setting up and maintaining a chemicals inventory, 
  • Ensuring legal compliance, e.g. assessing what chemicals-related requirements exist and whether they are all implemented, documenting compliance, and monitoring legal changes and future regulatory developments and providing information about such, 
  • (Chemicals- related) occupational health and safety tasks, including workplace risk assessment regarding chemical, implementation of chemicals-related precautionary measures, developing workplace instructions regarding the handling of chemicals, etc., 
  • (Chemicals-related) environmental issues, including permitting and monitoring of emission limit values, wastewater treatment / discharge, treatment of air emissions, waste management, 
  • Ensuring chemicals-related purchasing criteria are implemented, information on chemicals (Safety Data Sheets (SDSs) and additional) is obtained and forwarded within the company, 
  • Chemical safety of the products, eco-labelling and certification, consumer communication, 
  • Compilation of SDSs and additional information on hazards and risk management for downstream users, answering customer requests regarding chemicals, including in emergencies, 
  • Storage of chemicals in and emergency plans/measures if relevant (i.e. SEVESO installation), 
  • Chemicals risk/sustainability assessment of substances and mixtures throughout the life cycle.

Procedures

The need for standard operating procedures within the company as applicable bearing in mind the size of the enterprise, its management culture, the existence of quality management systems and handbooks and many other factors. It is useful to develop procedures appropriate for complex methods and processes.

To decide on the need for such procedures, ask the following questions: 

  • Who would use the procedure and how often? 
  • Does such a procedure facilitate the transfer of tasks and documenting knowledge for the future? 
  • In what other cases do such procedures exist? 
  • What experiences have been acquired through operating procedures (these should be considered when drafting new ones)?

Resource allocation

  • Implement a documentation system to regularly monitor resource spending, especially during the first years of CRMS implementation, in order to learn how much time should be allocated,
  • Anticipate a learning curve as staff take on new responsibilities and tasks,
  • Provide professional training to speed up proficiency,
  • Provide staff with appropriate (software) tools to reduce the time required for implementation of tasks.

How to integrate CRMS responsibilities into existing systems?

  • Attribute CRMS responsibilities to existing roles by updating job descriptions (responsibilities, tasks) and increasing resources,

Examples: the Environmental Manager is responsible for overseeing chemicals management. The Product Manager responsible for assessing chemical risks from products.

  • If no suitable role exists, create a new role (e.g., CRMS/CRM Officer),

  • Ensure that staff have the additional competences required and provide professional training for new tasks.

If an environmental management system exists, chemicals management should be integrated into the system. Hence, the environmental manager is responsible for chemicals as part of the system.

Ensure that staff have clear guidelines regarding: 

  • What their tasks are, 

  • What they can decide and what must be decided further up the hierarchy,

  • Which people they need to involve in their work,

  • What outcome is expected and by when,

  • How much time they can dedicate to their tasks.