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As awareness within the apparel industry increases regarding the harm caused by hazardous chemicals, the issue of chemical management has become more important.

One useful tool for implementing an effective chemical management program is the 4C model.

Every year, the apparel industry uses large amounts of chemicals – including some that are hazardous. This means that there is potential risk to workers during manufacturing, while the finished articles may pose risks to retailers, consumers and the environment.

To protect people’s health and safety, as well as the environment, increasingly strict laws and regulations on chemicals are being published. Complying with these laws requires investment and commitment – which not all manufacturers will find easy.

Many international brands established chemical management program years ago, and can adapt most readily to the ever-tightening controls. On the other hand, small and medium sized companies across the apparel supply chain may still lack the awareness and ability to manage chemicals effectively.

If the industry is to encourage the adoption of chemical management programs, the aims of such systems must be more widely understood. The program goals can be summarized as follows:

  • To protect consumers by preventing the inclusion of hazardous chemicals in final products
  • To reduce the exposure of workers to hazardous chemicals during manufacturing
  • To eliminate the emission of hazardous chemicals into the environment via air, water, and solid waste

How can organizations from across the apparel industry’s value chain put chemical management programs into place?

SGS and the 4C Model

SGS has developed a copyrighted 4C model, which is a practical tool that suppliers in the apparel industry can use to implement a chemical management system.

The 4C model has four sections: Commitment, Competence, Critical Point Control and Comprehensive System.

Figure 1 4C Model

4C Model


Before implementing a chemical management program, your company should analyze the industry situation. The analysis should include an investigation into the latest trends concerning the best available chemical management techniques and practices.

This phase allows your top management team to realize the significance of chemical management, and understand the real situation of your company and the risks it faces. Your business will then be in a better position to formulate a relevant and realistic policy and operational strategy.

With the plans and policy in place, your managers can make a full commitment and ensure that the whole company takes part and complies.


The second step of the 4C model is to improve competence. This involves establishing a special team, led by one person with overall responsibility for chemical management. This person must have the following professional knowledge and skills:

  • Good command of information collection
  • Chemical and environmental background
  • Knowing about legislation and the clients’ requirements
  • Familiarity with raw materials and the production process
  • Understanding the Globally Harmonized System (GHS) system of classification
  • Ability to evaluate the acceptability of a Material Safety Data Sheet (MSDS)
  • Ability to identify hazards and to conduct risk assessments
  • Effective communication
  • Experience with management systems

Critical Point Control

When launching a chemical management program, critical point control is the priority. Based on the flow and the use of each chemical in the manufacturing plant, these critical points are classified as:

  • Input – raw materials and chemicals
  • In Processing – product manufacturing
  • Output – product and waste discharge


Input control and testing is a more effective solution to the problem of controlling restricted substances than dependence upon only testing your finished products.

The raw materials and chemicals used in a manufacturing process are critical to chemical management, since they determine whether or not the final products and waste flow are harmless.

The chemical management team must work closely with the purchasing (sourcing) department to ensure that ALL chemicals, whether considered safe and hazardous, are evaluated before purchase. The chemicals must also be included in the chemical inventory list after purchase.

In Processing

The critical points within manufacturing include safe transportation, storage, movement, use and disposal of chemicals.

For example, hazardous chemicals storage areas should be well ventilated and incompatible chemicals should be segregated. To prevent contamination, secondary containment should also be in place, such as drip trays, troughs or bowls etc. to collect any drips or leakages of concentrated chemicals.


Testing on the final products and waste flow (solid waste, wastewater and air emission) is a way to verify the compliance and overall performance of the chemical management program.

If the test results reveal non-compliance, then the chemical management program is not working at some point – and is therefore ineffective overall. Finding the root cause and formulating an action plan to rectify the situation then becomes the first priority.

Comprehensive system

The establishment of comprehensive system is the top tier of 4C model. Continuous improvement is an important element of any comprehensive program.

A comprehensive chemical management system can improve efficiency and reduce the error rate regarding hazardous chemicals. The company can refer to, or adopt, various international standards, codes of conduct, and industrial best practices to improve and perfect their system.

Why SGS?

SGS is the world’s leading inspection, auditing, certification, testing and verification company, with a global network of laboratories and offices.

Our experts can help guide you through each step of the 4C model and improve your chemical management performance.

Your organization’s compliance with the legislation can contribute towards winning the trust of retailers and consumers, and encourage business growth.

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For more information contact your local SGS representative, or our global team and visit our website.

Jane Jiang, Ph. D.
Global Softlines Technical Director
SGS-CSTC Standards Technical Services Co. Ltd.
t: +86-21-61402666

Karen E. Kyllo, Ph.D.
Deputy Vice President, Global Softlines
SGS North America Inc.
t: +1 973 461 7934