Bosnia and Herzegovina: 7 Questions to Help You Prepare for an Inspection

If you're involved in the production or import of chemicals, you already know which inspections are responsible for overseeing chemical regulations.

In the Republic of Srpska, the oversight is carried out by the Republic Administration for Inspection Activities through health inspectors, specifically those for chemicals and biocides.

Today, I'm bringing you 7 key questions to help you prepare for an inspection in the Republic of Srpska. Find the answers to these questions and check yourself and your business.

1. Are you registered in the Register of Chemical Manufacturers and Importers?

This is the first thing a chemical inspector checks to determine if you are authorized to produce or import chemicals. Registration is mandatory for all manufacturers and importers of chemicals, including biocides and plant protection products.

As proof that you have fulfilled this obligation, you must possess the appropriate document issued by the Ministry (a decision on meeting the conditions or a certificate of registration).

2. Have you appointed a chemical advisor?

If you are registered in the Register of Chemical Manufacturers and Importers, you have surely appointed a chemical advisor. This is the person responsible for the proper management of chemicals in your company, helping you fulfill legal obligations and operate smoothly.

Check if the contract you signed with them is still valid. Also, ensure you have access to documentation proving the chemical advisor's qualifications (diploma of acquired profile and level of education, evidence of continuous education).

3. Do you meet the conditions for the production or storage of chemicals?

The person producing or handling chemicals must ensure conditions for conducting activities with chemicals without harmful effects on humans and the environment.

Conditions are defined for the production of chemicals, storage for further sale, or use for personal needs. They also include conditions regarding occupational safety, environmental protection, fire safety, and other areas related to your activity.

4. Have you submitted a chemical report?

Chemical manufacturers and importers are required to maintain records of chemicals (including biocides, detergents, plant protection products, or other mixtures). The content of the records is prescribed, but not the format in which they are kept. Based on the records, regular annual reports are submitted in the prescribed form electronically.

You need to provide proof that the report was submitted within the prescribed deadline (confirmation of receipt of the electronic mail by which the report was submitted).

5. Have you registered the chemicals you produce or import in the Inventory?

Chemicals produced or imported in quantities above the prescribed lower limit (usually 100 kg) must be registered in the Chemical Inventory. This obligation lies with the manufacturer or importer of chemicals (the first in the supply chain).

If you are a manufacturer or importer, you must present proof to the inspector that the chemicals you place on the market are registered in the Chemical Inventory (decision, certificate, or confirmation of registration in the Chemical Inventory).

6. Do you have adequate safety data sheets?

The inspector will familiarize themselves with the chemicals you trade through the safety data sheet (SDS). Have you prepared this document for all chemicals in your sales program? Are the documents prepared in accordance with regulations?

The SDS for all chemicals must be available to workers and also provided to your customers, as well as all actors in the supply chain. The inspector may also request proof of this.

7. Are the chemicals adequately classified, labeled, and packaged?

It is necessary to ensure that chemicals are classified according to current rules and that labeling is in accordance with the hazard classification. Labels for hazardous chemicals must contain all prescribed information and be aligned with the safety data sheet. The packaging of chemicals must meet prescribed standards.

These are the questions you must ask yourself if you want to successfully pass an inspection. The list is not exhaustive, but it will help you avoid fines that can reach up to 50,000 KM.

If you need assistance in fulfilling legal obligations, contact me at nina.pajovic@bens-consulting.eu.