The use, processing and disposal of chemicals in production processes not only poses significant EH&S risks but is also highly regulated in national and international legislation. Textile processes (and many other, too) are highly complex, where significant amounts of chemicals are used in many different steps. Neglecting chemicals management leads to serious consequences, not only for the companies that might face immense fines but also for our environment, which might be damaged for several years or, in a worst-case scenario, forever.
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For more than a decade the apparel, footwear and textile industries have focused on product safety when controlling chemicals. Due to external stakeholders raising the need to also consider the chemicals used in manufacturing, many companies are now expanding their chemicals programs to include manufacturing processes and the input management of chemicals. This is a demanding task.
Furthermore, one risk has not been seriously considered yet which is the risk of soil and groundwater contamination. Wherever chemicals are used without the necessary precautions, the chemicals can jeopardize workers, consumers and the surrounding environment. Soil and groundwater contamination may make it necessary to install very costly clean-up projects that may cost in the range of millions of Euros over many, many years.
Together we can tackle the challenges when it comes to managing chemicals in your own company or supply chain by gaining a better understanding of materiality in the supply chain and implementing standards such as the SAC (Sustainable Apparel Coalition) Higg Index, or becoming part of the ZDHC (Zero Discharge of Hazardous Chemicals) collaboration. A portfolio of our Detox services can be downloaded at the bottom of this article.
So, what makes good chemicals management highly important for your company?
In order to reduce the environmental, occupational and public health impacts throughout the manufacturing process, compliance with chemicals bans or restrictions and buyers’ expectations must be achieved. Awareness of the legal exposure limits, RSL (Restricted Substances List), MRSL (Manufacturing Restricted Substances List), SDS (Safety Data Sheets), chemicals inventories and substitution plans for hazardous substances are only a few of the various measures for achieving good chemicals management.
When it comes to materiality, a closer look at the manufacturing processes reveals the steps that are chemicals-intensive. Leadership & Sustainability can assist you in conducting a holistic materiality assessment that takes into account all the inputs/outputs, risks and opportunities.
Let’s take the example of athletic footwear production. All the indicated steps represent the output of hazardous materials/chemicals. Leather processing is included, although leather may not be used in all athletic footwear production.
At several steps of the athletic footwear manufacturing process, hazardous materials and chemicals emerge as an output. For the pre-treatment of leather such as tanning, the raw material is modified to serve the users’ needs. By applying chemicals such as biocides, surfactants, degreasers, lime, sodium, (hydro-)sulphide, soda, ammonium, sulphate, ammonium chloride, salt, formic acid, sulphuric acid, chromium sulphate and aldehyde tanning agents the natural tissue is removed of grease, hair, and any remaining flesh, and is made water resistant and durable. This appears as a long list of (hazardous) substances that, if procured, stored, utilized and disposed of correctly, might not have any harmful effects.
Let’s have a closer look at the apparel manufacturing processes.
A process that is common in both footwear and apparel manufacturing is dyeing textiles. When dyeing, textiles are brought into contact with aqueous (there are waterless dyeing technologies available today as well) dyestuff solutions, a great variety of chemicals (salts, acids) and dyeing auxiliaries (surfactants, dispersing agents, levelling agents). After dyeing, the exhausted dyebath is discharged. Rinsing, soaping and other special after-treatments generate hazardous outputs that load the effluent. The main environmental impacts originate from an undesired coloration of the effluent, heavy metal content, dyestuffs and high salt concentrations. Volatile organic carbon (VOC) might be released to the off-gas during the drying and curing steps.
These undesired outputs can be managed correctly by implementing chemicals management that is in line with the SAC, ZDHC or the German partnership for sustainable textiles (“Bündnis für nachhaltige Textilien”), which tackles the following challenges:
- Taking the right approach to Detox requirements
- Defining the standards for chemicals management
- Further implementation of the Individual Action Plan into the global supply chain
- Integrating chemicals management with an overall environmental approach
The different standards are:
- SAC (Sustainable Apparel Coalition) Higg Index – Verification with self-assessment
- ZDHC (Zero Discharge of Hazardous Chemicals) Audit protocol with self-assessment and an audit approach with different levels
- Partnership for sustainable textiles (Bündnis für nachhaltige Textilien) and a set of indicators
Leadership & Sustainability offers various Detox solutions that can assist you in implementing your roadmap, with supply chain mapping and risk assessments based on manufacturing processes, and with the implementation of suitable chemicals management, and EH&S and energy management systems. Using our approach, your company will be able to embed chemicals management into your business processes and supply chain management. L&S offers corporate and supplier training, elimination and substitution studies and policies, as well as verification and audit practices. Together we can achieve KPIs and performance improvements regarding the use of chemicals in your supply chain!
What does it mean for a company committing to Detox and/or ZDHC and/or German partnership?
By starting with studying the available materials, we seek to understand the current status of your own work and compare it with the requirements. Then we develop a plan for a chemicals management program within your own company following these stages:
What does a chemicals management system look like in practice?
A chemicals management system is designed as an integral or standalone part of an overall EH&S management system. The first step is to create visibility, conduct a risk assessment and define the chemicals standards (RSL & MRSL), followed by a substitution program that identifies the most hazardous substances in use, or that are produced during the process, and defines strategies to replace them with less hazardous substances. As illustrated in the above flowchart, procurement needs investigation as to how chemicals are selected and purchased. If relevant, MRSL is applied here. The amount of chemicals accidentally lost due to spillages, poor labelling or mixtures will be minimized. Thorough documentation will be put in place to ensure the re-evaluation of chemicals after a defined period of storage to determine their suitability for use, as well as to track any changes in the laws and regulations. An internal audit group will review, assess and verify the chemical hazards and inventory. A corrective action plan will be followed in case of non-compliance in order to respond to potential spills and accidents. In line with the customers or your own Restricted Substance List (RSL), the production processes and contractors will be monitored. All suppliers will be required to have an occupational and environmental health and safety program for chemicals management.
You can download a portfolio of all our Detox services here.
Find out more about our SAC & Higg Index services.
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