RØADMAP TO

Chemical
Management Board
Management for the ZERO
Meeting
Textile Industry DISCHARGE OF
HAZARDOUS
March 25/26,
MODULE 1 2013
CHEMICALS

IN ASSOCIATION WITH
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DISCLAIMER 1

PLEASE NOTE: The following presentation is being provided as an introduction to the

general use of chemicals in textile manufacturing.

The presentation is not intended to define applicable requirements or prescribe means

or methods in accordance with those requirements, but instead to inform training
participants of the potential hazards and use of chemicals in today’s textile
manufacturing industry.

The intent of the presentation is to provide awareness to these hazards, with a focus on
textile manufacturing process improvement and chemical-use reduction in the future.

Country-specific regulatory requirements are not addressed in detail in this training

session and each supplier is expected to become informed of these requirements for
their specific operation and incorporate manufacturing practices to maintain regulatory
compliance within their chemical management programs.

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MODULE 1

INTRODUCTION TO
CHEMICAL MANAGEMENT

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TRAINING PURPOSE

• Review the characteristics and harmful effects of

hazardous chemicals used in textiles
• Provide general guidance on chemical management
(including use, storage, transfer, treatment and
disposal)
• Recommend on how to establish an effective
chemical management system

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CHEMICAL MANAGEMENT

DO WE ARE THE DO WE

HOW
WHAT
WHY

MANAGE BENEFITS OF IMPLEMENT A

CHEMICALS? CHEMICAL CHEMICAL
MANAGEMENT? MANAGEMENT
SYSTEM?

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WHY WE MANAGE CHEMICALS

1. To address concerns from buyers, consumers and

other external stakeholders
2. To understand the hazards associated with
chemicals used in the manufacturing process
3. To take a greater responsibility for the health and
welfare of existing and future generations

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BENEFITS OF 1

CHEMICAL MANAGEMENT

1. Maintain a license to operate

2. Maintain a competitive advantage
3. Minimise excessive or replicative chemical
purchases/consolidate chemical purchasing
4. Reduction of chemicals can result in loading
reduction in ETP

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TRAINING SCOPE

The intended audience is the Factory Management

and their EHS managers of wet processing mills (i.e.,
dyeing, printing, laundries and tanneries)

Country specific and regulatory requirements are not

addressed in this training session. Each supplier is expected to
become informed of these requirements for their specific
operation and incorporate manufacturing practices to maintain
regulatory compliance within their chemical management
programs.

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TRAINING PURPOSE
• Introduce the ZDHC organisation, goals and progress to
date
• Inform supplier’s key management about the ZDHC
Group’s expectations
• Outline the importance and establishment of a Chemical
Management Team within a supplier’s facility
• Outline the importance of implementing chemical
management good practices
PLEASE NOTE: The following presentation is being provided as an
introduction to the ZDHC Group goals and the general use of chemicals in
wet processing. This presentation is not intended to serve as a guidance on
regulation.

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TRAINING CONTENT
MODULE1 INTRODUCTION TO CHEMICAL MANAGEMENT
MODULE2 HAZARDS AND RISK ASSESSMENT
RISK CONTROL HIERARCHY

MODULE3 ZDHC MRSL

FUNCTIONS AND BEST PRACTICES OF SDS
CHEMICAL LABELLING
CHEMICAL RISKS COMMUNICATION

MODULE4 CHEMICAL USE AND STORAGE

PPE SELECTION
EMERGENCY RESPONSE

MODULE5 ENVIRONMENTAL IMPACT MITIGATION MEASURES

WASTEWATER TREATMENT AND MONITORING

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WHO WE ARE 1

COMMITMENT JOINT ROADMAP

TOWARDS
 What
 When
 Why
 How

Towards the goal of Zero

Discharge of Hazardous Published the first Joint Roadmap,
Chemicals by year 2020 15 November 2011 and issued
update (Version 2) 11 June 2013.

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WHY ZDHC
• Chemicals are used in apparel and footwear production

• Some chemicals are hazardous and can be harmful for the

x
environment, for reproduction and for aquatic organisms
• This is why we have been working hard to regulate chemical
thresholds, which in many cases are more stringent than
required by legal regulations or industry standards
• However, residuals and contaminations can still exist

• Ultimately, chemical management across our supply chain must

be improved and integrated through measures like the MRSL
• That is why we have jointly made a commitment to lead our industry
towards zero discharge of hazardous chemicals (ZDHC) by 2020

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DEFINITION OF HAZARDOUS
CHEMICALS
Hazardous chemicals are those that show
intrinsically hazardous properties:
• Persistent, bioacculmulative and toxic
(PBT)
• Very persistent and very bioacculmulative
(vPvB)
• Carcinogenic, mutagenic and toxic for
reproduction (CMR)
• Endocrine discruptors (ED); or those of
equivalent concern, not just those that
have been regulated or restricted in other
regions

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11 CLASSES OF PRIORITY CHEMICALS 1

Typical Uses in Textile Specific Process where

Chemical Classes
Industry Utilised
Alkylphenol cleaners, detergents, sizing desizing, scouring, washing,
Ethoxylates/Alkylphenols agents dyeing, softening
(APEOs/APEs)
Halogenated Flame Retardants flame retardants functional finishing
Chlorinated Solvents spot cleaners, dry cleaning, sizing, dry cleaning, scouring
scouring
Chlorinated benzenes solvents, fiber swelling agents dyeing
Chlorophenols textile preservatives pesticides, sizing, dyeing
Heavy Metals dyes, pigments catalysts fiber polymerising, dyeing,
printing, tanning
Organotin Compounds (e.g., TBT) antimicrobial, preservatives, dyeing, leathering coating,
catalysts polyurethane synthesising
Per- and poly-fluorinated chemicals durable water repellents and functional finishing (water/oil
their by-products repellent)
Ortho-phthalates plasticisers dyeing, printing, coating,
softening
Short-Chained Chlorinated Paraffins leather conditioners tanning
Azo dyes that may release carcinogenic by-products of banned dyes dyeing, printing
amines as defined in Annex XVII of REACH

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CHEMICAL PRODUCTS THAT MAY CONTAIN 1

THE 11 CLASSES OF PRIORITY CHEMICALS

Solvents APEO
• Glues • Detergents
• Adhesives • Softeners
• Additives • Wetting agents
• Cleaners • Scouring agents
• Spot removers • De-gumming agents for silk
• Thinners • Emulsifiers
• Coatings • Dispersing agents
• Paints and lacquers • Dye and pigment preparations

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ENVIRONMENTAL EXPOSURE PATHWAYS 1
OF HAZARDOUS CHEMICALS

Wastewater
Waste gas Washing

Product (possible chemical residue)

Textile/garment
factory

Discard

Solid
waste

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ENVIRONMENTAL IMPACTS OF 1

IMPROPERLY TREATED WASTEWATER

Oxygen contamination

Eutrophication

Heavy metal contamination

Other contamination (e.g., organic and

inorganic substances)

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POTENTIAL IMPACT OF POORLY 1

HANDLED SLUDGE
Chemical sludge

Soil pollution

Water Crop (potentially)

Aquatic organism Food (potentially)

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ZDHC EXPECTATIONS OF SUPPLIERS

• Be aware of the ZDHC initiative, its context and implications

• Comply with the ZDHC MRSL
• Establish your chemical management system
• Continue to be stringent on the chemicals used in production
• Review the published materials on the ZDHC website,
ww.roadmaptozero.com
• Communicate with your own supply chain

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CHEMICAL MANAGEMENT TEAM

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CHEMICAL MANAGEMENT TEAM
The responsibility for managing chemicals should not be the sole responsibility of
one person but rather a team.
ZDHC strongly recommends involving the following team:

• EHS Manager to oversee the entire chemical management system

• Effluent Treatment Plant (ETP) Manager/Technician to provide insight and
understanding of the impacts on effluent from chemical inputs
• Product Quality Manager to ensure performance quality of the purchased
chemicals while ensuring compliance with the ZDHC MRSL
• Operations/Production Manager to ensure the proper application of chemicals
(for example, nature, quantity) for the production of products
• Purchasing/Procurement Manager/Officer to ensure alignment of purchasing
chemicals in compliance with the ZDHC MRSL

The above team members should work together and communicate regularly
amongst themselves and factory management.

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EHS MANAGER
The EHS Manager will have the following key roles and responsibilities:
• Oversee the entire chemical management system and attend any EHS audit in
the mill
• Lead investigations and review and implement a corrective action plan in case
of product/effluent noncompliance with the ZDHC MRSL
• Work with the rest of the Chemical Management Team to ensure: compliance
with the ZDHC MRSL, an adequate purchasing process, an updated facility
chemical inventory and up to date SDSs
• Provide internal training onsite for mill workers

Recommended Technical Competencies:

• Minimum of 5 years experience in textile and leather wet processing
• Knowledge of auxiliaries, dyestuffs/pigments and industrial processes related to the textile
and leather processing industry
• Attendance at technical trainings offered by accredited organisations including, but not
limited to, those offered by the ZDHC Group or its approved trainers

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EFFLUENT TREATMENT PLANT 1

MANAGER/TECHNICIAN
The ETP Manager/Technician will have the following key roles and responsibilities:
• Understand and provide insight on the impacts on effluent from chemical
inputs
• Ensure compliance of effluent quality to legal regulatory requirements
• Report to the EHS Manager and the Chemical Management Team if any of the
chemicals on the ZDHC MRSL are detected in the water quality (they will then
review and implement a corrective action plan)
• Maintain and regularly update chemical application records if chemical
treatment is in place at the ETP

Recommended Technical Competencies:

• Minimum of 2 years of experience with ETP
• Relevant legal certification for ETP operators (where applicable)
• Attendance at technical trainings offered by accredited organisations including, but not
limited to, those offered by the ZDHC Group or its approved trainers

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PRODUCT QUALITY MANAGER 1

The Product Quality Manager will have the following key roles and responsibilities:

• Ensure that any chemical purchases/substitutions meet not only product

performance needs but also are ZDHC MRSL compliant
• Understand the relationship between chemicals used (in manufacturing) and
the associated production processes
• Review all SDS for any incoming chemicals purchased to ensure compliance
with the ZDHC MRSL
• If any chemicals on the ZDHC MRSL are detected in the final product, this
should be reported to the EHS Manager and the Chemical Management Team
to review and implement a corrective action plan

Recommended Technical Competencies:

• Minimum of 5 years of experience
• The Product Quality Manager or someone within the Quality Team should be a chemist who
can work with Operations and ETP Managers should any concern over chemicals used in
product manufacturing arise
• Attendance at technical trainings offered by accredited organisations including, but not
limited to, those offered by the ZDHC Group or its approved trainers

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OPERATIONS/PRODUCTION MANAGER
The Operations/Production Manager will have the following key roles and
responsibilities:

• Ensure the proper application of chemicals (for example, nature,

quantity) and raw materials for the production of products
• Work closely with the Product Quality and Purchasing Manager to
ensure that chemicals being purchased and used are in compliance
with the ZDHC MRSL

Recommended Technical Competencies:

• Minimum of 5 years of experience
• Have some basic knowledge of chemicals inputs in the textile/footwear manufacturing
industry
• Attendance at technical trainings offered by accredited organisations including, but not
limited to, those offered by the ZDHC Group or its approved trainers

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PURCHASING/PROCUREMENT 1

MANAGER/OFFICER
The Purchasing/Procurement Manager/Officer will have the following key roles
and responsibilities:
• Align on purchasing chemicals that are in compliance with the ZDHC MRSL
• Obtain all SDS and relevant chemical test reports from chemical suppliers and
ensure that they are maintained and regularly updated
• Work with the Product Quality Manager and chemist to ensure such documents
meet the legal requirements prior to making any purchasing decisions

Recommended Technical Competencies:

• Minimum of 2 years of experience
• Attendance at technical trainings offered by accredited organisations including, but not
limited to, those offered by the ZDHC Group or its approved trainers

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CHEMICAL MANAGEMENT
GOOD PRACTICES

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ELEMENTS OF A GOOD CHEMICAL 1

MANAGEMENT SYSTEM

1. Risk assessment of chemicals

2. Chemical purchasing
3. Chemical inventory
4. Storage and containment
precautions
5. Communication of hazards
6. PPE selection/safe use procedures
7. Emergency response plans
8. Hazardous waste disposal

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IMPLEMENTING A CHEMICAL 1

MANAGEMENT SYSTEM
Commitment to CMS

Procurement/ Systematically identify and document Regulatory

Supplier Practices chemicals in your enterprise Assessments

Chemical Risk
Assessment

Chemicals and Processes of

Concern
Organisational Structure Training
Document/Record Chemical Management Work Practice
Development and Control Emergency Procedures
Performance Goals and
Action Plans

Monitoring and Measuring Change Management and

Corrective Action Audits

Management Review
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RISK ASSESSMENT 1

Before purchasing any chemicals, a risk

assessment should be conducted to:
• Clearly identify risks of each
chemical that is being considered
for purchase and use
• Understand the hazards and storage
requirements associated with the
given chemical(s)
• Confirm the adequacy of existing
environmental controls
• Ensure alignment with brands’ RSL/MRSL
• Identify any environmental concerns associated with each chemical
• Employees’ safety – is new PPE required?
• Determine chemical disposal needs and arrangements
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PURCHASING CHEMICALS 1

When purchasing new chemicals, it is imperative to:

• Select the least hazardous chemical suitable for use
• Strictly control the chemical’s use from pre-treatment to post-treatment
• Obtain the most updated SDS for each chemical
• Obtain an assessment and approval from environment, health and safety
(EHS) personnel
• Ask for a RSL/MRSL Confirmation or Guarantee Letter
• Get approval from the customs office and other relevant government
authorities, if needed
• Check that labels for all chemical containers (packages) meet the legal
requirements
• Maintain hazardous chemical purchase and transportation documentation
in accordance with regulatory requirements, including items such as the
license for hazardous chemicals and personnel qualifications

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PURCHASING CHEMICALS 1

Documentation needed onsite:

• Globally Harmonized System of Classification and Labelling
of Chemicals (GHS)/CLP
• Safety Data Sheet (SDS)
• Label/signage
• Supplier declarations
• Transportation

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CHEMICAL INVENTORY 1

All work areas must maintain an inventory of chemicals at all times

according to the following guidelines:
• When new chemicals are acquired, they must promptly be added to
the inventory.
• When chemicals are expended or disposed, they must be removed
from the inventory or a single line shall be drawn through them.
• This inventory must be examined and updated periodically (at least
annually).
• The inventory must be readily available to anyone entering the work
area.

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 TYPICAL CHEMICAL INVENTORY Mod.
1
RECORD
Location: Supervisor: Date
Chemical Inventory Form ____________________________ ____________________________ ______________________

Container Date of Expiration

Chemical Name Manufacturer Storage Location Special Requirements/Hazards
Amount Acquisition Date

Other items that may be useful to include:

- Internal ID number (if used) - SDS, if available
- Supplier ID (product number or ID, useful for re-ordering) - Date opened
- Number of containers purchased - Date disposed

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RESULTS OF GOOD CHEMICAL
MANAGEMENT

Improper labelling Proper labelling

No secondary containment Secondary containment

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NEXT FEW MODULES 1

More detailed discussions will cover the following aspects of

good chemical management system
• Chemicals usage within the workplace
• MRSL, SDS, Chemical Labelling and Chemical Inventory
• Chemical communications, root cause analysis and
emergency response
• Environmental impacts mitigation measures

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