The Zero Discharge of Hazardous Chemicals · PDF fileBuilding a Global Centre of Excellence in Responsible Chemical Management The Zero Discharge of Hazardous Chemicals Programme Chemical

Building a Global Centre of Excellence in Responsible Chemical Management

The Zero Discharge of Hazardous Chemicals Programme Chemical Management for the Textile Industry

Date May, 2017


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Disclaimer 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.


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 W

HY DO WE

MANAGE CHEMICALS?

WH

AT ARE THE

BENEFITS OF CHEMICAL MANAGEMENT? H

OW

DO WE IMPLEMENT A CHEMICAL MANAGEMENT SYSTEM?


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Why We Manage Cemicals

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 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 opera7on and incorporate manufacturing prac7ces to maintain regulatory compliance within their chemical management programs.


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Training Purpose

PLEASE NOTE: The following presenta7on is being provided as an introduc7on to the ZDHC Group goals and the general use of chemicals in wet processing. This presenta7on is not intended to serve as a guidance on regula7on.

•  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


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Training Content

MODULE2 HAZARDS AND RISK ASSESSMENT RISK CONTROL HIERARCHY

MODULE3 ZDHC MRSL FUNCTIONS AND BEST PRACTICES OF SDS CHEMICAL LABELLING CHEMICAL RISKS COMMUNICATION

MODULE5 ENVIRONMENTAL IMPACT MITIGATION MEASURES WASTEWATER TREATMENT AND MONITORING

MODULE4 CHEMICAL USE AND STORAGE PPE SELECTION EMERGENCY RESPONSE

MODULE1 INTRODUCTION TO CHEMICAL MANAGEMENT


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Who We Are

COMMITMENT

Towards the goal of Zero Discharge of Hazardous Chemicals by year 2020

TOWARDS

Published the first Joint Roadmap, 15 November 2011 and issued update (Version 2) 11 June 2013.

JOINT ROADMAP

ü  What ü  When ü  Why ü  How


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Why ZDHC •  Chemicals are used in apparel and footwear production

•  Some chemicals are hazardous and can be harmful for the 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

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•  That is why we have jointly made a commitment to lead our industry towards zero discharge of hazardous chemicals (ZDHC) by 2020

•  Ultimately, chemical management across our supply chain must be improved and integrated through measures like the MRSL


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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 Chemical Classes Typical Uses in Textile

Industry Specific Process where Utilised

Alkylphenol Ethoxylates/Alkylphenols (APEOs/APEs)

cleaners, detergents, sizing agents

desizing, scouring, washing, dyeing, softening

Halogenated Flame Retardants flame retardants functional finishing Chlorinated Solvents spot cleaners, dry

cleaning, scouring sizing, dry cleaning, 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, catalysts

dyeing, leathering coating, polyurethane synthesising

Per- and poly-fluorinated chemicals

durable water repellents and their by-products

functional finishing (water/oil repellent)

Ortho-phthalates plasticisers dyeing, printing, coating, softening

Short-Chained Chlorinated Paraffins

leather conditioners tanning

Azo dyes that may release carcinogenic amines as defined in Annex XVII of REACH

by-products of banned dyes

dyeing, printing


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Chemical Produccts that may Contain the 11 Classes of Priority Chemicals

Solvents •  Glues•  Adhesives•  Additives •  Cleaners •  Spot removers•  Thinners •  Coatings •  Paints and lacquers

APEO •  Detergents •  Softeners •  Wetting agents •  Scouring agents •  De-gumming agents for silk •  Emulsifiers •  Dispersing agents •  Dye and pigment preparations


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Environmental Exposure Pathways of Hazardous Chemicals

Textile/garment factory

Product (possible chemical residue)

Waste gasWastewater

Solid waste

Discard

Washing


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Environmental Impacts of Improperly Treated Water

Oxygen contamination

Eutrophication

Heavy metal contamination

Other contamination (e.g., organic and inorganic substances)


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Potential Impact of Poorly Handled Sludge

Chemical sludge

Soil pollution

Crop (potentially)Water

Food (potentially)Aquatic organism


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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 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



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Product Quality Manager • 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



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Purchasing/Procurement Manager

• 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



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Chemical Management Good Practices


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Elements of a Good Chemical Management System

1. Risk assessment of chemicals 2. Chemical purchasing 3. Chemical inventory 4. Storage and containment precau7ons 5. Communica7on of hazards 6. PPE selec7on/safe use procedures 7. Emergency response plans 8. Hazardous waste disposal


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Implementing a Chemical Management System

Management Review

Organisational Structure Document/Record

Development and Control

Change Management and Corrective Action

Performance Goals and Action Plans

Monitoring and Measuring

Regulatory Assessments

Systematically identify and document chemicals in your enterprise

Chemicals and Processes of Concern

Commitment to CMS

Audits

Procurement/ Supplier Practices

Chemical Risk Assessment

Training Chemical Management Work Practice

Emergency Procedures


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Risk Assessment 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

•  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

Documenta7on needed onsite: •  Globally Harmonized System of Classifica7on and Labelling of

Chemicals (GHS)/CLP •  Safety Data Sheet (SDS) •  Label/signage •  Supplier declara7ons •  Transporta7on


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Chemical Inventory •  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 Record

Chemical Inventory Form Location: ____________________________

Supervisor: ____________________________

Date ______________________

Chemical Name Container Amount Manufacturer Date of

Acquisition Expiration

Date Storage Location Special Requirements/Hazards

　　　　　　　

　　　　　　　

　　　　　　　

　　　　　　　

　　　　　　　

　　　　　　　

　　　　　　　

Other items that may be useful to include: -  Internal ID number (if used) -  Supplier ID (product number or ID, useful for re-ordering) -  Number of containers purchased

-  SDS, if available -  Date opened -  Date disposed


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Results of Good Chemical Management

Improper labelling No secondary containment

Proper labelling Secondary containment


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Next few Modules

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 communica7ons, root cause analysis and emergency response

•  Environmental impacts mi7ga7on measures

Leaders in Advancing Environmental Responsibility

Mod. 1 NEXT FEW MODULES

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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 communica7ons, root cause analysis and emergency response

•  Environmental impacts mi7ga7on measures

Documents

The Zero Discharge of Hazardous Chemicals · PDF fileBuilding a Global Centre of Excellence in Responsible Chemical Management The Zero Discharge of Hazardous Chemicals Programme Chemical