Chemical

Management
for the
Management Board
Meeting
Textile
Industry
MODULE
1 2013
March 25/26,

RADMAP TO
ZERO
DISCHARGE OF
HAZARDOUS
CHEMICALS

IN ASSOCIATION WITH

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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 todays 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
IMPLEMENT A
CHEMICAL
MANAGEMENT
SYSTEM?

HOW

ARE THE
BENEFITS OF
CHEMICAL
MANAGEMENT?

WHAT

WHY

DO WE
MANAGE
CHEMICALS?

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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
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 suppliers key management about the ZDHC
Groups expectations
Outline the importance and establishment of a Chemical
Management Team within a suppliers 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

COMMITMENT

JOINT ROADMAP

TOWARDS

Towards the goal of Zero

Discharge of Hazardous
Chemicals by year 2020

What
When
Why
How

Published the first Joint Roadmap,

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

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

Chemical Classes
Alkylphenol
Ethoxylates/Alkylphenols
(APEOs/APEs)

Halogenated Flame Retardants

Chlorinated Solvents
Chlorinated benzenes
Chlorophenols
Heavy Metals

Typical Uses in Textile

Industry
cleaners, detergents, sizing
agents

Specific Process where

Utilised
desizing, scouring, washing,
dyeing, softening

flame retardants
spot cleaners, dry cleaning,
scouring
solvents, fiber swelling agents
textile preservatives
dyes, pigments catalysts

functional finishing
sizing, dry cleaning, scouring

Ortho-phthalates

antimicrobial, preservatives,
catalysts
durable water repellents and
their by-products
plasticisers

Short-Chained Chlorinated Paraffins

Azo dyes that may release carcinogenic

leather conditioners
by-products of banned dyes

Organotin Compounds (e.g., TBT)

Per- and poly-fluorinated chemicals

amines as defined in Annex XVII of REACH

dyeing
pesticides, sizing, dyeing
fiber polymerising, dyeing,
printing, tanning
dyeing, leathering coating,
polyurethane synthesising
functional finishing (water/oil
repellent)
dyeing, printing, coating,
softening
tanning
dyeing, printing

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CHEMICAL PRODUCTS 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

Wastewater

Washing

Waste gas
Textile/garment
factory

Product (possible chemical residue)

Discard

Solid
waste
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ENVIRONMENTAL IMPACTS OF
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

HANDLED SLUDGE
Chemical sludge
Soil pollution
Water
Aquatic organism

Crop (potentially)
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

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

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
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

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
MANAGEMENT SYSTEM
Commitment to CMS

Procurement/
Supplier Practices

Systematically identify and document

chemicals in your enterprise

Regulatory
Assessments

Chemical Risk
Assessment

Chemicals and Processes of

Concern
Organisational Structure
Document/Record
Development and Control

Training
Chemical Management Work Practice
Emergency Procedures
Performance Goals and
Action Plans

Monitoring and Measuring

Change Management and

Corrective Action

Management Review

Audits

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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 chemicals 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
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
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

Chemical Name

Location:
____________________________

Container
Amount

Manufacturer

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Supervisor:
Date
____________________________ ______________________

Date of
Expiration
Acquisition
Date

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

Storage Location

Special Requirements/Hazards

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 communications, root cause analysis and
emergency response
Environmental impacts mitigation measures

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