Are MRSLs the panacea for Detox?

The background of the ‘Detox’ campaign:
In 2011- 12, the global NGO Greenpeace rocked the Apparel Industry with a sustained campaign called ‘Detox Now!’ that targeted the uninhibited pollution caused by the discharge of hazardous chemicals into rivers and other water bodies by textile mills around the world. The trail from these dyeing & finishing factories led to global apparel and footwear Brands who, for many years, have professed to ensure environmental and consumer protection in their policies and manufacturing practices.

Greenpeace went a step further and demonstrated – by actually testing garments from the Brands’ Stores – that apparel, imported and sold in their shops in the EU, contained chemicals that are hazardous to human health and can be discharged from these articles into EU rivers through simple home laundering!

The campaign made several Brands take a re-look at the chemical usage across their supply chain. The result was the ZDHC (Zero Discharge of Hazardous Chemicals) Initiative – a coming together of like- minded Brands & Retailers (as well as other stakeholders) to lead the apparel & footwear industry towards the goal of zero discharge of hazardous chemicals across all pathways by the year 2020.

The ZDHC MRSL:
After 4 years of sustained efforts, the ZDHC has published a Manufacturing Restricted Substances List (MRSL v 1.1), that is, a list of substances banned from intentional use in chemical formulations used in manufacturing facilities. The idea is to shift the focus from ‘end- of –pipe’ (that is restricting hazardous substances in finished articles through RSLs) to eliminating them in input chemicals.
The idea stems from the premise that “clean inputs = clean outputs”.

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While shifting the spotlight to input chemical management, the ZDHC MRSL acknowledges the possibility of ‘unintentional contaminations’ or ‘impurities’ or ‘uncontrolled residues’ of these hazardous substances creeping into the chemical formulations, either from their manufacturing process or from starting raw materials used to make a formulation.

To counter this, a Maximum Concentration Limit Value has been prescribed for each substance within a chemical formulation. It is expected that ‘responsible’ chemical manufacturers will be able to consistently conform to these concentration limit values, thereby ensuring that the discharge of such substances into products, wastewater and sludge will be as close to ‘Zero’ as possible.
For example, a chemical manufacturer should not only not use NPEOs intentionally but also ensure that each batch of the formulation should not exceed 500 ppm (limit given in the MRSL) of unintentional NPEO contamination in that formulation.
Will the MRSL provide a harmonized approach to Brands’ chemical restriction requirements?
There has been a persistent demand from suppliers to harmonize the Restricted Substances Lists (RSLs) of different Brands, which are currently extremely competitive and diverse in terms of limit values on final product as well as the list of analytes. The intent of the ZDHC MRSL is to provide this harmonized approach to managing chemicals during the processing of raw materials within the apparel and footwear supply chain.

But a study of the MRSLs issued by some Brands/Retailers belies this intent. The H&M, Esprit, Nike, Lululemon Atheletica and Inditex MRSL is different from the ZDHC MRSL in that it only stipulates a ‘Usage Ban’ for the list of substances, without any limits for unintentional contaminations. The Benetton, Puma, Aldi, Coop, Valentino and Mango MRSL stipulate limits for wastewater and/or sludge discharge. Some Brands have adopted the ZDHC MRSL, but made additions or deletions in the analytes or changes in the limit values for unintentional contaminations (Levi Strauss, Burberry). The New Balance MRSL simply segregates chemicals into two groups: those that can be easily substituted with more environment friendly ones and those that are not technically feasible to be eliminated yet, but should be controlled to minimize exposure to workers, environment and consumers.

Is the MRSL the solution for Detox?
The MRSL is definitely an effort to focus on clean inputs, while trying to incorporate the challenge of cross- contaminations. But this approach does raise several questions:

  1. Do chemical manufacturers know about unintentional contaminations that may occur during the synthesis process or can come from input raw materials sourced by them? This is extremely difficult for a manufacturer to monitor. The unintentional contamination is, well, unintentional and there will be no system in place to identify or monitor these at ppm level!
  2. Can formulators guarantee conformance to the MRSL limits in every batch manufactured? In a project that NimkarTek is currently doing at a yarn dope dyeing factory, COC (Chlorinated Organic Carrier) contamination of 1 to 4 ppm is being detected in the dyed polyester yarn. The source of this COC has been identified as contamination in certain pigment masterbatches used in the dyeing process. However, the masterbatch supplier has simply refused to give any guarantee for COC contamination, citing that there is no system for them to test each and every batch of the pigments used and declare it as COC –free.
  3. How does a material supplier (dyehouses) ensure that the declaration of conformance obtained from a chemical supplier to the MRSL is authentic? Most Brands insist that the MRSL should be communicated to chemical suppliers and a Conformance Declaration obtained. Only such ‘Positive List’ of chemicals are recommended to be used in the factory. But what is the authenticity of such self- declarations? If there any system to verify that there are no contaminations exceeding the MRSL limit in these Positive Lists? I know that many European chemical manufacturers source a lot of raw materials from China and India and it is unlikely that they are testing every batch of these raw materials for MRSL compliance!
  4. Is the MRSL understood by local chemical manufacturers, who cater to 85% of market requirements, or is it a commitment by a few multinational (global) chemical suppliers who have only 15% market share? Awareness about MRSL analytes is quite low in the ‘chemical hub’ of the world, that is China and India. These analytes (such as APEOs or Phthalates) are not regulated and hence there is no restriction for its manufacture and use in the textile industry. Training and awareness needs to be done to educate these chemical manufacturers.
  5. Are test methods standardized and correct standards of the restricted substances available for testing these contaminations in chemicals? Test methods for restricted substances in textile products are well established and corroborated amongst global testing laboratories. This is not the case with chemicals. Testing of formulations is a challenge, especially those that are in emulsion form. The ZDHC MRSL does not specify ISO or DIN or EN test methods (except for some groups), but only general techniques of analyzing chemicals using equipment such as GC-MS or LC-MS. Thus, test results are not as per standard methods and may vary from lab to lab. Also, do we have enough competent laboratory testing capabilities all over the world? Without these capacities, it would be difficult to scale up MRSL implementation through the supply chain.
  6. Do the MRSL limits for contaminations corroborate with limits in finished products or the limits for wastewater? The restricted substances contaminations from chemical formulations will be either transferred to products or wastewater. The MRSL threshold limits in input chemicals are much higher than the RSL limits on end- product as chemical formulations are highly concentrated and diluted before application on the textile substrate. But has it been confirmed that a limit of 1000 ppm for 1,2 dichlorobenzene in a chemical formulation will meet the limit of 1 ppm in finished article? Or the limit of 500 ppm APEO in a washing agent will meet the wastewater detection limit of 1g/L (when it is known that almost 95% of the APEO- based chemical will be washed out in the effluent!)?
  7. Can the MRSL requirements be met immediately by chemical manufacturers? Complying with the MRSL limits will require investments in testing infrastructure and product stewardship by chemical manufacturing units, especially the small and medium capacity manufacturers. This might mean higher cost of end-products. Substitution of ingredients in a chemical formulation is also a time-consuming process since performance parameters also need to be matched.

Conclusion:
The ZDHC Initiative is indeed a welcome step to tackle the issue of chemical management since this Herculean task will need collaboration across the industry stakeholders. The MRSL is a good concept that focuses on input chemical management rather than end-of-pipe. The idea to eliminate hazardous substances in input chemicals rather than only managing them in finished goods will also lead to cleaner production with respect to worker health & safety and environmental impact mitigation of the manufacturing process.

However, implementation of the MRSL has its challenges. It is not a panacea for Detox as the supply chain stakeholders, especially fabric dyeing and printing mills, will have to implement comprehensive systems for chemical management to achieve the goal of Detox. Chemical suppliers will need to take up a far greater responsibility of product stewardship and invest in testing capabilities in order to meet the demands of unintentional contaminations in the MRSL. Root cause analysis for MRSL failures will have to be undertaken and modification of process synthesis and raw materials will have to be incorporated for MRSL non- compliant formulations.

Moreover, a sustained and continuous training and capacity –building program will need to be implemented by Brands across all tiers of their supply chain to create awareness about MRSL, ZDHC and Chemical Management topics. Only such capacity- building will result in a positive change to move towards the goal of Zero Discharge of Hazardous Chemicals across all pathways. NimkarTek has designed a unique online training platform ‘NOTES’ to deliver such trainings quickly and effectively across all tiers of the supply chain and across different geographical areas and languages, by leveraging the web.

Lastly, the Brands and Retailers committed to the Detox goal should start engaging with chemical manufacturers – especially the local ones in China, India and other producing countries, or with their associations– to spread the message of the MRSL and understand their difficulties and challenges in meeting the MRSL requirements.

 

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NimkarTek

NimkarTek Technical Services Pvt Ltd is a consultancy company providing world-class ecological and environmental solutions to the textile and leather supply chain. We provide online training through our E-Learning Platform NOTES. We also help dyehouses or garment washing units to assess and grade the facility for their chemical compliance, chemical storage and waste management systems and implement Chemical Management through our unique online tool CMS-i. We also offer Certified Chemical Management Certificate Course to develop competencies in Chemical Management.

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