The document discusses the ZDHC MRSL (Manufacturers Restricted Substances List), which restricts hazardous substances used and discharged during textile manufacturing. The MRSL establishes limits for chemicals used in production facilities, addressing process chemicals that may not end up in finished products. It differs from an RSL (Restricted Substances List) which restricts chemicals that could be present in finished goods. Proper chemical management is important to eliminate intentional use of restricted substances and minimize environmental impacts.
1. ZDHC MRSL
Zero Discharge of Hazardous Chemicals (ZDHC)
Manufacturers Restricted Substances List (MRSL)
AZMIR LATIF
M.TECH (Textile Chemistry)
2. ZDHC MSRL
The ZDHC MRSL is a list of chemical substances banned from
intentional use in facilities that process textile materials and trim parts
in apparel and footwear. The MRSL establishes acceptable concentration
limits for substances in chemical formulations used within
manufacturing facilities. The MRSL limits are designed to eliminate the
possibility of intentional use of listed substances.
Purpose of the ZDHC MRSL
Existing RSL limits for materials and finished products ensure that
products are safe for consumer use, legally compliant and safe for the
environment upon disposal at end of life. The ZDHC MRSL is intended to
assist the apparel and footwear supply chain in phasing out the use of
restricted substances by establishing enforceable limits for hazardous
substances in chemical formulations used to process materials. The
MRSL addresses process chemicals used to produce materials but that
may not end up in the finished product.
3. The MRSL differs from a RSL because it restricts
hazardous substances potentially used and discharged
into the environment during manufacturing, not just
those substances that could be present in finished
products. The MRSL takes into consideration both
process and functional chemicals used to make
products, as well as chemicals used to clean equipment
and facilities. It addresses ANY chemical used within
the four walls of a manufacturing facility.
A MRSL changes the way we look at chemicals
management. It focuses at the beginning of the
manufacturing cycle by prohibiting chemicals entering
the facility and thus reduces the need to treat and clean
up effluent.
4. RESTRICTED SUBSTANCE LIST (RSL)
This Restricted Substance List (RSL) is intended to provide apparel and
footwear companies with information related to regulations and laws
that restrict or ban certain chemicals and substances in finished home
textile, apparel, and footwear products around the world.
The RSL was developed by a special working group of the American
Apparel & Footwear Association’s (AAFA’s) Environmental Task
Force or under REACH. It serves as a practical tool to help individuals
in textile, apparel and footwear companies, and their suppliers -
responsible for environmental compliance throughout the supply chain
- to become more aware of various national and international
regulations governing the amount of substances that are permitted in
finished home textile, apparel, and footwear products.
The RSL will be updated on a regular basis and will be supplemented
with additional resources to help officials in these companies undertake
responsible chemical management practices in the aforementioned
finished products.
5. 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
6. RSL V/S MRSL
A typical brand RSL sets concentration limits
for substances in materials or finished
products to comply with product regulation
and safety standards. The MRSL establishes
concentration limits for substances in
chemical formulations used within
manufacturing facilities.
MRSL limits apply to commercially available chemicals,
chemical mixtures or chemical formulations. A
commercial chemical formulation is usually a
proprietary blend of several chemical substances that is
available for purchase from chemical suppliers under
their own trade name.
7. 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.
Endocrine disruptors are chemicals that can interfere
with endocrine (or hormone) systems at certain doses. These
disruptions can cause cancerous tumors, birth defects, and other
developmental disorders.
9. ZDHC MRSL MANAGEMENT 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.
10. 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
11. 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
12. HOW TO AVOID USING
RESTRICTED SUBSTANCES
Ask your chemical supplier for a
correct and complete SDS and read
it carefully.
Ask your chemical supplier to
confirm the Restricted Substances
List and sign the declaration.
Test the chemical through a third-
party lab.
13. FACT FOR 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.
14. 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
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.
15. RISK ASSESSMENT OF HAZARDOUS
CHEMICALS
Four step of Risk Assessment Process
•Hazard Identification
What health problems are caused by the pollutant?
•Dose-Response Assessment
What are the health problems at different exposures?
•Risk Characterization
What is the extra risk of health problems in the exposed
population?
•Exposure Assessment
How much of the pollutant do people inhale during a
specific time period? How many people are exposed?
16. CHEMICAL SUBSTANCES SUBJECT TO USAGE BAN
These include relevant substances from the original 11
priority chemical groups in the Joint Roadmap along
with additional substances discussed with qualified
experts from the ZDHC Technical Advisory
Committee:
17. REVIEW SAFETY DATA SHEET
MRSL alignment requires a comprehensive review of
all SDSs
Safety Data Sheet (SDS):
• Provided by chemical manufactures, distributors or
importers
• Intended to provide workers and emergency personnel
with instructions for safe handling of chemicals
• Includes information such as:
─ Chemical properties
─ Toxicity/hazards
─ Environmental impact
─ Information for safe handling/transportation
─ Leakage/emergency response
─ Major physical and chemical parameters
─ Relevant rules and regulations
18. CHEMICAL STORAGE
• Hazardous chemicals must be stored in a specialised
storage area and obvious signage must be
displayed.
• Chemicals should not be exposed to direct sunlight.
• The chemical storage area should be dry and well
ventilated.
• Storage of chemicals should be based on their
compatibility with other chemicals.
• Chemical storage always requires extra
consideration:
Special building requirements, including room sizes,
building materials, locations and more
Only specific electrical devices can be used in
some cases (explosion hazard)
Ventilation or thermoregulation
Fire suppression equipment may be required
19. HAZARDOUS CHEMICALS - STORAGE
General Rules for Storage of Common Dangerous
Chemicals.
Basic requirements for hazardous chemical storage:
• Hazardous chemical storage should comply with
relevant government regulations.
• Hazardous chemicals should be stored in a specialised
storage area approved by the Public Security Department.
• Outdoor storage of hazardous chemicals should comply
with fire and explosion prevention requirements.
Explosives, level 1 flammable substances and poisonous
substances should not be stored where exposed to the
weather.
• Storage areas for hazardous chemicals should be
managed by specialised personnel, whose personal
protective equipment (PPE) are fully provided.
20. HAZARDOUS CHEMICALS – STORAGE
OF INCOMPATIBLE CHEMICALS
Segregated Storage
• Within the same building or area,
incompatible materials are separated and kept
apart, typically enclosed to avoid any potential
contact.
Cut-off Storage
• Within the same building, incompatible
materials are separated by wall or clapboard.
Detached Storage
• Materials are stored in different buildings or
areas.
21. INCOMPATIBILITY OF TEXTILE
CHEMICALS
Incompatible chemicals are combinations of substances,
usually in concentrated form, that react with each other to
produce very exothermic reactions that can be violent and
explosive and/or can release toxic substances, usually as
gases.
Care should be taken when handling, storing, or
disposing of chemicals in combination. A wide variety of
chemicals react dangerously when mixed with certain
other materials. Some of the more widely-used
incompatible chemicals are given below, but the absence
of a chemical from this list should not be taken to
indicate that it is safe to mix it with any other chemical.
!
25. OCCUPATIONAL HAZARDS IN THE TEXTILE
PRODUCTION PROCESS
Hazards are present in many steps in processing
textiles. The risk of these hazards can be managed
with proper PPE, environmental controls, and strong
chemicals management.
Some examples of chemical intensive processing
steps:
• Scouring (solvents, surfactants, acids, bases)
• Dyeing (dyes/pigments, surfactants, acids, bases)
• Other finishing processes (anti-stats, UV protectors,
water repellents, hand builders)
• Dry cleaning (solvents)
26. ZERO DISCHARGE OF HAZARDOUS
CHEMICALS IN WASTEWATER
When disposed of in water bodies or onto land,
effluents can result in the deterioration of
ecology.
• Factories must monitor the quality of their
wastewater and stay within or beyond national
limits for pollution control.
• International pressure for effluent treatment
is increasing and there is more concern over
whether textiles are produced in an
environmental-friendly way.
• To reduce pollution intensity, an onsite
WWTP should be used to treat the effluent
before it is discharged into the environment.