IM­PLE­MEN­TA­TION OF CHEM­I­CAL MAN­AGE­MENT SYS­TEM IN AP­PAREL IN­DUS­TRY

CRE­AT­ING COM­PET­I­TIVE­NESS WITH SUS­TAIN­ABLE PRAC­TICES IN CHEM­I­CAL MAN­AGE­MENT

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Among the dif­fer­ent tex­tile man­u­fac­tur­ing pro­cesses, wet pro­cess­ing, which in­cludes dye­ing, print­ing and fin­ish­ing – gives value ad­di­tion to the prod­uct. Wet pro­cess­ing is a chem­i­cal in­ten­sive process and uses va­ri­ety of chem­i­cals from sim­ple sub­stances to com­plex aux­il­iaries, many of which are haz­ardous to hu­man be­ings and the en­vi­ron­ment. There are chances of ex­is­tence of resid­ual chem­i­cals on the fin­ished tex­tiles after wet pro­cess­ing that have been proven to cause cancer, al­ler­gies, ge­netic dis­or­ders, etc. Re­spond­ing to the need to man­age chem­i­cal use in a con­trolled way, many reg­u­la­tions have been en­acted, and SGS is look­ing to support the tex­tile and leather in­dus­try, in­clud­ing the en­tire sup­ply chain in this area, through im­ple­men­ta­tion of Chem­i­cal Man­age­ment Sys­tem (CMS) in the fac­tory. Dr. K A Vi­jayaku­mar, Man­ager – Sus­tain­abil­ity – Con­sumer and Re­tail, SGS In­dia un­der­lines the im­por­tance of CMS and route to suc­cess­ful im­ple­men­ta­tion.

THE BACK­GROUND…

To safe­guard the con­sumer and the en­vi­ron­ment from haz­ardous chem­i­cals emit­ted/dis­charged from fin­ished prod­ucts in tex­tiles reg­u­la­tions like “REACH – Registration, Eval­u­a­tion, Autho­ri­sa­tion and re­stric­tion of CHem­i­cals (EC 1907/2006)”, have been put in place. Also, many of the brands have re­stricted the pres­ence of haz­ardous chem­i­cals on their prod­ucts by im­ple­ment­ing Re­stricted Sub­stances List (RSL). Re­ports by Green­peace – The Dirty Laun­dry and Dirty Laun­dry Reloaded, highlight the role played by tex­tiles and ap­parel in­dus­try in caus­ing wa­ter pol­lu­tion. The NGO has also ini­ti­ated a cam­paign called Detox, which is sup­ported by many brands. In Novem­ber 2011, a group of six ma­jor ap­parel and footwear brands and re­tail­ers de­cided to take up the chal­lenge and is­sued the “Joint Roadmap to­wards Zero Dis­charge of Haz­ardous Chem­i­cals”, a com­mit­ment and roadmap aim­ing at re­duc­ing the en­vi­ron­men­tal im­pact of the tex­tile in­dus­try, based on a list of 11 pri­or­ity chem­i­cal groups to be phased out by 2020. In June 2014,

The ZDHC Joint Roadmap Group has pub­lished the “Man­u­fac­tur­ers Re­stricted Sub­stance List (MRSL)”, a doc­u­ment that iden­ti­fies the chem­i­cal sub­stances banned from in­ten­tional use in fa­cil­i­ties that process tex­tile ma­te­ri­als in ap­parel and footwear. With so much fo­cus on the topic, it has now be­come a manda­tory re­quire­ment for the man­u­fac­tur­ers to avoid the us­age of haz­ardous chem­i­cals dur­ing pro­duc­tion. This can be suc­cess­fully im­ple­mented by introducing Chem­i­cal Man­age­ment Sys­tem (CMS) in the fac­tory.

AD­VAN­TAGES OF CMS…

Poor man­age­ment of chem­i­cals in the man­u­fac­tur­ing unit may end up with ac­ci­dents, prop­erty dam­age and en­vi­ron­men­tal pol­lu­tion. Im­ple­men­ta­tion of CMS will help the in­dus­try to avoid ex­ces­sive/ replica­tive pur­chase of chem­i­cals, in­tro­duce cost sav­ings, through more ef­fec­tive work prac­tices such as cor­rect stor­age, han­dling, use and dis­posal pro­ce­dures. Man­ag­ing chem­i­cals will also help the in­dus­try to iden­tify the haz­ardous chem­i­cals eas­ily from their chem­i­cal in­ven­tory and re­duce chem­i­cal load­ing on to the Effluent Treat­ment Plant or ETP. Re­duc­ing du­pli­ca­tion and op­ti­miz­ing ex­act dosage of use, choos­ing chem­i­cals with lower in­her­ent COD (Chem­i­cal Oxy­gen De­mand) and

BOD (Bio-chem­i­cal Oxy­gen De­mand) val­ues and re­duc­ing non-pro­duc­tive out­puts that ‘go down the drain’ can en­sure lower loads on ETP and thereby man­age­able effluent treat­ment costs.

Chem­i­cal Man­age­ment is im­por­tant for the in­dus­try to un­der­stand in­put chem­i­cals so as to meet the strin­gent re­quire­ments of effluent, air and sludge dis­charges out­lined in the Li­cense to Op­er­ate. Fol­low­ing all reg­u­la­tions through Chem­i­cal Man­age­ment pro­vides a com­pet­i­tive ad­van­tage over peers, as buy­ers want to deal with fa­cil­i­ties that can con­form to their Chem­i­cal Re­stric­tion re­quire­ments and who com­ply with all reg­u­la­tory norms.

EX­E­CU­TION OF CMS…

Even be­fore start­ing a chem­i­cal man­age­ment sys­tem, it is crit­i­cal that the fac­tory man­age­ment makes a com­mit­ment for the im­ple­men­ta­tion by re­view­ing pro­cure­ment and sup­plier prac­tices, iden­ti­fi­ca­tion and doc­u­men­ta­tion of chem­i­cals and as­sess the reg­u­la­tory com­pli­ance re­quire­ments for chem­i­cals used and dis­charged from the fac­tory. One of the key el­e­ments of CMS is the Chem­i­cal Man­age­ment Team, mem­bers of which need to be­long to var­i­ous de­part­ments in the fac­tory – The En­vi­ron­men­tal, Health and Safety (EHS) Depart­ment, The Effluent Treat­ment Plant or

(ETP) Depart­ment, The Pur­chas­ing Depart­ment, The Prod­uct Qual­ity Depart­ment and The Op­er­a­tions or Pro­duc­tion Depart­ment.

While the EHS Man­ager is the piv­otal mem­ber of the Chem­i­cal Man­age­ment Team and should over­see the en­tire chem­i­cal man­age­ment sys­tem, the

ETP Man­ager should pro­vide in­sight and un­der­stand­ing of the im­pacts on ef­flu­ents from chem­i­cals used in the man­u­fac­tur­ing pro­cesses. The Pur­chas­ing Depart­ment should en­sure that only those chem­i­cals and raw ma­te­ri­als which are in com­pli­ance are pur­chased by the fac­tory and that all doc­u­ments re­lated to the pur­chased chem­i­cals are in place. Fur­ther, the Prod­uct Qual­ity Depart­ment should en­sure that the chem­i­cals used in the fi­nal prod­uct meet the chem­i­cal re­quire­ments of brands, reg­u­la­tions, etc. along with other per­for­mance pa­ram­e­ters, and fi­nally the Op­er­a­tions Depart­ment must check that the chem­i­cals used in pro­duc­tion are ap­plied as per the rec­om­men­da­tions of the chem­i­cal sup­plier in terms of dosage and ap­pli­ca­tion con­di­tions. After a Chem­i­cal Risk As­sess­ment of the in­ven­tory and re­view of pro­cure­ment prac­tices and reg­u­la­tory as­sess­ment, per­for­mance goals, ac­tion plans should then be ini­ti­ated keep­ing in mind the fol­low­ing:

Or­ga­ni­za­tional struc­ture to man­age chem­i­cals, doc­u­men­ta­tion and record keep­ing and de­vel­op­ment and con­trol of sys­tems.

Train­ing of in­ter­nal and ex­ter­nal stake­hold­ers on chem­i­cal man­age­ment work prac­tices and emer­gency pro­ce­dures.

These per­for­mance goals should be mon­i­tored and mea­sured through au­dits and/or waste­water test­ing. Change Man­age­ment and Cor­rec­tive Ac­tions to re­view these per­for­mance goals and ac­tion plans should be taken based on the mon­i­tor­ing mea­sures and au­dits. As a team, the chem­i­cal man­age­ment sys­tem has to be im­ple­mented in the fac­tory.

The per­son­nel who are in­volv­ing in the CMS im­ple­men­ta­tion are to be trained thor­oughly. ZDHC is con­duct­ing dif­fer­ent modes of train­ing pro­grammes on CMS in tex­tile and footwear in­dus­tries. The good prac­tices in the im­ple­men­ta­tion of CMS are as be­low:

Chem­i­cal In­ven­tory is im­por­tant to list out each chem­i­cal used in the fac­tory, whether it is di­rectly used in the mak­ing of the fi­nal prod­uct or as a mis­cel­la­neous chem­i­cal,

such as ETP, lab­o­ra­tory, util­ity or san­i­tary chem­i­cals.

Carry out a Risk As­sess­ment of the chem­i­cals listed in the in­ven­tory by iden­ti­fy­ing the haz­ards, de­ter­min­ing the ex­po­sure and cal­cu­lat­ing the risk to hu­man health and the en­vi­ron­ment.

Plan out and im­ple­ment risk con­trol mea­sures or pre­cau­tions re­quired for stor­age, han­dling and containment of the iden­ti­fied haz­ardous chem­i­cals.

The haz­ards have to be com­mu­ni­cated to all the per­son­nel from store to fin­ish­ing. Im­ple­men­ta­tion of Per­sonal Pro­tec­tive Equip­ment (PPE) and safe use pro­ce­dures for work­ers han­dling chem­i­cals in the fa­cil­ity. Plan­ning for emer­gency re­sponse to chem­i­cal spillages and ac­ci­dents 7. In­cor­po­rate sys­tems for screen­ing of chem­i­cals for com­pli­ance and re­quired doc­u­men­ta­tion in the Pur­chas­ing Prac­tices.

De­velop a waste dis­posal and man­age­ment sys­tem, in­clud­ing clas­si­fi­ca­tion and seg­re­ga­tion of haz­ardous waste.

Chem­i­cal Man­age­ment Sys­tem can be im­ple­mented in the fac­tory in or­der to safe­guard our en­vi­ron­ment as well as present and fu­ture gen­er­a­tions from the haz­ardous chem­i­cals. Train­ing on CMS is very cru­cial for the suc­cess­ful im­ple­men­ta­tion of CMS in the fac­tory. In­dus­try also can utilise GIZ prac­ti­cal Chem­i­cal Man­age­ment Toolkit which will be very use­ful for the im­ple­men­ta­tion of CMS and train­ing to the staffs. The chem­i­cal man­age­ment sys­tem can be mon­i­tored in a fre­quent in­ter­val by au­dit sys­tem with ref­er­ence to Higg In­dex by Sus­tain­able Ap­parel Coali­tion (SAC) or equiv­a­lent. Man­age­ment re­view meet­ings have to be con­ducted to study the ef­fec­tive im­ple­men­ta­tions of CMS.

Small- and medium sized com­pa­nies across the ap­parel sup­ply chain still lack the aware­ness and abil­ity to man­age chem­i­cals ef­fec­tively.

Chem­i­cal Man­age­ment is im­por­tant for the in­dus­try to un­der­stand in­put chem­i­cals so as to meet the strin­gent re­quire­ments of effluent, air and sludge dis­charges out­lined in the Li­cense to Op­er­ate

Per­for­mance goals should be mon­i­tored and mea­sured through au­dits and/or waste­water test­ing

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