October 6, 2020
Following our webinar “Chemical Management — Insights, Benefits and Evolution”, we interviewed our global chemistry lead, Elisa Gavazza, to help provide you with further insights on the Zero Discharge of Hazardous Chemicals (ZDHC) program, wastewater testing and chemical compliance.
In the Manufacturing Restricted Substance List (MRSL) version 2.0 document on the ZDHC website, there are two specific chapters dedicated to the Candidate List and to Archived Substances. Which is the correct approach to be applied for substances included in these two groups?
The Candidate List includes a list of chemical substances that, at this moment, meets the ZDHC MRSL criteria, but must be monitored for potential future restrictions. This means that these substances are not yet restricted, and they are not tested in chemicals, formulations and wastewaters. The suggestion is to start addressing them, checking if alternatives are available for your specific use in order to start whenever possible to phase them out. These substances will be officially included in the ZDHC MRSL in future revisions as soon as alternatives are available on scale. On the contrary, the Archived Substances are those that have previously been used in the industry and are no longer in use. These substances are not included in the testing program for the certification of chemicals and formulations.
My company has performed wastewater testing for three years and there are no findings in the last three sampling campaigns. Can I stop testing?
At the moment, you cannot stop testing even if your wastewater is not containing any of the hazardous substances indicated in the MRSL, according to the ZDHC approach. If your customer is not a ZDHC contributor, you may discuss any change in the wastewater testing program with them. In general, I can say that these testing results show for sure that you have implemented effective chemical management, which is a good achievement. Still, I’m sure you introduce new chemicals or change ingredients of your recipes quite often, so, maintaining wastewater testing can be a good strategy to continue to monitor the efficacy of your system.
My factory has not yet implemented a chemical management program. Can we comply with the legislation on chemical substances applicable in our country?
The first step is understanding and clarifying the specific applicable legislation related to your country’s chemical substances’ handling. In general, I can say that if you are taking actions to comply with your local legislation, you are already applying a chemical management strategy. If you are only taking into consideration some elements, maybe you don’t have a full chemical management program in place, you can still move forward to implementing a more comprehensive program. Step by step, you can enlarge your chemical management scope to include not only legal, but also voluntary goals that can be more and more ambitious. This is a good exercise for all textile, footwear and leather companies that could bring immense benefits in terms of your employees’ well-being, new economic possibilities and visibility with your key customers.