I CampA Mode GmbH amp CoKG Chemical Management Plans amp Integration into Factory Process and Management AFIRM RSL Training Seminar 1 DRAFT AFIRM RSL Training Seminar 2 Preface ID: 734057
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Dr. Oliver Muth, Chemical & REACH Compliance Manager I C&A Mode GmbH & Co.KG
Chemical Management Plans & Integration into Factory Process and Management
AFIRM RSL Training Seminar1
DRAFTSlide2
AFIRM RSL Training Seminar
2PrefaceSlide3
AFIRM RSL Training Seminar
3PrefaceSlide4
AFIRM RSL Training Seminar
4PrefaceSlide5
AFIRM RSL Training Seminar
5Why is Chemical Management essential?
Contractual RelationshipConsequences of non-complianceDiscontinuation/ stop of business
Regulatory demand
to comply with chemical
regulations
Different Regulations, Directives, Legislations, Country Specific Laws in Global MarketSlide6
AFIRM RSL Training Seminar
6Why is Chemical Management essential?
Prevent any harm from using chemicalsEnsure workers healthEnsure not to pollute land, water and air
Produce safe products for the consumersSlide7
AFIRM RSL Training Seminar
7Specify Roles & Responsibilities
Identify all staff involved in chemicalsRSL & Chemical Compliance ManagerPurchaser of chemicals Chemical Inventory List KeeperChemical room / stock keeper
Developer
of
new chemical formula / recipes
All staff allowed to handle chemicals
Cleaning staff
Assign missing roles and processSlide8
AFIRM RSL Training Seminar
8Education / Training / Communication
Train all staff involved in chemicalsPurchaser of Materials
/
Chemicals
Production
Manager
Workers
Chemical
Room Manager
/
Stock
K
eeper
Cleaning S
taff
Ask
your chemical
suppliers and
clients
to support you in chemical training !Slide9
AFIRM RSL Training Seminar
9Realize Restricted
Substances List (RSL)Read the RSL and ToolkitChemical Names
Hazardous Background
Restricted Limits
Required Test Method
Ask your client, in case of any questionsSlide10
AFIRM RSL Training Seminar
10Realize ZDHC Manufacturing RSL
MRSL applies to chemical formulationsWhereas RSL applies to materials, semi finished and finished productsMRSL Threshold Limit Values on restricted substances apply to substances in commercially available chemical formulationsChemical formulations are highly concentrated before being diluted upon application to textiles and materials.Slide11
C&A is committed to ZDHC2011 Greenpeace dirty laundry report
DETOX Campaign Sport & Fashion BrandsIndustry ResponseZero Discharge of Hazardous ChemicalsToday 24 brands & Retailers committed to ZDHC together with over 50 value chain affiliates and 15 associates
AFIRM RSL Training Seminar
11Slide12
Identify Safer ChemicalsChemical management tracking system
Search engine for formulations conforming to the ZDHC MRSL Level of conformance against ZDHC MRSL
AFIRM RSL Training Seminar
12Slide13
Chemical & Wastewater ManagementSustainable Chemicals Management (SCM) Audit
Stepping stone to Higg Index 3.0Facility Environmental Module 3.0
Assessment of facility environmental and chemical management performance accepted by all members of the Sustainable Apparel Coalition Implementation commenced in 2017/2018, SAC members are working on adoption in their supply chainsPlanned C&A implementation 2019
AFIRM RSL
Training Seminar
13Slide14
Validate elimination of hazardous chemicals
Wastewater GuidelinesWastewater performance reportC&A remains committed to public disclosure of wastewater test results
AFIRM RSL Training Seminar
14Slide15
AFIRM RSL Training Seminar
15Hazardous Chemicals
No production without chemicalsChemical auxiliaries: Dyestuffs, colourants, printing inks, binders, fixing agentsDetergents, softeners, special
finishings
Adhesives, solvents, anti-oxidation agents, anti-
electrostatica
,
All chemicals are
hazardous
to some degree
Proper Risk A
ssessment is key !Slide16
AFIRM RSL Training Seminar
16Chemical Risk Assessment
SDS informationGHS hazard classificationHazard / Precautionary (H/P) statementsContact chemical supplier
All chemicals comply with RSL/MRSL?
Chemical
Inventory ListSlide17
AFIRM RSL Training Seminar
17Chemical Inventory List
Create comprehensive Chemical Inventory ListUse an electronic inventory list for tracking chemicalsIdentify all chemicals in the factory
Record Chemical Name, Hazard Class, MSDS, etc.
Perform regular inventory audits to identify chemicals that are not being used.
Identify chemicals of concern – risk potential
Conduct risk assessment for each chemicalSlide18
Chemical Inventory List Template
AFIRM RSL
Training Seminar18
Chemical Name and CAS Identification Number
Hazard Class
Physical, Health and Environmental Hazards, Hazard statements (H phrases), Precautionary statements (P phrases)
Work Instructions / Operation Instructions
Personal Protective Equipment (PPE)
Material Safety Data Sheets (MSDS)
Container Size and location
Dates on which chemicals are prepared or expired (disposal)Slide19
Chemical Inventory - IngredientsList of chemical ingredients per formulation
List of chemical supplier contacts
AFIRM RSL Training Seminar19Slide20
AFIRM RSL Training Seminar
20Purchasing Chemicals
You can decide, if hazardous or only safe chemicals pass the factory gate !Send clients’ RSL to your chemical suppliersAsk
chemical
companies to provide detailed
chemical information
Ask for and check Safety Data Sheet (SDS)
Demand for assurance letter of compliance
Ask
clients
to support you to identify hazardous chemicals and safe alternatives
If
the chemical
supplier
doesn’t
know what he is selling, don’t buy their chemicals!Slide21
AFIRM RSL Training Seminar
21Purchasing Chemicals
Consider disposal cost at time of purchaseAsk for handling and disposal requirementsReduce expired stock
Use older stock first (first in first out policy)
Do not accept donated chemicals without contestingSlide22
AFIRM RSL Training Seminar
22Chemical Purchasing Price
Lower chemical purchase price is not always equivalent to cheaper productionCalculate the price per garment considering dosage, water and energy consumption
Chemical
A
B
Price
50 USD / kg
150 USD / kg
Dosage per garment
25 grams
8 grams
Price
per garment
1.25
USD
1.20 USDSlide23
AFIRM RSL Training Seminar
23Chemical Purchasing Price
Buy concentrates and dilute during production, in case of long delivery distances, the transport costs play a significant role Chemical Companies are creating more and more Multifunctional Products, which has huge advantages, because of several properties in one product, you can save the usage of many different compounds
Latest generation of dyes used in an intelligent designSlide24
AFIRM RSL Training Seminar
24Purchasing Raw Materials
Buy only what you knowType of materialProduction backgroundUse AFIRM Risk Matrix to assess the risk to find hazard chemicalsSource of raw materials
Reputable supplier
Assurance/guarantee from supplier
Test reports (recent date, valid test method, same material)
Declaration / confirmation letter, eco labelsSlide25
AFIRM RSL Training Seminar
25Root Cause Analysis & Corrective Action
Establish process for dealing with potential non-compliance Follow up action for non-complianceStop productionIdentify the source for the non-compliant
chemicals
Chemical Testing
Chemical Formulations
Raw materials
Components
Semi finished and final productsSlide26
AFIRM RSL Training Seminar
26Root Cause Analysis & Corrective Action
Root CausesContaminated tech. chemical productsChemical containers not labeled or wrong labeledChemical containers not covered (no lid)Production line and workspace not cleaned
Pair of scales out of
calibration
Corrective Action
Substitute
chemical auxiliary
Exchange material
Destroy non-compliant
materialsSlide27
AFIRM RSL Training Seminar
27Verification of Compliance
Verification ProcessDocumenting corrective and preventive action and verifying effectiveness of action takenSlide28
AFIRM RSL Training Seminar
28
Thank you for your attention !