An important part of any sustainability strategy within the textiles and apparel industry is chemicals management. Wherever you are within the supply chain, it’s imperative to understand the chemicals used in the production of all apparel, footwear, home, hospitality and other textile products.
In the textile industry previous chemical management strategies have often relied on Restricted Substance Lists or “RSLs,” which focus on restricting the chemicals present in or on a finished product. However, this is no longer an area where having the classic RSL model is enough because while managing to an RSL is important, a majority of chemicals used in the production and manufacturing of textile products do NOT end up in or on the finished product. Herein lies the problem and the opportunity, as well as the responsibility to manage hazardous chemicals used in the production and manufacturing stages. To address these challenges, companies are increasingly beginning to utilize the Zero Discharge of Hazardous Chemicals (ZDHC) program’s Manufacturing Restricted Substances List (MRSL) as a mechanism to address and reduce the use of hazardous chemicals at the beginning of the manufacturing and production process, as opposed to at the end.
As the ZDHC MRSL quickly becomes the de facto chemicals management guidepost for the industry, it’s critical to understand what ZDHC is doing and the programs it offers—in particular the MRSL and the conformance pathway they’ve constructed with program levels ranging from one to three.
At NSF, we’re pleased to be an authorized assessor to two ZDHC-approved MRSL Conformance Level 1 programs: ToxFMD Screened Chemistry™ (ToxFMD®) and NSF’s own Basic Level 1 Conformance program. We believe both programs offer exceptional value and opportunities to achieve improved chemicals management at the factory level.
Basic Level 1
The Basic Level 1 review is NSF’s more foundational program. This is an excellent way for manufacturers, suppliers and chemical suppliers to get started on the pathway to understanding their chemical supply chain while working towards continuous improvement. NSF’s ZDHC Level 1 MRSL review requires disclosure of intentionally added ingredients, as well as residuals, by-products, contaminants or other impurities. The review focuses on evaluating against the levels set forth in Group B on ZDHC’s MRSL.
Upon completion of the review, NSF provides a report detailing the outcome for each product reviewed. All products deemed compliant with the Level 1 criteria receive a certificate of conformity and the relevant information is uploaded into ZDHC’s Chemical Gateway as a verification of Level 1 compliance and listed on NSF’s website.
ToxFMD is a more rigorous and comprehensive program. The review for this program includes a screen against ZDHC’s MRSL and utilizes additional chemical hazard assessment criteria to evaluate chemical formulations and their ingredients against several human and environmental hazard end points. As part of the ToxFMD program, full disclosure of all intentionally added ingredients and all residuals/impurities present in the final product’s formulation is required. Additional information from suppliers may be needed as part of the review. NSF evaluates all ingredients against the ZDHC MRSL, U.S. EPA Safer Chemical Ingredients List (SCIL), Safer Choice Master Criteria for Safer Ingredients, the GreenScreen List Translator or GreenScreen for Safer Chemicals. ToxFMD also includes analytical testing to confirm compliance with the ZDHC MRSL limits for heavy metals.
Upon completion of the review, NSF provides a report detailing the outcome for each product—either as ToxFMD Acceptable or ToxFMD Not Acceptable—and a formulation score. Additionally, a high-level scorecard is provided that can be shared with a client or another brand to easily communicate results of the ToxFMD review. Lastly, each ToxFMD Acceptable product also receives a certificate of conformity and the relevant information is uploaded into ZDHC’s Chemical Gateway as a verification of Level 1 compliance and listed on NSF’s website.
Challenging opportunities ahead
The lack of enthusiasm you might have for an intense conformance program is understandable. Yet as difficult and involved as the programs may seem, it’s important they get done. Chemical management within the textiles industry is widely misunderstood, complex and challenging—with many of the chemicals in use not currently being managed or assessed for hazards. As a result, textile manufacturing is the third-largest polluter of freshwater resources in the Eastern Hemisphere; however, within this challenge lies an opportunity.
If companies commit to including MRSL chemicals management into their sustainability plans—and begin to address it with their suppliers and chemical suppliers—the textiles industry can really start to make a meaningful dent in removing hazardous chemicals in critical phases of production. NSF stands ready to help and work with you in completing either of the two MRSL conformance programs. For further information on these programs, we welcome you to participate in our upcoming webinar on Oct. 2, 2019, at 1:00 PM EDT.