ZDHC – the beginning of a revolution?

Dr Muriel Rigout report on this recent SDC North of England region event, which focused on ZDHC.

If ZDHC sounds to you like a random combination of letters probably arisen from the idle or accidental depression of keys on the author’s keyboard, then do read on.

Indeed, the combination ZDHC is not appearing on this blog due to sloppy editing, but is in fact an acronym that you soon will not be able to avoid if you intend to live a normal life in the field of coloration.

The letters ZDHC stand for Zero Discharge of Hazardous Chemicals, and they are used to refer to the programme formed by brand members and retailers in association with other stakeholders (eg dyestuff and chemical auxiliary suppliers) to ‘catalyse positive change in the discharge of hazardous chemicals across the product life cycle’.

On the 24th of September 2014, members of the North of England region of the SDC had the pleasure to listen to two speakers on the topic: Dr Mark Sumner, now lecturer of Sustainability in Fashion and Retail at Leeds University, School of Design, speaking principally in the context of his former role as Sustainability Specialist at M&S, and John Murphy from Huntsman Textile Effects in charge of a Special Project on the matter.

Mark SumnerMark was involved very much from the inception of the ZDHC programme, and provided us first of all with an overview of the problem: what he termed ‘The Dyehouse Timebomb’. M&S, like a number of brands and retailers, had up to this point been working on a dyehouse compliance programme, looking at reducing the environmental impact and improving the productivity of dyehouses in their supply chain. However, the knowledge, expertise and standards that the retail community were applying to managing the operations of dyehouses in their supply chain were very diverse, with some retailers possessing a high level of knowledge and understanding, and some barely aware of legislative compliance.

The Detox Campaign, as launched by Greenpeace in 2011 in the Dirty Laundry reports, was the first detonation of this ‘timebomb’. Greenpeace tested various items of clothing as purchased from the high street, as well as effluent discharge from dyehouses in China with which they tried to link particular brands. Greenpeace’s aim was to raise the profile of chemical use within the clothing and textile industry, and were driven by the harm that chemicals and effluent discharge specifically can produce on local communities. Hence Greenpeace first invited the brand and retailers to voluntarily join the Detox Campaign, then proceeded to target the brands and retailers who had not done so by launching public campaigns against these individual brands.

In response to the strong campaigning from Greenpeace activists, a number of brands and retailers decided to join forces. Greenpeace was demanding zero discharge of hazardous chemicals through all pathways (ie including dyehouses, garment makers, laundries, and at consumer level). This posed extremely difficult challenges at both the commercial and technical level, not only because ‘zero’ is very ill defined, but also because other aspects come into play, including the complexity of the supply chain, the definition of ‘deliberate use’, and the divergent approach to the definition of ‘hazard’ (as opposed to risk).

The rationale for creating this association was mainly linked to the complexity of the challenge, and the fact that a dyehouse will supply a number of brands. As Greenpeace was demanding that all chemicals being discharged by a dyehouse processing a particular brand’s product were declared and managed irrespective of whether these were being applied on the said brand’s products or not, it soon became apparent that only a collaborative approach would lead to a successful outcome. Hence the creation of the ZDHC and its various workstreams.

The ZDHC has set itself some very ambitious targets. They openly acknowledge their mission as being to ‘transform the global apparel and footwear industry by improving environmental performance and chemical safety’ through a ‘systematic change’ and the ‘creation of alternative chemistries’ by 2020.

Mark then left us with an interesting final thought: the next ‘timebomb’. He confided in us that reports related to the residual chemicals on clothing that may cause us harm are already being published. And while the ZDHC is preoccupied with diffusing the original timebomb set-off by Greenpeace, we are soon to expect another wave of attacks on our industry.

John MurphyJohn Murphy then expanded on the topic, particularly through illustrating the challenges that are currently being faced, and provided us with examples of what Huntsman Textile Effects, as a chemical company, is actively doing within the ZDHC framework to contribute to resolving the difficulties raised by the Greenpeace reports, either directly, or through working with their dyehouse customers.

Specifically, John expanded on the so-called MRSL (Manufacturing Restricted Substances List), a ‘work in progress’ document published by the ZDHC to ‘address hazardous substances potentially used and discharged into the environment during manufacturing and related processes, not just those substances that could be present in finished products’. The chemical suppliers are particularly well positioned to work with the ZDHC, as, while retailers have poor knowledge and visibility of the various dyehouses in their supply chain, chemical suppliers are particularly aware of them and are in the best position to work with the dyehouses to improve their effluent composition.

The journey to ‘zero discharge’ involves two key components:
1. The chemical products themselves, that must be free from the banned substances and of optimum formulation (including through chemical fate analysis)
2. The application procedure, insofar as the product must be applied correctly, but also when possible through the best available technology

In response to the first point, the chemical suppliers were invited to self-declare a ‘positive list’, that is to say publish the list of chemical formulation they can supply which ‘do not intentionally contain any of the banned chemicals’ and hence contribute to the commitments of the ZDHC. This is followed by a high level of research from the part of the chemical manufacturers/suppliers so as to investigate the chemical fate analysis of their formulations, including aspects such as toxicity, persistence, bioaccumulation potential, COD value, and estimated percentage of product impurity left in the application bath.

As for the second point above, the chemical suppliers continue to work with the various dyehouses in their customer base, helping them draw a Productivity Improvement Plan. This is normally undertaken following a benchmarking exercise, and makes use of the chemical suppliers investing the time of their expert technical staff to work hand-in-hand with the said dyehouses.

Clearly, the task set out by the ZDHC, and in particular through the MRSL, is a sizeable task, and as yet not all formulation can be listed as ‘ZDHC compliant’. It also raises a number of questions, including: should a dyehouse carry two inventories (ZDHC compliant and non-ZDHC compliant) in order to satisfy the demands of their ZDHC customers? And while we suspect Greenpeace would like us to answer this question with a resounding ‘No!’, the reality of the commercial world is such that this remains an important question.

Audience picTo conclude our session, a member of the audience, Dr Peter Lockett, made a valid point. He related a story, taking place some 25 years ago in the vicinity, near Rochdale, where pentachlorophenol used on cotton fabrics caused the failure of the local water treatment plants. He concluded that the complete ban of substances, as was declared on pentachlorophenol at the time, is very difficult to manage, and requires a high level of testing. Thus it appears the real ‘winners’ of this situation are the test houses that are employed to certify compliance at all levels.

Nonetheless, as besides the few instances where coloration plays a role in the performance of the garment (eg safety in high-visibility clothing) its principal aim is to add value and beauty, it is unsurprising that the customer will demand a similar reflection of value and beauty for the communities involved. Hence it is reasonable to expect that the Detox Campaign launched by Greenpeace, and the ZDHC collaboration that ensued, are very much just at the beginning of a revolution in looking at the responsibilities of all members in the supply chain, that is to say including brand, retailers and chemical suppliers, on the impact their products have on all communities associated with their products. Zero discharge thus appears to proclaim the ways of the future.

The presentations from John Murphy and Mark Sumner are available to members in SDC’s Knowledge Vault.  (Please note: you will need to log in).   Not an SDC member yet?  You can find details of membership here, or please email members@sdc.org.uk.

For details of forthcoming SDC events, please check the SDC website.


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