ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ) : The Zero Discharge of Hazardous Chemicals Programme
ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ) : The Zero Discharge of Hazardous Chemicals Programme
Wastewater
Guidelines
Frequently
Asked
Questions
(FAQ)
Contents:
4. Why has leather been excluded from the scope of the Wastewater Guidelines? . 4
5. Why has the production of raw materials been excluded from the scope of the
Wastewater Guidelines? ............................................................................................. 4
6. Are there any legal implications from the Wastewater Guidelines? ....................... 4
7. Some of the limit values are comparable to drinking water standards. Why is
ZDHC asking suppliers to treat their wastewater to such high standards? .......... 5
8. Which experts has ZDHC contacted to ensure the Wastewater Guidelines are
implementable?............................................................................................................ 5
10. The Wastewater Guidelines cover a wide range of different facilities which
cannot necessarily be compared by wastewater types. Why do the Wastewater
Guidelines not differentiate according to the manufacturing process?................. 6
12. Why has sludge been included in the scope of these Wastewater Guidelines? ... 6
13. Why are there no limit values set for sludge testing? .............................................. 7
15. Do factories who already test their raw wastewater also need to test sludge?..... 7
16. What will be the cost associated with the testing of the water? ............................. 8
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
18. Will other brands accept wastewater test reports done in accordance with the
guidance? ..................................................................................................................... 8
21. Who can I contact for support if I want to improve my wastewater treatment
system?......................................................................................................................... 8
22. Why is ZDHC asking for testing of conventional wastewater parameters for
indirect discharge? ...................................................................................................... 9
23. A company is already uploading wastewater test reports on the IPE platform.
Does this company have to upload now to two platforms? .................................... 9
24. How do the Wastewater Guidelines relate to the Higg Index of the Sustainable
Apparel Coalition (SAC)? ............................................................................................ 9
28. Will the laboratories automatically upload the test results on the ZDHC Data &
Disclosure Platform? ................................................................................................. 10
29. How can I become a ZDHC accepted laboratory for the purpose of testing
wastewater?................................................................................................................ 10
31. Why are the reporting limits for the ZDHC MRSL parameters in the Wastewater
Guideline not zero if the goal is to strive for zero discharge of hazardous
chemicals?.................................................................................................................. 10
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
The ZDHC Wastewater Guidelines are freely available from the ZDHC
website and every actor within the textile and footwear value chain is
welcome to use it free of charge. To enable widespread industry adoption,
ZDHC encourages its contributors to adopt the Wastewater Guidelines within
their organisations.
a. Brands?
b. Factories?
An aligned standard by brands for wastewater means that suppliers can use
one guidance document. The ZDHC Wastewater Guidelines eliminate the
need for overlapping requirements and reduces the need for multiple tests
for various brands.
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
4. Why has leather been excluded from the scope of the Wastewater
Guidelines?
5. Why has the production of raw materials been excluded from the scope of the
Wastewater Guidelines?
The processes and chemicals used for the production of raw materials (for
example polyester) varies widely depending on the raw material type. To
include a diverse set of raw materials would have resulted in a very broad
and complex set of guidelines.
The intent of the ZDHC Wastewater Guidelines was to focus on parts of the
value chain that have the most immediate need for improvement. ZDHC may
consider issuing raw material specific guidance materials at a later stage.
ZDHC will not inform any regulatory authority on failures. However, as the
facilities are always expected to be in legal compliance, if data is reported
that doesn’t meet these requirements, each facility should take action to
correct the problem and inform the relevant authorities.
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
7. Some of the limit values are comparable to drinking water standards. Why is
ZDHC asking suppliers to treat their wastewater to such high standards?
8. Which experts has ZDHC contacted to ensure the Wastewater Guidelines are
implementable?
a. Conventional Parameters
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
b. MRSL Parameters
The MRSL or hazardous chemicals parameters were taken from the ZDHC
MRSL, a peer reviewed list of hazardous chemicals which can be eliminated
or replaced easily by existing alternative chemistry.
10. The Wastewater Guidelines cover a wide range of different facilities which
cannot necessarily be compared by wastewater types. Why do the
Wastewater Guidelines not differentiate according to the manufacturing
process?
ZDHC acknowledges that processes in the textile and footwear industry can
sometimes differ and that therefore it is more difficult to meet the limit values
for some types of production (for example, residual antimony from polyester
production).
12. Why has sludge been included in the scope of these Wastewater Guidelines?
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
13. Why are there no limit values set for sludge testing?
Unlike wastewater testing, where ZDHC could draw from a large number of
existing test reports, there are not enough test reports on MRSL parameters
in sludge currently available to allow for a representative sample that could
be evaluated to set limit values.
15. Do factories who already test their raw wastewater also need to test sludge?
Facilities who are already testing raw wastewater will not be required to test
sludge as well. However, ZDHC encourages facilities to engage in sludge
testing in order to receive a complete picture of the potential discharge of
hazardous chemicals via sludge and also to support the development of
respective limit values for sludge.
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
16. What will be the cost associated with the testing of the water?
For facilities which produce materials for more than one ZDHC contributor,
the ZDHC Wastewater Guidelines align the sampling and testing of all ZDHC
contributors, and eliminate the need for brand-specific testing. It is expected
that this will result in a net savings for these shared facilities.
18. Will other brands accept wastewater test reports done in accordance with the
guidance?
It is the explicit goal and expectation of ZDHC and its contributors that they
will accept the tests done in accordance with the ZDHC Wastewater
Guidelines instead of asking for individual and customised sampling and
testing methods, and reporting limits.
The facility will have the chance to take corrective measures and apply for
re-testing. If the re-testing is also failing the minimum requirements, the
facility is expected to inform their customers and upload a corrective action
plan to the ZDHC portal.
21. Who can I contact for support if I want to improve my wastewater treatment
system?
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
22. Why is ZDHC asking for testing of conventional wastewater parameters for
indirect discharge?
ZDHC acknowledges facilities that have indirect discharge will have different
agreements with the receiving wastewater treatment plants or local
authorities on the quality of their wastewater discharges. However, ZDHC
still recognises the need for indirect dischargers to be compliant to those limit
values.
23. A company is already uploading wastewater test reports on the IPE platform.
Does this company have to upload now to two platforms?
24. How do the Wastewater Guidelines relate to the Higg Index of the Sustainable
Apparel Coalition (SAC)?
The ZDHC Wastewater Guidelines and the SAC efforts are complementary.
The ZDHC Wastewater Guidelines will be integrated into the Higg Index
Environmental Facilities Module (Version 3.0) of the Sustainable Apparel
Coalition. The Higg 3.0 will be a method for validating whether or not a
facility has completed their testing and reporting per the ZDHC Wastewater
Guidelines.
ZDHC aims to update the Wastewater Guidelines after 12 months from the
date of release.
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
There are four global laboratory testing networks that have contributed to the
development of the Wastewater Guidelines and also confirmed their
capability to test the listed parameters. There will likely be additional
laboratory networks that are able to provide this testing. Each facility has the
option to use the laboratory of their choice as long as this laboratory meets
the minimum criteria listed in the guideline.
28. Will the laboratories automatically upload the test results on the ZDHC Data &
Disclosure Platform?
29. How can I become a ZDHC accepted laboratory for the purpose of testing
wastewater?
31. Why are the reporting limits for the ZDHC MRSL parameters in the
Wastewater Guideline not zero if the goal is to strive for zero discharge of
hazardous chemicals?
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ZDHC Wastewater Guidelines Frequently Asked Questions (FAQ)
32. Why are the limits set by ZDHC referring to concentration limits and not to the
overall load of a certain pollutant? Is this not penalising facilities with high
water recycling rates?
ZDHC acknowledges that facilities with high wastewater recycling rates
concentrate the pollutants in the remaining wastewater stream. Therefore,
ZDHC has considered adding pollution load factors rather than concentration
limits into the Wastewater Guidelines.
However, the calculation of pollution loads is complex and requires good
data on water consumption and material output. The ZDHC Wastewater
Guidelines want to set a simple and unified wastewater quality expectation. It
was therefore decided to set limits based on concentrations, while at the
same time prohibiting dilution of wastewater for the purpose of lowering
concentrations of a certain pollutant.
Should individual facilities believe they are unable to meet the concentration
limits set due to their very efficient water recycling programs, ZDHC invites
those facilities to contact their ZDHC contributing representatives for further
discussion.
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