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TOM TAILOR - Chemical Management Handbook V2.0 Aug 2020
TOM TAILOR - Chemical Management Handbook V2.0 Aug 2020
We started our journey to Zero Discharge since 2016 with our own MRSL which was
successfully integrated into our supply chain activities. As we need to strengthen our
activities for achieving Zero Discharge, we adopt the widely accepted industry best
practice ZDHC MRSL.
In partnering with us, we need the responsibility from our suppliers to ensure that all
legal requirements concerning labor compliance, occupational health and safety,
product safety and environmental safety are fully complied with.
This Chemical Management Handbook aims to provide some guidance for our
partners to develop their own chemical management processes and system which
helps to accomplish a better sustainable supply chain and compliance. This
Chemical Management Handbook will be reviewed and updated from time to time
depending on upcoming new requirements. Suppliers are welcome to interact with
us to provide comments and suggestions. We always look forward to working
together, sharing better information and practices in these corporate documents.
Overview 4
Appendix 18-36
Commitment Letter 36
In textile and apparel industry, lots of chemicals are being consumed in processing
and manufacturing of a product. Wet processing on textiles, garments and trims are
especially highly dependent on chemicals.
While scientists and chemists are still working on researches, there are readily
available literatures confirming some chemicals are hazardous and can be harmful
for the environment, marine lives and human beings.
The baseline for building the chemical management tool is the Manufacturing
Restricted Substances List (MRSL/RSL) which sets the minimum requirements for
chemical input and output for suppliers, partners and processing facilities. It can be
found in the Appendix of our chemical handbook.
Scope
TOM TAILOR wants to ensure compliance with laws and regulatory requirements,
like, in markets where TOM TAILOR products are sold and produced/ sourced. TOM
TAILOR looks forth to go beyond to DETOX its supply chain through eliminating
hazardous chemicals.
The procedures set forth in the coming pages, therefore apply to all suppliers of
products sold by TOM TAILOR, irrespective of their method of sourcing.
“Hazardous Chemicals” is a very broad and generic term. It means any substance,
item, chemical, or agent that could cause harm to humans, animals, or the
environment, either by itself or through interaction with other factors.
The following are keys for a better chemical management for suppliers, and should
be set as foundations for building suppliers’ own chemical management system:
In addition to adopting the above keys into one’s chemical management system, it
will be good to understand that in every system development, “Plan-Do-Check-Act”
(PDCA) is a common approach for continuous improvement to ensure the
management system is robust and sustainable. Hence, PDCA should be an
important method reiterating the chemical management system implementation.
In general, the scopes, goals and requirements are related to the interests of internal
and external stakeholders. Senior management of the supplier must adhere to the
commitment when creating policies, practices and procedures, also deliver and drive
the same to all related units and workers, from top to the bottom.
As an easy step for suppliers to start with their chemical management system, a
preferred industrial practice is to create a Chemical Master List and a Chemical
Inventory Record. Every single chemical must be registered and tracked. This
database is useful for the PDCA of chemical management system subsequently.
From the Master List and Inventory List, supplier needs to record below key
information of their chemicals (most of them can be found from the MSDS/ TDS):
This evaluation identifies the hazards of a chemical that may pose to the
environment, and human being. (Please refer to “Definition of Hazardous
Chemicals”.)
Hazard determination sets the baseline for a further estimation and assessment of
risk. Hazard refers to an inherent property of a substance that is capable of causing
an adverse effect. Risk refers to the probability that an adverse effect will occur with
specific exposure conditions. Thus, a substance will present the same hazard in all
situations due to its innate chemical or physical properties and its actions on cells
and tissues. However, considerable differences may exist in the risk posed by a
substance, depending on how the substance is contained or handled, personal
protective measures used, and other conditions that result in or limit exposure.
*Chemical suppliers should provide valid MSDS/ TSDS of the particular chemicals
purchased, and local language version should be available too for operational use.
Each organization may have its own infrastructure and organisation hierarchy setup
to run the chemical management system. In general, the roles and responsibilities
should at least cover –
Role Responsibility
Chemical Reports to top management and senior leadership
Management Responsible for day-to-day management of chemical
Officer (CMO) management system
Responsible for setting up goals and commitment for the
organization, ensuring compliance to applicable
requirements
Responsible for tracking progress, monitoring KPIs and
goals to supply chain partners
Regulatory Ownership of building, maintaining and updating the local,
Compliance national and international regulatory compliance
Officer (RCO) requirements within the organization
Addressing new or changing compliance requirements to
CMO that could affect the business and operation of the
organization
Responsible for RSL and MRSL compliance and
communication with supply chain partners
Technical Responsible for production process and product chemical
Officer (TO) knowledge
Responsible for working together with RCO to
communicate the necessary technical information with
supply chain partners; and provide technical support to the
organization
Responsible for chemical hazard determination and
assessment
Responsible for exploring safer alternatives (e.g.
chemicals, technology)
Chemical Labelling
Chemical containers and packaging should allow for clear identification of chemical
substances. Hazard and risk information needs to be delivered to people who will
have contacts with the chemical. Internationally standardized labels (e.g. GHS),
markings, symbols, warning statements are commonly used to serve above purpose.
Suppliers should ensure incoming chemicals are with proper labels on packaging
upon receipt. Simplified labels with essential information in local language including
chemical name, and warning sign should be used whenever smaller portions are to
be disseminated or distributed for use in the factory premise.
Any unidentifiable chemicals found in the workplace should be cleared and properly
handled to avoid contamination of the production floor.
The secondary containment can be in the form of absorbent material, special pallets,
or barrels, and it should comply with the following:
Chemically compatiable with the materials to be stored in them
Designed in accordance with the total volume of containers to be hold with
respect to the principles for whichever is better: (may refer to US OSHA or
other resources for more guidance)
o At least 10% of the total volume chemicals to be stored
o Able to hold 110% of the largest container to be stored
While it is critical to avoid hazards and risks at the first place when designing the
workshop and adopting particular process workflow, PPE, as a last resort though,
should always serve to protect employees from being hurt by an unexpected
accident or expected incident in daily operations.
For areas where chemicals are used, PPE usage warning signs and respective
instructions should be posted to guide the proper usage, and respective PPE should
be provided free for use by employees – regular maintenance and replacement of
such PPE should be done to ensure the protection.
***Caution***
Suppliers should ensure work environment assessment in relation to occupational
health and safety is conducted on a regular basis and when there are changes in the
production process, so as to make sure the setup is safe to operators. If potential
hazards are identified, suitable measures and PPEs should hence be provided as
protection for employees.
Storage
With respect to the potential hazards that chemicals may bring, precautions must be
taken in storing chemicals at the workplace.
Signage (chemical names, warning and hazard labels, etc.) and MSDS should be
available as identification for ease of segregation and onsite handling.
If suppliers may have any aboveground/ underground tanks onsite for chemical
storage, the rules above should apply as well, and regular integrity testing of such
tanks should be conducted. They should also ensure any license or permit
appropriate should be valid in place.
MSDS
For every chemical product, it should have its own MSDS/ TSDS/ SDS. Suppliers
should obtain such information from the chemical suppliers/ dealers/ agencies for
understanding thoroughly what chemicals are being used onsite, and what sort of
measures need to be taken.
Many production processes generate waste. The disposal can be to air, water or soil.
The hazards, risks and toxicity of disposed waste chemicals should be identified and
measured.
In best practice, recycle or reuse the waste is ideal whenever possible. However, if
recycle or reuse is not applicable, organization needs to make sure the waste and
disposal will be treated before discharging or releasing to public. The waste should
be properly handled by qualified service providers and the hazardous and toxic
impact to human and environment must comply with the regulation and should be as
low as possible.
Attention should be paid for effluent treatment if suppliers run any wet-processing
units. For effluent discharge, legal compliance is a baseline, and suppliers should
strive for excellence with adopting ZDHC Wastewater Guidelines.
https://www.roadmaptozero.com/post/updated-zdhc-wastewater-guidelines-v1-1-released
Suppliers should ensure operators who deal with chemicals directly as part of their
daily work are familiar with the risks and hazards such chemicals may bring to them,
and hence follow accordingly on the proper work procedures and take protective/
safety measures.
Orientation, regular training and daily briefing to such operators regarding health and
safety requirement and measures, and work standards are important. The Chemical
Management Team should include training as part of their work plan.
Hardware equipment including firefighting equipment and spare water tanks for
wastewater should be in place and well maintained to minimise impact in case.
With all these setup, it is crucial to ensure employees onsite understand well what to
do in case of emergency. Hence, regular drills should be conducted with
performance recorded for improvement planning.
Regular Review
Internal audits and management reviews should be conducted to check whether the
daily operation is consistent with the policy and procedures set. This is a good way
to identify loopholes and rooms for improvement to be made in terms of revision of
the procedures, communications, training, etc.
Suppliers could also consider seeking for third party certification programmes to
build up robust chemical management system.
TOM TAILOR as a member of amfori, has launched BEPI in the supply chain since
August 2019, and this is applicable to all our suppliers and factories (production
sites) (except license suppliers).
All our active Tier 1 suppliers/ factories are subjected to completion of the BEPI Self-
assessment questionnaire (SAQ) which covers the above 11 EPAs and respective
data collection for reflecting the environmental performances of such suppliers/
factories on a regular basis.
While the EPAs highlighted with a “star” is considered more relevant to our supply
chain, average score of “Pollution Prevention and Chemicals” and “Wastewater/
Effluent” becomes the “Chem-Index” for our assessing the chemical management
performance of our suppliers/ factories.
Our suppliers/ factories should hence follow this Chemical Handbook to drive
changes and maintain a good management system for eventually achieving “Green”
results:
Green 61-100 Considered good, or a strength
Yellow 41-60 As mediocre, and possibly a weakness
Red 0-40 As weakness
CSR Department
Ms. Claudia Landgraf, [email protected]
Ms. Tilky Wang, [email protected]
General Information 20
Chemical Test Package 20
Legal Requirements 21-22
REACh, SVHC, POP Regulation 21-22
RSL, MRSL and CADs RSL 23-35
RSL adults 24-27
RSL Baby’s, Kids 28-31
RSL Substances and CAS numbers 32-35
Commitment Letter 36
All chemical tests have to be organized by the supplier himself, and need to be done
at accredited laboratories, SGS and Bureau Veritas.
TOM TAILOR reserves the right to ask for rechecks and random tests.
If a consignment of goods does not meet these requirements, TOM TAILOR will
either reject the goods or they will be processed in Hamburg.
In both cases the respective costs incurred will be charged back to the supplier.
Test results have to be entered in PLM system and test report documents have to be
uploaded as PDF file.
Partners without PLM System login account have to send all test reports to the QA
testing department ([email protected]; [email protected]).
The Chemical Test Package is a random test and for certain selected styles by
TOM TAILOR Laboratory. All limits for the parameters are mentioned in the TOM
TAILOR Restricted Substances List (RSL).
Test application will be requested in PLM system for all necessary articles.
The European Union transposed the reform of the chemicals legislation by the
European Regulation (EC) 1907/2006. This regulation is also known under the
keyword “REACh” (Regulation for Registration, Evaluation, Authorisation and
Restriction of Chemicals). Since 1st June 2007 the regulation has a direct effect in
each member state of the European Union.
REACh aims at protecting health and environment through a safe handling with
chemicals. For this reason it contains rules about the registration, evaluation, licence
and limitation of chemicals (so-called “substances” in the regulation). The safe use of
chemicals must be ensured, particularly with regard to the protection of human
health and environment (ground, air, water) as certain key priorities of the REACh
regulation.
Substances of very high concern (SVHC) are defined in Article 57 of Regulation (EC)
No 1907/2006 (“the REACH Regulation”) and include substances which are
Carcinogenic, Mutagenic or toxic to Reproduction (CMR), meeting the criteria for
classification in category 1 or 2 in accordance with Directive 67/548/EEC,
Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very
Bioaccumulative (vPvB) according to the criteria in Annex XIII of the REACH
Regulation.
The supplied goods have to correspond to the prohibition and limitation of toxic
substances as they are laid down in the Annex XVII of the Regulation(EG)
1907/2006, which can be downloaded from the following website, and which forms
an essential part of this agreement:
https://echa.europa.eu/substances-restricted-under-reach
The supplied products are not allowed to include more than 0.1 % (this corresponds
to 1000 mg/kg or 1000 ppm) of a substance of very high concern registered in the
actual (date of delivery) REACh-“Candidate-List”, which can be downloaded from
the following website:
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp
The mentioned weight limit of 0.1 % refers to the weight of the respective products.
In case of a compound product, the weight of each separate component is relevant
(ECJ, judgment of 10. September 2015, C-106/14), for example the weight of yarn,
of inlays, buttons or zippers.
https://eur-lex.europa.eu/legal-
content/DE/ALL/?uri=uriserv:OJ.L_.2019.169.01.0045.01.DEU
and
https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32020R0784&from=EN.
The supplier is obliged to inform himself regularly about the current version of the
POP Regulation.
The delivered products correspond in each item to applicable legal requirements and
Restricted Substances List (RSL) of TOM TAILOR, the RSL is a part of each order
and is enclosed.
Shoes and bags supplied must comply with the requirements of CADs RSL.
The present version can be found under the following link:
https://www.cads-shoes.com/en/rsl
The supplier is obliged to inform himself regularly about the current version of the
CADs RSL.
In addition, only textile auxiliaries and colourants that comply with the limits of the
Manufacturing Restricted Substances List (MRSL) of the Zero Discharge of
Hazardous Chemicals Programme (ZDHC) in the version applicable at the time of
delivery are used for the production of the goods supplied, which can be downloaded
from
https://www.roadmaptozero.com/mrsl_online/
This contains the permissible pollutant concentrations for various substance groups
in the chemicals used. We reserve the right to verify compliance with this
requirement by submitting the chemical register and the confirmations of the
chemical suppliers.
RSL
Please find following Restricted Substances Lists (RSL) for TOM TAILOR.