ZDHC MRSL Substance Submission

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ZDHC MRSL UPDATE PROCESS - BACKGROUND

The ZDHC Roadmap to Zero Programme takes a holistic approach to tackling the issue of hazardous chemicals in the global textile, apparel, and footwear industry.

Our goal is to eliminate the use of priority hazardous chemicals by focussing on the following areas:

Input Focus Area: Manufacturing Restricted Substances List (MRSL), Conformity Guidance and the ZDHC Gateway - Chemical Module

Process Focus Area:  Chemical Management System (CMS) and HIGG FEM 3.0

Output Focus Area: Wastewater Quality and ZDHC Gateway - Wastewater Module

ZDHC Academy: Training and capacity building for all 3 focus areas

 

The intent of the ZDHC MRSL is to provide a harmonised approach to managing chemicals within the textile, apparel and footwear supply chain. The ZDHC MRSL achieves this by providing a clear list of priority chemicals and specifying the maximum limit value of each substance within commercial chemical formulations.The limits are designed to eliminate the possibility of intentional use of listed substances.

 

The current version of the ZDHC MRSL was released in Dec 2015, and we have created a transparent process for future updates of the ZDHC MRSL. We also understand the importance of having a clear and strong governance to support the update process

A well-defined MRSL governance, explained in the Principles & Procedures, managed by the MRSL advisory Council is in place to drive an objective process.

 

Submission criteria for an proposal are:

  • Identification of the proposed substance

  • Hazard

  • Volume

  • Use Pattern

  • Proposed Formulation limit value (optional)

  • Test Methodology (Optional)

  • Safer Alternative (Optional)

 

 

ZDHC MRSL UPDATE PROCESS - HIGH LEVEL STEPS, PRINCIPLES AND PROCEDURES

Step 1: A Proposing Entity Submits Proposal by Completing an Online Submission Form (will be made available in the ZDHC MRSL Submission Platform).

A Proposing Entity (PE) can be absolutely anyone. For example, it could be an individual, a chemical company, a dye-house, an NGO representing civil society, a professional body, the ZDHC Foundation, the ZDHC Input Focus Area team or Task Team, a ZDHC Contributor, an academic organisation or the MRSL Advisory Council. This is not an exhaustive list of all PEs. The submission criteria (see Section 5) address several critical areas including, but not limited to, relevance to apparel, textiles and footwear industry, estimates of the amount used in a specific scenario and in total across the industry, exposure and discharge scenarios and the presence of ‘feasible/viable’ substitutes.

 

 

Step 2: ZDHC to Do a First Screening of the Submissions (i.e. proposals that have been submitted)

ZDHC will apply a sense check screening/filtering system to:

●    Identify any submission with substances considered to be out of scope and exclude those submissions that have no relevance to apparel, textiles and footwear,

●    Identify duplicate submissions, and

●    Identify incomplete submissions.

 

This function will be carried out by a combination of using the screening of the online submission and the ZDHC Programme Management Team.

 

The PE will be informed if their submission

a)       has been filtered out,

b)       requires more information/data to be verified or

c)       if it has gone through for review by the ZDHC (see Step 3A) and the Technical Review Task Team (see Step 3B).

 

 

Step 3. Review and Assessment by ZDHC and Technical Review Task Team – Second Screening Level.

At this stage, ZDHC and the Technical Review Task Team (part of the ZDHC Input Focus Area) will conduct a second screening. Both groups will separately review, evaluate and assess the information on the submission document.

 

Step 3A. ZDHC to:

●      Provide comments and any additional relevant information (submission criteria) to the submissions.

●      Provide a recommendation to MRSL Advisory Council (MAC) as to which category (based on section 3) the chemical will go into.

All comments and recommendation from the ZDHC will be appended to the submission document via the ZDHC MRSL Submission Platform for review by the MAC (Step 4).

 

Step 3B. The Technical Review Task Team (TT) to:

●      Provide comments and any additional relevant information to the submissions.

●      Provide a recommendation to MRSL Advisory Council (MAC) as to which category (based on section 3) the chemical will go into.

TT does not need to attempt to reach a consensus opinion among themselves as a group, rather they will be able to send along all relevant comments and recommendation to the MRSL Advisory Council (MAC) as an individual or a (sub) group via the ZDHC MRSL Submission Platform. All comments and recommendation(s) from the TT will be appended to the submission document for review by the MAC (Step 4).

 

Additional relevant information could be additional data a company/organisation may have on usage, residual in product, feasibility of safer alternatives, test data, etc.

 

 

Step 4: MAC to Review Submissions and Provide Final Decision to ZDHC

MAC (MRSL Advisory Council) will review the submission documents including the comments and recommendations provided by the ZDHC and Technical Review Task Team. MAC will then make a final decision as to which category (see section 3) the chemical will go into and inform the ZDHC Programme Management on their final decision. MAC will append their commentary to the submission document including the final decision, and it will be passed on to the ZDHC Programme Management Team.

 

Definition of each of the categories (i.e. ZDHC MRSL, ZDHC Candidate List, Substances under Review- pending further information or Substances considered to be out of Scope) is explained in section 3 of this document.   

 

 

Step 5: ZDHC to Make Necessary Updates and Inform the Proposing Entity

Based on the final decision from the MAC (MRSL Advisory Council) i.e. Step 4, the ZDHC MRSL and ZDHC Candidate List will be updated accordingly. It is envisaged that new chemicals, changes of limit and or scope, and time-scaled chemicals will be added or reviewed at the next scheduled or 20XX ZDHC MRSL revision.

ZDHC will inform the Proposing Entity (PE) what the outcome of their submission is and provide information to them regarding which category their chemical has been put in, and the main reason for the decision.

 

 

Roles & Responsibilities

Although the steps and roles of the different key stakeholders are presented in the process flow chart and the high-level description of the steps, there will be cooperation and collaboration between the ZDHC Programme Management Team, Technical Review Task Team (TT) and MRSL Advisory Council (MAC) as outlined below.

I have read, and I agree with the online ZDHC MRSL Update Process.