Prasad Pant, CEO at NimkarTek Technical Services Pvt Ltd
The focus of brands on chemical management across their supply chains has traditionally been the ´tip of the iceberg´, that is, their direct contractual vendors. Their influence beyond direct vendors (the Tier 1 suppliers) has been minimal. This is partly due to the supply chains being fragmented and spread across different geographical areas, and partly due to limited volume of business at a supplier. It is only after the ´Detox Campaign´ by NGOs that brands are looking deeper into this iceberg, trying to fathom the depth and the ways to reach below the surface.
Their effort and approach is further compounded by the lack of knowledge and awareness about chemical issues at their suppliers. Traditionally, brands have relied on the RSL (Restricted Substances List) for communicating & monitoring hazardous chemicals used in their products. The complex RSL document is passed upstream from the Brand to the Tier 1 to Tier 2 to Tier 3 to (finally) the chemical suppliers and a paper trail of signed documents is established, that is usually filed and displayed at audits. The content of these documents is not really understood by suppliers. The compliance to RSLs is done through random testing of finished articles for a few RSL Groups (usually banned amines, formaldehyde and phthalates) and non-compliant goods rejected or re-worked.
Another problem in managing chemicals for brands has been disclosure of the chemical inventory used at a facility. Chemical suppliers often use ´proprietary´ formulations, which they are not willing to disclose. The information in the MSDS given by them does not, many a time, reveal the intrinsic hazards or restricted substances used in a formulation. Suppliers also do not have sufficient knowledge of how to interpret an MSDS to identify hazards and plan precautionary actions.
There is also no standard established audit protocol for brands to evaluate practices at suppliers for chemical management. From the supplier point of view, the RSL documents given by Brands have differing requirements and limit values, each Brand trying to be stricter than the other, often without any rationale. Effective sampling of the finished article that is representative of the bulk is another challenge.
Common problems and their ramifications
RSL non-compliance can lead to legal actions, financial losses, re-work of goods and loss in sales at the Store, besides loss of image. A common problem is use of chemicals and raw materials where restricted substances have been intentionally added, mainly due to lack of awareness. Some examples: An APEO-based scouring agent used to process the fabric for a ladies garment of a Brand led to 7,839 pieces being rejected. Presence of Chromium VI due to metal-complex dyes used in a leather jacket supplied to a Brand resulted in rejections worth $3,20,000. Lead in the red paint used in boots caused a loss of $4.4 million. All this despite of RSL documentation being in place! Sometimes, RSL presence in a component of a garment can lead to rejection of the entire shipment. Examples are: detection of APEO in pocket linings of a pair of jeans, allergenic disperse dyes in sewing thread used in a garment, phthalate (DEHP) in the company logo printed as a plastisol print on a t-Shirt, a banned amine detected in the inner black lining fabric of a ladies purse.
Another problem is cross-contamination from the process, substrates or during transportation which leads to RSL failures in end articles. This, again, is due to lack of knowledge about input chemicals used in the manufacturing process.
1.A printed silk fabric tested positive for PCP. Analysis of input chemicals showed tha