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FEM 2024 - Chemical Management Level 3

  • Updated

Table of Contents

  1. Chemzdhcroadtozero
  2. Chemzdhcroadtozero Verification And Scoring
  3. Chemtransparency
  4. Chemtransparency Verification And Scoring
  5. Chemcollabalternatives
  6. Chemcollabalternatives Verification And Scoring
  7. Chemanalysishumanenv
  8. Chemanalysishumanenv Verification And Scoring
  9. Chemanalysislifecycle
  10. Chemanalysislifecycle Verification And Scoring
  11. Chemcontractorsr
  12. Chemcontractorsr Verification And Scoring
  13. Chemcontractorsm
  14. Chemcontractorsm Verification And Scoring

Chemzdhcroadtozero

28. Have you adopted and implemented the ZDHC Roadmap to Zero (or the Supplier to Zero) programme on sustainable chemical management and its impact areas or other chemical management related industry programs?  (Ref Id: chemzdhcroadtozero)

Answer Yes if: Your facility has formally adopted and implemented the ZDHC Roadmap to Zero (or the Supplier to Zero) programme on sustainable chemical management and its impact areas or other chemical management related industry programs. 

Note: 

  • Adoption is the decision to use the ZDHC MRSL or other guidelines for your business, as evident by changes in company’s internal and external policies and its communication 
  • Implementation means steps are taken (beyond adoption) to put these decisions into action. Implementation could be, but is not limited to: training, change in purchasing / manufacturing practices to align with the programme, or adopting and monitoring metrics to track compliance with the policy.

If you select Yes, you will be asked the following sub question(s) to indicate which programs your facility has adopted and are implementing:

  • ZDHC Manufacturing Restricted Substances List (MRSL) & InCheck Solutions
  • ZDHC Wastewater Guidelines (for Leather & Textile) (WWG) & ClearStream report
  • ZDHC Chemical Management System (CMS) Framework & Technical Industry Guide & Supplier to Zero Certificate
  • ZDHC Man-Made Cellulosic Fibres (MMCF) Certificate (MMCF ONLY) / ZDHC MMCF Guidelines
  • ZDHC Air Emissions Guideline
  • ZDHC Waste Guidelines
  • Other
    • If Other, please specify.

Suggested Uploads: 

  • Documentation that demonstrates the facility has adopted and is implementing the selected programs (e.g., company policies/procedures showing commitment to and alignment with program requirements, adoption/use of program MRSL or positive lists). 

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they have adopted AND implemented procedures to align with the ZDHC Roadmap to Zero (or Supplier to Zero) programme, or any similar initiatives, to improve sustainable chemical management and address related environmental and health impacts within their operations.

Technical Guidance:

The adoption of industry programs such as the ZDHC Roadmap to Zero (or the Supplier to Zero) programme provide a framework and resources for facilities to focus efforts on sustainable chemical management and reducing hazardous chemicals in the supply chain. This also facilitates further industry collaboration efforts to improve sustainability performance in the industry and reduce impacts to human health and the environment. 

Adoption refers to the decision made by a facility to integrate the ZDHC Roadmap to Zero programme or other similar guidelines into its business operations, as demonstrated by incorporating the program guidelines and requirements into the facility’s internal policies and practices, and any relevant external policies and communication (e.g., chemical purchasing policy, CMS/EMS procedures, training of staff, communication with stakeholders, etc.)   

Implementation goes beyond adoption where facilities need to demonstrate that they are taking concrete actions to implement practices that align with the program guidance and requirements.  Such actions can include, but are not limited to, modifications in chemical procurement practices, staff training and capacity building, and the establishment of systems to monitor and ensure compliance with the program requirements. 

Resources:

The ZDHC Roadmap to Zero (or the Supplier to Zero) programme are initiatives aimed at promoting sustainable chemical management practices within the textile and footwear industry, with a focus on eliminating hazardous chemicals in production processes. 

Chemzdhcroadtozero Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have formally adopted and implemented one (1) or more of the programs listed in the sub question. 

Documentation Required:

  • Documentation that demonstrates the facility has adopted and is implementing the selected program(s). This may include:
    • Company policies/procedures showing commitment to the programme (e.g., chemical purchasing policy).
    • Demonstrated adoption/use of ZDHC MRSL or ZDHC Gateway- Chemical Module where applicable (e.g., chemical purchasing records, access to positive lists/databases)
    • Training records on policies/procedures related to program adoption.
    • Records of capacity building for staff on technical competencies needed to manage chemical programs in accordance with the adopted programs.

Interview Questions to Ask:

  • Staff responsible for program adoption are knowledgeable on the programme requirements and can explain the facility’s procedures for aligning with the program and how implementation/compliance with the program is monitored. 

Inspection - Things to Physically Look For:

  • Observations on site are consistent with the facility’s policies and procedures in place to align with the adopted program(s).

Partial Points: N/A

Chemtransparency

29. Do you have a transparency policy or procedure in which you share information regarding chemical products, chemical waste, and wastewater with stakeholders (For example: with ZDHC, chemical formulators, brands/retailers, authorities, NGOs)?  (Ref ID: chemtransparency )

Answer Yes if: Your facility has a documented transparency policy or procedure in place and you share information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders. 

Suggested Uploads:

  • Copy of the facility’s transparency policy
  • Examples of documented communications with stakeholders (email, report submittal, etc.)

What is the intent of the question? 

The intent of the question is for facilities to demonstrate they have a transparency policy in place and are actively communicating information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders. 

Technical Guidance:

Having a documented transparency policy or procedure demonstrates a facility’s commitment to openness, collaboration, and accountability in addressing environmental and health impacts associated with chemical management in their operations. 

A transparency policy should focus on sharing relevant information with specific groups of stakeholders such as customers, industry associations, local government, NGOs and supply chain partners. The transparency policy should include, but is not limited to: 

  • A list of stakeholders that the facility communicates with. 
  • The type of documents and information shared with each type of stakeholder. 
  • Frequency of sharing the documents and information 
  • Process of sharing 

The list below provides some examples of the information that may be shared with relevant stakeholders as part of a transparency program. 

  • Chemical Formulators and Raw Material Suppliers: 
    • MRSL/ Sustainable chemistry requirements 
    • SDS requirements
    • Chemical Management Policy
    • Specification for chemical compliance and quality requirements
  • Authorities/Local Government: 
    • Wastewater test reports
    • Permit renewals 
    • ETP design
  • Brands/Retailers/Industry Groups: 
    • Wastewater test report (e.g., ZDHC ClearStream)
    • Chemical Management Policy
    • Chemical/hazardous waste data 
    • Permit renewals 
  • NGOs: 
    • Corporate sustainability report
    • Proof of participation in industry program (e.g., ZDHC)

Resources:

Chemtransparency Verification And Scoring

How This Will Be Verified:

Full Points: 

Documentation Required:

  • Documentation that shows the facility has a documented transparency policy or procedure in place and they have shared information regarding chemical products, chemical waste, and/or wastewater with relevant stakeholders. This may include:
    • The facility’s transparency policy/procedure.
    • A list of stakeholders the facility communicates with.
    • Examples of documented communications with stakeholders (email, report/information submittals, etc.)

Interview Questions to Ask:

  • Staff responsible for the facility’s transparency policy and communicating to stakeholders can explain the facility’s transparency policy and how information is communicated to stakeholders.

Inspection - Things to Physically Look For: 

  • Observations indicate the information provided in the transparency policy and any stakeholder communications is accurate and relevant to the facility’s operations. 

Partial Points: N/A

Chemcollabalternatives

30. Does your facility collaborate with brands and/or chemical suppliers to select chemicals for alternatives assessment? (Ref Id: chemcollabalternatives)

Answer Yes If: Your facility has collaborated with brands and/or chemical suppliers to nominate and assess chemicals used in the manufacturing process for alternatives assessment and has established the following:

  • A list of prioritized chemicals used in production processes and proposed alternatives that was developed through a transparent, science-based approach that evaluates chemicals and/or chemical products.
  • A documented process for collaboration with brands or chemical suppliers regarding chemical alternatives, substances of concern.

Notes:

  • This assessment must cover chemicals/substances that are not already restricted through regulation. 
  • If your facility does not actively participate in identifying and assessing chemicals/substances of concern and/or alternative chemicals, you should answer No to this question.  

If you select Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads:

  • Prioritized list of substances of concern and alternatives for chemicals in use at the facility
  • Records from collaborative meetings between facility, brand customers, and/or chemical suppliers regarding alternative chemicals (e.g., meeting minutes)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have an established process in place to collaborate with brands and/or chemical suppliers to identify and assess chemical alternatives for chemicals used in the manufacturing process. 

Technical Guidance:

It’s critical that value chain partners work together to identify substances of concern and evaluate less hazardous alternatives. 

An alternative assessment for chemicals is a process to minimise chemicals of concern while considering performance and economic viability through identifying, comparing and selecting safer alternatives. A primary goal of an alternatives assessment is to reduce risk to property, humans and the environment by identifying less hazardous materials.

A chemical alternatives assessment may be used to prioritise replacement of hazardous chemicals or chemical products. To avoid regrettable substitutions, a thorough assessment of the proposed alternative should follow a transparent, science-based, simple and reasonable system that evaluates chemicals and/or chemical products.

Collaboration to identify and develop alternatives can take various forms which may consist of formal processes to:

  • Identify hazards associated with chemicals and/or substances of concern currently in use.
  • Identify alternatives (e.g., public database/internet searches or collaborative meetings to identify alternative chemicals and suppliers) 
  • Compare alternatives including potential changes required to production processes (e.g., technical/hazard review, pilot testing, etc.)

Resources:

Chemcollabalternatives Verification And Scoring

How This Will Be Verified: 

Full Points:

Documentation Required:

  • Documentation that demonstrates the facility has collaborated with brands and/or chemical suppliers to nominate and assess chemicals used in the manufacturing process for alternatives assessment. This must include:
    • A list of prioritized chemicals used in production processes and proposed alternatives that was developed through a transparent, science-based approach that evaluates chemicals and/or chemical products.
    • A documented process for collaboration with brands or chemical suppliers regarding chemical alternatives, substances of concern.
  • Records from collaborative meetings between facility, brand customers, and/or chemical suppliers regarding alternative chemicals (e.g., meeting minutes)

Interview Questions to Ask:

  • Staff responsible for evaluating alternatives can describe the facility’s process to collaborate with stakeholders to identify and assess chemicals or substances of concerns and alternatives.

Inspection - Things to Physically Look For:

  • Observations on site are consistent with the facility’s reported work to identify and assess alternatives (e.g., the facility’s priority list of hazardous chemicals or substances of concern is  consistent with chemicals used in production processes at the facility). 

Partial Points: N/A

Chemanalysishumanenv

31. Does your facility contribute to a chemical analysis against human and environmental hazard criteria (e.g., persistent, bio-accumulative, and toxic) for selecting alternative processes?  (Ref Id: chemanalysishumanenv)

Answer Yes if: Your facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria and have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.   

Answer Partial Yes if: Your facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria, but do not have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.    

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation. 

Suggested Uploads:

  • Hazardous chemicals risk assessment report such as a Screened Chemistry or Cradle2Cradle assessment report for chemicals in use and/or proposed alternatives. 
  • Evidence the facility has evaluated chemicals used in manufacturing and their alternatives against established human health and environmental hazard criteria.
  • Prioritized list of chemical substitutions based on the hazard assessment. 

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they actively participate in the alternative assessment process by conducting or contributing to a chemical hazard assessment that evaluates human and environmental hazards.

Technical Guidance:

For this question in the FEM, the alternative assessment/selection process refers to an evaluation of human health and environmental hazards and risks of chemicals in use or proposed as alternatives to ensure all hazards/risks are fully evaluated to avoid chemical substitutions that could result in unintended risk or impacts. This should be done to prioritize action to reduce, substitute or ultimately phase out hazardous chemical use.

This level of evaluation requires specific technical expertise to ensure all risks (e.g., hazards and exposure potentials) are appropriately identified and evaluated using systematic approach. This should include consideration of all intrinsically hazardous properties and risks (e.g., persistent, bio-accumulative, and toxic (PBT); very persistent and very bio-accumulative (vPvB); carcinogenic, mutagenic, and toxic for reproduction (CMR); endocrine disruptors (ED), etc.)  

Benefits of conducting a systematic hazard/risk assessment include:

  • The approach can be used to assess and compare alternatives to an incumbent chemical substance. The goal is to identify alternative chemicals that are inherently less hazardous, thereby preventing substitutions that may increase risk to human health and the environment.
  • The approach can be adapted and input into information technology tools, making it possible to screen a large number of chemicals in a relatively short period of time, and providing guidance for more comprehensive profiling of chemicals and materials.
  • The approach can readily be adaptable to multiple industry sectors and provides a science-based approach to evaluating chemical hazards so that less hazardous alternatives may be identified.

Resources:

Chemanalysishumanenv Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria and have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.  

Documentation Required:

  • Documentation that demonstrates the facility has conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria. This may include: 
    • Hazardous chemicals risk assessment report such as a Screened Chemistry or Cradle2Cradle assessment report for chemicals in use and/or proposed alternatives. 
    • Evidence the facility has evaluated chemicals used in manufacturing and their alternatives against established human health and environmental hazard criteria.
    • If applicable, a prioritized list of chemical substitutions/actions based on the hazard assessment. 

Interview Questions to Ask:

  • Staff involved in the chemical hazard assessment process can describe how the facility evaluates human health and environmental hazards and risks of chemicals in use or proposed as alternatives to ensure all hazards/risks are fully evaluated to avoid chemical substitutions that could result in unintended risk or impacts. 

Inspection - Things to Physically Look For:

  • Observations on site are consistent with the facility’s reported work to identify and assess alternatives (e.g., the facility’s hazard assessment is consistent with chemicals used in production processes at the facility). 

Partial Points:

  • Partial points will be awarded to facilities that have conducted or contributed to an assessment of chemicals used in manufacturing processes and alternatives against established human health and environmental hazard criteria, but do not have documented prioritized actions to switch to alternative chemicals to reduce human health and environmental hazards.   

Chemanalysislifecycle

32. Does your facility contribute to an analysis of lifecycle impacts for selecting alternative processes?  (Ref ID: chemanalysislifecycle)

Answer Yes if: Your facility has evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on all of the following aspects:

  • Water usage
  • Energy usage
  • Waste generation/disposal
  • Wastewater generation and quality
  • Resource depletion
  • Air emissions
  • Human health hazards

Answer Partial Yes if: Your facility has evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on some, but not all of the following aspects:

  • Water usage
  • Energy usage
  • Waste generation/disposal
  • Wastewater generation and quality
  • Resource depletion
  • Air emissions
  • Human health hazards

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads:

  • Evidence the facility has evaluated chemicals used in manufacturing and their alternatives to determine life cycle impacts in addition to chemical hazard and risk.
    • Lifecycle studies or other third-party assessments.
  • bluesign Xpert assessment.
  • Documented metrics for water, energy, waste, etc.
  • MFCA (Material Flow Cost Accounting).

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they have evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives. 

Technical Guidance:

Facilities should strive to optimize chemical use and manufacturing processes to minimize all environmental impacts associated with production (e.g., energy and water consumption, waste generation, wastewater quality, etc). An example would be choosing a different dyestuff or recipe that results in reduced water or energy consumption during a dyeing process. The efficiency of a manufacturing process can be highly dependent on the optimization chemical use along with the manufacturing equipment/process. The optimization of these elements can generate significant benefits by reducing the amount of chemicals used, reducing resource consumption, and waste associated with the process and therefore reducing the life cycle impacts of the system.

A life cycle assessment (LCA) is a systematic approach to evaluate the environmental footprint of a product. This evaluation goes beyond just assessing chemical hazards and risk and is a more comprehensive approach to sustainability which looks at the life cycle impacts within and beyond the facility.  LCAs should be conducted by qualified individuals in accordance with a recognized LCA framework such as ISO14040:2006.  

Resources:

Chemanalysislifecycle Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on all of the following aspects:

  • Water usage
  • Energy usage
  • Waste generation/disposal
  • Wastewater generation and quality
  • Resource depletion
  • Air emissions
  • Human health hazards

Documentation Required:

  • Documentation that shows the facility has evaluated chemicals used in manufacturing and their alternatives to determine life cycle impacts in addition to chemical hazard and risk. This may include:
    • Lifecycle studies or other third-party assessments.
  • bluesign Xpert Assessment.
  • Documented metrics for water, energy, waste, etc.
  • MFCA (Material Flow Cost Accounting).

Interview Questions to Ask:

  • Staff responsible for managing the assessment process can describe how the facility tracks and evaluates life cycle impacts of chemicals used in manufacturing processes and proposed alternatives.

Inspection - Things to Physically Look For:

  • Observations on site are consistent with the facility’s reported work to identify and assess the life cycle impacts of chemicals in use and alternatives (e.g., the facility’s life cycle impact assessment is consistent with chemicals used in production processes at the facility). 

Partial Points:

  • Partial points will be awarded to facilities that evaluated the environmental life cycle impacts (other than chemical hazards/risk) of chemicals used in manufacturing processes and alternatives and this includes impacts of replacing chemicals in your factory on some, but not all of the following aspects:
  • Water usage
  • Energy usage
  • Waste generation/disposal
  • Wastewater generation and quality
  • Resource depletion
  • Air emissions
  • Human health hazards

Chemcontractorsr

33. Does your contractor(s)/subcontractor(s)/upstream supplier(s) source already approved or preferred chemicals from a positive list to replace chemicals not already included in RSL?  (Ref ID: chemcontractorsr)

Answer Yes if: Your facility has a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements. 

Answer Partial Yes if:  Your facility has a documented policy/ agreement in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements, however you are unsure or cannot demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements. 

Notes: 

  • Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).
  • Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or Restricted Substance Lists with your contractor(s)/subcontractor(s)/upstream supplier(s)?
  • Please upload documentation.

Suggested Upload: 

  • Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. 
    • List of contractors, subcontractors, and upstream suppliers. 
    • Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence).  
    • Higg FEM verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
    • Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers. 
    • Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.  
    • Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or RSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a process or plan is in place to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists that go beyond RSL requirements.

Technical Guidance:

Facilities should proactively engage with their supply chain partners (i.e., contractors and upstream suppliers) to require the use of chemicals that are less hazardous and reduce impacts to human health and the environment. This can be done by requiring contractors and upstream suppliers to source chemicals from recognized positive lists (e.g., ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3) or bluesign FINDER, etc.)

Facilities should work with contractors and upstream suppliers to understand the chemicals used at their facilities with the goal of identifying and prioritizing hazardous chemicals for substitution that are not already regulated by legislation or existing RSL with a focus on reducing risk as much as possible. For example, if a facility is currently following an industry or brand specific RSL, the facility can also proactively search to identify and require the phase out of hazardous chemicals not listed in the RSL by using available databases or other sources of information on safer alternative chemistry (e.g., ZDHC Gateway- Chemical Module, ECHA SVHC List, ChemSec SIN list). 

It is also important to ensure that these expectations and requirements are clearly communicated with contractors and upstream suppliers. For example, facilities may include requirements to restrict chemicals and/or source from positive lists in the terms and conditions of contractual agreements. 

Resources:

Note:  Some resources provided below may include reference to legal requirements that may not apply to your facility. Facilities are expected to comply with applicable legal requirements related to chemicals management.

Chemcontractorsr Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond restricted substances list (RSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream supplier replacing chemicals with approved or preferred chemicals from a positive list that is not already included in RSL requirements. 

Documentation Required:

  • Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. This may include: 
    • List of contractors, subcontractors, and upstream suppliers that the facility engages with.
    • Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence)  
    • Higg FEM verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
    • Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers. 
    • Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.  
    • Records of chemical substitution at contractors, subcontractors, and upstream suppliers, if applicable.
    • Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or RSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

Interview Questions to Ask:

  • Staff responsible for engaging with contractors, subcontractors, and upstream suppliers can explain the facilities procedures or plan to require suppliers to source chemicals from positive lists.  

Inspection - Things to Physically Look For:

  • Where applicable, observations onsite indicate that the facility has, or is planning to engage with contractors, subcontractors, and upstream suppliers (e.g., observed supplier/contractor material or activities is consistent with the facility’s reported list of suppliers/contractors and type of engagement.) 

Partial Points:

  • Partial points will be awarded to facilities that have a documented policy/agreement  in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that goes beyond RSL requirements. 

Chemcontractorsm

34. Does your contractor(s)/subcontractor(s)/upstream supplier(s) source already approved or preferred chemicals from a positive list to replace chemicals not already included in MRSL? (Ref Id: chemcontractorsm)

Answer Yes if: Your facility has a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond manufacturing restricted substances list (MRSL) requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements. 

Answer Partial Yes if:  Your facility has a documented policy/agreement in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements, however you are unsure or cannot demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream suppliers replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements. 

Notes: 

  • Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).
  • Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or Manufacturing Restricted Substance Lists with your contractor(s)/subcontractor(s)/upstream supplier(s)?
  • Please upload documentation.

Suggested Upload: 

  • Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. 
    • List of contractors, subcontractors, and upstream suppliers. 
    • Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence).  
    • Higg verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
    • Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers. 
    • Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.  
    • Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or MRSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that a process or plan is in place to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists that go beyond MRSL requirements.

Technical Guidance:

Facilities should proactively engage with their supply chain partners (i.e., contractors and upstream suppliers) to require the use of chemicals that are less hazardous and reduce impacts to human health and the environment. This can be done by requiring contractors and upstream suppliers to source chemicals from recognized positive lists (e.g., ZDHC Gateway- Chemical Module(ZDHC MRSL Conformance Level 3) or bluesign FINDER, etc.)

Facilities should work with contractors and upstream suppliers to understand the chemicals used at their facilities with the goal of identifying and prioritizing hazardous chemicals for substitution that are not already regulated by legislation or existing MRSL with a focus on reducing risk as much as possible. For example, if a facility is currently following an industry or brand specific MRSL, the facility can also proactively search to identify and require the phase out of other hazardous chemicals not listed in the MRSL by using available databases or other sources of information on safer alternative chemistry (e.g., ZDHC Gateway- Chemical Module, ZDHC MRSL Candidate List, ECHA SVHC List, ChemSec SIN list). 

It is also important to ensure that these expectations and requirements are clearly communicated with contractors and upstream suppliers. For example, facilities may include requirements to restrict chemicals and/or source from positive lists in the terms and conditions of contractual agreements. 

Resources:

Note:  Some resources provided below may include reference to legal requirements that may not apply to your facility. Facilities are expected to comply with applicable legal requirements related to chemicals management.

Chemcontractorsm Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have a system in place that requires contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements and can demonstrate that this engagement has resulted in one (1) or more contractor/subcontractor or upstream supplier replacing chemicals with approved or preferred chemicals from a positive list that is not already included in MRSL requirements.  

Documentation Required:

  • Documentation that shows engagement or plan to engage with contractors, subcontractors, and upstream suppliers to require chemicals to be sourced from positive lists. This may include: 
    • List of contractors, subcontractors, and upstream suppliers that the facility engages with.
    • Communications/agreements with the contractors, subcontractors, and upstream suppliers requiring the practice of sourcing chemicals from positive lists (e.g., contractual, requirements, purchasing agreements, email correspondence)  
    • Higg verification report from contractors, subcontractors, and upstream suppliers showing that they are sourcing chemicals from positive lists.
    • Records of alternative chemical trials or piloting with contractors, subcontractors, and upstream suppliers. 
    • Positive lists and/or list of chemicals prioritized for substitution provided to contractors, subcontractors, and upstream suppliers.  
    • Records of chemical substitution at contractors, subcontractors, and upstream suppliers, if applicable.
    • Implementation plan to reduce the use of hazardous chemicals beyond chemicals specified by regulations and/or MRSL with your contractors, subcontractors, and upstream suppliers that requires the use of positive lists.

Interview Questions to Ask:

  • Staff responsible for engaging with contractors, subcontractors, and upstream suppliers can explain the facilities procedures or plan to require suppliers to source chemicals from positive lists.  

Inspection - Things to Physically Look For:

  • Where applicable, observations onsite indicate that the facility has, or is planning to engage with contractors, subcontractors, and upstream suppliers (e.g., observed supplier/contractor material or activities is consistent with the facilities reported list of suppliers/contractors and type of engagement.) 

Partial Points:

  • Partial points will be awarded to facilities that have a documented policy/agreement in place that will require contractors/subcontractors and upstream suppliers to source chemicals from positive lists that go beyond MRSL requirements. 

 

 

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