VERSION 1.0 MARKS & SPENCER MARCH 2013 ECP MODULE 6: APEO (ALKYLPHENOL ETHOXYLATES) VERSION 1.0 MARCH 2013

Transcription

1 ECP MODULE 6: APEO (ALKYLPHENOL ETHOXYLATES) VERSION 1.0 MARCH 2013 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING

2 MODULE CONTENT 1. Introduction What are alkylphenol ethoxylates? What are their uses? REASONS FOR ELIMINATION ELIMINATION TRHOUGH CHEMICAL MANAGEMENT General Process chemicals Non-process chemicals (machine cleaning, general cleaning products etc.) Substrate to be processed Incoming water APEO MANAGEMENT PROTOCOL APEO - SOURCES OF CONTAMINATION SUPPLIER AND M&S OBLIGATIONS Wet Processing Unit Obligations (including Due Diligence testing) Product Supplier Obligations M&S Obligations... 9 MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 2 of 9

3 1. INTRODUCTION What are alkylphenol ethoxylates? Alkylphenol ethoxylates (APEOs) are the product of an industrial process known as ethoxylation, where nonylphenol (NP) or octylphenol (OP) are treated with ethylene oxide to give nonylphenol ethoxylates (NPEO) and octylphenol ethoxylates (OPEO). About 90% of APEOs used in the textile and leather industry are NPEOs What are their uses? APEOs are non-ionic surfactants which have several uses in the textile and leather industries. They can be found in many preparations, including detergents, emulsifiers, dispersing agents and spinning lubricants. They can be found at practically every stage of textile and leather processing. 2. REASONS FOR ELIMINATION APEOs degrade only partially during wastewater treatment, reverting to the more toxic OP and particularly NP. NP is very persistent in the environment, and does not degrade readily. NP is known to mimic the hormone oestrogen, and is therefore described as a hormone (endocrine) disrupter. It is also very toxic to aquatic organisms. Therefore it is essential to eliminate APEOs from process wastewater and the final product. APEOs in industrial wastewater will be a persistent contaminant with potentially serious effects on aquatic life and the human drinking water supply. Although the greatest risk of APEO exposure is from industrial effluent, it is possible that fabric and garments may contain residual concentrations of APEO, especially if the wet processing facility is poorly managed. It is a condition of business that any wet processing facility supplying M&S eliminates APEO from production and ensure they are compliant with all aspects of the ECP standards and RSL. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 3 of 9

4 3. ELIMINATION THROUGH CHEMICAL MANAGEMENT General APEOs are man-made and not naturally-occurring chemicals, and therefore, in theory, should only be present in wastewater or on the finished product through deliberate use. In certain locations, however, because of unrestricted historical use, there will be background levels of APEO in the environment. This local background presence should not be used as an excuse to relax usage restrictions. The only way to limit their presence to this base level is to employ a policy of no deliberate use. The following actions will limit the presence of APEO in wastewater to the base environmental level. (Please refer to the chart in Section 4 for a detailed management protocol) Process chemicals Source dyes and processing auxiliary chemicals from suppliers who can give a written declaration that the products they supply to you do not contain APEO as intentional ingredients. The following suppliers, for example, will provide the necessary declaration: Dystar, Huntsman, Clariant, CHT-Bezema, Rudolf, Magna and BASF. Products based on alcohol ethoxylates provide effective alternatives to those containing APEOs. There is an EU restriction under REACH on using preparations containing NPEO and OPEO on textiles if the quantity in the preparation exceeds 0.1% (1000 ppm). It is possible, therefore, that the processing preparation could contain up to this amount of APEO. Best Practice Do not rely on the Material Safety Data Sheet for indication of the presence of APEO. The chemical may be entered under a synonym or a CAS number, which may not be obvious immediately. Check with the supplier if in doubt. Do not rely on agents for the APEO content information. The details must be obtained directly from the dye or chemical manufacturer. If intending to use chemicals from a source which has not made a written declaration as to APEO content, insist on a test report from the supplier before using the product. If necessary, have the product tested independently. If the product contains more than the 1000ppm EU limit, do not use it. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 4 of 9

5 3.1.3 Non-process chemicals (machine cleaning, general cleaning products etc.) APEOs may be present in machine cleaning preparations, and in general industrial and domestic products used for cleaning areas such as kitchens, washrooms, dormitories, floors, ceilings etc. This is a usage over which the production unit has direct control. It is essential that there is complete and documented transparency from the suppliers of cleaning chemicals regarding their APEO content. Obtain a written declaration that there is no intentional APEO content in the products. It may be suggested that the APEO content of some products will have little effect on the overall APEO content of the wastewater. However, to eliminate the risk, no deliberate use should mean just that Substrate to be processed The use of APEO is widespread throughout the textile and leather industries. It is therefore possible that a previously-treated substrate delivered to the wet processor for further treatment may contain APEO. Any APEO present may be removed from the substrate and appear in the processor s effluent. Ensure that your suppliers are aware of the M&S RSL, and in particular the ban on deliberate use of APEOs. Obtain a written declaration that the substrate does not contain APEO. If the supplier cannot provide this, have the substrate tested. Do not process a substrate without this declaration. Reject the substrate if there is APEO present. You will be held responsible if you supply fabric or products to M&S that contain APEOs as a result of treatments further upstream in the supply chain Incoming water Depending on the location, APEO may be present in the water supply to be used for processing. Although the site has no control over this, it needs to know of this presence and the quantity involved, as APEO content at this stage may provide a background presence for processing. If there is a quantity of APEO in the incoming water, this must be used as a base level which must not be increased by wet processing operations. Obtain monthly test reports from the supplier. If the site is responsible for its own supply (abstraction from river, borehole etc.), then the supply should be tested independently. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 5 of 9

6 4. APEO MANAGEMENT PROTOCOL SOURCE OF CONTAMINATION Processing chemical (all dyes, pigments and auxiliaries e.g detergents, deguming dispersing agents, lubricants etc.) ACTION RISK TEST PROTOCOL RECORDS TO BE KEPT Declaration 1. Obtain a written declaration from the supplier of each product supplied by them to you is free from APEO. 2. Obtain a new declaration annually from each supplier. 3. Obtain the declaration directly from the supplier, and not through an agent. 4. If the supplier cannot provide this for any reason, change to a supplier who can provide a declaration. Testing 1. Insist that the supplier tests the product and provides an independent test report. 2. If you have an independent test report from the supplier, carry out due diligence testing on every 10th delivery of each product. 3. If you do not have an independent test report from the supplier, carry out testing according to the Test Protocol. HIGH Test the first delivery of the product. If compliant (<1000ppm), test every 4 th delivery of that product. If not compliant (>1000ppm), do not use the product. 1. Annual declaration of compliance from all suppliers covering all products used. 2. Results of independent testing. Each batch of substrate to be processed, whether from an external source or from another site within the company Declaration 1. Obtain a written declaration from the supplier that the substrate they have supplied to you is free from APEO. 2. Obtain a written declaration for each substrate before the season commences. 3. If there is a change of substrate during the season, obtain a declaration before production commences. 4. If the supplier cannot provide this for any reason, investigate the possibility of changing to an alternative supplier who can provide a declaration. Testing 1. Insist that the supplier tests the substrate and provides an independent test report. 2. If you have an independent test report from the supplier, carry out due diligence testing on every 10 th delivery of the substrate. 3. If you do not have an independent test report from the supplier, carry out testing according to the Test Protocol. HIGH Test the first delivery of the substrate. If compliant (not detected), test every 4 th delivery of that substrate. If not compliant (>100ppm), do not process the substrate. 1. Annual declaration of compliance from all suppliers covering all products used. 2. Results of independent testing. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 6 of 9

7 SOURCE OF CONTAMINATION Cleaning products, including machine cleaners and all industrial and household products used on site ACTION RISK TEST PROTOCOL Declaration 1. Obtain a written declaration from the supplier of each product supplied by them to you is free from APEO. 2. Obtain a new declaration annually from each supplier 3. Obtain the declaration directly from the supplier, and not through an agent 4. If the supplier cannot provide this for any reason, change to a supplier who can provide a declaration Testing 1. Insist that the supplier tests the product and provides an independent test report. 2. If you have an independent test report from the supplier, carry out due diligence testing on every 10th delivery of each product. 3. If you do not have an independent test report from the supplier, carry out testing according to the Test Protocol. MEDIUM Test the first delivery of the product. If compliant (<1000ppm), test every 4 th delivery of that product. If not compliant (>1000ppm), do not use the product. RECORDS TO BE KEPT 1. Annual declaration of compliance from all suppliers covering all products used. 2. Results of independent testing. Incoming water 1. Obtain monthly test reports from the water supplier to give a quantitative analysis of APEO. 2. If the supplier cannot provide this for any reason, have the water tested independently. 3. If using own supply, carry out monthly analysis. MEDIUM / LOW Carry out a test each month. This test is to establish background levels of APEO. Monthly results of quantitative analysis from either the water supplier or independent test house. TEST METHOD Depending on the condition of the sample to be tested (water, effluent, preparation, substrate etc) the laboratory will determine the appropriate method to use. The extraction solvents used are either flammable or toxic, and these tests are only available from laboratories with analytical facilities. Provided the test house methods can extract 100% APEO with a detection level equal to or better than 0.05% (50ppm), the method is acceptable. Specify that the Limit of Detection required is 50ppm, and the Reporting Limit is 100ppm. The test house must have their in-house methods listed in the ISO Accreditation Schedule and the Accrediting organisation must have mutual recognition with UKAS. Submit samples in non-pvc containers or wrapping, as contamination with either PVC or phthalates may interfere with APEO determination. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 7 of 9

8 5. APEO - SOURCES OF CONTAMINATION Dyes and Chemicals Incoming Water Substrate to be processed Dyeing and Finishing Process Cleaning Products Effluent treatment To Our Environment MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 8 of 9

9 6. SUPPLIER AND M&S OBLIGATIONS Wet Processing Unit Obligations The wet processor will have a valid ECP registration number. The wet processor will comply with the ECP requirement of following the M&S policy of no deliberate use of APEO. The wet processor will inform suppliers of dyes, chemicals and substrates of the M&S policy, and obtain letters of compliance for all materials used. The wet processor will carry out internal due diligence testing of materials used, according to the testing protocol in Section Product Supplier Obligations The product supplier will ensure that they are using wet processing facilities registered with a valid ECP number. To be valid, they need to confirm adherence to the ECP RSL and the ban on deliberate use of APEO. The supplier will communicate M&S policy of the non deliberate use of APEO to their upstream suppliers. Non-compliance with the M&S ECP requirements, including the RSL and APEO policy, could result in removal of the supplier from the M&S supply base, and return of any contaminated product M&S Obligations M&S will support the policy through due diligence testing and factory audits. This will involve monthly product testing and regular factory audit visits. MODULE 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 9 of 9