NimkarTek accepted as ZDHC MRSL Version 2.0 certifier – Level 1 and Level 2

On 24th April, 2020, ZDHC announced NimkarTek Technical Services as an approved certifier to the ZDHC MRSL V 2.0 for Level 2 Conformance.

Chemical Suppliers can now get their products certified by NimkarTek and their Chemical formulations can be registered and listed on the ZDHC Gateway:Chemical Module – Level 2

Today, consumers are more aware of the pollution caused by the Textile Industry and are demanding proof that manufacturing units are using cleaner production techniques and cleaner chemicals. With this growing consumer demands on chemical compliance, more and more Brands and their manufacturers are moving towards the use of Cleaner chemicals. The ZDHC MRSL is a fantastic Chemical Management Industry tool that helps identify Suppliers and manufacturers of Cleaner chemicals. Chemicals conforming to the ZDHC MRSL ensure that along with finished articles, the factory waste water and sludge is also free from hazardous chemicals.

Since its inception in 2015, ZDHC works with existing companies and standards to ensure that chemicals conform to the ZDHC MRSL. NimkarTek has been actively promoting Chemical Management through our services of Analytical Testing, Training and Consultancy.

Anagha Nimkar, Director at NimkarTek, commented: “we are delighted to have received this recognition from ZDHC. NimkarTek’s Chemical Management Training, Testing and Consultancy services are trusted by global Brands and Retailers for many years. NimkarTek is an accepted Certifier for ZDHC MRSL V 2.0 Level 1 since Dec 2017. With this latest Level 2 approval by ZDHC, our program can support several current and new clients to develop better chemical management practices. We are committed to helping chemical manufacturers achieve ZDHC Conformance for their products.”


NimkarTek is a company offering world-class ecological services to the Textile and Apparel Industry in the form of Training, Testing and Chemical Management Consultancy Services. Our experts have over 30+ years experience, having worked with over 40 Brands across USA, Europe, UK and Australia. NimkarTek is an approved Certifier for ZDHC MRSL – Chemical Gateway : Level 1 and Level 2 Conformance indicator.

Contact NimkarTek experts for more information on ZDHC MRSL Level 1 and Level 2 accreditations. Call us on +91 9819641527 to speak to us or email us at

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666 was here

Who was here

दृश्यमाने भवेत् प्रीतिः सौहृदं नास्त्यदृश्यतः

666 WAS HERE :/

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Scivera and NimkarTek Pioneer New Screening and Scoring Process for Commodity Chemicals in the Global Apparel Supply Chain

IMG_3290MUMBAI (INDIA); CHARLOTTESVILLE (USA) (January 22, 2020) Global chemicals management software provider, Scivera, and international analytical chemistry lab, NimkarTek Technical Services Pvt Ltd., today announced a new Safer Commodity Screening program, featuring a pioneering methodology for screening, scoring, and tracking commodity chemicals in the global apparel supply chain.

Commodity chemicals are produced in bulk for industrial use and account for 80 percent of process chemicals by volume used in the apparel supply chain. These chemicals include sodium chloride (salt), acetic acid, sodium hydroxide, and citric acid, among others. Commodity chemicals are used at every step of wet processing, including bleaching, dyeing, and finishing. After use, commodity chemicals are treated and discharged directly into wastewater. Some commodity chemicals are supplied in pure form, directly from manufacturers. Others are supplied to the textile industry, through traders, as byproducts from other industries, such as pharmaceutical, biotech, or agro-chem products. Historically, customary testing and screening methods have proven ineffective for commodity chemicals due to high costs. As a result, companies have had limited visibility into potential contaminants from upstream processes that could lead to downstream environmental impacts. Safer Commodity Screening changes this paradigm.

Scivera and NimkarTek work with leading apparel and footwear brands and their diverse supplier networks on chemical management and sustainable chemistry programs. On commodity chemicals, Levi Strauss & Co. (LS&Co.) engaged Scivera and NimkarTek to develop and implement a scalable solution on textile process commodity chemicals. Safer Commodity Screening is comprised of NimkarTek’s IN-SCREEN process and Scivera’s cloud-based software platform, SciveraLENS®. IN-SCREEN is a cost-effective, qualitative, analytical screening program for testing the full range of commodity chemicals used in the textile, footwear, and apparel industries. It provides quick and reliable review of commodity chemical samples, thereby offering an unprecedented ability to identify substances restricted for use by the Zero Discharge of Hazardous Chemicals (ZDHC) Programme or impurities that may originate from other industries.

Scivera configured their SciveraLENS platform to create SciveraLENS Safer Commodities to provide brands and manufacturing facilities with a low-cost, scalable method to register, track, score, and compare commodity chemical screening results. Scivera’s flagship software product, SciveraLENS Rapid Screen, has been used for years by LS&Co. and other brands and their specialty chemical suppliers to support the scale-up of the Screened Chemistry program for textile auxiliary and dye formulations. SciveraLENS Rapid Screen also enables efficient exploration of safer alternative chemicals and reduces the cost of chemical management business processes for brands and suppliers in diverse consumer product categories including electronics, toys, cosmetics, and household items.

Safer Commodity Screening enables the efficient screening, scoring, and tracking of this critical part of textile chemical throughput at dyehouses, mills, and laundries. The innovative combination of SciveraLENS Safer Commodities and IN-SCREEN makes commodity chemical management and improvement accessible to all participants in the apparel and footwear supply chain. Factories and traders can consult scores and trends to make informed commodity chemical purchasing and use decisions ⎼ and to phase out use of poorly performing commodities. This much-needed transparency will make a significant contribution toward safer, more transparent, more sustainable chemical supply chains.

LS&Co. will establish Safer Commodity Screening as a requirement for all relevant manufacturing suppliers and work with NimkarTek and Scivera to scale the program across its supplier base in 2020. NimkarTek and Scivera are also supporting the expansion of the program to other brands in 2020.

For more information about the program, please visit

About NimkarTek:
NimkarTek is a Training, Testing, and Consultancy company providing world-class solutions to the Textile, Leather and Chemical supply chain in the areas of Restricted Substances and Chemical Management.

NimkarTek Media Contact:
Anagha Nimkar
NimkarTek Technical Services Private Limited

About Scivera:
Founded in 2008, Scivera is recognized as an innovator and leader in making the identification and replacement of hazardous chemicals in products simple, fast, and cost-effective. The company has built the most comprehensive resource for Chemical Hazard Assessments (CHA) verified by its board-certified toxicologists, with over 2,000 verified CHAs and tens of thousands of additional CHAs available to subscribers. This information is made available to subscribers worldwide through the innovative cloud-based app, SciveraLENS® Rapid Screen, bringing scalable, data-driven, chemicals management and safer alternatives exploration to all participants in the global consumer products supply chain.

Scivera Media Contact:
Betsy Murry
Scivera LLC
+1 (703) 483 1547

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MODINT Joins Forces with NimkarTek !

MODINT Joins Forces with NimkarTek !

NimkarTek is pleased to announce its collaboration with Modint, the Dutch Association for Fashion.

To lead the Dutch textile industry towards cleaner textile supply chain and reduce the usage of hazardous chemicals with safer alternatives, MODINT, The Dutch National Trade Association for Fashion has joined forces with NimkarTek, for providing Online training to Modint Members and suppliers. This co-operation will combine the expertise of NimkarTek and Dutch Textile Industry’s vision to lead it towards training their suppliers to produce safer products.

NimkarTek will provide online training to the MODINT members and their supply chain partners through its online training platform ‘NOTES.’ The co-operation will be limited exclusively to Modint members in The Netherlands and their supply chain stakeholders in any other country.

Under this co-operation NimkarTek will offer special prices of training modules to Modint members and a trouble-free access and helpdesk to resolve any problems faced by registered users from Modint group.

To know more about this co-operation or for any other questions please contact Anagha Nimkar on

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NimkarTek’s Chemical Compliance Workshop Series

NimkarTek has introduced a range of basic, intermediate and advanced workshops that will focus on restricted substances, chemical management, SDS authoring, REACH registrations and testing requirements for the Indian textiles and chemical industry.

As the sustainability sphere continues to evolve at a rapid pace it is crucial that those practising in the Textile and Chemicals industry take the necessary steps to enhance their knowledge, skillsets, and learn how to effectively apply this toeveryday business scenarios.

This is why NimkarTek’s chain of workshops are both relevant and refreshing. Our experienced team is committed to helping Brands and Retailers, Textile mills, colorant and auxiliary manufacturers and the chemical industry understand these changing requirements on restrictions and chemical compliance in a relaxed and encouraging environment. The workshops are planned on every alternate Friday and will be delivered by an industry professional, with the sole aim of imparting key updates, insightful tips and practical techniques.

The first NimkarTek’s workshop on’ ZDHC MRSL and its Impact’ was held on the 10th of March, in the NimkarTek office at Mumbai. It was led by Mr Prasad Pant, CEO,= NimkarTek and Mr UlLhas Nimkar, CMD, NimkarTek. The agenda of the workshop was:

  1. he ZDHC Initiative and Goals
  2. The ZDHC MRSL formats, terms and criteria
  3. The 16 MRSL Chemical Groups
  4. Actions to meet the ZDHC MRSL criteria – developing positive lists

After the training session, the workshop was followed by a tour of NimkarTek’s ecological testing laboratory and the brand new Eco-tox Lab.

The workshop was attended by 10 industry personnel. All the participants were extremely. pleased with the practical learnings that were delivered through the training sessions.

FUTURE WORKSHOPS: for future workshop details, please contact us on or call us on +91-9769313590. As limited spaces are available it is recommended you book your seat today.

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Zeroing in on the Zero Discharge of Hazardous Chemicals

Zeroing in on the Zero Discharge of Hazardous Chemicals

The background of Zero Discharge:

In 2011-12, the global NGO Greenpeace rocked the foundations of the Apparel Industry with a sustained campaign called ‘Detox Now! that targeted the uninhibited pollution caused by the discharge of hazardous chemicals into rivers and other water bodies by textile mills around the world. The trail from these dyeing & finishing factories led to global apparel and footwear Brands who, for many years, have professed to ensure environmental and consumer protection in their policies and manufacturing practices.

Greenpeace went a step further and demonstrated – by actually testing garments from the Brands’ Stores – that apparel imported and sold in shops in the EU, contained chemicals that are hazardous to human health and can be discharged from these articles into EU Rivers through simple home laundering!

The Detox campaign made several Brands sit up and take a re-look at the chemical usage across their supply chain. The result was the ZDHC Initiative – a coming together of like-minded Brands & Retailers (as well as other stakeholders) to lead the apparel & footwear industry towards the goal of zero discharge of hazardous chemicals across all pathways by the year 2020.

The ZDHC Impact:

There is no doubt in anyone’s mind that the ZDHC Commitment is an onerous task – akin to scaling the Mount Everest! This is mainly due to the fact that maximum use and discharge of chemicals happens at Tier 2 level of the supply chain (dyeing/finishing mills, laundries, tanneries and printers) – segments which is out of a Brand’s area of control and influence!

Over the past 4 years, the Signatory Brands of the ZDHC Commitment have made a steady progress towards the ZDHC goal. A Joint Roadmap (Version 1 and 2) was published, regular meetings with Signatory Brand representatives and external stakeholders (NimkarTek was included in some of these meetings!) were held, empowered ‘Workstreams’ were nominated to carry out specific tasks, Benchmarking Studies at select factories in several countries were conducted and several Progress Reports and Program Documents uploaded on the website ( for easy access and information to the suppliers of the ZDHC Signatory Brands. The membership to the ZDHC has also increased from the initial 6 members to 21 Signatory Brands and 7 Associate Members.

After 4 years of sustained efforts, the ZDHC has published a Roadmap in late 2015 that has declared five major thrust areas to achieve their goals by 2020:

  1. Implementation and Update of the Manufacturing Restricted Substances List (MRSL)
  2. An Environmental Audit Protocol to assess environmental as well as chemical management compliance systems in a facility
  3. Training and Education of the supply chain in chemical management modules
  4. Chemical Hazard Assessment to add the next list of chemicals of concern and engage with stakeholders to find safer alternatives
  5. Disclosure procedures and platforms to introduce transparency

Are we having the right focus?

Although these efforts are commendable, the real question is: Have these efforts made an impact on the ground? I wonder if any supplier fabric mill or garment laundry of a Brand has been actually declared (with measured facts) to have achieved or even progressed close to the Zero Discharge of hazardous chemicals across all pathways? Or are we simply obscuring our target by looking at too many things and loosing focus?

In the ancient Indian epic The Mahabharata, there is a story that the archery teacher of the young princes under his tutelage sets up a wooden bird on the branch of a tree and asks each prince to shoot an arrow into the eye of this wooden bird. Before a prince picks up his bow and arrow, the teacher asks him the question “What do you see, O Prince?” The princes give varied answers stating that they see a lot of things from the sky, the tree, a house to the grass. The teacher restrains each prince from shooting, till he calls up Arjuna, the best student of the lot, and asks him the question. Arjuna replies “I only see the eye of the bird and nothing else”! It is then that the teacher says, “Shoot, O Prince!” and Arjuna hits the bulls eye – the eye of the bird!

Like Prince Arjuna, a Brand committed to Detox should also completely focus on the eye of the bird, which is: achieving zero discharge of hazardous chemicals across all pathways in the supply chains of the Signatory Brands by 2020.

What a Brand really needs to do………. Zeroing in on Zero Discharge:

Achieving the Zero Discharge goal will require a focused approach so that the outcome is a supplier facility (or facilities) who can actually demonstrate having achieved zero discharge across all pathways i.e., finished articles, wastewater, sludge and air, alongwith measurable data.

It is now obvious that there is really no ZERO. Hence, we must define what we mean by Zero Discharge of Hazardous Chemicals before we start. Some criteria that can be agreed upon are:

  • Concentration of the 11 Priority Chemicals (PCs) in discharged Effluent < Priority Chemicals in Influent at the facility
  • Limit Values/Detection Limits in treated effluent and sludge established by a Brand’s MRSL or as per applicable test method are met
  • Discharge of hazardous chemicals to air within the facility is controlled through proper safety precautions for worker protection
  • Residues of hazardous chemicals in finished articles produced by the facility meet the RSL Limit Values of the Brand

At NimkarTek, we have prepared an 8- step focused approach that can help a Brand to achieve the Zero Discharge goal at their suppliers. The time-frame to achieve this at a target facility is estimated to be 12 months.

The 8 steps are:

  1. Form an Internal Working Group with members drawn from Sustainability, Quality, and Sourcing teams at HQ as well as from Regional/ Local offices. Train all the members of the Working Group on all aspects of ZDHC so that all members come on board with equal commitment. The objectives of this Working Group are to:

✓ Set up a Program Framework
✓ Define responsibilities, meeting schedules, review mechanisms & milestones for this Program framework
✓ Map supply chain across all tiers for all product lines for location, tier position, facility information, organization structure, level of business done, level of influence, importance to the Brand’s business and ability of the supplier to commit to the goal of ZDHC
✓ Select and prioritize the suppliers (after mapping) to roll-out a pilot with set milestones and assign responsibilities to the members of the Working Group
✓ Communicate with the pilot suppliers and get their commitment to achieve Zero Discharge (as defined before)

  1. Train and educate the suppliers in the pilot roll-out on all aspects of Zero Discharge such as The ZDHC Initiative, The ZDHC Priority Chemical Groups, Restricted Substances (RSL and MRSL), Understanding MSDS, Fundamentals of wastewater management and testing requirements for finished articles and wastewater. The training should set out EXPECTATIONS and MEASURE THE IMPACT of the training, once completed. The key employees to be trained at each Tier level must be identified and involved in the training program.

NimkarTek offers the solution to this step through its online training platform ‘NOTES

  1. Implementation of a basic chemical management framework at the facility to help achieve the goal of ZDHC. This framework should include:

✓ Formation of a Chemical Management Team with defined roles and responsibilities
✓ Screening of input chemicals for conformance to Brand MRSL through Supplier Declarations, study of MSDS and a “Smart Screening” technique
✓ Testing Plan to monitor Priority Chemicals in input chemicals, finished articles and wastewater
✓ Purchasing policies to ensure MRSL compliance
✓ Worker safety to hazardous chemicals at the workplace

NimkarTek offers an online chemical management implementation tool “CMS-i” for this step

  1. Phase out and substitute MRSL non-compliant chemicals identified from the chemical management practices implemented in Step 3. It is important that the ‘rogue’ chemicals are substituted with compliant chemical formulations (or a change of supplier), evaluated thoroughly on finished product prior to bulk implementation and regularly monitored for MRSL compliance. This should be done over a 2- month period before going onto the next step. Any new chemical required during this phase should be thoroughly screened for MRSL compliance prior to usage in bulk production.
  2. Testing of representative finished article for MRSL analytes: Once we are confident that the entire chemical inventory is MRSL compliant, we monitor the discharge to finished articles by sampling articles that are representative of all substrates, processes and chemicals used in the facility. The aim is to see if any of the 11 Priority Chemical Groups are detected in these articles. In case any restricted analyte is detected, a Root Cause Analysis needs to be done to identify the cause and implement corrective/preventive action. This exercise is repeated till it is confidently established that no residues of the Priority Chemicals are detected in finished articles produced in the facility.
  3. Testing of inlet water, wastewater and sludge: It is then that we start looking at discharges to wastewater and sludge. For this, the Inlet water should be tested (over a period of time) to establish background concentration. Sampling of wastewater before and after treatment is also done and tested regularly over a time-period. These results are analyzed and any detection of restricted analytes is subjected to a Root Cause Analysis to eliminate at source.
  4. Re-evaluation of Wastewater and sludge is then done, once the above exercise is completed. The Step 6 may be repeated in case MRSL analytes are detected in treated wastewater samples. All measurements related to these exercises must be stored in a database so that the data can be available for scrutiny and the project is made transparent.
  5. Regular monitoring of wastewater and sludge: If the results in Step 7 show that the MRSL analyates are not detected in the discharged wastewater and sludge, we need to test the facility’s wastewater and sludge on a periodic basis for the next 2 months to confirm compliance with the Limit Values/Detection Limits published in the Brand’s MRSL or are much below the background concentrations.

NimkarTek can offer its expertise in implementation of Steps 4 to 8.

What are the next steps?

Having completed such a pilot project over a period of 12-15 months at select facilities in their supply chain, the Brand can then collate the learnings made during the pilot to fine-tune the approach and scale-up to other facilities in their supply chain on a global basis.

The list of suppliers who have achieved Zero Discharge, alongwith measured data and learnings, can be reported for disclosure on the Brand’s website or on public disclosure platforms.


The Zero Discharge of Hazardous Chemicals goal is a Herculean task. It will be possible only through a focused approach to zero- in on target facilities and implement a holistic 8 -step approach to achieve the limits for unintentional residues of the Priority Chemical Groups in finished articles, wastewater and sludge.

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Environmental Risks of Dyes Used in Textile Processing

In a recent audit of a textile facility for chemical management systems, I found that the Safety Data Sheets (SDS) of some dyestuffs used at the facility did not contain any information on ecotoxicological parameters. Many dyes were vaguely classified as ‘irritant’ and ‘harmful’ under Hazard Identification (Section 2). Some were classified as ‘non-hazardous’ in spite of lack of any ecotoxicological data!

Not many dye manufacturers are fully conversant with the classification ‘dangerous to the environment’. The SDS of many dyes simply does not provide much information in Sections 11 and 12, which pertain to toxicological and ecological parameters. Specific precautionary measures for the discharge of unfixed dyes into wastewater are thus not adopted at textile processing mills, except decolourisation of the effluent.


A comprehensive hazard assessment should include ecotoxicological data on the following parameters:

  1. Acute toxicity to aquatic organisms: Acute toxicity is defined as the ability of a chemical to cause adverse impact on an organism ‘relatively soon’ after a single oral dose. Aquatic toxicity is tested on three species – fish, daphnia and algae – and expressed as LC50, EC50 and IC50 values in mg/L respectively. (LC stands for Lethal Dose; EC stands for Effective Concentration and IC stands for Inhibitory Concentration. The LC50, EC50 and IC50 values represent dosages of a chemical which causes death or inhibition in 50% of test specimens)
  2. Biodegradation: This is of two types: (a) Ready biodegradability– which is a measure of a substance to degrade on its own and (b) Inherent biodegradability – which is a measure of a substance to degrade under specific external conditions (such as in an ETP). For dyes, the term ‘Bioelimination’ is also used, which means removal of a substance from an aqueous solution by adsorption on activated sludge.
  3. Bioaccumulation or Bioconcentration: Is a measure of the increase in concentration of a substance in fat tissues of an organism (and thus up the food chain) over time.
  4. Chronic or long term toxicity: Is the ability of a chemical to cause toxic effects if an organism is exposed to it on a prolonged basis.
  5. Solubility: Is the ability of the dye to dissolve completely in water. (Some dyes, such as Disperse dyes, do not dissolve but get dispersed in water). If the solubility in water is high, bioaccumulation is not expected.

The major determining factors for environmental hazard assessment of water-soluble dyes are aquatic toxicity and biodegradability. Water Soluble Dyes, in general, do not readily biodegrade in standard tests and hence aquatic toxicity (LC50, EC50 and IC50 values) assumes great importance for environmental hazard assessment of a dyestuff.

Environmental hazards – which are measured primarily as impact on aquatic life – are classified as per the Globally Harmonized System (GHS) into:

  1. Very toxic to aquatic life (H 400)
  2. Toxic to aquatic life (H 401)
  3. Harmful to aquatic life (H 402)
  4. Very toxic to aquatic life with long lasting effects (H 410)
  5. Toxic to aquatic life with long lasting effects (H 411)
  6. Harmful to aquatic life with long lasting effects (H 412)
  7. May cause long lasting harmful effects to aquatic life (H 413)

Using data on aquatic toxicity and ready biodegradability values, the following guidelines can be used to classify a water-soluble dyestuff for environmental hazards:

Toxicity and biodegradability values H-Statements applicable Pictogram
Product has LC50, EC50 values < 1mg/L and is not readily biodegradable H- 400 (Very toxic to aquatic life)
H- 413 (May cause long lasting harmful effects to aquatic life)
Product has LC50, EC50 values < 1mg/L and is readily biodegradable H- 400 (Very toxic to aquatic life) post
Product has LC50, EC50 values < 10mg/L and is not readily biodegradable H -401 (Toxic to aquatic life)
H- 413 (May cause long lasting harmful effects to aquatic life)
Product has LC50, EC50 values < 10mg/L and is readily biodegradable H- 401 (Toxic to aquatic life) No pictogram required
Product has LC50, EC50 values < 100mg/L and is not readily biodegradable H- 402 (Harmful to aquatic life)
H- 413 (May cause long lasting harmful effects to aquatic life)
No pictogram required
Product has LC50, EC50 values < 100mg/L and is readily biodegradable H- 402 (Harmful to aquatic life) No pictogram required

For poorly water- soluble dyes (such as disperse dyes used to dye polyester),it is difficult to test the biodegradability at the concentrations recommended in the OECD biodegradability test methods. Hence, the bioaccumulative potential becomes critical due to their poor water solubility. This is measured in terms of the ‘Partition Coefficient’, that is, the tendency of a substance to dissolve preferentially in either water or n-octanol. N-Octanol is considered a surrogate for fat tissue. The Partition Coefficient is expressed as its logarithm (Log Po/w). If value of Log Po/w > 3, then the substance prefers to dissolve in n-octanol and has a potential to bioaccumulate.

Thus, for environmental hazard assessment of poorly water-soluble dyes, the following two parameters must be considered:

  1. Test data on the product or preparation itself OR
  2. Calculation method based on the concentration(s) of hazardous ingredient(s) in the dyestuff preparation


Classifying a dyestuff as an Environmental Hazard does not necessarily mean that it is an Environmental Risk. Risk is a function of hazard and exposure and if either of these factors is zero, then risk is also zero.

We must remember that dyes are intended to be fixed onto a substrate for coloration and the amounts entering the aquatic environment are much smaller than those used in the application process. The existence of an environmental risk – which is the amount of the dye that can cause harm in a water environment – needs to be calculated or measured.

A dye is estimated to be an environmental risk if its ‘Predicted Environmental Concentration’ (PEC) is greater than the ‘Predicted No- Effect Concentration’ (PNEC). For practical purposes, the PNEC is taken as the lowest of the aquatic toxicity values (LC50/EC50/IC50) divided by a factor of 1000.

For example, if a dyestuff has LC50 = 8 mg/l, EC50 = 100 mg/l and IC50 = 80 mg/l, then the PNEC of such a dyestuff = 8/1000 = 0.008 mg/l. If the concentration of this dyestuff (PEC) is found to be > 0.008 mg/ l, then it is termed an environmental risk to aquatic life.

Calculation of the PEC depends not only on aquatic toxicity values, but also the quantity of the dye used per day, Exhaustion/ Fixation of the dye on the substrate, Bioelimination percentage in the Effluent Treatment Plant and the Dilution Factor of the river body where the effluent is discharged.

Building on the above dyestuff example and assuming application data given in the below table on left hand side, the Environmental Risk of this dyestuff can be calculated as shown below in the right hand side column of below table:



It is important for dyestuff manufacturers to provide ecotoxicological data on their products or hazardous ingredients in the product and properly classify their products for Environmental Hazards. For water-soluble dyes, aquatic toxicity values and ready biodegradability are important factors, while for poorly water-soluble dyes, toxicity values and bioaccumulation potential are important.

Classifying a dyestuff as an Environmental Hazard does not necessarily mean that it is an Environmental Risk. The existence of an environmental risk needs to be calculated based on aquatic toxicity values, quantity of the dye used per day, Exhaustion/ Fixation of the dye on the substrate, Bioelimination in the Effluent Treatment Plant and the Dilution Factor of the river body where the effluent is discharged. Sometimes, it is seen that a dye labelled as “dangerous to the environment” may pose a lower RISK than that presented by a dye not labelled as dangerous to the environment!

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Are MRSLs the panacea for Detox?

The background of the ‘Detox’ campaign:
In 2011- 12, the global NGO Greenpeace rocked the Apparel Industry with a sustained campaign called ‘Detox Now!’ that targeted the uninhibited pollution caused by the discharge of hazardous chemicals into rivers and other water bodies by textile mills around the world. The trail from these dyeing & finishing factories led to global apparel and footwear Brands who, for many years, have professed to ensure environmental and consumer protection in their policies and manufacturing practices.

Greenpeace went a step further and demonstrated – by actually testing garments from the Brands’ Stores – that apparel, imported and sold in their shops in the EU, contained chemicals that are hazardous to human health and can be discharged from these articles into EU rivers through simple home laundering!

The campaign made several Brands take a re-look at the chemical usage across their supply chain. The result was the ZDHC (Zero Discharge of Hazardous Chemicals) Initiative – a coming together of like- minded Brands & Retailers (as well as other stakeholders) to lead the apparel & footwear industry towards the goal of zero discharge of hazardous chemicals across all pathways by the year 2020.

After 4 years of sustained efforts, the ZDHC has published a Manufacturing Restricted Substances List (MRSL v 1.1), that is, a list of substances banned from intentional use in chemical formulations used in manufacturing facilities. The idea is to shift the focus from ‘end- of –pipe’ (that is restricting hazardous substances in finished articles through RSLs) to eliminating them in input chemicals.
The idea stems from the premise that “clean inputs = clean outputs”.


While shifting the spotlight to input chemical management, the ZDHC MRSL acknowledges the possibility of ‘unintentional contaminations’ or ‘impurities’ or ‘uncontrolled residues’ of these hazardous substances creeping into the chemical formulations, either from their manufacturing process or from starting raw materials used to make a formulation.

To counter this, a Maximum Concentration Limit Value has been prescribed for each substance within a chemical formulation. It is expected that ‘responsible’ chemical manufacturers will be able to consistently conform to these concentration limit values, thereby ensuring that the discharge of such substances into products, wastewater and sludge will be as close to ‘Zero’ as possible.
For example, a chemical manufacturer should not only not kuse NPEOs intentionally but also ensure that each batch of the formulation should not exceed 500 ppm (limit given in the MRSL) of unintentional NPEO contamination in that formulation.
Will the MRSL provide a harmonized approach to Brands’ chemical restriction requirements?
There has been a persistent demand from suppliers to harmonize the Restricted Substances Lists (RSLs) of different Brands, which are currently extremely competitive and diverse in terms of limit values on final product as well as the list of analytes. The intent of the ZDHC MRSL is to provide this harmonized approach to managing chemicals during the processing of raw materials within the apparel and footwear supply chain.

But a study of the MRSLs issued by some Brands/Retailers belies this intent. The H&M, Esprit, Nike, Lululemon Atheletica and Inditex MRSL is different from the ZDHC MRSL in that it only stipulates a ‘Usage Ban’ for the list of substances, without any limits for unintentional contaminations. The Benetton, Puma, Aldi, Coop, Valentino and Mango MRSL stipulate limits for wastewater and/or sludge discharge. Some Brands have adopted the ZDHC MRSL, but made additions or deletions in the analytes or changes in the limit values for unintentional contaminations (Levi Strauss, Burberry). The New Balance MRSL simply segregates chemicals into two groups: those that can be easily substituted with more environment friendly ones and those that are not technically feasible to be eliminated yet, but should be controlled to minimize exposure to workers, environment and consumers.

Is the MRSL the solution for Detox?
The MRSL is definitely an effort to focus on clean inputs, while trying to incorporate the challenge of cross- contaminations. But this approach does raise several questions:

  1. Do chemical manufacturers know about unintentional contaminations that may occur during the synthesis process or can come from input raw materials sourced by them? This is extremely difficult for a manufacturer to monitor. The unintentional contamination is, well, unintentional and there will be no system in place to identify or monitor these at ppm level!
  2. Can formulators guarantee conformance to the MRSL limits in every batch manufactured? In a project that NimkarTek is currently doing at a yarn dope dyeing factory, COC (Chlorinated Organic Carrier) contamination of 1 to 4 ppm is being detected in the dyed polyester yarn. The source of this COC has been identified as contamination in certain pigment masterbatches used in the dyeing process. However, the masterbatch supplier has simply refused to give any guarantee for COC contamination, citing that there is no system for them to test each and every batch of the pigments used and declare it as COC –free.
  3. How does a material supplier (dyehouses) ensure that the declaration of conformance obtained from a chemical supplier to the MRSL is authentic? Most Brands insist that the MRSL should be communicated to chemical suppliers and a Conformance Declaration obtained. Only such ‘Positive List’ of chemicals are recommended to be used in the factory. But what is the authenticity of such self- declarations? If there any system to verify that there are no contaminations exceeding the MRSL limit in these Positive Lists? I know that many European chemical manufacturers source a lot of raw materials from China and India and it is unlikely that they are testing every batch of these raw materials for MRSL compliance!
  4. Is the MRSL understood by local chemical manufacturers, who cater to 85% of market requirements, or is it a commitment by a few multinational (global) chemical suppliers who have only 15% market share? Awareness about MRSL analytes is quite low in the ‘chemical hub’ of the world, that is China and India. These analytes (such as APEOs or Phthalates) are not regulated and hence there is no restriction for its manufacture and use in the textile industry. Training and awareness needs to be done to educate these chemical manufacturers.
  5. Are test methods standardized and correct standards of the restricted substances available for testing these contaminations in chemicals? Test methods for restricted substances in textile products are well established and corroborated amongst global testing laboratories. This is not the case with chemicals. Testing of formulations is a challenge, especially those that are in emulsion form. The ZDHC MRSL does not specify ISO or DIN or EN test methods (except for some groups), but only general techniques of analyzing chemicals using equipment such as GC-MS or LC-MS. Thus, test results are not as per standard methods and may vary from lab to lab. Also, do we have enough competent laboratory testing capabilities all over the world? Without these capacities, it would be difficult to scale up MRSL implementation through the supply chain.
  6. Do the MRSL limits for contaminations corroborate with limits in finished products or the limits for wastewater? The restricted substances contaminations from chemical formulations will be either transferred to products or wastewater. The MRSL threshold limits in input chemicals are much higher than the RSL limits on end- product as chemical formulations are highly concentrated and diluted before application on the textile substrate. But has it been confirmed that a limit of 1000 ppm for 1,2 dichlorobenzene in a chemical formulation will meet the limit of 1 ppm in finished article? Or the limit of 500 ppm APEO in a washing agent will meet the wastewater detection limit of 1g/L (when it is known that almost 95% of the APEO- based chemical will be washed out in the effluent!)?
  7. Can the MRSL requirements be met immediately by chemical manufacturers? Complying with the MRSL limits will require investments in testing infrastructure and product stewardship by chemical manufacturing units, especially the small and medium capacity manufacturers. This might mean higher cost of end-products. Substitution of ingredients in a chemical formulation is also a time-consuming process since performance parameters also need to be matched.

The ZDHC Initiative is indeed a welcome step to tackle the issue of chemical management since this Herculean task will need collaboration across the industry stakeholders. The MRSL is a good concept that focuses on input chemical management rather than end-of-pipe. The idea to eliminate hazardous substances in input chemicals rather than only managing them in finished goods will also lead to cleaner production with respect to worker health & safety and environmental impact mitigation of the manufacturing process.

However, implementation of the MRSL has its challenges. It is not a panacea for Detox as the supply chain stakeholders, especially fabric dyeing and printing mills, will have to implement comprehensive systems for chemical management to achieve the goal of Detox. Chemical suppliers will need to take up a far greater responsibility of product stewardship and invest in testing capabilities in order to meet the demands of unintentional contaminations in the MRSL. Root cause analysis for MRSL failures will have to be undertaken and modification of process synthesis and raw materials will have to be incorporated for MRSL non- compliant formulations.

Moreover, a sustained and continuous training and capacity –building program will need to be implemented by Brands across all tiers of their supply chain to create awareness about MRSL, ZDHC and Chemical Management topics. Only such capacity- building will result in a positive change to move towards the goal of Zero Discharge of Hazardous Chemicals across all pathways. NimkarTek has designed a unique online training platform ‘NOTES’ to deliver such trainings quickly and effectively across all tiers of the supply chain and across different geographical areas and languages, by leveraging the web.

Lastly, the Brands and Retailers committed to the Detox goal should start engaging with chemical manufacturers – especially the local ones in China, India and other producing countries, or with their associations– to spread the message of the MRSL and understand their difficulties and challenges in meeting the MRSL requirements.


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Managing Chemical Risks in Your Supply Chain

Why should we manage chemical risks?

Supply chain management is now not only about deliveries, lead times, logistics, optimisation, stock replenishments and prices, but also managing possible chemical risks that may surface in the product or a production process.

In a report by Frost and Sullivan on Chemical & Material Practices, one of the Megatrends identified for companies to focus on (besides functionality, low carbon economy and globalization) is ‘Health and Wellness’. (Megatrends are long-term global transformational processes and arise at the interplay between what is happening to us as individuals and changes happening to the world at large). There is a growing trend of Consumers wanting companies to be ‘transparent’, that is, provide more information on what is in a product and how ethically it has been made. “Being Green” is the new mantra for apparel brands to make a cutting- edge differentiation in today’s competitive market.

Our world is rapidly changing. There has been more information produced in the last 30 years than in the last 5000 years. The internet has revolutionised the way we work, travel and connect with people. The world of chemicals is also changing fast with new new toxicological findings. What was used freely till yesterday is identified as a Substance of Very High Concern (SVHC) – based on its toxicological study – and its usage is banned or restricted. Developing countries are recognising that chemical- intensive products and the negative impacts of their production processes is reaching alarming levels and are tightening the regulations and pollution norms. Keeping up with global regulations such as REACH, CPSIA and GB Standards will be an enormous challenge for Brands and their supply chains. NGO and Social Media campaigns about chemical ‘transgressions’ by responsible Brands can make or break a Brand’s corporate reputation. The recent ‘Detox Now!’ campaign by Greenpeace to highlight hazardous chemicals used and discharged in the supply chains and products of several global apparel brands is a case in point!

There are 4 main reasons that companies manage chemical risks:

  1. Brand & Reputation enhancement: Several global apparel brands have built a reputation of ensuring consumer safety by ensuring conformance in their supply chains to chemical restrictions through their ‘Restricted Substances Standards’, which was a list of substances subject to a usage ban for production of their articles. Minimising chemical risks enhances a Brand’s image and its reputation.
  2. Gaining a competitive edge: In order to differentiate their product offerings, some Brands have built-in the principles of sustainability in their Business Strategy. ‘Eco’ or ‘Green’ or ‘Organic’ are the new buzz words that help to drive up consumer trust in products against other competition
  3. Innovation: Some Brands have used sustainability and chemical compliance as a tool for innovation. Patagonia’s “Because denim if filthy business” or Levis’ Water
  4. Saving costs: Managing chemical risks can – many times- drive down costs since using ‘green’ or ‘bio’ chemicals can help to reduce costs of effluent treatment as well as resources such as water and energy that go into making a product. Use of enzymes to replace hazardous chemicals in bleaching and finishing of garments are increasing due to this fact.

How can Brands manage chemical risks?

Brands can adopt the “SEAM” Approach to manage chemical risks in their supply chains. SEAM stands for:

Set-Up Program



Measure & Monitor

  1. Set-Up Program: A Brand can set- up a ‘Working Group’, with defined responsibilities, that drives the commitment to manage chemical risks. The Working Group should define the Program Scope, timelines, milestones and budgets. An important aspect is to map the supply chain and document vendor data such as organization structure, volume of business, level of influence, long- term relationship, vendor capabilities, geographical locations, type of product sourced, etc. It is important that there is a ‘Buy-in’ to the program by all stakeholders involved.
  2. Evaluate: This step involves evaluation all tiers of the supply chain with respect to their understanding of chemical compliance issues, internal purchasing practices, risk assessment of their chemical inventory, oversight of their upstream suppliers, chemical storage & handling practices and waste management. This information will help to identify the gaps in your supply chain chemical management readiness and plan actions to ‘plug’ them.
  3. Actualize: This involves implementing actions to ‘plug’ the identified gaps. It will require training of vendors on chemical management topics, building competencies at each supply chain level for chemical management, implementing control measures for identified chemical risks at upstream suppliers, phase- out and substitution of ‘risky’ chemicals at supplier facilities and screening input chemicals and raw materials used in the Brand’s products through Supplier Declarations and random testing.
  4. Measure and Monitor: This can be done through due diligence testing of finished products and of discharges/ emissions to water and air, regular review of chemical documentation and planning corrective actions for continuous improvements. A digital platform to record and share chemical management data across the tiers of a supply chain can be designed and implemented to monitor real-time progress and compliance.

A holistic approach of input chemical management, process controls and output controls at supplier facilities will be required to ensure that chemical risks are reduced and finally eliminated from all levels of the supply chain.

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CMS-i — A Path Towards Implementation of Chemical Management Systems

In today’s world, textile factories are under increasing pressure – from governments, Brands and NGOs – to use safe and sustainable chemicals so as to minimize the impact on human health, worker and the environment. In order to conform to these requirements, implementation of chemical management systems at textile production factories such as dye-house, garment laundry, fabric mill and printer needs to be carried out

In reality, implementing safe chemical management practices in globally dispersed textile manufacturing facilities is a herculean task which might take months of training, audits, preparing procedures and finally implementing these systems and then monitoring it for the seamlessness. To ease the process and roll it out to a large number of facilities, NimkarTek has developed an on-line implementation tool called CMS-i for Chemical Management Systems implementation at Dyehouses, fabric mills and Garment washing units. Here in CMS-i, “I” stands for instructions for systems implementation and to map the improvements made by the user facility. This tool can also be used by Brands to know the current status of chemical management systems at a vendor/supplier and the improvements made by using this tool. Thus Brands can map their supplier facilities in terms of ‘Good or Satisfactory or Not satisfactory’.


This tool is based on the premise of Self- improvement by a user facility. A User facility can log into the CMS-i (Chemical Management System – implementation) on-line platform and go through the stages mentioned below:

  • Basic Information of the facility: This contains details about the facility in terms of its operations, substrates and processes.
  • Pre-Assessment Form: This is an electronic questionnaire containing Key Performance Indicators (KPIs) on various aspects of chemical management. The user facility has to assess each KPI in terms of “Yes”, “Yes- Partial” or “No” based on its current state of knowledge and competency. In some cases, facility should upload the required documents related to the KPI.
  • Pre –assessment Summary Report and Opportunities for Improvement (OFIs): Based on the pre-assessment inputs, a summary report – along with the recommended best practice required on certain KPIs will be generated to initiate actions at the user facility.
  • CMS Implementation: This is the key step in chemical management in three Stages. NimkarTek provide ‘guideline documents’ in the form of word or excel files on key areas of chemical management. The user facility should read, understand and implement certain systems on the basis of these guidelines. Wherever required an on-line support is provided by NimkarTek to help facility lead towards CMS implementation during implementation stages.
  • Re-Assessment Form: Once the implementation of guidelines in the 3 stages is complete, the user facility can proceed for Re-assessment which is similar to Pre-assessment. However, the user facility is asked to upload certain documents on the basis of implementation and actions taken in certain KPIs. A comparison matrix of Pre and Re-assessment is automatically generated and mailed to the user facility.

At a Glance:

The CMS-i is:

  • A tool to provide guidelines on chemical management systems
  • A framework of readymade forms and formats to document data on chemical management at a facility
  • A starting point of engagement between internal stakeholders of a facility and its buyers and suppliers of chemicals and raw materials

The CMS-i is not:

  • Just a self-assessment tool
  • A compliance tool
  • A vendor evaluation tool
  • A tool to screen chemicals
  • A certification process

CMS- provides implementation Guideline Documents on:

  • Chemical Management Team – Roles & Responsibilities.
  • Chemical Management Manual.
  • Purchasing practices for chemical conformance.
  • Local and global regulatory requirements for chemical conformance.
  • Risk assessment of chemical inventory & control measures.
  • Declarations of conformance to RSL/MRSLs from chemical and raw material suppliers.
  • Testing protocol for raw materials, finished products and wastewater to monitor RSLs.
  • Communication of hazards through labeling of chemical containers.
  • Internal audits for chemical management systems.
  • MIS reporting on chemical management actions.

For more information on the CMS-i tool please write to

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The Business Case for Water Conservation


The textile processing and finishing industry is water –intensive and peans have been sung for its conservation due to rapidly declining ground water and fresh water resources. The challenges of non-availability of water of the desired quality are likely to be more acute in countries experiencing rapid economic growth.

But it has always been a challenge to build a Business Case to conserve water in textile production, mainly because of the low cost of water. In fact, in some producing countries, water is treated as a ‘free’ or ‘under-priced’ resource. Due to this, water is used indiscriminately and inefficiently in textile production. There is no monetary incentive to conserve it. In fact, many times, the investment cost required to conserve water is much higher than the returns made in terms of cost benefit.

Since industry focuses on maximizing production and profits, it is imperative to build a business case to conserve water for monetary benefits.


Water in a textile processing facility serves the same purpose as blood in the human body. There are three typical uses of water in textile production:

  1. As a mode of application or transport
  2. As a carrier of chemicals and waste
  3. As a receptor/disseminator of energy

If a typical “Water Circuit” is drawn for a textile plant, it would look like the chart below:

During this entire circuit, water undergoes transformation in terms of addition of energy, chemicals or waste to it. The cost of water is thus not only that of the raw water that is made available at the beginning of this circuit, but also the resources- that is energy and chemicals – added to it at every stage of the circuit. The total cost of this water- energy- chemicals nexus should be used to build a business case for water conservation. Ascertaining the cost of water as a summation of (water + electricity+ heat + chemicals+ waste) helps in identifying the ‘hotspots’ where this cost is of a high value. Such hotspots can then be used to identify opportunities to improve efficiencies and thus reduce costs.


From the time ‘cheap’ raw water is made available to a factory, it is subjected to addition of resources that increases the cost of water as it progresses through the factory:

  1. ‘Free’ ground water needs to be pumped up, which adds electricity costs in kWh units consumed
  2. This raw water is not of the right quality in terms of Total Dissolved Solids, hardness, pH and other parameters and hence it is passed through a Softening Treatment plant, such as an Ion exchange plant or activated charcoal filter or RO membrane. This adds to electricity costs in kWh units, equipment fixed and running/ maintenance costs.
  3. A part of this input water is required in Boilers where it is heated to generate steam that is used in process operations. This means additional cost in terms of Kcal or MJ or kg steam and cost of chemicals added during boiler operations
  4. During process, water is required to be heated to high temperatures. For example, dyeing with reactive dyes is done at 80⁰C, soaping is done at 95⁰C and dyeing of polyester is done at 130⁰C. The energy cost for heating the water in terms of Kcal or KJ needs to be added to this.
  5. Chemicals added to water during process are either on a gram per litre basis or % of the substrate. A gram per litre approach will depend on the liquor ratio used in the process. If 1 kg of a substrate is bleached in a machine with a liquor ratio of 1:6, then the peroxide used in the bleaching process can be dosed at:

1 % , which means 10 Gms of peroxide must be dosed.

1gm/L, which means 1gm × 6 litres = 6 gms to be dose

1mL/L, which means 1(mL) × 1.2 (Sp. Gravity of peroxide) × 6 = 7.2 Gms dosage

Thus, cost of chemicals will vary depending on the quantity added in each process step, thereby resulting in increase in the total value of water.

  1. Untreated water coming out from the process carries waste and needs to be treated in an Effluent Treatment Plant (ETP). This will require adding to this wastewater the electricity costs of pumping into the ETP, chemical costs used in ETP for flocculation, biological treatment, reverse osmosis, etc and the fixed + running costs of the ETP equipment.

Thus, when we think of the cost of water, we should consider costs at every stage as follows:


Cost of water = (Cost of Raw water + Energy+ Chemicals+ Electricity + ETP costs) – (Cost of energy + chemicals recovered from process water)


Water serves as the bloodline for textile processing operations and yet it is used indiscriminately and inefficiently as it is an underpriced resource in producing countries.

To build a business case for water conservation as a monetary saving, we must look at water as carrier of resources such as electricity, steam and chemicals and of waste.

At every stage of the process, the total cost of water should be calculated to include the water- energy- electricity- chemical nexus and ‘hotspots’ identified for improving efficiencies and thereby reducing costs.

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Teflon’s Toxic Legacy

For more than half a century DuPont hid information that a chemical it was using to make Teflon might be making people sick.

Almost two decades ago, Carla Bartlett, a then 41-year -old West Virginia secretary and mother of two, was first diagnosed with cancer – what her surgeon later labeled a “garden variety” type of kidney cancer.

“I was scared to death,” Bartlett, now 59, told an Ohio federal jury this fall during hearings in the first of more than 3,500 personal injury and wrongful death suits by West Virginia and Ohio residents against the chemical giant DuPont. “And all I could think of was not being there, not being able to be there for my family.” Bartlett’s tumor and part of her rib were removed in a surgery in 1997 that, she said, involved cutting her “virtually in half.” Though the cancer hasn’t recurred since, for Bartlett, the harm, both physical and emotional, has lingered. “It’s never out of my mind, because you worry constantly about it,” she said. “And then I have the reminder of the scar, every day, that, you know, this… this is… this was cancer; this could come back.”

On October 7, after less than a day of deliberations, the jury found DuPont liable for Bartlett’s cancer, agreeing with the defendant that the company had for years negligently contaminated her drinking water supply in Tuppers Plain, Ohio with a toxic chemical formerly used to make its signature brand of nonstick coating: Teflon.

What makes the verdict remarkable is that unlike, say, mesothelioma – a form of lung cancer almost exclusively linked to asbestos exposure – the renal cell carcinoma that struck Bartlett is not usually considered the calling card of a specific carcinogen. So it was difficult for her doctors to definitively say what had first made Bartlett sick – it could have been virtually anything. The $1.6 million the jury awarded to Bartlett – the product of decades’ worth of legal battles that unearthed reams of secret DuPont studies and internal emails – came despite the extreme difficulty of connecting common ailments to a specific chemical under the current United States legal system.

Proving that DuPont was legally culpable for Bartlett’s kidney cancer required years of extraordinarily innovative lawyering – and at times some plain dumb luck. The very improbability of that verdict demonstrates much that is flawed about the way this country regulates potentially dangerous chemicals. With no mandatory safety testing for the vast majority of the tens of thousands of chemicals used daily in America, doctors and public health officials have little information to guide them as they seek to identify potential health hazards – including the chemical, called C8, that DuPont knowingly allowed to pollute Bartlett’s drinking water. Bartlett’s travails are also a cautionary tale about C8, which has become so pervasive today that it’s found in virtually every American’s blood.

A federal jury has found DuPont liable for Carla Bartlett’s kidney cancer.

“Part of a diagnosis is: Well, tell me what you’ve been around,” one of Bartlett’s attorneys, Mike Papantonio, told the jury in opening arguments in the case. “Well, I drank my water. That doesn’t sound like a problem. It was a problem”

Teflon was first created, as many miracle chemicals were, in a laboratory accident. In 1938, Roy J. Plunkett, a DuPont chemist, was experimenting with refrigerants when he discovered a white waxy material that seemed very slippery. The material turned out to be an inert fluorocarbon – Polytetrafluoroethylene (PTFE) – that had superior nonstick properties. In 1945, the company patented the chemical and registered it under the trademark “Teflon,” touting it as “the most slippery material in existence.” By 1948 DuPont was producing about 2 million pounds of Teflon a year at its Washington Works plant in Parkersburg, West Virginia. For DuPont, Teflon, which was used to coat pots and pans, proved to be a gold mine, with sales peaking at roughly a billion dollars a year in 2004, according to the company’s SEC filings.

Starting around 1951, DuPont began using another laboratory-formed chemical known as Perfluorooctanoic (PFOA) acid, or C8 (so called because it contains eight carbon molecules), to smooth out the lumpiness of freshly manufactured Teflon. An unusually durable chemical, C8 first entered the world in 1947 and due to its nonstick and stain-resistant properties its use as a “surfactant” spread with extraordinary speed. The white, powdery compound, often said to look like Tide laundry detergent, would ultimately be used in hundreds of products including fast food wrappers, waterproof clothing, electrical cables, and pizza boxes. (DuPont used to purchase C8 from another chemical company called 3M until 2002, when the company phased it out. DuPont then started manufacturing C8 on its own at a factory in Fayetteville, North Carolina.)


Buck Bailey, whose mother worked at the Teflon plant in Parkersburg, was born with just one nostril and other facial deformities.


all photos by Maddie McGarvey

The trouble was that the compound – which has since been linked to a variety of health risks including cancer, liver disease, developmental problems, and thyroid disease – escapes into the air easily. In fact, C8 was often shipped to factories pre-mixed with water to keep the dust from worker’s lungs.

Because it’s an extremely stable chemical, C8 does not biodegrade. Instead, it bioaccumulates, building up in people’s blood over time if they continue to drink water or breathe air laced with the substance. Due to its ubiquitous use, the chemical can now be found in trace amounts in the bloodstream of more than 98 percent of Americans, and even in umbilical cord blood and breast milk, according to the Centers for Disease Control. It’s also been found in the blood of seals, eagles, and dolphins around the world, including in animals living in a remote wildlife refuge in the middle of the North Pacific. The chemical is expected to stay in the environment for thousands of years.

Concerns about the hazards posed by Teflon and C8 began to garner public attention only about 15 years ago. By 2003, DuPont had dispersed almost 2.5 million pounds of C8 from its Washington Works plant into the mid-Ohio River Valley area, according to a peer-reviewed study. The company’s most egregious disposal practices occurred before US environmental laws were first written in the 1970s and included burying toxic waste in drums along the banks of the Ohio River and dropping barrels of it out into the open ocean (where it once caused a scandal when a local fisherman dredged a barrel up in his nets), and, in more recent decades, burying it in local “non-hazardous” landfills.

Now, information emerging from millions of pages of internal company reports reveals that several DuPont scientists and senior staff members had for many years either known, or at least suspected, that C8 was harmful. Yet DuPont continued to use the chemical, putting its own workers, local residents, and the American public at risk.

The documents show that signs of C8’s toxicity began to emerge very quickly as DuPont scaled up its Teflon production in the 1950s. The company funds its own safety-testing laboratory – the Haskell Laboratory of Industrial Toxicology – in part to screen workers for signs of illnesses that might be tied to DuPont products. In 1961, company lab tests linked C8 exposure to enlarged livers in rats and rabbits. DuPont scientists then conducted tests on humans, asking a group of volunteers to smoke cigarettes laced with C8. “Nine out of ten people in the highest-dosed group were noticeably ill for an average of nine hours with flu-like symptoms that included chills, backache, fever, and coughing,” the researchers noted.

“Concerns about the potential toxicity of C8 had been raised internally within DuPont by at least 1954, leading DuPont’s own researchers to conclude by at least 1961 that C8 was toxic and, according to DuPont’s own Toxicology Section Chief, should be ‘handled with extreme care,’” Bartlett’s February 2013 suit against DuPont alleged.

But it wasn’t until the 1970s that DuPont’s researchers began to understand that C8 was building up in the bloodstreams of workers, and soon after, they began to see troubling signs that the chemical could pose serious health risks. The stakes were high: The Washington Works plant where Teflon is manufactured was one of the biggest employers in the region. The plant currently employs more than 2,000 people – 3,000 if you include sub-contractors – in a sparsely populated Appalachian community alongside the Ohio River separating West Virginia from Ohio.

In 1981, the company ordered all female employees out of the Teflon division after two out of seven pregnant workers gave birth to children with birth defects. One of those children, Bucky Bailey, was born with just one nostril and other facial deformities that required many painful surgeries to fix.

"In 1981, two out of seven pregnant workers at the Teflon plant gave birth to children with birth defects."

“I’ve never, ever felt normal. You can’t feel normal when you walk outside and every single person looks at you. And it’s not that look of He’s famous or He’s rich,” he told ABC News in 2003. “It’s that look of He’s different. You can see it in their eyes.”

In 1984, DuPont began to secretively collect local tap water, asking employees to bring in jugs of water from their own homes, schools, and local businesses, and discovered that C8 was making its way into public drinking water supplies in both Ohio and West Virginia at potentially dangerous levels. Minutes recorded at a meeting at DuPont’s corporate headquarters in Delaware that year suggest a high level of concern regarding how this could affect the company’s image and bottom line. “Legal and medical will likely take the position of total elimination,” notes from the meeting read. The company executives present, however, concluded the available methods for cutting pollution were not “economically attractive.”

In the years following that meeting, instead of slashing its use of C8, DuPont escalated production, while keeping much of what it knew about the chemical’s dangers secret. The company’s Washington Works factory continued with its usual practice of dumping C8-laden sludge in unlined landfills, allowing it to enter the Ohio River, and pumping out C8-laced vapors from its smokestacks.

None of this would have come to light had it not been for a West Virginia cattle rancher named Wilbur Tennant who, along with four other members of his family, sued DuPont in 1998 claiming he had lost hundreds of head of cattle because of pollution from a landfill next to his farm. DuPont had purchased the patch of land, which included a creek that ran directly into the Ohio River, from Tennant in the 1980s, telling him that it would be used as a non-hazardous landfill.

But soon after the landfill got underway, the creek started to turn black and smelly. Sometimes there would be a layer of foam on the water. Within a few years, about 280 of Tennant’s cattle, which drank water from the creek, had died. When the Tennants cut open a cow to investigate the cause of its death, they discovered that its internal organs had turned bright, neon green, video footage recorded by the rancher shows. Tennant and his family members, too, suffered breathing difficulties and cancers.

Tennant’s attorney, Robert Bilott, forced DuPont to turn over tens of thousands of pages of internal company documents as part of the legal process. Buried in those materials was a single mention of a chemical Bilott had never heard of before: PFOA (C8). The chemical sounded similar to another one, called PFOS, which had just been pulled off the market by its maker 3M (which, if you recall, supplied C8 to DuPont for decades). So Bilott made another request to DuPont. This time he asked the company to turn over all documents related to C8.

“I did not immediately recognize the significance [of C8],” Bilott told Earth Island Journal, “but we came to.”

The trove of documents ultimately uncovered during the ensuing legal battles offered up incriminating evidence about the company’s decades-long cover-up. In addition to research findings, copies of internal emails and documents included in this cache were especially illuminating. One 2001 email describes a scientist warning that when airborne, C8 is so hard to deal with that “it might require the public to wear ‘gas masks.’”

Another, by DuPont’s in-house counsel, Bernard Reilly, shows that company officials planned to push regulators to allow the public to be exposed to higher levels of the chemical than DuPont itself had recommended. In an October 2001 email to his son, Reilly wrote:

“So far DuPont has been saying there are safe levels, we need to have an independent agency agree, we are hoping that it will agree to higher levels than we have been saying. If for no other reason than we are exceeding the levels we say we set as our own guideline, mostly because no one bothered to do air monitoring until now, and our water test has been completely inadequate.”

Reilly’s personal emails, written mostly to family members between late 1999 and mid-2001 using his work email address, give an unfiltered insight into the company’s legal efforts to cover up C8’s risks. In one August 2000 email he writes: “The shit is about to hit the fan in WV. The lawyer for the farmer finally realizes the surfactant issue. He is threatening to go to the press to embarrass us to pressure us to settle for big bucks. Fuck him.”

This information not only helped the Tennant case – which DuPont settled in 2001 for an undisclosed amount – it would eventually lead to one of the most significant class-action lawsuits in the history of environmental law (which culminated in the landmark October ruling in Carla Bartlett’s case). Sadly, Tennant didn’t live to see the ripple effect of his lawsuit. He died of cancer in 2009 at age 67.

By 2001, while still working on the Tennant case, Bilott came to realize that the C8 contamination wasn’t isolated to the Tennant property, but extended across a large swath of the mid-Ohio River Valley. The chemical had seeped into the water supply of at least six public water systems in West Virginia and Ohio. That year, Bilott filed a class action lawsuit against DuPont, Leach, et al. v E.I. du Pont de Nemours and Co., on behalf of about 80,000 people in the six water districts. He also reported his findings to the US Environmental Protection Agency and sent along copies of some 900 pages of DuPont’s internal documents, after which the agency launched a “priority review” of C8.

In 2004 the US EPA, too, filed a lawsuit against DuPont, charging it with concealing evidence about C8’s risks for more than two decades. In 2005 the company agreed to pay $16.5 million as part of a settlement agreement with the EPA – the largest civil penalty ever in the agency’s history. But environmental groups argue that the fine was little more than a slap on the wrist to a company where a single division sold more than that amount in a single day.

“We also learned that not only do we have people drinking our famous surfactant, but levels in the ambient air are above our guidelines… we should have checked this years ago and taken steps to remedy, guess the hills on the other side of the river cause great conditions for high ambient levels, the plume hits them before it can disperse more fully. Ugh. “

“Under the terms of the settlement, the company wasn’t even obliged to pull C8 from the market… the best the agency could negotiate was a voluntary phase-out by 2015,” the watchdog organization Environmental Working Group says in its May 2015 report “Poisoned Legacy.”

The same year, DuPont settled the class-action suit filed by Bilott’s firm for over $100 million – plus another $235 million if research funded by the settlement turned up evidence that people might be getting sick. Under the settlement, DuPont promised to install filtration systems in contaminated water districts and put $70 million into a community health and education project. And, in a rather unusual move, the company also agreed to fund a multimillion dollar health study, overseen by independent, court-appointed scientists, to determine whether exposure to C8 had actually harmed people. Moreover, DuPont agreed that if the study did prove that the C8 had caused certain diseases, those who suffered from diseases connected to C8 would be entitled to sue individually for personal injury.

It’s not quite clear why DuPont agreed to the independent study. Perhaps it was the knowledge that most medical monitoring programs fail to attract enough participants, which usually makes it almost impossible to draw reliable inferences about disease clusters. But in this case, nearly 80 percent of the surrounding community in West Virginia and Ohio showed up at makeshift medical clinics in trailers around the region to have their blood drawn and a health care questionnaire completed. Community members were, more often than not, drawn by the $400 checks (pulled from the DuPont settlement) that the enterprising team of medical researchers offered to each man, woman, and child who participated.

“The shit is about to hit the fan in WV. The lawyer for the farmer finally realizes the surfactant issue. He is threatening to go to the press to embarrass us to pressure us to settle for big bucks. Fuck him.” BERNARD J. REILLY, 08/13/2000

“We have families of five dragging their three kids kicking and screaming, and the parents are saying, ‘Yes, you’re going to get stuck in the arms – that’s $2,000!’” one local resident told The Huffington Post.

The C8 science panel, which took seven years to complete its research, ultimately linked C8 exposure to six diseases: ulcerative colitis; pregnancy-induced hypertension; high cholesterol; thyroid disease; testicular cancer; and kidney cancer. The panel’s findings, published in several peer-reviewed journals, were remarkable because they proved that the chemical pretty much affected the entire body, even at low exposure levels. The researchers concluded that C8 posed health threats at just 0.05 parts per billion in drinking water for people who drank that water for a single year. They found that the average C8 level in blood samples from the mid-Ohio Valley was 83 parts per billion. The average C8 level for those living closest to the plant – whose drinking water came from Ohio’s Little Hocking water district – was more than 224 parts per billion compared to 4 parts per billion for average Americans.


When this all started, I did not think it would get out of hand like it has,” says Joe Kiger, a lead plaintiff in the 2005 class action lawsuit against DuPont. photo by Maddie McGarvey“

Once the connection between C8 exposure and the diseases was established, more than 3,500 Ohio Valley residents, including Carla Bartlett, filed personal injury cases against DuPont. Bartlett’s case was the first to go on trial this past September. The court’s verdict in her favor might just set the tone for the rest of cases that will come to trial.

Still, there are many who feel the company will keep trying to wriggle its way out of its responsibilities. (During Bartlett’s trial, for instance, DuPont attorneys argued that her cancer was triggered by her obesity rather than C8, even though, as per terms of the class action suit settlement, DuPont isn’t permitted to dispute the fact that C8 can cause the kind of cancer she endured.)

“I’ve been at it 16 years, if that tells you anything,” Joe Kiger, a local gym teacher and lead plaintiff in the original 2005 class action suit, told the Journal. “When this all started, I did not think it would get out of hand like it has, but we kept finding out more and more of what DuPont did, what the cover-ups were, them knowing full well that this stuff was toxic.” Kiger – who suffers from numerous kidney and liver problems and and had to have surgery following a heart attack in May – is a member of Keep Your Promises DuPont, a community-based organization working to hold the company accountable for its actions. “Our biggest faith and trust we have is in our utilities,” he said. “We flip that light switch on, we expect it to come on. We don’t think anything about it. You turn on your tap to get water, you expect that water to be clean and not have all these chemicals in it. I think now, people are starting to find out that someone has lied to them.”

To understand how C8 managed to remain in use for so long requires a look back at the history of chemical regulation in the US, and the role that DuPont itself played in crafting those laws.

Since the early 1970s, pressure had been growing to regulate the rising use of chemicals in almost every aspect of post-World War II American life. And few companies were as responsible for – or as dependent on – that expansion as DuPont.

FROM: BRUCE KARRH, DUPONT’S MEDICAL DIRECTOR, 1982 FROM INTERNAL COMPANY DOCUMENT “There is obviously great potential for current or future exposure of members of the local community from emissions leaving the plant perimeter.”

In 1930, DuPont created Freon, making mass-market refrigerators and air conditioners possible for the first time. In 1935, a DuPont scientist invented nylon, a synthetic fiber that proved invaluable during World War II. Cellophane, Mylar, Tyvek, Rayon,Lycra – household names to this day – were all developed by DuPont in the past century. The company also made artificial fertilizers, fungicides, pesticides, plastics, and paints. “We have been proud to publicize the fact that more than 60 percent of our sales in 1950 resulted from products that were unknown, or at least were only laboratory curiosities, as recently as 1930,” a DuPont rep told a group of financiers in 1955. But as thousands of new chemical innovations entered the daily lives of Americans, pressure was also rising to find out what health risks many of them posed.

FROM MAY 1984 DUPONT CORPORATE MANAGERS MEETING MINUTES: “None of the options developed are … economically attractive and would essentially put the long term viability of this business segment on the line.”

One of the first acts of the White House Council on Environmental Quality, afterit was established in 1969, was to highlight the need for federal chemical controls – a system that would let regulators figure out which substances could pose public health risks before people got sick. “The Council’s study indicates the high-priority need for a program of testing and control of toxic substances,” it said as it released a 1971 report calling for new chemical rules. “We should no longer be limited to repairing damage after it has been done; nor should we continue to allow the entire environment to be used as a laboratory.”

For several years, the Manufacturing Chemists Association, an industry trade group that counted DuPont as a core member (known as the American Chemistry Council today), managed to block any attempt to regulate the industry. But as a growing list of chemicals like PCBs, asbestos, and vinyl chloride began to be linked to illness, so did the demand to regulate them. Foreseeing the inevitable, many chemical companies decided that it would be better to be involved in the drafting process than to risk the type of bans that barred the use of the notorious pesticide DDT in 1972.

FROM: DUPONT INTERNAL DOCUMENT, 1995 “We are concerned about the potential long term human health effects of these materials considering they all appear to have long biological half lives.”

DuPont had a key seat at that drafting table.

Robert C. Eckhardt, a progressive Texas politician from a north Houston district packed with chemical and oil companies, is often described as the chief craftsman of the legislation that came out of this drafting process – the Toxic Substances Control Act (TSCA), which even today is the primary law regulating chemicals used in the US. First elected in 1966, Congressman Eckhardt was known for riding a bicycle to work at the Capitol – carrying his legislative files in a whisky case strapped to his bike – a habit that put him far ahead of the curve as an environmentalist and gained him support from early conservationists, especially after the 1970s’ energy crisis. During his career in DC, which ended in 1980, the Democratic congressman championed civil rights, fought to tax oil and gas companies, and helped ensure that core environmental statutes like the Clean Air Act and Superfund laws passed.

TSCA, as it stands today, was the product of an unlikely collaboration between the iconoclastic Eckhardt and DuPont.

Early meetings between Eckhardt and DuPont had gone so badly that Eckhardt stormed out of the room during a March 1976 negotiation. But as a draft chemical control bill passed the Senate, DuPont reluctantly returned to the table. One of the biggest sticking points was whether safety tests should be required before companies were allowed to put new chemicals on the market – an effort that the industry successfully blocked. “No mandatory testing was a huge compromise,” Rena Steinzor, University of Maryland School of Law professor and president of the Center for Progressive Reform, told the Journal.


The bill that “Bicycle Bob” Eckhardt ultimately produced was so packed with compromises that some of his early supporters opposed the law’s final version. “I mean, it was [called] the Heckert-Eckhardt bill,” Steven D. Jellinek, the EPA’s first-ever assistant administrator for toxic substances, told the Chemical Heritage Foundation’s Oral History Project, referring to Richard Heckert, then a DuPont vice-president and the chair of the Manufacturing Chemists Association. “It was written by industry.”

Eckhardt’s good intentions might have been undermined by the fact that he was on the Senate Commerce Committee rather than the Environment and Public Works Committee. “The Senate Environment and Public Works Committee was composed of people who believed in the EPA’s mission and knew a great deal about it,” Steinzor says. “The Senate Commerce Committee, like its name, was focused on other concerns and not knowledgeable about toxic chemicals.”

Under the toothless TSCA law that DuPont helped write, industrial chemicals – unlike pharmaceuticals or pesticides – do not have to be tested before they are put on the market. The law does require that the EPA keep a current list of all chemicals used commercially in the US, but it does not require that the chemicals be tested for environmental or human health impacts. Additionally, TSCA allows manufacturers to claim some information, including the chemical’s identity, as a trade secret.

Though the law also requires manufacturers give the EPA some information necessary to assess a new chemical’s safety, roughly 60,000 chemicals that were in use at the time TSCA was enacted were exempted from this rule. These chemicals include bisphenol A (BPA), formaldehyde and several flame retardants – all of which have since been found to present significant risks to human health and the environment. Today, there are more than 85,000 industrial chemicals in commercial use in the US – roughly 2,000 new chemicals are introduced every year in the US – but federal regulators have so far required only a tiny percentage of these to undergo any safety testing. You can literally count on one hand the number of chemicals that EPA has banned or widely restricted under TSCA: asbestos, PCBs, dioxin, CFCs, and hexavalent chromium (made famous in the movieErin Brockovich). That’s only five chemicals in nearly 40 years.

“In many ways, C8 is a poster child for the failures of US toxic chemical law,” says Bill Walker, one of the authors of the Environmental Working Group (EWG) report on C8. “Between 3M and DuPont you have a increasingly damning cover-up. And yet the law is so toothless that neither company was really concerned about being caught by the EPA.”

The lack of safety testing helps explain why, back in 1998 when the Tennants first contacted Bilott, virtually no one outside of DuPont and 3M – not EPA field inspectors, OSHA chemists, or state environmental testing laboratories – had ever heard of C8. The two companies essentially had a monopoly on information relating to this chemical. DuPont used that monopoly to illegally cover up its own research that showed that C8 was making its workers ill.

“But for the lawsuit, it is very likely that the EPA would be completely unaware of this chemical as well its toxicological profile,” says Ned McWilliams, another plaintiff’s attorney. “This lawsuit quite literally blew the whistle on this still unregulated chemical.”

C8 “is the poster child for the failures of US toxic chemical law.”

DuPont, unsurprisingly, plans to appeal the court’s verdict. “The knowledge base around [C8], its environmental footprint, and its health profile has evolved,” company spokesperson Dan Turner told theJournal. “Over the same period, the chemical industry and its regulators have also learned a great deal about how to operate more safely, sustainably and to reduce emissions.” The company has, in the meantime, spun off its Teflon-related operations into another company, called Chemours, in a move that could limit the amount of compensation that plaintiffs can recover.

Over the past few years, DuPont, 3M, and other chemical firms have begun marketing C8-free Teflon, and recent studies show that the levels of C8 in most people’s blood are dropping. Unfortunately, the new chemicals that have replaced C8 are also raising concerns. “These next generation PFCs [perfluorinated chemicals] are used in greaseproof food wrappers, waterproof clothing and other products,” the EWG’s “Poisoned Legacy” report says. “Few have been tested for safety, and the names, composition and health effects of most are hidden as trade secrets.”

On a positive note, efforts to strengthen TSCA, which is the only major environmental law that has not been updated since it was first enacted, have gained steam in recent months. This fall, Congress was on the verge of passing TSCA reform measures. The House and the Senate introduced separate TSCA reform bills this year and while the House passed its bill (HR 2576) in June, and the Senate was yet vote on its bill (S 697) as this story went to press. Reforms proposed by these bills include speeding up the pace of the EPA’s chemical assessments, changing how the agency prioritizes chemicals for safety review, and amending TSCA’s definition of chemicals that may pose an “unreasonable risk” of harmful exposure.

Still, critics say these efforts fall short of what’s needed and may be at risk of repeating the errors of the past.

“Neither bill provides the EPA with the resources to act quickly enough on reviewing and regulating the use of chemicals that can cause cancer and other serious health problems,” Scott Faber, the Environmental Working Group’s senior vice-president for government affairs told the Journal. “Neither clears away the legal hurdles that prevent the EPA from banning chemicals like asbestos, which we already know are dangerous.” Faber is also concerned that the reforms might interfere with regulatory laws introduced by states and other local governments to make up for the lack of effective federal oversight of chemicals. (There are about 172 individual laws regulating chemicals in 35 US states, and another 100 or so similar bills have been under consideration in 28 states this year.)

In the end, it all comes down to the need for a strong political push that can override industry influence and introduce laws to regulate chemicals before they cause the kind of harm that C8 has wreaked. The history of C8, still unfolding, offers many lessons for those battles.


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Saving Money through Zero Discharge of Hazardous Chemicals

Saving Money through Zero Discharge of Hazardous Chemicals

The prevention of discharge of hazardous chemicals used in textile processing operations is always looked at as a ‘COST’ that is to be incurred for mandatory compliance requirements –enforced either by a Brand or by local regulatory authorities. All chemical management and effluent treatment exercises are aimed at eliminating or limiting the exposure of such chemicals in the final outputs (viz product, effluent and air emissions) or within the workplace.

However, zero discharge of hazardous chemicals can also be looked at as a ‘PROFIT’ centre by incorporating innovative techniques and ‘green’ chemistry alternatives that help to reduce costs through savings in input resources such as chemicals, water & energy and result in increased productivity as well as reduced impact on wastewater treatment costs.

Let me enumerate some of these techniques:

  1. Reduce chemicals that ‘go down the drain’:

Many chemicals that are used to process fabrics and garments are NOT actually included in the final product, but are simply ‘washed down the drain’. These are called as “Non- productive outputs”. The total cost of these undesired outputs can be anywhere between 15- 30% of the total production costs , including disposal costs .If these are simply eliminated or reduced in the various processes, it directly results in cost-savings. Let me illustrate this with 2 examples:

Example 1: Scour- bleach process of Cotton Knits

Item Conventional Recipe Enzymatic Sourcing
Dosage (gpl) Dosage (gpl)
Wetting agent 1.0 1.0
Lubricating agent 0.5 0.5
Sequestering agent 0.5 0.5
Enzyme (Pectinase & Lipase) 0 0.5
H2O2 (35%) 2.0 2.0
Caustic Soda Flakes 1.75 0.5
H2O2 Stabilizer 0.3 0.3

The table above illustrates the chemicals used in a conventional scour-bleach recipe versus a recipe using ENZYMES for scour- bleach of a 140 gsm Cotton Knit fabric. The use of enzymes reduces the usage of Caustic Soda (that is used as an alkali in the scour-bleach process) from 1.75 grams per litre to 0.5 grams per litre. Thus, for a knits dyehouse dyeing about 20 tons per day, with an average liquor ratio of 1:6, the amount of caustic soda consumption can be reduced from 210 kgs per day to 60 kgs per day! At an average cost of half a dollar per kg of caustic, a saving of $75 per day can be effected. The lesser use of caustic soda also drastically reduces the COD load on the Effluent Treatment Plant, thereby indirectly reducing the chemical costs for effluent treatment!

Example 2: Dyeing of pale shades with direct dyes in place of reactive dyes

Reactive Dyes are the most popular dye class used for dyeing of cotton. However, almost 25 -40% of the dye is not fixed on the cotton fibre and gets this unfixed dye needs to be washed out, resulting in use of large amounts of water and washing agents. Additionally, salt used for exhaustion of the reactive dyes during dyeing process also goes down the drain. Thus, unfixed reactive dyes , salt and washing agents used in reactive dyeing process are all non-productive outputs!

How do we reduce these undesired outputs? By using Specialty Direct Dyes dye pale shades – say upto 1.5% depth – in place of reactive dyes by exhaust dyeing process.

Parameter Reactive Dyeing Direct Dyeing
Dye Quantity x x/2 or x/3 for some depth of shade
Dye Fixation 60-85% 98%
Salt Quantity x x/5 for some depth of shade
Time of Dyeing 6 to 8 hours 2.5 hours

The above table shows a comparison of the direct dyeing and reactive dyeing processes for light shades. The dye quantity required to dye the same depth of shade with direct dye is half or one-third of a reactive dye. The salt quantity requirement is also 1/5th, which also helps to reduce the Total Dissolved Solids (TDS) load on the Effluent Treatment Plant. Direct Dyes need only a simple Cold Water wash – there is no need to use any washing agents! This type of dyeing not only helps to save chemical and water costs, but also improves productivity by reducing the total dyeing cycle time and eliminates the use of washing agents that may contain APEO contamination!

  1. Improving the ‘Right First Time’ (RFT) Dyeing Rate:

Right First Time Dyeing means achieving the target shade in the first attempt itself – without any additions of chemicals or re-processing the dyed fabric. In simple terms, RFT means “Fill it, shut it, forget it”, meaning the fabric load should be taken out of the dyeing machine in the first shot itself. This is a challenging task, since there are so many process variables to be controlled in the dyeing and finishing cycle.

Process Cost Productivity Profit
Blind Dyeing 100 100 100
Small Addition 110 80 48
Large Addition 135 64 -45
Strip & Re-Dye 206 48 -375

RFT improvement can have a huge impact on your profitability. The table above shows a study by P.S.Collishaw, DAS Phillip and M J Bradbury published in a JSDC issue on the impact on productivity and profits due to shade additions in dyeing. If Blind dyeing, i.e dyeing without any additions is taken as a base of 100, then a small addition results in cost increase by 10%, productivity loss of 20% and a drop in profit to 48 %. In case you strip and re-dye a fabric, then you are already incurring double the costs and you are in a huge loss!

It is estimated that only a 5% increase in RFT (from 75% to 80%) reduces the cost of inputs (chemicals, water and energy) by 15-20%!

To achieve a high RFT rate, variations in 3 areas need to be controlled:

  • Lab to lab reproducibility
  • Lab to bulk reproducibility
  • Bulk to bulk reproducibility
  1. Recovery and recycling of chemicals

The 3rd factor for improving profitability is to recycle and re-use chemicals so as to reduce fresh consumption. Some examples of this are:

  1. Recovery and Reuse of caustic soda from the mercerization bath
  2. Recovery of Indigo from dyeing of denim
  3. Recovery & Reuse of PVA Size
  4. Reuse of softeners baths with reconstitution of required amount of softening agent in the reused bath for a fresh batch.
  5. Reuse of spent baths of disperse dyeing, direct dyeing, vat dyeing (standing bath method) or metal complex dyeing of wool by collecting spent liquor in a separate tank after completion of dyeing, and making- up of the bath with required chemicals for circulation to a new batch for dyeing. Some investments in tanks, piping and metering devices will be required.
  1. Reducing chemical usage through new technology and processes:

The Pad- Humidity- Fix process – or what is popularly known as E-Control process from Monforts – is an innovation that gives savings in chemical usage and other parameters in comparison to the Cold- Pad- Batch (CPB) batch dyeing method.

Formulation Cold-pad-batch Pad-dry-humidity fix process
Remazol Yellow R 28.26 g/l 25.26 g/l
Remazol Red RB 133 31.00 g/l 28.83 g/l
Remazol Black B 3.4 g/l 3.5 g/l
Total Dye 62.66 g/l 57.59 g/l
Urea 100 g/l 0
Wetting Agent 3 g/l 3 g/l
Sodium Silicate 42 °Be 110 g/l 0
Caustic Soda 38 °Be 33.5 g/l 20 g/l
Trough Capacity 60 L 32 L
Dwell Time 10 hrs 3 mins

The table above is a case study between Cold –Pad- Batch and E-Control processes for a brown shade. You can see that there is not just less dyestuff used, but there is no need to use urea and silicate in the E- Control process. Also, the amount of caustic soda required for fixation of the reactive dyes is reduced by about 25%! Other indirect benefits include less dwell time, resulting in faster production.

Similarly, new machine manufacturing technology uses Low material to liquor Ratios (MLR) in dyeing machines that help to reduce water and chemicals consumption. The Then Air flow Synergy dyeing machines have been designed to reduce MLR to 1:2.5 for CO/PES and 1: 4 for CO fabrics. This lower use of water helps to reduce chemical and dyes consumption by 20- 30%.

Another innovative technique is the use of CLAYS in textile pre-treatment processes. Clays are inorganic, naturally- occurring volcanic material that have the ability to adsorb ions. The negatively charged plate- like structure of clay separates out in water and adsorbs metal ions and other impurities from the raw cotton. Clays can be used as a single auxiliary in cotton pre-treatment in place of sequestering agent, stabiliser for peroxide, scouring agent and lubricant. Thus, 4 chemicals that are normally used in cotton pre-treatment can be replaced by a single auxiliary, resulting in chemical savings as well as lower impact on the effluent treatment.

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Zero Liquid Discharge: a solution to Zero Discharge of Hazardous Chemicals?

Zero Liquid Discharge: a solution to Zero Discharge of Hazardous Chemicals?

The use of hazardous chemicals in the textile & apparel wet processing has been under the scanner of NGOs, Fashion and Outdoor Brands & Retailers, governments (in some countries) and even consumers who are now getting interested in ‘green’ or ‘organic’ products – though this is largely focused on the food that they buy!

We know that these hazardous chemicals, that are used in a fabric mill or a dyehouse or a garment laundry or a printing unit, do not all remain on the final product – the fabric or garment – but get washed out and drained through the effluent discharged from the production factory into nearby river bodies, municipal sewers or groundwater. It is estimated that the textile industry is the third most water- polluting industry, after paper and leather.

In the past decade, there have been NGO movements across different parts of the world- and especially in the producing countries like China and India – to control these discharges of hazardous chemicals into rivers, lakes and groundwater from textile factories. Governments in China and India are clamping down on polluting factories and implementing stringent laws for wastewater discharge, which includes Zero Liquid Discharge (ZLD). The Greenpeace Detox campaign and other NGO initiatives have resulted in the Zero Discharge of Hazardous Chemicals (ZDHC) Program by Signatory Brands, which is pushing the apparel and footwear supply chain to ensure that hazardous chemicals are not discharged across all pathways, that is, end products, wastewater, sludge and air.

The story of Zero Liquid Discharge (ZLD) in India:

20(27)An interesting development happened in a small place in the South of India called Tirupur in 2010. Known as the ‘Knit City’, due to the plethora of T-Shirt processing and garmenting units located here, Tirupur’s 700–odd dyeing units were ordered to be shut down by the Madras High Court in 2011 on a petition moved by the Farmers Association in the area. The petition claimed that these units were discharging hazardous dyes and chemicals into the Noyyal River and into the surrounding farmlands and this had caused the river water and farmlands to become toxic – resulting in children developing skin problems, livestock dying after drinking water from the Noyyal River and field cultivation getting impossible due to the highly colored groundwater. The Total Dissolved Solids (TDS) of the effluent being discharged by these units was 4000- 5000 ppm, well above the legal limit of 2100 ppm.

The closure of these 700- odd units severely impacted the USD 1.8 billion industry in this area, and even led to migration of workers and export orders from Tirupur to other cities!

The Tirupur cluster is a startling example of how sustainability gives rise to innovation and long- term environmental protection in practice. The closure of the dyeing units led to the evolution of ‘Zero Liquid Discharge’ or ZLD. Simply put, ZLD means Zero or No discharge of wastewater or any liquid effluent from a factory to the outside surroundings. The ENTIRE wastewater generated due to processes inside a factory has to be treated and RECYCLED back into the factory!

The concept of ZLD has been successfully implemented in Tirupur and subsequently in many parts of India and even at the Common Effluent Treatment Plants (CETPs) set up by the government for industrial clusters.

ZLD has its merits such as:

  • No impact on surrounding soil salinity, groundwater pollution or ecology of river bodies
  • Conservation of water resource through recovery and re-use of treated effluent
  • Recovery and re-use of salt used in the textile dyeing process

But, ZLD also has some de-merits, such as:

  • Use of higher amount of chemicals in wastewater treatment
  • Increase in energy usage
  • Generation of enormous amount of hazardous sludge and other solid waste
  • Impact on cost of processing (implementing ZLD pushes up costs by 25-30%)

In order to achieve Zero Liquid Discharge, we have to recover the water and salt separately from the effluent and reuse it in the dyeing process. This is a very complicated, tedious and expensive process, in terms of investment and running costs. We also need to apply lot of chemistry, engineering & technology know-how. As a simple explanation, the effluent is treated in an Effluent Treatment Plant (ETP) comprising Primary, Secondary and Tertiary Treatment steps. The treated water is recovered from the Reverse Osmosis Plant (RO) process during tertiary treatment phase and Salt is then recovered by using Multiple Effect Evaporation (MEE) with Crystallisation.

There is also a water loss in the treatment process and hence only about 80- 85% of the water can be recovered and re-used back in the process. The cost of this recovered water recycled into the process is always much higher than the cost of input water used from other sources. But if ZLD is viewed from an ecological, social and environmental viewpoint – and not as a Cost Centre – then it merits implementation at all factories with no access to a Common Effluent Treatment Plant.

Looking at the Tirupur ZLD success story- which is the first of its kind in the world- the Indian government has initiated a Draft regulation on 22nd October 2015, which will make ZLD mandatory for textile units having wastewater discharge of more than 25 KLD (Kilolitres per day), including re-use of the treated water back in process. No groundwater extraction will be allowed by industry except for make- up water and drinking purposes.The Bangladesh government has also announced in September 2015 that it is keen to implement Zero Liquid Discharge system in another four years in their country.

ZLD and ZDHC: what is the difference?

The Zero Discharge of Hazardous Chemicals (ZDHC) Initiative should not be confused with the Zero Liquid Discharge (ZLD) concept, although both have the same objective of mitigating the impact of hazardous chemicals used and discharged in textile wet processing facilities.

Limited to discharge of hazardous chemicals in wastewater only Considers discharge of hazardous chemicals across ALL pathways: end-product, wastewater, sludge and air
Is an ‘end-of pipe’ solution to prevent pollution of the environment The focus is on ‘Input Chemical Management’ (using the MRSL) so that input chemicals are screened for restricted substances
Prohibits discharge of wastewater (and thus the hazardous chemicals) to the surroundings/environment by a factory Discharge of wastewater is not prohibited, but the hazardous chemicals in the discharged wastewater should be below the detection limits of testing laboratories
Its scope does not cover elimination of hazardous chemicals in the inventory of a facility, but only preventing release Its scope covers elimination of chemicals which intentionally use the listed Priority Chemical Group substances listed in the ZDHC MRSL
Initiated and monitored by local Pollution Control Boards/ Governments Initiated and encouraged by global Brands & Retailers across their supply chains
Contributes to conservation of water resources by recycling of treated wastewater Does not include conservation of water resources in its scope
Is limited to Tier 2 suppliers i.e., dyehouses Is applicable to all Tiers of the supply chain


Brands and Retailers have initiated the ZDHC Program to lead the textile and apparel industry towards the goal of zero discharge of hazardous chemicals across all pathways across their entire supply chain by the year 2020.

Although Zero Liquid Discharge or ZLD is an ‘end-of-pipe’ concept to mitigate the impact of wastewater pollution on the environment and human health, it can partially help to meet the objective of ZDHC by ensuring that hazardous chemicals are not discharged through the pathway of wastewater.

ZLD has its trade-offs in terms of increased economic burden (due to high investments in the ETP technology), higher energy requirements and the generation of enormous amount of sludge (which will increase the need for secured landfills, thus putting pressure on land resources). However, ZLD is an innovation that contributes to sustainable use of water resources and prevents soil salinity, groundwater contamination and pollution of river bodies.

With the recent Indian government’s draft circular of October 2015 making ZLD mandatory for textile units discharging wastewater of more than 25 KLD, the concept of ZLD will gain more acceptance, which may lead to improvements in the technology and lower the costs. ZLD, alongwith proper input chemical management systems, could help suppliers to achieve the goal of ZDHC!

(The views and opinions expressed in this article are that of the author alone and do not reflect the position of NimkarTek or any other agency)


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‘TRAIN’ to the future: Online Training

‘TRAIN’ to the future: Online Training


Every organization indulges in training for its employees. Research shows that high-performing companies are three times more likely than others to foster a strong learning culture (Bersin & Associates).

Organizations train their employees on a variety of subjects such as Communication Skills, Technical Competencies and Behavioural & Ethical requirements. But the most common and mandatory training across all industries is COMPLIANCE TRAINING.

Compliance Training is important because employees need to:

  • Be knowledgeable about regulations
  • Keep pace with changes in the law
  • Facilitate better risk management
  • Avoid penalties or serious impacts due to violation of the law
  • Meet the compliance expectations of their Buyers

Classroom training has been the classical/traditional form to impart this training. But as organizations expand operations to multiple locations and as supply chains get more and more fragmented across diverse geographical locations, such training methods are no longer feasible or have many limitations. Let’s look at some of the challenges of classroom training:

  • Multiple trainers required at multiple locations OR Trainers who are constantly zipping across the globe for training sessions, resulting in heavy travel expenses and increased carbon emissions!
  • Pulling several employees out of their workplace and box them into a room at an appointed day and time
  • Pushing a heavy dose of content down the throats of the audience due to limited/ fixed time of engagement
  • Training is not standardized as the training session depends on the knowledge, skills and capability of the Trainer and his method of delivery
  • New hires in an organization may not be trained immediately on compliance norms
  • Training on any change in compliance norms cannot be done quickly

ONLINE TRAINING or E-LEARNING: the ‘train’ to the future!

Corporates are now more inclined to use technology to reduce training costs, provide just-in-time skills instruction and supplement in-person, classroom-based training. In 2013, nearly 42 percent of Fortune 500 companies used technology during formal learning hours (Ibis Capital). That same year, E-learning was a $ 56.2 billion industry. This figure was expected to more than double by 2015 (Global Industry Analysts). According to a survey conducted by Towards Maturity, 98% organizations showed preference towards imparting technology-enabled compliance training.

The reasons for the growing popularity of ONLINE TRAINING are simple:

  1. Flexibility: E-Learning‘s tag line “At your own pace, From your own place” says it all! The employee can learn at his/her convenience –not as per the diktats of the HR department! Training can be re-scheduled in case an employee is not available at a given timeframe.
  2. On-demand Access: Online modules are available on a laptop, iPad or mobile phone. A learner can even access them while waiting at the airport or at home. No more getting ‘boxed into a training room’!
  3. Standardized content: The content is delivered in a uniform, consistent manner as per the quality required and can be vetted by several Subject Matter Experts
  4. Small doses of content: A large subject matter can be broken up into structured ‘digestible’ number of modules that can be completed by the employee over a staggered duration
  5. Cost effective delivery mechanism: Mandatory trainings such as Compliance Trainings can be made cost –effective by hosting the modules on the E-Learning LMS (Learning Management Software) and which can be the accessed globally from anywhere. Travel, trainer accommodation and workshop hosting costs are simply cut out!
  6. Tracking and Reporting: A record of who has completed the training and how far they have understood the content can be automatically tracked and maintained through the LMS delivering the online training. Reports on User Details, Course Completion and Evaluation Scores can be communicated to all levels of the Organization Management.
  7. Quick communication of changes: E-Learning can be used to quickly and effectively communicate internal company documents or changes in regulations to a target set of employees or train new recruits as soon as they join an organization.
  8. Overcoming the language barrier: An online module can be translated and ‘localized’ into any native language for text as well as audio. Thus, language barriers can be easily overcome
  9. Explaining through visuals: Most online modules have a variety of images and visuals to explain the content. It is said that the brain processes images 60,000 times faster than text (Parkinson). People seek out visuals and videos to access information. No wonder YouTubeTM is the second most popular search engine after Google™! Online modules are also interactive to retain the interest and engagement of the learner (which may not be always be possible in classroom training)
  10. Watch and re-watch: An online module lets learners revisit the different sections/ slides of a module they may have initially not understood well enough. This also helps to reinforce information users learned previously and increase knowledge retention. Research also shows that mobile learning results in better retention than more traditional training models.


It is important to measure the success of online training. Reports generated through the E-Learning LMS can provide data on successful completion of the training as well as scores obtained in the Evaluation tests succeeding the module completion.

But it is also important to measure the impact of the online training by answering the following questions:

  • Was the training taken by the intended audience?
  • What were the percentages of completion v/s registration for the training?
  • How long did the learners take to complete the training modules?
  • How well did the learners learn the content?
  • Did the learners ask questions or doubts or give feedback during the online training?
  • How did they transfer or apply the learnings at their workplace?
  • Did the training create new initiatives or thought processes in the trainee organization?
  • Did the training impact the bottom-line of the organization? In what way?
  • Has the online training met the business objective(s) of the organization?

Ideally, success metrics should be established even before training is implemented and data on these metrics should be collected before and after training to assess the impact. Behavioural changes due to training may be difficult to measure since some of these changes can be seen only after a long- term. However, short- term gains such as employee satisfaction, productivity increase, lesser rejections and improved retention of training content can be measured and recorded.


NimkarTek has pioneered a unique online training portal called ‘NOTES’ – an acronym for NimkarTek Online Training for Environment and Sustainability. Through this online training portal, NimkarTek has leveraged the power of the internet and best practices of E-Learning to help businesses and global organizations meet their learning and development needs. NimkarTek NOTES can thus be used by organizations as a turnkey solution to replace or supplement classroom training.


Through this platform, NimkarTek provides training to Brands and their stakeholders in the Apparel and Textile Supply Chain through on-demand 24×7 available modules on:

  • Elements of Chemical Management at a textile facility
  • Understanding and compliance to Restricted Substances requirements of Brands & Retailers (RSL,MRSL)
  • Global Regulations on restricted substances in consumer articles
  • Understanding Material Safety Data Sheets (MSDS)
  • Chemical Safety Measures at the workplace
  • Fundamentals of Wastewater management
  • Eco-labels (GOTS V4.0)
  • Basics of textile fibres and coloration

We also develop CUSTOMIZED MODULES for an organization to communicate their internal documents or requirements exclusively to their internal employees or supply chain stakeholders.

These online modules can be TRANSLATED into a variety of native languages – both in terms of text and audio- to deliver the content in the localized language of any country in the world!

Each module is made in an interactive manner and comprises a mix of text, visuals, animations and audio presented in a template. A module:

  • is of 45 mins running time, but a User may need 2 to 3 hours to comprehend the entire content
  • can be accessed repeatedly for a duration of 5 days from the ‘launch’ of the module
  • entitles the Learner to a ‘Certificate’ on completion of the Module and online Exam.

Accessing the training modules is easy – as shown below:



We work with Apparel Brands & Retailers to develop their TRAINING STRATEGY which is then rolled out and monitored by the Admin Staff at NimkarTek. Intermittent Reports on the progress of the training are communicated to the concerned person in the Brand or Organization. Thus, the entire training hassles are managed by NimkarTek! Please see a Case Study on the online training program conducted by NimkarTek for Levi Strauss & Co., where 350 employees + 800 vendors + 200 Licensees across 35 countries trained within 6 months through 4 customized modules developed for Levis on their training topics.


As organizations’ operations touch new shores and the supply chains of Brands & Retailers get dispersed over the globe, they will need to shift from the classical in-person or classroom training to E-Learning or Online Training. Using technology to reach out quickly and cost-effectively across different time-zones and language barriers will be the need of the hour to impart training – especially compliance training.

NimkarTek’s NOTES online training portal is a comprehensive solution to Brands & Retailers to add value to their business operations through training their internal employees and supply chain stakeholders on chemical compliance issues. In addition, NimkarTek can help Brands develop a customized Training Strategy and monitor the progress and impact of the training roll-out.

For more information on NimkarTek’s online training solution, please contact

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Are you updated with the new changes in Global Organic Textile Standard 4.0 (GOTS)?

NimkarTek has developed a unique module on Global Organic Textile Standard Version 4.0 (GOTS). The benefits of this online module are:

  1. Complete understanding of the changes made in Version 4.0
  2. Interactive explanation of the critical criteria of the standard
  3. Reference point for changes to be incorporated by Certified Entities to meet the requirements of the new version

Are you updated with the new changes in Global Organic Textile Standard 4.0 (GOTS)?

The Global Organic Textile Standard (GOTS) is recognised as the world’s leading processing standard for textiles made from organic fibres. It defines high-level environmental criteria along the entire organic textiles supply chain and requires compliance with social criteria as well.
GOTS 4.0 version snapshot

As you are aware that, GOTS standard is subject to a continuous change over a period of time and requires concerned people from the certified entities and organic supply chain to keep themselves updated on GOTS standard. It is thus important for a concerned person in the certified entity to know the changes in newer version so as to take necessary steps required for certification as per GOTS.
Gots logo and fibres

So update yourself and enhance your competencies on Global Organic Textile Standard from NimkarTek’s online training module on GOTS 4.0.

In case of any query, you can contact on email:

See the video below to watch the trailer for GOTS module.

You can update your knowledge on the GOTS by taking this course. Registration is open.

Click the button below and start your course now !

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Banned Amines in Textile and Leather

Banned Amines in Textile and Leather


Customers always love colourful products and hence colour has become an important aesthetic factor in the fashion industry. Different colourants including dyes and pigments are used for the colouration of fashion articles such as apparel, textile, footwear and accessories. These colourants are based on two major chemistries: Azo and Anthraquinone. Colourants based on azo chemistry contain “-N=N-” group or azo group and are known as “Azo Colourants”.

Under certain conditions, azo colourants can undergo a cleavage of the “-N=N-” azo bond to form “–NH2” group or an “Amino” group. Such a compound is called an amine.

Azo Dyes

Some amines are carcinogenic in nature i.e. they can cause cancer and hence there is a ban on usage of dyes and pigments that can release such amines.

Carcinogenic Pictogram
Currently, there are 24 carcinogenic amines which are banned (as releasable amines from azo colourants under reductive condition) in textile and leather by global legislations. Some brands and ecolabels have listed a few more in their criteria (25 to 28).

Banned Amines
S. No. Substance CAS No.
1. 4-aminodiphenyl 92-67-1
2. Benzidine 92-87-5
3. 4-chloro-o-toluidine 95-69-2
4. 2-naphthylamine 91-59-8
5. o-Aminoazotoluene 97-56-3
6. 2-amino-4-nitrotoluene 99-55-8
7. 4-chloroaniline 106-47-8
8. 2,4-diaminoanisole 615-05-4
9. 4,4′-diaminodiphenylmethane 101-77-9
10. 3,3′-dichlorobenzidine 91-94-1
11. 3,3′-dimethoxybenzidine 119-90-4
12. 3,3′-dimethylbenzidine 119-93-7
13. 3,3′-dimethyl-4,4’diaminodiphenylmethane 838-88-0
14. 4-cresidine 120-71-8
15. 4,4′-methylene-bis-(2-chloroaniline) 101-14-4
16. 4,4′-oxydianiline 101-80-4
17. 4,4′-thiodianiline 139-65-1
18. 2-aminotoluene 95-53-4
19. 2,4-diaminotoluene 95-80-7
20. 2,4,5-trimethylaniline 137-17-7
21. 2-methoxyaniline 90-04-0
22. 4-aminoazobenzene 60-09-3
23. 2,4-Xylidine 60-09-3
24. 2,6-Xylidine 87-62-7
25. 5-Chloro-2-methylaniline 95-79-4
26. p-Phenylenediamine 106-50-3
27. N,N-Dimethylaniline 121-69-7
28. Aniline 62-53-3

Do all azo dyes release Banned Amines?


It must be remembered that not all azo dyes release banned amines. Out of the total synthetic dyes manufactured for coloration, almost 70% are based on the ‘Azo’ group. Out of these, only about 4 to 5% can release banned amines under certain conditions. Thus, only those azo dyes, which on reductive cleavage release a specific amine, are banned for usage, and a proper study of the same needs to be done by the user of the dyes before using in his production process.

Sources of Banned Amines in Textile and Leather:

Sources of Banned Amines

In general, banned amines can come from different classes of colourants such as Disperse Dyes, Direct Dyes, Acid Dyes and certain Basic Dyes, Reactive dyes and Organic pigments.

In garments, the sources of banned amines are all coloured items such as polyester buttons, beads and sequins, zipper fabric, sewing threads or yarns, base fabrics and leather components.

Human Exposure to Banned Amines:

Humans can be exposed to Banned Amines either through direct and prolonged skin contact with the garment or through ingestion of the dye present on a garment.
Ingestion of Banned AminesSkin contact

In Skin Contact, the dye migrates from a textile or leather article to the skin due to effect of sweat and poor fastness, and then gets absorbed through the pores in the skin.

Ingestion of the dye can happen when a baby or infant sucks on the textile garment or toy allowing traces of the unfixed dye to enter the body along with the saliva.

Once the dye has entered the human body, enzymes in our body cleave the dye to release the amine(s) from the dye molecule.

Banned Amines/ Azo Dyes Regulations:

Azo dyes releasing specific amines (under certain conditions) are restricted in the EU, China, India, Egypt, South Korea, Taiwan and Vietnam. The amount of a banned amine that can be detected in the finished articles is limited to either 30 mg/Kg in the EU and 20 mg/Kg in China. Several brands have a Maximum Allowable Concentration on finished articles as 20 mg/Kg.

Testing of Banned Amines:

Testing is an important step to monitor presence of banned amines in finished products. To ensure accurate results, samples must be tested in an ISO 17025 accredited laboratory covering the analysis of banned amines under its accreditation scope. Here are some guidelines for testing a sample for banned amines:

  • All components of an article must be tested.
  • All colours present in the article must be tested.
  • An undyed fibre or fabric need not be tested, e.g. full white fabric treated with an optical brightening agent need not be submitted for banned amines test.

The test methods to be used for the analysis of Banned Amines in Finished Articles are:

Substrate Type Test Method
  • ISO 24362-1:2014
  • GB/T 17592 (China)
Textile (for 4-aminoazobenzene)
  • ISO 24362-3:2014
  • GB/T 23344 (China)
Natural Leather (All amines except 4-aminoazobenzene)
  • ISO 17234-1: 2015
  • GB/T 19942 (China)
Leather (for 4-aminoazobenzene)
  • ISO 17234-2: 2011

Azo dyes that can release banned amines:

Acid Dyes
Acid Black 29 Acid Black 94 Acid Black 131
Acid Black 132 Acid Black 209 Acid Brown 405
Acid Orange 24 Acid Orange 45 Acid Red 4
Acid Red 5 Acid Red 24 Acid Red 73
Acid Red 85 Acid Red 114 Acid Red 115
Acid Red 116 Acid Red 128 Acid Red 148
Acid Red 150 Acid Red 158 Acid Red 167
Acid Red 264 Acid Red 265 Acid Red 420
Acid Violet 12 Acid Violet 49

Basic Dyes
Basic Brown 4 Basic Red 42 Basic Red 111

Disperse Dyes
Disperse Orange 159 Disperse Red 151 Disperse Yellow 7
Disperse Yellow 23 Disperse Yellow 56

Solvent Dyes
Solvent Orange 7 Solvent Red 19 Solvent Red 23

Pigment Red 8 Pigment Red 22 Pigment Red 38

Direct Dyes
Direct Black 4 Direct Black 29 Direct Black 38
Direct Black 91 Direct Black 154 Direct Blue 1
Direct Blue 2 Direct Blue 3 Direct Blue 6
Direct Blue 8 Direct Blue 9 Direct Blue 10
Direct Blue 14 Direct Blue 15 Direct Blue 22
Direct Blue 25 Direct Blue 35 Direct Blue 53
Direct Blue 76 Direct Blue 151 Direct Blue 160
Direct Blue 173 Direct Blue 192 Direct Blue 201
Direct Blue 215 Direct Blue 295 Direct Brown 1
Direct Brown 1:2 Direct Brown 2 Direct Brown 6
Direct Brown 25 Direct Brown 27 Direct Brown 31
Direct Brown 33 Direct Brown 51 Direct Brown 59
Direct Brown 79 Direct Brown 95 Direct Brown 101
Direct Brown 154 Direct Brown 222 Direct Green 1
Direct Green 6 Direct Green 8 Direct Green 8:1
Direct Green 85 Direct Orange 1 Direct Orange 6
Direct Orange 7 Direct Orange 8 Direct Orange 10
Direct Orange 108 Direct Red 1 Direct Red 2
Direct Red 7 Direct Red 10 Direct Red 13
Direct Red 17 Direct Red 21 Direct Red 22
Direct Red 24 Direct Red 26 Direct Red 28
Direct Red 37 Direct Red 39 Direct Red 44
Direct Red 46 Direct Red 62 Direct Red 67
Direct Red 72 Direct Violet 1 Direct Violet 12
Direct Violet 21 Direct Violet 22 Direct Yellow 1
Direct Yellow 24 Direct Yellow 48

Precautions for Ensuring Banned Amines Compliance of Finished Articles:

For ensuring compliance to Banned Amines in finished articles, you should:

  • Get Declarations from all your suppliers to ensure that the dyes and pigments supplied by them do not release banned amines.
  • Monitor the presence of banned amines in your finished articles through random testing of your finished articles
  • Ensure that trims and accessories used in the garment do not contain colorants that can release banned amines.

Nimkartek has developed a complete online course to Understand the Banned Amines. The ‘Introduction to Banned Amines’ module introduces you to Azo colourants and banned amines. It describes how these amines are released from azo dyes. The module then discusses why some these amines are restricted and briefly lists their sources in Textile and Leather processing. The module describes the Global regulations on banned amines and then enlists the precautions that must be taken for ensuring Banned amine compliance.

To see a trailer of the course you can see this video:

You can take this course right away and improve your understanding on the banned amines and their compliance in the textile manufacturing.

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REACHing Out to an APEO Ban in Textiles

REACHing Out to an APEO Ban in Textiles

Recently, Member States of the European Union took a step that will have far-reaching consequences in the textile producing countries of the world: They unanimously voted to amend the Entry no 46 relating to Nonylphenol and Nonylphenol Ethoxylates under Annexure XVII of the REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulation.

This means that in the near future, apparel and clothing articles manufactured outside the EU but imported into the EU will be subject to a restriction on Nonylphenol Ethoxylate in such articles, which effectively translates into a usage ban for Nonylphenol Ethoxylates in these producing countries.

As a textile or apparel or chemical manufacturer, if this does not ‘register’ any alarm bells for you or ‘restrict’ your breathing, let me ‘evaluate’ the new situation for you.

Nonylphenol Ethoxylates (NPEs) are widely used in the textile industry as wetting/scouring agents, as emulsifiers in spin finished, loom oils, pigment emulsions and softeners and in detergent and cleaning formulations. NPEs are extremely popular in textile auxiliary formulations due to their excellent performance parameters and cost advantages. There are (yet) no legal restrictions in Asian countries producing textile fabrics and garments for the use or discharge of NPEs. Hence, they are freely used. Due to their unique properties, NPEs are used in chemicals applied across the entire spectrum of textile manufacturing – right from pesticide formulations in Cotton cultivation to Spinning of the yarn to weaving/knitting, dyeing, printing and finishing of fabric or garment. It is thus difficult to pin down their presence in final articles to any one source or input chemical used in their manufacture.

The use of NPEs was earlier restricted in the EU under Entry No 46 of Annexure XVII of REACH in textiles and leather processing as follows:

“NPEs shall not be placed on the market or be used in concentrations greater than or equal to 0.1% (1000 ppm) by weight in textiles and leather processing, unless it is done:

  • with no release into wastewater
  • special treatment systems are installed where the process water is pre-treated to remove the organic fraction completely prior to biological wastewater treatment (degreasing of sheep skin)”

The proposed draft amendment now states that:

“NPEs shall not be placed on the market after [date 60 months after entry into force] intextile articles which can reasonably be expected to be washed in water during their normal lifecycle, in concentrations greater than or equal to 0.01% (100 ppm) by weight of that textile article or of each part of the textile article.”

It further defines “textile article” as “any unfinished, semi-finished or finished product which is composed of at least 80% textile fibres by weight, or any other product that contains a part which is composed of at least 80% textile fibres by weight.”

This translates into a virtual USAGE BAN on NPEs in those countries where textile articles are being produced and exported to the EU (which is all countries!) Of course, there is a saving grace of 60 months (5 years) for the amendment to be enforced from the date it is adopted, but stakeholders in textile producing countries would be naïve if they do not wake up now and take proactive steps to meet this criterion in their apparel and clothing products.

In what way would this amendment impact Brands and Retailers as well as garment producers and exporters in China or India or Vietnam or Mexico or Brazil or Cambodia or Bangladesh or Indonesia?

Firstly, they will need to understand

  • Everything about this convoluted word ‘Alkyl Phenol Ethylene Oxide Condensates (APEOs)’
  • The possible use and potential sources of APEOs across their supply chain
  • Causes of unintentional cross- contamination of APEOs in their supply chain

Secondly, they will require to:

  • Locate the “hot spots” for APEOs across their supply chain and in their products
  • Build strategies to monitor and eliminate these “hot spots”

Thirdly, they will need to:

  • Implement these strategies in their supply chain
  • Regularly monitor compliance to the APEO ban and take corrective actions for deviations

The first step will require training of their own internal employees (Buying teams, merchandisers, quality teams, fabric technologists) and their suppliers (fabric dyers, printers, garment finishers, trims and chemical suppliers).

The second step would be to build competencies for chemical management at their supplier facilities and close interaction with chemical and raw material suppliers for ensuring APEO-free products.

The third step would be to implement systems for transparency and disclosurefrom suppliers, and monitoring methods such as testing and facility audits.

You may wonder why is there so much action on the NPE front? Well, NPEs are chemical compounds that are toxic to aquatic life. So, if they are discharged into rivers – either from a chemical factory or a textile processing factory or simply by washing of garments containing residues of NPEs – we will ensure that one day there are no fish left in our rivers. Moreover – and this is more damning– NPEs biodegrade into a persistent chemical Nonylphenol (NP), which is now known to be an ‘Endocrine Disruptor’. This means that when the NP molecule gets into our body, it mimics some hormones (such a β- Oestradiol) secreted by our body and disrupts the normal functioning of the endocrine system.

So, all in all, REACHing out to an APEO usage ban should benefit all of us – those producing textiles in Asian countries and those importing and using them in the EU!

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