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September 2017 RSL Screening Methodology

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RSL Screening Methodology




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Table of content

Introduction ...................................................................................................................................................... 2

Benetton’s RSL .................................................................................................................................................. 3

Screening Methodology .................................................................................................................................... 3

Chemical Database ........................................................................................................................................ 3

Chemical Inventory ........................................................................................................................................ 5

RSL Definition ................................................................................................................................................ 5

Further investigation ........................................................................................................................................ 8

The importance of wet processes ................................................................................................................. 8

Definition of the chemical’s hazardous and facility’s toxicity level ............................................................... 8

Definition of the clothing’s chemical-toxicological impact ........................................................................... 8

RSL updating...................................................................................................................................................... 9

References ......................................................................................................................................................... 9




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Introduction

Benetton Group has a relevant experience on sustainable business practice and it firmly believes in a “clean

factory approach”. Among others, in 2013 Benetton partnered with Greenpeace’s Detox program to lead

the textile industry towards the complete elimination of hazardous chemicals from manufacturing

(http://www.benettongroup.com/sustainability/detox/). Moreover, in the same years, as signatory brand,

Benetton also joined the Zero Discharge of Hazardous Chemicals (ZDHC) Programme

(http://www.roadmaptozero.com/).

The Restricted Substances List (RSL) represents the main and the most important instrument to achieve the

goal of having a “clean supply chain” and “clean products”, with zero discharge of hazardous chemicals, by

2020. To minimize the impact on the environment and to ensure the highest product safety, Benetton RSL

is divided into Manufacturing RSL (MRSL) and Product RSL (PRSL).

Concerning chemicals and their impact on environment, the main focus of Benetton Group is on the water

effluents of facilities involved in wet processes. This is due to the fact that wet process constitutes one of

the most important stage in manufactured textile; normally it is carried out in aqueous stage and for this it

is called wet process.

Sustainability is the main concept on which Benetton’s philosophy is based on: products have to be

sustainable not only in terms of production processes, but they also have to be safe for consumers. For this

reason Benetton Group is at the forefront of efforts to eliminate dangerous substances and guarantee the

highest safety standards in products.

Benetton Group applies the “precautionary principle” (i.e., taking preventive action before waiting for

conclusive scientific proof regarding cause and effect between the substance/activity and the damage)1

across its global supply chain as it continues to make progress in the elimination of hazardous chemicals

and screens for new chemicals.

In this document, the Benetton’s hazardous chemical screening methodology is described.

1 See BENETTON GROUP’S DETOX COMMITMENT

(http://static.benettongroup.com/wp-content/uploads/2016/05/Benetton_Group_Detox_Commitment.pdf)




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Benetton’s RSL

Benetton’s RSL is intended to put into practice the environmental provisions included in the Code of

Conduct. It sets out the minimum requirements related to the product safety for the end consumer,

including the chemical and eco-toxicological parameters for the products purchased by Benetton Group.

By following the RSL, in fact, facilities can focus on specific actions to prevent and eliminate certain

substances not only in the products but also in their processes.

Benetton’s RSL is divided into two sections, Manufacturing Restricted Substances List (MRSL), related to

wet processes, and Product Restricted Substances List (PRSL), related to products. The RSL clearly restrict

and monitor the use of the 11 initial priority groups defined in the Detox program (see description in the

following sections) and other additional substances.

In spite to this division, there is only one hazardous chemical screening methodology to define the RSL, that

is the same for both Product RSL and Manufacturing RSL. As described in the following, the difference

between the two sections refer to limits definition.

Screening Methodology

The Benetton’s RSL is constituted by a list of various substances groups, with their respective

bans/restriction, and it must be complied by all facilities at any step of the Benetton’s supply chain.

The RSL is compiled based on a 3 main steps process:

- Chemical Database definition

- Chemical Inventory definition

- RSL definition

Chemical Database: together with the recognized chemical substances, it includes a wide range of

publicly available technical information such as countries’ regulations and supranational entities, as for

example the European Chemical Agency (ECHA)2, and other official listings of industrial chemicals (e.g.,

Chem Portal3 , KEMI Prio

4 and others). In particular, the general chemical substance regulations that are

continuously consulted are:

- REACH (Registration, Evaluation, Authorization and Restriction of Chemicals): Regulation

EC/1907/2006

It establishes a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council

Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive

76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC (Text with

EEA relevance). The regulation details the evaluation process, the authorization and the restriction

process of substances.

- CLP (Classification, Labelling and Packaging of substances and mixture Regulation): Regulation

EC/1272/2008

It harmonizes the criteria for classification of substances and mixtures, and the rules on labelling and

packaging for hazardous substances and mixtures to align the European Union system of classification,

2 https://echa.europa.eu/it

3 www.organic-chemistry.org

4 http://www.kemi.se/en/prio-start




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labelling and packaging of chemical substances and mixtures to the Globally Harmonized

System (GHS), that is the set of the classification criteria and labelling rules agreed at the UN level. It

also aims at establishing a classification and labelling inventory of substances.

- POP (Persistent Organic Pollutants): Regulation EC/850/2004

It creates a legal framework to protect human health and the environment by prohibiting, phasing out

as soon as possible or restricting the production, placing on the market and use of POPs (Persistent

Organic Pollutants). It also lays down rules for dealing with stockpiles and waste containing POPs.

- EU Biocides Regulation: Regulation EU/528/2012

It concerns the placing on the market and use of biocidal products, which are used to protect humans,

animals, materials or articles against harmful organisms, like pests or bacteria, by the action of the

active substances contained in the biocidal product.

- Toy Safety Directive: EC/48/2009 and UNI EN 71

The EC/48/2009 lays down rules on the safety of toys, i.e. products designed or intended, whether or

not exclusively, for use in play by children under 14 years of age.

The UNI EN 71 specifies the requirements and the test methods to evaluate both physical and

mechanical toys’ characteristics.

- OEKO-TEX certification

It is an independent testing and certification system for textile products from all stages of production

along the whole value chain.

- EU Ecolabel Directive for textiles: EU/350/2014

It promotes the production and consumption of products with a reduced environmental impact along

the life cycle and is awarded only to the best (environmental) performing products in the market.

- UNI Safety management of textiles, clothing, furniture, footwear, leather and accessories: UNI/TR

11359/2010

It describes in detail hazardous chemical potentially present in textiles and their respective risks, by

indicating the acceptability limits basing on the use categories (children, contact with skin, no contact

with skin).

- Textiles and textile products - Guidance on health and environmental issues related to chemical

content of textile products intended for clothing, interior textiles and upholstery: CEN/TR 16741/2014

It specifies environmental and health recommendations for textile products (including accessories)

with direct skin contact and in the surroundings of the human body. It is a technical report that

facilitates the understanding of chemicals with intended uses in the manufacturing of goods in the

fields of textile products intended to clothing, interior textiles and upholstery, to comply with the

European chemical regulations and recommendations in force in EU.

- Footwear - Critical Substances Potentially Present In Footwear And Footwear Components: CEN

ISO/TR 16178-2012

It establishes a list of critical chemical substances potentially present in footwear and footwear

components, their potential risks, the materials in which they could be found and which test

method(s) can be used to quantify them.




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- Greenpeace’s Eleven hazardous chemicals (11 Detox Chemical Groups)

They represent the priority list of hazardous chemicals that brands in the textile industry have to

eliminate in the supply chain by 2020.

- GOTS, Global Organic Textile Standard (http://www.global-standard.org/the-standard.html)

It is the world's leading processing standard for textiles made from organic fibers. It defines high-level

environmental criteria along the entire organic textiles supply chain and it also requires compliance

with social criteria.

- ZDHC, 2015 Manufacturing Restricted Substances List

(http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf)

It is a list of chemical substances banned from intentional use in facilities that process textile materials

and trim parts in apparel and footwear. It also establishes acceptable concentration limits for

substances in chemical formulations used within manufacturing facilities.

- ZDHC, 2016 Wastewater Guideline

(http://www.roadmaptozero.com/fileadmin/content_2016/ZDHC_Wastewater_Guidelines_Print.pdf)

It is a harmonized set of wastewater parameters (i.e., conventional parameters and original priority

chemical groups included in the ZDHC MRSL), limit values and test methods, to ensure brands and

suppliers are working to the same set of expectations.

Chemical Inventory: it is the result of the previous step and it is constituted by two list, namely the

Preliminary List and the Alert List. In particular, the Chemical Inventory is defined by evaluating all

substances basing on their hazardous level, according to the classifications reported by REACH

(https://echa.europa.eu/it/regulations/reach/), CLP (https://echa.europa.eu/it/regulations/clp/),

GreenScreen® List Translator™ (http://www.greenscreenchemicals.org/learn/greenscreen-list-translator).

1. Preliminary List: it contains all substances, including the hazardous or potentially hazardous ones,

resulting from the revision of the regulations grouped in the Chemical Database. In particular, they

are all substances that are classified in any of the hazardous categories listed in the regulations and

they constitute the candidates substances to be included in the Benetton’s RSL.

2. Alert List: it includes all the substances that are not yet regulated and that, therefore, need further

investigations.

RSL Definition: This, in turn, is based on three steps:

1. RSL Substances’ list: in this step all substances in the Preliminary List are evaluated depending on

their use and/or regulation in the textile industry. If they are neither used nor regulated in textile

industry, their use in growing and/or feeding is evaluated since they could have affected both

animal and vegetal fibers. All other substances that do not belong to these “categories” are

momentarily not considered and left for future investigations.




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2. Limits definition: in this step limits for PRSL and MRSL are respectively defined.

2.1. Detection Limits: information given by laboratories concerning instruments’ detection limits to

minimize the presence of any regulated (hazardous) substance. It is settled on the minimum

detection limit that even one of the selected laboratories can guarantee in all its sites all over

the world.

2.2. Limit Value and Methods: information resulting from the Chemical Database are compared

each other. When they are regulated, the most restrictive limit is chosen with the related

methods; on the contrary, when a fixed limits do not exist, they are defined on experience on

testing results. Methods are carefully screened selecting those that ensure the stronger

guarantees. Basing on improved results, both limits and methods are yearly reduced and

revised respectively.

2.3. USAGE BAN: this refers to substances that must not be intentionally used, due to their

hazardousness, at every stage of production. Even if they are banned, in some cases a

tolerability of them is granted since residual traces could be present caused by inevitable

impurities in the input.

3. RSL Publication: it includes the publication of both PRSL and MRSL. After the limits’ definition for

each substance/group of substances, the RSL can be officially published by listing all substances,

grouped by family, with respective limits, methods and bans. In particular, concerning PRSL, 25

groups of substances have been individuated: Alkylphenols/Alkylphenols Ethoxylates, Asbestos,

Biocides, Bisphenol A, Chlorobenzenes and Chlorotoluenes, Dimethyl Fumarate, Dyes – Azo, Dyes-

Carcinogenic, Dyes-Allergenic, Flame Retardants, Formaldehyde, Heavy Metals, Heavy Metals

(extractable), Isocyanates, Nickel, N-Nitrosamine, Oils, Organotin Compounds, Pesticides, PFCs,

Phenols, Phthalates, Polycyclic Aromatic Hydrocarbons, Solvents, Heavy Metals (Toys). The MRSL,

instead, is constituted by 18 substances groups, including General Chemicals and the 11 Priority

Group indicated by Greenpeace

(http://www.greenpeace.org/international/en/campaigns/detox/fashion/about/eleven-flagship-

hazardous-chemicals/). The 18 groups are: Alkylphenol ethoxylates/Alkylphenols (APEOs/APs),

Chlorobenzenes and Chlorotoluenes, Chlorophenols, Dyes – Azo (Forming Restricted Amines),

Dyes-Carcinogenic or Equivalent Concern, Dyes-Disperse (Sensitizing), Flame Retardants, Glycols,

Halogenated Solvents, Organic Tin Compounds, Perfluorinated and Polyfluorinated Chemicals

(PFCs), Ortho-Phtalates, Polycyclic Aromatic Hydrocarbons (PAHs), Volatile Organic Compounds

(VOC), Heavy Metals, Cyanide, Anions and General Chemicals.




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The whole process for the RSL definition is described by the flow chart reported here below.

Figure 1 Flow chart to define the Benetton's RSL.




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Further investigation

Starting from 2016, to deepen which substances need more attention, Benetton is partnering with the

University of Venice (Italy) in the research titled “Environmental impacts research and smart monitoring

strategy development focused on the Detox Programme” (Gambaro et al., 2016), that focus on water test

results of the wet process facilities.

The importance of wet processes

Water represents an important element in the process of sustainable development and it is important to

check the water pollution level through the whole supply chain (of a production system). Concerning the

supply chain of textile production, a large use of water is required in the wet process, in which, through

different steps (i.e., fabric preparation, dyeing and/or printing and functional finishing), the final

appearance is given to the products. For this reason, wet process has been chosen as focusing point of the

chemical monitoring in the Benetton Group’s supply chain.

According to the results published by Greenpeace International (2011, 2015), the sustainability assessment

of textile production systems is strongly threatened by the release of hazardous substances in the aquatic

systems. Textile industries, in fact, represent not only one of the major consumers of water but they also

dispose large volumes of polluted effluent in the environment.

In order to achieve a deeper vision of the general situation and for a better understanding of the suppliers’

responsibility, starting from 2013, Benetton has evaluated water performances of its suppliers by testing 12

toxic compounds (11 priority groups plus Cyanide) in their wastewater. The test has always included

sampling in three crucial points: Incoming Water - InW (sampled at the water sourcing point), Raw Waste

Water - RWW (sampled at the end of the production line) and Treated Waste Water - TWW (sampled at the

exit of the Effluent Treatment Plant (ETP)). In particular, RWW was tested for all toxic compounds defined

in the Chemicals Inventory, InW was tested in case of findings on RWW and focused on founded groups,

TWW was tested in case of findings on RWW and focused on founded groups.

Definition of the chemical’s hazardous and facility’s toxicity level

According to the method developed in the before mentioned research (Gambaro et al., 2016), the

hazardous level of any analyte that is represented by its AGTS (Analyte Global Toxicity Score), has been

calculated by using a proper weight criteria assessment, starting from the five kinds of toxicity5 identified

by combining the UNECE (United Nations Economic Commission for Europe) categories and the IARC

(International Agency for Research on Cancer) groups. By combining the results from the Water Tests and

the toxicity level of the compounds, another indicator, namely the Facility Global Toxicological Score (FGTS)

is calculated. Based on this, facilities are classified into five impact categories.

Definition of the clothing’s chemical-toxicological impact

Collaboration with the University of Venice is still ongoing extending the range of the research not only to

the processes but also to the Benetton’s products.

5 Acute toxicity (AC), Carcinogenicity (CARC), Reproductive toxicity (REP), Acute aquatic toxicity (AC AQ) and Chronic aquatic toxicity

(CHR AQ).




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RSL updating

Benetton Group is continuously monitoring all public sources where chemicals are listed to keep updated

its database, whenever there is a change or a new published information, to ensure the most up-to-date

version. In particular, Benetton annually updates the RSL and it makes available its detailed reports on its

web page (http://www.benettongroup.com/sustainability/detox/).

In particular, since the used method to define the RSL is based on a multi-criteria analysis, that is a very

versatile technique, periodic checks of changes (and updating when necessary) in the classification of

compounds are made by Benetton Group. This means that there is a continuous monitoring of the

screening procedure within the Group.

Moreover, Benetton Group, encourage its suppliers and sub-suppliers to transparency, by inviting them to

disclose their DETOX analysis results on the IPE (Institute of Public & Environmental Affairs) platform

(http://wwwen.ipe.org.cn/) and in the ZDHC Gateway (http://gateway.roadmaptozero.com/).

References

Gambaro, A., Gregoris, E., Roman, M., Barbante, C., 2016. Environmental impacts research and smart

monitoring strategy development focused on the Detox Programme. Technical Report of the Research

Collaboration between Benetton Group S.r.l. and Department of Environmental Science, Informatics and

Statistics (DAIS) of the Ca’ Foscari University of Venice (Italy).

Greenpeace International, 2011. Dirty laundry: the toxic secret behind global textile brands

http://www.greenpeace.org/international/Global/international/publications/toxics/Water%

202011/dirty-laundry-12pages.pdf. Accessed 18 January 2017.

Greenpeace International, 2015. Footprints in the snow.

http://www.greenpeace.org/international/Global/international/publications/toxics/2015/Footprints-in-

the-Snow-Executive-Summary-EN.pdf. Accessed 18 January 2017.

Documents

RSL Screening Methodology - Benetton Groupstatic.benettongroup.com/wp-content/uploads/2017/... · Benetton’s RSL is divided into two sections, Manufacturing Restricted Substances