In the current textile and footwear industry, the difficulty in controlling diverse health or environment-related chemical hazards lies not only in the vast volume of chemicals used in the manufacturing process, but is also due to the complexity and multi-tiered textile supply chain which involves tens of thousands suppliers worldwide. Chemical information is not always transparent and does not always move smoothly along the supply chain. Suppliers, especially small-to-mid-sized ones, often lack awareness and competence to manage chemicals effectively. The current industry trend of moving from traditional "push model" (production based on prediction) to a "pull model" (lean retailing/fast fashion) further increases the complexity of the supply chain.
Accompanying the faster pace of the industry, more and more stringent laws and regulations on chemicals are being issued by governmental authorities globally. Traditional solutions of performing chemical tests on finished products for the purpose of complying with regulations cannot be sustained in the long-term. New solutions need to be found.
Textile testing and low tier suppliers in the supply chain
For some brands and suppliers, depending only on finished product testing is like performing a risky high wire-walking act. Those companies would face great difficulties when confronting testing failure issues or experiencing product recall cases since where the chemical risk occurred can be very difficult to determine. They are still faced with products that conflict with regulations and consumers interests. Unlike physical properties, products with unwanted chemicals present are hard to fix and are usually recalled and destroyed with a high cost, which could include fees for potential accountability and lawsuits.
Testing can be a more effective solution when it is conducted in the early stage of production and from the low tier of suppliers, such as the chemical suppliers and material suppliers. Buyers should pass on their requirements to their upstream suppliers and push these suppliers to demand better control of chemicals and products from their own suppliers. Risks will be lowered if the testing is performed at the very beginning of the supply chain.
Upstream textile chemical management is the key
In addition to a thorough testing approach, experiences and practices in controlling chemical risks have revealed several basic guidelines toward sound management of chemicals:
- Establish a competent hazardous substance control (HSC) team with the involvement of senior level management. The related employees should possess sufficient knowledge on general hazardous substances control and know-how such as REACH, GHS and MSDS, etc.
- Require all the upstream suppliers to formally sign a Declaration of Conformity (DOC) to indicate responsibility and duty, and enforce requirements.
- Establish a dynamic management mechanism to review suppliers HSC performance periodically and apply control measures and testing plans accordingly. An increased sampling level plus a testing programme for suppliers with poor HSC performance will help to ensure better chemical and raw material quality. Elimination of unqualified suppliers should be considered as an option.
- Perform risk analysis on incoming chemicals and materials and establish clearly written HS sampling and testing protocols. Test reports should be archived and the data summarized to support HSC and management decisions.
- The chemical suppliers should be asked to improve the quality of MSDSs for their products. Accurate and necessary information should be indicated in MSDSs in the format recommended in REACH Annex II or other similar standard formats.
- Provide training to employees to ensure all containers are well labelled and chemicals