Is tolerance of zero impurities the be-all and end-all for a cleaner textile industry?

The tiger. As an endangered species, this beautiful animal is a particularly suitable star for a sustainability blog. It’s also a great way to introduce the topic of risk.

The tiger is associated with power and bravery, but also fear and respect. We all know that an encounter in the wild would present a severe danger to our lives and is clearly associated with potential hazards. However, we feel very comfortable about taking a child to a zoo to see the tigers. We feel confident that the child is taking no risk due to the controlled conditions ensured by the zoo. We feel safe that the child will not be directly exposed to the tiger.

We seem to naturally recognize that two conditions are required to define a risk: the hazard potential and the exposure.

This tale of the tiger got me thinking about the textile industry and how we consider the risks posed to our health and environment. Specifically, about whether the tolerance of zero hazardous impurities in our chemicals, largely promoted by the major textile brands, could be distracting us from what else needs to be done to achieve a cleaner industry. I think so.

Battle of the brands

In 2011, the brands came together and agreed on the Zero Discharge of Hazardous Chemicals (ZDHC) Program in response to the Greenpeace Detox Campaign challenging top brands to eliminate eleven groups of hazardous chemicals across their entire supply chain and the entire life-cycle of their products.

More recently, this aspirational goal has transformed into a contest among brands. The battle is on to claim the lowest tolerance on a residual trace amount of hazardous chemicals.

As a result, we’ve got more than 100 different brand-specific restricted substances lists, with the objective being to refer to the lowest analytical detection limit available. All the while, we know that ZERO is an absolute value that cannot be reached in the world of analytical chemistry.

So, in essence we have a big focus of energy on what could be said to be an impossible target.

Cost versus effect

My motivation to lead the Product Stewardship Program at Archroma is to have the opportunity to contribute towards making our industry sustainable. This mission is very close to my heart.

However, when I reflect on the daily market requests I get to bring some chemical commodities for the textile industry into a pharmaceutical grade – by which I mean, higher purity and so on – I’m not convinced that we are tackling the major environmental issue of the textile supply chain.

Looking back at the past, the major environmental impact was triggered by an intentional and extensive use of chemicals selected solely for their technical effects without any consideration of the associated risk.

We are seeing public attention being drawn onto traces, while the main issue has come from the uncontrolled use of chemicals selected only on the basis of “cost versus effect”.

The risk-based approach

In Archroma we are committed to a full evaluation and understanding of the human health and environmental impact of our products throughout the supply chain. We consider health and environmental related data as a valuable asset that needs to be considered when selecting which chemicals are to be used in textiles.

Responsible players like us have already phased out the large majority of the identified chemicals of high concern; we did this some time ago. More than that, we also offer alternative chemistry and innovations. Sadly, these are not (yet) voluntarily adopted by all parties in the industry.

Here’s where I see a big opportunity.

Instead of solely considering the hazard of a given substance, we would make huge progress on the path to clean the industry if all decision makers agreed to ban any large-scale use of such harmful substances in their supply chain.

Some effects used by the textile industry involve chemical processes and technology that generate unavoidable trace amounts of hazardous substances. However, the quantities are so small that the trace amounts do not represent a risk for the environment or the human health. This statement is supported by extensive risk analysis that is communicated and accepted by the most demanding authorities like ECHA or EPA.

It’s time to bring the tiger rationale into play.

Unfortunately, risk assessment or exposure assessment are never in focus in discussions around the aspirational goal of ZDHC, even if they could make a large contribution.

I strongly believe that they should be. There’s the chance to make a real impact if we go beyond concentrating all efforts on controlling trace limits of some unavoidable impurities.

Zero Discharge of Hazardous Chemical can be achieved by striving for zero traces of hazardous chemicals in the products. But it can also be achieved by zero discharge. Textile processes that involve a strictly controlled release into the waste water, or a reduction of the water used, can have an even greater influence on making our industry sustainable.

Call on the tiger

Of course, we must continue to strive to bring the limits to the lowest possible level. And in parallel, we need R&D to develop new technology to eliminate traces of some critical contaminants. But focusing the efforts solely on limits and traces is questionable in terms of actual impact on the environment.

It feels like we are missing the forest for the trees.


– Carole


Carole Mislin

Carole works at Archroma as Global Head of Product Stewardship. She's leading a team of regulatory professionals on a worldwide basis and has herself a regulatory expertise of 20 years ensuring compliance and successful completion of regulatory activities in the major relevant regions. Carole is committed to a full evaluation and understanding of the human health and environmental impact of Archroma products throughout the supply chain and considering health and environment related data as a valuable asset. By advocacy outreach, she's striving for an open discussion with the authorities, the industry and other interested parties to ensure an appropriate product management and effective implementation of the regulations.

Opinion pieces are written by our employees sharing their view on a given topic.

Comments (17)

  1. Really interesting article from Carole for releasing our Archroma Sustainability Blog!

  2. Good reflection!! Impurities in discharges are of course to be paid attention to, but it does seem worth to make the biggest effort on reducing the water discharge itself, rather than focusing exclusively on its content.

  3. My motivation at Archroma is to have the opportunity to contribute towards making our industry sustainability. My mission is my passion…!!

  4. Nice Article…..Specially…Relation Between Exposure To Risk Assessment With Tiger. Textile Hazardous Chemical Waste is One & Very Important Aspect But We Must Focus To Reduce Water & Energy Consuption. Likewise, At Archroma We Continuously Challenge Status Qio In Deep Belief To Make Our Industry Sustainable.
    good Article By Carole.

  5. There is always a huge debate amongst NGOs and the chemical industry about Hazards and Risks. NGOs prefer to focus on intrinsic hazards as these are easier to ‘communicate’ to the public, forgetting the fact that almost EVERYTHING that we are using is hazardous, including the Salt and Sugar that we consume everyday! The risk or impact based on exposure is not given a chance. In that sense, the US EPA’s approach towards hazardous chemicals is more pragmatic that ECHA, since the US EPA focusses more on the Risks from exposure rather than only the hazards. What we should first focus on are the CMR and ED substances and totally ban their production or use!


    “Zero Discharge of Hazardous Chemical can be achieved by striving for zero traces of hazardous chemicals in the products. But it can also be achieved by zero discharge. Textile processes that involve a strictly controlled release into the waste water, or a reduction of the water used, can have an even greater influence on making our industry sustainable”

  7. I am really agree with you! It’s a very interesting article and encourage us to take care/think of our environment and… at the end…our planet!

  8. Great article, especially the analogy with the tiger!

    You could also argue with the law of diminishing marginal utility: Below a certain level of parts-per-million/billion, the total costs to reduce the level by another PPM might be higher than the marginal (safety) benefit for society. And there might be other areas where the same investment would create a much larger safety benefit!

    1. Dear Mr. M!
      That’s an absolute valid and great comment ! The aim of the article is to trigger reflection on the most appropriate and efficient way to make Textile supply chain sustainable and reduce it’s impact on the environment. To do so, it is essential that we focus our efforts, ressources and costs in the area having the highest impact!

  9. Right timing and right approach, hope that some of the targeted addressees will read it carefully and consider doing the necessary. Excited to read more from our PSP team on other subjects that are of key importance for our industry.

  10. Nicely worded with a good analogy!

    Wish it would be simpler with RSLs and the rest of it, but same as in pharma where you have a choice in selecting medicine for a particular ailment, here too we give a choice to the processor of how to reduce havoc in the environment; be it via chemicals or reduction in usage or discharge of water.
    So the issue has been around for more time or may well will be for a lot more time than is desired.

    Looking forward for more such articles! Thanks!

  11. Nice reflexion! Thank you for sharing! I feel very proud to belong to Archroma, a company in which sustainability and environment is a priority.

  12. Very comprehensive. I like the Idea of Zero discharge of Hazards substance to eliminate the risk and clean the environment. It goes beyond product & offering. Also The idea of new technologies and solutions which will eliminate Restrictive Hazards Substance from value chain is encouraging. Thanks Carole for such a beautiful blog.

  13. Thought provoking article! When we talk of cost saving than smaller players cannot avoid using substandards and I think here more efforts are required. To make ZDHC more viable, supply chain from A-Z has to be re-visited, re-evaluated and re-run.