L Brands is focused on partnering with its vendors and other industry leaders to promote environmentally sensitive practices. This philosophy permeates throughout each facet of our garment production, including attention to chemical management in wastewater. We have adopted the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List (MRSL) and the Oeko-Tex® 100 Standard harmful substances value limits as our Restricted Substances List (RSL) to guide us and our suppliers in environmentally responsible product design, development and manufacturing. More specifically, we are committed to the goal of eliminating the discharge of the following 14 priority chemical categories in conjunction with the manufacturing of our apparel products by 2020:
|AP & APEOs||Detergents, wetting agents, emulsifiers, softeners|
|Banned Dyes (azo, disperse, carcinogenic or equivalent concern)||Dyestuffs, pigment prints|
|Brominated and chlorinated flame retardants||Sleepwear|
|Halogenated solvents (TCE)||Paint, spot removers, metal cleaners|
|Chlorobenzenes||Solvents, dyestuffs, insecticides|
|Chlorophenols||Insect control, fungicides|
|Glycols||Softeners, anti-static agents|
|Heavy metals (cadmium, lead, mercury, chromium VI)||Dyestuffs, leather tanning, paints, alloys, pesticides|
|Organotin compounds||Catalysts, inks, paints|
|Perfluorinated chemicals*||Water, oil and stain repellents|
|Phthalates||Flexible plastic components, e.g. PVC, print pastes|
|Polycyclic aromatic hydrocarbons (PAHs)||Rubber/plastic components, lubricants|
|Short-chain chlorinated paraffins||Flame retardants, leather greasing|
|Volatile Organic Compounds (VOCs)||Adhesives, textile finishes|
* Banned by L Brands since 2013
To meet this goal, we are working closely with our suppliers to ensure chemical purchases, manufacturing practices and the quality of water discharge are aligned with our commitment to eliminate certain substances. Engagement activities include:
- Sourcing agreements with suppliers outlining their accountability in the ban and removal of the 14 priority chemical groups
- Annual training on chemical management best practices
- Review of chemical inventories submitted by suppliers to ensure compliance with the MRSL
- In-person audits of suppliers’ chemical management and manufacturing practices and subsequent follow-up on corrective action plans
- Regular testing of on-site water and waste streams
Our chemical management audits review:
- Supplier’s chemical storage and handling practices
- Environmental permits, personal protective equipment and safety policies
- Management’s commitment to achieving zero discharge of the priority chemicals
- Presence of technical staff person(s) with the required competencies to operationalize improved chemical management
The follow timeline outlines when each of these engagement activities was implemented, as well as other important milestones on our journey to ensure environmentally sensitive manufacturing:
2013: L Brands began collecting baseline wastewater testing data from its suppliers and working with design teams to eliminate the need for PFCs and other stain/water repellent finishes from its assortment.
2014: L Brands adopted the ZDHC MRSL, implemented its wastewater testing program* and began working with suppliers to complete chemical inventories and attend chemical management trainings on an annual basis.
If the supplier is unable to provide any certification of MRSL compliance, we ask them to obtain evidence from the chemical supplier. If we identify a formulation that does not meet our requirements, we work with the supplier to find an alternative.
2015: L Brands officially directed all suppliers to not intentionally add PFCs (regardless of chain length) to L Brands apparel products nor use them in the manufacturing process of fabrics, trims or components intended for use in those final products. L Brands also began working with second tier vendors to hold trainings for their chemical suppliers on eliminating hazardous substances.
2016: L Brands began on-site audits of chemical management and worked with suppliers on subsequent corrective action plans. L Brands also launched their “train the trainers” program, where first tier vendors were empowered to offer chemical management training for their direct suppliers.
* Included 90 percent of apparel supply chain by volume
L Brands sees its wastewater testing program as a key element in tracking progress towards the goal of eliminating targeted chemicals. Water is collected from suppliers at four sampling points:
- incoming water
- pre-treated wastewater
- post-treated wastewater
We require our wet-processing mills to test their wastewater annually by a nominated third-party lab. If a chemical listed on our MRSL is found above our limits in treated or untreated water, we work with the supplier to identify the source of that chemical and to find a compliant alternative. Sometimes the chemical is generated during production. In these latter cases, we work with suppliers to identify adjustments to be made to the production process to prevent the generation of this chemical. We then require them to have their wastewater retested. Thus, suppliers for which a restricted chemical is found in violation of our policy are required to have their wastewater tested more than once per year.
In 2015, 90 percent of suppliers in L Brands apparel supply chain were included in the program. By 2016, this number grew to 95 percent. A summary of results from the last four years are provided in the infographic below.
While the environmental performance of our supply chain has improved significantly during the past few years, there is always more work to be done as new suppliers are brought on board. However, as L Brands’ experience working with suppliers on these issues grows and matures, chemical issues are identified, diagnosed and resolved with greater efficiency and agility.
CASE STUDY 1 L Brands’ multi-faceted approach to testing and supplier engagement resulted in the elimination of a priority chemical
CASE STUDY 2 Elimination of a hazardous chemical by looking further upstream
To ensure that we are moving expeditiously and with the best thought leadership, the company is a signatory member of the ZDHC program - an apparel and footwear brand-led alliance formed to set a new standard for environmental performance by leading the global industry towards zero discharge of targeted chemicals for all products and all pathways in their supply chains by 2020.
Removal of APs/APEOs
Our restriction on APs/APEs has been well communicated to our tier 1, tier 2 and tier 3 suppliers who we have direct relationships with, and we have seen a dramatic decrease in the presence of APs/APEs in the past five years. When we do detect their presence, we immediately work with suppliers to replace the source.
Because of their pervasive use throughout the supply chain, eliminating APs/APEs has been more of a challenge. Whether they are discovered in janitorial cleaners, washroom hand soap, production detergents or knitting oils, it seems their possible uses are endless. This is an industry challenge; we believe their occurrence will continue to be minimized as more and more apparel brands emphasize this goal and as more chemical companies provide lists of positive alternatives from which our suppliers can confidently source.
Ninety-five percent of China facilities also report their water testing data on the Institute of Public & Environmental Affairs (IPE) platform.
CHEMICAL SUBSTITUTION OBJECTIVES AND BEST PRACTICES
L Brands is focused on working with our supply chain to remove all chemical formulations containing chemicals restricted in our MRSL from our suppliers’ inventories. We collect updated and accurate chemical inventories from our suppliers and identify formulations that require substitution. Identifying these formulations often requires coupling a review of the chemical inventory with results from wastewater and sludge test reports. When a targeted chemical is identified in discharge reports, we review the inventory with the supplier to identify possible sources. The supplier then sends the suspected formulations to a nominated lab for screening. Once the culprit formulation is identified by screening, we work with the supplier to find a replacement immediately. Since 2016, L Brands has worked to identify and replace more than 30 formulations using this process.
The chemical management training module published by the apparel industry collaborative, ZDHC, describes best practices in the textile industry for removing hazardous chemicals and replacing them with environmentally friendly substitutions. When a chemical that has a preferred alternative available is discovered either in the chemical inventory or wastewater discharge of an L Brands supplier, we encourage the vendor to discuss the alternative(s) with their chemical suppliers.
L BRANDS AND GREENPEACE
View the January 2013 agreement between L Brands and Greenpeace related to the elimination of industrial releases of targeted chemicals.