Ultra-fast fashion – hazardous chemicals in supply chain

Ultra-fast fashion does not have a positive public image. It is rarely out of the headlines, mostly for the wrong reasons. Product tests on 47 products from a large Chinese retailer found that seven of them (15 per cent) contained hazardous chemicals that break EU regulatory limits. Five of the products broke the limits by 100 per cent or more, while 15 of the products contained hazardous chemicals at levels of concern (32 per cent).^[reference1]

This is supported by a documentary shown in France on non-compliance with REACH regulations in Europe, with levels of lead in a T-shirt four times higher than the regulations allow.^{[reference 2]} Lead can cause damaging health effects to the brain, heart, kidneys and reproductive system. Children and pregnant people are more vulnerable, and infants and children are the most at risk, according to Health Canada’s website.^{[reference 3]}

Lead can be used in textile dye pigments, however there are safer alternatives, such as alternative plasticisers, not phthalates.^{[reference 4]}

Another example is Viscose, which is used in dresses and skirts among other items. Because viscose is being manufactured cheaply, the process is more chemically intensive, using carbon disulphide. This is a toxic ingredient linked to coronary heart disease, birth defects and cancer in textile workers and those that live close to the factories.^{[reference 5]}  

This is unacceptable for consumers and workers involved in the supply chain and manufacture of ultra-fast fashion brands. If the final product is not safe for the consumer, then it is not safe for the workers handling the chemicals who make it. The testing of these products suggest that ultra-fast fashion brands’ supply chain is exposing workers to hazardous substances, as well as the potential for exposure to the local environment and communities in which they work.

When these products are discarded, as is often the case with high volume, disposable manufacturing of textiles,^{[reference 6]} they contaminate the textile waste that is either burnt or sent to landfill.^{[reference 7]}

It is well known that some large ultra-fast fashion brands have poor human rights records, and a concerning lack of health and safety in their factories. Many emergencies exits are blocked and upper floors barred.^{[reference 8]} However, the lack of regard for hazardous chemical control is concerning.

Many ultra-fast fashion companies do not publish a suppliers list, meaning it is impossible to know the level of hazardous substance control throughout the supply chain. This is the case for the entire fashion industry. Beauty products come with an ingredients list, clothes do not. Therefore, it is becoming increasingly difficult to avoid chemicals. It is often unknown which chemicals have been used in the manufacture, dye, weave and finish of a piece of clothing.^{[reference 9]}

OSH professionals’ role 

OSH professionals need to be aware of these hazards. This is not only in terms of poor working conditions and poor human rights records associated with this industry traditionally, but also the more hidden risk of hazardous chemicals in the supply chain and all the way through to the finished product.

In the US, there are no federal standards for what can be put on clothes and sold to adults, although the EU has banned more than 30 substances for use in fashion, and shipments are rejected at the border. However, the testing programme is small and easy to avoid.^{[reference 9]} Chemical companies need to register all chemicals in use.^{[reference 9]}

Firstly, OSH professionals should ensure there is a complete and up-to-date inventory of all chemicals. A safety data sheet (SDS) contains the necessary information to carry out a risk assessment. It describes the hazards of a chemical, allowing OSH professionals to assess the probability of these hazards occurring and decide the appropriate control measures.

The SDS should be sourced from the manufacturer. The manufacturer/supplier is responsible for classifying the hazards in line with international legislation, so this will be on the SDS. The Health and Safety Executive’s hazard pictogram gives a quick indication of the hazards.^{[reference 10]}

Manufactured chemicals will follow the UN (United Nations) Global Harmonised System of Classification and Labelling of Chemicals (GHS). It is not a formal treaty or a legally binding international agreement, so countries will create local or national legislation to implement the GHS.  

The GHS outlines the assessment of the intrinsic hazards of a chemical as follows:

• identification of the relevant data regarding the hazards of a substance
• review of the data to determine the hazards
• is the substance classified as hazardous?

Given that there are so many chemicals available, it is not practical that there are individual regulations for each chemical. This classification provides the information to use the chemicals safely by identifying their hazards and appropriate protective measures.

Hazard statements are identified with a H and precautionary statements are represented as a P. For example:

• H301 Toxic if swallowed – the purpose is to provide simple and understandable information that describes the nature of the hazard.
• P102 Keep out of reach of children – the purpose is to describe the measures that need to be taken to prevent harm arising.

The CLP labels need to contain the name, address and phone number of the supplier, nominal quantity, product identifiers, signal words and hazard statements where needed.

• Acute toxicity – the adverse effects following digestion of the hazardous chemicals, or of multiple doses given within a brief period, for example 24 hours. The toxicity levels are determined from levels 1-5, with 1 being the most toxic.
• Germ cell mutagenicity – a chemical that may cause mutations in the germ cells of humans. This can cause cancer or genetic defects being passed to offspring in the future.

Under GHS, these will be labelled as a ‘health hazard’.

• Carcinology – a substance that can increase cancer risk. Under GHS, these are labelled as Category 1A – known to cause cancer with human evidence. Category 1 B presumed to cause cancer – strong animal evidence. Category 2 – suspected with insufficient evidence. Health hazard symbol.  
• Reproductive toxicity – can cause sterility, miscarriage or birth defects. This is classified in a similar way to carcinology. Health hazard symbol.
• Labelling – within the EU, for many chemicals, the classification and labelling has already been done and they simply look up the chemical in the CLP Annex VI Table 3.1.^{[reference 11]}

It is good practice for employers to carry out a hazardous chemicals risk assessment. For example, in the UK this is mandatory under the COSHH 2002 regulations.

COSHH assessments can follow the process below.

1. Gather information about the substance and the work – what substances will be used? Who could be harmed and how?
2. Evaluate the risks to health – what is the likelihood of exposure occurring? How often could exposure occur?
3. Decide on the control measures needed – plan for emergencies, monitoring exposure, health surveillance, maintaining controls.
4. Record and review and update as necessary – decide trigger points for reviewing the risk assessment.

OSH professionals should consult an occupational hygienist (OH) when identifying hazards in the workplace. An OH can ensure health monitoring is undertaken and identify health hazards using a wide range of monitoring techniques, for example air sampling. OHs have access to specialist equipment and are trained and competent to carry out this monitoring and interpret the results.

Takeaway for OSH professionals

It is good practice to be aware of all the chemicals and substances within the supply chain. In the textile industry, manufacturers can join the Roadmap to Zero programme, led by the ZDHC. It aims to eliminate harmful chemicals from the global supply chain and provides guidelines and regularly updates its manufacturing restricted substances list (ZDHC MRSL).^{[reference 12]} 
 
I’ve used the ultra-fast fashion industry as an example in this blog. Identifying and controlling hazardous substances is important across all industries. In the UK, COSHH regulations are an example of good practice for managing hazardous substances.

When dealing with hazardous substances, OSH professionals should:

• ensure that there is a complete and up-to-date inventory of all chemicals
• source SDSs from the manufacturer
• understand the manufacturer/supplier is responsible for classifying the hazards in line with international legislation
• check the classification of a substance in the SDS and use this to decide how to control the storage and use of the substance
• where possible, refer to the hierarchy of control and eliminate and substitute hazardous chemicals from your organisation.

References

1. Taking the shine off SHEIN: Hazardous chemicals in SHEIN products break EU regulations, new report finds – Greenpeace International
2. MY TFI (2022), Les reportages de Martin Weill – Victimes de la mode, quels sont leurs nouveaux codes? 08 February 2022
3. Experts warn of high levels of chemicals in clothes by some fast-fashion retailers | CBC News
4. Toxic Chemicals in Fast Fashion Could Be Harming Your Health – Good On You
5. Material Guide: What is Viscose and Is It Sustainable? – Good On You
6. Results of a survey in Germany, see: Greenpeace e.V (2015), Wegwerfware Kleidung: Repräsentative Greenpeace-Umfrage zu Kaufverhalten, Tragedauer und der Entsorgung von Mode
7. Ellen McArthur Foundation (2017), A New Textiles Economy (p.37, ref 61), op.cit.
8. Public Eye (2021), 75 hour weeks for Shein: Public Eye looks behind the Chinese online fashion giant’s glitzy front, 12 November 2021
9. Are your clothes making you sick? The opaque world of chemicals in fashion | Fashion | The Guardian
10. Hazard symbols and hazard pictograms – Chemical classification
11. Table of harmonised entries in Annex VI to CLP – ECHA (europa.eu)
12. Roadmap to Zero | ZDHC