Looking for insights into other industries, what is their process for assigning substances to their restricted substances lists?
With nearly a decade in the regulatory and chemical industries, including almost three years working at ZDHC, I've advocated for safer chemistries while identifying and red-flagging hazardous ones. I wonder how other industries work on their lists of restricted substances? It is clear that across multiple industries, there are multiple variations on what is hazardous (if referring purely to the lists). Some scientifically proven hazardous and pragmatically replaceable substances (e.g., phthalates, restricted amines) are strictly banned in the textiles and leather industry, yet do not appear on the restricted substance lists of other industries. I'd greatly appreciate any insights on the regulatory rationale, risk assessment differences, or economic/practical factors behind these inconsistencies.
Other industries typically build restricted substance lists using hazard identification, exposure assessment, and technical feasibility. Many sectors follow a risk-based approach, where restrictions depend on actual exposure during the product lifecycle. In contrast, the textiles and leather industry through initiatives like the Zero Discharge of Hazardous Chemicals often applies a more precautionary, hazard-focused approach due to direct skin contact, wet processing, and potential environmental discharge. Regulatory frameworks such as the REACH Regulation, supported by bodies like European Chemicals Agency and the US Environmental Protection Agency, provide a common scientific base. However, sector-specific standards and use-case differences lead to variations in restriction levels across industries. Overall, differences in exposure scenarios, regulatory interpretation, and supply chain feasibility explain why some substances are strictly restricted in textiles but managed differently in other sectors.
Dear Sajjath Thank you very much for your inputs. Do you suggest that Textiles and leather industry are more thorough and pro-active compared to other industries?
Dear Pushkar, yes, in many respects, the textiles and leather industry through initiatives like ZDHC has been notably more thorough and proactive compared to several other manufacturing sectors when it comes to managing hazardous substances at the source.