What's Wrong With Red Lists?

Google should be applauded for requiring that all products used in their workplaces be compliant with the Living Building Challenge Red List. Because textiles are, by weight, approximately 27% synthetic chemicals, and because they surround you from the time you wake in the morning and throughout the night, they are a major contributor to our chemical body burden (changing us in unknown and unforeseen ways). Search PFAs on our blog to learn more (Per- and polyfluoroalkyl substances are both included as PFAS).

Make no mistake, we think it’s critical that we begin to develop these lists, because we all need a baseline. As long as we need to eat and breathe, toxins should be an important consideration.

But using a Red List only to evaluate a fabric overlooks what we consider to be the biggest problem.

First, lists for the most part are developed on the basis of science that usually occurred five or 10 years ago, so they tend to be lagging indicators of safety to humans and the environment. (That’s a minor point, admittedly, but can be important.)

When using lists, it’s important to remember the concept of reactive chemistry: many of the chemicals, though possibly deemed to be benign themselves, will react with other chemicals to create a third substance which  is toxic. This reaction can occur during the production of inputs, during the manufacture of the final product, or at the end of life (burning at the landfill, decomposing or biodegrading). So isn’t it important to know the manufacturing supply chain and the composition of all the products – even those which do not contain any chemicals of concern on the list you’re using – to make sure there are no, let’s say, … dioxins created during the burning of the product at the landfill, for example?

It’s also important to remember that chemicals are synergistic – toxins can make each other more toxic. A small dose of mercury that kills 1 in 100 rats and a dose of aluminum that will kill 1 in 100 rats, when combined, have a striking effect: all the rats die. So if the product you’re evaluating is to be used in a way that introduces a chemical which might react with those in your product, shouldn’t that be taken into consideration?

The Red List (like other lists trying to do the same thing), by attempting to address all product types, does not mention many of the toxic chemicals which ARE used in textile processing. Chemicals which are commonly used in textile processing, and which are NOT included on the Red List but have been found to be harmful, include:

Chlorine (sodium hypochlorite NaOCL); registered in the Toxic Substances Control Act as hypochlorous acid ; sodium chlorite
Sodium cyanide; potassium cyanide
sodium sulfate (Na2SO4)
Sodium sulfide
APEOs ( Alkylphenolethoxylates)
Chromium VI (hexavalent chromium)
pentachlorophenol (PCP)
Dichloromethane (DCM, methylene chloride)
Tetrachloroethylene (also known as perchloroethylene, perc and PCE)
Methyl ethyl ketone
Toluene: toluene diisocyanate and other aromatic amines
Methanol (wood alcohol)
Chloroform; methyl chloroform
Phosphates (concentrated phosphoric acid)
Dioxin – by-product of chlorine bleaching; also formed during synthesis of certain textile chemicals
Benzenes and benzidines; nitrobenzene; C3 alkyl benzenes; C4 alkyl benzenes
Sulfuric Acid
Optical brighteners: includes several hundred substances, including triazinyl flavonates; distyrylbiphenyl sulfonate
ethylenediaminetetra acetic acid [EDTA]
diethylenetriaminepenta     acetic acid [DTPA]
Perfluorooctane sulfonates (PFOS)

In the case of arsenic (used in textile printing and in pesticides) and pentachlorophenol (used as a biocide in textile processing) – the Red List expressly forbids use in wood treatments only – so fabrics, by default, can contain these chemicals.

Perhaps we should manufacture with a “green list” in mind: substituting chemicals and materials that are inherently safer, ideally with a long history of use (so as to not introduce completely new hazards).

But as I said at the outset, using the Red List ignores what we consider to be the most important aspect needing amelioration in textile processing – that of water treatment.

The chemicals used by the textile industry include many that are persistent and/or bioaccumulative which can interfere with hormone systems in people and animals and may be carcinogenic and reprotoxic, and the industry often ignores water treatment even when it is required (chasing the lowest cost).  So the costs of dumping untreated effluent into our water is incalculable.

But indeed, it does not even have to be a “toxic” chemical which wreaks environmental havoc – salt is the most commonly used chemical in textile processing. And nobody will argue that it’s toxic. Yet, the sheer quantity of salt used and expelled in wastewater is enormous – in Europe alone 1 million tons of salt are expelled each year. [1] That much salt is bad in many ways beyond killing aquatic organisms.

And the textile industry uses a LOT of water – it’s the #1 industrial polluter of water on the planet.[2] In India alone textile effluent averages around 425,000,000 gallons per day, largely untreated[3].   The chemically infused effluent – saturated with dyes, de-foamers, detergents, bleaches, optical brighteners, equalizers and many other chemicals – is often released into the local river, where it enters the groundwater, drinking water, the habitat of flora and fauna, and our food chain. And we wonder why PBDE’s are found in practically every animal on earth?

Please refer to the  campaign by Greenpeace  on their efforts to clean up textile effluent (called “Dirty Laundry”: http://www.greenpeace.org/international/Global/international/publications/toxics/Water%202011/dirty-laundry-report.pdf), which points the finger at compliant corporations who support what they call the “broken system”. It asks corporations to become champions for a post toxic world, by putting in place policies to eliminate the use and release of all hazardous chemicals across a textile company’s entire supply chain based on a precautionary approach to chemicals management, to include the whole product lifecycle and releases from all pathways.

To our knowledge there are only three certifications which look at both the chemical toxicity of the inputs and which require water treatment:

  1. GOTS (Global Organic Textile Standard)
  2. Oeko Tex 100 Plus
  3. and GRS (Global Recycle Standard)

The Cradle to Cradle certification does not require water treatment at ANY level except Platinum – and even at that level, the requirement is written as follows: “(the company must) implement innovative measures to improve quality of water discharges”.   Not one textile has been awarded the Platinum certification from C2C to date.

[1] Dyeing for a change: Current Conventions and New Futures in the Textile Color Industry (2006, July) http://www.betterthinking.co.uk

[2] Cooper, Peter, “Clearer Communication”, Ecotextile News, May 2007

[3] CSE study on pollution of Bandi river by textile industries in Pali town, Centre for Science and Environment, New Delhi, May 2006 and “Socio-Economic, Environmental and Clean Technology Aspects of Textile Industries in Tiruppur, South India”, Prakash Nelliyat, Madras School of Economics. See also:  Jacks Gunnar et al (1995), “The Environmental Cost of T-Shirts”, Sharing Common Water Resources, First Policy Advisory Committee Meeting, SIDA, Madras Institute of Development Studies, Chennai.

Also: CSE: Down to Earth Supplement on Water use in India, “To use or to misuse”; http://www.cseindia.org/dte-supplement/industry20040215/misuse.htm

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