Proposed release guidelines for Disperse Yellow 3 and 25 other azo disperse dyes in the textile sector

February 2019

Abstract

Azo disperse dyes represent a significant proportion of the textile dye market. Disperse dyes are exclusively used for textile dyeing and are principally used in the dyeing of synthetic fibres such as polyester, polyester blends, cellulose acetate and nylon.  The present release guidelines address 26 azo disperse dyes with molar weights below 360 grams per mole (g/mol), including Disperse Yellow 3 (DY3) and 25 other azo disperse dyes. Exposures of concern for the 26 azo disperse dyes are their release to water resulting from textile dye formulation and textile dyeing activities.

Disperse Yellow 3 (DY3) is persistent and inherently toxic (PiT) to aquatic organisms, and was assessed under the Canadian Environmental Protection Act, 1999 (CEPA) as being harmful to the environment. DY3 is not manufactured in Canada, but is imported. The other 25 azo disperse dyes were identified as having potential ecological effects of concern, but are not in commerce in Canada.

The guidelines recommend limits, expressed as concentrations or quantities, for the release of the 26 azo dyes into the aquatic environment from textile dye formulation and textile dyeing activities. These guidelines cannot be used as a substitute for, or be in conflict with existing requirements.

The overall goal of these release guidelines is to recommend concentration limits for the release of DY3 and the 25 other azo disperse dyes with molar weights below 360 g/mol to levels below the predicted no effect concentration (PNEC) of 2.3 micrograms per litre (µg/L) at the final discharge point of textile facilities.

If you have any questions or require further information about these guidelines, please refer to the contact information in Appendix 6.

Abbreviations used in the guidelines

1. Introduction

Textile manufacturing is one of Canada’s oldest and most diverse industries. Textiles can be found in an array of applications such as clothing, transportation, medical, agriculture, civil engineering, packaging, protection, (individual, environmental) and construction. Approximately 90% of textile mills in Canada are micro businesses (i.e. less than 5 employees) or small businesses (i.e., 5 to 99 employees) (Industry Canada, 2012). They are part of a relatively small sector that, in 2010, constituted 0.05% of the Canadian Gross Domestic Product (Industry Canada 2011 and Statistics Canada 2011). The Canadian textile industry is mainly concentrated in Quebec and Ontario (Environment Canada 2005). Azo disperse dyes represent a significant proportion of the textile dye market. These dyes are exclusively used for textile dyeing, mainly of synthetic fibres such as polyester, polyester blends, cellulose acetate and nylon.

Azo disperse dyes were assessed under CEPA, which provides for a broad range of tools to achieve environmental protection objectives.  As a result of this assessment, it was determined that the most appropriate tool for managing Disperse Yellow 3 (DY3) and 25 other azo disperse dyes (listed in Appendix 1) is release guidelines. In the context of the Chemicals Management Plan (CMP), a Government of Canada initiative aimed at reducing the risks posed by chemicals to Canadians and their environment, azo disperse dyes were identified as having potential ecological effects when released to surface water. These releases were shown to occur during formulation and use of the textile dyes.

The present release guidelines recommend standard release limits and daily use limits for 26 azo disperse dyes with molar weights below 360 g/mol including DY3 and 25 other azo disperse dyes, used in specific textile activities (i.e. dye formulation and dyeing operations).

2. Targeted textile activities

The textile activities subject to the guidelines are:

3. Applicability

The guidelines apply to any person who:

• owns and operates a textile dye formulation and/or textile dyeing facility; and
• uses any of the 26 azo disperse dyes listed in Appendix 1; and
• releases an effluent containing any of the 26 azo disperse dyes at the final discharge point of the facility

4. Standards

4.1 Release limit

Overall release of the 26 azo disperse dyes at a facility’s final discharge point should not be in a concentration greater than:

A proposed method for determining effluent concentration is included in Appendix 2.

4.2 Daily use limit

Total daily use of the 26 azo disperse dyes should not be in a quantity greater than:

5. Alternatives

Facilities are encouraged, when appropriate, to use alternatives that reduce or minimize human health or environmental risks. It is important that the chosen alternatives are not azo disperse dyes with a molar weight below 360g/mol. Information on the chosen alternative(s) should be reported through the Declaration of the operator included in Appendix 3.

6. Declaration of the operator

The entities listed in Section 3 should inform in writing the Minister of the Environment of their intention to implement these guidelines by completing the Declaration of the operator no later than 6 months after the final publication of the guidelines or six months before the initial use of any of the 26 azo disperse dyes.

7. Monitoring and analysis

Any person/entity subject to these guidelines should continually monitor their activities on an ongoing basis to ensure conformity with the guidelines by:

• determining the quantity used and/or the concentration of the 26 azo disperse dyes released at their facility’s final discharge point for each day of use
• determining effluent concentration either by laboratory analysis or by following the method for determining effluent concentration included in Appendix 2; and
• recording the resulting information in the conformity evaluation report included in Appendix 4

Any analysis performed for the purposes of the guidelines must be conducted by a laboratory that is accredited under ISO and standard ISO/IEC 17025:2005, entitled General Requirements for the Competence of Testing and Calibration Laboratories, as amended from time to time.

8. Reporting

Any person/entity subject to these guidelines should:

• provide the first conformity evaluation report included in Appendix 4 to the Minister of Environment no later than one year after the final publication of the guidelines. Subsequently, a conformity evaluation report should be submitted if any of the 26 azo disperse dyes are still in use.
• record in the conformity evaluation report the quantity of azo disperse dye(s) released into the environment or to a wastewater system, each day the dyes are used, in order to verify conformity with the standards

Conformity evaluation reports should include the following:

If the approach used to calculate the concentration at a facility’s final discharge point differs from the method proposed in Appendix 2, a facility should submit a copy of the method used and the results obtained (e.g. chemical analysis) with the report.

9. Record keeping

Any person/entity subject to these guidelines should retain all records pertaining to these guidelines for at least five years beginning on the date of their creation and make them available to the Minister of the Environment upon request. It is important that the company keep all such records; as well as reported instances of spills, leak detection and repairs, annual estimates of releases, stock supply, quantity used, concentration estimated, laboratory analysis data, use dates, batch number etc.

10. Verification

Verification activities will be carried out six months after the facilities’ annual reports have been received. Site visits of selected facilities by Environment and Climate Change Canada (ECCC) representatives will help confirm the accuracy of the reported data. ECCC will verify the current use/processes involving the 26 azo disperse dyes and determine the end of use if applicable. This includes verifying the equipment and the machinery used inside the facility, as well as the implementation of the recommended best practices and record keeping activities in the facility, as outlined in these guidelines.  Additionally, verifiers may ask to review records and auxiliary data, obtain information through interviews or ask for supplemental documentation.

11. Confidentiality

In accordance with section 313 of the act, any person who submits information under these guidelines could request that the information be treated as confidential.

12. Best practices

The following are the proposed best practices to mitigate releases of the 26 azo disperse dyes. These best practices should be implemented across the facility where chemicals are handled.

12.1 Training on operational procedures

A training program should be established by the facility to ensure that all employees and contractors are familiar with the various best practices to minimize environmental releases of the 26 azo disperse dyes. It is recommended that the training utilizes various communication methods such as videos, presentations, group discussions and e-learning to ensure employees and contractors are aware of operational procedures. This training could also provide employees and contractors with knowledge on other environmental policies and procedures.

The facility should include environmental responsibilities in job descriptions, incorporate environmental performance into job evaluations and look for ways to improve performance. Specific employee awareness campaigns and communication tools such as posters and flyers should be placed across the facility in strategic locations (cafeterias, washrooms, front desk, main entrance, etc.) where they will best capture the attention of employees and contractors.

12.2 Reception of chemicals

Only individuals with current training should be permitted to use, handle and transport chemicals including chemical waste. The facility’s loading/unloading area should:

12.3 Use

The dates should be recorded and displayed on chemical containers once they are opened. This will help reduce waste by ensuring chemicals are used before they expire. Computer inventory control should be used to minimize the amount of stock purchased.

12.4 Storage

Chemicals should be stored according to need, with minimal product inventory kept on hand. Inventory information should be recorded and maintained up-to-date at all times. Chemical containers should be kept tightly sealed, covered and stored upright in order to reduce potential leaks, spills and evaporation.

Appropriate physical storage consideration may include specific temperature, pressure and humidity, incompatibilities with other potentially stored materials, etc. These considerations are usually described in Material Safety Data Sheets and/or are available from the supplier.

Importantly, chemicals should be stored away from sewers, drains, and other openings that may allow environmental releases in the event of an undetected leak.

12.5 Transfer of chemicals

Chemical substances transferred from storage containers into processing vessels for production operations can result in unintended releases. There is often precise handling guidelines outlined for specific substances or substance groups, and the facility operators should be cognizant of which practices should be applied within their facilities. Regardless of the type of container utilized, all employees and contractors involved in transferring of chemicals should be fully trained to understand the contents of containers and prevent spills.

Proper precautions should be exercised at all times to prevent spills during transfers operations. These precautions and procedures should be documented in work instructions or protocols. Some best practices for transferring chemicals may include the following:

12.6 Production operations

Production processes within the facility are potentially key sources of releases of the 26 azo disperse dyes into the environment. Owners and operators of facilities should contact their respective industry association and, if available, review relevant references, and consult with technology vendors and experts to gather information on best practices and controls related to individual production processes.

Overall, facilities in the textile sector should review their individual wastewater systems and make any necessary modifications to ensure that they are operating at peak performance.

12.7 Packaging, loading and shipping

Facilities should engage with transportation partners and logistics service providers to ensure that they have properly implemented chemical spill prevention procedures, as losses can occur at transport interfaces (loading, unloading, and handling) during transport from the distributor to end-user.

Chemicals should be received in sealed containers. The condition of packaging should be inspected and documented before offloading in order to detect any potential leaks.  If the shipment is significantly damaged, notify the transporter and importer. Consider refusing to accept delivery. Punctured packages should be repaired or replaced immediately and any spills should be cleaned-up immediately to prevent environmental releases. Packaging should be designed to minimize the possibility of breakage and subsequent chemical leakage. Proper bags should be selected to help reduce damage.

12.8 Container/tank cleaning

There are a number of methods for cleaning drums and totes, but a method that produces the least waste is normally environmentally and often economically advantageous.

If tanks or containers are cleaned with water at the facility, the aqueous rinsate from this process should be collected for on-site disposal and meet proposed discharge limitations prior to being discharged to the municipal wastewater system or transferred to an off-site disposal facility.

Equipment that may require cleaning may include weigh scales, blenders, transfer bins, metering devices, melt processor hoppers, etc.

12.9 On-site waste management and handling

Facilities should develop and implement a waste management plan covering all aspects of waste management at their site. This waste management plan should address opportunities for recycling/reuse of waste materials as well as the disposal of waste materials.

A designated safe storage area should be made available for hazardous and liquid waste. Waste should also be designated, clearly labeled and kept in appropriate containers in closed areas. Efforts should be made to ensure waste containers are suitable for the specific chemicals.

Waste should be transported in completely sealed containers to avoid possible releases into the environment. Facilities should routinely inspect and confirm the proper handling and storage procedures are in place. If an outside carrier/collector is used for waste removal to an off-site disposal facility, the disposal company should provide a written confirmation that the waste will be disposed of in the manner agreed to.

Totes and drums can be reused, recycled, or disposed of depending on the supplier and user’s circumstances. After the contents are used, and before the packaging is returned to a designated handler, it is important to properly seal the empty package by closing valves, caps, lids, etc. This will prevent losses of residual product from the package into the environment.

12.10 Maintenance and housekeeping operations

In regards to maintenance of equipment, an effective maintenance programs should be in place. This program should require all equipment (owned, leased or subcontracted) to be adequately maintained to prevent and detect defects before they cause spills/leaks. Employees and contractors should repair leaks and other problems immediately as they occur in order to reduce cleaning efforts, extend the life of the equipment and reduce the consumption of raw materials/avoid loss of manufactured product.

Facility operators should establish schedule for maintaining and cleaning equipment employed at the facility and ensure that the schedule is adhered to. Maintenance procedures should deal with the control of chemical losses, disposal of fugitive process materials and proper handling of personal protective equipment and tools that may have come into contact with various chemicals.

12.11 Spills and leaks

In the event of a spill of any of the 26 azo disperse dyes, the facility should immediately take all necessary measures to contain and prevent releases into the environment. The first priority is to minimize the amount of the spill and to cover all drains in the surrounding area. Isolate or interrupt the flow by immediately closing valves, rotating drums or transferring the contents to minimize the spill.

Spill kits with materials (e.g., absorbents, neutralizing agents, clean-up tools, etc.) should be immediately available and easily accessible to contain, clean-up and securely store the spilled materials. These kits should be made available in the vicinity of areas where a risk of spills occurring has been identified (e.g., chemical storage rooms). These spill kits should be maintained on a regular basis to ensure that they are always available and fit for the intended purpose. This ensures that the most appropriate measure is available to deal with a spill in the most effective way.

All persons or entities are encouraged to track all spills and to document the cause, response, and take steps to prevent their recurrence. Advanced planning to prevent/address such incidents, in the form of written procedures (i.e., a spill prevention and management plan) for spill prevention, containment and cleanup, should be undertaken by all facilities.

12.12 Risk communication and transparency

It’s recommended that dye formulators and dye providers/ distributors include information on the ecological risks of the 26 azo disperse dyes and the guidelines, upon transfer of dye products containing any of the 26 azo disperse dyes to another person, such as a textile dyeing facility. Approaches to providing the information could include, but are not limited to, package labelling, information sheets or inclusion in Safety Data Sheets.

References

Cheminfo 2018. Environmental Management Practices Guidelines for the Management and Handling of Chemical Substances, Final Guidelines. Submitted to Environment Canada by Cheminfo Services Inc., February 28, 2018

Canada. 2017a. Dept. of the Environment, Dept. of Health. Consultation Document on the Options for Addressing Certain Aromatic Azo and Benzidine-Based Substances with Effects of Concern.

Canada. 2017b. Dept. of the Environment and Dept. of Health. Canadian Environmental Protection Act, 1999: Notice with respect to certain Azo Disperse Dyes substances. Canada Gazette, Part I, vol. 151, no. 10, p. 1086 to 1101.

Canada. 2017c. Dept. of the Environment, Dept. of Health. Screening Assessment of Certain Azo Disperse Dyes.

Canada. 2017d. Risk Management Approach for Acetamide, N-[4-[(2-hydroxy-5-methylphenyl)azo]phenyl]- (Disperse Yellow 3), Chemical Abstracts Service Registry Number 2832-40-8 (PDF 170KB).

Canada. 2016b. Screening Assessment, Aromatic Azo and Benzidine-based Substance Grouping, Azo Solvent Dyes.

Canada. 2016c. Screening Assessment, Aromatic Azo and Benzidine-based Substance Grouping, Monoazo Pigments.

Canada. 2016d. Screening Assessment, Aromatic Azo and Benzidine-based Substance Grouping, Certain Azo Acid Dyes.

Canada. 2016e. Screening Assessment, Aromatic Azo and Benzidine-based Substance Grouping, Azo Basic Dyes.

Industry Canada, 2012: Canadian Industry Statistics (CIS): Textile Mills (NAICS 313): Establishments).

Statistics Canada, 2011: Real Gross Domestic Product, expenditure-based, by province and territory.

FINTEX 2008. Étude technique sur certaines substances du défi en vertu du plan de gestion des produits chimiques, d’intérêt et présentes dans l’industrie textile. Phase II, Rapport final. Soumis à Environnement Canada par FINTEX méchanique et procédés inc, Octobre 2008

Environment and Climate Change Canada 2005. Risk Management Strategy in Respect of Effluents from Textile Mills that Use Wet Processing (TMEs) and Nonylphenol (NP) and its Ethoxylates (NPEs) Under CEPA (revised 2005). (PDF 86KB)

Environment and Climate Change Canada and Health Canada, 2001: Environment and Climate Change Canada and Health Canada 2001b. Priority Substances List Assessment Report. Textile Mill Effluents.

Appendix 1 – Chemical Abstract Service Registry Number (CAS RN) and Domestic Substance List (DSL) name of azo disperse dyes with molar weights below 360 g/mol

^a Meets one or more criteria under section 64 of CEPA

^b Substance with both ecological and human health effects of concern

Appendix 2 - Proposed method for estimating effluent concentrations

Textile dye formulation and textile dyeing activities

The effluent concentrations of the 26 azo disperse dyes (including DY3 and 25 other azo disperse dyes) at the facility final discharge point should be calculated as follow:

DRQS = Daily release quantity to the sewer system (kg/day)

   = DUQ × EF × (1-WTR)
   = DUQ × 0.011 × (1-0.262)

DUQ = Daily use quantity (kg/day)

EF = Emission factor to wastewater = 1.1% = 0.011 (see Appendix E of the FSAR)

WTR = Wastewater treatment removal = 26.2% = 0.262 (see Appendix E of the FSAR)

C = Concentration at the facility final discharge point (ug/L or mg/L)

Nb = Number of batches/day

Vb= Volume of each batch

Appendix 3 - Declaration of the operator

This form may be used as a template for the purpose of Section 6 of the guidelines.

Name and civic address of the mill/facility:

______________________________________________________________________________________________________________

______________________________________________________________________________________________________________

Declaration: (choose one)

◻   Our mill/facility is not using any of the substances subject to the guidelines.

◻  Our mill/facility will no longer be using substances subject to the guidelines starting (year/month/day)    _________________________.

◻   Our mill/facility currently uses at least one of the substances subject to the guidelines for textile dyeing and textile dye formulation and we plan to conform to the guidelines. 

• A list of substances used is attached

◻  Our mill/facility currently uses alternatives to the substances subject to the guidelines for textile dyeing and textile dye formulation.

• A list of alternatives used, along with their CAS RNs and the supplier(s), is attached.

◻   Our mill/facility does not plan to conform to the guidelines.

____________________________
Operator name (print)

____________________________
Title

____________________________
Telephone

____________________________
Email

____________________________
Operator signature

____________________________
Date of signature

Please return this form to:

Environment and Climate Change Canada
351 St. Joseph Blvd
Gatineau (QC) K1A 0H3

Fax: 819-420-7386 or toll free 1-844-580-3637
Email address: ec.RG-DR.ec.@canada.ca

Subject: “Release guidelines for Disperse Yellow 3 and 25 other azo disperse dyes“

Appendix 4 - Conformity evaluation report

This form may be used as a template for the purpose of Section 8 of the guidelines.

Name and civic address of the mill/facility:

___________________________________________________________________________________________

___________________________________________________________________________________________

Period covered by the report: from ___________________________ to __________________________________

Please provide information for each day of using of any of the 26 azo disperse dyes in a textile dye formulation or textile dyeing operation

(1) Each facility should consider its own emission factor to wastewater, if available. If not, refer to the emission factors included in Appendix E of the FSAR

(2) Refer to the proposed method for estimating effluent concentrations, included in Appendix 2. If the method used differs from this approach, include a copy of the method used with the report

(3) The method to calculate a facility’s Predicted Environmental Concentration (PEC) is included in Appendix 5

____________________________
Operator name (print)

____________________________
Title

____________________________
Telephone

____________________________
Email

____________________________
Operator signature

____________________________
Date of signature

Please return this form to:

Environment and Climate Change Canada
351 St. Joseph Blvd
Gatineau (QC) K1A 0H3

Fax: 819-420-7386 or toll free 1-844-580-3637
Email address: ec.RG-DR.ec.@canada.ca

Subject: “Release guidelines for Disperse Yellow 3 and 25 other azo disperse dyes“

Appendix 5 - Method to calculate a facility-specific predicted environmental concentration (PEC) in surface water

PEC = Predicted environmental concentration (μg/L)

DRQS = Daily release quantity to the sewer system (see Appendix 2)

WTR = wastewater treatment removal = 0.262 (see Appendix E of the FSAR)

Receiving water dilution factor = 10 (see Appendix E of the FSAR)

Flow: Each mill/facility should consider the flow (L/day) related to its off-site wastewater treatment system receiving the treated wastewater, if available. If not, refer to the flow estimated in Appendix E of the FSAR

Appendix 6 - Participants in the development of the guideline

Please send your comments to the below, indicating that the comments relate to these proposed release guidelines for Disperse Yellow 3 and 25 other azo disperse dyes in the textile sector:

Contact information

Innovative Measures Section
Environment and Climate Change Canada
351 Saint-Joseph Boulevard
Gatineau (QC)  K1A 0H3
Phone number: 1-844-580-3637 (information)
Fax number: 819-420-7386 or toll free 1-844-580-3637
Email address: ec.RG-DR.ec@canada.ca
Subject: “Release Guidelines for Disperse Yellow 3 and 25 other azo disperse dyes“

For technical questions or comments about theses proposed Guidelines, please contact or send queries to:

Products Division
Environment and Climate Change Canada
351 Saint-Joseph Boulevard 9th Floor
Gatineau (QC)  K1A 0H3
Phone number: 819-938-4483 / 1-888-391-3426 (information)
Fax number: 819-938-4480 / 1-888-391-3695
Email address: ec.produits-products.ec.@canada.ca
Subject: “Release Guidelines for Disperse Yellow 3 and 25 other azo disperse dyes“