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Wastewater
Guidelines Draft V.3
DRAFT
Signatory Brands
Value-Chain Affiliates
Associates
1
Contents
A Introduction 4 Appendix A
B Definitions and Abbreviations 6
C Scope 8 1. Limits and Test Methods for Targeted (Conventional and MRSL 22
D Disclaimer 10 Wastewater Parameters)
Appendix B
2 3
A. Introduction
Objectives
Overview These guidelines include analytical test Hazardous Chemicals and included in the
These guidlines build upon ZHDC’s methods and sampling procedures, with ZDHC MRSL.
The Zero Discharge of Hazardous Manufacturing Restricted Substances the ultimate objective of allowing ZDHC
Chemicals (ZDHC) Programme represents List (MRSL) which is a list of chemical brands1 and suppliers to share their testing These chemical groups have been peer
over 20 leading textile and footwear brands substances banned from intentional use in results in a systematic and efficient manner reviewed by independent third-party
committed to eliminating hazardous facilities that process textile materials and via a ZDHC Portal. technical experts and industry associations
chemicals from the global value-chain. trim parts in apparel and footwear. involved in the production of key raw
The expected outcomes of utilising these materials, and include:
The purpose of the ZDHC Programme’s Prevention of water contamination requires guidelines are to:
Wastewater Guidelines is to define a that facilities avoid the use of restricted 1 | Alkylphenol (AP) and Alkylphenol
single, unified expectation concerning chemical substances by using chemical 1 | Ensure wastewater discharge does not Ethoxylates (APEOs), including all
wastewater discharge quality that goes formulations that conform to the ZDHC have an adverse impact on communities isomers
beyond regulatory compliance, not only for MRSL. In addition, prevention of water and the environment. 2 | Chlorobenzenes, Chlorotoluenes,
conventional wastewater parameters, but contamination also requires that facilities 2 | Create a unified monitoring and testing 3 | Chlorophenols
also for hazardous chemicals. ensure wastewater leaving the facility is programme to aid suppliers to 4 | Dyes
properly treated prior to discharge, or sent systemically and efficiently share 4.1 Azo (Forming Restricted Amines)
Currently, wastewater guidelines published to a well-operated central treatment facility. discharge data with consumers, 4.2 Carcinogenic or Equivalent
by different brands, as well as amongst brands, and other interested agencies. Concern
multi-brand consortia, vary greatly. ZDHC brands remain committed to the 3 | Reduce supplier operating costs 4.3 Disperse (Sensitising)
Furthermore, many current regulations target of zero discharge of hazardous and increase operational efficiencies 5 | Flame Retardants
are far from requiring zero discharge of chemicals by 2020. As an important by eliminating gaps and redundancies 6 | Glycols
hazardous chemicals. step towards this goal, in 2015, the ZDHC in wastewater testing and reporting 7 | Halogenated Solvents
Programme commissioned a study to better requirements. 8 | Organotin Compounds
The ZDHC Programme recognises the value understand the regulatory landscape of 9 | Perfluorinated and Polyfluorinated
of addressing hazardous substances that wastewater discharge regulations and These guidelines address conventional Chemicals (PFCs)
may be discharged into the environment guidelines across the textile industry. wastewater discharge parameters such as 10 | Ortho-Phthalates – Including all
during the manufacture of materials used pH, BOD, COD, etc, as noted in Table 1 in ortho esters of phthalic acid
in the textile and footwear industry. That is, This report – Textile Industry Wastewater Appendix A. 11 | Polycyclic Aromatic Hydrocarbons
hazardous substances that could be used Discharge Quality Standards Literature (PAHs)
deep within the value-chain and not just Review – demonstrated the need for These guidelines also address the original 12 | Volatile Organic Compounds (VOC)
those substances that could be present in uniform, global guidance pertaining to priority chemical groups outlined in the 13 | Heavy Metals
finished goods. wastewater discharge to enable a more Joint Roadmap to Zero Discharge of
sustainable industry.
1 Potentially also SAC brands and their suppliers, bluesign member brands, etc.
4 5
B. Definitions and Abbreviations Abbreviations
Definitions AOX Adsorbable organic halogens, where 'X' represents the halogens chlorine, bromine and iodine
AP Alkylphenol
parameters such as temperature, pH, properties in wastewater prior to the BOD5 Biochemical oxygen demand (5 days)
biological oxygen demand, chemical oxygen indirect discharge of the wastewater into a °C Degrees Celsius
on those parameters with foundational, using hazardous chemicals. ZDHC brands DIN Deutsches Institut für Normung (German Institute of Standards)
progressive and aspirational limit values. monitor zero discharge by testing DL Detection Limit
conveyance or system such as outlet pipes HJ Chinese required environmental protection standard (Chinese industry standard)
are direct dischargers. ZDHC MRSL: Manufacturing Restricted HJ/T Chinese recommended environmental protection standard (Chinese industry standard)
Substances List developed by the ZDHC IPE Institute of Public & Environmental Affairs
(vPvB); carcinogenic, mutagenic and toxic storing and analysing water and wastewater ml Millilitre
for reproduction (CMR); endocrine disrup- test results for the ZDHC value-chain. µg/L Microgram(s) per litre
MS Mass spectrometry
tors (ED)].
MSMS Tandem mass spectrometry
6 7
Abbreviations: • For direct discharge, all parameters covered by these guidelines apply.
P Phosphorous
• For indirect discharge, the coverage of these guidelines will be limited to ZDHC
PAHs Polycyclic aromatic hydrocarbons
MRSL banned parameters (Table 2A-2N), recognising the requirements for
Pb Lead
8 9
D. Disclaimer
10 11
The Guidelines
3 | Sampling
A. Three-Level Approach 3.1 The number and type of sampling points for direct and indirect discharge follows
internationally accepted, recognised methodologies and defines the locations where
1 | As manufacturing facilities are not identical in terms of capabilities, knowledge, samples, including incoming water, need to be taken on a fixed frequency (at least twice
strategic priorities, and resources, these guidelines provide a three-level approach a year depending on production peaks). For more detail, refer to section C.
for wastewater discharge limits which is consistent with other collaborations,
including the Stockholm International Water Institute (SIWI), the Sustainable Apparel 4 | ZDHC Accepted Laboratories
Coalition (SAC), and the Outdoor Industry Association (OIA) to develop industry tools 4.1 ISO 17025 Accreditation.
and guidance. The intent is that suppliers are actively executing a continuous 4.2 Experience in wastewater testing.
improvement plan to reach the next level. 4.3 Passing an internal correlation test organised by the ZDHC Programme,
or one of the established ZDHC accepted laboratories1.
The three levels are:
Foundational: At a minimum, meets legal discharge requirements and ensures effective 5 | Data Reporting
control of ZDHC MRSL chemicals. 5.1 These guidelines seek to establish a unified reporting structure to simplify
Progressive: Demonstrates increasing knowledge of chemical management and and enable efficiency in reporting results to regulatory authorities, brands,
applies advanced wastewater treatment processes. and other relevant stakeholders.
Aspirational: Demonstrates best-in-class performance and strives for continuous 5.2 The suppliers discharging wastewater own their respective water and
improvement in both chemicals and wastewater treatment process knowledge; creates wastewater test reports and must authorise the disclosure of the data to the
industry best practices. ZDHC Portal.
12 13
3.2 (Optional) Incoming Freshwater
C. Sampling a. Freshwater shall be sampled at the point where the freshwater
enters the facility, and prior to any on-site treatment of the freshwater.
1 | This section outlines the recommended sample points to fulfill the requirements b. The intent of collecting this sample is to assist with point-source
of these guidelines. identification of hazardous chemicals in the event the wastewater test
results indicate a hazardous chemical above the reporting limits.
2 | Each facility is expected to develop facility-specific sampling procedures, documenting c. In the event that a wastewater sample analysis results in a hazardous
the locations of each of the sampling points. Documentation may include: Written chemical above the reporting limits outlined in Appendix A,
description within the documented procedures, photographs, or signs at the sample the freshwater sample shall be analysed to determine if the
locations identifying the points as sample points. freshwater is contributing to the hazardous chemicals identified in
the wastewater.
3 | Minimum Required Sampling Point Locations and Methods d. In the event that a wastewater sample analysis does not result in any
3.1 Discharged Wastewater hazardous chemicals above the reporting limit, this sample can be
a. Wastewater sampling shall occur at the most feasible location closest discarded without testing.
to the point where the wastewater leaves the property of the
manufacturing facility. 4| (Optional, but recommended) Sludge:
b. In the event that a facility has multiple permitted discharge locations, 4.1 Sludge analysis is considered another indicator of verifying MRSL compliance,
each discharge location shall have a sampling point, and sampling but limit values have yet to be determined.
shall occur independently at each sampling point in accordance
with these guidelines. 5| Sampling Methodology
c. For instances where sampling at multiple wastewater discharge 5.1 Wastewater and freshwater samples shall be collected as composite samples
locations occurs, each wastewater sample taken shall be tested following the general guidance in Standard Methods for the Examination of
independently of the others; at no time should the wastewater Water and Wastewater, 21st edition, Method 1060, Collection and Preservation
samples be blended. of Samples; or in accordance with applicable local or national standards.
d. Wastewater being sampled shall be of the same quality which is 5.2 To ensure representative samples, composite sampling should be performed
discharged to beyond the facility property boundary. for no less than eight hours, with no more than one hour between discrete
e. Alteration of the wastewater quality flow rate downstream of the samples. Each discrete sample shall be of equal volume. Sampling using
sampling point is prohibited. calibrated autosamplers is preferred, but in instances where national standards
do not require autosampling (for example, in Thailand and Mexico), laboratory
3.2 (Optional) Raw Wastewater personnel collecting samples are expected to meet the requirements of national
a. Sampling of raw wastewater for testing of ZDHC MRSL parameters standards.
may be added as an optional requirement by ZDHC brands. 5.3 Wastewater and freshwater samples should, as much as possible, be collected
Raw wastewater testing will give further insights into the usage of simultaneously.
ZDHC MRSL chemicals which may be diverted into the sludge during 5.4 Consult ISO 5667- 1, 3, 10, 13 and 15 Water Quality Sampling Guidance
wastewater treatment. for the preservation and handling of water samples.
14 15
Sampling points for facility with indirect discharge; WWTP is
5.5 Samples shall be taken by a qualified third-party or by specially managed by third-party, or, optionally, company has pre-treatment
trained staff. (equalisation, buffering etc) on-site:
5.6 In no circumstance shall samples be taken during times when the
production process is not running or the wastewater is diluted due to
heavy rainfall, etc.
5.7 Suppliers are expected to allow for unannounced sampling by ZDHC
accepted laboratories.
16 17
D. Data Reporting
1| To optimise ZDHC wastewater testing, first test the sample of wastewater before 6.1 Notify
or after treatment. If there are no results above the reporting limit for MRSL a. Regional authorities for any permit/legal value excursion(s).
substances, then the wastewater is considered acceptable and no further testing for b. ZDHC brands and/or other customers and submit a corrective action
ZDHC MRSL parameters is required, until the next regularly scheduled wastewater plan with a defined completion date for resolution of the excursion.
testing date. 6.2 Upload the root cause analysis and corrective action plan to the ZDHC portal.
6.3 Re-sample in accordance with the flowchart provided in Appendix B.
2| In the event that a ZDHC MRSL parameter has a concentration above the reporting
limit, proceed with analysis of fresh incoming water to determine if: 7 | The ZDHC Programme will provide its contributor brands and affiliated organisations
1.1 The ZDHC MRSL parameter in the incoming water is above with access to extract this data and run reports on their respective suppliers.
the reporting limit (freshwater analysis).
1.2 All lab data from incoming freshwater and outgoing wastewater 8 | To enable widespread adoption of these guidelines, and to optimise wastewater
discharge shall be reported to the ZDHC Portal in case background sampling across the value-chain, the ZDHC Programme is collaborating with
concentration is indicated as the reason for MRSL substances above reporting other industry organisations such as the Sustainable Apparel Coalition (SAC),
limits in the wastewater. the Outdoor Industry Association (OIA) and the Institute of Public & Environmental
Affairs (IPE) to enable data sharing capabilities.
3 | Conventional parameter testing and reporting is required for the wastewater at
the final monitoring point at the facility where an onsite treatment plant is in place. 9 | The ZDHC Programme will make the wastewater test reports available to the public
via the ZDHC website. The reporting system is currently being developed and is set
4 | Facilities which discharge into centralised wastewater treatment plants, will be asked to launch end of 2016.
to disclose agreed limits of conventional wastewater parameters and relevant test
reports. E. Schedule
5 | After permission from suppliers, wastewater test reports from ZDHC-accepted 1 | It is expected that every supplier discharging wastewater has a license to
laboratories will be reported directly by laboratories to ZDHC brands via the ZDHC operate and is currently and continually compliant with legal, permitted limits
portal on the ZDHC website, making best use of available data standards. set by local or regional authorities.
For any additional testing that may occur (beyond these guidelines),
the manufacturing facility is encouraged to upload the data to the ZDHC Portal. 2 | Foundational limits for Conventional Parameters (Table 1) are expected to be already
met by suppliers upon publishing of these guidelines. If the foundational limits are
6 | In the event that a test report value either exceeds a foundational limit value for more restrictive than the supplier’s legal, permitted limits, suppliers are expected to
conventional parameters, or reporting limit for the ZDHC MRSL (as listed in meet compliance with foundational limits within a period of six months from the
Appendix A), or exceeds a legal permit limit, then the manufacturing facility is publishing of these guidelines.
expected to:
18 19
F. Related Work, Relevant Organisations and Contributions
3| Progressive limits for Conventional Parameters (Table 1) are expected to be met
or exceeded by: Related Work
3.1 Brand new facilities, including wastewater treatment, that is operational 1| Joint Roadmap for Zero Discharge of Hazardous Chemicals
after January 1, 2018. 2| World Health Organization – Making Water a Part of Economic Development
3.2 A current facility, but with a new onsite wastewater treatment facility 3| Textile Industry Wastewater Discharge Quality Standards Guidelines Literature Review
that is operational after January 1, 2018. 4| Business for Social Responsibility (BSR) Guidelines 2010
3.3 A current production facility that undergoes enhancement and/or expansion 5| ZDHC Manufacturing Restricted Substances List V1.1
that is operational after January 1, 2018.
3.4 An enhancement, expansion, or modification to an existing wastewater Relevant Organisations
treatment facility that is operational after January 1, 2018. 1| The International Organisation for Standardisation. http://www.iso.org/
2| Sustainable Apparel Coalition. http://apparelcoalition.org/
All facilities are encouraged to meet aspirational or progressive limits as early as possible 3| Leather Working Group. http://www.leatherworkinggroup.com/
and share best practices on how to achieve it. 4| Stockholm International Water Institute. http://www.siwi.org/
5| Institute of Public & Environmental Affairs (IPE). http://www.ipe.org.cn/
4 | Aspirational limits for Conventional parameters (Table 1) are expected to be met by 6| Solidaridad. http://www.solidaridad.nl/
January 1, 2020. Suppliers are encouraged to continuously improve to achieve one
of the following: With thanks to all contributors who have assisted in the development of these
4.1 Attain and demonstrate performance that meets or exceeds aspirational guidelines, including:
performance; or 1| Charlie He / Carollo Engineers Inc. http://www.carollo.com/
4.2 In the absence of aspirational performance, attain and demonstrate 2| Dr. Dirk Czarnowski, ITS. http://www.intertek.com/
progressive performance, and have a plan with deadlines in place to achieve 3| Dr. Thomas Schaefer / bluesign technologies. http://www.bluesign.com/
aspirational performance. 4| Mohan Seneviratne, IFC. http://www.ifc.org/
5| Prof. Danli Xi, Shanghai University. http://en.shu.edu.cn/
5 | Reporting limits for ZDHC MRSL parameters (Tables 2A to 2N) are expected to be fully 6| Nathan Zaugg / MWH Global. http://www.mwhglobal.com/
met by suppliers by January 1, 2020. From January 2018, ZDHC expects suppliers to be
able to provide evidence of a progressive phase-out schedule in order to reach the
2020 goal.
20 21
Appendix A
Limits and Test Methods for Targeted (Conventional and ZDHC MRSL) Wastewater
Parameters
22 23
Limits Standard Test Method
Conventional Parameters + sum anions +
Table 1: metals (mg/L unless otherwise noted)
Foundational Progressive Aspirational ISO European Union United States China
Conventional parameters
showing foundational,
Temperature [°C] Δ15 or 35 Δ10 or 30 Δ5 or 25 No standard USEPA 170.1 GB/T 13195
progressive, and aspi-
rational limits; and the
TSS 50 15 5 ISO 11923 USEPA 160.2, APHA 2540D GB/T 11901
standard test methods
for measurement. It is
expected that suppliers COD 150 80 40 ISO 6060** USEPA 410.4, APHA 5220D** GB/T 11914**
will use the standard
methods that best apply
USEPA 351.2, APHA 4500P-J,
to their region. When Total-N 30 10 5 ISO 5663, ISO 29441 HJ 636, GB 11891
APHA 4500N-C
reporting data, state the
standard test methods
used to obtain the data. pH 6-9 ISO 10523 DIN EN ISO 10523 USEPA 150.1 GB/T 6920
ISO 11732.
Ammonium-N 10 1 0.5 DIN EN ISO 11732 USEPA 350.1, APHA 4500 NH₃-N HJ 535, HJ 536
ISO 7150
ISO 11885,
Total-P 3 0.5 0.1 DIN EN ISO 11885 USEPA 365.4, APHA 4500P-J GB/T 11893
ISO 6878
AOX 5 1 0.1 ISO 9562 DIN EN ISO 9563 USEPA 1650 HJ/T 83-2001
Oil and Grease 10 2 0.5 ISO 9377-2 DIN EN ISO 9377-2 USEPA 1664 HJ 637
Phenol 0.5 0.01 0.001 ISO 14402 DIN EN ISO 14402 APHA 5530 B, C&D HJ 503
Coliform [bacteria/100 ml] 400 100 25 ISO 9308 DIN EN ISO 9308 USEPA 9132 GB/T 5750.12
Anions
Sulfide 0.5 0.05 0.01 ISO 10530 APHA 4500-S2-D GB/T 16489
Sulfite 2 0.5 0.2 ISO 10304-3 DIN EN ISO 10304-3 USEPA 377.1
Metals
Chromium (VI) 0.05 0.005 0.001 ISO 18412 DIN EN ISO 18412 USEPA 218.6 GB 7467
24 25
Reporting limits mentioned in the following tables (2A - 2N) apply to
Table 2B:
each single chemical substance of the respective substance group.
Chlorobenzenes and
Chlorotoluenes
Substance or Sub- Reporting Limit Standard Test
CAS
stance Group (µg/L) Method
Table 2A:
1,2-Dichlorobenzene 95-50-1
Alkylphenol (AP) and
Alkylphenol Ethoxyl- 1,3-Dichlorobenzene 541-73-1
Substance or Reporting Limit Standard Test
ates (APEOs): Including CAS
Substance Group (µg/L) Method 1,4-Dichlorobenzene 106-46-7
All Isomers
1,2,3-Trichlorobenzene 87-61-6
104-40-5
1,2,4-Trichlorobenzene 120-82-1
Nonylphenol (NP), 11066-49-2
mixed isomers 25154-52-3 1,3,5-Trichlorobenzene 108-70-3
84852-15-3
NP/OP: ISO 18857 1,2,3,4-Tetrachloroben-
634-66-2
-2 (modified zene
140-66-9 dichloromethane
Octylphenol (OP), 1806-26-4 extraction) or ASTM 1,2,3,5-Tetracloroben-
634-90-2
mixed isomers 27193-28-8 D7065 (GC/MS or zene
LC/MS(-MS)
1,2,4,5-Tetrachloroben-
95-94-3
5 OPEO/NPEO: ISO zene
9002-93-1 18857 -2 or ASTM
Pentachlorobenzene 608-93-5
Octylphenol ethoxyl- 9036-19-5 D7065(LC/MS; GC/
ates (OPEO) 68987-90-6 MS or LC/MSMS for Hexachlorobenzene 1198-74-1
n=1,2)
2-Chlorotoluene 95-49-8
9016-45-9 APEO 1-18
3-Chlorotoluene 108-41-8
26027-38-3
Nonylphenol 37205-87-1 4-Chlorotoluene 106-43-4 USEPA 8260B,
ethoxylates (NPEO) 68412-54-4 8270D.
127087-87-0 2,3-Dichlorotoluene 32768-54-0
Dichloromethane
2,4-Dichlorotoluene 95-73-8 0.2
extraction
followed by GC/
2,5-Dichlorotoluene 19398-61-9
MS
2,6-Dichlorotoluene 118-69-4
3,4-Dichlorotoluene 95-75-0
2,3,6-Trichlorotoluene 2077-46-5
2,4,5-Trichlorotoluene 6639-30-1
Alpha,2,4-Trichlorotolu-
94-99-5
ene
Alpha,2,6-Trichlorotolu-
2014-83-7
ene
Alpha,3,4-Trichlorotolu-
102-47-6
ene
Alpha, alpha,2,6-tetra-
81-19-6
chlorotoluene
Alpha, alpha,alpha,
5216-25-1
4-tetrachlorotoluene
Pentachlorotoluene 877-11-2
26 27
Table 2C: Table 2D:
4-chloroaniline 106-47-8
2,3,4,6-tetrachlorophenol 58-90-2 3,3’-dimethoxylbenzi-
119-90-4
dine
6-methoxy-m-toluidine 120-71-8
2-chlorophenol 95-57-8
2,4,5-trimethylaniline 137-17-7
4,4’-thiodianiline 139-65-1
2,4-dichlorophenol 120-83-2
4-aminoazobenzene 60-09-3
2,5-dichlorophenol 583-78-8 4-methoxy-m-phenyl- EN 14362.
615-05-4
enediamine
USEPA 8270 D. Reduction step
2,6-dichlorophenol 87-65-0 4,4’-methylene-
838-88-0 with Sodiumdi-
di-o-toluidine 0.1
Solvent extraction, thionite, solvent
derivatisation with 2,6-xylidine 87-62-7 extraction, GC/
2,4,5-trichlorophenol 95-95-4 0.5
KOH, acetic MS or LC/MS
anhydride followed o-anisidine 90-04-0
by GC/MS
2,4,6-trichlorophenol 88-06-2
2-naphthylamine 91-59-8
3,’3-dichlorobenzidine 91-94-1
3,5-dichlorophenol 591-35-5
4-aminodiphenyl 92-67-1
o-toluidine 95-53-4
3,4-dichlorophenol 95-77-2
2,4-xylidine 95-68-1
4-chloro-o-toluidine 95-69-2
3-chlorophenol 108-43-0
4-methyl-m-phenylene-
95-80-7
diamine
4-chlorophenol 106-48-9
o-aminoazotoluene 97-56-3
2,3,4-trichlorophenol 15950-66-0
5-nitro-o-toluidine 99-55-8
2,3,5-trichlorophenol 933-78-8
3,4,5-trichlorophenol 609-19-8
28 29
Table 2E: Table 2F:
30 31
Table 2G:
Pentabromodiphenyl ether
32534-81-9
(PentaBDE)
Octabromodiphenyl ether
32536-52-0
(OctaBDE)
Table 2J:
Bis(2,3-dibromopropyl)phosphate ISO 22032, USEPA
5412-25-9
(BIS) 527 and USEPA Organotin Compounds
8321B. Substance or Sub- Reporting Limit Standard Test
CAS
Tris(1-aziridinyl)phosphine oxide) stance Group (µg/L) Method
545-55-1 5
(TEPA) Dichloromethane
extraction GC/MS
or LC/MS(-MS) Dibutyltin (DBT) Multiple
Polybromobiphenyls (PBB) 59536-65-1
Mono-, di- and
Multiple
tri-methyltin derivatives ISO 17353
Tetrabromobisphenol A (TBBPA) 79-94-7
Mono-, di- and Derivatisation
Multiple 0.01
Hexabromocyclododecane tri-butyltin derivatives with NaB(C2H5)
3194-55-6
(HBCDD) GC/MS
Mono-, di- and
Multiple
tri-phenyltin derivatives
2,2-bis(bromomethyl)-1,3-propane-
3296-90-0
diol (BBMP) Mono-, di- and
Multiple
tri-octyltin derivatives
Tris(1,3-dichloro-isopropyl)
13674-87-8
phosphate (TDCP)
Triethylene glycol
112-49-2
dimethyl ether
32 33
Table 2L: Table 2M:
Benzo[j]fluoranthene 205-82-3
Di-isononyl phthalate (DINP) 28553-12-0
Benzo[b]fluoranthene 205-99-2 DIN 38407-39
Benzo[a]anthracene 56-55-3
Dinonyl phthalate (DNP) 84-76-4
Acenaphthene 83-32-9
Fluorene 86-73-7
Di-n-propyl phthalate (DPRP) 131-16-8
Naphthalene 91-20-3
m-cresol 108-39-4
34 35
Appendix B
36 37