Marks & Spencer C99
C99
Environmental, Chemical and Factory Minimum Standards
for
Dyeing, Printing and Finishing
Clothing and Textiles
September 2005
Replaces ECOP Issue No. 5 dated September 2004
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Introduction
Dear Supplier Marks and Spencer has always taken its responsibility to protect customers, workers and the environment seriously. We accept that without the use of dyes and chemicals we would not be able to provide our customers with satisfactory products but it is incumbent on the supply base to use chemicals responsibly and use those that do not pose unnecessary risks to workers, customers or the environment. The ‘Environmental Code of Practice’ was a landmark document and that has served us well for many years but we are now working with a far more complex range of products from a truly global supply base against a backdrop of tighter legislation. There are also, quite rightly, greater demands for accountability from customers, media and non-governmental organisations. With this in mind we have developed a simplified, integrated set of minimum standards for worker safety, environmental compliance and chemicals on finished product. Management of chemicals is a very complex subject and, in addition to setting out our minimum standards, this document aims to provide some background information outlining the reasons for our policies and also some guidance to help minimise the risk of factory, environmental or product failures. Please confirm that you have received this document by e-mail and then carry out the simple self-audit. Compliance with minimum standards and the completion of a self audit is a mandatory requirement for doing business with Marks and Spencer. If you require any further assistance please do not hesitate to contact me. Phil Patterson Dyeing, Printing, Finishing and Colour Manager
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What you will find in this document?
• An explanation of our corporate policies and general requirements relating to worker safety, environmental compliance and customer safety, and why they are important to us.
• Step by step guidance for supplier compliance • Details of our minimum standards requirements • A simple, one-page Self- Audit document to demonstrate compliance (also available as a separate word document) • A table containing all necessary information regarding chemicals that we must eradicate or control (including test methods and
permitted limits) • Explanatory notes to give guidance on selection of dyes and chemicals to ensure compliance • Several appendices - containing detailed lists of controlled chemicals, information on who is responsible for meeting the minimum
standards and detailed best practice to meet minimum standards
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These standards apply to:
• Dyehouses • Printworks • Finishing Facilities • Laundries • Tanneries
• The Chemicals used within them • The Products they produce
− Facilities that process products with Marks & Spencer labels attached will also require a social compliance audit. − Additional componentry such as zips, threads and interlinings must comply with the standards relating to chemicals on
finished product and the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied.
− Although chemical use is limited in knitting, weaving and garment making facilities the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied.
Marks & Spencer will not place orders with companies who fail to declare full details of production routes Marks & Spencer reserve the right to cancel orders and return products in the event of non-compliance Full details of dyes and chemicals used must be made available on demand, if necessary under a secrecy agreement
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What Next? – How to demonstrate compliance:
1. Confirm receipt of this document to [email protected] stating your company name, the nature of your business, the garment/product maker and M&S departments you are supplying
2. Read all the information in this document –including appendices 3. Select dyes from suppliers ‘compliant dyes and chemicals’ list or get confirmation from suppliers that dye and
chemical inventory complies with these minimum standards. 4. Gather information regarding effluent, discharge and disposal consents and recent test results to confirm
compliance. 5. Ensure factory meets minimum standards for worker safety and QA procedures. 6. Carry out risk-based checks on raw materials and finished product to confirm compliance. 7. Complete Minimum Standards Self Audit form (available as stand alone document on Quality Standards website
and send to [email protected] as a Word document or fax to +44 20 87187725. Please do not send scans with file size > 0.5 Mb.
8. Read and follow best practices in appendix x to build ongoing compliance into normal working procedures.
How Marks & Spencer Monitors Compliance with Minimum Standards
Worker Safety and Quality Systems – Site-visit by garment/product manufacturers or Marks & Spencer personnel is required to verify self audits. Failures will be addressed by either action plans for minor discrepancies, or termination of business for severe failures.
Environmental – on site visits by Marks & Spencer personnel or independent environmental auditor to verify self audits.
Chemicals on Product – Risk based product testing. Failures will need to be discussed with Marks & Spencer and will result in either an action plan for eradication or products being removed from stores depending on the circumstances. Chemical testing may be demanded at the time of technical submission by Marks & Spencer technologists.
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Minimum Standards Policy
Factory / Worker Safety Environment Chemicals on Garments/Product Marks & Spencer will not do business with suppliers who fail to look after the health and safety of their workers.
QC Systems
Marks & Spencer will not do business with suppliers who do not have the necessary controls and management systems in place to consistently meet our technical, safety and environmental standards and on-time delivery.
Marks & Spencer will not do business with suppliers whose processes pollute the environment in which they operate.
Marks & Spencer will not sell products if
The chemical content renders them illegal or harmful to customers.
Anyone in the supply base has broken any laws regarding the use or disposal of specific chemicals.
Anyone in the supply base has wilfully failed to adhere to our policies regarding the use or disposal of specific chemicals.
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Minimum Standards Detail
Factory / Worker Safety Environment Chemicals on Garments/Product All fire exits must be marked, unlocked and not obstructed Adequate and appropriate fire fighting equipment must be
available and be clearly marked and accessible No smoking in working areas of factory No eating or drinking in areas where dyes or chemicals are
handled Housekeeping, building construction and working
environment must be to a standard that does not compromise worker safety
Working dye and chemical stores must be indoors, dry and tidy
An authentic material safety data sheet for every dye and chemical must be available in the local language in the vicinity of where dyes and chemicals are handled
Dyes and chemicals must be labelled and stored in accordance with detailed information in the MSDS
Appropriate personal protective equipment must be worn All machines must be electrically and mechanically safe Factory must comply with local health, safety and
employment law
QC Systems All dyes and chemicals must be accurately weighed or
measured (not approximated using scoops etc) Scales must be clean, dry and calibrated Must have an Indoor greige area that is clean, dry and tidy Written procedures must be available for all processes Batch cards must accompany every batch of production Must have light box and basic QC tests on-site Records of colour continuity and test results must be kept
for every batch Raw materials must be checked, finished production must
be examined prior to dispatch and records must be kept Must have access to Marks & Spencer quality standards
website
Untreated effluent must not be discharged directly into water courses
Water must be treated on-site, in a communal water treatment plant or by a local authority water treatment plant
Measures must be taken to avoid emission of noxious fumes into the air from stored chemicals and solvents, textile processing, utilities (steam production, generators etc) or incineration of waste
Solid waste must be disposed of according to local government recommendations and regulations
Packaging must be disposed or recycled in accordance with local legislation
The natural balance of the surrounding area should not be disturbed e.g. over-abstraction of water
Suppliers must demonstrate ongoing compliance with local government discharge and emission (consent) limits.
Although we do not have any specific standards regarding water and energy consumption we do expect this information to be provided and expect suppliers to take all reasonable steps to minimise wastage. The major source of wastage is the inability to meet standards without re-dyeing or re-finishing.
The following chemicals must not be deliberately used and must not be present on final product at concentrations above those specified
Banned Azo dyes 30 ppm Skin sensitising dyes 30 ppm Apeo’s 1000 ppm Organo Tin 0.05 ppm PCP’s 0.05 ppm Mercury 2 ppb Moth-proofing 10 ppm PFOS 1 ppm PFOA 2 ppm Carriers 1 ppm
Processes using the following chemicals must only be used with written consent of a Marks & Spencer technologist and must not be present at concentrations above those specified:
Chromium VI 3 ppm Organic Solvents limit of detection
The following chemicals are only permitted above the specified concentrations if their use has been authorised by Marks & Spencer
Biocidal Finishes see table p.9-12 Applied Flame Retardants 5 ppm PVC / Phthalates see table p.9-12
The following chemicals must not be present above the specified concentrations:
Formaldehyde 75 ppm (free), 300 ppm (released) Pesticides/Insecticides 0.5 ppm (wool), 0.05 ppm
(cotton) See chemicals on finished product table for detail additional detail for leather and children’s wear
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Minimum Standards Self Audit – Please see Quality Standards website for stand alone document in Word format.
Factory / Worker Safety Environment Chemicals on Garments/Product
All fire exits are marked, unlocked and not obstructed Average yearly energy consumption per kg of production
Adequate and appropriate fire fighting equipment is present in all areas of factory and is clearly marked and accessible
Electricity (Kwh)
All dye and chemical suppliers have confirmed that their products being used for M&S production meet these minimum standards
No smoking in working areas of factory Oil / Coal / Gas (KJ)
No eating or drinking in areas where dyes or chemicals are handled
Total water consumption per kg of production including steam (litres)
Please confirm that the following chemicals are not knowingly applied or brought in via raw materials at concentrations above those stated in the Marks & Spencer minimum standards
Banned azo dyes Housekeeping, building construction and environment is to a standard that does not compromise worker safety
Production volume for past 12 months (tonnes)
Skin sensitising dyes
APEO's Dye and chemical stores are indoors, dry and tidy
% of batches topped up, re-dyed or refinished
Organo tin
PCP's Confirm no breaches of air emission consent limits in previous 12 months
Mercury
Moth proofing
A material safety data sheet for every dye and chemical is available in the local language in the vicinity of where dyes and chemicals are handled Confirm all solid waste is disposed in accordance with
local government recommendations
PFOS based fluorocarbons PFOA containing fluorocarbons Dyes and chemicals are labelled with appropriate safety
clauses and stored in accordance with MSDS information Untreated effluent is not discharged directly into water
courses
Carriers Pesticides / Insecticides Appropriate personal protective equipment and closed shoes
are worn as detailed in the MSDS
Effluent pass rate for past 12 months No. of Tests
%
pH All machines have been checked and are electrically and mechanically safe
COD BOD The company complies with local health, safety and
employment legislation
Suspended Solids
QC Systems Temperature
All dyes and chemicals are weighed or measured (not scooped) Metals
Please confirm that the following chemicals are either not used, or have been authorised for use by an Marks & Spencer technologist
Not Used Used by Consent
Scales are clean, dry and calibrated Toxins / Restricted substances Chromium VI
Indoor greige area Organic Solvents
PVC Written procedures for all processes Batch cards accompany every batch of production
Phthalates
Capable of basic QC tests on-site Biocidal Finishes Records of colour continuity and test results kept for every batch FR Finishes
Production is examined prior to dispatch and records of inspection are kept.
Detail water and energy reduction measures
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Chemicals on Finished Product
Chemical
What M&S products are most likely to be affected?
What is the origin of the controlled
chemical? Why is it nasty?
Retail legal status
Supply base legal status
Acceptable limit on finished
product
Limit of Detection
Test method
Banned Azo dyes No deliberate use
All fibre types Banned amines listed in appendix 7. Examples of dyes that can form such amines listed in appendix 6
Dyes can split to form carcinogenic amines
Sale of products containing > 30 ppm is illegal
Use of products containing > 30 ppm is illegal
30ppm 10 ppm Textiles: C62a (refers to EN 14362 part 1 and 2) Leather :C62b (CEN ISO/TS 17234:2003)
Skin Sensitising Dyes No deliberate use
Polyester, Acetate, disperse-dyed nylon
Disperse Dyes listed in appendix 8
Once sensitised to a dye people can react violently to trace quantities
No Legal restriction
No Legal restriction
30 ppm (2 ppm in extract)
2 ppm DIN 54231
Alkyl phenyl ethoxylates (APEO's) No deliberate use
All fibre types In widespread use as detergents, Wetting agents and as emulsifying agents
Endocrine disruptors (sex change chemicals) for aquatic species
No Legal restriction
Use of formulations
containing over 0.1% of NPEO is illegal in Europe
1000 ppm* temporary standard
1 ppm C65
GCMS or LCMS
APEO notes NPEO (nonyl phenyl ethoxylate) is the APEO that causes greatest concern. It is anticipated that legislation regarding its use will harmonise worldwide and we will then lower the standard. Current EU legislation is Marketing and Use Directive 2003/53/EC
Organo tin compounds. No deliberate use
All fibre types Preservative for fabrics and chemical formulations. Occasionally used as stabilizers and catalysts
Tributyl tin is highly toxic and related products have toxicity issues
could be governed by biocidal substances directive
Use is effectively prohibited via water authority
regulations
0.05 ppm (in extract)
0.05 ppm Textiles: Solvent extraction + gcms (in-house methods) Leather: SATRA TM277
PCP – pentachlorophenol and derivatives No deliberate use
Cotton, Viscose Preservative for cotton and viscose. Main risk is on imported greige
Highly Toxic could be governed by biocidal substances directive
Use is effectively prohibited via water authority
regulations
0.05ppm (in extract)
Leather 0.5ppm
0.1ppm Textiles: water/steamdistillation (in-house methods) Leather: EN TS 14494:2003
Mercury No deliberate use
Cotton Caustic soda that is made by the 'mercury cell process'
Highly toxic could be governed by biocidal substances directive
Use is effectively prohibited via water authority
regulations
2 ppb 2 ppb Any appropriate technique e.g. Combustion amalgamation with cold vapour detection
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Chemical
What M&S products are most likely to be affected?
What is the origin of the controlled
chemical? Why is it nasty?
Retail legal status
Supply base legal status
Acceptable limit on finished
product
Limit of Detection
Test method
Mothproofing No deliberate use
Wool, (Cashmere, Angora)
Commonest chemical is permethrin - found on wool and cashmere
Nerve agent and toxic to aquatic species
No Legal restriction
Use is effectively prohibited via water authority
regulations
Contamination limit 10ppm
1 ppm Analytical -HPLC
PFOS No deliberate use
All fibre types Water-repellent ‘8-chain’ fluorocarbon finishes based on electrofluorination (old generation Products)
proven health risks and persistent in the environment
Legislation restricting PFOS has been proposed
No Legal restriction
1 ppm (in extract)
1 ppm solvent extraction + lc-ms
PFOA No deliberate use
All fibre types Water-repellent finishes based on telemerisation
Persistent in the environment and suspected health risks
No Legal restriction
No Legal restriction
1 ppm (in extract)
1ppm solvent extraction + lc-ms
PFOA notes PFOA (perfluorooctanoic acid) is used in the manufacture of the building blocks for fluorocarbons that are applied to textiles. Users of fluorocarbon finishes should get written confirmation from the manufacturer that traces of PFOA and materials that can theoretically form PFOA have been minimised.
Dye Carriers No deliberate use
Polyester Used to dye polyester and blends at low temperatures in machinery not capable of being pressurised
Various depending on type of carrier - generally toxic, irritants or carcinogens
No Legal restriction
Some chemical types are
prohibited
1 ppm For halogenated
aromatic hydrocarbons, tri-chlorobenzene,
biphenyl or ortho phenyl phenol
1 ppm solvent extraction gc-ms
Chromium VI. Consent Required
Wool, (Cashmere, Angora)
Chromium compounds used in 2-stage 'after-chrome' wool dyeing
Highly toxic / carcinogenic both to humans and aquatic species
No Legal restriction
Large scale use is effectively
prohibited via water authority
regulations
3 ppm
Leather 10ppm
3 ppm
CEN 14495 = 10ppm
Textiles: C60 (refers to BS 6810) Leather: CEN/TS 14495:2003
Organic solvents Consent Required
Panel Printed or solvent-scoured fabrics
Used in some adhesives, print formulations, solvent scouring and spot cleaning
Various depending on type of solvent
Some solvents are restricted
Some solvents are banned - e.g. ozone depleting substances, carcinogens
Limit of detection Varies according to chemical type
GCMS + Head Space
Organic solvent notes
Where solvents are used suppliers should always seek to change to water based alternatives. Where this is not possible e.g. dry pigment discharge printing there must be adequate extraction of fumes, good ventilation, and workers must be provided with appropriate personal protective equipment. Solvents are permitted for scouring greige but these must be in fully enclosed, zero emission systems. No residual solvent is permitted on any finished product.
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Chemical
What M&S products are most likely to be affected?
What is the origin of the controlled
chemical? Why is it nasty?
Retail legal status
Supply base legal status
Acceptable limit on finished
product
Limit of Detection
Test method
Biocidal Finishes Consent Required Not permitted in Childrenswear
All fibre types Deliberate application
Toxic Some chemicaltypes are restriced
Some chemical types are restricted
by water authorities
Limit of detection unless agreed in writing by technologist
varies according to type
Analytical - HPLC
Biocidal finish notes
Biocidal finishes must be permanent, non-leaching, work only on the fabric and not on customers skin and must not be implicated in antibiotic resistance. Biocidal finishes should not be confused with odour absorbers such as cyclodextrins or Dew White.
Flame retardants Consent Required Not permitted in Childrenswear
Cotton Deliberateapplication
Depends on exact chemistry - Toxic, not biodegradable and suspected health risks
Performance is governed by legislation. Certain chemical types are restricted
Certain chemical types are restricted
5ppm for penta-, hexa- and octa -brominated biphenyl ethers
5 ppm solvent extraction + gc-ms or lc-ms
Flame retardant notes
Flame retardant finishes should only be applied where there is a legislative need with written consent from M&S. Penta, Hexa and Octa –brominated types must not be deliberately applied and must not be present above 5 ppm. Suppliers using Deca brominated types should follow VECAP best practice - http://www.bsef.com/product_stew/vecap/
PVC Consent Required Not permitted in Childrenswear
Mock leather and plastisol prints. Sequins
Deliberate use Not biodegradable, releases dioxins on combustion
No Legal restriction
Strict controls on disposal
Qualitative test qualitative C64 - qualitative (Belstein test) then/or FTIR for confirmation
Phthalates Consent Required for PVC Not permitted in Childrenswear
PVC mock leather and plastisol prints
Used to soften rigid PVC
Suspected sex change chemicals /suspected carcinogen
Illegal in articles that may be sucked (toys, babywear motifs etc.) above specified limits
No Legal restriction at
present – restrictions expected
Limit of detection for childrenswear.
1 ppm C61 Solvent extraction +
GCMS
PVC and Phthalate notes
It is essential that all suppliers who are using PVC based products familiarise themselves with, and comply with the M&S PVC policy. Phthalate contamination is a real problem so the only way to guarantee Childrenswear is phthalate-free is to use segregated phthalate-free facilities.
Formaldehyde Not permitted in Children’s underwear or any babywear
Resinated Cotton and Viscose
Naturally occurring but most commonly found in resinated products (and in lower levels in fixing agents for cotton and nylon)
Known irritant to skin and mucous membranes. Recently reclassified as carcinogen by WHO
No Legal restriction
Controls on workplace
airborne quantities
Free and hydrolysable 75ppm Released 300ppm Babywear 20ppm
Background levels are approx 20
ppm
Textiles:C18B and C18C Leather: EN ISO TS 17226 HPLC
Pesticides / Insecticides
Wool (and lower levels on cotton)
Used to protect sheep and cotton crops from parasite infestation. See appendix 5
Toxic Selected chemicalsare banned under POP convention
Strict controls on effluent
Total 0.5ppm for wool Total 0.05ppm for cotton
0.05 ppm Analtyitcal – HPLC or GCMS
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Chemical
What M&S products are most likely to be affected?
What is the origin of the controlled
chemical? Why is it nasty?
Retail legal status
Supply base legal status
Acceptable limit on finished
product
Limit of Detection
Test method
Chlorine based bleach
Cotton Deliberate application
Toxic in high concentrations. Concerns over ‘AOX’ formation in effluent
No Legal restriction
No Legal restriction. May
form AOX in effluent and these
are controlled
No limit specified Best practice is to use peroxide based systems
N/A
Cadmium Various -including components
Used in pigments, alloys, some dyes and some fibres
Toxic EN 71 + Cadmium directive
Strict controls on effluent
0.5 ppm
0.5ppm Solvent extractionmethods - MS
Nickel See nickel policy
Various -including components
Present in some green and turquoise dyes
Allergenic See nickel policy Strict controls on effluent
Dyes – best practice Metal components – see nickel policy
Nickel Release EN 1811
Heavy Metals Various -including components
Used in pigments, alloys, some dyes and some fibres
Toxic EN 71 Strict controls on effluent
Antimony 2 ppm Arsenic 1 ppm Lead 1ppm
Solvent Extraction Leather : Extraction in artificial sweat + AAS / ICP
Potassium Permanganate
Denim Used as a localised bleaching agent - usually as a spray
Toxic for workers No Legal restriction
No Legal restriction
Best Practice to use permanganate –free process
Some Sequesterants e.g. EDTA
All products Used as an additive for softening water
Can upset the balance of water courses
No Legal restriction
Some restriction on some products eg
EDTA
No limit specified
There are many thousands of chemicals that are not mentioned in the above section that are known to be harmful to humans or the environment. They are not mentioned because there is little chance they would ever be used on the type of products we sell. However, we do not expect any harmful chemicals to be present and draw your attention to lists in Appendix 10. Marks and Spencer will continue to promote the minimisation of harmful chemicals in our products and responsible use of safer technology.
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Dye and Chemical Selection – Avoidance of non-compliance
With the exception of some contaminants that are brought in on raw materials most chemical safety and environmental issues are caused by the dyes and chemicals that are deliberately used for the manufacture of products.
Dyehouses, printers, finishers, laundries and tanneries must take care to select products that do not harm textile workers, the environment or Marks & Spencer customers.
To minimise the risk of non-compliance Marks & Spencer recommend that dyes from ETAD member companies are used. ETAD member companies work to a voluntary code of conduct to minimise the negative health and environmental effects arising from the manufacture and use of dyes and pigments. (member companies in appendix 5 or www.etad.com).
There are however several reputable dye manufacturers and distributors who have declined ETAD membership and there is no analogous organisation for textile chemicals. With this in mind Marks & Spencer are developing a directory of dyes and chemicals that meet the minimum standards laid out this document to minimise the risks to customers, textile workers and the environment.
All worldwide dye and chemical suppliers will be able to register their compliant chemicals free of charge under a self certification arrangement. (Contact [email protected] for details).
Ultimately it is expected that production for Marks & Spencer will have to use these registered chemicals otherwise finished products will have to be subjected to exhaustive chemical compliance tests.
Compliant dyes and chemicals – Products selected from the following lists will not give rise to non-compliance if applied appropriately
Dystar have the information relating to their dyes and pigment formulations available in brochure format (ref 09.0047-00) or at www.dystar.com.
Ciba have a list of compliant dyes and chemicals at www.cibasc.com
Childrenswear Panel Prints The following companies entire range of panel printing chemicals comply with our general requirements for chemicals and more stringent Childrenswear standards of PVC-free, Phthalate-free. It is strongly recommended that products utilising new technology from these companies are used to minimise the risk of non-conformance.
Magna
M.B.Creative
Kimya
CHT
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Appendices 1. General Requirements – why we impose minimum standards
2. Best practice
3. Who is responsible for managing compliance with minimum standards
4. Managing failure
5. ETAD member companies
6. Banned Amines
7. Examples of dyes that can cleave to form banned amines
8. Skin sensitising dyes
9. Pesticides / Insecticides
10. Chemicals of concern
11. Test methods and techniques.
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Appendix 1 − General Requirements
Factory / Worker Safety Environment Chemicals on Garments/Product The following are three key areas in ensuring worker safety. Chemicals. Dyes and chemicals used to manufacture our products can pose an immediate danger to workers (acids, corrosives etc) and/or have long term effects associated with prolonged exposure. Exposure of workers to unnecessary risks from dyes and chemicals is unacceptable. Good factories will invest in automated dispensing, ducting, ventilation and other engineering solutions to protect their workers. In the absence of these it is imperative that appropriate personal protective equipment is provided and worn. See appendix 2 for further best practice. Machinery has to have moving parts in order to function – however it is not acceptable for machinery to be unsafe. All moving parts must be guarded, there must be no exposed electrics and all machinery should be serviced, tested and certificated. Most accidents and fires occur in areas where housekeeping, the fabric of the building or the working environment is poor. Poor air quality and extremes of temperature are also harmful to employees. Where differences exist between local legal requirements and the standards detailed in this document the tighter standard must be employed.
QC Systems Factories must be able to demonstrate that they have systems in place to consistently meet our requirements in production. Factories that occasionally meet our requirements (e.g. at sample stage) are much higher risk than those that never meet our requirements.
All authorities worldwide have ‘consent limits’ for effluent and emissions that set out which chemicals, and how much of them (both concentration and total per annum) can be discharged to drain or to the air. Effluent and air quality will be tested by the authorities and they will provide written documentation to the factory to denote compliance or non-compliance. There will also be local guidelines for disposal of solid waste, redundant dye stocks and chemicals. Factories must be able to demonstrate ongoing compliance with local government legislation.
Dyes and chemicals are essential to produce saleable products but we do have a duty to ensure that our customers, and workers involved in manufacture, are not exposed to risks arising from their use. We control (and test for the presence of) the chemicals specified in this document for the following reasons: • It is illegal to sell merchandise containing certain
chemicals above specified levels. • Certain chemicals, although legal in terms of use and
sale, are known to be harmful to customers and workers involved in the manufacture of our products
• In certain parts of the world there are laws regulating
the use/disposal of certain chemicals above specified levels. Although it is legal for us to sell the final product, detection of such chemicals indicates that they have been used at some stage of manufacture.
Where there are local laws preventing the use or sale of chemicals that differ from the minimum standards detailed in this document the tighter standard must be applied.
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Appendix 2 – Best Practice
Factory / Worker Safety Environment Chemicals on Product
• Health and safety policy from the CEO. • Appoint trained safety and fire officer. • Individual training for all factory workers. • Inter-departmental auditing within a factory. • Selection of safest form of dyes and
chemicals (liquids, low dusting powders) • Use engineering controls to minimise
exposure to harmful chemicals. • Reduced impact of manual handling. • Planned maintenance of machinery. Further information at www.hse.gov.uk
QC Systems
• Quality policy from CEO • Appoint quality assurance manager • Systems for checking consistency of water
and raw materials • Work to standard operating procedures • Use examination department and labs to
collect information not just to pass/fail • Visual display of quality indicators for all
areas • Visual display of cost of non-conformance ISO 9001 gives some measure of competence.
• Environmental policy from CEO on display. • Appoint environmental officer. • Put in place an environmental management
system • Training for all workers on chemical
knowledge. • Display performance indicators in all areas of
factory (details of licences, breaches of consent, energy and water consumption).
• Display cost benefits of reduced re-dye / refinish with respect reduced water and energy consumption.
ISO 14001 is a very good indicator of environmental competence.
Bluesign technologies ag are leaders in the field of environmental compliance and resource management. Suppliers will benefit from a full factory and chemical inventory audit by bluesign's experts and their recommendations will invariably lead to lower costs due to improved efficiency and productivity as well as reduced risk of non-compliance. http://www.bluesign-tech.com
• Chemical policy from CEO. • Formalised risk assessment of all dyes and
chemicals used on site. • Single point accountability for dye and
chemical inventory. • Up to date inventory of all dyes and
chemicals with supporting MSDS (including locally purchased process chemicals).
• Do not buy chemicals from companies who refuse to supply MSDS.
• Letters of ECOP-compliance for all chemicals from their manufacturer.
• Formalised due diligence programme for incoming raw materials, dyes and chemicals.
• Formalised due diligence programme for outgoing production.
Oekotex 100 certification is confirmation that a factory can achieve the oekotex standard on a particular finished fabric. Whilst it is a reasonable indicator some degree of competence it does not guarantee that factory conditions, working practices and environmental compliance are good.
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Appendix 3 − Who is Responsible for Managing Compliance with Minimum Standards?
Factory / Worker Safety Environment Chemicals on Product
• Self Audit is the minimum requirement before orders are placed.
• Garment/product manufacturer assessment is required by time of first production (It is recommended that all garment suppliers have a technical resource capable of managing compliance – where Marks & Spencer have agreed to place business with suppliers who lack this resource the Marks & Spencer technologist is responsible for factory audit).
• Marks & Spencer technologists reserve the right to visit any production facility at any time.
• Dyeing and finishing specialists will also take cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.
QC Systems • Self Audit is the minimum requirement before
orders are placed. • Garment/product manufacturer assessment is
required by time of first production. • Marks & Spencer technologists reserve the right
to visit any production facility at any time. • Dyeing and finishing specialists will also take
cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.
• Self audit to report on meeting local consent limits.
• Marks & Spencer reserve the right to carry
out or commission a detailed environmental audit (at our cost) to check raw data used for self audit.
• Dyer, printer or finisher is responsible for collating data on raw materials, dyers and chemicals.
• Dyer, printer or finisher is responsible
for selecting dyes and chemicals to comply with Marks & Spencer requirements.
• Dyer, Printer or Finisher to decide with
garment maker at pre-production what is required and who is responsible for compliance testing.
• Garment maker to carry out additional
due diligence checks – risk assessment in collaboration with Marks & Spencer Dyeing and Finishing Specialists.
• Marks & Spencer to carry out due
diligence checks.
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Appendix 4 − Managing Failure
Factory / Worker Safety Environment Chemicals on Product
Compliance with minimum standards must be demonstrated before production commences.
QC Systems
Strongly inadvisable to place business with suppliers who do not meet the elementary minimum standards. To be managed by Marks & Spencer departmental technologist who may delegate to trusted garment suppliers.
Generally governed by local authorities – repeated and or serious breaches of consent will result in financial penalties or closure of the factory. Marks & Spencer should not commit to business with repeated offenders as there is significant risk of non-delivery due to forced closure.
All results that fall outside published standards will have to be discussed with the Departmental Technologist and Dyeing, Printing, Finishing and Colour Manager. Some failures will result in an immediate removal of product from stores (RTM). In other cases RTM’s may not be actioned provided the source of the failure is identified and the chemical eradicated from the supply chain. Repeated breaches will result in an RTM.
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Appendix 5 − E.T.A.D. Member Companies
Albion Colours Ltd Hodogaya Chemical Co Ltd
Aliachem a.s. Kyung-In Synthetic Corporation
ATUL Limited Lanxess (formerly Bayer)
Avecia Ltd Lanxess Corp
BASF AG M Dohmen GmbH
BASF Corporation Mike Dyes Works Ltd.
Bezema AG Mitsubishi Chemical Corporation
Cappell Pigments n.v. Nippon Kayaku Co Ltd.
Carey Industries Inc. Oh Young Ind. Co. Ltd.
Ciba Speciality Chemicals Corporation Oriental Giant Dyes & Chemical Ind. Corporation
Ciba Speciality Chemicals Inc. RIFA Ind. Co. Ltd
Clariant (Schweiz) AG Rohm & Haas Company
Clariant Corporation Sanyo Color Works Ltd
Dainichiseika Sensient Colours Inc.
Dainippon Ink & Chemicals Inc. Sestas Kimya Sanayi A.S.
Dystar L.P. Stahl International b.v.
Dystar Textilfarben GmbH & Co. Deutschland KG Sun Chemical A/S
E C Pigments T&T Industries Corporation
Everlight Chemical Ind. Corporation Tennants Textile Colours Limited
Everlight USA Inc. TFL Ledertechnik Gmbh & Co. KG Francolor Pigments SA Thai Ambica Chemicals Co., Ltd
Heubach GmbH Toyo Ink Mfg. Co. Ltd
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Appendix 6 − Aromatic Amines Specified in EC 2002/61
CAS Number Index Number EC Number Substances
1. 92-67-1 612-072-00-6 202-177-1 Biphenyl-4-ylamine 4-aminobiphenyl xenylamine
2. 92-87-5 612-042-00-2 202-199-1 Benzidine
3. 95-69-2 202-441-6 4-chloro-o-toluidine
4. 91-59-8 612-022-00-3 202-080-4 2-naphthylamine
5. 97-56-3 611-006-00-3 202-591-2 o-aminoazotoluene 4-amino-2’, 3-dimethylazobenzene 4-o-tolylazo-o-toluidine
6. 99-55-8 202-765-8 5-nitro-o-toluidine
7. 106-47-8 203-401-0 4-chloroaniline
8. 615-05-4 210-406-1 4-methoxy-m-phenylenediamine
9. 101-77-9 612-051-00-1 202-974-4 4,4’-methylenedianiline 4,4’-diaminodiphenylmethane
10. 91-94-1 612-068-00-4 202-109-0 3,3’-dichlorobenzidine 3,3’-dichlorobiphenyl-4,4’-ylenediamine
11. 119-90-4 612-036-00-X 204-355-4 3,3’-dimethoxybenzidine o-dianisidine
12. 119-93-7 612-041-00-7 204-358-0 3,3’-dimethylbenzidine 4,4’-bi-o-toluidine
13. 838-88-0 612-085-00-7 212-658-8 4,4’-methylenedi-o-toluidine
14. 120-71-8 204-419-1 6-methoxy-m-toluidine p-cresidine
15. 101-14-4 612-078-00-9 202-918-9 4,4’-methylene-bis-(2-chloro-aniline) 2,2’-dichlor-4,4’-methylene-dianiline
16. 101-80-4 202-977-0 4,4’-oxydianiline
17. 139-65-1 205-370-9 4,4’-thiodianiline
18. 95-53-4 612-091-00-X 202-429-0 o-toluidine 2-aminotoluene
19. 95-80-7 612-099-00-3 202-453-1 4-methyl-m-phenylenediamine
20. 137-17-7 205-282-0 2,4,5-trimethylaniline
21. 90-04-0 612-035-00-4 201-963-1 o-anisidine 2-methox aniline
22. 60-09-03 611-088-00-4 200-453-6 4-amino azobenzene *no test available
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Appendix 7 − Examples of Dyes which Potentially Cleave
AROMATIC AMINES (LISTED IN APPENDIX 6) UNDER REDUCING CONDITIONS
CI Acid Orange 45 22195 Direct Red 21 23560 Direct Blue 173 CI Acid Red 24 16140 Direct Red 22 23565 Direct Blue 192
CI Acid Red 85 22245 Direct Red 28 22120 Direct Blue 201
CI Acid Red 114 23635 Direct Red 37 22240 Direct Blue 215 24115
CI Acid Red 115 27200 Direct Red 39 23630 Direct Blue 295 23820
CI Acid Red 128 24125 Direct Red 44 22500 Direct Green 1 30280
CI Acid Red 148 26665 Direct Red 46 23050 Direct Green 6 30295
CI Acid Red 158 20530 Direct Red 62 29175 Direct Green 8 30315
CI Acid Red 167
Direct Red 67 23505 Direct Green 8.1
CI Acid Red 265 18129 Direct Red 72 29200 Direct Green 85 30387
CI Acid Black 29 Direct Violet 1 22570 Direct Brown 1 30045
CI Acid Black 209 Direct Violet 12 22550 Direct Brown 1:2 30110
Azoic Diazo Component 12 37105 Direct Violet 21 23520 Direct Brown 2 22311 Basic Brown 4 (= Solvent Brown 12) 21010 Direct Violet 22 22480 Direct Brown 6 30140 Developer 14 (=Oxidation Base 20) 76035 Direct Blue 1 24410 Direct Brown 25 36030 Direct Yellow 1 22250 Direct Blue 2 22590 Direct Brown 27 31725
Direct Yellow 24 22010 Direct Blue 3 23705 Direct Brown 31 35660
Direct Yellow 48 23660 Direct Blue 6 22610 Direct Brown 33 35520
Direct Orange 1 22370 Direct Blue 8 24140 Direct Brown 51 31710
Direct Orange 6 23375 Direct Blue 9 24155 Direct Brown 59 22345
Direct Orange 7 23380 Direct Blue 10 24340 Direct Brown 79 30056
Direct Orange 8 22130 Direct Blue 14 23850 Direct Brown 95 30145
Direct Orange 10 23370 Direct Blue 15 23790 Direct Brown 101 31740
Direct Orange 108 29173 Direct Blue 22 24280 Direct Brown 154 30120
Direct Red 1 22310 Direct Blue 25 23790 Direct Brown 222 30368
Direct Red 2 23500 Direct Blue 35 24145 Direct Black 4 30245
Direct Red 7 24100 Direct Blue 76 24411 Direct Black 29 22580
Direct Red 10 22145 Direct Blue 151 24175 Direct Black 38 30235
Direct Red 13 22155 Direct Blue 160 Direct Black 154
Direct Red 17 22150
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Appendix 8 − Dyestuffs implicated in Contact Dermatitis by Consumers, which include:
CI
Disperse Blue 1
CI Disperse Blue 3
CI Disperse Blue 7
CI Disperse Blue 26
CI Disperse Blue 35
CI Disperse Blue 102
CI Disperse Blue 106
CI Disperse Blue 124
CI Disperse Yellow 1
CI Disperse Yellow 3
CI Disperse Yellow 9
CI Disperse Yellow 39
CI Disperse Yellow 49
CI Disperse Orange 1
CI Disperse Orange 3
CI Disperse Orange 37
CI Disperse Orange 76
CI Disperse Red 1
CI Disperse Red 11
CI Disperse Red 17
CI Disperse Brown 1
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Appendix 9 − Pesticides / Insecticides
Cotton and Natural Cellulosic Fabrics; Blends of these with Other Fibres
Maximum Limits for each Product Listed - 0.05 ppm
Wool and Other Keratin Fabrics; Blends of these with Other Fibres
The Sum Total should Not Exceed 0.5ppm
Aldrin Alpha-Hexachlorocyclohexane Captafol Beta-Hexachlorocyclohexane Chlordane Gamma-Hexachlorocyclohexane DDT Lindane Dieldrin Aldrin Endrin Endrin Heptachlor Dieldrin Hexachlorobenzene DDT Hexachlorocyclohexane (total Isomers) DDD 2,4,5,T Propetamphos 2,4 D Diazinon Chlordimeform Dichlofenthion Chlorobenzilate Fenchlorphos Dinoseb (and its salts) Chlorfenvionphos Monocrotophos Cyhalothrin
Cypermethrin Deltamethrin Fenvalerate
In addition to due diligence testing of finished products, we would recommend that documentary evidence should be obtained from the raw material suppliers that these chemicals are not present. It is our intention in the future to specify these standards back to the raw material, i.e., fibres.
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Appendix 10 − Summary : Chemicals for Concern
EU Water Framework UK Environmental OSPAR List for CHEMICALS
Directive Protection Act Priority Action
1,2,3 trichlorobenzene 1,2,4 trichlorobenzene 1,2-Dichloroethane
1,3 Cyclopentadiene
1,3,5 trichlorobenzene
4-tert-butyltoulene
Alachlor
Aldrin
All isomers of DDT
All isomers of hexachlorocyclohexane
All isomers of trichlorobenzene
Anthracene
Atrazine
Azinphos-methyl
Benzine
Brominated diphenylether
Brominated flame retardants
C10-13-chloroalkanes
Cadmium
Cadmium and its compounds
Certain Phthalates- Dibutylphthalate & Diethylhexylphthalate
Chlorfenvinphos
Chlorpyrifos
Di(2-ethylhexyl) phthalate (DEHP)
Dichloromethane Dichlorvos Dicofol
Dieldrin
Diuron
Dodecylphenol
Endosulfan
Endrin
Fenitrothion
Hexachlorobenzene
Hexachlorobutadiene
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EU Water Framework UK Environmental OSPAR List for CHEMICALS
Directive Protection Act Priority Action
Hexachlorocyclohexane
Hexachlorocyclohexane (total Isomers)
Hexamethyldisiloxane
Isoproturon
Lead and its compounds
Lead and organic lead compounds
Malathion
Mercury and its compounds
Methoxychlor
Musk xylene
Naphthalene
Nickel and its compounds
Nonylphenol/ethoxylates (NP/NPEs) and related substances
Nonylphenols
Octylphenol
Organic tin compounds
Pentachlorobenzene
Pentachlorophenol and its compounds
Polyaromatic hydrocarbons (PAHs)
Polychlorinated biphenyls (PCBs)
Polychlorinated dibenzodioxins (PCDDs)
Polychlorinated dibenzofurans (PCDFs)
Short chained chlorinated paraffins (SCCP)
Simazine
Tetrabromobisphenol A
Tributyltin compounds
Trichlorobenzenes
Trichloromethane (Chloroform)
Trifluralin
Triphenyltin compounds
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Appendix 11 − Chemical Testing Notes
General Remarks Testing Requirements
Chemicals can be detected in amounts that fall into 3 categories: Background levels – amounts found in nature Contamination – low levels present Deliberate application – higher levels present
There are two broad types of test: Qualitative – tells you something is definitely there in high low or
medium amounts. Quantitative – tells you exactly what is there.
For any test there will be a ’limit of detection’ below which a chemical cannot be detected. (Where methods use solvent extraction the limits of detection and permissible levels may refer to the extract and not the test fabric/component – see chemicals on product table). In some instances the M&S ‘Acceptable limit’ refers to the acceptable limit in the solvent extract and not the total amount on the fabric under test.
All tests must be conducted in UKAS accredited laboratories or those that operate a mutual recognition scheme (e.g. HOKLAS, COFRAC). Certain laboratories will carry out screening tests for families of similar chemicals before doing specific targeted quantitative tests. A negative result from an accredited laboratory is normally sufficient. Chemical tests from non-accredited laboratories may need to be re-tested and will at best be submissable as quantitative evidence.
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