Leather Manufacturer Audit Protocol 7
P.7.0 was published on 22 February 2021. We released P7.1 on 6 July 2021, and P7.2 on 21 January 2022. Protocol 7 became mandatory on 22 August 2021, after the 6 month introductory period. To change the language of this page, use the Google Translate button above.
To access protocol document, visit the P7.2 Documentation page.
High-level Changes
230
Here are the main highlights:
- The Chemical Management Module has been fully integrated
- We've introduced stricter requirements for effluent treatment
- Traceability has been developed significantly and integrated as a scored section
- Social auditing from a recognised 3rd party has been included as a requirement
Other highlights:
- Audit title changed to LWG Leather Manufacturer Audit Protocol from the previous LWG Environmental Audit Protocol
- Total audit score is not fixed - N/A sections and questions will not be scored
- More specific requirements to achieve medal levels included for individual questions
- There are 17 sections in total
- Social Audits and Inward Traceability have zero as the minimum threshold in P7 (to be increased in P8)
- All other sections have a minimum threshold for an audited certification or medal status
- Data period to cover full 24 months (increased from 12 months), with the following exceptions:
- Change to be phased in to allow adjustment to new requirement for traceability and production data
- exclusion of 3 months of data per 12 possible for energy to account for seasonal variations
- and an additional temporary 3 months exclusion possible per 12 months for water and energy due to Covid (subject to a rolling 6 month review)
01 General Facility Details
213
This is a non-scored section.
02 Subcontracted Operations
214
Section details:
- This is a new, critical section, and the minimum threshold to pass the audit is 50%
- The audit score of all sub-contractors used will to feed into this new section score
- Scoring
- The sub-contractor audit score is weighted according to relative significance
- Weighting based on relative energy consumption of sub-contractor facility, and amount of material processed by sub-contractor
- Penalty if details of sub-con not provided prior to audit – capped at audited or fail (no change to current protocol)
- Fail if any sub-contractor fails
Additional note: the mini-audit will be phased out by mid-2022, so please make sure your sub-contractors are audited
03 Social Audit
215
Section Details:
- The LWG will not conduct any social auditing, you will be required to have an LWG recognised social audit
- This is a new, non-critical section, and it is still possible to achieve gold status without a social audit
- This requirement will become critical in P8, which will be launched 12 months after P7
- Acceptance criteria is limited to 2 years prior to audit
These are the social compliance audits and verifications that we currently recognise:
- Sedex Members Ethical Trade Audit (SMETA)
- Worldwide Responsible Accredited Production (WRAP)
- Higg FSLM
- Social Accountability International SA8000
- UNIC Code of Conduct and Social Accountability
- Business Social Compliance Initiative (BSCI)
Please refer to our full requirements document here: LWG Social Audit Requirements
Further social compliance audits can be reviewed upon application.
For questions, contact social@leatherworkinggroup.com
04 Operating Permits
216
Important section changes:
- This is a critical section, and the minimum threshold to pass the audit is 50%
- Scoring more stringent
- Scoring highlights for fines, cautions, warnings and legal operations:
- Legal compliance always required to pass an audit
- Fine received – penalty, not able to achieve gold rating
- Caution/ warning received – penalty, but able to achieve gold if only 1 received
- Certain redemption possible if corrective action taken
- If LWG not notified of fine/caution/warning that occurs – penalty: not able to achieve gold rating, or fail if 3+ received
05 Production Data (Previously Tannery Data)
217
Important section changes:
- This is a critical section, and the minimum threshold to pass the audit is 25%
- The name has been changed from “Tannery Data”
- Scoring highlights:
- A gold medal requirement is to source 100% from LWG certified sources (with conditional 5% allowance if trialing new suppliers)
06 Incoming Material Traceability
218
Important section changes:
- This is a non-critical, scored section
- This section will be pashed-in to become critical 12 months after the launch of P7
- Section name changed from “Material Traceability”
- Points scored for % traceable material, and weighted by method and level of traceability:
Type
|
Level
|
Detail
|
Weighting
|
Physical traceability
|
to slaughterhouse
|
Sourcing from commercial slaughterhouses
|
100% |
Documented traceability
|
to slaughterhouse
|
Sourcing from commercial slaughterhouses
|
80% |
Physical traceability
|
to group of slaughterhouses
|
mostly applicable to splits, split marked to identify supplier
|
70% |
Documented traceability
|
to a region (e.g. collection point/geo-referenced location)
|
mostly applicable to rural sourcing of small skins
|
60% |
Introduced “Sourcing Factor”
- a supplier score including risk assessment factors (deforestation, etc.)
- For those purchasing part-processed material, factor is based on supplier sourcing factor, traceability score and proportion of material from each supplier
Exotic material
- Critical requirement to source 100% of material legally (according to CITES or other legal document)
Material sourced from areas at risk of deforestation
- Increased regions to include the 3 main biomes at risk in South America, including Brazil and Paraguay
- For more information on this development, please visit our page on traceability
- Evidence will be required to prove that due diligence measures have been taken to ensure there is a low risk that materials have been sourced from areas of illegal deforestation
- Score awarded based on % traceable material and level of evidence provided:
- Robust evidence, for example a copy of a report of compliance from meatpacker’s in-house monitoring system or a copy of a report from 3rd party monitoring service provider - 100% weighting
- Simple declaration of compliance – 50% weighting
- No evidence – 0% for this section
07 Outgoing Material Traceability
219
Section details
- This is a new critical section, and the minimum threshold to pass the audit is 25%
- Points awarded for % of material traced through facility, as well as level of information tracked
- A minimum requirement is that a facility has a written procedure explaining the traceability system through the facility
- Scoring highlights:
- A minimum requirement for gold medal: traceability through facility AND tracking of batch data OR raw material supplier/group of suppliers
- Failure penalty for exotics if there is no continuity of traceability to a legal source
- Score awarded for physical marking of splits to identify producing tannery
08 Environmental Management Systems (EMS)
220
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- Increased environmental objectives to 5 - and 2 must be quantifiable with results showing progress/achievement
- Increased the importance of preparing and following an Impacts analysis
09 Restricted Substances, Compliance, Chromium VI Management
221
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- RSL is aligned with AFIRM’s risk-based RSL for leather, with appropriate ISO test methods specified for Cr VI
- Scoring highlights:
- Fail criteria if limit for CrVI is above 3ppm
- Medal award requirement:
- to test minimum 0.1% of batches against RSL
- to test to own and client’s RSL, and take corrective action in case of failures
- to follow 3rd party testing procedures specified by the company
- to ensure in-coming material and chemicals are RSL compliant
- Gold medal requirement:
- to test out-going part-processed and finished leather for CrVI sufficiently (according to a matrix of requirements)
- to test tanned leather a minimum of 4 times per year
10 Energy Consumption
222
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 25%
- Further differentiation of renewable energy sources, between GHG releasing sources and non-GHG releasing sources
11 Water Usage
223
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 25%
- Scoring highlights:
- Medal award requirement to effectively measure all in-coming sources of water
12 Air & Noise Emissions
224
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- Scoring highlights:
- Medal award requirement to maintain air emissions inventory by identifying all sources of air emissions AND identify each type (OR quantify the emissions)
- Gold medal requirement to have functioning emissions control devices
- Medal thresholds specified for VOC emissions per medal
- Gold <45 g/m2
- Silver <60 g/m2
- Bronze <75 g/m2
13 Waste Management
225
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- Scoring highlights:
- Medal award requirement
- to have waste management procedure, and it should comply with all local laws
- to maintain a register of all waste
- to monitor gaseous emissions and contaminants if waste is burnt on-site
- New requirement for management of excess salt recovered from salted or brined hides:
- Fail for uncontrolled disposal
- Penalty if stored on-site
14 Effluent Treatment
226
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- The relative section weighting has been increased to reflect its importance
- 24 months of data is required to be inspected
- Further alignment with ZDHC WW requirements
- Increased testing requirements to 5 key wastewater contaminants (from 4)
- Stricter limits
- Scoring highlights:
- Medal award requirement for 3rd party testing of wastewater used for irrigation
- Penalty for salt discharge above allowance (base level accepted is processor of fresh hides using 6% salt in pickle), still possible to achieve gold rating if salt managed well
- Minimum points required for each medal rating for testing of the 5 key wastewater contaminants
15 Health, Safety, Emergency Preparedness
227
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- 2 sections have been merged
- Scoring highlights - Medal award requirement:
- to ensure correct PPE is available and used by all staff + proof of continuous use
- to ensure correct incident response equipment is available where needed
- as a minimum to conduct annual assessment for worker VOC exposure
- to assess risk of exposure to H2S in all appropriate areas, and all risk management requirements are applied
- there are procedures in place covering all possible emergencies
- for drum guarding
16 Chemical Management
228
Section details
- This is a new, critical section, and the minimum threshold to pass the audit is 50%
- Minimum recognised MRSL is the ZDHC MRSL
- All LWG audited members now have free access to the ZDHC Gateway - contact us if you did not receive your invitation
- Introduced the ZDHC Gateway as a route to provide evidence of MRSL compliance
- Plan to ramp up compliance requirements in P8
- Scoring highlights:
- Medal award requirement for input material to be MRSL compliant (with different levels of requirements applied)
- Gold medal requirement to store all chemicals correctly and safely
17 Operations Management
229
Important section changes
- This is a critical section, and the minimum threshold to pass the audit is 50%
- This section merges the previous non-critical process sections