Leather Manufacturer Audit Protocol 7

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)

This is a non-scored section.

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

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:

1. Social Labour Convergence Program (SLCP)
2. Sedex Members Ethical Trade Audit (SMETA)
3. Worldwide Responsible Accredited Production (WRAP)
4. Higg FSLM
5. Social Accountability International SA8000
6. UNIC Code of Conduct and Social Accountability
7. Business Social Compliance Initiative (BSCI)

Further social compliance audits can be reviewed upon application - please contact us to find out more.

Brand audits will need to be approved to be considered equivalent to third-party audits. 

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

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)

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:

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

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

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

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

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

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

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

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

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

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

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

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