How much time is there between updates?

The Environmental Audit Protocol will remain in each issue state for at least three years wherever possible. However, minor or correctional updates may be made during this time.

How was the audit protocol developed?

The original Environmental Audit Protocol was developed by brands and leather manufacturers, with input from NGO’s such as WWF and Greenpeace, over a period of several years. It is regularly updated ensure it remains relevant and takes into account industry need and evolution, as well as providing the mechanism for gradual improvement. Additional audit protocols have been developed to meet the growing scope of the group.

What is the philosophy of the audit scope?

The philosophy is to keep the subject of the protocol focussed on environmental elements within leather production.

What is the scoring system based on?

The scoring system for the original versions of the Environmental Audit Protocol was based on benchmarking information gathered in the early pilot studies conducted around the world. Later versions of the Environmental Audit Protocol incorporated further data gathered during the auditing process and the scores are now determined by the LWG Technical Sub-Group (TSG).

How has the grading system been developed?

The system of scoring for awards was drawn on some of the concepts used by the International Safety Rating System (ISRS), a health and safety management system promoted and supported worldwide by Det Norske Veritas (DNV). That health and safety management system is based on a series of safety audits which comprise several sections with some 600 questions. Each answer is individually scored and finally the scores are accumulated. To achieve a given grade, a minimum score in each area is required. This is represented by the Audited, Bronze, Silver and Gold awards used by the Leather Working Group.

Are leather manufacturing facilities that process from raw skins penalised due to the additional waste they create?

The focus of the Environmental Audit Protocol is based upon ensuring that wastes are treated in an environmentally sound manner. The scores for the manufacturing sections are rationalised so that leather manufacturing facilities are compared on their overall manufacturing operations, not on the individual components of those operations.

Do leather manufacturers operating in regions with stricter environmental legislation score differently?

All leather manufacturers are expected to be in conformance with local regulations or with Environmental Audit Protocol requirements, whichever are the more stringent.

Do leather manufacturers with their own effluent treatment plants score more highly?

The greater the effort that a leather manufacturer takes to reduce environmental impacts whether by reducing usage of environmental resources such as water or energy, or by reducing the level of emissions to the environment, whether gaseous, solid or liquid, the higher the score on the Environmental Audit Protocol.

Can an auditor terminate an audit if standards are found to be too low?

In general terms the audit will not be terminated although a low score or a failure may be the result. However, if an auditor has concerns about the credibility or integrity of the data, they may decide to cancel the audit.

What feedback does a leather manufacturer get from the audit?

The auditor will provide a verbal report at the end of the audit to the appointed facility representative(s). The auditor will provide constructive advice regarding elements that could be improved upon and about any elements that are observed to require immediate attention. A copy of the completed audit report will be provided along with a summary report giving commentary on the performance of the auditee and relevant recommendations for improvement.

What documents need to be made available?

Copies of valid operating permits will need to be made available during the audit. The auditor may contact the company to be audited in advance of the audit to ascertain which regulatory authorities are responsible for issuing permits. Evidence of material source, energy and water usage, discharge parameters and EMS will also be required. See the Environmental Audit Protocol for further details.

Will a leather manufacturing group require more than one audit?

Yes. The audit is an assessment of the site, not the organisation. An exception may apply if two sites operate as one unit, have one operating permit and are located close to each other however, where an organisation has multiple sites each site must be audited. Two companies operating on one site will require separate audits only if they are distinct legal entities with separate operating licenses and operating as separate units. Please Note: Where the organisation works through a marketing company, reference can be made to this company in the body of the summary report, but only the site name can be included on the LWG audit reports, certificate and website.

Will the scale of operation (size or output of the leather manufacturing facility) affect the audit result?

Factors such as air emissions, energy consumption etc are determined per unit of leather produced not gross values.

What is the correct level of restricted substance testing?

The correct level of testing, whether it is for restricted substances or any other property, remains subject to agreement between the individual supplier and customer. This Environmental Audit Protocol aims to assess the leather manufacturing facility’s system for managing restricted substances.

Will an LWG audit mean I will have no restricted substance failures?

No. The audit covers a leather manufacturer’s compliance with each customer’s requirements and its ability to understand and manage chemicals. The audit will verify that the leather manufacturing facility has relevant customer’s restricted substance specifications and that it has tested against these using ISO17025 at a customer nominated accredited laboratory during the 24-month period between audits.

Can the audit protocol be used to improve performance?

The leather manufacturer undergoing an audit is provided with a copy of the assessment so that it is possible to identify those aspects which score less highly. The LWG-approved auditor will be capable of giving advice on the best means of achieving improved performance. This advice will be given at both the verbal debrief and in the audit report.

Is it advantageous for the leather manufacturer to be accredited by any other scheme such as ISO14000 or EMAS?

No, this used to be the case however, this accreditation may be used as evidence in some sections of the Environmental Audit Protocol.

Our organisation is already certified to ISO 14001. In what way is this different from the LWG audit?

The LWG audit measures environmental performance whereas the ISO standard does not. The operation of the ISO (or other) standard is a component part of the LWG Environmental Audit Protocol. The ISO standard relates to the management system and is explicit in not attempting to quantify environmental performance. The LWG Environmental Audit Protocol assesses leather manufacturing facility operations in absolute terms, for example energy requirement to produce a square foot of leather, proportion of wastes recycled etc

Will information from third party organisations be required?

A certain amount of information, such as copies of permits from regulatory authorities issuing operating permits, third party restricted substance test reports etc will be required. The auditor can advise well in advance of the audit what documents will need to be examined.

Are there sections that lead to automatic failure in the audit?

Yes. Please view the current audit protocol here; http://www.leatherworkinggroup.com/howwe-work/audit-protocols; for further understanding.

Are sub-contracting operations taken into account?

Yes, by way of an LWG mini-audit on all sub-contractors used by the company. The mini-audit is based on a limited number of the sections of the protocol but does not result in a rating for the sub-contractor.

How does LWG take into account leather manufacturing facilities that produce 30% of their production as small samples or that produce very small amounts of leather?

Many of the audited leather manufacturers already produce high numbers of small samples. In addition, leather manufacturers with this profile have achieved Gold and Silver.

Why is traceability important in Europe?

Traceability is a global requirement, not a regional one. Brand members have repeatedly said that they want to know where their material comes from, as there is increasing pressure from consumers who want to be reassured that materials used are appropriate.

What process is in place to ensure the accuracy and confidentiality of the data and results of individual company audits?

Auditors will be required to submit their client’s full audit results. These must be submitted to a peer review process so that the results, calculations and assumptions can be verified. All audits will be peer reviewed by another LWG-approved auditor, who will review the calculations and findings using a systematic process of evaluation. Data and results from individual audits are treated in the strictest confidence and are only made available to the LWG contracted facilitator for verification purposes and for use in benchmarking studies, only upon permission having been granted by the audited party. The data is aggregated and at no time is any of the data recognisable as coming from an individual leather manufacturing facility.

Scope of traceability

LWG’s aim is to have material marked from the slaughterhouse, right through to the end product manufacturer. Traceability is rated separately from the environmental score and has no impact on the final score or medal rating. Only the percentage of material that is traceable back to slaughterhouse through physical marking and through robust paperwork is shown on the audit certificate.

Why is traceability important in Europe?

Traceability is a global requirement, not a regional one. Brand members have repeatedly said that they want to know where their material comes from, as there is increasing pressure from consumers who want to be reassured that materials used are appropriate.

Does the audit cover animal husbandry and slaughtering practices?

No. The audit is site specific and does not assess farms, animal husbandry, and transportation of animals or slaughtering practices.

How does the audit cover environmental violations?

The Environmental Audit Protocol has a section that identifies previous violations and scores the leather manufacturing facility accordingly. Violations are declared by the leather maker at the time of the audit. The audit is a two-day snapshot in time and not a live situation. Any subsequent violations or warnings will be scored during the next audit.

What if a leather manufacturing facility experiences major violations or persistent discharge problems?

If a leather manufacturer is seen to have persistent problems or a major violation, then their certification may be suspended by the auditing body or the LWG Executive Committee depending on the circumstance.

What is the position with regard to LWG audit certification and effluent treatment plant violations?

If the leather manufacturing facility operates its own ETP and there is a violation of sufficient severity to prompt withdrawal of certification, a re-audit will be required for the company to be recertified. If the leather manufacturing facility discharges to a CETP or METP and there is a violation of sufficient severity at the treatment works to prompt suspension of certification, a re-audit will NOT be required for the company to be recertified. If the situation is rectified, and there is evidence of this, certification would be reinstated if the operations in the leather manufacturing facility are unchanged.

What happens if a leather manufacturer deliberately misleads an auditor?

If a leather manufacturer withholds critical information or is found to be providing misleading information, then their certificate will be withdrawn, and they may be restricted from re-audit for a period of time and their membership of the LWG cancelled.

Will an LWG audit ensure my leather manufacturer has no violations in the future?

No. The audit is a two-day snapshot in time and does not provide live monitoring. Following certification, it is the leather manufacturing facility’s responsibility to maintain compliance throughout the certification term.

How does the protocol cover common effluent treatment plants?

The quality of the final effluent is assessed as part of the audit which means the efficiency of a CETP could affect the scores achieved by the leather manufacturing facility. CETPs are not audited but third-party evidence of CETP performance will be required as part of the audit.

How will I be scored if my effluent plant performs better than the CETP?

If the discharge from the in-house ETP is of a higher standard than that of the municipal or CETP then this will form the basis of the audit scores. The ETP must meet local legislative requirements as a minimum.

Does the audit measure air quality?

Currently the audit requires leather manufacturers to comply with local legislation, identify emission points and have appropriate control devices. There are currently no measurements of internal air quality as part of this audit.

Is there a full legal compliance check conducted as part of this audit?

No. This is a site audit and it does not include a full legal compliance check with local authorities.

Is worker safety assessed in this audit?

No. The focus is environmental issues. There is an assessment of emergency plans which includes a limited assessment of the provision of health and safety equipment as well as clear access routes and guarding of machinery.

Will an LWG audit mean a leather manufacturer will have no Chrome VI failures?

Due to the batch nature of leather processing it is impossible to guarantee that a Chrome VI or any form of RSL failure will not occur. It is a requirement that any failures are reported to the LWG auditor.

What is the Trader Assessment Protocol?

The Trader Assessment Protocol assess the facilities that buy and sell material in a partprocessed state. It verifies volumes of material from suppliers and customers to improve traceability of material through the supply chain.

What is the Chemical Management Module (CMM)?

The CMM is a voluntary add-on to the main Environmental Audit Protocol. it is designed to ensure compliance and testing of MRSL and management of Chrome and Chemical Health and Safety. The CMM will be incorporated into the main Environmental Audit Protocol when the next update is launched.

How can I better understand the scoring system?

The best way to understand the scoring is to read the Environmental Audit Protocol and review the scoring table at the front of the document. http://www.leatherworkinggroup.com/howwe-work/audit-protocols. Leather manufacturing operations vary considerably depending on the type of hide or skin being processed, and the type of leather being made. Discretion and realism must be practiced by the auditor during the audit, the score calculation and the reporting to reflect these differences. Where the activities of the leather manufacturer fall between two or more possible score options, the auditor is required to assign a score (or partial score) that reflects the evidence presented.

Scoring for awards

The sections with values in the columns for Gold, Silver or Bronze in the table on page i are critical scoring sections. That is to say that if you do not score the minimum for each and every one of those sections you do not get the classification. The total percentage score at the bottom refers to the overall minimum percentage score required for the classification. You must score at least the minimum for each critical section plus additional points from the noncritical sections and so doing achieve the minimum total score for the classification.

Differences between medal awards

The medal levels have been set based upon best practice within the industry and the incremental improvement philosophy of the LWG. Therefore, because of both the content of each section and the above items there is not necessarily a linear connection between the environmental impacts of the awards. The sections are scored 85 (Gold), 75 (Silver), 65, (Bronze) for simplicity. A non-medal rated (Audited) and fail are also possible outcomes.

What is Eco or Environmentally preferred leather?

There are no official characteristics that determine whether leather can be classed as an ECO-leather. This language is typically marketing or consumer communication versus an actual classification of the leather type. The LWG believes, based on extensive research and industry knowledge, that environmentally preferred leather can be defined by two key parameters: 1. How the leather is manufactured 2. The inputs used to manufacture it.

What is organic leather?

There is no official terminology. This term is sometimes used for leathers that are not tanned with mineral tanning agents. It is highly ambiguous and has led to the false belief in some quarters that the skins or hides have come from organically reared animals.

Is Chrome free leather better than leather containing chrome?

These two types of leather have different properties, and each have their own market position. Lifecycle analyses have indicated that different tanning agents all have environmental impacts, but different ones. It is up to individual values to decide which impacts are higher priorities over others. Also, lifecycle analysis work has shown that significant impacts occur throughout the leather making process, not just when the article is tanned.

Why are volumes for pig leather not included in the LWG Benchmarking?

LWG benchmarking data for leather volumes is prepared using the FAO figures (Food & Agriculture Organisation of the United Nations) and Pig is not included within those statistics for the following reasons: • Metrics can be highly variable as pigskin is often split meaning that figures could be 2 billion, 4 billion or any number between per annum. • Many pigs are raised and slaughtered in China and Vietnam, so any data tends to be unreliable. • Pigs can be raised quickly (with accelerators sometimes being employed) so metrics might not reflect the true number of pigs raised and slaughtered in any one year. LWG is careful to ensure that for benchmarking purposes we provide as accurate a picture as possible which is why we exclude pig from the data.

How can national leather manufacturing facility associations take part in LWG or how can they become members of LWG?

National associations and industry groups are permitted to join the LWG as Associate Members. Members rights are the same as other members except voting rights which are not part of Associate Membership.

How do leather manufacturers join the LWG?

As a leather manufacturer you can join the group by having an LWG audit conducted by any approved auditor shown here http://www.leatherworkinggroup.com/how-we-work/ourauditors. Membership is only granted while a leather manufacturing facility is covered under a valid audit certificate.

How frequently should I have an audit?

Certification is valid for 24 months for leather manufacturing facilities and 12 months for partprocessed material traders.

Can I schedule an audit earlier or later than the renewal date?

An audit can be conducted as often as the audited party wishes, but for some metrics a minimum of six months new data may be required. Currently, an audit can be conducted up to one month after the expiry date. If the audit falls outside this one-month window the audited party will be removed from the LWG web-site and the certificate deemed to have expired.

What is the audit duration?

Audit duration is typically two days per site for an average leather manufacturing facility. Additional time and costs will be associated with assessment of sub-contractors if applicable.

How do those that do not manufacture leather become members?

Brands, retailers, chemical suppliers, machinery suppliers and other suppliers and technical experts can join through an annual subscription. Please find our Membership Proposal Pack here https://www.leatherworkinggroup.com/brands-and-retailers.