PROTOCOL AND TECHNICAL
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.
GENERAL, LEATHER AND THE ENVIRONMENT
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.