Getting to know P7: 24-month data period phase in

Leather manufacturers will be required to submit 24 months of data under the LWG Leather Manufacturer Audit Protocol 7 (P7)

In previous versions of the LWG Audit, tanners were required to submit 12 months of data to achieve their LWG certification. Under Protocol 7, the period for assessment has been increased from 12 months to 24 months. Monthly data for 4 key sections will need to be submitted during an audit: Production Data, Energy Consumption, Water Usage, and Effluent Treatment.

Phasing in the requirement

The period for assessment has been increased from 12 months to 24 months from P6.7 to P7. As this is a new requirement, announced on 22 February 2021, it will be phased in. This means that between August 2021 and August 2022, the period of assessment will increase each month, from 12 to 24 months.

Tanners will need to submit data for a period of 12 months PLUS the number of months since August 2021, when P7 becomes mandatory. The final number of months assessed will depend on the data period selected. The data period is flexible and should be the most recent months for which data is available, with the last month being not more than three months prior to the audit.

For example, a company being audited in November 2021 may be assessed using 14 months of data – including 12 months from 1 September 2020 to 31 August 2021 PLUS the 2 months from 1 September to 31 October 2021.

However, a company being audited in December 2021 may also be assessed using the same 14-month data period – including 12 months from 1 September 2020 to 31 August 2021 PLUS the 2 months from 1 September to 31 October 2021. This is because the data period ends with the last month being not more than three months prior to the audit.

By November 2022, all leather manufacturers undergoing an LWG Audit will be required to provide the full 24 months’ worth of data.

Concessions and Covid-19

There is always a standard annual 3-month seasonal exemption for energy consumption, to account for additional energy needs for heating or cooling during extreme winter or summer months. Monthly data, including energy consumption and energy type, for the two full years should be supplied and recorded in the audit report. The data period can be calculated based on two periods of nine months’ worth of data. The three months making up an excluded period must be consecutive, and both of the excluded periods must cover the same months.

For audits undertaken during the Covid-19 pandemic, there is an additional three-month exclusion allowed for water and energy – for energy, this is in addition to the standard seasonal exclusion allowance. The additional three months do not need to be consecutive, but the same three months must be selected for both water and energy. Monthly data for the full 2 years must be supplied and recorded in the report.

This allowance is only applicable during the Covid-19 pandemic. The LWG Technical Sub-group will review this concession periodically and will decide to discontinue it once the situation improves. Notice of the change will be published on the LWG website.

Production Data

Tanners must provide 24 months of data related to their suppliers and the procurement of their material, as well as the types of production completed on site.

Energy Consumption

Tanners must provide 24 months of data related to their energy usage on site to establish a metric for the amount of energy used per area of material produced. This includes the amount of energy used on site, the energy source, and the energy used by all subcontractors (if any), over a 24-month period.

Water Usage

Tanners must provide 24 months of data related to their water consumption on site to establish a metric for the amount of water used per area of material produced. This looks at the quantity of water used, the water sources, and water recycling over a 24-month period.

Effluent Treatment

Tanners must provide evidence of testing five contaminants contained within wastewater over a 24-month period, to establish average emissions and understand the performance against set limits.

Additional Sections

Some additional sections will require evidence of compliance within the 24-month period, but tanners will not be required to submit data points for a full continuous 24-month period.

 

Questions? Please reach out to the LWG team at info@leatherworkinggroup.com