VERSION 1.0 MARKS & SPENCER MARCH 2014 ECP MINIMUM STANDARDS DUE DILIGENCE FOR CHEMICAL COMPLIANCE

Transcription

1 ECP MINIMUM STANDARDS DUE DILIGENCE FOR CHEMICAL COMPLIANCE ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 1 f 6

2 MODULE CONTENT 1 Intrductin Due Diligence Testing Prduct testing Risk assessment Respnse t M&S Due Diligence Testing Test results Risk assessment... 6 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 2 f 6

3 DUE DILIGENCE TESTING FOR CHEMICAL COMPLIANCE 1 INTRODUCTION During the manufacturing prcess, gds may be expsed t chemicals which may be hazardus t wrkers, the envirnment and cnsumers. The main (but nt exclusive) area fr expsure is wet prcessing, (dyeing, finishing, tanning, printing, garment washing etc), and the hazardus chemicals likeliest t be used in these prcesses are listed in the Marks & Spencer Restricted Substances List (RSL) and Manufacturing Restricted Substance List (MRSL). The MRSL defines chemicals which must nt be present deliberately in frmulatins used in the prductin f gds fr Marks & Spencer. The RSL gives the maximum limits allwed fr each chemical as residue n the final prduct. The Primary Supplier must have a Due Diligence Prcedure in place t ensure cmpliance with these limits. Nn-cmpliance with the requirements f the RSL may lead t actins such as Return t Manufacturer (RTM) f the prduct and/r a fine chargeable t the Garment/Prduct Supplier fr breach f RSL cmpliance. It is a criminal ffence under Eurpean and United Kingdm Prduct Safety Legislatin t ffer fr sale merchandise which is unsafe r misleading r t make cmmercial claims which are nt substantiated. Therefre it cannt be emphasised sufficiently that the RSL must be cmplied with at all times. The purpse f the prcedure is t demnstrate that Marks & Spencer and Suppliers perate systems f checks and cntrls t shw that Marks & Spencer has taken all reasnable precautins and all due diligence in discharging its bligatins with regard t residual chemicals n the final prduct in accrdance with the Marks and Spencer RSL. The Primary Supplier must als be able t demnstrate that they have systems f checks and cntrls in place t ensure that prducts cmply t M&S s standards. The Primary Supplier is required t infrm their suppliers f Due Diligence requirements, and t instigate plans t manage their suppliers cmpliance. As such, each Primary Supplier must identify a named member f their management team t be respnsible fr Due Diligence in their cmpany. Due Diligence fr chemical testing is carried ut in additin t physical and clur fastness testing and testing fr safety and prmtinal claims as apprpriate. Fr further infrmatin n Marks & Spencer s Due Diligence plicy and requirements, please visit the Supplier Exchange. ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 3 f 6

4 2 DUE DILIGENCE TESTING 2.1 Prduct testing The Garment/Prduct Supplier is respnsible fr ensuring that the prduct supplied cmplies with the requirements f Marks & Spencer. It is mandatry fr Wet Prcessrs t have a current ECP number and be cmpliant with the requirements f the MRSL and RSL. Best practice fr the Primary Supplier is t ensure that the mills carrying ut wet prcessing are cnversant with the RSL, and they may wish t have a prir agreement with the mill as t the cnsequences f nn-cmpliance with the RSL. Marks and Spencer expects the Primary Supplier t test finished prducts at a frequency t ensure cmpliance. The frequency f testing will depend n the risk f ptential nn-cmpliance, and the Garment/Prduct Supplier shuld evaluate this risk based n criteria including the fllwing: The Mill s reputatin, and the skills and knwledge f their technical persnnel Incidence f previus RSL failures frm the Mill The cmplexity f the prduct, including the applicatin f special finishes The end use f the prduct, eg Kidswear Testing frequency may vary with the prduct, but a suggested minimum frequency is t test at the fllwing stages f manufacture where apprpriate: Preprductin First bulk Prductin - nce per style per seasn 2.2 Risk assessment The selectin f tests will depend n the likely prcessing t which the prduct has been expsed. Criteria will include fibre type, shade dyed, special finishes applied, presence f accessries etc. Marks and Spencer will test against the methds listed in the RSL, and Suppliers are advised t use these methds. Risk f nn-cmpliance will depend n the prduct type, and the dyes and chemicals likely t have been used in their manufacture. The Risk Assessment Chart (please see 2.5) is designed t assist in assessing the risk f the presence f residual chemicals n the final prduct. Marks and Spencer will use this chart in its risk-based testing prgramme. The areas f risk are highlighted fr each general prduct type, and either all, r a cnsidered selectin f, these tests will assist in ensuring cmpliance with the RSL requirements. Please nte that the chart prvides a guideline nly, and if the Garment/Prduct Supplier has cncerns ver ther areas f cmpliance, then tests shuld be carried ut accrdingly. ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 4 f 6

5 2.3 Respnse t Marks & Spencer rutine Due Diligence Testing If a failure is fund during Marks & Spencer s rutine Due Diligence testing, the Primary Supplier will prvide n request their Due Diligence test reprts fr the prduct. If requested, the Garment/Prduct Supplier will carry ut further tests n the prduct, and prvide the results t the Departmental Technlgist within tw weeks. 2.4 Test results The limits quted in the RSL d nt have inbuilt tlerances. A result equal t r belw the limit is a pass, while a result abve the limit is a failure. If a failure is fund, the fllwing prcedure shuld be adpted: Infrm the Marks & Spencer Technlgist f the failure immediately, and prvide the riginal test reprt Test mre f the prduct t establish the scale f the prblem Infrm the wet prcessing Mill f the failure, and agree an actin plan t establish the cause f the failure and the steps necessary t prevent further ccurrences. Please be aware that Marks and Spencer may request full details f the wet prcess in rder t establish the nature f the issue and their respnse t the nn-cmpliance ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 5 f 6

6 VERSION 1.0 MARKS & SPENCER XXXX Due Diligence Testing Risk Assessment fr Chemical Testing RSL Test Cttn, Linen Viscse, Tencel Cttn/PES Viscse/PES Wl & hair fibres Wl/ PES Silk Plyester Plyamide Natural leather Acrylic Acetate Pigment Dye/Print Reactive Print Plastisl Print Mck Leather Metal Zips etc. Az dyes Black Black Black Disperse dyes Pale Pale APEOs Organtins Chlrinated Phenls Mercury Cttn Mthprfing agents PFOS/PFOA Where PFC finish applied Dye carriers Chrme VI Black Navy Black Navy Organic slvents Bicidal finishes Where Bicidal finish applied Dimethyl fumurate Flame retardants Where FR finish applied Phthalates Frmaldehyde Easy care Dark Dark Pesticides ph Childrenswear and Intimates Cadmium Red, Orange, Yellw Red, Orange, Yellw Nickel Antimny Lead Cpper Chrmium SCCPs Area f higher risk MODULE 8 ENVIRONMENTAL & CHEMICAL POLICY FOR TEXTILE PROCESSING Page 6 f 6