M&S

Marks & Spencer C99

C99

Environmental, Chemical and Factory Minimum Standards

for

Dyeing, Printing and Finishing

Clothing and Textiles

November 2006

Replaces ECOP Issue No. 5 dated September 2004

Environmental, Chemical and Factory Minimum Standards November 2006 Page 1 of 27

Marks & Spencer C99

Introduction

Dear Supplier Marks and Spencer has always taken its responsibility to protect customers, workers and the environment seriously. We accept that without the use of dyes and chemicals we would not be able to provide our customers with satisfactory products but it is incumbent on the supply base to use chemicals responsibly and use those that do not pose unnecessary risks to workers, customers or the environment. The ‘Environmental Code of Practice’ was a landmark document and that has served us well for many years but we are now working with a far more complex range of products from a truly global supply base against a backdrop of tighter legislation. There are also, quite rightly, greater demands for accountability from customers, media and non-governmental organisations. With this in mind we have developed a simplified, integrated set of minimum standards for worker safety, environmental compliance and chemicals on finished product. Management of chemicals is a very complex subject and, in addition to setting out our minimum standards, this document aims to provide some background information outlining the reasons for our policies and also some guidance to help minimise the risk of factory, environmental or product failures. Please confirm that you have received this document by e-mail and then carry out the simple self-audit. Compliance with minimum standards and the completion of a self audit is a mandatory requirement for doing business with Marks and Spencer. If you require any further assistance please do not hesitate to contact me. Phil Patterson Dyeing, Printing, Finishing and Colour Manager


Marks & Spencer C99

What you will find in this document

• An explanation of our corporate policies and general requirements relating to worker safety, environmental compliance and customer safety, and why they are important to us.

• Step by step guidance for supplier compliance. • Details of our minimum standards requirements. • A simple, one-page Self Audit document to demonstrate compliance (also available as a separate word document). • A table containing all necessary information regarding chemicals that we must eradicate or control (including test methods and

permitted limits). • Explanatory notes to give guidance on selection of dyes and chemicals to ensure compliance. • Several appendices - containing detailed lists of controlled chemicals, information on who is responsible for meeting the minimum

standards and detailed best practice to meet minimum standards.


Marks & Spencer C99

These standards apply to:

• Dyehouses • Printworks • Finishing Facilities • Laundries • Tanneries

• The Chemicals used within them • The Products they produce

− Facilities that process products with Marks & Spencer labels attached will also require a social compliance audit. − Additional componentry such as zips, threads and interlinings must comply with the standards relating to chemicals on

finished product and the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied.

− Although chemical use is limited in knitting, weaving and garment making facilities the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied.

Marks & Spencer will not place orders with companies who fail to declare full details of production routes Marks & Spencer reserve the right to cancel orders and return products in the event of non-compliance Full details of dyes and chemicals used must be made available on demand, if necessary under a secrecy agreement


Marks & Spencer C99

What Next? – How to demonstrate compliance:

1. Confirm receipt of this document to [email protected] stating your company name, the nature of your business, the garment/product maker and M&S departments you are supplying

2. Read all the information in this document –including appendices 3. Select dyes from suppliers ‘compliant dyes and chemicals’ list or get confirmation from suppliers that dye and

chemical inventory complies with these minimum standards. 4. Gather information regarding effluent, discharge and disposal consents and recent test results to confirm

compliance. 5. Ensure factory meets minimum standards for worker safety and QA procedures. 6. Carry out risk-based checks on raw materials and finished product to confirm compliance. 7. Complete Minimum Standards Self Audit form (available as stand alone document on Quality Standards website

and send to [email protected] as a Word document or fax to +44 20 87187725. Please do not send scans with file size > 0.5 Mb.

8. Read and follow best practices in Appendix 2 to build ongoing compliance into normal working procedures.

How Marks & Spencer Monitors Compliance with Minimum Standards

Worker Safety and Quality Systems – Site-visit by garment/product manufacturers or Marks & Spencer personnel is required to verify self audits. Failures will be addressed by either action plans for minor discrepancies, or termination of business for severe failures.

Environmental – on site visits by Marks & Spencer personnel or independent environmental auditor to verify self audits.

Chemicals on Product – Risk based product testing. Failures will need to be discussed with Marks & Spencer and will result in either an action plan for eradication or products being removed from stores depending on the circumstances. Chemical testing may be demanded at the time of technical submission by Marks & Spencer technologists.


mailto:[email protected]


Marks & Spencer C99

Minimum Standards Policy

Factory / Worker Safety Environment Chemicals on Garments/Product Marks & Spencer will not do business with suppliers who fail to look after the health and safety of their workers.

QC Systems

Marks & Spencer will not do business with suppliers who do not have the necessary controls and management systems in place to consistently meet our technical, safety and environmental standards and on-time delivery.

Marks & Spencer will not do business with suppliers whose processes pollute the environment in which they operate.

Marks & Spencer will not sell products if

The chemical content renders them illegal or harmful to customers.

Anyone in the supply base has broken any laws regarding the use or disposal of specific chemicals.

Anyone in the supply base has wilfully failed to adhere to our policies regarding the use or disposal of specific chemicals.


Marks & Spencer C99

Minimum Standards Detail

Factory / Worker Safety Environment Chemicals on Garments/Product All fire exits must be marked, unlocked and not obstructed Adequate and appropriate fire fighting equipment must be

available and be clearly marked and accessible No smoking in working areas of factory No eating or drinking in areas where dyes or chemicals are

handled Housekeeping, building construction and working

environment must be to a standard that does not compromise worker safety

Working dye and chemical stores must be indoors, dry and tidy

An authentic material safety data sheet for every dye and chemical must be available in the local language in the vicinity of where dyes and chemicals are handled

Dyes and chemicals must be labelled and stored in accordance with detailed information in the MSDS

Appropriate personal protective equipment must be worn All machines must be electrically and mechanically safe Factory must comply with local health, safety and

employment law

QC Systems All dyes and chemicals must be accurately weighed or

measured (not approximated using scoops etc) Scales must be clean, dry and calibrated Must have an Indoor greige area that is clean, dry and tidy Written procedures must be available for all processes Batch cards must accompany every batch of production Must have light box and basic QC tests on-site Records of colour continuity and test results must be kept

for every batch Raw materials must be checked, finished production must

be examined prior to dispatch and records must be kept Must have access to Marks & Spencer quality standards

website

Untreated effluent must not be discharged directly into water courses

Water must be treated on-site, in a communal water treatment plant or by a local authority water treatment plant

Measures must be taken to avoid emission of noxious fumes into the air from stored chemicals and solvents, textile processing, utilities (steam production, generators etc) or incineration of waste

Solid waste must be disposed of according to local government recommendations and regulations

Packaging must be disposed or recycled in accordance with local legislation

The natural balance of the surrounding area should not be disturbed e.g. over-abstraction of water

Suppliers must demonstrate ongoing compliance with local government discharge and emission (consent) limits.

Although we do not have any specific standards regarding water and energy consumption we do expect suppliers to take all reasonable steps to minimise wastage. The major source of wastage is the inability to meet standards without re-dyeing or re-finishing.

The following chemicals must not be deliberately used and must not be present on final product at concentrations above those specified

Banned Azo dyes 30 ppm Skin sensitising dyes 30 ppm Apeo’s 1000 ppm Organo Tin 0.05 ppm PCP’s 0.05 ppm Mercury 2 ppb Moth-proofing 10 ppm PFOS 1 ppm PFOA 1 ppm Carriers 1 ppm

Processes using the following chemicals must only be used with written consent of a Marks & Spencer technologist and must not be present at concentrations above those specified:

Chromium VI 3 ppm Organic Solvents limit of detection

The following chemicals are only permitted above the specified concentrations if their use has been authorised by Marks & Spencer

Biocidal Finishes see table p.9-12 Applied Flame Retardants 5 ppm PVC / Phthalates see table p.9-12

The following chemicals must not be present above the specified concentrations:

Formaldehyde 75 ppm (free), 300 ppm (released) Pesticides/Insecticides 0.5 ppm (wool), 0.05 ppm

(cotton) See chemicals on finished product table for detail additional detail for leather and children’s wear


Marks & Spencer C99

Minimum Standards Self Audit – Please see Quality Standards website for stand alone document in Word format.

Factory / Worker Safety Environment Chemicals on Garments/Product

All fire exits are marked, unlocked and not obstructed Production volume for past 12 months (tonnes)

Adequate and appropriate fire fighting equipment is present in all areas of factory and is clearly marked and accessible

% of batches topped up, re-dyed or refinished

All dye and chemical suppliers have confirmed that their products being used for M&S production meet these minimum standards

No smoking in working areas of factory Confirm no breaches of air emission consent limits in

previous 12 months

No eating or drinking in areas where dyes or chemicals are handled

Confirm all solid waste is disposed in accordance with local government recommendations

Please confirm that the following chemicals are not knowingly applied or brought in via raw materials at concentrations above those stated in the Marks & Spencer minimum standards

Banned azo dyes Housekeeping, building construction and environment is to a standard that does not compromise worker safety

Untreated effluent is not discharged directly into water courses

Skin sensitising dyes

APEO's Dye and chemical stores are indoors, dry and tidy

Organo tin PCP's

Effluent pass rate for past 12 months No. of Tests

% Mercury

pH Moth proofing

A material safety data sheet for every dye and chemical is available in the local language in the vicinity of where dyes and chemicals are handled

COD PFOS based fluorocarbons BOD PFOA containing fluorocarbons Dyes and chemicals are labelled with appropriate safety

clauses and stored in accordance with MSDS information

Suspended Solids Carriers Temperature Pesticides / Insecticides Appropriate personal protective equipment and closed shoes

are worn as detailed in the MSDS

Metals

Toxins / Restricted substances All machines have been checked and are electrically and mechanically safe

The company complies with local health, safety and employment legislation

QC Systems

All dyes and chemicals are weighed or measured (not scooped)

Please confirm that the following chemicals are either not used, or have been authorised for use by an Marks & Spencer technologist

Not Used Used by Consent

Scales are clean, dry and calibrated Chromium VI

Indoor greige area Organic Solvents

PVC Written procedures for all processes Batch cards accompany every batch of production

Phthalates

Capable of basic QC tests on-site Biocidal Finishes Records of colour continuity and test results kept for every batch FR Finishes

Production is examined prior to dispatch and records of inspection are kept.

Any additional information:


Marks & Spencer C99

Chemicals on Finished Product

Chemical

What M&S products are most likely to be affected?

What is the origin of the controlled

chemical? Why is it nasty?

Retail legal status

Supply base legal status

Acceptable limit on finished

product

Limit of Detection

Test method

Banned Azo dyes No deliberate use

All fibre types Banned amines listed in appendix 7. Examples of dyes that can form such amines listed in appendix 6

Dyes can split to form carcinogenic amines

Sale of products containing > 30 ppm is illegal

Use of products containing > 30 ppm is illegal

30ppm 10 ppm Textiles: C62a (refers to EN 14362 part 1 and 2) Leather :C62b (CEN ISO/TS 17234:2003)

Skin Sensitising Dyes No deliberate use

Polyester, Acetate, disperse-dyed nylon

Disperse Dyes listed in appendix 8

Once sensitised to a dye people can react violently to trace quantities

No Legal restriction


30 ppm (2 ppm in extract)

2 ppm DIN 54231

Alkyl phenyl ethoxylates (APEO's) No deliberate use

All fibre types In widespread use as detergents, Wetting agents and as emulsifying agents

Endocrine disruptors (sex change chemicals) for aquatic species


Use of formulations

containing over 0.1% of NPEO is illegal in Europe

1000 ppm* temporary standard

1 ppm C65

GCMS or LCMS

APEO notes NPEO (nonyl phenyl ethoxylate) is the APEO that causes greatest concern. It is anticipated that legislation regarding its use will harmonise worldwide and we will then lower the standard. Current EU legislation is Marketing and Use Directive 2003/53/EC

Organo tin compounds. No deliberate use

All fibre types Preservative for fabrics and chemical formulations. Occasionally used as stabilizers and catalysts

Tributyl tin is highly toxic and related products have toxicity issues

could be governed by biocidal substances directive

Use is effectively prohibited via water authority

regulations

0.05 ppm (in extract)

0.05 ppm Textiles: Solvent extraction + gcms (in-house methods) Leather: SATRA TM277

PCP – pentachlorophenol and derivatives No deliberate use

Cotton, Viscose Preservative for cotton and viscose. Main risk is on imported greige

Highly Toxic could be governed by biocidal substances directive


regulations

0.05ppm (in extract)

Leather 0.5ppm

0.1ppm Textiles: water/steamdistillation (in-house methods) Leather: EN TS 14494:2003

Mercury No deliberate use

Cotton Caustic soda that is made by the 'mercury cell process'

Highly toxic could be governed by biocidal substances directive


regulations

2 ppb 2 ppb Any appropriate technique e.g. Combustion amalgamation with cold vapour detection


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Chemical




Retail legal status



product

Limit of Detection

Test method

Mothproofing No deliberate use

Wool, (Cashmere, Angora)

Commonest chemical is permethrin - found on wool and cashmere

Nerve agent and toxic to aquatic species



regulations

Contamination limit 10ppm

1 ppm Analytical -HPLC

PFOS No deliberate use

All fibre types Water-repellent ‘8-chain’ fluorocarbon finishes based on electrofluorination (old generation Products)

proven health risks and persistent in the environment

Legislation restricting PFOS has been proposed


1 ppm (in extract)

1 ppm solvent extraction + lc-ms

PFOA No deliberate use

All fibre types Water-repellent finishes based on telemerisation

Persistent in the environment and suspected health risks



1 ppm (in extract)

1ppm solvent extraction + lc-ms

PFOA notes PFOA (perfluorooctanoic acid) is used in the manufacture of the building blocks for fluorocarbons that are applied to textiles. Users of fluorocarbon finishes should get written confirmation from the manufacturer that traces of PFOA and materials that can theoretically form PFOA have been minimised.

Dye Carriers No deliberate use

Polyester Used to dye polyester and blends at low temperatures in machinery not capable of being pressurised

Various depending on type of carrier - generally toxic, irritants or carcinogens


Some chemical types are

prohibited

1 ppm For halogenated

aromatic hydrocarbons, tri-chlorobenzene,

biphenyl or ortho phenyl phenol

1 ppm solvent extraction gc-ms

Chromium VI. Consent Required

Wool, (Cashmere, Angora)

Chromium compounds used in 2-stage 'after-chrome' wool dyeing

Highly toxic / carcinogenic both to humans and aquatic species


Large scale use is effectively

prohibited via water authority

regulations

3 ppm

Leather 10ppm

3 ppm

CEN 14495 = 10ppm

Textiles: C60 (refers to BS 6810) Leather: CEN/TS 14495:2003

Organic solvents Consent Required

Panel Printed or solvent-scoured fabrics

Used in some adhesives, print formulations, solvent scouring and spot cleaning

Various depending on type of solvent

Some solvents are restricted

Some solvents are banned - e.g. ozone depleting substances, carcinogens

Limit of detection Varies according to chemical type

GCMS + Head Space

Organic solvent notes

Where solvents are used suppliers should always seek to change to water based alternatives. Where this is not possible e.g. dry pigment discharge printing there must be adequate extraction of fumes, good ventilation, and workers must be provided with appropriate personal protective equipment. Solvents are permitted for scouring greige but these must be in fully enclosed, zero emission systems. No residual solvent is permitted on any finished product.


Marks & Spencer C99

Chemical




Retail legal status



product

Limit of Detection

Test method

Biocidal Finishes Consent Required Not permitted in Childrenswear

All fibre types Deliberate application

Toxic Some chemicaltypes are restriced

Some chemical types are restricted

by water authorities

Limit of detection unless agreed in writing by technologist

varies according to type

Analytical - HPLC

Biocidal finish notes

Biocidal finishes must be permanent, non-leaching, work only on the fabric and not on customers skin and must not be implicated in antibiotic resistance. Biocidal finishes should not be confused with odour absorbers such as cyclodextrins or Dew White.

Flame retardants Consent Required Not permitted in Childrenswear

Cotton Deliberateapplication

Depends on exact chemistry - Toxic, not biodegradable and suspected health risks

Performance is governed by legislation. Certain chemical types are restricted

Certain chemical types are restricted

5ppm for penta-, hexa- and octa -brominated biphenyl ethers

5 ppm solvent extraction + gc-ms or lc-ms

Flame retardant notes

Flame retardant finishes should only be applied where there is a legislative need with written consent from M&S. Penta, Hexa and Octa –brominated types must not be deliberately applied and must not be present above 5 ppm. Suppliers using Deca brominated types should follow VECAP best practice - http://www.bsef.com/product_stew/vecap/

PVC Consent Required Not permitted in Children’s clothing

Mock leather and plastisol prints. Sequins

Deliberate use Not biodegradable, releases dioxins on combustion


Strict controls on disposal

Qualitative test qualitative C64 - qualitative (Belstein test) then/or FTIR for confirmation

Phthalates Consent Required for PVC Not permitted in Children’s clothing

PVC mock leather and plastisol prints

Used to soften rigid PVC

Suspected sex change chemicals /suspected carcinogen

6 phthalates now illegal in certain articles in Europe Directive 2005/84/EC

No Legal restriction at

present – restrictions expected

1000 ppm for the 6 legislated phthalates

1 ppm C61 Solvent extraction +

GCMS

PVC and Phthalate notes

It is essential that all suppliers who are using PVC based products familiarise themselves with, and comply with the current M&S PVC policy. DEHP, DBP and BBP are banned above 1000ppm in all childcare articles and toys. DINP, DIDP and DOP are banned above 1000ppm in articles that are intended for children under 36 months and can be mouthed.

Formaldehyde Not permitted in Children’s underwear or any babywear

Resinated Cotton and Viscose

Naturally occurring but most commonly found in resinated products (and in lower levels in fixing agents for cotton and nylon)

Known irritant to skin and mucous membranes. Recently reclassified as carcinogen by WHO


Controls on workplace

airborne quantities

Free and hydrolysable 75ppm Released 300ppm Babywear 20ppm

Background levels are approx 20

ppm

Textiles:C18B and C18C Leather: EN ISO TS 17226 HPLC

Pesticides / Insecticides

Wool (and lower levels on cotton)

Used to protect sheep and cotton crops from parasite infestation. See appendix 5

Toxic Selected chemicalsare banned under POP convention

Strict controls on effluent

Total 0.5ppm for wool Total 0.05ppm for cotton

0.05 ppm Analtyitcal – HPLC or GCMS


http://www.bsef.com/product_stew/vecap

Marks & Spencer C99

Chemical




Retail legal status



product

Limit of Detection

Test method

Chlorine based bleach

Cotton Deliberate application

Toxic in high concentrations. Concerns over ‘AOX’ formation in effluent


No Legal restriction. May

form AOX in effluent and these

are controlled

No limit specified Best practice is to use peroxide based systems

N/A

Cadmium Various -including components

Used in pigments, alloys, some dyes and some fibres

Toxic EN 71 + Cadmium directive

Strict controls on effluent

0.5 ppm 0.5ppm Solvent extraction methods - MS

Nickel See nickel policy

Various -including components

Present in some green and turquoise dyes

Allergenic See nickel policy Strict controls on effluent

Dyes – best practice Metal components – see nickel policy

Nickel Release EN 1811

Heavy Metals Various -including components

Used in pigments, alloys, some dyes and some fibres

Toxic EN 71 Strict controls on effluent

Antimony 2 ppm Arsenic 1 ppm Lead 1ppm

Solvent Extraction Leather : Extraction in artificial sweat + AAS / ICP

Potassium Permanganate

Denim Used as a localised bleaching agent - usually as a spray

Toxic for workers No Legal restriction


Best Practice to use permanganate –free process

Some Sequesterants e.g. EDTA

All products Used as an additive for softening water

Can upset the balance of water courses


Some restriction on some products eg

EDTA

No limit specified

There are many thousands of chemicals that are not mentioned in the above section that are known to be harmful to humans or the environment. They are not mentioned because there is little chance they would ever be used on the type of products we sell. However, we do not expect any harmful chemicals to be present and draw your attention to lists in Appendix 10. Marks and Spencer will continue to promote the minimisation of harmful chemicals in our products and responsible use of safer technology.


Marks & Spencer C99

Dye and Chemical Selection – Avoidance of non-compliance

With the exception of some contaminants that are brought in on raw materials most chemical safety and environmental issues are caused by the dyes and chemicals that are deliberately used for the manufacture of products.

Dyehouses, printers, finishers, laundries and tanneries must take care to select products that do not harm textile workers, the environment or Marks & Spencer customers.

To minimise the risk of non-compliance Marks & Spencer recommend that dyes from ETAD member companies are used. ETAD member companies work to a voluntary code of conduct to minimise the negative health and environmental effects arising from the manufacture and use of dyes and pigments. (member companies in appendix 5 or www.etad.com).

There are however several reputable dye manufacturers and distributors who have declined ETAD membership and there is no analogous organisation for textile chemicals. With this in mind Marks & Spencer are developing a directory of dyes and chemicals that meet the minimum standards laid out this document to minimise the risks to customers, textile workers and the environment.

All worldwide dye and chemical suppliers will be able to register their compliant chemicals free of charge under a self certification arrangement. (Contact [email protected] for details). An up-to-date list is available on the Quality Standards website.

Ultimately it is expected that production for Marks & Spencer will have to use these registered chemicals otherwise finished products will have to be subjected to exhaustive chemical compliance tests.

Compliant dyes and chemicals – Products selected from the following lists will not give rise to non-compliance if applied appropriately.

Dystar dyes and pigment formulations in brochure format (ref 09.0047-00) or at www.dystar.com.

Ciba dyes and chemicals at www.cibasc.com.

Clariant dyes and chemicals at www.clariant.com.

CHT Chemicals at www.cht-group.com.

Magna print and speciality chemicals at www.magnacolours.com

Basf chemicals at www.basf.com

Childrenswear Panel Prints The following companies entire range of panel printing chemicals comply with our general requirements for chemicals and more stringent Childrenswear standards of PVC-free, Phthalate-free. It is strongly recommended that products utilising new technology from these companies are used to minimise the risk of non-conformance.

Magna Print Kimya Zydex CHT


http://www.etad.com/


http://www.dystar.com/

http://www.cibasc.com/

http://www.clariant.com/

http://www.cht-group.com/

http://www.magnacolours.com/

http://www.basf.com/

Marks & Spencer C99

Appendices 1. General Requirements – why we impose minimum standards.

2. Best practice.

3. Who is responsible for managing compliance with minimum standards?

4. Managing failure.

5. ETAD member companies.

6. Banned Amines.

7. Examples of dyes that can cleave to form banned amines.

8. Skin sensitising dyes.

9. Pesticides / Insecticides.

10. Chemicals of concern.

11. Test methods and techniques.

12. Kidswear requirements.


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Appendix 1 − General Requirements

Factory / Worker Safety Environment Chemicals on Garments/Product The following are three key areas in ensuring worker safety. Chemicals. Dyes and chemicals used to manufacture our products can pose an immediate danger to workers (acids, corrosives etc) and/or have long term effects associated with prolonged exposure. Exposure of workers to unnecessary risks from dyes and chemicals is unacceptable. Good factories will invest in automated dispensing, ducting, ventilation and other engineering solutions to protect their workers. In the absence of these it is imperative that appropriate personal protective equipment is provided and worn. See appendix 2 for further best practice. Machinery has to have moving parts in order to function – however it is not acceptable for machinery to be unsafe. All moving parts must be guarded, there must be no exposed electrics and all machinery should be serviced, tested and certificated. Most accidents and fires occur in areas where housekeeping, the fabric of the building or the working environment is poor. Poor air quality and extremes of temperature are also harmful to employees. Where differences exist between local legal requirements and the standards detailed in this document the tighter standard must be employed.

QC Systems Factories must be able to demonstrate that they have systems in place to consistently meet our requirements in production. Factories that occasionally meet our requirements (e.g. at sample stage) are much higher risk than those that never meet our requirements.

All authorities worldwide have ‘consent limits’ for effluent and emissions that set out which chemicals, and how much of them (both concentration and total per annum) can be discharged to drain or to the air. Removal of colour from effluent is not a requirement in some areas of the world. Normal effluent treatment processes should dilute and balance colour so that offensive colour discharges do not occur. Marks and Spencer strongly recommend that effluents are treated to remove colour. Effluent and air quality will be tested by the authorities and they will provide written documentation to the factory to denote compliance or non-compliance. There will also be local guidelines for disposal of solid waste, redundant dye stocks and chemicals. Factories must be able to demonstrate ongoing compliance with local government legislation.

Dyes and chemicals are essential to produce saleable products but we do have a duty to ensure that our customers, and workers involved in manufacture, are not exposed to risks arising from their use. We control (and test for the presence of) the chemicals specified in this document for the following reasons: • It is illegal to sell merchandise containing certain

chemicals above specified levels. • Certain chemicals, although legal in terms of use and

sale, are known to be harmful to customers and workers involved in the manufacture of our products

• In certain parts of the world there are laws regulating

the use/disposal of certain chemicals above specified levels. Although it is legal for us to sell the final product, detection of such chemicals indicates that they have been used at some stage of manufacture.

Where there are local laws preventing the use or sale of chemicals that differ from the minimum standards detailed in this document the tighter standard must be applied.


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Appendix 2 – Best Practice

Factory / Worker Safety Environment Chemicals on Product

• Health and safety policy from the CEO. • Appoint trained safety and fire officer. • Individual training for all factory workers. • Inter-departmental auditing within a factory. • Selection of safest form of dyes and

chemicals (liquids, low dusting powders) • Use engineering controls to minimise

exposure to harmful chemicals. • Reduced impact of manual handling. • Planned maintenance of machinery. Further information at www.hse.gov.uk

QC Systems

• Quality policy from CEO • Appoint quality assurance manager • Systems for checking consistency of water

and raw materials • Work to standard operating procedures • Use examination department and labs to

collect information not just to pass/fail • Visual display of quality indicators for all

areas • Visual display of cost of non-conformance ISO 9001 gives some measure of competence.

• Environmental policy from CEO on display. • Appoint environmental officer. • Put in place an environmental management

system • Training for all workers on chemical

knowledge. • Display performance indicators in all areas of

factory (details of licences, breaches of consent, energy and water consumption).

• Display cost benefits of reduced re-dye / refinish with respect reduced water and energy consumption.

ISO 14001 is a very good indicator of environmental competence.

Bluesign technologies ag are leaders in the field of environmental compliance and resource management. Suppliers will benefit from a full factory and chemical inventory audit by bluesign's experts and their recommendations will invariably lead to lower costs due to improved efficiency and productivity as well as reduced risk of non-compliance. http://www.bluesign-tech.com

• Chemical policy from CEO. • Formalised risk assessment of all dyes and

chemicals used on site. • Single point accountability for dye and

chemical inventory. • Up to date inventory of all dyes and

chemicals with supporting MSDS (including locally purchased process chemicals).

• Do not buy chemicals from companies who refuse to supply MSDS.

• Letters of ECOP-compliance for all chemicals from their manufacturer.

• Formalised due diligence programme for incoming raw materials, dyes and chemicals.

• Formalised due diligence programme for outgoing production.

Oekotex 100 certification is confirmation that a factory can achieve the oekotex standard on a particular finished fabric. Whilst it is a reasonable indicator some degree of competence it does not guarantee that factory conditions, working practices and environmental compliance are good.


http://www.bluesign-tech.com/

Marks & Spencer C99

Appendix 3 − Who is Responsible for Managing Compliance with Minimum Standards?


• Self Audit is the minimum requirement before orders are placed.

• Garment/product manufacturer assessment is required by time of first production (It is recommended that all garment suppliers have a technical resource capable of managing compliance – where Marks & Spencer have agreed to place business with suppliers who lack this resource the Marks & Spencer technologist is responsible for factory audit).

• Marks & Spencer technologists reserve the right to visit any production facility at any time.

• Dyeing and finishing specialists will also take cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.

QC Systems • Self Audit is the minimum requirement before

orders are placed. • Garment/product manufacturer assessment is

required by time of first production. • Marks & Spencer technologists reserve the right

to visit any production facility at any time. • Dyeing and finishing specialists will also take

cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.

• Self audit to report on meeting local consent limits.

• Marks & Spencer reserve the right to carry

out or commission a detailed environmental audit (at our cost) to check raw data used for self audit.

• Dyer, printer or finisher is responsible for collating data on raw materials, dyers and chemicals.

• Dyer, printer or finisher is responsible

for selecting dyes and chemicals to comply with Marks & Spencer requirements.

• Dyer, Printer or Finisher to decide with

garment maker at pre-production what is required and who is responsible for compliance testing.

• Garment maker to carry out additional

due diligence checks – risk assessment in collaboration with Marks & Spencer Dyeing and Finishing Specialists.

• Marks & Spencer to carry out due

diligence checks.


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Appendix 4 − Managing Failure


Compliance with minimum standards must be demonstrated before production commences.

QC Systems

Strongly inadvisable to place business with suppliers who do not meet the elementary minimum standards. To be managed by Marks & Spencer departmental technologist who may delegate to trusted garment suppliers.

Generally governed by local authorities – repeated and or serious breaches of consent will result in financial penalties or closure of the factory. Marks & Spencer should not commit to business with repeated offenders as there is significant risk of non-delivery due to forced closure.

All results that fall outside published standards will have to be discussed with the Departmental Technologist and Dyeing, Printing, Finishing and Colour Manager. Some failures will result in an immediate removal of product from stores (RTM). In other cases RTM’s may not be actioned provided the source of the failure is identified and the chemical eradicated from the supply chain. Repeated breaches will result in an RTM.


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Appendix 5 − E.T.A.D. Member Companies

Albion Colours Ltd Hodogaya Chemical Co Ltd

Aliachem a.s. Kyung-In Synthetic Corporation

ATUL Limited Lanxess (formerly Bayer)

Avecia Ltd Lanxess Corp

BASF AG M Dohmen GmbH

BASF Corporation Mike Dyes Works Ltd.

Bezema AG Mitsubishi Chemical Corporation

Cappell Pigments n.v. Nippon Kayaku Co Ltd.

Carey Industries Inc. Oh Young Ind. Co. Ltd.

Ciba Speciality Chemicals Corporation Oriental Giant Dyes & Chemical Ind. Corporation

Ciba Speciality Chemicals Inc. RIFA Ind. Co. Ltd

Clariant (Schweiz) AG Rohm & Haas Company

Clariant Corporation Sanyo Color Works Ltd

Dainichiseika Sensient Colours Inc.

Dainippon Ink & Chemicals Inc. Sestas Kimya Sanayi A.S.

Dystar L.P. Stahl International b.v.

Dystar Textilfarben GmbH & Co. Deutschland KG Sun Chemical A/S

E C Pigments T&T Industries Corporation

Everlight Chemical Ind. Corporation Tennants Textile Colours Limited

Everlight USA Inc. TFL Ledertechnik Gmbh & Co. KG Francolor Pigments SA Thai Ambica Chemicals Co., Ltd

Heubach GmbH Toyo Ink Mfg. Co. Ltd


Marks & Spencer C99

Appendix 6 − Aromatic Amines Specified in EC 2002/61

CAS Number Index Number EC Number Substances

1. 92-67-1 612-072-00-6 202-177-1 Biphenyl-4-ylamine 4-aminobiphenyl xenylamine

2. 92-87-5 612-042-00-2 202-199-1 Benzidine

3. 95-69-2 202-441-6 4-chloro-o-toluidine

4. 91-59-8 612-022-00-3 202-080-4 2-naphthylamine

5. 97-56-3 611-006-00-3 202-591-2 o-aminoazotoluene 4-amino-2’, 3-dimethylazobenzene 4-o-tolylazo-o-toluidine

6. 99-55-8 202-765-8 5-nitro-o-toluidine

7. 106-47-8 203-401-0 4-chloroaniline

8. 615-05-4 210-406-1 4-methoxy-m-phenylenediamine

9. 101-77-9 612-051-00-1 202-974-4 4,4’-methylenedianiline 4,4’-diaminodiphenylmethane

10. 91-94-1 612-068-00-4 202-109-0 3,3’-dichlorobenzidine 3,3’-dichlorobiphenyl-4,4’-ylenediamine

11. 119-90-4 612-036-00-X 204-355-4 3,3’-dimethoxybenzidine o-dianisidine

12. 119-93-7 612-041-00-7 204-358-0 3,3’-dimethylbenzidine 4,4’-bi-o-toluidine

13. 838-88-0 612-085-00-7 212-658-8 4,4’-methylenedi-o-toluidine

14. 120-71-8 204-419-1 6-methoxy-m-toluidine p-cresidine

15. 101-14-4 612-078-00-9 202-918-9 4,4’-methylene-bis-(2-chloro-aniline) 2,2’-dichlor-4,4’-methylene-dianiline

16. 101-80-4 202-977-0 4,4’-oxydianiline

17. 139-65-1 205-370-9 4,4’-thiodianiline

18. 95-53-4 612-091-00-X 202-429-0 o-toluidine 2-aminotoluene

19. 95-80-7 612-099-00-3 202-453-1 4-methyl-m-phenylenediamine

20. 137-17-7 205-282-0 2,4,5-trimethylaniline

21. 90-04-0 612-035-00-4 201-963-1 o-anisidine 2-methox aniline

22. 60-09-03 611-088-00-4 200-453-6 4-amino azobenzene *no test available


Marks & Spencer C99

Appendix 7 − Examples of Dyes which Potentially Cleave to form Aromatic Amines

(listed in Appendix 6) under reducing conditions

CI Acid Orange 45 22195 Direct Red 21 23560 Direct Blue 173 CI Acid Red 24 16140 Direct Red 22 23565 Direct Blue 192

CI Acid Red 85 22245 Direct Red 28 22120 Direct Blue 201

CI Acid Red 114 23635 Direct Red 37 22240 Direct Blue 215 24115

CI Acid Red 115 27200 Direct Red 39 23630 Direct Blue 295 23820

CI Acid Red 128 24125 Direct Red 44 22500 Direct Green 1 30280



CI Acid Red 167

Direct Red 67 23505 Direct Green 8.1


CI Acid Black 29 Direct Violet 1 22570 Direct Brown 1 30045

CI Acid Black 209 Direct Violet 12 22550 Direct Brown 1:2 30110

Azoic Diazo Component 12 37105 Direct Violet 21 23520 Direct Brown 2 22311 Basic Brown 4 (= Solvent Brown 12) 21010 Direct Violet 22 22480 Direct Brown 6 30140Developer 14 (=Oxidation Base 20) 76035 Direct Blue 1 24410 Direct Brown 25 36030 Direct Yellow 1 22250 Direct Blue 2 22590 Direct Brown 27 31725

Direct Yellow 24 22010 Direct Blue 3 23705 Direct Brown 31 35660

Direct Yellow 48 23660 Direct Blue 6 22610 Direct Brown 33 35520

Direct Orange 1 22370 Direct Blue 8 24140 Direct Brown 51 31710






Direct Red 1 22310 Direct Blue 25 23790 Direct Brown 222 30368

Direct Red 2 23500 Direct Blue 35 24145 Direct Black 4 30245



Direct Red 13 22155 Direct Blue 160 Direct Black 154

Direct Red 17 22150


Marks & Spencer C99

Appendix 8 − Dyestuffs implicated in Contact Dermatitis by Consumers, which include:

CI Disperse Blue 1

CI Disperse Blue 3

CI

Disperse Blue 7

CI Disperse Blue 26

CI Disperse Blue 35

CI Disperse Blue 102



CI Disperse Yellow 1





CI Disperse Orange 1




CI Disperse Red 1

CI Disperse Red 11

CI Disperse Red 17

CI Disperse Brown 1


Marks & Spencer C99

Appendix 9 − Pesticides / Insecticides

Cotton and Natural Cellulosic Fabrics; Blends of these with Other Fibres

Maximum Limits for each Product Listed - 0.05 ppm

Wool and Other Keratin Fabrics; Blends of these with Other Fibres

The Sum Total should Not Exceed 0.5ppm

Aldrin Alpha-Hexachlorocyclohexane Captafol Beta-Hexachlorocyclohexane Chlordane Gamma-Hexachlorocyclohexane DDT Lindane Dieldrin Aldrin Endrin Endrin Heptachlor Dieldrin Hexachlorobenzene DDT Hexachlorocyclohexane (total Isomers) DDD 2,4,5,T Propetamphos 2,4 D Diazinon Chlordimeform Dichlofenthion Chlorobenzilate Fenchlorphos Dinoseb (and its salts) Chlorfenvionphos Monocrotophos Cyhalothrin

Cypermethrin Deltamethrin Fenvalerate

In addition to due diligence testing of finished products, we would recommend that documentary evidence should be obtained from the raw material suppliers that these chemicals are not present. It is our intention in the future to specify these standards back to the raw material, i.e., fibres.


Marks & Spencer C99

Appendix 10 − Summary : Chemicals for Concern

EU Water Framework UK Environmental OSPAR List for CHEMICALS

Directive Protection Act Priority Action

1,2,3 trichlorobenzene 1,2,4 trichlorobenzene 1,2-Dichloroethane

1,3 Cyclopentadiene

1,3,5 trichlorobenzene

4-tert-butyltoulene

Alachlor

Aldrin

All isomers of DDT

All isomers of hexachlorocyclohexane

All isomers of trichlorobenzene

Anthracene

Atrazine

Azinphos-methyl

Benzine

Brominated diphenylether

Brominated flame retardants

C10-13-chloroalkanes

Cadmium

Cadmium and its compounds

Certain Phthalates- Dibutylphthalate & Diethylhexylphthalate

Chlorfenvinphos

Chlorpyrifos

Di(2-ethylhexyl) phthalate (DEHP)

Dichloromethane Dichlorvos Dicofol

Dieldrin

Diuron

Dodecylphenol

Endosulfan

Endrin

Fenitrothion

Hexachlorobenzene

Hexachlorobutadiene


Marks & Spencer C99

EU Water Framework UK Environmental OSPAR List for CHEMICALS

Directive Protection Act Priority Action

Hexachlorocyclohexane

Hexachlorocyclohexane (total Isomers)

Hexamethyldisiloxane

Isoproturon

Lead and its compounds

Lead and organic lead compounds

Malathion

Mercury and its compounds

Methoxychlor

Musk xylene

Naphthalene

Nickel and its compounds

Nonylphenol/ethoxylates (NP/NPEs) and related substances

Nonylphenols

Octylphenol

Organic tin compounds

Pentachlorobenzene

Pentachlorophenol and its compounds

Polyaromatic hydrocarbons (PAHs)

Polychlorinated biphenyls (PCBs)

Polychlorinated dibenzodioxins (PCDDs)

Polychlorinated dibenzofurans (PCDFs)

Short chained chlorinated paraffins (SCCP)

Simazine

Tetrabromobisphenol A

Tributyltin compounds

Trichlorobenzenes

Trichloromethane (Chloroform)

Trifluralin

Triphenyltin compounds


Marks & Spencer C99

Appendix 11 − Chemical Testing Notes

General Remarks Testing Requirements

Chemicals can be detected in amounts that fall into 3 categories: Background levels – amounts found in nature Contamination – low levels present Deliberate application – higher levels present

There are two broad types of test: Qualitative – tells you something is definitely there in high low or

medium amounts. Quantitative – tells you exactly what is there.

For any test there will be a ’limit of detection’ below which a chemical cannot be detected. (Where methods use solvent extraction the limits of detection and permissible levels may refer to the extract and not the test fabric/component – see chemicals on product table). In some instances the M&S ‘Acceptable limit’ refers to the acceptable limit in the solvent extract and not the total amount on the fabric under test.

All tests must be conducted in UKAS accredited laboratories or those that operate a mutual recognition scheme (e.g. HOKLAS, COFRAC). Certain laboratories will carry out screening tests for families of similar chemicals before doing specific targeted quantitative tests. A negative result from an accredited laboratory is normally sufficient. Chemical tests from non-accredited laboratories may need to be re-tested and will at best be submissable as qualitative evidence.


Marks & Spencer C99

Appendix 12 − Kidswear : Clarification of Chemical Restrictions

The general business requirements for chemicals are detailed in the table on pages 9-12, however the following extra restrictions are required for Kidswear merchandise: Formaldehyde – deliberate use of Formaldehyde containing products not permitted in underwear or babywear. PVC and Phthalates – deliberate use not permitted (normally found in panel prints. Biocidal finishes – not permitted. Flame Retardant finishes – not permitted. All product must comply with EN71 part 1, however the levels specified in this legislation for certain chemicals is much higher than would reasonably be expected in textile production therefore the permitted levels for Marks & Spencer production are those detailed in the table on pages 9-12 and not those in the legislation.


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