Contract Number

LWG LEATHER MANUFACTURER AUDIT

PROTOCOL RESPONSES REPORT
An environmental audit protocol, covering key elements of leather manufacturing
including traceability, social responsibility, health & safety, and chemical management.

Issue 7.1.0

Company
Address Line 1
Address Line 2
Address Line 3
Address Line 4
Address Line 5

Month 2021

Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Audit Result Summary
% Score Rating
Not applicable if 100% subcontract work

Performance
% % % % Sourcing
physically document source-group regionally transfer value
traceable traceable traceable traceable only suppliers of
part-processed
Material Traceability

Primary processing scope for tannery audit Category

The following activities also undertaken
Percentage processing undertaken as subcontractor
The types of leathers produced are
The national violations website consulted was
The number of sub-contractors used is
Audit number Continuous member since

Minimum requirement (%)

Maximum

Potential

Actual
score

score

score

Gold Silver Bronze Audited Percent

01 General facility details - - - - -

02 Subcontracted operations 100 85.0 75.0 65.0 50.0
03 Social audit 50 0 0 0 0
04 Operating permits 100 85.0 75.0 65.0 50.0
05 Production data 100 85.0 75.0 65.0 25.0
06 Traceability (incoming) 50 0.0 0.0 0.0 0.0
07 Traceability (outgoing) 60 0.0 0.0 0.0 0.0
08 EMS 100 85.0 75.0 65.0 50.0
09 RSL, Compliance, CrVI 150 85.0 75.0 65.0 50.0
10 Energy consumption 100 85.0 75.0 65.0 25.0
11 Water usage 100 85.0 75.0 65.0 25.0
12 Air & noise emissions 100 85.0 75.0 65.0 50.0
13 Waste management 150 85.0 75.0 65.0 50.0
14 Effluent treatment 150 85.0 75.0 65.0 50.0
15 H&S, Emergency Plans 150 85.0 75.0 65.0 50.0
16 Chemical Management 150 85.0 75.0 65.0 50.0
17 Operations Management 100 85.0 75.0 65.0 50.0

Total 1710 85.0 75.0 65.0 50.0

Audit completed by
Auditor
Date the audit was conducted
The next audit is due
Audit protocol LWG - Issue 7.1.0 July 2021

The assessment was based on sampling and therefore nonconformities may exist which have not been identified.

Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Leather Working Group

Guidance notes are published on the LWG website. This document contains basic information associated
with the audit process, but it must be used in conjunction with the guidance notes during audits.

Mission statement
The objective of this multi-stakeholder group is to develop and maintain a protocol that assesses the environmental
compliance and performance capabilities of tanners and leather producers and promotes sustainable and
appropriate environmental and socially responsible business practices within the leather industry.

The group seeks to improve the leather industry by creating alignment on environmental priorities, bringing visibility
to best practices, and providing suggested guidelines for continual improvement.

It is the group’s objective to work transparently, involving suppliers, brands, retailers, leading technical experts
within the leather industry, NGOs, academic institutions, and other stakeholder organisations.

Leather manufacturer protocol

• The protocol is intended to assess the environmental performance of tanneries and leather producers and
provide suggested guidelines for improvement.
• The protocol was developed and reviewed by leather producers, brands, and industry experts to ensure
adequacy and technical feasibility.
• The original versions of the environmental auditing protocol were peer reviewed by the World Wildlife
Fund US and further NGO input will be requested as budget allows.
• The leather working group produces guidance documentation for use in conjunction with this protocol
and which gives tanners and leather producers information on suggested best environmental practices.
• The operating and reporting language is English. The protocol is translated into several languages and
these can be downloaded from the website (https://www.leatherworkinggroup.com/how-we-work/audit-
protocols/main-protocol). The translated versions are supporting tools with the English language version
taking precedence in all aspects. Additional translations will be considered subject to demand and
justifiability and to there being at least 10 tanners already audited who use that language.

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Scope of the audit
LWG publishes audit protocols designed to assess the performance of organisations operating within the leather
production sector with respect to issues surrounding environment, chemical management, procurement, best
practice, health & safety, and social responsibility:
Leather Manufacturer Audit Protocol (this protocol)
Commissioning Manufacturer Audit Protocol
Subcontractor Audit Protocol
Mini-Audit Protocol
Trader Protocol

The purpose of this leather manufacturer audit protocol is to evaluate the environmental and associated best
practice performance of tannery operations. This protocol is applicable to all organisations undertaking a range of
operations that fall within one of the LWG leather manufacturer audit categories. It is applicable to all organisations
whose scope of operations render them capable of being audited by this protocol. It is applicable to all
organisations, including subcontractors, that apply chemicals either into the substrate or onto the substrate.
The leather manufacturer audit applies to all operations undertaken in any given site, with the following conditions:
• It is applicable to companies that have registered their scope of operations with LWG and which have
been issued with a registration code
• It includes the full range of operations referred to by all applicable operating licenses unless these are
demonstrably unrelated to leather making. Example: a tannery produces automotive leather to a finished
condition AND undertakes cutting operations. The cutting operations do not form part of typical tannery
operations. Energy usage, water usage etc. associated with cutting operations can be excluded from the
calculation of energy usage per square metre of leather, water usage per square metre of leather etc.
• it includes effluent treatment operations even if these are performed in a different location and/or in other
companies
• it includes technical, maintenance and administrative activities even if these are being undertaken on
behalf of other companies within a group
• it excludes residential aspects (dormitories, canteens etc.) even if within the site boundary, but only if
these can be reliably separated from production aspects i.e., energy and water are on separate meters.
• performance assessment (e.g., energy consumption, water usage etc) will be undertaken based on 24
month’s operations. These should be the most recent 24 months for which data is available, the last of
which must not be more than three months prior to the audit (i.e., an audit undertaken on 15 June 2021
would use data from no earlier than the preceding period 01 April 2019 to 31 March 2021)
• compliance assessment (e.g., effluent discharge, emissions to atmosphere etc) will be undertaken based
on the previous 24 months operations. In the initial months following the implantation of this protocol a
phased introduction will apply, being 12 months plus the number of months elapsed following
implementation. For example, a company being audited in November 2021 using the data up to the period
ending 31 October 2021 maybe assessed using 14 months of data (the 2 months of September and
October following implementation plus the previous 12 months beginning September 2020 to end August
2021).
• in the energy section the value can be calculated based on two periods of nine months’ worth of data
provided month by month data for production and each type of energy for the two full years has been
supplied and recorded in the report. The three months making up an excluded period must be
consecutive. The excluded two periods must cover the same months.

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 • for audits undertaken whilst LWG recognises the Covid-19 pandemic is affecting global trade three
months exclusion will be allowed for water and an additional three months for energy (i.e., including the
three months seasonal allowance this could result in up to six months data exclusion for energy). The
additional three months do not need to be consecutive but the same three months must be selected for
both water and energy. Month by month data for production, water, and each type of energy for a full
year must be supplied and recorded in the report. The allowance is only applicable during the Covid-19
pandemic and only applicable for audits undertaken using this (P7.0.0) protocol document.
• If significant capital expenditure has been undertaken leading to a performance improvement (e.g.,
installation of a new boiler) the scoring may be based on subsequent performance. Month by month
performance data before and after the change will need to be provided to demonstrate genuine,
irreversible change.
• Facilities presenting for their very first audit may be assessed on the basis of the previous 12 months’
worth of data.
• Facilities that have not been operating for 24 months may be audited after 6 months. A provisional
certification will be issued (12 months from date of the audit).
• in those instances where insufficient industry benchmarking data is available to record a score for a
particular section (i.e. the energy requirement to produce exotic leathers) the section will be reported as
“not applicable”. These are expected to be exceptional circumstances and will not be decided at the time
of the audit; each case being individually submitted to the LWG Technical Sub Group and/or the LWG
Executive Committee for approval (or pre-approval if data is available in advance of the audit).
• certified tanneries are expected to demonstrate reputable practices in all areas of business. If an auditor
witnesses’ practices globally recognized as being unacceptable (failure to safeguard the health of workers,
worker exploitation, child labour etc.) or practices likely to lead to detriment of the reputation of LWG, that
auditor is required by LWG to refer the issue to the LWG facilitator. The LWG facilitator will consult with
TSG/EC as appropriate to determine whether possible Failure should be recorded in the light of the auditor
evidence presented.
• This protocol is not applicable to any company whose effluent discharge is to a CETP listed on the LWG
webpages as being a CETP of concern or at risk. This includes all types of leathermaking organisations
even if the scope of processing does not involve wet operations, since all manufacturers are deemed
generate some industrial effluent that must be treated.
• for several questions throughout the protocol there is reference to a batch of leather,; taken to be one
production drum load of leather, small sample and development loads may be ignored. Manufacturers
whose incoming material is crust should consider a batch of leather to be the group of hides skins that
are processed together as a unit (e.g. through a spray machine).
• The taking of photographs and their inclusion into the protocol report are a fundamental and necessary
aspect of the audit. Refusal to allow the necessary photographic evidence required will lead to failure of
the audit. Questions for which the auditor is required to include photographic evidence are identified with
the following symbol 📷. Auditors may need to take additional photographs as required as supporting
evidence.

Key to Photographs:
📷 – Photograph mandatory where symbol displayed
📷 – Photograph recommended where symbol displayed

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 There may be special circumstances (e.g. new machinery installations, etc, which may be excluded from
photograph if declared to the auditor.

Multi-site audit
The Leather Manufacturer protocol is a site audit and is designed to assess the environmental performance of an
organisation operating from a single site. Organisations operating facilities in different geographical locations will
require an audit of each site.

An audit may be classed as “multi-site audit” in those cases where an organisation operates out of two or more
geographically different sites, but only if those sites are located close to each other (e.g. same street or same
industrial park), they operate as one unit, and despatch documentation and invoicing cites just one of the
addresses. Furthermore, when considered jointly the scope of operations of the units must correspond to an LWG
tannery category (there will be one audit that covers all units). One unit might individually fall into an LWG category,
no two units could individually fall into the same LWG category.

Two companies operating on one site will be treated as separate audits only if they are distinct legal entities with
separate operating licences and operating as separate units.

Subcontracted operations
In those instances where one or more operations are being undertaken on behalf of the company at a different site
(sub-contracted out) an assessment of the sub-contracted operations will be required. Depending on the work sub-
contracted out different levels of assessment may be required. The subcontractor audit/mini audit applies to the
site, not to the operations subcontracted out. If the range of operations undertaken at the subcontractor’s facility
covers the range of operations that fall within an LWG audit category a full environmental audit will be required.
Example
#1 If a tannery sends wet blue to be shaved by a subcontractor that only has shaving machines the
subcontractor would be assessed using the subcontractor protocol.
#2 If a tannery sends wet blue to be shaved by a subcontractor that processes from raw to tanned the
subcontractor would be assessed using the leather manufacturer protocol.

It is a condition of the audit that the company being audited informs the auditor/audit body at the time of application
for an audit of the full extent of operations undertaken off-site as well as the scope of operations of each of the
subcontractors as additional time may be required to complete the risk assessment (full audit, subcontractor audit
or mini-audit as appropriate) and additional charges may need to be levied.

Subcontractors applying chemicals will be assessed using the Leather Manufacturer Audit Protocol (this protocol).
The Chemical Management section and Health, Safety and Emergency Planning sections of this protocol apply
irrespective of the amount of chemical applied and must therefore be taken into consideration. Effluents and air
emissions will be generated depending on the chemicals used and methods of application. An organisation is
responsible for all chemicals and chemical usage onsite even if those chemicals are supplied by the contracting
organisation.

Restricted Substances Subcontractors are not responsible for restricted substance content of the leathers
produced on a subcontract basis. This is the responsibility of the contracting organisation that supplies the material
and who subsequently sells the product. For organisations working on a 100% subcontract basis most of the

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questions associated with restricted substance management will not apply. Organisations who process some
material on a subcontract basis and some material of their own will be assessed on their own material (that they
buy and subsequently sell). Within this section there are questions that are related specifically to management of
CrVI and tanning operations and which are related to operations and processes that are within the control of the
tannery. For subcontracting tanners undertaking chrome tanning operations those question apply.

Sourcing Subcontractors have no control over the source of the incoming material.
Subcontractors are not responsible for the sourcing of the leathers produced on a subcontract basis. This is the
responsibility of the contracting organisation that supplies the material and who subsequently sells the product. For
organisations working on a 100% subcontract basis the Production Data section will apply if the subcontracted
operations involve tanning of material. For organisations working on a 100% subcontract basis and for whom 100%
the starting material is part-processed the Production Data section will not apply. Organisations who process some
material on a subcontract basis and some material of their own will be assessed on their own material (that they
buy and subsequently sell).

Incoming Traceability Subcontractors have no control over the source of the incoming material.
Subcontractors are not responsible for the traceability of the leathers produced on a subcontract basis. This is the
responsibility of the contracting organisation that supplies the material and who subsequently sells the product. For
organisations working on a 100% subcontract basis the Traceability section will not apply. Organisations who
process some material on a subcontract basis and some material of their own will be assessed on their own material
(that they buy and subsequently sell).

Outgoing Traceability Subcontractors have control over the movement of material through their
facility even though that material is owned by a client. Subcontractors will be assessed on the basis of all materal
that is processed through their facility.

Subcontractor Audit
This will be undertaken in accordance with the Subcontractor Protocol. For the reasons outlined above the
Subcontractor Protocol will only apply to organisations undertaking mechanical operations and/or drying of wet
leather. Subcontractors attain certification valid for two years during which time they are members of LWG. Their
audit determines a “transfer value” for energy consumption, water usage and VOC emissions. The transfer values
may be used in the Leather Manufacturer Audit. The transfer values are valid for the period of certification (there
is no requirement for re-assessment during the two-year certification period). The subcontractor audit is a site audit.
All site operations must be assessed. If the scope of operations falls within one of the LWG tannery categories a
full audit will be required.

Mini-Audit
This will be undertaken in accordance with the less rigorous Mini-Audit Protocol. Subcontractors assessed by this
protocol do not attain certification and they do not become members of LWG. Their audit also determines a “transfer
value” for energy consumption, water usage and VOC emissions. The transfer values may be used in the Leather
Manufacturer Audit. The transfer values are only valid for the Leather Manufacturer audit which has prompted the
assessment. All sub-contractors (not otherwise audited against the Subcontractor Protocol) will be required to be
assessed against the mini-audit protocol. It is the responsibility of the facility being audited to facilitate this. 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. The auditor will visit all subcontractors so that the responses may be verified by means of normal

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auditing procedures. The results of the mini audit will be reported in the auditee main audit report. The following
additional points apply:
• The auditor will undertake an audit on each of the subcontractors
• The mini-audit must be undertaken at the same time as the audit
• Additional time will be required to undertake the confirmation mini-audits and may result in additional
charges
• It is the responsibility of the company being audited to ensure that the auditor/audit body is informed of
the full extent of all sub-contracting operations in advance so that sufficient time is allowed.
• The mini-audit audit is a site audit. All site operations must be assessed. If the scope of operations falls
within one of the LWG tannery categories a full audit will be required
Notes:
• The energy and water used by the sub-contractor must be taken into account when calculating the overall
energy and water usage figures for the company undergoing the full LWG audit. VOC emissions must be
taken into account If accurate data is not made available by the sub-contractor the auditor will assign
values to sub-contracted operations on a “worst case” basis using any data that is available;
• If a sub-contractor records “Automatic Audit Failure” the company undergoing the full audit will also record
“Automatic Audit Failure”. The audit is intended to ensure that the leather manufacturer and its operations
conform to good environmental practice; this includes the selection and monitoring of sub-contracted
operations.
• The mini audit will remain a valid protocol for the twelve-month period following the implementation date
of P7 (the date from which mandatory use of P7 is required). Thereafter the mini audit will no longer be
applicable, and all subcontractors will need to be assessed by the Subcontractor Audit Protocol (or
Leather Manufacturer Audit Protocol if site operations cover a full leather manufacturer audit category).

Disclosure of data
The tannery being audited is required to provide the auditor with full and accurate data during the audit to support
the audit findings. The tannery is required not to withhold information nor to mislead or attempt to mislead the
auditor. The tannery is required to present all operating permits, plus all additional data or documentation that may
be required and to confirm that the tannery is operating in accordance with all operating permits. The auditor will
be required to assess whether the tannery is in compliance with its operating permits, however the audit process
is a not a full legal compliance investigation and is not expected to prove that the tannery is fully compliant; that is
the responsibility of the tannery. There are issues that are addressed in this audit protocol that might be considered
to fall within the remit of a Health and Safety audit or review and others that fall within the remit of a quality audit
or review. LWG auditors are knowledgeable regarding health and safety or quality issues in tanneries and would
draw attention to any issues that require urgent attention. If any data or information is found to have been withheld
or presented in a way designed to mislead the auditor the entire audit will be reclassified “Automatic Audit Failure”.

Certification period and re-audit

All leather manufacturer audit results are valid for 24 months. Certification remains valid over this timescale unless
evidence becomes available to suggest that the audit result is no longer valid. A facility being re-audited in the two-
month period preceding the certification expiry date will be issued with a certificate valid from the current expiry
date. A facility that is not re-audited on or before certification expiry date will cease to be a member of LWG and
the listing on the LWG website will be removed

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A tanner may be re-audited at any time within the period of certification; however, the following points should be
noted:
• The audit will be undertaken on the basis of the tannery’s previous 24 month’s operations
• A full re-audit will be required irrespective of the period since the previous audit

Categories

Code Category
A Raw hide/skin to tanned
B Raw hide/skin to crust
C Raw hide/skin to finished leather
D Tanned hide/skin to finished leather
E Crust hide/skin to finished leather
F Tanned hide/skin to crust leather
G Raw hide/skin to pickled/pre-tanned material

Scoring
The scoring has been developed as far as possible in accordance with the following hierarchy
• Reduce – the amount of resource used (energy, water, chrome etc.)
• Reuse – material for the same purpose without additional (or minimal) input (pallets, wastewater etc.)
• Recycle – material that cannot be reused into other products
• Recover – raw material (i.e. heat energy for example from oils or solvents that cannot be recycled)
• Refuse – any material that can only be disposed of (provided disposal is safe and legal)

Most questions require that the most appropriate option is selected, i.e., select 1 answer from 5 potential answers.
Where the potential score for an option is greater than 1 this is the maximum score; the auditor will award a lower
score if the evidence is weak or partial. There are also several cumulative questions where all appropriate options
should be recorded. Where the activities of the tannery fall between two or more possible options the auditor is
required to assign a score (or partial score) that appropriately reflects the evidence presented. If a question is not
applicable the auditor will mark the question as “not applicable” and adjust the possible section score based on
those questions that are applicable.

Scoring for Awards

The overall audit award is governed by the rating of the lowest scoring section. The total percentage score at the
bottom refers to the overall minimum percentage score required for the classification. Some questions in the
protocol are classed as “threshold questions”. These questions are of enhanced significance and may affect the
section rating irrespective of the score for the section.

Those companies that operate on a 100% subcontract basis but who undertake a range of operations that covers
a full audit scope will be given a score instead of a rating. This is not the overall score for the audit but one that
equates with the mechanism for determining ratings – it is the minimum section score (percentage).

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Random Inspection Visits
From time-to-time random inspection visits will be made to ensure audit standards are maintained. All audited
members are subject to these visits (if required). Any leather manufacturer selected for a random visit will be given
a minimum of 7 days’ notice prior to such a visit. It is a condition of certification that audited tanners agree to
facilitate inspections (if required). Any costs incurred to carry out an inspection will be the responsibility of LWG.
Failure to allow or facilitate a visit could result in certificate withdrawal and termination of LWG membership. It
should be noted that the outcomes of a random inspection may affect the existing audit rating of a leather
manufacturer.

Glossary

The following terms will be used in the protocol and in reporting procedures

APEO Alkyl phenol ethoxylates BCS Basic chrome sulphate

Common Effluent
CETP SSG Supplier Sub-Group
Treatment Plant
Environmental
EMS Chromium Cr (the element)
Management System
Institute of Public and
LWG Leather Working Group IPE
Environmental Affairs
Municipal Effluent
N/A Not Applicable METP
Treatment Plant
NOx Nitrogen Oxides n.d. not detected

P6 LWG Protocol 7.0 NPE/NPEO Nonyl phenol ethoxylate

Personal Protective
SO2 Sulphur Dioxide PPE
Equipment
TSG Technical Sub-Group THC Total Hydrocarbon
Wastewater Treatment Volatile Organic
WWTP VOC
Plant Compound
Serviço de Inspeção Brazilian Department of Agriculture, Livestock and
SIF
Federal Food Supply animal products certification scheme.
Part-processed material e.g. splits, whole hides, pickled skins etc.
An evaluation of potential hazards, the probability of their occurrence and the
mitigation methods required to reduce risk. A risk assessment is NOT a single or
Risk assessment annual test which shows compliant results. The assessment may be made by third
parties or by in-house personnel but whoever it is done by must demonstrate
appropriate training/ qualifications.

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 LEATHER WORKING GROUP
Declaration of accuracy of data presented to the auditor.

I, …………………………….
a Director of XYZ Tannery Co Ltd (the company) confirm, on behalf of the company that the Opening Statement
and Declaration of Understanding was presented prior to commencement of the audit I confirm that no information
required for the fulfilment of the audit was withheld by the company, nor was any attempt made to mislead the
auditor in any way that might lead to an inaccurate audit result being obtained.

I understand that LWG requires that it be notified of all fatalities and all regulatory non-compliance incidents
(incurring cautions, warnings, prosecutions, fines etc.) during the period of certification. I understand that any failure
of a social audit during the period of certification must be reported to LWG. If such notification is not made to
Leather Working Group by the company but is discovered by other means the LWG certification will be withdrawn
and the result reclassified “Automatic Audit Failure” and the company delisted from the LWG website

I understand that in the event that any data or information is found to have been deliberately withheld or presented
in a way designed to mislead the auditor the entire audit may be reclassified “Automatic Audit Failure” and
certification withdrawn.

I understand that LWG reserves the right to carry out a random inspection visit to ensure audit standards are
maintained. I understand that it is a condition of certification and I agree to facilitate inspections (if required)
following a minimum of 7 days’ advance notice of a specified intended date of visit. I understand that the result of
the inspection may affect the existing audit result.

I understand that it is a condition of publication of listing on the LWG rated suppliers’ webpage that the data
gathered will be used (confidentially) for the purposes of benchmarking. The data listed on the webpage includes
relevant audit data such as award level, expiration date, traceability etc.

Please tick as appropriate:

I agree to the listing of the company on whose behalf I am signing on the LWG rated suppliers’
webpage and for the use of the data for confidential benchmarking purposes
I do not wish the company on whose behalf I am signing to be listed on the LWG rated suppliers
page but I understand the data may be used for confidential benchmarking purposes
I give consent for key data (energy usage per square metre, water usage per square metre etc,
to be displayed on the Supplier Scorecard (to be displayed on the LWG webpages)
I do not give consent for key data (energy usage per square metre, water usage per square
metre etc, to be displayed on the Supplier Scorecard (to be displayed on the LWG webpages)

Signature …………………………..

Name (printed) …………………………..

Position …………………………..

Date …………………………..

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CONTENTS

Opening Statement and Declaration of Understanding ................................................................... 1

1 GENERAL FACILITY DETAILS .................................................................................................... 2
2 SUBCONTRACTED OPERATIONS.............................................................................................. 5
3 SOCIAL AUDIT.............................................................................................................................. 8
4 OPERATING PERMITS ............................................................................................................... 10
5 PRODUCTION DATA .................................................................................................................. 17
6 TRACEABILITY (INCOMING) ..................................................................................................... 27
7 TRACEABILITY (OUTGOING) .................................................................................................... 34
8 ENVIRONMENTAL MANAGEMENT SYSTEMS ........................................................................ 36
9 RESTRICTED SUBSTANCES, COMPLIANCE, CHROMIUM VI MANAGEMENT .................... 41
10 ENERGY CONSUMPTION .......................................................................................................... 54
11 WATER USAGE .......................................................................................................................... 62
12 WASTE MANAGEMENT ................................................................... Error! Bookmark not defined.
13 AIR & NOISE EMISSIONS .......................................................................................................... 67
14 WASTE MANAGEMENT ............................................................................................................. 73
15 EFFLUENT TREATMENT ........................................................................................................... 83
16 HEALTH, SAFETY, EMERGENCY PREPAREDNESS............................................................... 98
17 CHEMICAL MANAGEMENT ..................................................................................................... 108
18 OPERATIONS MANAGEMENT ................................................................................................ 117

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Opening Statement and Declaration of Understanding

If any data or information required for the completion of the audit is subsequently found to
have been deliberately withheld or presented in a way designed to mislead the auditor the
entire audit may be reclassified “Fail” and certification withdrawn.

If any aspect of business operations not covered by this protocol is judged by the auditor to
be of a nature that would be detrimental to the reputation of LWG the auditor is required to
bring that issue to the attention of LWG. If the issue is judged to be serious certification may
be declined, irrespective of the scoring of the audit.

If social audits have been undertaken for which there are outstanding non-conformances
these must be notified to the auditor. Failure to notify may lead to failure of the audit.

In addition to these conditions being made clear at commencement of the audit a senior
manager/director will be required to sign a declaration that full and accurate information has
been presented prior to any final reports or certification being issued.
Yes/No
A Has the above statement been read aloud or displayed on screen to the principal
contact for the audit?

B Does the principal contact for the audit accept responsibility for ensuring other
members of staff, who will be assisting or taking part in the audit, act in accordance
with the above statement?
C The response to A and/or B is “No” FAIL

Leather Working Group does not employ or endorse consultants.

If consultants have been engaged for the preparation of this audit any and all agreements
between the tannery and the consultant are outside of the scope of the audit and will have no
bearing on the audit result.
Yes/No
Was a consultant engaged in the preparation of this audit?
A

Has the tannery undergone an unpublished audit or any form of pre-audit by an LWG
B auditor?
Give details
If a consultant has been engaged for the preparation of the audit, please state the name
C of the consultant(s) (and consulting organisation if applicable) below.

Consultant Company Scope of consultation

Do you give consent for key data (energy usage per square metre, water usage per square
metre etc, to be displayed on the Supplier Scorecard (to be displayed on the LWG webpages)?

A Yes

B No

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 1 GENERAL FACILITY DETAILS
This section gathers introductory information regarding the facility. If the facility has operations or
warehousing located off-site the addresses and description of these off-site locations should also be
recorded. The operations should be included in this audit (subject to conditions outlined in “Scope of the
Audit” above).

Abbreviations used in this report (other than those in the glossary):

Abbreviation Full Title

1 Site Name and Category of Production:

Site Name:
Category of Production:

2 Company Registration/Identification Number:

3 Geographical Coordinates and Google Maps illustration:

4 Full Postal Address:

5 Telephone Number:

6a Principal Contact Name and Position:

This is the person to whom the report, the certificate and other LWG communications will be sent.
These may be critical communications about audit renewals, protocol changes or other issues that
might affect certification or performance in a future audit. The principal contact should be the person
who is responsible for disseminating audit-critical information to the rest of the organisation and is
not necessarily the head of the company.

To reduce environmental impact hard/paper copies are not produced. If required, they can be
printed by the client
Name
Position
email

6b Who is ultimately responsible for environmental issue at this site?

Name
Position
email

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 6c Who is responsible on a day-to-day basis for environmental issue at this site?

Name
Position
email

7 Are there any members of the organisation that also need to be sent LWG communications
such as Audit Report, Audit Certificate, LWG News and Protocol Updates?

All communications are electronic so it would be expected that the person named in q4 would be
capable of forwarding to relevant recipients within their own organisation. If applicable state which
communications are required
email address Communication required
#1
#2
#3

8 Website:

9 Description of the facility and its surroundings

Description of the facility (e.g. purpose-built tannery constructed 1995) site setting (e.g. within an
industrial park) and an indication of environmental receptors on, adjacent, or close to the facility (e.g.
several small lakes and the tannery discharges treated effluent into a river) .

10 State the total site area (in m2, indicating if within single or multiple boundaries)

11 Provide a site plan for all direct operations under this audit

12 How many people work at the site?

a.m. p.m. Night Overall
shift shift shift total
A Direct Labour 0
B Indirect Labour (management & administration) 0
C Shift total 0

State number of days to which the above applies

If reduced shifts are used regularly at weekends state
number of employees per shift as appropriate
A (w/e) Direct Labour 0
B (w/e) Indirect Labour (management & administration) 0
C (w/e) Shift total 0
State number of days to which the above applies

3
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 13 How many days per year does the tannery operate?
Days per week Weeks per year Days per year
Worker
Manufacturing operations

14 Are any significant construction projects or process/manufacturing or utility changes planned

in the next 3 years that will require environmental review, action or modification?
If applicable, please note details of the most likely environmental impacts based upon specific
planning/development requirements.
1
2
3
4
5

15 Are any operations undertaken on behalf of other organisations (does the company operate
wholly or in part as a subcontractor for other organisations)?
All incoming and outgoing material is owned by the tannery
Some processing and/or machine work is undertaken on behalf of other organisations
The company works wholly as a subcontractor
If applicable, please indicate details of the operations undertaken on
a subcontract basis.
Client
Scope of operations
Area of leather processed annually (m2)

4
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2 SUBCONTRACTED OPERATIONS

1 List all the supplying sub-contractors that have been assessed using the “Leather
Manufacturer Audit Protocol”.

Note – all subcontractors will need to be taken into consideration. Subcontractors holding current LWG
certification will only need to make their “transferable data” available. All other subcontractors will be
required to be assessed by means of a “mini-audit” note – the mini-audit is to be discontinued
approximately one year after the implementation of this protocol)
Sub-contractor Location Range of operations LWG
(town) Environmental
Audit score
1
2
3

4
5

2 List all the supplying sub-contractors that have been assessed using the “Subcontractor Audit
Protocol”

Note – all subcontractors will need to be taken into consideration. Subcontractors holding current LWG
certification will only need to make their “transferable data” available. All other subcontractors will be
required to be assessed by means of a “mini-audit” (note – the mini-audit is to be discontinued
approximately one year after the implementation of this protocol)
Sub-contractor Location Range of operations LWG
(town) Subcontractor
Audit score
1
2
3
4
5

3 List all the supplying sub-contractors that have been assessed using the “Mini-Audit Protocol”

Note – all subcontractors will need to be taken into consideration. Subcontractors holding current LWG
certification will only need to make their “transferable data” available. All other subcontractors will be
required to be assessed by means of a “mini-audit” (note – the mini-audit is to be discontinued
approximately one year after the implementation of this protocol)
Sub-contractor Location Range of operations LWG mini-
(town) audit score
1
2
3
4
5

4 Were details of all sub-contractors provided prior to the commencement of the audit.
The auditor may choose to continue with the audit if time allows and apply a negative score of -40 or
fail the audit if it cannot be carried out within the time allowed.
score attained
A Yes 0
B No, audit continued -40
C No, audit failed FAIL

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 5 Subcontractor Scores and Weighting

Subcontractor Score The overall score for the subcontractor (subcontractor audit or mini audit)

Energy Contribution The amount of energy expended on manufacturing operations on behalf

of the Leather Manufacturer (see section 10). This is derived by taking
the energy per unit area produced multiplied by total area produced.

Energy Energy
contribution contribution x Weighting Fractional
Subcontractor Score MJ Score factor score
1A 0 #DIV/0! #DIV/0!
2B 0 #DIV/0! #DIV/0!
3 0 #DIV/0! #DIV/0!
4 0 #DIV/0! #DIV/0!
5 0 #DIV/0! #DIV/0!
6 0 #DIV/0! #DIV/0!
7 0 #DIV/0! #DIV/0!
8 0 #DIV/0! #DIV/0!
9 0 #DIV/0! #DIV/0!
10 0 #DIV/0! #DIV/0!
11 0 #DIV/0! #DIV/0!
12 0 #DIV/0! #DIV/0!
13 0 #DIV/0! #DIV/0!
14 0 #DIV/0! #DIV/0!
15 0 #DIV/0! #DIV/0!
SUM 0 #DIV/0!
WEIGHTED SCORE #DIV/0!

Scores and Energy contributions

Note – all subcontractors will need to be taken into consideration. Subcontractors undertaking a range of operations
that are covered by one of the Leather Manufacturer Audit categories are required to undergo a full audit.
Subcontractors that have already completed a Sub-Contractor audit and therefore holding current LWG certification
will only need to make their “transferable data” available. All other subcontractors will be required to be assessed
by means of a “mini-audit” undertaken at the time of the Leather Manufacturer audit. The current Leather
Manufacturer Audit protocol does not express “transferable data” in the same manner as the Subcontractor Audit
Protocol or the Mini-Audit Protocol. Such reports will need to be made available to the auditor for extraction of that
data.

6
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Subcontracted Operations
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
4 0 0 0
5 100 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

7
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
3 SOCIAL AUDIT
This section seeks to determine if the organisation can demonstrate social responsibility through
independent assessment. This list may be expanded on application to and approval by LWG. This section
will become critical in future versions of the protocol.

LWG recognised audit systems and auditing organisations are listed on the LWG webpages.
https://www.leatherworkinggroup.com/key-areas/social

1 Social Audit
Yes/No
A Has your facility undergone Social Audits within the past 24 months?
If yes give details of all audits (add additional rows B-E as necessary)
B Audit programme/protocol
C Audit body
D Date of audit
E Date next audit due

B Audit programme/protocol
C Audit body
D Date of audit
E Date next audit due

2 Has the facility undergone an LWG recognised social audit within the past 24 months?
score attained
A At least one satisfactorily completed audit by an LWG recognised social
(
'
&
%
$
#
"
📷 auditing organisation and undertaken by qualified auditors (e.g. APSCA
registered)
Insert image of certificate, executive summary or report conclusion 50
demonstrating successful completion.

B No social audit undertaken / audit body or programme not recognised by

0
LWG

3 Has the company recorded any critical/zero tolerance compliance issues in any social audit
within the past 24 months?

Identify the nature of issue

Date of Audit body Reason for critical/zero Corrective action Current
audit tolerance recording status

8
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 4 Has the company undergone any social audit for which non-conformances have been
identified and which remain unresolved at the time of this LWG audit?

Identify the nature of each outstanding non-conformance, the corrective action required, the date by
which the audit body requires corrective action to have been undertaken.
Date of Audit body Nature of non-conformance Corrective action Required
audit completion
date

(
'
&
%
$
#
"
📷 Insert image of executive summary/conclusion indicating current status with respect to non-
conformances or actions required.

Social Audit
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
2 50 0 0
MAX 50 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

9
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
4 OPERATING PERMITS
This section assesses the facility’s compliance with the applicable licences and legislation. Violations,
warnings or fines, and what corrective actions must be recorded. The facility could fail the audit in this
section.

The tanner may be required to supply an assurance to the auditor, in advance of the audit, that all necessary permits
are available for assessment (photocopies could be supplied in advance). The tanner may also be required to
supply the auditor with the contact names and contact details, as requested by the auditor, of the responsible
authorities so that the auditor can determine in advance and independently the types of permit that are required.

1 Does the company maintain a register of all operating permits required including data
necessary to demonstrate validity?
Which of the following fields are included in the registers?
Cumulative Score Attained
A Title of permit 0
B Issuing authority 0
C Date of issue 0
D Date of expiry 0
E Due date of submission of renewal application 0
F Reporting frequency 0
G Date of most recent report submitted 0
H Title of the permit is NOT included -5
I Issuing authority is NOT included -5
J Date of issue is NOT included -5
K Date of expiry is NOT included -5
L Due date of renewal application is NOT included -5
M Reporting frequency is NOT included -5
N Date of most recent report submitted is NOT included -5
TOTAL (MAX 0)

2 Please list operating permits required.

The permits listed below should be the full set of permits (or regulatory limits as they apply to the
tannery) relating to environmental discharges/emissions. All test reports will need to be made
available to demonstrate compliance and should be a complete record of the company’s testing
regime.

Table 1
General Operating Permit
Permit Number
Issuing Authority
Date Permit Expires
Conditions

Table 2
Water Abstraction
Permit Number
Issuing Authority
Date Permit Expires
Permit Limit Recorded Value
(average)
Volume per day
Volume per week
Volume per month
Volume per year
Any other relevant conditions:

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
Table 3a
Water Discharge from the tannery to the Environment (River, Lake, Sea, Irrigation)
Permit Number
Issuing Authority
Date Permit Expires
Destination of Discharge
Permit Limit Recorded Value Recorded Value
(average) (max)
Volume per hour
Volume per day
Volume per week
Volume per month
Volume per year
Chemical Oxygen Demand
Biological Oxygen Demand
Total Kjeldahl Nitrogen
Total Nitrogen
Ammonia (nitrogen)
Suspended Solids
Oil & Grease
Total Chromium
Chromium VI
Sulphides
Phosphorous
Phenol
Chlorides
Synthetic Detergent Limit
Copper
Cyanide
Lead
Mercury
Nickel
Cadmium
Zinc
Sulphates
pH range
Temperature limits
Prohibited Contaminants
Any other relevant conditions:

11
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
Table 4b
Water Discharge direct to drainage (treatment by third party - CETP, METP)
Permit Number
Contract Number
Issuing Authority
Date Permit Expires
Destination of discharge
Permit Limit Recorded Value Recorded Value
(average) (max)
Volume per hour
Volume per day
Volume per week
Volume per month
Volume per year
Chemical Oxygen Demand
Biological Oxygen Demand
Total Kjeldahl Nitrogen
Total Nitrogen
Ammonia (nitrogen)
Suspended Solids
Oil & Grease
Total Chromium
Chromium VI
Sulphides
Phosphorous
Phenol
Chlorides
Synthetic Detergent Limit
Copper
Cyanide
Lead
Mercury
Nickel
Cadmium
Zinc
Sulphates
pH range
Temperature limits
Prohibited Contaminants
Any other relevant conditions:

12
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
Table 5
Air Emissions
Permit Number
Issuing Authority
Date Permit Expires
Permit Limit Recorded Value
(average)
Volume per hour
Volume per day
Volume per week
Volume per month
Volume per year
Odour
Noise
Particulates
Nitrogen Oxides (NOx)
Sulphur Dioxide (SO2)
Volatile Organic Compounds (VOC)
Any other relevant conditions:

Table 6
Solid Waste Disposal
Permit Number
Issuing Authority
Date Permit Expires

Yes
Distinguishes Hazardous and Non-Hazardous Wastes
No

Permit Limit Recorded Value

(average)
Volume/mass per day
Volume/mass per week
Volume/mass per month
Volume/mass per year
Any other relevant conditions:

Table 7
Storm Water
Permit Number
Issuing Authority
Date Permit Expires
Any other relevant conditions:

Table 8
Boilers
Permit Number (s)
Issuing Authority
Date Permit (s) Expire
Any relevant conditions:

13
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
Table 8
Chemical Purchase/Storage
Permit Number
Issuing Authority
Date Permit Expires
Parameter Permit Limit Recorded Value
(average)

Any other relevant conditions:

Table 9
Building Stability
Permit Number
Issuing Authority
Date Permit Expires
Any other relevant conditions:

Table 10
Other permit as applicable (replicate table as required)

Permit Number
Issuing Authority
Date Permit Expires
Any other relevant conditions:

Table 11
Details of the National
Violations Register consulted
Date National Violations
Register check
Date pre-audit Internet
search completed

An example of a National Register is the IPE website applicable to China.

Go to www.ipe.org.cn . You should get a picture and at the top are some Chinese characters. Click on the one
that says pollution map (污染地图). A map of China should appear and on the upper right hand side of the screen
there is an orange button with Chinese characters. In the white area in front of the orange button, enter the
company's name in Chinese characters. Use a business card to check that the name is correct. When you click
the orange button, if there is anything against this company it will show up on the lower part of the screen, under
the paler blue line. The dark line at the top, with the few boxes of characters underneath explains the search result.

14
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 3 Have there been any regulatory environmental enforcement actions or fines in the past 24
months?
Cumulative Number Attained
Score per
of
incident
instances
A Baseline score N/A 0 100
B Caution/warning -12
C Fine -20
D Caution/warning/fine for which evidence of effective
+7
corrective action has been presented
E There have been no actions or fines, but the company
has failed to provide evidence that it is acting in FAIL
accordance with permit conditions and/or legislation
TOTAL (Max 100)
If yes, attach details and dates of past violations and regulatory actions

4 Did the company notify LWG in writing (within 30 days) of all regulatory enforcement actions
or fines (against itself or CETP if CETP is the route of discharge of effluent to the environment)
occurring in the past 24 months?
State number of instances if response is B or D
Score per Attained
instance
(B&D)
A No written cautions, warnings, prosecutions, or any form
0
of regulatory action have been taken against the company
B Written cautions, warnings, prosecutions, or other form of Number of
regulatory action have been taken against the company, instances
0
but the company have advised the audit body of ALL of
them (within 30 days)
C This is the first audit for the company therefore no prior
requirement or undertaking was in place to notify the audit
0
body of regulatory enforcement actions

D Written cautions, warnings, prosecutions, or other form of Number of

regulatory action have been taken against the company, instances
but the company has not advised the audit body of one or
-20
more of them (within 30 days)
Note: If 3 or more instances of non-reporting, automatic
failure will be recorded
TOTAL (Max 0)
State details and dates of past violations and regulatory actions

5 How frequently do the regulatory authorities visit to check that the site is operating in
accordance with the permit conditions?

Number of times per year

Provide evidence and indicate date of the last visit (Date)

A In last 6 months
B In last 12 months
C In last 18 months
D In the last 24 months
E Not done

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 6 Did any enforcement actions or improvement requirements result from the last visit?
A No
B Yes – violations have occurred (provide details below)

Request sight of visit report from the regulatory authority.

Corrective actions

7 Is the facility operating within the designated limits of its permit or any other pertinent
legislation or restriction (i.e., is the facility complying with permit requirements, local/national
regulations, local/national emissions limits etc.)?
Evidence has been presented that suggests that the factory has been operating well
A
within consent limits during the 24 months prior to the audit
Evidence has been presented that indicates that the factory has not been operating
within consent limits during the 24 months prior to the audit, but that the issues have
B been addressed, the tannery is currently operating in compliance with permit
conditions as well as local and national legislation and a positive score has been
recorded in question 3.
C No evidence has been presented to demonstrate compliance FAIL
Conclusive evidence has been found that demonstrates that the facility is not currently
D FAIL
in compliance with one or more of its operating permits
A negative score has been attained.
E FAIL
Evidence will be in the form of reports from external agencies confirming testing and
compliance or internal testing (if the latter evidence that the testing is occurring should
be sought i.e., view lab books).

In the event of response “C”, “D” or “E” leading to automatic audit failure the
remainder of the audit will proceed. In this event all information may be used to
support improved performance in a subsequent audit, however any subsequent audit
will be a FULL audit. None of the data gathered during this audit may be used.

Operating Permits
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
Q1 0 0 0
Q3 100 0 0
Q4 0 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

16
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
5 PRODUCTION DATA
This section is designed to connect the leather supply chain together and assess the risk and rating of
those that are supplying part-processed and raw material. For those starting from part-processed material,
their supplier’s engagement with the LWG audit process will be assessed. Depending on scope of
operations subcontractors may or may not be assessed in accordance with this section (see introductory
notes)

For some organisations some of the questions are not applicable but all tanners are capable of attaining the
maximum score of 100 through the pro-rata scoring of those questions that are applicable to each type of operation.
Tanners undertaking operations that fall into a combination of categories will also answer all applicable questions
which will be scored on a pro-rata basis.

The following definitions of subcontracting are to be applied for Q19

Sub-contracting
LWG defines sub-contracting as the arrangement whereby one organisation contracts with another, independent
organisation for one or more operations to be undertaken (with or without payment). Organisations within a group
of companies are not considered independent of each other and operations undertaken between them are not
considered to be sub-contracting arrangements. Alternative definitions of sub-contracting are not accepted.

Sub-contracting out
This is where an auditee arranges for work to be undertaken on its behalf by another, third party
organisation. In this instance assessment of the sub-contracted operations will be required. Depending
on the work sub-contracted out different levels of assessment may be required. If the organisation being
used as a subcontractor is capable of being audited using the Leather Manufacturer Audit Protocol then
that protocol must be used, irrespective of the operations that have been subcontracted.

Sub-contracting in
This is where an auditee undertakes work on behalf of another, third party organisation.

Verification of amount of material obtained from traders

For those tanneries sourcing part-processed material from traders there will be a requirement for the auditor to
verify whether the supplying trader is an LWG Approved trader and the amount of LWG origin material obtained
from the trader. It is important to be aware that an LWG audited trader can trade material that was manufactured in
LWG audited facilities as well as material that was not manufactured in LWG audited facilities. Traders are required
to clearly differentiate between these two types of original source (by use of different pallet covers, packing list
design, invoice data etc). This audit will only accept, for the purposes of scoring, material that has been obtained
by the trader from an LWG audited facility. This audit will only accept, for the purposes of scoring, material that is
supported by differentiating identifiers that indicate it as having originated in an LWG audited manufacturing facility.
It is the responsibility of the tanner being audited to communicate its requirements to supplying trader and to ensure
material received can be proven to have originated in an LWG audited manufacturing facility.

If a leather manufacturer sources material from a paper trader (i.e. a trader that buys/sells material without receiving
or storing it in his own facility), then a score will only be allowed if there is clear evidence of the material originating
from a LWG audited manufacturing facility, and shipped direct to the leather manufacturer being audited. Evidence
required will include shipping Bills of Lading, Invoices, Packing Notes, etc. It is the leather manufacturer’s
responsibility to produce this evidence at audit, otherwise the material score will not be allowed.

1 Is any leather produced at another site sold using this site’s name/paperwork/tax code?
A No

B Yes, at a LWG audited facility with the same audit scope.

The overall result for the entire audit will need to be given a pro-rata score in relation
to the proportions manufactured at this site and elsewhere, and in accordance with
the scores indicated in table 9
C Yes, at a LWG audited facility with a different audit scope.
The overall result for the entire audit will be based upon the rating of the poorest
performing facility
D Yes, at a non-LWG audited facility. FAIL

17
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 2 The production, energy usage and water consumption aspects of the audit are based on 24
consecutive months’ worth of data.

These should be the most recent 24 months for which data is available, the last of which must not be
more than three months prior to the audit (i.e., an audit undertaken 15 June 2022 would use data
from no earlier than the preceding period 01 April 2020 to 31 March 2022)

(in the early months after implementation the period may be taken as “since February 2020”)
Indicate the twenty-four-month period for which data is being presented
From
To

For processors of untanned material, the main calculation should be based on fleshed weight. Conversion factors
are embedded in the following table

Actual wt Converted wt
Bovine Green fleshed weight 0 0
Bovine Green weight (unfleshed rawstock) 0 0
Bovine Salted (pre-fleshed) 0 0
Bovine Salted (unfleshed) 0 0
Bovine Brine cured (pre-fleshed) 0 0
Bovine Brine cured (unfleshed) 0 0
Total weight 0

Goat Green fleshed weight 0 0

Goat Green weight (unfleshed rawstock) 0 0
Goat Salted (pre-fleshed) 0 0
Goat Salted (unfleshed) 0 0
Goat Brine cured (pre-fleshed) 0 0
Goat Brine cured (unfleshed) 0 0
Total weight 0

Sheep/pigskins Green fleshed weight 0 0

Sheep/pigskins Green weight (unfleshed rawstock) 0 0
Sheep/pigskins Salted (pre-fleshed) 0 0
Sheep/pigskins Salted (unfleshed) 0 0
Sheep/pigskins Brine cured (pre-fleshed) 0 0
Sheep/pigskins Brine cured (unfleshed) 0 0
Total weight 0

18
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 3 Production type (input into work, not Type of animal note1 Number of Weight of
purchases) skins/hides skins
per year /hides
per year
A Fresh hides/skins
B Brined hides/skins
C Wet or dry-salted hides/skins
D Limed splits
E Pickled hides/skins
F Wet blue hides/skins
G Wet white/wet green hides/skins
H Crust hides/skins
I Splits (tanned)
J Splits (crust)

Note 1 If the animal from which the skin is obtained is classed as exotic and/or is subject to controls as
described in the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
certification is further dependent upon approval by LWG. In case of doubt, it is strongly recommended that the
tannery consults the LWG administrative team prior to embarking upon an audit.

If the animal from which the skin is obtained was not farmed and/or was not part of the human food chain
certification is further dependent upon approval by LWG. In case of doubt, it is strongly recommended that the
tannery consults the LWG administrative team prior to embarking upon an audit.

4 Indicate activities and type of production performed by the facility during the audit period.
Note – the energy and water scores are based on the amount of leather MADE, not the amount
of leather sold.

The energy and water scores for category “A” tanners may be based on weight or area. If the
tannery operations include both “A” and other category outputs the energy and water scores
will need to be based on area. In such cases reliable data relating to the area of unsplit wet
blue will need to be provided.

Weight Area (m2)

A Raw, limed, pickled hide to tanned
B Raw, limed, pickled hide to crust
C Raw, limed, pickled hide to finished leather
D Tanned hide to finished leather
E Crust hide to finished leather
F Tanned hide to crust leather
G Raw hide/skin to pickled/pre-tanned material

5 Identify the organisations for which any subcontracting work was undertaken

Organisation Scope Area produced

(category or operation) (m2)
A
B
C
D

19
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 6 Scale of operations – is the company a small or large manufacturer
(as determined by mass of input/area of output)?

This question is for the purposes of LWG sub-group classification

Insert input/output data as appropriate Mass of input (tonnes) Area of output (m2)
(based on responses in section 3)
“Small Leather Manufacturer”
less than 7,000 tonnes (green fleshed) input / year
Output less than 1,000,000 m2 per year
“Large Leather Manufacturer”
more than 7,000 tonnes (green fleshed) input / year
Output more than 1,000,000 m2 per year

7 Provide an as accurate as possible breakdown of weight/substance of leathers made

(not Category A)
Factor %
A 0.41 - 0.8 mm 0.006 0 0.0
B 0.8 to 1.2 mm 0.010 0 0.0
C 1.21 – 1.6 mm 0.014 0 0.0
D 1.61 – 2.0 mm 0.018 0 0.0
E 2.01 – 2.4 mm 0.022 0 0.0
F 2.41 – 2.8 mm 0.026 0 0.0
G 2.81 – 3.2 mm 0.030 0 0.0
H 3.21 – 3.6 mm 0.034 0 0.0
I 3.61 – 4.0 mm 0.038 0 0.0
J 4.01 – 4.4 mm 0.042 0 0.0
K 4.41 - 4.8 mm 0.046 0 0.0
L 4.81 mm+ 0.050 0 0.0
Average thickness
0.0
(Right click on mouse and update field for each grey shaded cell)

20
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 8 Please indicate the percentage of the following types of leather manufacturing operations
apply
Tannage type Output
Leather type
(Cr, Veg, Cr-free) Crust, Finished
chrome veg Cr - free crust finished
A Calfskin
B Chamois
C Full grain
D Lining
E Nubuck
F Patent
G Pony leather
H Printed
I PU coated
J Sole / belt / strap
K Split
L Suede
M Wool-on
TOTAL

Wet part-processed
Limed Pickled Tanned
A Cow
B Sheep
C Goat
D Pig
E Kangaroo
F Ostrich
G Exotic (state type)
TOTAL

Industry Served
A Apparel / Clothing
B Automotive
C Contract
D Footwear
E Footwear (Athletic)
F Leather goods
G Upholstery
TOTAL

9 List all the supplying LWG audited tanners (Q 19, supplier categories A to D)
Tannery Location (town) material type LWG rating % of
supply
chain
1
2
3
4
5

10 State number of unaudited tanners (Q 19, supplier categories E)

Number of unaudited tanners Type of material supplied % of
(wet blue, crust etc) supply
chain
1

21
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 11 List all the supplying LWG audited processors to pickle (Q 19, supplier categories F to I)
Processor Location (town) material type LWG rating % of
supply
chain
1
2
3
4
5

12 State number of unaudited processors to pickle (Q 19, supplier category J)

Number of unaudited tanners Type of material supplied % of
(sheep, goat, kangaroo etc) supply
chain
1

13 List all LWG approved (traders from whom part-processed material originating from LWG
audited sources) is obtained for further processing, (Q 19, supplier category K)
.
Trader Location (town) Part-processed Trader % of
material type score supply
(limed, w/b, crust chain
etc.)
1
2
3
4
5

14 List all LWG approved (traders from whom part-processed material originating from non- LWG
audited sources) is obtained for further processing, (Q 19, supplier category L)
.
Trader Location (town) Part-processed Trader % of
material type score supply
(limed, w/b, crust chain
etc.)
1 N/A
2 N/A
3 N/A
4 N/A
5 N/A

15 State number of unaudited traders from whom part-processed material is obtained for further
processing, (Q 19, supplier category M)
Number of Traders from whom part- Part-processed material type % of
processed material are obtained (limed, w/b, crust etc.) supply
chain
1

22
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 16 State the percentage of your hide/skin supply chain for the past 24 months from each of the
sources listed below (The production, energy usage and water consumption aspects of the audit
are based on 24 months’ worth of data).

(in the early months after implementation the period may be taken as “since February 2020”)
Part processed (pickled/tanned/crust etc) material processed on a sub-contract in basis is not
included in the scoring for this question
% Score per Overall
% score
(% x score)
A Tanned material obtained from LWG Gold rated suppliers
0 1 0.00
Subcontractors scoring ≥ 85%
B Tanned material obtained from LWG Silver rated suppliers
0 0.9 0.00
Subcontractors scoring ≥ 75%
C Tanned material obtained from LWG Bronze rated
0 0.8 0.00
suppliers Subcontractors scoring ≥ 65%
D Tanned material obtained from LWG audited suppliers
0 0.7 0.00
(pass) Subcontractors scoring ≥ 50%
E Tanned material obtained from Non-LWG certified
0 0 0.00
suppliers
0 0.00
F Pickled material obtained from LWG Gold rated suppliers 0 0.2 0.00
G Pickled material obtained from LWG Silver rated suppliers 0 0.18 0.00
H Pickled material obtained from LWG Bronze rated
0 0.16 0.00
suppliers
I Pickled material obtained from LWG audited suppliers
0 0.14 0.00
(pass)
J Pickled material obtained from Non-LWG certified
0 0 0.00
suppliers
0 Trader
For material from traders use score applicable to type of score 00.00
material processed of material /100
K Part-processed material from LWG audited traders
0 0.00
(material LWG origin)
L Part-processed material from LWG audited traders
0 0 0.00
(material non-LWG origin)
M Part-processed material from unaudited traders
0 0 0.00
(not LWG approved)
0 0.00
N Raw/cured hides/skins/splits (including sub-contract-in
0 0 0.00
work)
0 0
TOTAL (Max 100)
0.00
Right click to update

Threshold question
For award of Gold in this section 100% of part-processed material input must come from LWG audited
sources (and if from traders, must be of LWG origin). Conditional 5% allowance if proof of purchase for
trialling new suppliers (maximum of three purchases)

17 What proportion of final output is

%
A Tanned on site
B Tanned prior to receipt by the company
(If 100% do not complete questions 18-25)
C Processed only to pickled condition
(If 100% do not complete questions 18-25)
Section score to be recorded as “Not Applicable”

23
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 18 Tanning method is a
(expressed as a proportion of total 24-month output) % score per attained
%
A Chrome tanning method
0
B Chrome free tanning method
Process commences from raw/cured
1
Processing only as far as pickle
(go to end of section if 100%)
D Chrome free tanning method
0.8
Process commences from pickled
TOTAL (Max 100)

19 The chrome content of the leather tanned on-site is measured

Applies to tanners starting with raw/cured material
(expressed as a proportion of chrome tanned leather out % of total score per attained
of total output) %
A Routinely, (at least once a week) 0.1
B At least once a month 0.08
C At least once every three months 0.05
D Only for technical changes, modifying the process. 0.03
E Less than 4 times per year 0

20 The chrome content of the leather tanned on-site is measured

Applies to tanners starting with pickled material
(expressed as a proportion of chrome tanned leather out % of total score per attained
of total output) %
A Routinely, (at least once a week) 0.080
B At least once a month 0.064
C At least once every three months 0.040
D Only for technical changes, modifying the process. 0.024
E Less than 4 times per year 0

21 The chrome content of the end of tanning liquor is measured

Applies to tanners starting with raw/cured material
(expressed as a proportion of chrome tanned leather out % of total score per attained
of total output) %
A Routinely, (at least once a week) 0.1
B At least once a month 0.08
C At least once every three months 0.05
D Only for technical changes, modifying the process. 0.03
E Less than 4 times per year 0

22 The chrome content of the end of tanning liquor is measured

Applies to tanners starting with pickled material
(expressed as a proportion of chrome tanned leather out % of total score per attained
of total output) %
A Routinely, (at least once a week) 0.080
B At least once a month 0.064
C At least once every three months 0.040
D Only for technical changes, modifying the process. 0.024
E Less than 4 times per year 0

24
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 23 What percentage of the chrome purchased by the tannery for use in tanning of raw/cured
hides/skins is utilised or treated in such a way that it does not enter the environment?

The chrome discharged into the environment (directly into water courses or onto land) must be taken
into account. The chrome waste that is rendered safe (i.e. by being deposited into regulated landfill,
used in cement manufacture etc.) may be excluded.

Applies to tanners starting with raw/cured material

% score
chrome
utilised

score = ((% utilised x 4.2553) – 342.98) x % of total output chrome tanned onsite
100

MAX Score = 80 x % of total output chrome tanned onsite

100

24 What percentage of the chrome purchased by the tannery for use in tanning of pickled
hides/skins is utilised or treated in such a way that it does not enter the environment?

The chrome discharged into the environment (directly into water courses or onto land) must be taken
into account. The chrome waste that is rendered safe (i.e. by being deposited into regulated landfill,
used in cement manufacture etc.) may be excluded.

Applies to tanners starting with pickled material

% score
chrome
utilised

score = ((% utilised x 4.2553) – 342.98) x % of total output chrome tanned onsite x 0.8
100

MAX Score = 64 x % of total output chrome tanned onsite

100

25 What is the frequency of testing of waste streams (discharged into the environment) used for
the calculation in Q23 and/or 24?
Note - this should include liquid wastes discharged to watercourses as well as slurries or solids applied
to land.
(expressed as a proportion of chrome tanned leather out % of total score per attained
of total output) %
A Monthly 0
B Quarterly -10
C Biannually -20
D Annually -40
E Less than Annually -80

25
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Production Data
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
16 T 100 0 0
18 100 0 0
19 10 0 0
20 8 0 0
21 10 0 0
22 8 0 0
23 80 0 0
24 64 0 0
25 0 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold question
For award of Gold in this section 100% of part-processed material input must come from LWG audited
sources, and if from traders, must be of LWG origin (q16). Conditional 5% allowance if proof of purchase
for trialling new suppliers (maximum of three purchases)

26
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
6 TRACEABILITY (INCOMING)
This section assesses the ability of leather manufacturers to trace their incoming material back to the
specific slaughterhouse or region of origin. It also provides a breakdown of country of origin and a
description of the traceability system used. Depending on scope of operations subcontractors may or may
not be assessed in accordance with this section (see introductory notes)

Processers of fresh, salted or brined hides.

Processers must be able to present documents that indicate the facility where slaughter
occurred. Only those hides for which documentation can be presented that indicates that the
entire consignment contains hides originating from the same (named) slaughterhouse, are
considered to be traceable.

Processers receiving hides in a part processed condition

Consignments may be made up on the basis of weight or quality and may therefore be made
up of several pallets of material each of which may or may not support hides originating from
different process loads. Only those hides on individually marked pallets for which
documentation can be presented that indicates that the entire pallet contains hides originating
from the same (named) slaughterhouse, can be considered to be traceable.

1 Is there a written procedure that describes the way the organisation ensures traceability of
incoming material to the slaughterhouse or region?

Note – even if the hides/skins are technically traceable by virtue of being physically marked, for the
purposes of this audit no material will be deemed to be traceable to the slaughterhouse unless a
procedure is presented that describes in detail the manner in which traceability can be assured.
Yes/No
A Yes
B No

2a This question relates to hides/skins that are individually physically marked in a manner that
identifies the slaughterhouse from where the hide/skin was obtained.

List countries from which raw material has been obtained in the past 24 months.

List country from which hides/skins Total overall

are obtained. percentage score
traceable
to this level
% should be based on TOTAL input
% of hides/skins that are physically
marked but traceable only to the N/A
country of origin
% of hides /skins that are physically
marked and traceable to the
slaughterhouse (note A)
% of Brazilian and Paraguayan
hides/skins physically marked,
traceable to the slaughterhouse and
include date of slaughter (note B)

Score % Traceability demonstrated during on-site audit activity

Note A This is a minimum requirement for all material.

Note B This is a minimum requirement for all hides sourced from Brazil and Paraguay

27
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 2b This question relates to hides/skins that are NOT physically marked but which are
accompanied by documentation that identifies the slaughterhouse from where the hide/skin
was obtained.

List countries from which raw material has been obtained in the past 24 months.

List country from which hides/skins Total overall

are obtained percentage score
traceable
to this level
% should be based on TOTAL input
% of hides/skins that are not
physically marked but are traceable
through documentation to the N/A
country of origin
% of hides /skins that are not
physically marked but are traceable
through documentation to the
slaughterhouse (note C)
% of Brazilian and Paraguayan
hides /skins that are not physically
marked but are traceable through
N/A
documentation to the
slaughterhouse and include date of
slaughter (note D)

Score % Traceability demonstrated during on-site audit activity

Note C This is a minimum requirement for all material.

Note D This is a minimum requirement for all hides sourced from Brazil and Paraguay.

2c This question relates to part-processed hides/skins/splits that are traceable to a group of

slaughterhouses due to the supplier having and based on supplier’s own physical traceability
score. The hides/skins/splits must be individually marked to indicate the immediate supplier.
There is traceability only to a source group.

List the supplier and supplier countries from which part-processed material has been obtained
in the past 24 months.

List supplier and country from which Total overall

hides/skins/splits are obtained percentage score
traceable
to this level
% should be based on TOTAL input
% of hides/skins/splits that are not
physically marked
N/A

% of hides /skins/splits from supplier

N/A

% Supplier’s own physical

traceability score
N/A

Weighted traceability % sourced x

% physically traceable

Score % Traceability demonstrated during on-site audit activity

28
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 2d This question relates to hides/skins that are not traceable to a slaughterhouse, but which are
obtained from a supplier whose base (trading premises) has been geo-referenced. There is
traceability only to a region.

List countries from which raw material has been obtained in the past 24 months.

List country from which hides/skins Total overall

are obtained percentage score
traceable
to this level
% should be based on TOTAL input
% of hides/skins that are not
physically marked but are traceable
through documentation to the N/A
country of origin
% of hides /skins that are not
physically marked but are traceable
through documentation to the region
of the supplier/collector note E

Score % Traceability demonstrated during on-site audit activity

Note E Both the geo-reference of the supplier and the supplier’s catchment area (operating radius) must be stated in q10

3a Provide a detailed description of the traceability system(s) applicable to hides skins that are
📷 physically marked

3b Provide a detailed description of the manner in which documents ensure that each entire
(
'
&
%
$
#
"
📷 consignment/pallet load can be shown to have come from the same (named) slaughterhouse.

29
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 3c Provide a detailed description of the manner in which documents ensure that each entire
(
'
&
%
$
#
"
📷 consignment/pallet load can be shown to have come from a known group of slaughterhouse.

3d Provide a detailed description of the manner in which documents ensure that each entire
(
'
&
%
$
#
"
📷 consignment/pallet load can be shown to have come from a georeferenced region.

4 For those hides originating from Brazil how does the company (tannery) ensure that the
supplying slaughterhouse’s own immediate suppliers are not involved in deforestation,
invasion of indigenous lands and/or protected areas in the Amazonian biome and thereby meet
minimum acceptable criteria which includes the following;

• The direct farms (within the Amazon Biome) should have their complete boundary shape GPS
registered by January 1st, 2015.
• The direct farms should not have been involved in any form of deforestation in the Amazon
biome since October 5th, 2009.
• The indirect farms should not have been involved in any form of deforestation in the Amazon
biome since August 1st, 2019
• The farms should not be involved in slave labour, invasion of indigenous lands and protected
areas, or farms included in IBAMA’s embargo list (www.ibama.gov.br)

The map for all regions of concern in South America is available from:
http://terrabrasilis.dpi.inpe.br/en/home-page/
Description of the system (the level of evidence of compliance provided will be factored into the score, and the
minimum acceptable is a declaration affirming compliance to ALL the above)

30
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 5 For those hides originating from Paraguay how does the company (tannery) ensure that the
supplying slaughterhouse’s own immediate suppliers are not involved in deforestation,
invasion of indigenous lands and/or protected areas in the Chaco biome and thereby meet
minimum acceptable criteria which includes the following.

• Slaughterhouse shall not have as suppliers any farms in the Chaco Biome overlapping with
illegal deforestation polygons, using the cut-off date of January 01, 2018. The current areas are
subject to revision; if the area changes a subversion of this protocol will be issued.
• Slaughterhouse shall not have as suppliers any farms in the Chaco Biome located in officially
recognized protected areas owned by the Government of Paraguay (ASP).
• Slaughterhouse shall not have as suppliers any farms in the Chaco Biome located in officially
recognized indigenous land owned by the Government of Paraguay (FAPI).

Description of the system (the level of evidence of compliance provided will be factored into the score, and the
minimum acceptable is a declaration affirming compliance to ALL the above)

6 For tanners processing fresh or cured hides/skins originating from Brazil identify each
supplying slaughterhouse, the amount of material received during the audit period, and
whether the slaughterhouse has provided evidence of compliance with the conditions
stipulated in question 4

Note – percentage expressed relates to total input of fresh/cured material.

Evidence of compliance
Score x 1 if compliance evidence (q4) is a copy of an IBAMA report and/or copy of evidence of
compliance from meatpacker’s in-house monitoring system and/or copy of report from 3rd party
monitoring service provider.
Score x 0.5 if compliance evidence (q4) is a simple declaration of compliance
Slaughterhouse Geo-reference SIF Quantity of Evidence %
material of compliant
supplied. compliance material
Tons See note
0
0
0
Sourcing factor = total compliant 0.00

7 For tanners processing fresh or cured hides/skins originating from Paraguay identify each
supplying slaughterhouse, the amount of material received during the audit period, and
whether the slaughterhouse has provided evidence of compliance with the conditions
stipulated in question 5.

Note – percentage expressed relates to total input of fresh/cured material

Evidence of compliance
Score x 1 if compliance evidence (q5) is a copy of evidence of compliance from meatpacker’s in-
house monitoring system and/or copy of report from 3rd party monitoring service provider
Score x 0.5 If compliance evidence (q5) is a simple declaration of compliance
Slaughterhouse Geo-reference Quantity of Evidence of Percentage
material compliance compliant
supplied. material
Tons
0
0
0
Sourcing factor = total compliant 0.00

31
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 8 For tanners processing fresh or cured hides/skins originating from countries other than
Paraguay or Brazil and which are marked in a way that identifies the slaughterhouse, identify
each supplying slaughterhouse and the amount of material received during the audit period.

Note – percentage expressed relates to total input of fresh/cured material

Slaughterhouse Country Geo-reference Quantity of Percentage
material of total
supplied. input
Tons
0
0
0
Sourcing factor = total 0.00

9 For tanners processing fresh or cured hides/skins originating from countries other than
Paraguay or Brazil, which may or may not be physically marked but which are supported by
documentation that that identifies the slaughterhouse, identify each supplying
slaughterhouse and the amount of material received during the audit period.

Note – percentage expressed relates to total input of fresh/cured material

Slaughterhouse Country Geo-reference Quantity of Percentage
material of total
supplied. input
Tons
0
0
0
Sourcing factor = total 0.00

10 For tanners processing part processed material, identify each supplier and the amount of
material received during the audit period.

Note – percentage expressed relates to total input of fresh/cured material.

For suppliers audited against P6 the sourcing factor = supplier’s combined physical and
documentation traceability score
Supplier Country Quantity Supplier’s % Sourcing
supplied. sourcing of total input factor
m2 factor (suppliers x %)

Sourcing factor = total 100

Supplier Operating licence Expiry date Issuing authority

32
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 11 For tanners processing fresh or cured hides/skins originating from countries other than
Paraguay or Brazil, which are not physically marked, for which there is no slaughter location
data, but which are supported by documentation that that identifies the immediate [geo-
referenced] supplier, identify each supplier and the amount of material received during the
audit period.

State the collection radius of each supplier.

Note – percentage expressed relates to total input of fresh/cured material

Supplier Country Geo- Supplier’s Quantity %
reference collection supplied. of total
radius M2 input
0
0
0
0.00
Sourcing factor = total

12 Overall sourcing factor

Sourcing
factor
A Question 6 score 0
B Question 7 score 0
C Question 8 score 0
D Question 9 score 0
E Question 10 score 0
F Question 11 score 100
Total (Max 100) 100

13 If exotic materials are processed, are they fully traceable to legal sources?

Exotics are materials are those covered by legislation or agreements such as the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES)
score attained
A Exotics are not processed N/A
B There is 100% traceability to legal sources 0
C There is less than 100% traceability to legal sources FAIL

Traceability (incoming)
% Traceability Weighted
traceability factor traceability
2a Physical traceability to slaughterhouse 1
2b Documented traceability to slaughterhouse 0.8
2c Traceability to group of slaughterhouses 0.7
2d Regional traceability 0.6
No traceability 0
13
Total weighted traceability
12 Sourcing factor
Overall traceability score = weighted traceability score x Sourcing factor
200
0.00
Max 50

33
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
7 TRACEABILITY (OUTGOING)
This section assesses the ability of leather manufacturers to trace their material through their own
manufacturing processes. It assesses the manner in which outgoing material (i.e. material leaving the site)
is identified and the extent to which the identifier allows data recorded about each process stage to be
retrieved. A batch of leather is one drum load of leather.

1 Is there a written procedure that describes the way the organisation ensures traceability of
material through its own manufacturing processes?

Note – even if the hides/skins are technically traceable by virtue of being physically marked, for the
purposes of this audit no material will be deemed to be traceable unless a procedure is presented that
describes in detail the manner in which traceability can be assured.

Note – even if the batch is technically traceable by virtue of being physically marked, for the purposes
of this audit no batch will be deemed to be traceable unless all of the following can be determined
from the batch code.
• the recipe sheet,
• the type of material
• the origin of the material (immediate supplier)
Yes/No
A Yes
B No

2 Are there procedures that allow the immediate source material making up individual batches
to be followed through to completion of the process?

Example - In this question the immediate source material for a tanner processing from wet blue to
finished leather refers to the group of wet blue suppliers, not the original source (slaughterhouse, farm
etc). For a tanner producing wet blue the immediate source is slaughterhouse or hide trader.
score attained
Each hide /skin is marked
A 55
Batch and exact supplier can be identified
Each hide /skin is marked
B 41
Batch and group of suppliers can be identified
Each hide /skin is marked
C 47
Either group of suppliers OR batch can be identified
All outgoing PO’s supported with robust paperwork, no marking applied
D 42
Batch and group of suppliers can be identified
All outgoing PO’s supported with robust paperwork, no marking applied
E 37
Either group of suppliers OR batch can be identified
No marking or documentation provided with shipments, no information
0
tracked

3a Provide a detailed description of the traceability system(s) applicable to hides skins that are
📷 physically marked

34
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 3b Provide a detailed description of the way documents ensure that each entire batch can be
📷 traced through manufacturing processes

4 If exotic materials subject to CITES requirements are processed, is despatch from the tannery
supported by the required permits and identification enabling them to be fully traceable to legal
sources?

Exotics are materials are those covered by legislation or agreements such as the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES)
score attained
A Exotics are not processed 0
B There is 100% traceability to legal sources 0
C There is less than 100% traceability to legal sources FAIL

5 Are splits generated during the process physically stamped?

This question applies to splits that are generated with the intention of being sold for leathermaking
operations.

This questions applies equally to tanners undertaking splitting at the end of their operations (for
example Category A tanners who split wet blue prior to despatch) as well as to those splitting received
material, part of which is sold onwards (for example Category D tanners who do not processes
internally generated splits)
Choose one score attained
Wet blue splits are stamped/physically marked such that each split can
A 5
individually be traced to the producing tannery
Crust splits are stamped/physically marked such that each split can
B 5
individually be traced to the producing tannery
Splits are not marked, but all shipments supported with robust
documentation. The producing tannery or a possible group of producing 3
tanneries can be identified
C Splitting is not part of tannery operations 5
D Splits are generated but are not stamped 0

Traceability (outgoing)
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
2 55 0 0
4 0 0 0
5 5 0 0
MAX 60 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold question
For award of Gold in this section a minimum score of 30 points must be attained in q2

35
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
8 ENVIRONMENTAL MANAGEMENT SYSTEMS
This section assesses if the facility has a documented, effective, and active system for managing the
environmental aspects of their business

1 Is there a written environmental policy for the company?

Cumulative score attained
A Yes, there is a one-paragraph policy statement 1
Yes, there is a detailed breakdown of the company’s commitments with
B respect to each broad aspect of environmental performance (air 3
emissions, wastes management etc.
C No (go to q3a, consider q2 “not applicable”) -2
TOTAL (Max 4)

2 Has policy been communicated effectively to facility staff?

score attained
A Yes 2
B No -2

3a Are there any written environmental procedures for

score attained
Ensuring that the company is operating in accordance with legal and
A customer requirements. 2
State title and reference number of the procedure
There are no written procedures (go to Q4a, consider q3b “not
B -2
applicable”)

3b Can the company provide evidence that the environmental procedures described in 3a have
been implemented
Cumulative score attained
There is a register of legal requirements (permits etc) which is up to
A 4
date (score 100 in Operating permits section q1)
There is a register of customer restricted substance requirements which
B 4
is up to date (score 5 in RSL section q4)
If neither A or B are applicable state two alternative means of
demonstrating that response A in q3a is valid
8
Evidence #1
Evidence #2
C No 0
TOTAL (Max 8)

4a Are there any written environmental procedures for

score attained
Ensuring at least five environmental objectives are set, two of which
A must be quantifiable environmental objectives. 1
State title and reference number of the procedure
There are no written procedures/only one quantifiable objective is
B -2
stated (go to Q5a, consider q4b “not applicable”)

36
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 4b Can the company provide evidence that the environmental procedures described in 4a have
been implemented for at least two objectives
Cumulative score attained
Yes, one of the quantified objectives is:
A 1
Yes, one of the quantified objectives is:
1
B
Yes, one of the objectives is:
C 1
Yes, one of the objectives is:
D 1
Yes, one of the objectives is:
E 1
F No/only one quantifiable objective has been addressed -2
TOTAL (Max 5)

5a Are there any written environmental procedures for

score attained
Ensuring the resources, roles, and responsibilities necessary to fulfil
A environmental objectives are established. 4
State title and reference number of the procedure
There are no written procedures.
B -2
(go to Q6a, consider q5b “not applicable”)

5b Can the company provide evidence that the environmental procedures described in 5a have
been implemented
Cumulative score attained
Yes, for each objective identified in q4b there is a written record
A 2
identifying why the objective was chosen
For each objective identified in q4b there is a written record identifying
B 2
how or why the performance target was determined
C For each objective identified in q4b there is a named project leader 2
For each objective identified in q4b the names and or roles of the team
D 2
members is identified
For each objective identified in q4b budgetary requirements have been
E 2
identified
F No -2
Total (Max 10)

6a Are there any written environmental procedures for

score attained
Ensuring that all personnel have an appropriate understanding of the
environmental objectives of the company and are competent and those
A personnel responsible for their achievement are trained where 2
applicable
State title and reference number of the procedure
There are no written procedures
B -2
(go to Q7a, consider q6b “not applicable”)

6b Can the company provide evidence that the environmental procedures described in 6a have
been implemented
Cumulative score attained
Yes there is environmental awareness training for ALL staff at least
A annually 4

The academic and/or professional experience requirements of the

project leader(s) (Q5b) are appropriate to the objectives that have been 4
determined
B No 0
TOTAL (Max 8)

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 7a Are there any written environmental procedures for
score attained
Ensuring that documentation associated with the EMS is correctly
A maintained 2
State title and reference number of the procedure
There are no written procedures (go to Q8a, consider q7b “not
B -2
applicable”)

7b Can the company provide evidence that the environmental procedures described in 7a have
been implemented?
score attained
Yes
A Evidence #1 8
Evidence #2
B No 0

8a Are there any written environmental procedures for

score attained
Ensuring that internal audits are undertaken at defined intervals by
A competent personnel 2
State title and reference number of the procedure
There are no written procedures (go to Q9a, consider q8b or q8c “not
B -2
applicable”)

8b Can the company provide evidence that the environmental procedures described in 8a have
been implemented
score attained
A Yes, internal audits are undertaken monthly 8
B Yes, internal audits are undertaken quarterly 4
C Yes, internal audits are undertaken biannually 2
D Internal audits are undertaken but less frequently than twice a year 0
E No internal audits are undertaken -8

8c Who carries out the audits?

score attained
Nominated internal auditor from a different area of the facility
A 4
Third party training by a nationally certified / registered trainer
Nominated internal auditor from a different area of the facility
B 3
Third party training by a professional consultant
Nominated internal auditor from a different area of the facility
C 0
Internal training by another member of staff
D Un-trained staff/training records unavailable -2

In

9a Are there any written environmental procedures for

score attained
Ensuring that management reviews are undertaken at defined intervals
A 2
State title and reference number of the procedure
There are no written procedures (go to Q10a, consider q9b “not
B -2
applicable”)

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 9b Can the company provide evidence that the environmental procedures described in 9a have
been implemented
score attained
A Yes, reviews are undertaken quarterly 8
B Yes, reviews are undertaken biannually 4
C Yes, reviews are undertaken annually 2
D No 0

9c Who sits on the management review committee? (describe position held in the company)

10 To whom does the person having primary responsibility for environmental issues at the site
report (section 1, Q8)?

A Board of Directors
B Managing Director or Chief Executive
C Production or Technical Director
D No formal relationship

11 Has the facility performed aspects and impacts analysis as part of its environmental
(
'
&
%
$
#
"
📷 management system?
score attained
A Yes 10
B No 0

12 Can the facility provide evidence that the aspects and impacts analysis (if undertaken) is being
used to improve the environmental performance of the business?
score attained
Yes
A Evidence #1 10
Evidence #2
B No 0

39
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Environmental management Systems
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
1 4 0 0
2 2 0 0
3a 2 0 0
3b 8 0 0
4a 1 0 0
4b 5 0 0
5a 4 0 0
5b 10 0 0
6a 2 0 0
6b 8 0 0
7a 2 0 0
7b 8 0 0
8a 2 0 0
8b 8 0 0
8c 4 0 0
9a 2 0 0
9b 8 0 0
11 10 0 0
12 10 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

40
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
9 RESTRICTED SUBSTANCES, COMPLIANCE, CHROMIUM VI MANAGEMENT

This section assesses the extent to which the facility manages, understands and enacts the Restricted
Substance requirements of its customers. It assesses the extent to which the company undertakes to
minimise the risk of formation of CrVI. For tanners operating on a 100% subcontracting basis this section
is not applicable – the clients on whose behalf they are undertaking processing are responsible for
restricted substance management of their product. Tanners who both produce their own material and who
produce material on a subcontract basis will be assessed on the restricted substance management of their
own material. Depending on scope of operations subcontractors may or may not be assessed in
accordance with this section (see introductory notes)

Chrome-free leather is defined by LWG for the purposes of this protocol as leather containing less than 1000
mg/kg chromium based on dry leather weight, this value being based on currently used standards (BS EN 15987).

Questions in the first part of this section refer to Restricted Substance Lists (RSL). An RSL is used by customers
or brands to control and restrict the presence of unwanted substances in the material they are purchasing. An
RSL could and should be developed by a tanner to apply to leathers supplied to customers who do have not
submitted an RSL. An RSL applies to leather, it does not apply to chemical products used in leather manufacture.

Questions in the second part of this section refer to Restricted Substance Lists that a company may apply to its
own suppliers to ensure that they will be able to conform to both client and own RSL. In this instance the RSL
may apply to incoming part-processed material or incoming chemicals. It should be designed to ensure
compliance to the RSL of outgoing product.

Questions in section 16 “Chemical Management” refer to Manufacturing Restricted Substance Lists (MRSL). An
MRSL is used to control or restrict the presence of unwanted substances in the chemicals used in leather
manufacture. An MRSL applies to chemical products used in leather manufacture, it does not apply to leather.

For several questions in this section there is reference to a batch of leather,; taken to be one production drum
load of leather, small sample and development loads may be ignored. Manufacturers whose incoming material is
crust should consider a batch of leather to be the group of hides skins that are processed together as a unit (e.g.
through a spray machine).

OUTGOING MATERIAL:

1 Is there a written restricted substances management system and/or set of written restricted
substances procedures for the company?
score attained
A Yes 2
B No 0

2 How does the company communicate with clients to determine the restricted substances
specifications of those clients?
score attained
Formally, for those clients who have not already made known their
A restricted substances requirements there is evidence (e.g. emails) of
2
(
'
&
%
$
#
"
📷 clients being contacted to determine if they have a restricted substance
specification.
Informally, there are no written records (e.g. emails)
B 0

3 Does the company have its own restricted substance specification for outgoing leather
(applicable whenever there is not a client specification)?
score attained
A Yes 4
B No 0

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 4 Does the company maintain a register (e.g. spreadsheet) that records the compliance to up-to-
date client specifications? If so, does it reference the following records?
Cumulative score attained
A Date contacted 1
B Means of contact (telephone, email etc) 1
C Date response received 1
D Reference number/code of clients’ specification 1
E Client’s acceptance of tannery RS spec (client without their own spec) 1
F Review date 1
TOTAL (Max 6)

5 How frequently are restricted substances specifications reviewed?

score attained
A Every 6 months 2
B Every 12 months 1
C Less frequently than every 12 months 0
The frequency should be explicitly stated in the procedures to record a
score
The auditor should be shown evidence of reviews

6a Which of the following substances are specified in the company’s internal restricted
substances specification?
A stated limit must be included to attain a score
A schedule of testing must be in place to obtain a score
Evidence of testing for leathers supplied to customers without their own specification must be
presented to obtain a score
Only those parameters actually tested will be scored
Spec band Band attained
Cumulative mg/kg score
Chromium VI (2 points) note 1 <3 2
A Chromium VI With ageing (3 points) note 2 <3 3
>3 Fail
< 75 2
B Formaldehyde (adult products) note 3 75-150 1
>150 0
<100 2
C Chlorinated paraffins (C10-C13) 100-200 1
>200 0
<100 2
D AP ((Alkyl phenol) total 100-200 1
>200 0
<100 2
E APEO (Alkyl phenol ethoxylate) total 100-200 1
>200 0
<0.1 2
F Dimethylfumarate 0.1-0.2 1
>0.2 0
Azo-amines (each type) <20 2
G (producers of un-dyed/uncoloured material 20-30 1
exempted) >30 0
TOTAL (Max 15)

Note1 Test method must be ISO 17075-1 or -2 (third party)

Note 2 Ageing method must be ISO 10195:2018 (A2)
Note 3 If the company produces leather that it knows will be used in child products this should be included in
their internal specification and the following limits apply to option B in q6

Spec band Band attained

mg/kg score
< 16 2
B Formaldehyde (child products) 16-30 1
>30 0

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 6b Does the company’s internal restricted substances specification include all the following
heavy metals and require compliance with at least the limits stated for each?

A schedule of testing must be in place to obtain a score

Spec yes/no
mg/kg
A Antimony (extractable) <30
B Arsenic (extractable) <0.2
C Barium (extractable) <1000
D Cadmium extractable <0.1
E Cobalt extractable note4 <4
F Copper extractable note4 <50
G Lead extractable note4 <1
H Mercury extractable 0.02
I Nickel <1
J Selenium <500
All “yes” score 3
One or more “no” score 0

Note 4 If the company produces leather that it knows will be used in child products this should be included in
their internal specification and the following limits apply to option B in q6b
Spec yes/no
mg/kg
E Cobalt extractable (child) <1
F Copper extractable (child) <25
G Lead extractable (babies) <0.2

7 Does the written restricted substances management system and/or set of written restricted
substances procedures for the tannery make reference to the following?
Cumulative score attained
A The frequency of testing 2
B The qualifications and credentials of the third-party testing organizations 2
C Definition of product lines (for the purposes of RS testing) 2
TOTAL (Max 6)

8 What are the top three product lines?

Note – for the purposes of restricted substance control “clothing”, “footwear” etc are not product lines.
This question refers to chemically different leathers. A product line relates to leather made with a
specific set of retanning, fatliquoring, finishing chemicals etc varying only in colour or physical print. A
change in any one of the chemicals used introduces the risk of a restricted substance failure.
“Footwear” will only be accepted as a product line if there is evidence that the company uses a single
retanning and finishing system for ALL leather, the only variable being colour
% of
production
#1
#2
#3

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 9 Can the tannery provide evidence that the laboratory undertaking the testing is ISO 17025
certified or is a client approved testing facility?
score attained
A Yes 2
B No 0

10 What is the incidence of third-party restricted substances testing for outgoing crust and
finished leathers?

Note – this question requires presentation of evidence of all reports to verify incidence of testing. This
could be through physical presentation of all reports or submission of the testing register from which
a random selection of reports will be requested by the auditor for examination.

The scope of each test must encompass at least the company’s own restricted substance specification
score attained
For the following responses a batch of leather is one
production drum load of leather, small sample and
development loads may be ignored.
0.5% or more of batches of crust and finished leather
A 12
produced are tested in a third-party laboratory
0.3% or more of batches of crust and finished leather
B 8
produced are tested in a third-party laboratory
0.1% or more of batches of crust and finished leather
C 4
produced are tested in a third-party laboratory
testing is less than 0.1% of batches of crust and finished
D 0
leather produced

TOTAL (Max 12)

Threshold question
For award of medal rating in this section a minimum score of 4 points must be attained in q10

11 Is third party testing carried out in accordance with the procedures outlined in questions 1-9
above?
score attained
Yes, provide evidence below
The auditor should list sufficient evidence of the test report
A 0
numbers/dates that have been presented to confirm that the frequency
and scale of testing justifies the scores awarded in questions 1-10
B No -40

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q11

44
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 Product line Comments
Percentage of total output
Test house
Report number
Date
Customer
Specification
Result

Product line Comments

Percentage of total output
Test house
Report number
Date
Customer
Specification
Result

Product line Comments

Percentage of total output
Test house
Report number
Date
Customer
Specification
Result

12 Does the company verify that all outgoing leather, irrespective of whether covered by client or
tannery RS specifications for Chrome VI, conforms to the industry standard of <3ppm to
ISO17075 by means of testing in a laboratory certified to ISO17025 (or client nominated
laboratory)?

Note – for the purposes of restricted substance control “clothing”, “footwear” etc are not product lines.
This question refers to chemically different leathers. A product line relates to leather made with a
specific set of retanning, fatliquoring, finishing chemicals etc A change in any one of the chemicals
used introduces the risk of a restricted substance failure. “Footwear” will only be accepted as a product
line if there is evidence that the company uses a single retanning and finishing system for ALL leather,
the only variable being colour
score attained
A All outgoing material is free of chromium 3
B Each product line is tested at least quarterly, with artificial ageing method 3
C Each product line is tested at least quarterly, without artificial ageing
2
method
D Each product line is tested at least annually, with artificial ageing method 2
E Each product line is tested at least annually, without artificial ageing
1
method
F No testing evidence provided -2

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 13 What is the incidence of CrVI testing for outgoing crust and finished leathers?
Test method must be ISO 17075-1 or -2 (third party)
Ageing method must be ISO 10195:2018 (A2)

Note – this question requires presentation of evidence of all reports to verify incidence of testing. This
could be through physical presentation of all reports or submission of the testing register from which
a random selection of reports will be requested by the auditor for examination.
Cumulative score attained
A All outgoing material is free of chromium 12
For the following responses a batch of leather is one
production drum load of leather, small sample and
development loads may be ignored. Without With
ageing ageing
The third-party laboratory should be ISO 17025 or one that
has been nominated by at least one of the top three clients.
Extensive (> 20% of batches) either in the tannery’s own
B 4 8
client-approved laboratory or a third-party laboratory.
Substantial (> 10% < 20% of batches either in the
C tannery’s own client-approved laboratory or a third-party 3 6
laboratory.
5% or more of batches of crust and finished leather
D 2 4
produced are tested for CrVI in a third-party laboratory
3% or more of batches of crust and finished leather
E 1 2
produced are tested for CrVI in a third-party laboratory
1% or more of batches of crust and finished leather
F 0.5 1
produced are tested for CrVI in a third-party laboratory
CrVI testing is less than 1% of batches of crust and
G 0 0
finished leather produced
If response B or C state incidence of testing:

TOTAL (Max 12)

Threshold question
For award of Gold in this section a minimum score of 2 points must be attained in q13

14 What is the incidence of CrVI testing for tanned leathers (sold as tanned)?

Note – this question requires presentation of evidence of all reports in order to verify incidence of
testing. This could be through physical presentation of all reports or submission of the testing register
from which a random selection of reports will be requested by the auditor for examination.

Response should be in relation to each recipe (e.g. summer and winter formula, heavy bovine and
light bovine etc.)
score attained
A All outgoing material is free of chromium 4
B Four tests per year 4
C Two tests per year 2
D One test per year 1
E No testing (less than annually) 0

Threshold question
For award of Gold in this section a minimum score of 1 point must be attained in q14

15 Does the company have effective procedures to respond to CrVI failures such that future
occurrences will be minimised/eliminated?
score attained
A Yes, written procedures are in place to establish the cause if a failure
occurs. Re-testing is undertaken to demonstrate effectiveness of 2
procedures.
B Yes, procedures are in place to establish cause if a failure occurs 1
C No, there is no procedure in place 0

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 16 What is the incidence of CrVI failures within the tannery?

For the following responses a batch of leather is one production drum score attained
load of leather, small sample and development loads may be ignored.
A There have been no CrVI failures in the past 2 years and testing
incidence is greater than 5% of batches of crust and/or finished leather 5
produced
B There have been no CrVI failures in the past 2 years and testing
incidence is greater than 3% of batches of crust and/or finished leather 4
produced
C There have been no CrVI failures in the past 2 years and testing
incidence is greater than 1% of batches of crust and/or finished leather 3
produced
D There have been no CrVI failures in the past 2 years and testing
incidence is less than 1% of batches of crust and/or finished leather 2
produced
E CrVI failures have occurred in the past 2 years however testing incidence
is greater than 1% of batches of crust and/or finished leather produced.
1
The causes have been identified and verified by retesting. There have
been no further occurrences
F CrVI failures have occurred in the past 2 years however testing incidence
is less than 1% of batches of finished leather produced. The causes have
0
been identified and verified by retesting. There have been no further
occurrences
G CrVI failures have occurred in the past 2 years. The causes have not
-10
been identified.

17 To what extent is the company conforming to customer restricted substances specifications?

Note - the following declaration relating to the entire audit that a director of the company will be
required to sign prior to issuance of audit certificate - “I understand that in the event that any data or
information is found to have been deliberately withheld or presented in a way designed to mislead the
auditor the entire audit may be reclassified “Automatic Audit Failure” and certification withdrawn.”
score attained
The company can present evidence that it is testing and fully
A conforming to all customer restricted substances specifications. No 8
failures have been recorded
There have been failures, but evidence has been presented that the
B cause has been identified, the product lines affected have been 7
retested, passed and the reasons for failure have been resolved
There have been failures and although the cause has not been fully
resolved the company can provide evidence that it is actively working to
C 6
address the issue – production of the affected product lines is currently
suspended
There have been failures, but no evidence has been presented to
D indicate that the product lines affected have been retested or that -16
production has been suspended

Threshold question
For award of medal rating in this section a minimum score of 6 points must be attained in q17

47
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 18 To what extent is the company conforming to its own restricted substances specifications?

Note - the following declaration relating to the entire audit that a director of the company will be
required to sign prior to issuance of audit certificate - “I understand that in the event that any data or
information is found to have been deliberately withheld or presented in a way designed to mislead the
auditor the entire audit may be reclassified “Automatic Audit Failure” and certification withdrawn.”
score attained
The company can present evidence that it is testing and fully
A conforming to its restricted substances specifications. No failures have 8
been recorded
There have been failures, but evidence has been presented that the
B cause has been identified, the product lines affected have been 7
retested, passed and the reasons for failure have been resolved
There have been failures and although the cause has not been fully
resolved the company can provide evidence that it is actively working to
C 6
address the issue – production of the affected product lines is currently
suspended
There have been failures, but no evidence has been presented to
D indicate that the product lines affected have been retested or that -16
production has been suspended

Threshold question
For award of medal rating in this section a minimum score of 6 points must be attained in q18

48
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
INCOMING MATERIAL

19 Does the tannery have its own restricted substance specification for all incoming materials?

score attained
A Yes, for all incoming part-processed leather 1
B Yes, for all incoming chemicals 1
C No 0

20 To what extent does the tannery require suppliers of input materials (part-processed leather)
to follow the tannery’s restricted substance specification?
This applies to ALL suppliers of materials used in the leather manufacturing process.
score attained
The tannery will not use a material unless it is supported by evidence
A supplied twice a year (e.g. test report) that it conforms to the tannery’s 4
RSL
The tannery will not use a material unless it is supported by evidence
B 3
supplied annually (e.g. test report) that it conforms to the tannery’s RSL
The tannery will not use a material unless it is supported by a
C 2
declaration that it conforms to the tannery’s RSL
The tannery uses one or more materials without RSL compliance
D -1
declarations from suppliers

Threshold question
For award of medal rating in this section a minimum score of 2 points must be attained in q20

21 To what extent does the tannery require suppliers of input materials (proprietary chemical /
formulation) to follow the tannery’s restricted substance specification?
This applies to ALL suppliers of materials used in the leather manufacturing process.
score attained
The tannery will not use a material unless it is supported by evidence
A 2
(e.g. test report) that it conforms to the tannery’s RSL
The tannery will not use a material unless it is supported by a
B 1
declaration that it conforms to the tannery’s RSL
The tannery uses one or more materials without RSL compliance
C -1
declarations from suppliers

Threshold question
For award of medal rating in this section a minimum score of 1 points must be attained in q21

22 Does the tannery maintain a register (e.g. spreadsheet) that records supplier compliance
details for incoming leather? If so, does it reference the following:
Cumulative Score attained
A Date contacted 1
B Means of contact (telephone, email, etc) 1
C Date response received 1
D A record of the supplier’s ability to conform to the tannery’s RS spec 1
E Amount of material used annually 1
F Review date 1
TOTAL (Max 6)

23 What procedures are in place whenever any chemical in a process is substituted by an

alternative?
Cumulative score attained
A The change is documented 1
The leather range affected is subjected to renewed restricted substance
B 2
risk analysis (and testing if risk analysis indicates high risk)
TOTAL (Max 3)

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Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 24 What percentage of incoming material (by mass) is subject to compliance verification?

This question does not imply that the tanner needs to have the material third party tested.
Documentation from the supplier providing evidence that the materials supplied conform to the
specifications indicated by the tanner would be sufficient.
attained
Cumulative Score
Mass of incoming materials (only part processed hides i.e. wet blue,
crust etc. should be considered)
A
Verifications sought and received twice per year % x 0.06
Mass of incoming materials (only part processed hides i.e. wet blue,
crust etc. should be considered)
B
Verifications sought and received once per year % x 0.03
C Mass of incoming chemicals % x 0.06
TOTAL (Max 12)

25 Does the company verify that all incoming part-processed chrome tanned material conforms
to the industry standard of <3ppm to ISO 17075 for Chrome VI?
score attained
A All incoming material is free of chromium 3
B Each supplier provides test reports at least annually, with artificial ageing
3
method
C Each supplier provides test reports at least annually, without artificial
1
ageing method
D No testing evidence provided -2

26 Does the company ensure that all relevant incoming chromium containing chemicals (chrome
tanning salts, dyes and pigments) contain less than 10 ppm CrVI
score attained
A Yes, declarations of compliance are required from ALL suppliers 3
B Chromium containing chemicals are used even if no compliance
-10
declaration has been received

27 Does the company ensure that natural fat is at levels that are unlikely to contribute to the
formation of CrVI?
All measurement is based on dry weight.
Cumulative score attained
A The specification for fat content in incoming wet blue is <3%
2
(Category D & F tanners)
B The specification for fat content in own produced wet blue is <3%
2
(Category A, B & C tanners)
Incoming material is crust leather
2
C (Category E tanners)
There are no specifications relating to natural fat content
0
D (Category A, B, C, D, F tanners)
TOTAL (Max 2)

50
Issue 7.1.0 Copyright © 2021 Leather Working Group Limited. All Rights Reserved Issue Date 01/07/21
 28 Does the company have a written procedure for ensuring that fat content is <3% for incoming
wet blue material?
score attained
A Yes, every consignment is supported by a compliance declaration
3
(Category D, F tanners)
B Yes, compliance declarations are received annually
2
(Category D, F tanners)
C No, compliance declarations are not required or supplied
0
(Category D, F tanners)
D Incoming material is raw hide or crust leather
3
(Category A, B, C, E tanners)
E Chrome tanning is not part of the company’s operation 3

29 Does the company have a procedure for ensuring that fat content is <3% for material tanned
on site?
score attained
A Yes, testing is done weekly
4
(Category A, B, C, tanners)
B Yes, testing is done monthly
2
(Category A, B, C tanners)
C No, testing is less frequent than monthly
0
(Category A, B, C tanners)
D Chrome tanning is not part of the company’s operation 4

30 Is the re-tanning process designed to ensure that pH values (in chrome containing materials)
are consistently at levels that are unlikely to contribute to the formation of CrVI?
score attained
A The pH is maintained below 4.0 in the final bath (fixation) of the re-tanning
steps to ensure entire cross section of leather is at acidic pH 2
(Category B, C, D, F, tanners)
B Re-tanning is not undertaken
2
(Category A, E, G tanners)
C pH in the final bath (fixation) of the re-tanning steps remains at a pH
higher than 4.0 0
(Category B, C, D, F tanners)
D No testing for pH has been done after completion of the re-tanning
processing steps -2
(Category B, C, D, F tanners)

31 Does the company ensure that strong oxidising agents such as peroxides and permanganates
(if used) are unlikely to contribute to the formation of CrVI?
Simple tests for oxidising agents are starch-iodide papers and ferrous score attained
chloride solution or ORP measurement
A Oxidising agents are used prior to application of chrome tanning agents
but are fully reduced prior to addition of chrome tanning agents 2
(Category A, B, C, D & F tanners)
B Oxidising agents are not used at any stage in the process. 2
C Oxidising agents are used but are either NOT fully reduced prior to
addition of chrome tanning agents (no testing is undertaken to ensure full
-2
reduction), OR are applied after addition of chrome
(Category A, B, C, D & F tanners)

32 Does the company have a register of all fatliquors used in the tannery and which includes
supplier declarations that fatliquors are suitably formulated with an appropriate antioxidant
and protected against the potential for CrVI formation?
score attained
A Yes, and declarations have been obtained for all fatliquors used 2
B Yes, but not all fatliquors are supported by supplier declarations 1
C No, there is no register 0

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 33 Does the tannery use subcontractors for chemical processing and if so does it ensure that
they comply with the tannery’s RSL requirements?
score attained
A Subcontractors are not used 2
Yes, subcontractors are used and the tannery or the subcontractor
B 2
undertakes testing of the material produced to demonstrate compliance
D No evidence of a compliance is demonstrated 0

34 Does the company use scavenging agents/antioxidants as a precautionary measure to prevent

the formation of CrVI?

A chemical will only be accepted as being a scavenging agent if the following conditions are met:
• There is a supplier’s written declaration indicating that it is suitable and appropriate for this purpose.
• Supplier has indicated amount to be used, process stage, recommended contact time
• Tanner has provided evidence that product use complies with supplier recommendations
• The material is used in all chromium containing product lines
score attained
A Scavenging agents (antioxidants) are added
(Category B, C, D & F tanners)
2
Please list names and evidence of functionality of any scavenging agents
/ antioxidants used:
B The company does not process material to a sufficiently advanced stage
to where scavenging agents are appropriate 2
(Category A tanners)
C Incoming material is crust leather
2
(Category E tanners)
D Scavenging agents are not added
0
(Category B, C, D & F tanners)

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 Restricted Substances, Compliance & Chromium VIi Management
Actual potential score Score Percentage
Theoretical potential
(if question not
score
applicable enter 0)
1 2 0 0
2 2 0 0
3 4 0 0
4 6 0 0
5 2 0 0
6a 15 0 0
6b 3 0 0
7 6 0 0
9 2 0 0
10 T 12 0 0
11 T 0 0 0
12 3 0 0
13 T 12 0 0
14 T 4 0 0
15 2 0 0
16 5 0 0
17 T 8 0 0
18 T 8 0 0
19 2 0 0
20 T 4 0 0
21 T 2 0 0
22 6 0 0
23 3 0 0
24 12 0 0
25 3 0 0
26 3 0 0
27 2 0 0
28 3 0 0
29 4 0 0
30 2 0 0
31 2 0 0
32 2 0 0
33 2 0 0
34 2 0 0
MAX 150 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold questions
For award of medal rating in this section a minimum score of 4 points must be attained in q10
For award of medal rating in this section a minimum score of 0 points must be attained in q11
For award of Gold in this section a minimum score of 2 points must be attained in q13
For award of Gold in this section a minimum score of 1 points must be attained in q14
For award of medal rating in this section a minimum score of 6 points must be attained in q17
For award of medal rating in this section a minimum score of 6 points must be attained in q18
For award of medal rating in this section a minimum score of 2 points must be attained in q20
For award of medal rating in this section a minimum score of 1 points must be attained in q21

53
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10 ENERGY CONSUMPTION
This section assesses the energy usage per unit produced, including operations that have been
subcontracted out. The scoring rewards usage of renewable energy generated on-site.

Energy consumption includes ALL aspects of site operations such as administration, engineering, space heating,
fork trucks, and operation of the wastewater treatment. It includes off-site activities associated with treatments that
are often undertaken onsite, such as effluent treatment.

Score based on 9 months’ worth of data per 12-month period.

The score for this energy section may be based on nine months’ worth of data per 12-month period provided a
monthly breakdown of both energy usage and production data for the full year period is available at the time of the
audit. The purpose of this is to screen out the peak energy requirements encountered during the very hottest or
very coldest parts of the year. The nine months’ worth of data may be selected by the tannery being audited
although the excluded three months must be three consecutive months. The month-by-month production and
energy usage must be included in the audit report. The energy calculation and score for both the 24-month and the
two 9-month periods must be included.

An additional three months of energy data may be excluded due to the effects on trade of the Covid-19 pandemic.
The periods of interruption may be variable; there may be second waves that could result in production interruptions
directly affecting the tannery during non-consecutive months, there could be subsequent waves affecting the
customers which then leads to production interruption through delayed orders, even if the tannery is capable of
operating. Therefore, the three additional excluded months (per 12-month period do not need to be consecutive,
but they must be the same as those chosen for water (if water data is also excluded)

Leather manufactures who only process to the tanned condition can choose to undertake the score calculation
based on area of leather produced or tonnes of hides/skins processed. All other categories must calculate the
score based on area of leather produced. Producers undertaking operations that fall into more than one category
must calculate the score based on the area of leather produced.

Factors used when auditing processors of skins and splits

Due to the different energy requirements associated with processing different types of raw material the mass of
raw material processed or area of leather produced must be converted into “bovine equivalents” in accordance
with table 2 below.
Note: Sheep and goat skins scores are to be calculated based on 0.783 bovine equivalents. This figure is based
on data gathered during the audits undertaken whilst version 6.6 and variants of the protocol was effective.
Pigskins and splits are to be scored based on 0.975 bovine equivalents.

Factors to be used for producers/processors of limed and pickled material

For operations that involve starting or finishing in the limed or pickled condition the following factors apply:

The energy requirements for processing from raw to tanned are 1.7645 that of processing from raw to limed
• If processing from raw to limed multiply weight by 0.567 and treat as “A” category.
• If processing from limed to tanned multiply weight by 0.433 and treat as “A” category.
• If processing from limed to crust or finished leather multiply final by 0.433 and treat as “A” category.
Thereafter use final area for D or F category operations as applicable

The energy requirements for processing from raw to tanned are 1.2240 that of processing from raw to pickled
• If processing from raw to pickled multiply weight by 0.817 and treat as “A” category.
• If processing from pickled to tanned multiply weight by 0.183 and treat as “A” category.
• If processing from pickle to crust or finished leather multiply final by 0.183 and treat as “A” category.
Thereafter use final area for D or F category operations as applicable

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Actual fuel energy values must be supplied by tanner being audited
There is no single conversion factor into MJ for many fuels – the conversion factor depends on the composition
and state of the fuel concerned. The energy conversion factors can normally be obtained from the supplier of the
fuel. The auditor will use the actual factors provided evidence is supplied as to what these factors are. If the actual
factors are not supplied to the auditor the conversion factors below will be used (which may be higher and may
adversely affect the score obtained).

Table 9 Standard energy factors

MJ/kg MJ/litre
Natural Gas 60 0.045
LPG 55 30
Fuel Oil 50 50
Coal 35 N/A
Diesel 50 45
Petrol/Gasoline 55 40
Wood 20 N/A

Energy associated with waste-water treatment must be included

Those companies that do not operate their own waste-water treatment plant must indicate the energy usage of
the plant that is responsible for the treatment of their effluent, the volume of effluent treated and therefore an
apportioned amount of energy associated with the treatment of the volume of effluent generated by the tannery. If
this information is not available an estimated value per cubic metre of effluent treated will be used as follows:
Conventional treatment technologies without membrane filtration 10 kWh per cubic metre of effluent
Treatment including membrane filtration (e.g. reverse osmosis) 30 kWh per cubic metre of effluent
Treatment including filtration and evaporation 100 kWh per cubic metre of effluent

Those companies who treat their own effluent to at least a Bronze standard (25 points or more in section 14
questions 11-21) and who could discharge to the environment but are obliged to discharge to an additional
treatment plant and who use their own discharge results for scoring in section 14 may discount the energy
associated with the external WWTP.

Table 10 Bovine equivalents

BOVINE EQUIVALENTS
Splits & Bovine
Cow Sheep Goat
Pigs Equivalents
Mass of hide or skin
Category A 0 0 0 0 0 kg
processed
Area of leather
Category A 0 0 0 0 0 m2
produced
Area of leather 2
Category B 0 0 0 0 0 m
produced
Area of leather
Category C 0 0 0 0 0 m2
produced
Area of leather 2
Category D 0 0 0 0 0 m
produced
Area of leather
Category E 0 0 0 0 0 m2
produced
Area of leather
Category F 0 0 0 0 0 m2
produced

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Companies undertaking an audit can request an editable copy of the above table from
[email protected]

Q1 What is the non-renewable energy contribution from each of the commissioned

subcontractors (if applicable)?
Subcontractor Operations Area m2 MJ/m2 MJ
Right click to
update
0
0
0
0
0
0
0

TOTAL 0

Q2 What is the renewable energy contribution from each of the commissioned subcontractors (if
applicable)?
Subcontractor Operations Area m2 MJ/m2 MJ
renewable renewable
Right click to
update
0
0
0
0
0
0
0

TOTAL 0

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 3a
Energy consumption
Energy consumption includes ALL aspects of site operations such as administration, engineering,
space heating , fork trucks, operation of the waste water treatment plant, etc (excluding
dormitories provided actual values can be shown)

Energy
Calculation Enter data Conversion Automatic
Supplied energy and fuels Annual usage Factor MJ
Electricity Kwhr 0 3.6 0
0
Fuels units (m3, ltr, kg) 0
Natural Gas 0 0 0
LPG 0 0 0
Fuel Oil 0 0 0
Coal 0 0 0
Diesel 0 0 0
Petrol/Gasoline 0 0 0
Steam 0 0 0
Other 0 0 0
External WWTP energy 0
Electricity 0 0 0
0
Sustainably sourced renewable energy 0
Wood 0 0 0
Tallow 0 0 0
Biomass 0 0 0

Self generated renewable energy

Wind Turbine 0 0 0
Solar panel 0 0 0
Geothermal well 0 0 0
Other 0 0 0
Total Energy 0
Total bought in Energy 0
Total Renewables 0
Internally generated renewables 0
Total Renewables Percentage 0.0

Average thickness (b, c, d & f category tanners only) 0.0

Total less self generated

2
renewable Energy (MJ) 0 Energy MJm
m2 ratio
A Raw to Wet Blue 0 #DIV/0! 0 0.65
B Raw to Crust 0 #DIV/0! 0 1.71
C Raw to Finished 0 #DIV/0! 0 2.86
D Wet Blue to Finished 0 #DIV/0! 0 2.15
E Crust to Finished 0 #DIV/0! 0 1.15
F Wet Blue to Crust 0 #DIV/0! 0 1.00

Aggregate Score (max 90) #DIV/0!

Total 0

E factor 0 Max 90.0

Min 0

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Companies undertaking an audit can request an editable copy of the above table from
[email protected]

3b If one or more of the fuels used by the tannery have been entered in the rows allocated to
“sustainably sourced renewable energy” (Q3a) provide justification/evidence below.

Fuel Justification

A
B
C

The following tables are included for illustrative purposes

In the following questions “t”= average thickness of the leather (mm)

3c Energy Use/Unit Output

The value can be calculated on the basis of nine months’ worth of data provided month by month
production and energy data for a full year has been supplied.

In the event that demonstrable, quantifiable changes have been introduced that provide evidence
supported by at least 6 months data of on-going long-term energy savings the value base on those 6
months will be used.
MJ tonne-1 score SCORE
raw hide Based on total
processed energy
A Raw hide to (recorded usage – 5984)
tanned -54.4

Score Average score if more than one

production type (based on max 90
proportions of area produced)

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 3d Energy Use/Unit Output*
The value will be calculated on the basis of nine months’ worth of data provided month by month
production and energy data for a full year has been supplied.

In the event that demonstrable, quantifiable changes have been introduced that provide evidence
supported by at least 6 months data of on-going long-term energy savings the value base on those
6 months will be used.
MJm-2 score SCORE
finished Based on total
product energy
A Raw hide to (recorded usage – 37.4)
tanned -0.34

B Raw hide to (recorded usage -2.12t – 116.4)

crust -1.06

C Raw hide to (recorded usage –4.24t – 182.4)

finished leather -1.66

D Tanned hide (recorded usage – 4.24t – 123.2)

finished leather -1.12

E Crust hide to (recorded usage – 66)

finished leather -0.6

F Tanned hide to (recorded usage –2.12t – 57.2)

crust leather -0.52

Score Average score if more than one max 90

production type (based on
proportions of area produced)

Energy
(MJ/tonne)
Consumption
A
Raw to
Points
tanned
0 5984
5 5712
10 5440
15 5168
20 4896
25 4624
30 4352
35 4080
40 3808
45 3536
50 3264
55 2992
60 2720
65 2448
70 2176
75 1904
80 1632
85 1360
90 1088

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 (MJ/m2) Energy Consumption
A B C D E F
Raw to Raw to Tanned to Crust to Tanned to
Points Raw to crust
tanned finished finished finished crust
0 37.4 116.4 182.4 123.2 66.0 57.2
5 35.7 111.1 174.1 117.6 63.0 54.6
10 34 105.8 165.8 112.0 60.0 52.0
15 32.3 100.5 157.5 106.4 57.0 49.4
20 30.6 95.2 149.2 100.8 54.0 46.8
25 28.9 89.9 140.9 95.2 51.0 44.2
30 27.2 84.6 132.6 89.6 48.0 41.6
35 25.5 79.3 124.3 84.0 45.0 39.0
40 23.8 74.1 116.1 78.4 42.0 36.4
45 22.1 68.8 107.8 72.8 39.0 33.8
50 20.4 63.5 99.5 67.2 36.0 31.2
55 18.7 58.2 91.2 61.6 33.0 28.6
60 17 52.9 82.9 56.0 30.0 26.0
65 15.3 47.6 74.6 50.4 27.0 23.4
70 13.6 42.3 66.3 44.8 24.0 20.8
75 11.9 37.0 58.0 39.2 21.0 18.2
80 10.2 31.7 49.7 33.6 18.0 15.6
85 8.04 25.0 39.2 26.5 14.2 12.3
90 6.8 21.2 33.2 22.4 12.0 10.4

4 What proportion of the factory total energy usage comes from sustainably sourced
renewable sources*?
The scoring is designed to award the commissioning of % Score (per Overall
sustainably sourced renewable energy generating %) score
capacity (% x score)

A Greenhouse gas emissions reduction technologies

(Combined Heat & Power/Co-generation) 0-100 0.05

B GHG releasing sustainably sourced renewable energy*

usage provided that the conversion has been undertaken 0-5 0.2
on-site or by plant owned wholly by the tannery. 5.1- 100 0.042

C Zero Greenhouse Gas Emissions technologies

(Solar panels, wind turbines, etc.) 0-100 0.1

Energy from these sources is not included in the energy

calculation and are given an additional reward via this
question to promote GHG reduction technologies
TOTAL (Max score 10)

*Renewable Energy:

For the purposes of this protocol, the definitions in European Union Directives 2009/28/EC and 2003/54/EC apply,
namely:

‘energy from renewable sources’ means energy from renewable non-fossil sources, namely wind, solar,
aerothermal, geothermal, hydrothermal and ocean energy, hydropower, biomass, landfill gas, sewage treatment
plant gas and biogases;

and where

‘aerothermal energy’ means energy stored in the form of heat in the ambient air;

‘geothermal energy’ means energy stored in the form of heat beneath the surface of solid earth;

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‘hydrothermal energy’ means energy stored in the form of heat in surface water;

‘biomass’ means the biodegradable fraction of products, waste and residues from biological origin from agriculture
(including vegetal and animal substances), forestry and related industries including fisheries and aquaculture, as
well as the biodegradable fraction of industrial and municipal waste;

5 If operations are undertaken on behalf of other organisations (e.g the tannery acts as a
subcontractor) what is the energy requirement of those operations?
Operation Basis on which energy Area m2 MJ/m2 MJ
contribution was determined Right click to
e.g splitting e.g machine power rating update
0
0
0
0
0
0
0

TOTAL 0

Energy Consumption
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
3a 90 0 0
4 10 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

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11 WATER USAGE
This section assesses the freshwater usage, per unit produced. The scoring rewards the use of water that
is recycled.

Score based on 9 months’ worth of data per 12-month period during the Covid-19 pandemic
The score for this water section may be based on nine months’ worth of data per 12-month period provided a
monthly breakdown of both energy usage and production data for a full year is available at the time of the audit.
The three month of water data may be excluded due to the effects on trade of the Covid-19 pandemic. The periods
of interruption may be variable; there may be subsequent waves that could result in production interruptions directly
affecting the tannery during non-consecutive months, there could be subsequent waves affecting the customers
which then leads to production interruption through delayed orders, even if the tannery is capable of operating.
Therefore, the three additional excluded months do not need to be consecutive, but they must be the same as
those chosen for energy (if energy data is also excluded).

1 What is the water usage contribution from each of the commissioned subcontractors?
Subcontractor Operations Area m2 m3/m2 Total m3

TOTAL

2 Water usage. What is the quantity fresh water used annually (m3)?
Quantity
m3
Municipal water system
Wells/boreholes
River/canal/lake
Reservoir/man-made lake
Other
Subcontractor

Overall quantity of fresh water

This value used for water scoring in this section

3 Water usage. What is the total quantity entering the site annually (m3)?
Quantity
m3
A Fresh water (q2 total)
B Recycled after treatment in CETP
C Recycled after treatment in METP
D Reused (without pre-treatment) following use in another industrial facility
E Run-off (collected from gutters, roofing etc)
Overall quantity
This value used for water usage/discharge verification in the effluent section

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 4 Is incoming water volume determined through the effective measurement of all incoming
📷 sources?
score attained
A Measurement of EACH water supply 0
B Incomplete metering or measurement of incoming fresh water -40

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q4

5 Has Water usage data has been presented for the previous 24 months
Score attained
A Yes 0
B No per month of missing data -10

Due to the different water requirements associated with processing different types of raw material the mass of raw
material processed or area of leather produced must be converted into “bovine equivalents” in accordance with the
following table.

Table 11 Bovine equivalents

BOVINE EQUIVALENTS
Splits & Bovine
Cow Sheep Goat
Pigs Equivalents
Mass of hide or skin
Category A 0 0 0 0 0 kg
processed
Area of leather
Category A 0 0 0 0 0 m2
produced
Area of leather 2
Category B 0 0 0 0 0 m
produced
Area of leather
Category C 0 0 0 0 0 m2
produced
Area of leather 2
Category D 0 0 0 0 0 m
produced
Area of leather
Category E 0 0 0 0 0 m2
produced
Area of leather
Category F 0 0 0 0 0 m2
produced

Note: Sheep and goat skins scores are to be calculated based on 1.008 bovine equivalents. This figure is based
on data gathered during the audits undertaken whilst version 6.6 and variants of the protocol was effective.
Pigskins and splits are to be scored based on 1.000 bovine equivalents.

Companies undertaking an audit can request an editable copy of the above table from
[email protected]

The water requirements for processing from raw to tanned are 1.829 that of processing from raw to limed

• If processing from raw to limed multiply weight by 0.547 and treat as “A” category.
• If processing from limed to tanned multiply weight by 0.453 and treat as “A” category.

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 • If processing from limed to crust or finished leather multiply final by 0.453 and treat as “A” category.
Thereafter use final area for D or F category operations as applicable

The water requirements for processing from raw to tanned are 1.270 that of processing from raw to pickled
• If processing from raw to pickled multiply weight by 0.787 and treat as “A” category.
• If processing from pickled to tanned multiply weight by 0.213 and treat as “A” category.
• If processing from pickle to crust or finished leather multiply final by 0.213 and treat as “A” category.
Thereafter use final area for D or F category operations as applicable

6 Water Usage
Water usage includes ALL aspects of site operations such as administration, engineering, operation
of the waste water treatment plant, etc (excluding dormitories provided actual values can be shown)

Total Fresh Water (m3) 0

Quantity of leather m2 ratio

A Raw to Wet Blue 0 #DIV/0! 0 2.31
B Raw to Crust 0 #DIV/0! 0 4.29
C Raw to Finished 0 #DIV/0! 0 4.71
D Wet Blue to Finished 0 #DIV/0! 0 2.13
E Crust to Finished 0 #DIV/0! 0 0.17
F Wet Blue to Crust 0 #DIV/0! 0 1.00
#DIV/0!
Total 0 Aggregate Score

E factor 0 Max 100.0

Min 0

Companies undertaking an audit can request an editable copy of the above table from
[email protected]

6b What is the current level of water consumption in this facility?

Expressed in m3tonne-1 of substrate processed the calculation should be based on fresh water
only
In the event that demonstrable, quantifiable changes have been introduced that provide evidence
supported by at least 6 months data of on-going long-term water savings the value based on those 6
months will be used.
Water consumption includes ALL aspects of site operations such as administration, engineering, space cooling
(excluding dormitories etc.)
SCORE
m3tonne-1
A Raw hide to tanned (recorded usage -56.24)
-0.52
max 100

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 6c What is the current level of water consumption in this facility?
Expressed in ltr/m2 of leather produced. The calculation should be based on fresh water only.
In the event that demonstrable, quantifiable changes have been introduced that provide evidence
supported by at least 6 months data of on-going long-term water savings the value based on those 6
months will be used.
Water consumption includes ALL aspects of site operations such as administration, engineering, space cooling
(excluding dormitories etc.)
SCORE
ltr/m2
A Raw hide to tanned (recorded usage – 356.4)
-3.24

B Raw hide to crust (recorded usage – 660)

-6

C Raw hide to finished (recorded usage – 726)

leather -6.6

D Tanned hide to (recorded usage – 327.8)

finished leather -2.98

E Crust hide to finished (recorded usage – 26.4)

leather -0.24

F Tanned hide to crust (recorded usage – 154)

leather -1.4

Score Average score if more than one production type (based max 100
on proportions of area produced)

The following tables are included for illustrative purposes

(m3 per tonne) Water consumption

A
Points Raw to tanned
0 56
5 54
10 51
15 48
20 46
25 43
30 41
35 38
40 35
45 33
50 30
55 28
60 25
65 22
70 20
75 17
80 15
85 12
90 9
95 7
100 4

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 (ltr/m2)
Water consumption
A B C D E F
Raw to Raw to crust Raw to Tanned to Crust to Tanned to
Points
tanned finished finished finished crust
0 356 660 726 327.8 26.4 154
5 340 630 693 312.9 25.2 147
10 324 600 660 298 24 140
15 308 570 627 283.1 22.8 133
20 292 540 594 268.2 21.6 126
25 275 510 561 253.3 20.4 119
30 259 480 528 238.4 19.2 112
35 243 450 495 223.5 18 105
40 227 420 462 208.6 16.8 98
45 211 390 429 193.7 15.6 91
50 194 360 396 178.8 14.4 84
55 178 330 363 163.9 13.2 77
60 162 300 330 149 12 70
65 146 270 297 134.1 10.8 63
70 130 240 264 119.2 9.6 56
75 113 210 231 104.3 8.4 49
80 97 180 198 89.4 7.2 42
85 81 150 165 74.5 6 35
90 65 120 132 59.6 4.8 28
95 49 90 99 44.7 3.6 21
100 32 60 66 29.8 2.4 14

7 Are any active boreholes or wells located on-site?

number
A Yes
B No

8 Has the processing scope of the tannery changed since the last assessment?
A Yes
B No

Water Usage
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
4T 0 0 0
6 100 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q4

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12 AIR & NOISE EMISSIONS
This section assesses the management of a facility’s air and noise emissions to the
environment and requires inventories, management and monitoring

1 Has an air emission inventory been completed?

The inventory will detail all points of forced emissions to air i.e., boiler stacks, spray machines, fume
cupboards etc.
Cumulative score attained
A All emissions points have been listed or represented on a diagram or a
4
site plan
B The type of material emitted from EACH type of emissions source has
4
been identified
C The amount of material from EACH type of emissions source has been
4
measured and subsequently calculated
D An air emission inventory has not been created (Go to Q4) -40
TOTAL (Max 12)

Threshold question
For award of medal rating in this section a minimum score of 8 points must be attained in q1

2 Identify the plant emissions sources requiring a device that is designed to limit the quantity of
emission. Identify the type of limiting/restricting device for each applicable source and the
pollutant that the device is designed to restrict. The measured quantities of pollutant emitted
are to be specifically referenced in question 12.
Emissions source Number of Emissions control device Pollutant that device is Number of
requiring control device emissions designed to restrict functioning
e.g., spray m/c sources e.g. water wash control
e.g., VOC devices

3 Identify the total number of other plant emissions sources not requiring an emissions
limiting/restricting device

Note - If the auditor considers an emissions source as requiring an emissions

limiting/restricting device or if no adequate explanation is given as to why it does not require
one it WILL be entered in Q2

Emissions source without Number of State why control device is not required
control device emissions
sources

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 4 Indicate percentage of air emissions control devices that are functioning
Spray machines, boilers, buffing machines etc. % of machines score per
fitted with %
appropriate
control device
A Functioning 20
B Not functioning or not fitted -20
Total (Max 20)

Threshold question
For award of Gold medal rating in this section a minimum score of 20 points must be attained in q4

5 Is there a preventative maintenance programme for the emissions control devices employed?
score attained
A Yes, and the maintenance department can demonstrate that the
5
maintenance schedule conforms to recommendations
B Yes, although the maintenance department cannot demonstrate that the
2
maintenance schedule conforms to recommendations
C No 0

6 Are any wastes or by-products incinerated either on or off-site?

(incineration is not uncontrolled burning, it is a process subject to specified parameters, for
example as defined in DIRECTIVE 2000/76/EC OF THE EUROPEAN PARLIAMENT)
score attained
A None 9
B Incineration in a regulated co-generation plant 9
C Incineration controlled by external authority 7
D On-site incineration with regular (at least monthly) emission’s monitoring 0
E On-site incineration with annual emission’s assessment -9
F On-site or off-site, non-regulated and/or with no evidence of monitoring
FAIL
or assessment less than annually
If co-generation insert evidence here.

Registration details of Incinerator should be included with those of other disposal agents in the “Wastes”
section of this protocol

7 Is emissions monitoring or control required to comply with a permit condition?

A Yes
B No

8 How frequently has monitoring of boiler stack emissions been performed in the last 24 months
and is it undertaken on a routine basis?
Evidence will be required to demonstrate frequency
Cumulative score attained
A Third party analysis of relevant emissions as specified by permit or
10
legislation is undertaken at least monthly
Third party analysis of relevant emissions as specified by permit or
5
legislation is undertaken at least twice a year
B Evidence has been presented to indicate that emissions are non-
existent/do not warrant or do not require monitoring 5
e.g., Heat energy is supplied by gas boiler/direct steam supply
C Third party analysis of relevant emissions as specified by permit or
2
legislation is undertaken at least annually
D Not undertaken
-5
TOTAL (Max 10)

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 9 How frequently has monitoring of other stack emissions been performed in the last 24 months
and is it undertaken on a routine basis?
Evidence will be required to demonstrate frequency

In the specific case of VOC, and only if there are no applicable limits, LWG will accept absence of
monitoring only if it can be demonstrated that VOC emissions could not possibly be more than 35 g/m2
of leather (the solvents inventory records total issues fall below 35 g/m2 of leather)

Cumulative score attained

A Evidence has been presented to indicate that emissions identified in Q2

are within permit and legislative limits AND third party verification of
5
relevant emissions and emissions points identified in Q2 is undertaken at
least annually (or more frequently if permit/legislation dictates)
B Evidence has been presented to indicate that emissions identified in Q2
are within permit and legislative limits AND in-house analysis of relevant
2
emissions and emissions points identified in Q2 is undertaken at least
annually (or more frequently if permit/legislation dictates)
D Not undertaken -5
TOTAL (Max 5)

10 Is monitoring or assessment of ammonia is undertaken

Cumulative score attained
A Near the release points close to workers (monthly) 6
B Near the release points close to workers (annually) 2
C Outside the building (monthly) 3
D Outside the building (annually) 1
E Not undertaken 0
TOTAL (Max 9)

11 State the name of the organisation(s) undertaking monitoring

12 Summary of air emissions generated by the facility

Pollutant Regulatory Limit (if Annual Average Comments
applicable) Emission (N mg/m3)
Boilers
Particulates
NOx
SO2

Spray Machines
Particulates
VOC

Other sources
Sulphides
Ammonia

Cross-reference emissions test results with discharge permits

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 13 Describe the presence of detectable odours
Within buildings

Outside buildings, but within site property limits

At the site boundary

14 Are there any other obvious potential sources of air pollution from neighbouring sites?

A Yes
B No

15 If Yes, give details of distance, location, pollutants

16 Does the company calculate the total amount of solvent used in finishing?
Solvents include pure solvents as well as solvents forming a constituent of finishing chemicals.

Score one option only score attained

A The company has provided evidence that less than 10g/m2 of solvent is
10
used as part of processing
B Monthly data is available for the TOTAL amount of solvent used
10
including solvents forming a constituent of finishing chemicals
C Annual data is available for the TOTAL amount of solvent used
6
including solvents forming a constituent of finishing chemicals
D Monthly data is only available for the amount of pure solvent used (the
solvent component of liquid dyes, lacquers, toners etc. has not been 5
included)
E Annual data is only available for the amount of pure solvent used (the
3
solvent component of liquid dyes, lacquers etc. has not been included)
F No -5

17 What are the VOC emissions from each of the commissioned subcontractors?
Expressed in term of grams of solvent emitted to the environment per square metre of finished
leather produced
Subcontractor Operations Area m2 g/m2 Total g

TOTAL

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 18 What are the VOC emissions (as expressed in term of grams of solvent emitted to the
environment per square metre of finished leather produced)?

This question can only be answered if response is “A”, “B”, or “C” in Q16 or if full emissions
testing that allows calculation of mass of VOC emitted has been undertaken.

If responses D, E or F are recorded in Q16 or if full emissions’ testing has not been undertaken
it is not possible to calculate actual emissions and response “B” in this question will be
recorded.

This should include VOC emitted by subcontractors

g/m2 score attained
Score = g/m2 -50
10
A -5
Incomplete or non-existent inventory
B -10
(assumed to be greater than 75 g/m2, maximum audit rating “Audited”)

Threshold question
For award of Gold in this section VOC emission (as recorded in Q 18) must be less than 45 gm-2
For award of Silver in this section VOC emission (as recorded in Q 18) must be less than 60 gm-2
For award of Bronze in this section VOC emission (as recorded in Q 18) must be less than 75 gm-2

Appendix V contains further information regarding VOC emissions calculations, in particular with respect to those
emissions which can be discounted because they do not enter the environment by virtue of being recovered or
destroyed. Companies undertaking an audit can request an editable copy of the tables that may be used for
calculation of the above value from their auditor.

19 What are the VOC emissions associated with solvent degreasing?

Emiisions include fugitive emissions so response this questions must be based on usage unless
evidence is provided for the mass of solvent captured and recycled/destroyed

Score one option only score attained

A The company does not undertake solvent degreasing operations 0
B Solvent usage/emissions are less than 20g/kg of product degreased (dry
0
weight basis)
C Solvent usage/emissions are greater than 20g/kg of product degreased
-10
(dry weight basis)

20 Sound level values outside the building are measured and controlled
score attained
A At least three times per year (they should have been taken at several
10
periods of the day and in several locations)
B At least twice per year (they should have been taken at several periods
8
of the day and in several locations)
C At least once per year (they should have been taken at several periods
6
of the day and in several locations)
D The tannery is located such that external noise level measurements are
10
not applicable or appropriate
E Testing has been undertaken but in only one location OR at only one
0
period of the day
F Testing has not been undertaken within the past 12 months -10

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 Air & Noise Emissions
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
1T 12 0 0
4T 20 0 0
5 5 0 0
6 9 0 0
8 10 0 0
9 5 0 0
10 9 0 0
16 10 0 0
18 T 10 0 0
19 0 0 0
20 10 0 0
MAX 100
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold question
For award of medal rating in this section a minimum score of 8 points must be attained in q1
For award of Gold medal rating in this section a minimum score of 20 points must be attained in q4

Threshold condition
For award of Gold in this section VOC emission (as recorded in Q 18) must be less than 45 gm-2
For award of Silver in this section VOC emission (as recorded in Q 18) must be less than 60 gm-2
For award of Bronze in this section VOC emission (as recorded in Q 18) must be less than 75 gm-2

72
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13 WASTE MANAGEMENT
This section assesses a facility’s management and control of the wastes generated by the site and
requires inventories, categorisation of wastes and appropriate storage and disposal.

1 Does the facility have a formal waste management procedure?

Cumulative score attained
There are clear written guidelines regarding the identification, collection,
A 2
storage, and disposal of hazardous and non-hazardous wastes
The individuals (names or positions) within the tannery for management
B of hazardous and non-hazardous wastes are defined within a written 2
procedure
C There is no formal waste management procedure -2
TOTAL (Max 4)

Threshold question
For award of medal rating in this section a minimum score of 2 points must be attained in q1

2 Does the waste management procedure refer to local regulatory standards for waste
management?
score attained
A The procedures (the waste management plan) refer to all applicable
national, regional, and local laws in addition to any other applicable 2
regulations
B The procedures (the waste management plan) do not refer to any
-2
applicable legislation/regulation

Threshold question
For award of medal rating in this section a minimum score of 2 point must be attained in q2

3 Does the waste management procedure comply with regulatory standards for waste
management?
score attained
Evidence has been presented that indicates compliance, for example

• the waste management procedures have been made known to

the authorities
• there are currently no regulatory or other enforcement actions
in place against the company in relation to waste management
A 0
practices
• The authorities have visited the site – no corrective actions in
relation to waste were required

If response “B” recorded in Q2 indicate the evidence for response A in

this question
The procedures (the waste management plan) fail to comply with one or
B FAIL
more legal or regulatory standards for waste management

4 What regulatory authorities are involved in waste management issues at the facility?

5 Have the authorities inspected the site within the past 24 months to ensure compliance with
regulations?
A Yes
Date of most recent inspection
B No

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 6 Was the facility found to be in compliance with permit and legal requirements during the last
inspection?
score attained
A Yes 1
B The authorities have not visited within the past 24 months 1
C The facility was not found to be in compliance - corrective actions were
required and have been completed or are on-going in accordance with -10
the regulator’s schedule
List the corrective actions required

7 Does the company maintain a register of the type and quantity of hazardous, non-hazardous
waste, by-product and part-product disposed of or sold?
score attained
A Yes 0
B No -10

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q7

The primary product of a tannery is leather. Tanners do not produce shavings, buffing dust, trimmings etc. These
are wastes that are generated by the process. Even if these products are generated and sold they are still
considered first and foremost as wastes. Drop splits can be used to make leather so fall outside of this definition.
For example – trimmings that are converted to gelatin are classified as wastes by the EU (and by extension by this
protocol), even if sold. This is indicated by the definition of recycling from the EU definitions

‘recycling’ means any recovery operation by which waste materials (e.g. trimmings) are reprocessed into
products (e.g. gelatine), materials or substances whether for the original or other purposes. It
includes the reprocessing of organic material but does not include energy recovery and the
reprocessing into materials that are to be used as fuels or for backfilling operations;

Completion of the following table (available as an editable table from an LWG auditor or
[email protected]) would be one example of a suitable response to question 7. It may be necessary
to modify the waste types in accordance with the types of waste generated and/or the wastes classifications used
by the authorities.

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 General summary of hazardous and non-hazardous waste & part-product disposed

5
Waste Classification
Disposal Arrangements
Mass reused, recyclyed, recovered, sent to refuse

Hazardous Non-Hazardous Kind of

reuse recovery reuse recovery disposal
Type of waste or byproduct recycle refuse recycle refuse Disposal
(retains (heat, (retains (heat, (gelatine, Carrier
(solids) (into other (landfilled, (into other (landfilled, agent
same nutrient same nutrient compost
product) destroyed) product) destroyed)
function) etc) function) etc) etc.)
Pallets 0
Metal containers
Plastic containers
Plastic
Raw hide fleshings
Raw hide trimmings
Limed hide fleshings
Limed hide splits & trimmings
Hair
Tanned trimming waste
Tanned shaving waste
Tanned split waste
Finished leather wastes
Buffing dust
Finishing wastes
Pigment, resins, dyes, chemicals
Activated carbon
WWTP sludge (contains chromium)
WWTP sludge (chromium free)
Chrome precipitation sludge
Chemical contaminated packaging.
Batteries/ lights/ ink cartridges
Card & Paper
Employee & General waste
Food waste
Type of waste or byproduct
(liquids)
Waste Oil
Waste Solvent
Total kg of Solids (per category) 0 0 0 0 0 0 0 0
Total kg solids 0 0
Hazardous Non-Hazardous
Percenatge reused/recycled/recovered #DIV/0! #DIV/0!
Total kg of Liquids (per category) 0 0 0 0 0 0 0 0
Total kg liquids 0 0
Hazardous Non-Hazardous
Percenatge reused/recycled/recovered #DIV/0! #DIV/0!

8 The identity of carriers and disposal agents associated with wastes that are not recycled
must be listed below to indicate that those wastes are removed from the site and disposed of
in a suitable and legal manner.

Recyclable wastes that are sold may be considered to have been legally removed from site
and used appropriately due to their having commercial value. Details do not need to be listed
here.

The details of agents removing and receiving recyclable wastes that are NOT sold must be
included here as evidence of legal removal from site
Disposal agent or carrier Company registration number Permit Permit
number expiry

A
B
C
D
E
F

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 9 Has a legal disposal route been identified for each of the wastes that are subject to final
disposal and for each of the materials that are recyclable as by-product, but which are not
sold?

score attained
A Yes 0
B No, for one or more of the waste streams identified in the wastes register
FAIL
there is no evidence of permitted disposal
C No. for one or more of the agents identified in Q8 there is either no permit
FAIL
or the permit validity has expired

10 Does the facility maintain records for collection and disposal of hazardous wastes (manifests,
collection receipts etc.)?
(All necessary statutory waste consignment documents have been completed)
score attained
A None of the wastes generated require disposal manifests as part of the
6
disposal process
B Yes, they are up-to-date and have been maintained for the past 24
6
months
C They are incomplete or have not been maintained for the periods
FAIL
identified above

11 Does the facility maintain records for collection and disposal of non-hazardous wastes
(manifests, collection receipts etc.)?
(All necessary statutory waste consignment documents have been completed)
score attained
A None of the wastes generated require disposal manifests as part of the
6
disposal process
B Yes, they are up-to-date and have been maintained for the past 24
6
months
C They are incomplete or have not been maintained for the periods
-6
identified above

12 Prior to processing, excess physical salt removal is

Cumulative score per attained
%
A By desalting machine 0
B By shaking the hide/skins 0
C By brushing off the excess 0
D Not performed -5
TOTAL (Max 0)

13 What is the destination of excess salt recovered from salted or brined hides prior to
processing?

score attained
A Recovered excess salt is re-used 4
B There is no recovery of excess salt – hides are processed as received 0
C Recovered excess salt is deposited in landfill.
0
Enter permit details below
Recovered excess salt is held in secure storage (maximum 3 years) prior
to deposition in secure landfill 0
Enter permit details below
D Recovered excess salt is stored (intention is to deposit in landfill but no
-4
legal landfill sites currently being used)
E Uncontrolled disposal FAIL

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 Operating Permit applicable to landfill site
Permit Number
Issuing Authority
Date Permit Expires
Conditions

There are multiple options for questions 14 to 23b and not all can be listed here. Scoring should be based on the
waste hierarchy with a justification of the score applied if the waste treatment method does not correspond
exactly with the examples in the questions.

• Recycle – material that cannot be reused into other products

• Recover – raw material (i.e. heat energy for example from oils or solvents that cannot be recycled)
• Refuse – any material that can only be disposed of (provided disposal is safe and legal)

Where the activities of the tannery fall between two or more possible options the auditor is required to assign a
score (or partial score) that appropriately reflects the evidence presented and include a justification for the score
awarded.

14 What is the destination of fleshings (raw and/or limed)?

score attained
A Recycle - Rendered (onsite) 4
B Recycle - Rendered (offsite) 4
C Recovery - Composting 2
D Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

15 What is the destination of trimmings (raw and/or limed)

score attained
A Recycle - Gelatine production 4
B Recycle - Rendered 4
C Recovery – give details 2
D Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

16 What is the destination of limed splits

score attained
A Recycle - Used for leathermaking (internally or sold) 4
B Recycle - Used in manufactured product (e.g. dog toys, gelatine) 4
C Recycle - Rendered 4
D Recovery – give details 2
E Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

17 What is the destination of recovered hair

score attained
A Recycle - Used (i.e. as product input, fertiliser component etc.) 4
B Recovery - 2
C Filtered out but not used (e.g. landfilled) 1
D Not filtered out (hair burn process) 0

18 What is the destination of tanned (e.g. wet blue) flesh splits

score attained
A Recycle - Used for leathermaking (internally or sold) 5
B Recycle - Used in manufactured product (e.g. leather board) 5
C Recovery - 2
D Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

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 19 What is the destination of tanned (e.g. wet blue) shavings
score attained
A Recycle - Used in manufactured product (e.g. leather board) 4
B Recovery – give details 2
C Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

20 What is the destination of tanned (e.g. wet blue) trimmings

score attained
A Recycle - Used in manufactured product (e.g. leather board) 4
B Recovery – give details 2
C Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

21 What is the destination of dry (crust and/or finished) trimmings

score attained
A Recycle - Used in manufactured product (e.g. small leather goods) 4
B Recovery – give details 2
C Disposed of (e.g. landfilled or incinerated by a licensed operator) 0

22 What is the destination of dust generated by the buffing operation

score attained
A Recycle - Compacted then used in manufactured product (e.g. leather
4
board)
B Recycle - Manually collected then used in manufactured product 3
C Recovery – give details 2
D Compacted then disposed of (e.g. landfilled or incinerated by a licensed
0
operator)
Manually collected then disposed of (e.g. landfilled or incinerated by a
E -2
licensed operator)

23 What is the destination of oil and solvent based wastes (including those generated by the
maintenance department)
score attained
Recovery and/or reuse
A 4
(this “waste” stream is considered to be a by-product)
B Disposed of (e.g. incinerated by a licensed operator) 0

24 What is the destination of ETP sludge (only applies to those generated by tannery own ETP)
score attained
A Fertirrigation (chrome free sludge only) 5
B Co-processing – residues used 4
C Incineration – residues used 3
D Co-processing – residues landfilled 2
E Incineration - residues landfilled 1
F Direct landfill 0

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 25 If wastes are used as a fuel source on-site which of the following gaseous are monitored
annually?
Wastes include both those generated by the tannery and/or any other organisation
Cumulative score attained
A No wastes are used as fuels on-site N/A
B Particulates 2
C NOx 2
D SO2 2
E Heavy metals 3
F Dioxins 3
The waste is biomass that has not been contaminated with chemicals
G and the tannery has provided evidence that the emissions of heavy 12
metals, dioxins, furans etc. would be unlikely
H No evidence of monitoring has been presented in the past 12 months -10
I No evidence of monitoring has been presented in the past 24 months -20
TOTAL (max 12)

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q25

26 If wastes are used as a fuel source on-site which of the following possible contaminants of
residues (ash etc.) are monitored annually?
Cumulative score attained
A Chromium VI 1
B Lead 1
C Mercury 1
D Antimony 1
E Arsenic 1
F Selenium 1
G Barium 1
H Cadmium 1
I No wastes are used as fuels on-site N/A
The waste is biomass that has not been contaminated with chemicals
J and the tannery has provided evidence that none of the heavy metals 6
(lines A to H) would be present.
The waste is classed as hazardous and disposed of as hazardous
K 6
waste to a licensed operator
L Residues have not been analysed within the past 12 months -10
M Residues have not been analysed within the past 24 months -20
TOTAL (max 6)

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q26

27 Is the amount of by-product (destined for recovery or reuse) monitored to ensure that
operations are controlled?
score attained
At least two major by-product streams generated per unit of leather
produced are regularly calculated (at least monthly). Procedures have
A 6
been developed determine whether or not the amount conforms to
expected levels
The amount of by-product generated per unit of leather produced is
B 2
regularly calculated (at least monthly)
C There is no monitoring of the amount of waste per unit 0

The auditor should assess that any schemes referred to are actively being progressed for scores to be
awarded

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 28 Is the amount of waste (destined for final disposal) monitored to ensure that excessive
quantities are not generated?
score attained
At least two major waste streams generated per unit of leather produced
are regularly calculated (at least monthly). Procedures have been
A 6
developed that are to be implemented if the waste generated exceeds
specified levels
The amount of waste generated per unit of leather produced is regularly
B 2
calculated (at least monthly)
C There is no monitoring of the amount of waste per unit 0

The auditor should assess that any schemes referred to are actively being progressed for scores to be
awarded

29 Describe on-site storage arrangements for empty chemical containers (formerly containing
📷 hazardous chemicals) awaiting removal from site
Cumulative score attained
A Correctly marked, adequately segregated locations 2
B Hard standing, impervious base (e.g. concrete) 2
Spillage/leachate containment (if empty vessel washing is undertaken
C 2
by agency removing containers from the site)
No spillage/leachate containment (empty vessel washing is undertaken
D 2
by tannery prior to transfer to storage area)
H No formal segregation of stored materials is evident -2
I Storage is such that ground/soil contamination could occur FAIL
TOTAL (Max 8)

30 Describe on-site storage arrangements for empty chemical containers (formerly containing
📷 non-hazardous chemicals) awaiting removal from site
Cumulative score attained
A Correctly marked, adequately segregated locations 2
B Hard standing, impervious base (e.g. concrete) 2
Spillage/leachate containment (if empty vessel washing is undertaken
C 2
by agency removing containers from the site)
No spillage/leachate containment (empty vessel washing is undertaken
D 2
by tannery prior to transfer to storage area)
H No formal segregation of stored materials is evident -2
I Storage is such that ground/soil contamination could occur FAIL
TOTAL (Max 8)

31 Describe on-site storage arrangements for hazardous waste

📷
Cumulative score attained
A Correctly marked, adequately segregated locations 3
B Unmarked, but adequately segregated locations. 1
C Hard standing, impervious base (e.g. concrete) 2
D Spillage/leachate containment 2
E Covered storage (e.g. roofed) 2
F Sealed containers 2
G Secure (restricted access) area 2
H No formal segregation of stored materials is evident -2
I Storage is such that ground/soil contamination could occur FAIL
TOTAL (Max 13)

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 32 Describe on-site storage arrangements for non-hazardous waste
📷
Cumulative score attained
A Correctly marked, adequately segregated locations. 2
B Unmarked, adequately segregated locations 1
C Hard standing, impervious base (e.g. concrete) 2
D Spillage/leachate containment 2
E Covered storage (e.g. roofed) 2
F Sealed containers 2
G Secure (restricted access) area 2
H No formal segregation of stored materials is evident -2
I Storage is such that ground/soil contamination could occur FAIL
TOTAL (Max 12)

33 Describe all on-site waste disposal methods. This includes off-site if owned and managed by
📷 the organisation being audited.

Include permit details (if not already recorded in section 2)

34 Empty barrels/containers from incoming hazardous chemicals and empty barrels, containers,
pallets etc. that have been rendered hazardous due to contamination are
score attained
A Ultimately returned to supplier/recycled by a licensed agent 6
B Disposed of in an approved manner by a licensed operator 2
No evidence has been presented to indicate that they are legally
C FAIL
disposed of

35 Empty barrels/containers from incoming non-hazardous chemicals are

score attained
A Ultimately returned to supplier/Recycled by a licensed agent 2
B Disposed of in an approved manner by a licensed operator 1
No evidence has been presented to indicate that they are legally
C FAIL
disposed of

36 Are there cleaning procedures employed for non-hazardous chemical containers?

score attained
There is a written work instruction that describes how, after checking for
A complete emptiness, they are washed out and the wash-water goes to 2
the effluent system
B There is an informal procedure for washing out empty containers 0
C No evidence that wash water goes to effluent treatment system -2
D No cleaning process employed -2

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 Waste Management
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
1T 4 0 0
2T 2 0 0
3 0 0 0
6 1 0 0
7T 0 0 0
9 0 0 0
10 6 0 0
11 6 0 0
12 0 0 0
13 4 0 0
14 4 0 0
15 4 0 0
16 4 0 0
17 4 0 0
18 5 0 0
19 4 0 0
20 4 0 0
21 4 0 0
22 4 0 0
23 4 0 0
24 5 0 0
25 T 12 0 0
26 T 6 0 0
27 6 0 0
28 6 0 0
29 8 0 0
30 8 0 0
31 13 0 0
32 12 0 0
34 6 0 0
35 2 0 0
36 2 0 0
MAX 150 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold questions
For award of medal rating in this section a minimum score of 2 points must be attained in q1
For award of medal rating in this section a minimum score of 2 point must be attained in q2
For award of medal rating in this section a minimum score of 0 points must be attained in q7
For award of medal rating in this section a minimum score of 0 points must be attained in q23
For award of medal rating in this section a minimum score of 0 points must be attained in q24

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14 EFFLUENT TREATMENT
This section assesses a facility’s management of their liquid wastes, either at their own site or at a third-
party provider. It requires legal discharge of the wastewater and rewards with higher scores those that
achieve target levels of water quality using a range of appropriate technologies.

1 Is outgoing water from the tannery determined through effective measurement?

Note - Acceptable effective measurement is by means of automatic metering, namely: Parshall
with ultrasound, in-line meter, tanker of known volume with supporting transfer records.

Internal use for non-production purposes (e.g. watering gardens, washing trucks etc.) must
also be measured.

score attained
A Yes, by measurement / metering of outgoing water
0
(data available for the full 24 consecutive months of the audit period
📷 under consideration)
There is no means of measurement and incoming water volume is less
B than 10 m3 per working day. Discharge is directly to a municipal 0
treatment facility
There is no means of measurement and incoming water volume is less
C than 3 m3 per working day. Discharge is to a common/central 0
treatment facility or to environment.
-5 x
There is incomplete measurement / metering of outgoing water
months
D (data available for less than the full 24 consecutive months of the audit
without
period under consideration)
data
E No measurement / metering of outgoing water FAIL

2 What proportion of incoming water is discharged as effluent?

m3
A Incoming water volume
B Outgoing water volume
Proportion of incoming water that is discharged as effluent %
If outgoing water is less than 85% of incoming water an explanation (with evidence)
must be provided here

3 Which of the following types and/or sources of wastewaters are discharged from the facility?
tick
A Process wastewater
(water associated with leathermaking, including cleaning of floors and equipment)
C Sanitary wastewater
(domestic wastewater from food preparation areas, bathrooms, showers etc.)
D Surface water
(storm water runoff)

4 Do separate site drainage systems exist for the following?

Cumulative score attained
A Surface water runoff 3
B Foul/sanitary effluent 3
C Process effluent 4
D No -10
TOTAL (max 10)

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 5 The treatment of process liquors is
How are tannery process waste waters treated?

Note – the period of compliance covers the 24-month period of the audit under consideration
(see S3q1) as well as the follow-on period leading up to and including the date of the audit.
Cumulative score attained
Within the tannery’s own waste-water treatment plant and in compliance
A with regulatory limits for discharge and other permit or legislative 10
requirements (internal WWTP)
Within an external common effluent treatment plant (CETP) and in
compliance with regulatory limits for discharge and other permit or
legislative requirements

This response must be supported by 24 consecutive sets of monthly

analysis covering the current audit period. The analysis must have been
B 10
undertaken in an ISO 17025 certified laboratory or laboratory specified
by the authority to whom the CETP reports. Recording (in this protocol
document) of all possible permit/legislative discharge parameters is not
required however those parameters that are jointly specified by permit
legislation and marked with an asterisk in q8 are required for this
question.
Within an external municipal effluent treatment plant (METP) and in
C compliance with regulatory limits for discharge and other permit or 10
legislative requirements
Within an external common effluent treatment plant (CETP)
Only 8-23 data sets presented within the audit period and/or not
D -60
undertaken in ISO 17025 certified laboratory or laboratory specified by
the authority to whom the CETP reports.
Either Not undertaken (Internal WWTP, CETP, METP),
Or Less than 8 data sets presented (CETP)
E FAIL
Or Not in compliance with regulatory limits for discharge and/or
other permit or legislative requirements (Internal WWTP, CETP, METP),
TOTAL (max 10)

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 6 General Operating Permit of CETP/METP

Name
Address

Permit Number
Issuing Authority
Date Permit Expires
Geo-reference of WWTP
Destination of Discharge
Permit Limit Recorded Value (average)
Details Volume per hour
Volume per day
Volume per week
Volume per month
Volume per year
Effluent Limits Chemical Oxygen Demand
Biological Oxygen Demand
Total Kjeldahl Nitrogen
Total Nitrogen
Ammonia Nitrogen
Total Chromium
Chromium VI
Suspended Solids
Oil & Grease
Sulphides
Chlorides
Synthetic Detergent Limit
Copper
Cyanide
Lead
Mercury
Nickel
Cadmium
Zinc
Sulphates
Phosphorous
pH range
Temperature limits
Prohibited Contaminants
If discharge is to a marine environment provide evidence of discharge in compliance with national legislative
requirements

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 7 Salt discharge (expressed as chloride)
What is the mass of chloride discharged to the environment by the tannery per unit of
production? This excludes legal discharge to controlled or approved receptors (i.e. landfill,
marine environment) and for which evidence of permitted disposal has been presented.
The calculation is based on an “allowance” being made for salt necessary for pickling (6%
on the weight basis of hides processed).
The tannery should provide data demonstrating that the salt in ALL applicable waste streams
discharged directly to the environment has been accounted for
score
(max 25, min
0)

points = total discharge -104.132

The mass of chloride
- 4.6153
discharged from the tannery
Category “A” tanners
Total discharge kg per tonne of hide processed
(all liquid and solid waste streams)

points = total discharge -679.43

- 27.1775
The mass of chloride
discharged from the tannery
Category “B & C” tanners
Total discharge grams per square metre of
leather produced
(all liquid and solid waste streams)

D, E, F category tanners all score 25 points

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7 Chloride discharge
US standards for cured hides indicate that the moisture content should be between 44% and 48% and that the
saturation of brine should be 85%. Average moisture assumed to be 46%

A saturated salt solution is 28% salt by weight (CRC Handbook of Chemistry and Physics, 63rd Edition 1982-
1983)
Mass of salted or brined hides/skins into process 10 tonnes
Mass of fresh hides/skins into process 0 tonnes
Total mass of hides/skins input to soaking 10 tonnes
Associated water (assuming 46% moisture content) 4600 litre
Associated salt (assuming 28% in a saturated solution) 1288 kg
Mass of hides/skins entering pickling/tanning stage 10 tonnes
Percentage salt offer for pickling (LWG allowance 6%) 6 %
Mass of salt added for pickling 600 kg
Excess/defecit over LWG "allowance" 0
Salt entering process 1888 kg
Salt entering process (less LWG "allowance") 1288 kg
Chloride as a percentage of salt 60.65 %
Potential chloride discharge 1145 kg
Potential chloride discharge (Less LWG "allowance") 781.2 kg
Chloride discharge / Tonne (Cat A) 188.8 kg
Chloride discharge / Tonne (Cat A) (less LWG allowance) 78.1 kg
Total effluent discharge 1000 cubic metres
Total area of hides leather produced (starting from raw/salted/brined) 1533 m2
Total area of skins leather produced (starting from raw/salted/brined) 0 m2
Total area of hides leather produced (starting from part-processed) 1533 m2
Total area of skins leather produced (starting from part-processed) 0 m2
Total area produced 3066
Total area produced (allowing for "bovine equivalents") 3066
Chloride discharge / m2 (Cat B or C) 373.47 g/m2
Chloride discharge / m2 (Cat B or C) (Less LWG "allowance") 254.79 g/m2
Theoretical chloride concentration of discharged effluent 1.15 g/litre

Score (if calculated on basis of weight into work) 6.25

Score (if calculated on basis of area produced) 15.62

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 8 By what means do treated wastewaters enter the environment?
tick
They are used for irrigation
A
(Go to Q 23)
B They are discharged to a river or other inland water course
C They are discharged to coastal or tidal waters
Evaporation
D
(Go to Q11)

9 What is the destination of the salt washed out of salt-preserved hides?

Cumulative score per attained
(scoring percentage refers to the percentage of input that is salt %
preserved)
Wastewaters containing the salt washed out of hides goes to a
A CETP/METP holding a valid permit and operating in compliance with
0
📷 permit and legislative requirements. A score of 10 points returned for q5.

Wastewaters containing the salt washed out of hides goes to an effluent

B treatment plant and from there, directly to a marine receptor.
0
📷 Cite legislation or provide governmental/municipal statement confirming
note 1
this as a legal turbulent flow marine disposal route
Wastewater containing the salt washed out of hides goes to an effluent
treatment plant and from there to an inland receptor in accordance with
discharge limits for chloride.
C 0
Chloride discharge limit
Chloride discharge (maximum)
Chloride discharge (average)
D Salt washed out of hides is ultimately recovered onsite (e.g., by reverse
osmosis). The reverse osmosis residues are stored onsite, no evidence -0.16
📷 of permitted storage available.
E There is no evidence of a legal disposal route Fail
TOTAL (Max 0)

Note 1 Brine is denser than sea water and discharge of brine or salt to non-turbulent areas can result in
creation of anoxic conditions at the sea floor and consequent impairment of marine habitat. Marine discharge
must be to an area of turbulent flow.

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 10 Summary of treated wastewater discharged to the environment (inland or marine receptors)
If treated wastewaters are evaporated go to Q11
If treated wastewaters are discharged to a marine environment go to Q11
If treated wastewaters are used for irrigation go to Q22
Analysis in an ISO17025 Regulatory Limit Annual Average Emission (mg/litre)
laboratory unless
otherwise specified by METP /Tannery WWTP
permit. 8 quarterly data points

CETP
24 monthly data points
Chemical Oxygen Demand*
Biological Oxygen Demand
Total Kjeldahl Nitrogen
Total Nitrogen
Ammonia (nitrogen)
Suspended Solids
Oil & Grease
Total Chromium
Chromium VI
Sulphides
Phosphorous
Phenol
*Chemical Oxygen Demand (must be dichromate method)

11 How frequently does the tanner/ETP operator monitor the wastewater discharge quality?
This question refers to
• the quality of the effluent discharged from the tannery ETP (for those tanners who operate their
own plant)
• the quality of the effluent discharged from the common ETP (for those tanners who discharge
into a jointly operated plant)
• the quality of the effluent discharged from the municipal ETP (for those tanners who have no
direct control over their own effluent treatment)
Any two or more parameters from box 10 score attained
At least TWO parameters must be recorded in order to record a score.
Recording one parameter only results in no score. Two parameters at
different frequencies gains the lower score, NOT the average of the
two scores
A Daily 20
B At least three times per week 15
C Weekly 10
D Monthly 5
E Quarterly 0
F Only one parameter, regardless of frequency 0
G Less than quarterly FAIL
H All water is evaporated so testing is not applicable (Go to end) Note 1 105
All water is discharged to the marine environment. Evidence of
I discharge in accordance with National Legislative Requirements must 105
be demonstrated and evidence provided in q6. (Go to end)

Note1 If this option has been selected a sludge would have been generated. Ensure that it is properly
accounted for in the wastes section. If this option is selected energy would have been required for evaporation.
Ensure that it is properly accounted for in the energy section.

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 12 How frequent is 3rd party verification monitoring of the waste-water discharges (including
regulatory)?
For tanners operating their own ETP and for operators of common ETPs 3rd party verification
monitoring includes those samples sent to an ISO 17025 certified laboratory or laboratory specified
by the authority to whom the tannery/CETP reports. or monitoring undertaken by a governmental
authority. Municipalities are to be considered competent for self-verification, i.e. their own internal
testing will be considered 3rd party verification monitoring for the purposes of this question.

It is not acceptable to claim that CETP monitoring or analysis is outside of the control of the tanner.
The CETP is treating the effluent on behalf of the tanner. For the avoidance of failure, a tannery
might consider arranging independent testing of CETP discharge.
score attained
A Monthly 20
B Quarterly 10
C Less than quarterly FAIL

Provided data exists, five out of questions 13 to 24 should be answered for scoring purposes. If tests are
required, either by permit or legislation, for Oxygen Demand, Suspended Solids, Nitrogen and Chromium
VI, this data must be used for scoring questions 13 to 24. Selection of alternative data is only permitted
when there is no permit or legislative requirement for analysis of the five specified tests.

Oxygen Demand either COD or BOD (choose one only)

Nitrogen either Total Kjeldahl, Total or Ammonia Nitrogen (choose one only)
Suspended Solids
Chromium either total Chromium or Chromium VI – choose one only

In those instances where a tannery has its own effluent treatment plant and would be capable of legal
discharge to the environment but is obliged to discharge to METP, CETP or effluent collector the quality
of the treated tannery waste waters may be used for scoring purposes.

13 COD
Annual Average Emission (mg/litre). Must be dichromate-based analysis
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 140 ppm >240 ppm 0
C 121 – 140 ppm 211 - 240 ppm 2
D 101 – 120 ppm 181 – 210 ppm 4
E 81 – 100 ppm 151 – 180 ppm 6
F 60 – 80 ppm 121 – 150 ppm 9
G < 60 ppm < 120 ppm 13

14 BOD
Annual Average Emission (mg/litre).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 60 ppm >90 ppm 0
C 46 – 60 ppm 71 - 90 ppm 2
D 31 – 45 ppm 51 – 70 ppm 4
E 16 – 30 ppm 31 – 50 ppm 6
F 10 – 15 ppm 15 – 30 ppm 9
G < 10 ppm < 15 ppm 13

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 15 Total Kjeldahl Nitrogen
Annual Average Emission (mg/litre).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B >40 ppm >80 ppm 0
C 31 - 40 ppm 61 - 80 ppm 2
D 21 – 30 ppm 41 – 60 ppm 4
E 11 – 20 ppm 21 – 40 ppm 6
F 6 – 10 ppm 11 – 20 ppm 9
G < 6 ppm < 10 ppm 13

16 Total Nitrogen
Annual Average Emission (mg/litre).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B >80 ppm >120 ppm 0
C 61 - 80 ppm 91 - 120 ppm 2
D 41 – 60 ppm 61 – 90 ppm 4
E 21 – 40 ppm 31 – 60 ppm 6
F 11 – 20 ppm 16 – 30 ppm 9
G < 10 ppm < 15 ppm 13

17 Ammonia Nitrogen
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 20 ppm >40 ppm 0
C 16 – 20 ppm 31 - 40 ppm 2
D 11 – 15 ppm 21 – 30 ppm 4
E 6 – 10 ppm 11 – 20 ppm 6
F 3 – 5 ppm 6 – 10 ppm 9
G < 3 ppm < 6 ppm 13

18 Suspended Solids
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 45 ppm >100 ppm 0
C 36 – 45 ppm 81 - 100 ppm 2
D 26 – 35 ppm 61 – 80 ppm 4
E 16 – 25 ppm 41 – 60 ppm 6
F 10 – 15 ppm 20 – 40 ppm 9
G < 10 ppm < 20 ppm 13

19 Total Chromium
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 1.0 ppm >1.5 ppm 0
C 0.71 – 1.0 ppm 1.01 – 1.5 ppm 2
D 0.41 - 0.7 ppm 0.61 – 1.0 ppm 4
E 0.11 – 0.4 ppm 0.21 – 0.6 ppm 6
F 0.05 – 0.10 ppm 0.1 – 0.2 ppm 9
G < 0.05 ppm < 0.1 ppm 13

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 20 Chromium VI
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 0.08 ppm > 0.1 ppm 0
C 0.051 – 0.08 ppm 0.08 – 0.1 ppm 2
D 0.011 - 0.05 ppm 0.06 – 0.08 ppm 4
E 0.006 – 0.01 ppm 0.04 – 0.06 ppm 6
F 0.003 – 0.005 ppm 0.02 – 0.04 ppm 9
G < 0.003 ppm < 0.02 ppm 13

21 Sulphide
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 2.5 ppm > 5.0 ppm 0
C 2.01 – 2.5 ppm 4.1 – 5.0 ppm 2
D 1.51 – 2.0 ppm 3.1 – 4.0 ppm 4
E 1.01 – 1.5 ppm 2.1 – 3.0 ppm 6
F 0.5 – 1.0 ppm 1.1 – 2.0 ppm 9
G < 0.5 ppm < 1.0 ppm 13

22 Oil & Grease

Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 20 ppm >40 ppm 0
C 16 – 20 ppm 31 - 40 ppm 2
D 11 – 15 ppm 21 – 30 ppm 4
E 6 – 10 ppm 11 – 20 ppm 6
F 3 – 5 ppm 6 – 10 ppm 9
G < 3 ppm < 6 ppm 13

23 Phosphorous
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 5.0 ppm > 10.0 ppm 0
C 4.1 – 5.0 ppm 5.1 – 10.0 ppm 2
D 3.1 – 4.0 ppm 6.1 – 8.0 ppm 4
E 2.1 – 3.0 ppm 4.1 – 6.0 ppm 6
F 1.1 – 2.0 ppm 2.1 – 4.0 ppm 9
G < 1.0 ppm < 2.0 ppm 13

24 Phenol
Annual Average Emission (ppm).
METP Tannery WWTP/CETP score attained
A Not measured Not measured 0
B > 1.25 ppm > 2.5 ppm 0
C 1.0– 1.25 ppm 2.01 – 2.5 ppm 2
D 0.75– 1.0 ppm 1.51 – 2.0 ppm 4
E 0.51 – 0.75 ppm 1.01 – 1.5 ppm 6
F 0.25 – 0.5 ppm 0.5 – 1.0 ppm 9
G < 0.25 ppm < 0.5 ppm 13

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The following questions (25 - 31) relate to wastewaters used for irrigation. Waste-water treatment plants
discharging to a water course should bypass these questions and proceed to question 29

25
Is irrigation subject to permit conditions?
score attained
Yes – the permit is issued in the name of the tannery
The permit details must be listed in Section 2
A 15
Operations/discharges should already have been checked - return to
Section 2 if this has been overlooked.
Yes – the permit is issued in the name of the organisation undertaking
treatment on behalf of the tannery (identified below) and evidence has
B 15
been presented that this organisation is irrigating in accordance with its
permit conditions
Yes – the permit is issued in the name of the organisation undertaking
treatment on behalf of the tannery (identified below) but no evidence
C FAIL
has been presented that this organisation is irrigating in accordance
with its permit conditions
No – there are no conditions applicable in the state/country where
D irrigation is occurring but the organisation adheres to the requirements 15
of a neighbouring state/country where standards are applicable
No permit is required but the tannery has presented evidence that it is
E 15
irrigating in accordance with all local/regional/national legislations
Name of organisation irrigating if not the tannery

………………………………………………………..

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 26 For which of the following properties are wastewaters analysed prior to discharge on to land
for the purposes of irrigation

Note; if the irrigator is a municipal authority, they will be deemed competent to undertake the
required analysis. Full marks should be awarded for this question if a declaration is obtained from
the authority that it is irrigating in accordance with its legislative and permit requirements.
Annual Average
Regulatory Limit
Pollutant Emission (mg/litre) Score attained
(if applicable)
At least 4 measures
A Total Chromium 4

B Chromium VI 3

C Chloride 3
TKN or other N
D 3
determination
Other State type
E 3
…………
Other State type
F 3
…………
Other State type
G 3
…………
Other State type
H 3
…………
Other State type
I 3
…………
Other State type
J 3
…………
Other State type
K 3
…………
Other State type
L 3
…………
Other State type
M 3
…………
TOTAL (max 40)

27 Has the data for Q26 above been obtained from an independent laboratory?
Score Attained
A Yes 0
B No -40

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q27

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 28 For which of the following properties are soils analysed following irrigation with tannery
wastewaters?

Note; if the irrigator is a municipal authority, they will be deemed competent to undertake the
required analysis. Full marks should be awarded for this question if a declaration is obtained from
the authority that it is irrigating in accordance with its legislative and permit requirements.
Pollutant Regulatory Limit (if Last recorded Score Attained
applicable) average
concentration
A Total Chromium 5

B Chromium VI 5

C Chloride 5
TKN or other N
D 5
determination
Other State type
E 4
…………
Other State type
F 4
…………
Other State type
G 4
…………
Other State type
H 4
…………
Other State type
I 4
…………
Other State type
J 3
…………
Other State type
K 3
…………
Other State type
L 2
…………
Other State type
M 2
…………
50
TOTAL (max 50)

29 Has the data in Q28 above been reviewed and approved as acceptable by an independent soil
analyst?
Score Attained
A Yes 0
B No -50

Threshold question
For award of medal rating in this section a minimum score of 0 points must be attained in q29

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 30 What types of primary treatment system are in place and observed to be functioning correctly?
Treatment may occur on-site or off-site (such as at a common effluent treatment plant)
List in the order that treatment occurs. Treatment could include, but is not Observed Observed
limited to: on-site off-site
Automatic/manually raked screen(s), Oxidation of sulphides Settlement, 📷 📷
Grease traps, Clarification by coagulation, Clarification by flocculation,
Dissolved Air Flotation system, etc.
A

31 Which of the following techniques are used to reduce the biological loading of the effluent?
Treatment may occur on-site or off-site (such as at a common effluent treatment plant)
List in the order that treatment occurs. Treatment could include, but is Observed Observed
not limited to: on-site off-site
Anaerobic treatment, Up flow anaerobic sludge blanket, Oxidation 📷 📷
ditch with activated sludge, Nitrification, De-nitrification, etc
A

32 Tertiary Treatment technology applied consists of (select main type only)

Treatment may occur on-site or off-site (such as at a common effluent treatment plant)
List in the order that treatment occurs. Treatment could include, but is not Observed Observed
limited to: on-site off-site
Final clarifier, Sand filter, Reed beds/controlled wetlands, Activated 📷 📷
carbon filter, Fenton system, Membrane filtration nanofiltration,
Membrane filtration ultrafiltration, Reverse osmosis
A

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 For award of Gold tanneries must be able to demonstrate measurement of emissions for any of the 5
discharge pollutants specified and achieve at least 52 points from in questions 13 to 24

For award of Silver tanneries must be able to demonstrate measurement of emissions for any of the 5
discharge pollutants specified and achieve at least 39 points from questions 13 to 24

For award of Bronze tanneries must be able to demonstrate measurement of emissions for any 5
discharge pollutants specified but must achieve at least 33 points from questions 13 to 24
Sore
Parameter assessed
attained
1 0
2 0
3 0
4 0
5 0
Total (max 65) 0
Five parameter award rating

Effluent Treatment
Theoretical potential score Score Percent
Inland Irrigation Evaporate Marine
water discharge
course
1 0 0 0 0 0
4 10 10 10 10 0
5 10 10 10 10 0
7 25 25 25 25 0
9 0 0 0 0 0
11 20 0 105 105 0
12 20 0 0 0 0
13 13 0 0 0 0
14 13 0 0 0 0
15 13 0 0 0 0
16 13 0 0 0 0
17 13 0 0 0 0
score only 5 of
18 13 0 0 0 0
these
19 13 0 0 0 0
questions
20 13 0 0 0 0
21 13 0 0 0 0
22 13 0 0 0 0
23 13 0 0 0 0
24 13 0 0 0 0
25 0 15 0 0 0
26 0 40 0 0 0
27 T 0 0 0 0 0
28 0 50 0 0 0
29 T 0 0 0 0 0
MAX 150 150 150 150 0
Total recorded >>>
Right click to update 0.00 0.00

Threshold questions
For award of medal rating in this section a minimum score of 0 points must be attained in q27
For award of medal rating in this section a minimum score of 0 points must be attained in q29

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15 HEALTH, SAFETY, EMERGENCY PREPAREDNESS
This section assesses the facility’s ability to manage a range of emergency and health and safety risks.
This includes systems, processes and responsibilities. It also requires an assessment of risk and
management in relation to the creation of Hydrogen Sulphide on site.

1 Does the company have a staff member on-site who manages health & safety issues, including
the emergency planning and response procedures?
score attained
A Yes, individual whose sole responsibility is health and safety issues 3
B Yes, individual who is appointed but who has other duties 1
C No 0

2 Has a health & safety risk assessment of all the chemicals used in the facility been undertaken?
score attained
A Yes, documents are freely available to all workers who use chemicals 2
B Yes, but documents are restricted to specified staff members 1
No evidence of an assessment having been undertaken and/or no
C 0
documentary record

3 How detailed was the assessment?

📷 score attained
A Assessment for each role / workstation (i.e. for each individual) 3
B Assessment for each department 2
C Assessment for the factory as a unit 1
D No record of assessment having been undertaken 0

4 Was the chemical hazard assessment undertaken by a suitably qualified assessor?

score attained
Yes, the assessor is an external agency specialising in health and safety
A 2
issues
Yes, the assessor is a health and safety technician employed by the
B company holding nationally recognised qualifications / registrations in 2
health and safety
Yes, the assessor is a health and safety technician employed by the
C 1
company
No, a hazard assessment has not been undertaken / the assessor does
D 0
not have recognised qualifications

5 Does the company require its chemical suppliers to provide safety data information in Globally
Harmonised System (GHS) format?
score attained
A Yes 2
B No -2

6 Is the critical information contained in the Safety Data Sheets transcribed into a standard
simplified format for workers and is this readily available in the workplace?
score attained
A Yes 1
B No 0

7 Has the company prepared a chemical compatibility matrix that is made clearly visible in the
workplace?
score attained
A Yes 1
B No 0

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 8 For each chemical group (e.g. corrosive, oxidising, flammable and toxic) used and for each
workstation has the organisation identified the appropriate PPE to be used?

For example a matrix similar to a chemical compatibility matrix

Cumulative score attained
A Yes, it has been identified 1
B Yes, it has been issued to all staff 1
C Yes, its use is obligatory as part of company policy 1
D Signage indicates the type of PPE that must be used 1
Although appropriate identification of required PPE has been undertaken
E -5
it use is optional
F No assessment of PPE requirements has been undertaken -10
Total (Max 4)

Threshold question
For award of medal rating in this section a minimum score of 3 points must be attained in q8

9 Does the company ensure that PPE is regularly assessed for functionality / replaced / renewed
in accordance with a defined schedule or defined procedures?
Cumulative score attained
Yes, all PPE is assessed in accordance with manufacturer’s
A 1
recommendations
Yes, all PPE is assessed by a safety technician holding sufficiently
B advanced qualifications that would permit assessments to be undertaken 1
appropriately
C Staff are trained in PPE use and self-assess fitness of equipment 1
D Stores records indicate PPE having been issued for the past 2 years 3
E No evidence of assessments being undertaken 0
Total (Max 6)

Threshold question
For award of medal rating in this section a minimum score of 3 points must be attained in q9

10 Has the company provided the following incident response equipment in ALL locations where
chemicals are present (stored and used)?
Cumulative score attained
A Safety showers 2
B Eye wash facilities 2
C Fire extinguishing facilities 2
D Access to first aid equipment / medication 2
E Spill-kits 2
F No 0
Total (Max 10)

Threshold question
For award of medal rating in this section a minimum score of 3 points must be attained in q10

11 Is there a written procedure in place for workers to bring incidences of adverse reaction to
chemicals used in the workplace to the attention of managers / workers representatives?
score attained
A Yes 2
B No 0

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 12 Has the company installed any automated delivery systems that would eliminate the manual
handling of (and therefore exposure to) chemicals?
Cumulative score attained
Yes, liquid chemicals delivered in bulk (container quantities greater than
A 5 tonnes) are dispensed directly into process vessels by automated 1
systems
Yes, liquid chemicals delivered in standard demounts (container
B quantities of 1 to 5 tonnes) are dispensed directly into process vessels 1
by automated systems
C No 0
Total (Max 2)

13 Is there a formal induction programme for new employees?

score attained
A Yes, it is completed on or prior to the first day of employment 3
B Yes, it is completed within the first week of employment 1
C Yes, it is completed within the first month of employment 0
A new employee could have been working in excess of a month without
D -10
formal induction

14 Assessment of workplace exposure to VOCs is undertaken by

score attained
A Not undertaken because usage is less than 35 g/m2 of finished leather. 5
Third party, quarterly assessment in the vicinity of the release points
B 5
close to workers
C Quarterly assessment in the vicinity of the release points close to workers 4
Third party annual assessment in the vicinity of the release points close
D 3
to workers
In-house annual assessment in the vicinity of the release points close to
E 2
workers
Not undertaken even though usage is more than 35 g/m2 of finished
F -30
leather

Threshold question
For award of medal rating in this section a minimum score of 2 points must be attained in q14

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 15 Has a risk assessment of beamhouse or other workplace exposure to hydrogen sulphide (H2S)
been undertaken by a competent assessor?

Recommendations made by the assessor must be demonstrated to have been acted upon
Cumulative score attained
A A comprehensive risk assessment of all facility operations has been
📷 undertaken. The risk assessment should address ALL hazards, not just
the potential for hydrogen sulphide release. There is either no mention of
the potential for hydrogen sulphide release or the risk has been identified
as negligible with no detection equipment required. The risk assessment
report has been signed off by the Plant Manager N/A

This response will only be accepted if all three of the following apply:
there are no beamhouse operations, sulphur containing chemicals are
not used, the company does not operate its own wastewater treatment
plant
The written assessment includes the risks of H2S release and poisoning
associated with beamhouse processing and/or the use of sulphur
4
B containing chemicals the conclusions and/or recommendations have
been shown to have been implemented.
Not undertaken for this area -5
The written assessment includes the risks of H2S release and poisoning
associated with the management of sulphur containing chemicals
4
C (storage, weighing, transfer to drum etc.) and the conclusions and/or
recommendations have been shown to have been implemented.
Not undertaken for this area -5
The written assessment includes the risks of H2S poisoning associated
with maintenance activities (entry into confined spaces, drainage sumps
4
D etc) and the conclusions and/or recommendations have been shown to
have been implemented.
Not undertaken for this area -5
Risk assessment has been undertaken but the assessor’s
E -15
recommendations not acted upon (for any of A, B, or C).
TOTAL (Max 12)
Basis upon which the assessor is considered competent to undertake the assessment

Threshold question
For award of medal rating in this section a minimum score of 4 points must be attained in q15
(i.e. at least 2 of the above scoring positively)

16 Does the risk assessment include or make reference to a site plan on which the areas of risk
have been identified?
Cumulative score attained
A There is a plan which shows the areas where a release of H2S would be
expected to be detected by a fixed point detector (Including an 1
📷 indication of where the detector(s) are located)
B There is a plan which shows the areas where a release of H2S might be
encountered but where fixed point monitors are not appropriate and 1
📷 where entry is therefore not permitted without a personal H2S monitor.
C There is no plan indicating areas of risk -10
TOTAL (Max 2)

Threshold question
For award of medal rating in this section a minimum score of 1 points must be attained in q16

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 17 In the event of release of hydrogen sulphide (H2S) in general production areas where a potential
📷 release has been identified is there a mechanism for detection?

Responses relating to personal monitors are only accepted for those monitors that have a triple alarm
system of sound, vibration and light. The type, number and position of detection equipment necessary
for the site should be identified within the competent risk assessment.
score attained
A There is constant, fixed, monitoring detection coupled to an alarm
📷 system which alerts all areas of the site including offices, and ALL 6
workers in at risk areas at all times carry personal H2S detectors
The company does not undertake any beamhouse operations and does
B not use sulphur containing chemicals. Personal H2S detectors are
6
📷 available should any staff need to enter a confined space (in addition to
all other required protective measures)
There is constant, fixed, monitoring detection coupled to an alarm
C system which alerts all of the process areas on the site
4
📷 and ALL workers in at risk areas at all times carry personal H2S
detectors
There is constant, fixed, monitoring detection coupled to an alarm
D system which alerts certain process areas e.g. beamhouse and areas
where sulphide containing chemicals are stored, weighed transported 2
📷 etc and ALL workers in at risk areas at all times carry personal H2S
detectors
There is constant, fixed, monitoring detection coupled to an alarm
E system which alerts at least certain process areas e.g. beamhouse
1
📷 only. Personal detectors are not issued or are issued only to some
workers.
F There is NO constant, fixed, monitoring detection coupled to an alarm
system however ALL workers in at risk areas carry personal H2S 1
📷 detectors
A thorough risk assessment of all facility operations has been
G undertaken. The potential for hydrogen sulphide release has been
-6
📷 identified as negligible with no detection equipment required. The risk
assessment report has been NOT signed off by the Plant Manager
There is no constant, fixed, or personal detection monitoring of potential
H FAIL
high levels of hydrogen sulphide

Threshold question
For award of medal rating in this section a minimum score of 1 point must be attained in q17

18 Has a risk assessment of exposure to hydrogen sulphide (H2S) at the waste water treatment
plant been undertaken by a competent assessor?

Recommendations made by the assessor must be demonstrated to have been acted upon
score attained
The written assessment includes the risks of H2S release and poisoning
A associated with waste water treatment operations and the conclusions 4
and/or recommendations have been shown to have been implemented.
Risk assessment has not been undertaken, the assessor’s
B recommendations not acted upon and/or the assessor was found not to -15
be competent, because existing risks were not mentioned.
C No wastewater treatment plant N/A
Basis upon which the assessor is considered competent to undertake the assessment

Threshold question
For award of medal rating in this section a minimum score of 4 points must be attained in q18

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 19 In the event of release of hydrogen sulphide (H2S) in the WWTP areas is there a mechanism for
📷 detection?

Responses relating to personal monitors are only accepted for those monitors that have a triple alarm
system of sound, vibration and light. The type, number and position of detection equipment necessary
for the site should be identified within the competent risk assessment.
score attained
All workers in the WWTP areas at all times carry personal H2S
A 0
detectors
There is no personal detection monitoring of potential high levels of
B FAIL
hydrogen sulphide in WWTP areas

20 Does the company instruct third parties who might spend substantial time on site in
manufacturing or chemical storage areas (e.g. visitors, contractors etc) in the health and safety
procedures to be followed whilst on-site?
score attained
A Yes, formal presentation including sign-off 2
B Yes, verbal briefing 1
C No 0

21 Does the company provide and require the wearing of applicable PPE to third parties who
might spend substantial time in manufacturing or chemical storage areas of the site?
score attained
A Yes 2
B No 0

22 Has the facility prepared a formal set of written procedures addressing environmental,
chemical and health & safety related emergencies?
Cumulative score attained
Potential environmental emergencies identified; response procedures
A 2
clearly stated
Potential chemical related emergencies identified; response procedures
B 2
clearly stated
Potential health & safety emergencies identified; response procedures
C 2
clearly stated
D No evidence of potential emergencies having been evaluated FAIL
TOTAL (Max 6)

Threshold question
For award of medal rating in this section a minimum score of 6 points must be attained in q22

23 Do the written emergency procedures include the following?

Note – this question relates to potential emergencies, it is not a question about day to day health &
safety issues which are addressed in question xx to yy below.
Cumulative score attained
A Emergency contacts list 1
Identification of the physical resources required to deal with the
B 1
emergencies identified (e.g. chemical spill kits, fire extinguishers)
Identification of the human resources required to deal with the
C 1
emergencies identified (e.g. trained first responders)
Identification of the safety equipment required to deal with the
D 1
emergencies identified (e.g. PPE)
E First aid measures, key personnel 1
How the external emergency services are contacted, how they gain
F 1
access to the plant and with whom they liaise
G Evacuation procedures 1
H Response D in q22 (A-G cannot be answered – there are no procedures) 0
TOTAL (Max 7)

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 24 How are emergency responses procedures reviewed and updated?
score attained
Regular assessment and updating as a matter of company policy (at least
A 3
monthly)
Regular assessment and updating as a matter of company policy (at least
B 2
quarterly)
Periodical review of internal audit reports by the Safety Manager,
C 1
improvements agreed with the company directors
D No up-dating is envisaged as necessary, the current plan is adequate 0

25 What training is given to emergency response team members? (documentary evidence

required to support the statement selected below):
score attained
External certification by external 3rd party authority, including regular
A exercises (at least quarterly) and periodical re-assessment (at least 7
annually)
External certification by external 3rd party authority, including regular
B exercises (but less than quarterly) and periodical re-assessment (but less 5
annually)
C External certification by external 3rd party authority 4
D Internal training system with regular re-assessment 2
E No formal training given 0

26 What is the frequency of emergency practice drills?

score attained
A Monthly 4
B Every 6 months 2
C Every 12 months 1
D No formal arrangement 0

27 Have local agencies/authorities been informed of the emergency procedures and facility
operations?
score attained
A Yes 5
B No 0

28 How many events requiring implementation of an emergency response have occurred in the
past 3 years (excluding natural phenomena and events originating off-site due to third party
activity)?
score attained
A None 4
B 1-3 0
C More than 3 -4

29 Did the company notify the Leather Working Group in writing (within 30 days) of any fatalities?
Only applies to tanneries undergoing re-audit but applies to the period since the previous audit
Score attained
A There have been no fatalities 0
There have been fatalities and they have been reported to Number of
B Leather Working Group within 30 days instances 0

There have been fatalities, but they have not been Number of
C reported to Leather Working Group within 30 days instances Fail

D This is the first audit for the company 0

State details and dates of fatality

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 30 Emergency response actions, for each of the following areas where appropriate, are facilitated
by:
Cumulative score attained
A Exit signs and exit areas being clearly marked and accessible 2
B Evacuation routes and destinations being clearly marked 2
There are sufficient externally trained emergency response team
members for i) all shifts and ii) not less than 1 per 30.
C For each of: 2
Fire
First aid
There are sufficient externally trained emergency response team
D 2
members for all shifts for chemical spillage
All employees are issued with a manual describing emergency response
E 2
requirements
TOTAL (Max 10)
Note – the response for option C should be based on the number of people on site for
each shift (as recorded in the section “General Facility Details”)

31 Are production drums / vessels appropriately and sufficiently guarded at ground level? The
minimum required method of guarding must physically prevent contact with any moving
drum and be secured from a fixed position.
score attained
A Drums are of a sufficient height that physical contact is not possible
10
📷 (evidence must be provided)
B
All drums have fine grill, full height level guarding 10
📷
C All drums have infrared guarding technology.
The beam is positioned at least 1.5 horizontal metres from the drum for 10
📷 each second required for the drum to come to complete standstill
D
All drums have at least flat panel guarding to waist height 8
📷
E
All drums have at least solid metal bar guarding 6
📷
F All drums have at least the minimum required standard of guarding as
3
📷 described above
G All drums have infrared guarding technology
The beam is positioned at least 1.0 horizontal metre from the drum for 3
📷 each second required for the drum to come to complete standstill
H
One or more drums has insufficient or no guarding Referral
📷
Referral:
If the issue is considered serious the auditor could refer directly to TSG.

Threshold question
For award of medal rating in this section a minimum score of 3 points must be attained in q31

32 Does the production drum guarding include an auto cut-off mechanism?

score attained
A
Yes 0
📷
B
No -2
📷

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 33 Are platforms and overhead working areas (including production drum access) appropriately
and sufficiently guarded? The minimum required method of guarding must physically
prevent contact with any moving drum, risk of falling from height and be securely fixed.
score attained
A All platforms and overhead working areas have fine grill guarding from
10
📷 drums and safety rails for walkway and staircase access.
B All platforms and overhead working areas have at least solid metal bar
6
📷 guarding at waist height.
C
One of more areas has no guarding Referral
📷
Referral:
If the issue is considered serious the auditor could refer directly to TSG.

Threshold question
For award of medal rating in this section a minimum score of 6 points must be attained in q33

34 Does the production drum guarding include an auto cut-off mechanism?

score attained
A
Yes 0
📷
B
No -2
📷

35 Are laboratory/trials drums and vessels appropriately and sufficiently guarded? The
minimum required method of guarding must physically prevent contact with any moving
drum and be secured from a fixed position.
score attained
A All drums are fully enclosed so that physical contact is not possible
10
📷 (evidence must be provided)
D
All drums have at least flat panel guarding to waist height 8
📷
E
All drums have at least solid metal bar guarding 6
📷
H
One or more drums has insufficient or no guarding Referral
📷
Referral:
If the issue is considered serious the auditor could refer directly to TSG.

Threshold question
For award of medal rating in this section a minimum score of 6 points must be attained in q35

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 Health, Safety, Emergency Preparedness
Actual potential score Score
Theoretical potential
(if question not
score
applicable enter 0) Percentage
1 3 0 0
2 2 0 0
3 3 0 0
4 2 0 0
5 2 0 0
6 1 0 0
7 1 0 0
8T 4 0 0
9T 6 0 0
10 T 10 0 0
11 2 0 0
12 2 0 0
13 3 0 0
14 T 5 0 0
15 T 12 0 0
16 T 2 0 0
17 T 6 0 0
18 T 4 0 0
19 0 0 0
20 2 0 0
21 2 0 0
22 T 6 0 0
23 7 0 0
24 3 0 0
25 7 0 0
26 4 0 0
27 5 0 0
28 4 0 0
29 0 0 0
30 10 0 0
31 T 10 0 0
32 0 0 0
33 T 10 0 0
34 0 0 0
35 T 10 0 0
MAX 150 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold questions
For award of medal rating in this section a minimum score of 3 points must be attained in q8
For award of medal rating in this section a minimum score of 3 points must be attained in q9
For award of medal rating in this section a minimum score of 6 points must be attained in q10
For award of medal rating in this section a minimum score of 4 points must be attained in q15
For award of medal rating in this section a minimum score of 1 point must be attained in q16
For award of medal rating in this section a minimum score of 1 point must be attained in q17
For award of medal rating in this section a minimum score of 4 points must be attained in q18
For award of medal rating in this section a minimum score of 6 points must be attained in q22
For award of medal rating in this section a minimum score of 3 points must be attained in q31
For award of medal rating in this section a minimum score of 6 points must be attained in q33
For award of medal rating in this section a minimum score of 6 points must be attained in q35

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16 CHEMICAL MANAGEMENT
The purpose of this section is to assess awareness, understanding and management of chemicals used
within the leather manufacturing process

This section makes references to Manufacturing Restricted Substances List (MRSL). An MRSL is a list of chemical
substances that are banned from intentional use in facilities processing textile materials, leather, rubber, foam,
adhesives and trim parts in textiles, apparel, and footwear. Using chemical formulations that conform to an MRSL
allows suppliers to assure themselves, and their customers, that banned chemical substances are not intentionally
used during production and manufacturing processes. MRSL limits apply to substances in commercially available
formulations, not those from earlier stages of chemical synthesis.

The above text is a selective extract (03/11/2020); full text available from https://mrsl.roadmaptozero.com/

A chemical formulation is a manufactured product as sold to a tannery. It includes complex formulations such as
dyes and retanning agents as well as simple commodity products such as formic acid and sodium sulphide.
Commodity chemicals are excluded from consideration in MRSL related questions for this version of the protocol.
They will be taken into account in future versions of the protocol.

The MRSL advocated by ZDHC is the minimum standard for this audit protocol. Other MRSLs will be accepted for
scoring purposes only if they exceed the ZDHC standards of stringency in ALL aspects.

1 Is there a written chemicals management system and/or set of written chemicals management
procedures for the company?
score attained
There is a chemicals management policy that clearly states the
company’s principles with respect to chemical selection and with
A respect to chemicals handling. 4
The policy includes a statement of intent and specific policy details.
Written procedures reflect the company’s policies
There is a chemicals management policy but is limited to a broad
B statement of intent 2
There are written chemicals management procedures.
C There are written chemicals procedures but no policy 1
D There is a policy but no written procedures -4

2 Does the management system clearly refer to the following?

Cumulative score attained

The individual (name or position) responsible for chemical management
A 1
is clearly stated
The qualifications and/or experience of the individual (name or position)
responsible for chemical management is clearly stated and
B 1
demonstrated.
(Graduate of a chemistry orientated discipline)
The procedures to be followed during normal working conditions are
C 1
clearly stated.
The procedures to be followed during emergency events (such as
D 1
significant spillages) are clearly stated.
E The company’s chemicals procurement policies 1
F A specific reference to the company’s policies with respect to MRSLs 1
G There are verbal/informal procedures only. 0
Total (Max 6)

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 3 Has the chemicals management policy been communicated effectively to facility staff?
Cumulative score attained
Yes – training - all people who use chemicals have been adequately
A trained in chemicals handling and use. The training programme reflects 2
the principles outlined in the policy statement
Yes – visual communication – e.g. posters clearly referencing the
B 2
chemicals management policy
Yes – written communication – e.g. each employee has a manual that
C 2
includes the chemicals management policy
Yes – there is a register or record of manuals issued, of associated
D training being given, and of employees signing to confirm understanding 2
of training and receipt of manual
E No 0
Total (Max 8)

4 How does the company communicate with clients to determine the MRSL requirements of
those clients?
score attained
A
Formally, there is evidence (e.g. emails) of clients being contacted 1
(
'
&
%
$
#
"
📷
Informally, there are no written records (e.g. emails)
B 0

5 If the company maintains a register (e.g. spreadsheet) that records the compliance against
client MRSL requirements which of the following are recorded?
Cumulative score attained
Date customer contacted to determine if there are requirements that
A 1
need to be followed
Date response received
B 1
Reference number/code of clients’ requirement (e.g. MRSL to be
C 1
applied)
D Review date 1
An assessment determining whether the client’s MRSL requirements
E 6
are capable of being fully met.
F There is no register of client MRSL requirements 0
TOTAL (Max 10)

6 This question relates to process chemicals.

If the company maintains a register (e.g., spreadsheet) that records MRSL compliance
declarations which of the following are recorded?
Cumulative score attained
The company uses third party platforms (e.g., ZDHC gateway, GloBlu
A 5
etc) to ascertain MRSL compliance status and maintains a register.
Date supplier contacted to advise that MRSL compliance declarations
B 1
are required
Date response received.
D 1
Reference number/code of MRSL covered by the declaration.
E 1
F Review date 1
G There is no register of compliance status 0
TOTAL (Max 5)

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 7 This question relates to manufactured input materials other than process chemicals (e.g., wet
blue, crust etc).

Does the company contact its suppliers to determine if they, in turn, ask their chemical
suppliers to provide declarations of MRSL compliance? If the company does so, does it
maintain a register (e.g., spreadsheet) that records the compliance declarations which of the
following are recorded?
Cumulative score attained
The company does not require its suppliers of input material to supply
A declarations that they, in turn, are asking their chemical suppliers for -5
MRSL compliance declarations.
Date supplier contacted to advise that MRSL compliance declarations
B 1
are required
Date response received.
C 1
Reference number/code of MRSL covered by the declaration
D 1
E Review date 2
F There is no register of compliance declaration -1
TOTAL (Max 5)

Threshold question
For award of medal rating in this section a minimum score of 1 points must be attained in q7

8 Has the company listed all of the process chemicals used and stored within the facility?
Cumulative score attained
All chemicals on site are listed (currently used in production, dormant,
A 3
and all R&D chemicals including samples)
B Only production chemicals (currently used and dormant) are listed 2
C Only production chemicals currently in use are listed 1
The quantity of all production chemicals onsite (currently used or
D 1
dormant) is accurately known. Records updated weekly:
The quantity of all production chemicals onsite (currently used or
E 0
dormant) is accurately known. Records updated less than weekly:
F Records are incomplete or non-existent -2
Total (Max 4)

9 Are there written procedures for the selection and purchase of process chemicals?
Cumulative score attained
The company will only use chemicals/suppliers that comply with the
A 1
chemicals management policy
The company will only use chemicals that are supported by a statement
B 1
or declaration of quality
The company will only use suppliers who can present their own
C 1
chemicals management policy statement
There are no written procedures relating to the selection and purchase
D 0
of process chemicals
Onsite auditing uncovers the use of chemicals whose use contravenes
E -5
the company’s own policies and or procedures
Total (Max 3)

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 10 Are there written procedures for the selection and purchase of manufactured process inputs
other than process chemicals (e.g. wet blue, crust etc)?
Cumulative score attained
A The company will only use inputs that comply with the purchasing policy 1
The company will only use inputs that are supported by a statement or
B 1
declaration of quality
The company will only use inputs who can present their own chemicals
C 1
management policy statement
There are no written procedures relating to the selection and purchase
D 0
of manufactured process inputs
Onsite auditing uncovers the use of inputs whose use contravenes the
E -5
company’s own policies and or procedures
Total (Max 3)

11 What proportion of the company’s incoming chemicals (by mass) is obtained from companies
that have documented compliance to MRSL?
Cross reference Q4
score attained
A Percentage x 0.2

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 12 Have all declarations been presented for auditor examination?
NB: Auditor should first assess what chemicals are used by the tannery, select two for each type
and then look to see if there are declarations for those selected. Auditor should list the two that were
chosen to identify them and provide evidence of declarations.
Note – listing on a LWG recognised third party platform (ZDHC Gateway, BHive etc) will be
accepted as being more robust than a formal supplier declaration). “Independent verification”, as
listed below, refers to the chemical having been tested by a third party and listed as compliant
on a third-party platform. Score either for supplier declaration or independent verification.
If a company formulates its own mix/formulation this is assessed as one chemical and all
ingredients must be MRSL complaint.

Recognised platforms can be found on the FAQs page of the LWG website.
https://www.leatherworkinggroup.com/how-we-work/faqs
Cumulative Supplier Independent attained
self- verification
declaration
Yes and at least 50% of all suppliers have been
reviewed to determine if they provide declarations of
MRSL compliance (minimum 5, maximum 10
suppliers). List of suppliers:
1
2
3
A 4 3 6
5
6
7
8
9
10
Yes and at least 2 declarations related to each category of applicable chemical / supplier (in each
case declarations from different suppliers) have been examined (or viewed on a LWG recognised
B third party platform). Alternatives from a different category may be substituted if the tannery does not
use chemicals belonging to one or more of the categories listed (16 chemicals need to be reviewed
to attain full score in this question).
Beamhouse auxiliaries (e.g., enzymes, unhairing
assists)
1 2

Tanning agents (e.g., chromium, vegetable tannins)

1 2

Retanning agents (e.g. syntan, resin, filler)

1 2

Lubricating agents (e.g. fatliquor, softening polymer)

1 2

Speciality agents (e.g. fixatives, penetrants, biocides)

1 2

Drum or surface applied colourants (e.g. dye, pigment)

1 2

Finishing chemicals (e.g. penetrant, binder, )

1 2

Total (Max 20)

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 13 What proportion of the company’s incoming (part processed) raw material (by area supplied)
is obtained from companies that have documented commitments to MRSL compliance? (This
will not apply to those processing fresh hides (not treated with chemicals))

score attained
A Percentage x 0.03

14 Are there written procedure governing the identification of controls to identify potential
contamination and/or product integrity prior to storage?
Cumulative score attained
Yes, all containers are inspected for integrity following receipt and prior
A 1
to storage
Yes, labelling on all containers is inspected following receipt and prior to
B 1
storage
C Bulk deliveries are supervised at time of delivery 1
D There are no procedures in place 0
Total (Max 3)

15 Are there material inventory lists, including quantities and locations available?
score attained
Yes, the database/spreadsheet includes coding related to the nature of
A 2
the product (hazardous, flammable, corrosive etc)
B Yes, but quantity only 1
C No 0

16 If yes, what is the target frequency for reconciliation between computer based stock levels and
actual physical stock (how often is a full physical stock take performed)?
score attained
A every week 3
B every month 2
C every 6 months 1
D Less than every 6 months 0

17 Does chemical warehousing take account of the shelf life of each chemical?
Cumulative score attained
A The company operates first in - first out stock control 1
Containers are labelled to indicate production date or date of entry to
B 1
stores
C A process or procedure exists to identify products that are out of date 1
Chemicals are removed from stores (or to a clearly marked area for
D expired chemicals) and appropriate remedial action taken once the “use- 1
by” date is exceeded
Total (Max 4)

18 Does the company reconcile actual quantities of chemicals issued into work against
theoretical quantities as suggested by recipe cards?
score attained
A Yes 1
B No 0

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 19 To what extent can the company identify which chemicals were used in the manufacture of an
individual batch of tanner’s product?

In this question the term” recipe sheet” could indicate either a physical, paper sheet or a computerised
record.
Cumulative score attained
Each of the chemicals used could be identified
A (for each batch of leather processed there is a recipe sheet that names 1
the chemical to be used in the process)
The quantity of each of the chemicals used could be identified
B (for each batch of leather processed there is a recipe sheet that indicates 1
the amount of chemical to be used in the process)
The supplier of each of the chemicals used could be identified
(for each batch of leather processed there is a recipe sheet that indicates
C 1
both the name of the chemical to be used in the process AND the name
of the supplier)
The batch number of each of the chemicals used could be identified
(for each batch of leather processed there is a recipe sheet that indicates
D 1
both the name of the chemical to be used in the process AND the
supplier’s batch number of the chemical)
Total (Max 4)

20 Does the organization have written chemical safe handling procedures to ensure that storage
and conditions are appropriate for the chemical hazard class?
Cumulative score attained
A The procedures refer to each of the main storage areas 2
B The procedures refer to each of the process areas 2
C The procedures refer to transfers between storage and process areas 2
D No 0
Total (Max 6)

21 Has the company provided training for all employees that handle chemicals?
score attained
A Third party training by a nationally certified / registered trainer 3
B Third party training by chemicals supplier 2
C In-house training by safety technician 2
D No -3

22 Can the company provide evidence that any training given has been understood (i.e. that the
trained employees follow the guidance of the training programme).

score attained
Training programme includes an examinable component
A 6
Evidence of examinable component and positive results is required).
B No 0

23 Has the facility labelled and stored work-in-progress chemicals appropriately?

Defined and suitable storage locations are used for

📷
(
'
&
%
$
#
" Cumulative score attained
A Flammable chemicals (e.g., solvents) 1
B Liquid chemicals (e.g., fatliquors) 1
C Corrosive chemicals (e.g., acids) 1
D Incompatible chemicals (e.g., acids and sodium sulphide) 1
E Powder chemicals (e.g., syntans) 1
TOTAL (Max 5)

Threshold question
For award of Gold rating in this section a minimum score of 4 points must be attained in q23

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 24 Are safety data sheets readily accessible?
(Provide details of any documented procedures) score attained
A Yes 1
B No 0

25 Main Chemical Storage Area:

Are the chemicals within the main storage area adequately stored and labelled?

Cumulative Score Attained

A
Are chemicals clearly labelled? 2
(
'
&
%
$
#
"
📷
B
IBCs (1000 litre containers) are not stored more than 3 units high 2
(
'
&
%
$
#
"
📷
C Incompatible chemicals are not stored together (refer to an
2
(
'
&
%
$
#
"
📷 incompatibility chart for guidance)
D If racking is used, all liquid chemicals are NOT stored above powder
1
(
'
&
%
$
#
"
📷 chemicals
E If racking is used, is it correctly weight labelled and in good condition /
1
(
'
&
%
$
#
"
📷 fit for purpose
F
Health & safety information is available for workers in the area 2
(
'
&
%
$
#
"
📷
G
Provided with fire extinguishing facilities 2
(
'
&
%
$
#
"
📷
H Fully surrounded by raised boundaries or dedicated drainage to sumps
2
(
'
&
%
$
#
"
📷 (i.e. potential liquid spills would be contained)
Separated from main production areas
I 2
Well ventilated and out of direct sunlight
J 2
Flammable chemicals storage areas are suitably protected against
H 2
static electricity build-up/discharge.
TOTAL (Max 20)

Threshold question
For award of Gold rating in this section a minimum score of 80% of applicable points must be attained in
q25

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 Chemical Management
Actual potential score Score Percentage
Theoretical potential
(if question not
score
applicable enter 0)
1 4 0 0
2 6 0 0
3 8 0 0
4 1 0 0
5 10 0 0
6 5 0 0
7T 5 0 0
8 4 0 0
9 3 0 0
10 3 0 0
11 20 0 0
12 20 0 0
13 3 0 0
14 3 0 0
15 2 0 0
16 3 0 0
17 4 0 0
18 1 0 0
19 4 0 0
20 6 0 0
21 3 0 0
22 6 0 0
23 T 5 0 0
24 1 0 0
25 T 20 0 0
MAX 150 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

Threshold question
For award of medal rating in this section a minimum score of 1 points must be attained in q7
For award of Gold rating in this section a minimum score of 5 points must be attained in q23
For award of Gold rating in this section a minimum score of 80% of applicable points must be attained in
q25

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17 OPERATIONS MANAGEMENT
This section assesses the facility’s ability to control its manufacturing processes, reviewing best
practices, measuring equipment use and calibrations, etc

For housekeeping related issues, the auditor will assess the organisations in relation to three departments
(manufacturing sections) taken at random but appropriate to the range of operations of the tannery. There will also
be an assessment of the external areas of the tannery. The score for each question will be the average of the
scores recorded for each department. Depending upon the scale of operations the auditor may decide to assess
more than three departments to report the state of housekeeping more accurately.

If an assessment of the state of housekeeping of the external areas of the tannery is possible this must be done, if
it is not applicable an additional area should be substituted instead.

NB: In some organisations it is not possible to clearly identify three distinct departments. Examples include wet
blue tanneries (where there is often only the drum platform and samming/sorting areas) and PU coating plants
(where there is often only the main PU coating line). In such circumstances the score should be based on the
departments that can be assessed. A justification must be included in the report if fewer than three departments
are assessed.

Department #1 Department #2 Department #3

1 Is there a procedure in place for regular/ongoing cleaning/housekeeping?

score attained
A Yes 2
B No 0

2 Is there a traffic management system for controlling motor vehicle and pedestrian movement
within the internal production areas and external perimeter of the site?
Cumulative Score score attained
A
Yes, there is a written document and site map 2
📷
Signage throughout the site clearly indicates those areas which are
B pedestrian traffic only and those which are not. Markings indicate
2
📷 separate access routes for pedestrians and vehicles (other than
designated crossing points).
C Signage throughout the site clearly indicates access routes; pedestrians
1
📷 and vehicles share the same access routes.
Traffic management is included in the induction of employees, visitors
D 2
and contractors.
TOTAL (Max 6)

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 3 Access routes (walkways, fork-truck routes, etc)
If the area being assessed is a wet area, painted lines are not expected (respond to the first of
the two options for each wet area.
maximum attained
score
Dept Access routes are clearly marked (e.g. with clearly defined visible lines)
10
1 and are free from obstruction
Access routes are not marked (e.g. with clearly defined visible lines) but
📷 are free from obstruction
5
Access routes are clearly marked (e.g. with clearly defined visible lines)
Dept 2 10
and are free from obstruction
📷 Access routes are not marked (e.g. with clearly defined visible lines) but
5
are free from obstruction
Access routes are clearly marked (e.g. with clearly defined visible lines)
Dept3 10
and are free from obstruction
📷 Access routes are not marked (e.g. with clearly defined visible lines) but
5
are free from obstruction
AVERAGE (Max 10)

4 Work in Progress (WIP)

If the area being assessed is a wet area, painted lines are not expected (respond to the first of
the two options for each wet area.
maximum attained
score
Dept1 WIP is in areas that are clearly marked (e.g. with clearly defined visible
10
lines) and are free from obstruction
📷 WIP is in areas that are not marked but are free from obstruction. 5
Dept 2 WIP is in areas that are clearly marked (e.g. with clearly defined visible
10
lines) and are free from obstruction
📷 WIP is in areas that are not marked but are free from obstruction. 5
Dept 3 WIP is in areas that are clearly marked (e.g. with clearly defined visible
10
lines) and are free from obstruction
📷 WIP is in areas that are not marked but are free from obstruction. 5
AVERAGE (Max 10)

5 Chemicals
maximum attained
score
Chemicals are not used in the department N/A
Dept 1 Chemicals are in areas that are clearly marked (e.g. with clearly defined
8
visible lines) and are free from obstruction
📷 Chemicals are in areas that are not marked but are free from
4
obstruction.
Chemicals are not used in the department N/A
Dept 2 Chemicals are in areas that are clearly marked (e.g. with clearly defined
8
visible lines) and are free from obstruction
📷 Chemicals are in areas that are not marked but are free from
4
obstruction.
Chemicals are not used in the department N/A
Dept 3 Chemicals are in areas that are clearly marked (e.g. with clearly defined
8
visible lines) and are free from obstruction
📷 Chemicals are in areas that are not marked but are free from
4
obstruction.
AVERAGE (Max 8)

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 6 Equipment
Does the equipment used by staff in the department (for example maximum attained
brooms, thermometers, buckets etc.) have defined storage locations? score
Dept 1
Yes, equipment is stored in clearly defined areas 1
📷
Dept 2
Yes, equipment is stored in clearly defined areas 1
📷
Dept 3
Yes, equipment is stored in clearly defined areas 1
📷
AVERAGE (Max 1)

7 General cleanliness
Is the machinery in the department (dryers, drums, roller-coaters etc.) maximum attained
clean and in good order? score
Dept 1
Department #1 6
📷
Dept 2
Department#2 6
📷
Dept 3
Department #3 6
📷
AVERAGE (Max6)

8 The grounds/outside areas (or other internal area if not applicable)

What proportion of the grounds/the outside areas (or other internal area maximum attained
if not applicable) are clean and tidy? score
A
The grounds/outside areas 3
📷
B
Other internal area 3
📷
AVERAGE (Max 3)

9 Is there evidence of up-to date calibration of measuring equipment (directly related to

processing) for the following equipment?
(CUMULATIVE) score attained
A Factory weigh scales 1
B pH meters / standardised pH papers 1
C Water metering systems 1
D Water measurement is by graduated drum marking 0
E Thermometers 1
F No evidence of accurate weighing (no calibration records) -1
G No evidence of accurate pH measurement (no calibration records) -1
H No evidence of accurate water measurement (no calibration records) -1
I No evidence accurate of temperature control (no calibration records) -1
TOTAL (Max 4)

10 How is the amount of water used in processing controlled?

score attained
A Dosing/metering system 2
B Manual measurement 1
C Visual/estimation method 0

11 Fleshing operation is normally carried out in

score attained
A Green state 4
B Limed state 2
Max 4

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 12 General description of the unhairing process is
score attained
A Hair save system 2
Hair burn system
B 4
beamhouse sludge is used for controlled agricultural application
Hair burn system
C 0
beamhouse sludge is land filled

13 Are processes controlled at key points to ensure efficiency and exhaustion (time, temperature,
pH, etc.)?
score attained
Always checked (all required checks indicated on process sheets and all
A 3
process loads)
B Sometimes checked (checks on some process sheets not recorded) 2
Rarely checked (checks recorded on some process sheets, other sheets
C 1
with no checks recorded)
D Never checked 0

14 Uniformity of mixing of the various finishing chemicals is achieved by

score attained
A Electric stirrers 2
B Manual stirring 0

15 Colour control is achieved by

score attained
A Instrumental colour matching and assessment 2
B Manual assessment 0

16 Are VOC emissions managed through the formulation of low solvent finishing systems?

This question requires a determination of the amount of VOC used expressed as a percentage of the
total amount of finishing chemicals used.
Score = (percentage VOC x -0.2) + 12 kg
Example 20% -4 +12 = 8
Total mass of finishing chemicals applied
Total mass of solvent used in finishing
% attained
Percentage of solvent used in finishing
TOTAL (Max 12)

17 Use of solvents in finishing is controlled, the company has produced evidence of monitoring
(The company must provide evidence of how it is using its monitoring data to reduce or control
solvent usage)
score attained
A Monthly 3
B Annually 1
C No evidence available 0
D Solvent accounts for less than 10% of total finishing chemicals 3

18 Wetting agents used are of the following chemical classification

Cumulative score attained
A Biodegradable 1
B NPE free 1
C Non-Biodegradable -1
D Contain NPE -1
TOTAL (Max 2)

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 19 The amount of bactericide used is
score attained
A Well controlled (i.e. by regular dip slide monitoring) 1
B Uncontrolled 0

20 De-greasing chemicals used to clean the samming machine are

score attained
A Regulated in accordance with a written work instruction 0
B Not formally monitored -1

21 If fungicide is used in the retanning/dyeing process is excess use avoided?

score attained
Yes, the fungicide has been selected with the assistance of the supplier
A 2
including testing, to ensure that it is appropriate
Yes, the fungicide has been selected based on the recommendations
B 1
contained in the technical literature
Yes, but no evidence has been presented to indicate that the fungicide
C 0
used is appropriate to the process or the leather being made
No fungicide is used
D 2
OR retanning/dyeing is not part of the facility’s operations

22 Technology is in place to reduce sulphide in the process

score attained
A Total sulphide (60% Na2S equivalents) is less than 2.0% offer 4
B Total sulphide (60% Na2S equivalents) is more than 2.0% offer 2
C None 0
If response is A or B indicate the nature of the chemical/technology used:

% offer Na2S 0.00

% purity of Na2S 60.00
% offer NaHS 0.00
% purity of NaHS 56.00
Na2S equivalents 0.00

Companies undertaking an audit can request an editable copy of the above table from their auditor.

23 The delime process follows one of the general descriptions below

score attained
A Ammonium-free system 3
B Ammonium-reduced system
2
Total ammonium salt ((NH4)2SO4 equivalents) is less than 1.5% offer
C Ammonium-reduced system
1
Total ammonium salt ((NH4)2SO4 equivalents) is less than 2.5% offer
D Standard system based on ammonium salts 0
If response is A, B or C indicate the nature of the chemical/technology used:

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 % offer (NH4)2SO4 0.00
% purity of (NH4)2SO4 99.00
% offer NH4Cl 0.00
% purity of NH4Cl 99.00
Na2S equivalents 0.00

Companies undertaking an audit can request an editable copy of the above table from their auditor.

24 The earliest point at which waste liquors from the beamhouse are mixed with other liquors
from within the tannery is
score attained
A At the wastewater treatment plant 2
B Before the waste-water treatment plant but outside of the building 0
C At any point inside the building -2

25 Have neighbours or the public complained about nuisance/visual impact from any of the
following in the past 18 months:
(check all that apply)
A Site aesthetics
B Lighting at night
C Litter
D Waste materials storage
E Dust
F Vehicle movements
G Noise
H Odour
I No complaints
Give details of the number of complaints per year in each category

26 How are complaints processed?

score attained
A There is a defined, written procedure that ensures all complaints are
2
investigated and acted upon (including records being maintained)
B There is a procedure (but not written) that ensures all complaints are
0
investigated and acted upon/There is no defined procedure

27 Are any regulatory enforcement actions or prosecutions outstanding related to the above?
score attained
A No 2
B Caution/warning -2
C Prosecution -2

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 28 Is the company operating in a manner that could be considered to conform to globally
recognized standards or are there practices that are likely to lead to detriment of the reputation
of LWG should the tanner be otherwise awarded certification?

Caveat #1

The LWG audit is principally an environmental audit undertaken by auditors approved by LWG as specialists in
tannery environmental auditing. The auditors are not necessarily specialists in building stability, electrical &
mechanical safety or issues related to corporate social responsibility. A positive assessment in response to the
issues below is only a value judgment based on experience and observations made at the time of the audit. It
is not an endorsement of compliance to the legislative requirements to which the tannery may be subject. It
does not imply that the tannery is operating legally with respect to these issues.
Does the tannery appear to be operating suitably with respect to the Yes No
following issues?
A Buildings and infrastructure appear to be well maintained
📷
(if “no”)
B Moving equipment (splitting machines, staking machines, presses, let
📷 driven motors, etc) appear to be appropriately and sufficiently guarded
C Appropriate PPE is provided, and its use enforced
📷
D Electrical systems appear to be suitably enclosed so as to prevent
📷 electrocution
(if “no”)
E Chemicals and wastes appear to be stored such that soil contamination
📷 cannot occur
(if “no”)
F Soils/grounds within and surrounding the tannery appear to be free from
📷 signs of contamination
(if “no”)
G All other aspects of the business appear to be conducted in a manner
📷 such that they would not lead to detriment of the reputation of LWG
(if “no”) should the tanner be awarded certification

In the event that other situations not covered by criteria A-H are
observed, a description (with photographs) of the situation should be
inserted here:

Caveat #2

The issues above have not been extensively addressed thus a positive assessment is not an endorsement nor
an indication of legal compliance

If the response to any of the above criteria is “No” the auditor may refer the situation to the facilitator who will
submit to TSG as appropriate.

TSG could downgrade or fail the audit depending on the seriousness of the situation.

The tanner and/or auditor can submit a report of the situation to the LWG facilitator for guidance/appeal if
considered necessary or desirable.

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 Operations Management
Actual potential score Score Percentage
Theoretical potential
(if question not
score
applicable enter 0)
1 2 0 0
2 6 0 0
3 10 0 0
4 10 0 0
5 8 0 0
6 1 0 0
7 6 0 0
8 3 0 0
9 4 0 0
10 2 0 0
11 4 0 0
12 4 0 0
13 3 0 0
14 2 0 0
15 2 0 0
16 12 0 0
17 3 0 0
18 2 0 0
19 1 0 0
20 0 0 0
21 2 0 0
22 4 0 0
23 3 0 0
24 2 0 0
26 2 0 0
27 2 0 0
MAX 100 0 0
Total recorded >>>
Right click to update 0.00 0.00 0.00
(first two columns only)

124
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