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Sustainability audit procedures

1. Background

Several dictionary definitions are available for the meaning of ‘sustainability’ including to support, maintain and endure. Since the 1980s, the term ‘sustainability’ has been increasingly used in respect of human survival on planet earth which has resulted in the concept of ‘sustainable development’ which ‘should meet the needs of the present without compromising the ability of future generations to meet their own needs’.

Concurrent with this development, from the late 1970s onwards, a global economy began to emerge in which a number of mature industries migrated from high-cost, developed countries in the western hemisphere to low cost, developing countries in the eastern hemisphere. The textile manufacturing industry was a major casualty of this migration, including fibre, yarn, fabrics and garment production. Particularly adversely affected was the worldwide dye manufacturing industry which resulted in the demise of the industry in the UK, the USA and to a lesser extent in Germany and Switzerland, with an expansion of the industry in the east, particularly in India and China. Increasingly severe legislation concerning health, safety, effluent and ecological factors in the developed countries contributed to this migration.

As a result, developed countries were unable to support a domestic textile industry and overcapacity was often created by developments in low-cost countries, so that major geographical and technical changes occurred within the global textile industry. Many developing, low-cost countries established textiles as a primary industry for reasons including:

(1)   technology and machinery were readily acquired from developed countries

(2)   there was an adequate supply of labour

(3)   a large domestic market existed for textile goods

(4)   some governments subsidised the developing textile industry


Although labour costs in the original low-cost countries started to rise, ecological factors, such as effluent treatment and emissions, became and remain major and costly issues. Similar issues exist in the developing dye and chemical manufacturing sector. From around 2010, several organisations, but notably Greenpeace, initiated ‘detox’ campaigns to reduce or eliminate dangerous substances such as cancer-causing amines in dyes. Greenpeace also published the results of several case studies [1] detailing the costs and effects of water pollution on people and the environment. The entire textile chain has been under increasing pressure over recent years with an emphasis on occupational health, environmental safety and safe working conditions. Textile companies now face three sources of pressure:

(1)   shareholder expectations

(2)   customer demands and loyalty

(3)   ethical and sustainable textiles and clothing.

This triple bottom line now contains environmental, social and economic components. Furthermore, the textile industry has changed dramatically over recent years from mainly a vertical production-led organisation to retail-specified manufacturing. In traditional vertical manufacturing, garments were designed by manufacturers who had the responsibility of selecting yarns, fabric constructions, colour, finish and the final garment design. In theory at least, a garment was never designed that could not readily be made and costs were kept within a pre-determined budget to arrive at a profitable selling price. Many of these factors are now specified by the retailer. Nevertheless, an informed input is required from other sectors of the manufacturing chain, including dyers and finishers. Since it is estimated that there are 1600 retail groups worldwide, this sector now has a greater decision-making and purchasing power.

Without doubt, retailers were initially instrumental in urging the adoption of low-cost facilities in developing countries. To the environmental factors listed above, retailers also added the ethical factors of fair labour practices and social justice. Major retail chains are now exerting further pressure in a demand for suppliers to introduce ‘sustainable’ technology.  This in turn leads to significant cost increases which cannot be achieved without further price increases or financial contributions. Many retailers have issued their own ‘restricted substances’ lists while some retailers have announced their intention to ‘detox the chain’ including involvement in the development of waterless dyeing processes.

International trade in textiles and clothing was governed until 2005 by the multi-fibre agreement (MFA), established in the early 1970s as an interim measure to control imports from low-cost developing markets during the restructuring of the mature textile producers. After 2005, the global industry has operated as a free zone area, with further import penetration into developed markets. Globalisation of textile manufacture implies that suppliers must be able to operate internationally in a highly competitive economic environment   and this induced textile producers to develop quick response (QR) marketing in the 1980s. This is turn lead to the need for Just-in-Time (JIT) and Right-First-Time (RFT) processing. As a result of the creation of long supply, electronic distance quality control is also required.

The traditional textile and supporting industries were originally situated in counties with a long tradition of governance based on countywide legislation that had increasingly imposed strict and increasing measures on labour, environmental, health, safety and ethical issues. The developing countries which have become the world’s principal suppliers of textiles and garments have no such history of extensive legislature, although many companies in these areas are utilising modern equipment, technology and concepts, including RFT, JIT and QR.

‘Sustainable technology’ depends on processes which do not lead to:

  • the emission of greenhouse gases
  • use of non-renewable materials
  • generation of waste.

In turn, sustainability is achieved by:

  • occupational health
  • environmental safety
  • safe working conditions
  • ethical and fair labour practices and human justice.

The following procedures are intended to assess the current state of sustainability in individual textile operations by the means of an informed auditing procedure, after which recommendations can be made for implementing the required improvements in conjunction with the necessary technical factors. The audit applies to production and laboratory facilities.

2.  Health and safety

2.1 General

Employers must provide safe and healthy working conditions for their employees. This includes buildings of adequate design and strength together with the provision of adequate entrances of suitable width. There must be a specified number of emergency exits with push-bar opening devices and these must not be locked. Modern buildings must certainly meet the local building regulations and specifications.

The workplace environment should be comfortable with safe and clean conditions with adequate controls to manage emergency preparedness. Residential facilities provided to employees should contain adequate living space, be clean and well maintained. Working conditions require sufficient lighting, acceptable noise levels, air quality, temperature, hygienic canteens and food preparation areas, hygienic and sufficient toilets.

In many textile operations, temperature and humidity controls are necessary to obtain optimum processing conditions in addition to achieving the comfort of operatives. A maximum specified weight can be handled by operatives, especially females. Smoking is not permitted. Fire extinguishers of the appropriate type should be placed in strategic positions. There should be a trained and qualified first aid operative on each shift.

2.2 Textile processing

Many textile machines contain dangerous and rapid moving parts so that all machines must be fitted with guards. Steam pipes and high-temperature equipment must be insulated and protected. Clothing and, particularly with females, hair styles should not be of a nature to be caught in machinery, Preferably protective clothing should be provided and this is mandatory in certain areas as discussed later. Protective gloves and footwear may be required.

Textile processes such as fibre, yarn, fabric and garment production may produce significant quantities of dust, so that for a number of reasons eye protection (glasses or goggles) and respiratory protection (in its simplest form this may be disposable masks) must be provided. Hearing protection, available in a number of formats, must be provided in areas where high noise levels are experienced.

2.3 Dyeing and finishing operations

These are areas of major concern since they include the combination of health, safety and environment factors. Dyeing processes are still normally hot aqueous procedures with atmospheric dyeing being carried out at temperatures up to 100°C involved. High temperature (HT) processes, for example in polyester dyeing, are carried out in pressurised vessels at temperatures of up to 135°C. Equipment for both types of dyeing must be designed to avoid scalding with hot liquids by safety locks to prohibit accidental opening. With HT machines, the machines must be tested and certified to withstand the required pressures with valve controls and safety lid locks fitted to prevent opening at high pressures and temperatures, usually not above 85°C. Drying and other dry finishing machines also operate at high temperatures. Steam pipes should be insulated for safety and energy-saving reasons. Stenters are now fitted with equipment to reduce the volatile emissions and odours in the exhaust gases. Machine guards are essential on raising and cutting machines.

2.4 Dyes and chemicals

A principle concern is the storage, handling, weighing and dispensing of dyes and chemicals and for these reasons, these operations are usually situated in specially designed, highly sophisticated and controlled areas in a modern dyeing and finishing operation. Dyes and chemicals should be eliminated which are likely to cause:

  • carcinogenicity
  • mutagenicity
  • dustiness
  • risk of respiratory problems
  • risk of allergies

Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) is European Union regulation which replaces a number of European directives and is likely to be adopted worldwide. Its aim is to provide a high level of protection of human health and the environment from the use of chemicals. This legislation makes manufacturers and importers responsible for understanding and managing the risks associated with use. With a global reduction in global R&D, particularly application research, in the dye manufacturing industry, there is likely to be a need for more final product testing to ensure the elimination of prohibited substances. The key principles of REACH are:

  • protection of human health and the environment
  • increased transparency
  • conformity across borders
  • registration of products complete by 2018
  • supply chain communication
  • no data, no market
  • one substance, one registration
  • substances registered, not products

Suppliers of dyes and chemicals must provide a Material Safety Data Sheet (MSDS) for each product and these, in addition to a list of products, must be available for inspection during the audit.

It is standard practice to isolate the dispensary from the main production area and major advances have occurred in dispensary design to improve dyeing reproducibility in addition to health and safety factors. These include air-conditioning with a double door ‘air-lock’ entry system activated by electronic sensors. Separate storage for bulk materials is usually provided and the main dispensary has the following areas:

  • weighing area with balances situated in a laminar flow extraction booth. Dyes and chemicals are weighed into stainless steel buckets
  •  pasting and pre-mixing
  • dispensing to the dye application equipment from stainless steel, controlled dispensing tanks.

This total area should be air-conditioned and employees carrying out the weighing and dissolving operations should be specifically trained in these operations and provided with protective clothing which will include total ‘space-suiting’. Guidance has been given on the various aspects of handling dyes and chemicals in the dispensary, including dust control [2].

2.5 Effluent

Any effluent to be disposed through a sewer or water course must meet the consent limits of the local governing authority. These limits include values for temperature, pH and a number of substances. Temperature and concentrations will normally be balanced in mixing tanks on site. Unless a relatively harmless effluent is created, however, it is necessary to carry out effluent treatment on site before disposal. Depending on the cost of raw water, the cost of effluent treatment either in-house or at the local municipal plant, water recycling may be a cost effective alternative. This has been discussed elsewhere [3].

3. Ethical/sustainability issues

The ethical issues covered by the sustainability audit involve many factors and is the area given most emphasis by retailers. The audit covers many of the factors involved in technical audits but a much higher degree of documentary proof is required from the company being audited. The audit scope covers:

  • legal compliance
  • prohibition of corruption and bribery
  • respect for basic human rights of employees
  • prohibition of child labour
  • health and safety of employees
  • environmental protection

The audit is usually structured into five sections:

  • opening meeting with company management; a formal request to conduct an audit; explanation of audit; interview with top management
  • factory inspection; collection of records; cross-checking; photography if required
  • employee interviews – employees selected by auditors with interviews held in private with records being taken
  • review of records and results collected together with summary of findings
  • closing meeting with factory management to discuss findings, confirm any corrective action and ‘sign off’ by management and auditors

The audit checklist will include the following:

3.1 Legal compliance and prohibition of corruption and bribery : this intention must be documented in company policy, employee rules and included in training.

3.2 An effective management system should be in place with a management ‘family tree’ which shows responsibilities and reporting. Risk assessment and corrective measures for social and environmental issues are included.

3.3 Forced, bonded, indentured or trafficked labour, involuntary prison labour must not be used. Activities that restrict freedom of movement, retaining employee ID or monetary deposits, forced overtime, leaving at the end of a shift, restricting leaving the current employment, coercion by security staff must not be used.

3.4 Harassment and abuse must not be used. Employees must be treated with respect and dignity as described in clearly understood disciplinary procedures that forbid acts of bullying, the threat of physical abuse, sexual or other harassment, verbal abuse, monetary deductions or other forms of intimidation of any kind. Fair disciplinary procedures and written rules must be communicated; wage deductions must be within legal regulations; channels for reporting harassment and abuse must be effective and communicated to employees.

3.5 Discrimination in any form, including hiring of employees, payment and compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, disease, pregnancy or political affiliation should not be carried out. Equal pay, written description of qualification for each position are required. Confidential methods of reporting infringement must be available. No pregnancy or other tests can be used as discriminatory elements (e.g. HIV).

3.6 Regular hours and overtime working should comply with the legal limitations of the country. Accurate and complete record keeping is essential. Employees should not be requested to work overtime on a regular basis and total hours should be aligned with international-benchmark industry standards with ongoing continuous improvement. Employees should be provided at least one day off, following six consecutive days working. The company should introduce effective tools for productivity development and provide support to working hour reduction. A process and system is necessary to check hours worked and there should be adequate meal breaks.

3.7 Wages, overtime pay, benefits and paid leave are provided and at least meet or exceed legal minimum requirements and/or collective bargaining agreements with accurate and complete records being maintained. Employees should receive documentation with each payment. Benefits such as maternity leave, annual leave, social insurance must meet legal requirements.

3.8 Freedom of association is practiced.

3.9 Child labour is a violation of fundamental human rights. Under-age employees should not be hired under the age established by local legislation or age 15 if there is no local law. Special protection should be in place for employees under 18. No overtime working for young workers.

3.10 Health and safety requirements have been discussed above in some detail.

3.11 The potential impact of the site on the environment should be recognised and must comply with the environmental laws, regulations and permits relating to solid-waste, hazardous-waste, waste water/effluent, storm-water and air emissions.

4. Documents

It is apparent from the above eleven sections that substantial documentation must be established by the employer and this must be made available to the auditors. In addition to the management chart, written instructions and guidelines together with training manuals, these include employment requirements, labour and wages records, normal and overtime working hours, benefit entitlements, disciplinary procedures, regional health, safety and environmental requirements. Minutes of meetings with management and employees during the audit should be kept.

The basic rules of the company should be recorded and well-defined in a company rule book which should be given to each operative during induction. A hazard check list should be developed for the regular assessment of each department.

5. Conclusions

A sustainability audit, if carried correctly and effectively, is lengthy and covers many factors. Some of these factors are covered in normal technical audits as shown in Appendices 1 and 2 but much more documentary evidence together with verbal discussions are required to support a total sustainability audit. It is also unlikely that an operation with a poor technical performance and unable to achieve a high level of right-first-time (RFT) production to industry norms would be able to achieve sustainability. Conversely, high levels of RFT production are unlikely to be obtained without many aspects of sustainability. Finally, tomorrow’s environmental problems cannot be solved with yesterday’s technology, products and processes.

6. References

[1] Hidden consequences – The costs of industrial water pollution on people, planet and  profit (The Netherlands: Greenpeace International, July 2010)

[2] Series of seven information sheets published by the Health and Safety Executive (available free of charge on the Internet)

[3] Water and effluent in textile wet processing; Review of effluent treatment.  J. Park, November 2010.

If anyone has any feedback or input regarding the published news, please contact: info@textiletoday.com.bd

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