DISCHARGE DATA REPORT Summary report February 2013

All discharge data meet local

wastewater legislations4

Traces of

5 out of 11 priority chemicals

were found in

wastewater discharge

ONE Chemical group2

seems to originate from incoming water

rather than manufacturing

processes3

Most results meet WHO’s suggested

Daily Tolerable Intake 5

Some results meet drinking water

legislations6

Verification of 11 Priority Chemicals In Wastewater Discharge

1. C&A’s RSL, H&M’s RSL, G-Star’s RSL 2. Chlorobenzenes

3. Local meaning where the water was tested; Bangladesh, China and India 4. Based on Result of this study

5. Based on Available Data

Stringent chemical requirements have long been imposed in production; we ban chemicals that are considered hazardous for use in production process, and sets limit values for finished products through our Restricted Substances List or RSL1). Our Chemical Restrictions on our products are as a minimum always based on the highest legal standard in any of our sales countries as well as on information from authorities, NGOs and scientific reports.

This study however, does not focus on the chemical contents in our products, but rather, on the chemical contents in the wastewater discharged from manufacturing processes. This brings us to our aim; to verify whether certain chemical groups are in the wastewater discharge of factories.

It has taken us almost 1 year to conduct this study, from planning to delivering this report. We have chosen to make this verification for 11 groups of chemicals; what we call the ‘Priority 11’. Key findings are on the right hand side. Although this study is only pilot, the selection represents factories that conducts highly water intensive processes, located in key production markets; China, Bangladesh & India.

We acknowledge that the outcome of this study only provides a snapshot of the situation; however, we have been able to draw strong patterns from the results collected, providing us with a clearer next step towards tackling our goal towards zero discharge of hazardous chemicals 2020.

GENERAL PICTURE

2

Introduction

AIM The aim of this study is to determine whether 11 priority chemicals groups are discharged from factories by onsite audits, inventories and analytics.

BACKGROUND To lead the Apparel and Footwear Industry towards Zero Discharge of Hazardous Chemicals (ZDHC) by 2020, a Joint Roadmap, which involves various specific projects and actions, is developed by brands to drive the industry to reach the goal. This verification study is one of the projects in joint roadmap.

Bangladesh

China

India

TOTAL NUMBER OF FACTORIES

5 in Bangladesh, 3 in China, 3 in India 11

11 PRIORITY CHEMICALS

1. Alkylphenols (APs) & Alkylphenol Ethoxylates (APEOs), 2. Azo Dyes, 3. Brominated and Chlorinated Flame Retardants, 4. Chlorinated solvents, 5. Chlorobenzenes, 6. Chlorophenols, 7. Organotin, 8. Phthalates, 9. Short Chain Chlorinated Paraffins (SCCPs), 10. Total heavy metal, 11. Perfluorinated Chemicals (PFCs)

SERVICE PROVIDERS

Bureau Veritas Consumer Product Service Ltd (BVCPs)

Sustainable Textile Solution (STS)

WHERE

Factory

Wastewater Treatment Plant

Open bodies of water e.g. River

Incoming water for manufacturing processes1

e.g. River/ Ground water

Verification of 11 chemicals in the wastewater discharge

Wastewater Discharge

1. The source of incoming water for manufacturing processes is often river or ground water. This source is not the same as the source used for domestic/

drinking use, which instead, is often water from the municipality.

Aim: To verify if

11 chemical groups

are in the discharge

Within the 11 chemical groups, we tested 93

analytes, at 11 factories

Out of 93 analytes tested, 16 were found in

the discharge

These 16 belongs to 5 chemical groups

These groups are: 1. Azo Dyes 2. Chlorobenzenes 3. Phthalates 4. SCCPs 5. Heavy Metals1

They were found at this many factories:

16

77 11 groups

93 analytes

No of factories

1. For Heavy Metals, Cadmium, Mercury, Lead and Chromium VI were tested. 3 out of 4 chemicals were found in the discharge. Chromium VI was not found.

2 6 5 6 10

Discharge verification results overview

11

5

Chemical Groups

FINDINGS AT WASTEWATER DISCHARGE

3

C: China B: Bangladesh I: India

Chemical Groups Detected

Chemicals

Average Concentration

(ppm) in Incoming Water

Average Concentration

(ppm) in Discharged Water

Average Actual

Concentration

(Discharge – Incoming)

C B I C B I C B I

Phthalates

BBP ND ND ND ND ND 0.0012 ND ND 0.0012

DBP 0.0050 ND 0.0032 0.2952 ND 0.0017 0.2902 ND -0.0015

DEHP 0.0275 ND 0.0025 0.0418 ND 0.0050 0.0144 ND 0.0026

DNOP ND ND 0.0040 ND ND ND ND ND -0.0040

DIDP ND ND ND ND ND 0.0022 ND ND 0.0022

DMP ND ND 0.0054 0.0647 ND 0.0014 0.0647 ND -0.0040

DEP 0.0011 ND 0.0014 0.0052 ND ND 0.0041 ND -0.0014

DIBP 0.0080 ND ND 0.0254 ND 0.0011 0.0174 ND 0.0011

DNP ND ND ND ND ND 0.0010 ND ND 0.0010

Azo Dyes

4-

Aminoazobenzene ND ND ND ND ND 5.3688 ND ND 5.3688

Aniline ND ND ND ND ND 0.2803 ND ND 0.2803

4-Chloroaniline ND ND ND ND 0.0008 ND ND 0.0008 ND

Chlorobenzenes

Chlorobenzene 0.0820 ND 2.1453 0.0514 ND 1.1790 -0.0305 ND -0.9660

Dichlorobenzene ND ND 0.0057 ND ND ND ND ND -0.0057

Trichlorobenzene ND ND 0.0001 ND ND ND ND ND -0.0001

SCCPs SCCPs 0.0314 0.0004 0.0098 0.0251 0.0011 0.0169 -0.0063 0.0007 0.0071

Heavy Metals

Cadmium (Cd) ND ND ND ND 0.0109 0.0001 ND 0.0109 0.0001

Lead (Pb) 0.0018 0.0145 0.0268 0.0028 0.0010 0.0158 0.0010 -0.0135 -0.0109

Mercury (Hg) ND ND ND 0.0001 ND ND 0.0001 ND ND

Results Analysis: i

COMPARISON BETWEEN INCOMING WATER & DISCHARGE WASTEWATER The chemicals detected in the wastewater could be originated from the incoming water of factories and/or manufacturing process. Therefore, the incoming water was also collected and subjected to chemical tests, from which the “background concentration” of the chemicals can be determined.

Chemical Concentration

higher at discharged wastewater

Chemical concentration

Higher at Incoming

Water

1. This is an indication only, based on results generated from this study. However, it is to note that these snapshot indications have also shown patterns, where concentrations of certain chemicals found were typically higher at the incoming source.

Indication1: There is a strong indication that Chlorobenzenes originates from the incoming water rather than

through manufacturing processes.

4

Cadmium Lead

Chlorobenzenes Phthalates

Comparison against: Results Summary: Overall Indication: See Graphs

1. WHO’s Tolerable Daily Intake

• When comparing the discharge data with WHO, all but DBP’s (Phthalates) chemical concentration were found lower than the recommended daily intake.

2. Drinking Water Legislative Requirements

• When comparing the discharge data with legislative requirements for drinking water, Mercury meets the requirements, the rest exceeds.

Results Analysis: ii

Result of Highest Concentration Discharge Wastewater

Vs.

Since all of the results detected are in traces, it can be difficult to put them into context. Therefore, the following strict, extreme comparisons were made to help illustrate this: 1. First comparison against the suggestive standard by the WHO1 on Tolerable daily Intake (TDI). 2. Second comparison against Drinking Legislative Requirements.

Drinking Water Suggestive/ Legislative Standards

Comparison against: Results Summary: Overall Indication See Graphs

3. Wastewater Legislative Requirement

• All discharge results meet the legislative requirement of Bangladesh, China and India2.

• However, some discharge results exceeded the legislative requirements of the EU, or US2.

Bangladesh, China, India

EU, USA

2. COMPARISON AGAINST WASTEWATER LEGISLATIVE STANDARDS

DBP

Mercury

Click Here

Click Here

Click Here

1. World Health Organization 2. Based on Available Data

5

PUTTING RESULTS INTO CONTEXT:

The intention of making these comparisons was not to illustrate how wastewater quality should be at drinkable standard, but rather, to illustrate how these results compare to drinkable quality. Results show that a lot of chemicals in fact meet the suggestive/ legislative standards2.

Heavy Metals, Chlorobenzenes

DIDP, DEHP, BBP

11 Verified

Traces of 5 Chemical

Groups found in discharge

1. AIM OF STUDY FULFILLED

All1 but DBP meets WHO’s

Tolerable Daily Intake

All3 discharge data meet local4

wastewater legislations

Some2 wastewater results meet

drinking water legislations

We acknowledge that the study

illustrates a snapshot only

This study provides a

clearer direction towards action

2. THE SITUATION

3. ACTION PLAN

(Action Plan: Next Page)

Conclusion

The aim of this study has been fulfilled where we found that 5 out of 11 chemical groups in traces, present in the discharge of factories. Out of these 5, strong indications show that 4 chemical groups originate from the manufacturing process. Chlorobenzenes however, has clearly shown higher concentrations in the incoming water when compared with the discharge wastewater. We have found that most1 wastewater results apart from DBP (one phthalate) meet the suggestive ‘Tolerable Daily Intake’. Some2 wastewater results meet drinking legislations. All3 wastewater results meet local4 wastewater legislations. We acknowledge that this report only provides a snapshot of the situation and does not reflect a picture of the entire industry, however, all findings and comparisons help provide us with a clearer picture towards how to move forward and set priority actions; i.e. address phase out (Project 02 of the Joint Roadmap).

1. Based on Available Data 2. Based on Available Data 3. Based on Available Data

4. Local meaning where the water was tested; Bangladesh, China and India

Chlorobenzenes originates from incoming water

Indications from data

Other 4 Chemicals originates from manufacturing processes

6

Action Plan

1. Monitor 2. Implement

2 Streams of Actions

Based on the results obtained, the action plan for coming projects will be divided into two directions, Monitoring and Implementing.

Although; • 6 chemical groups were not found in the discharged

wastewater; • Results for Chlorobenzenes indicate that the source is

mainly derived from the incoming water; We need to still acknowledge that this study only provides a snapshot of the situation, and that these chemicals might still be used in the manufacturing process. Therefore, continuous close monitoring of these 7 chemical groups are required to prevent the use of them in manufacturing processes. Not detected in discharge: 1. Brominated and Chlorinated flame retardants 2. Organotin Compounds (e.g., TBT) 3. Chlorinated Solvents 4. Chlorophenols 5. Alkylphenols (APs) & Alkylphenol Ethoxylates (APEOs) 6. Perfluorinated Chemicals (PFCs) Indications that source originates from incoming water (not manufacturing process): 7. Chlorobenzenes

For the four chemical groups generated from manufacturing process, specific actions needs to be implemented by different sectors, e.g., chemical suppliers, factories, and government, in order to reach the goal towards zero discharge of hazardous chemicals by 2020. Previous comparisons with suggestive and legislative requirements should be referred to when setting priority actions. This implementation process is described in our next project ‘Phase out’. This will include finding of sources to these chemicals and sequentially, phase them out. Detected in Discharge: 1. Azo Dyes 2. Phthalates 3. Short-Chained Chlorinated Paraffins (SCCPs) 4. Heavy Metals*

7 1. For Heavy Metals, Cadmium, Mercury, Lead and Chromium VI were tested. 3 out of 4 chemicals were found in the discharge. Chromium VI was not found.

Graphs to Results Analysis ii

1. Benchmark Results Vs. WHO suggested limits

*The WHO states that the Daily Intake (DI) level of a specific chemical must be lower than the Tolerable Daily Intake (TDI), which refers to the daily amount of a chemical that has been assessed safe throughout the lifetime.

2. Chlorobenzenes 3. Phthalates 1. Heavy Metals

0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50

BBP

DBP

DEHP

DIDP

0.00 0.05 0.10 0.15

Chlorobenzene

0.000 0.001 0.002 0.003 0.004

Cadmium (Cd)

Mercury (Hg)

Lead (Pb)

Meets Exceeds/ Meets Suggested Limits:

Meets Exceeds

DBP Meets DIDP, DEHP and BBP

mg/ kg mg/ kg mg/ kg

1. WHO (World Health Organization) suggested limits

Limitation: There is no data available for Azo Dyes and SCCPS.

TDI- Tolerable Daily Intake

Benchmark Results- calculated using WHO’s formula for Daily Intake

9

Back to Results Analysis ii

2. Chlorobenzenes 3. Phthalates

1. Heavy Metals

00.010.020.030.040.050.060.070.080.09

0.1

Cadmium Cr* Lead Mercury

0

0.5

1

1.5

2

2.5

Chlorobenzene0

0.01

0.02

0.03

0.04

0.05

0.06

0.07

DEHP

Exceeds

Exceeds

Exceeds

Meets Meets Exceeds/ Meets Legislation:

Legislative Requirement

EU

USA

Bangladesh

China

India

Benchmark Result

Benchmark Result (Highest Measured Concentration)

Exceeds EU, USA &

China

mg/

kg

mg/

kg

mg/

kg

2. Legislative Requirement for Drinking Water

Limitation: There are no legislative standards in all countries for Azo Dyes, SCCPs and all types of Phthalates.

There are no legislative standards in Bangladesh, India or EU for Chlorobenzenes.

Exceeds/ Meets Legislation:

10

Back to Results Analysis ii

3. Legislative Requirement for Wastewater Quality

0

0.01

0.02

0.03

0.04

SCCPs

0

0.2

0.4

0.6

0.8

1

Cadmium Chromium VI Lead Mercury

0

0.05

0.1

Cadmium Chromium VI Lead Mercury

0

0.02

0.04

0.06

0.08

DEHP

0

0.5

1

1.5

2

2.5

Chlorobenzene

Exceeds/ Meets Legislation:

Exceed/ Meet Legislation:

2. Chlorobenzenes 3. Phthalates

1. Heavy Metals

1. Heavy Metals

Meets Meets Meets Meets

Meets Meets Exceeds

in EU Exceeds Exceeds Exceeds Exceeds

4. SCCPs

mg/

kg

mg/

kg

mg/

kg

mg/

kg

mg/

kg

Limitation: There are no legislative standards in Bangladesh, China or India for Azo Dyes, Chlorobenzenes, Phthalates and SCCPS.

Limitation: There are no legislative standards in EU or USA for Azo Dyes and all types of Phthalates

Legislative Requirement

EU

USA

Bangladesh

China

India

Benchmark Result

Benchmark Result (Highest Measured Concentration)

11

Back to Results Analysis ii

Publication details

Contact Details C&A Alain Renard alain.renard@canda.com H&M Hennes & Mauritz AB Anna Eriksson annaE.eriksson@hm.com G-Star Raw Frouke Bruinsma frouke-bruinsma@g-star.com