Benetton Group srl 2018 Detox Programme Guideline

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1 Benetton Group srl 2018 Detox Programme Guideline

2 Table of contents PREMISES and DESCRIPTION... 2 ZDHC WASTEWATER GUIDELINES... 3 Benefits of the Wastewater Guidelines:... 3 What sampling is requested?... 3 DEFINITIONS... 3 FACTORY WASTEWATER TEST... 4 Water Sampling Methodology... 4 Water Sampling Analysis... 5 Data Reporting... 7 IPE (Institute of Public & Environmental Affairs) Disclosure... 7 HIGG INDEX FACILITY ENVIRONMENTAL MODULE (Higg FEM)... 7 SUMMARY

3 PREMISES and DESCRIPTION Benetton Group partners with Greenpeace through their DETOX PROGRAMME in a joint effort to lead the textile industry towards the complete elimination of hazardous chemicals from manufacturing. The complete text of BENETTON DETOX commitment is linked at: In line with its Detox commitment to achieve a zero discharge of 11 Priority Chemicals by 2020, Benetton joins the ZERO DISCHARGE OF HAZARDOUS CHEMICAL (ZDHC) group in which a group of international brands are cooperating to understand environmental performance of supply chain and to devise methodologies to minimize and eventually eliminate the priority chemicals. This program, named Joint Roadmap: Toward Zero Discharge of Hazardous Chemicals, is published at As many other members of ZDHC, starting from 2017 year, Benetton Group adopted the ZDHC Wastewater Guideline (available in the ZDHC website, Wastewater Quality section, at and invites its suppliers to follow it, respecting the Minimum Reporting Frequency, that is a semi-annual testing and reporting completed by April 30 and October 31 of each year, and with no less than three months between testing and reporting. In addition to the Wastewater Test, that the facility conducts by appointing a SERVICE PROVIDER, as new member of the Sustainable Apparel Coalition (SAC) and as many other brands are already doing, starting from 2018 Benetton Group is asking to all its suppliers to complete the Higg Index Facility Environmental Module (Higg FEM), that should be then verified by a SAC approved verifier. Therefore, the 2018 DETOX PROGRAMME consists of two parts: 1. Wastewater Analysis made by following the ZDHC Wastewater Guideline and 2. Sustainability Evaluation made by using the SAC s Higg FEM both carried out by the facility. 2

4 ZDHC WASTEWATER GUIDELINES The ZDHC Wastewater Guidelines is a single set of expectations on wastewater discharge that goes beyond regulatory compliance, not only for conventional wastewater parameters, but also for hazardous chemicals. The ZDHC Wastewater Guidelines was developed in collaboration with multiple brands, non-governmental organizations, universities, and technical experts. It aligns all ZDHC contributors to a unified set of expectations related to sampling, test methods, pass/fail criteria, testing frequency and disclosure. Benefits of the Wastewater Guidelines: The ZDHC Wastewater guidelines define equivalence between US, EU, and Chinese standard methods for traditional wastewater parameters, allowing laboratories in each region to use their own standard methods. The data obtained per the ZDHC Wastewater Guidelines will help confirm that the facility does not intentionally use chemicals on the ZDHC Manufacturing Restricted Substances List (MRSL). There are operational efficiencies to be realized if one test per the ZDHC Wastewater Guidelines is valid for all ZDHC Contributors using that shared facility. It is a milestone for facilities as its adoption will enable data sharing across multiple external organizations to an aligned set of parameters, test methods and limits. What sampling is requested? Wastewater discharged at the property line of the facility, and sludge produced from wastewater treatment operations. Or as an alternative, test raw, untreated wastewater. Incoming water supplied to the facility should be sampled at the same time, but only tested if hazardous chemicals are found above the reporting limits specified in the Wastewater Guidelines. DEFINITIONS Incoming Water (IW): Water that is supplied to a manufacturing process, usually withdrawn from surface water bodies, groundwater, or collected from rainfall. This includes water supplied by municipalities, and condensate obtained from external sources of process steam. Raw Wastewater Waste Water Before Treatment (WWBT): Wastewater that has not yet been treated prior to direct or indirect discharge from the facility, or prior to water recycling efforts. Sludge: The solids separated during the biological treatment of industrial or municipal wastewater. Wastewater Waste Water After Treatment (WWAT): Water no longer considered useable for a given operational purpose that is directly or indirectly discharged from the facility. 3

5 FACTORY WASTEWATER TEST The Factory Wastewater Test is based on the ZDHC Wastewater Guideline and, according to the sampling requirements (just described in the above section), it has to be made in wastewater and sludge or in the raw, untreated water. In other words, facility can choose one of the following options: Option 1: Wastewater + Sludge or Option 2: Raw, untreated wastewater Note that, even if it has to be sampled together (i.e., at the same time) with the other samplings, incoming water has to be tested only in case of hazardous chemicals are found in one of the two previous options. Moreover, note that: - Benetton is asking for Option 2 (see WATER SAMPLING ANALYSIS Section). - the facility is free to choose both options or only one of them. If the facility has recently (i.e., in the current year) performed the test by following the ZDHC requirements, it can provide to Benetton the already owned Test Report. Otherwise, the facility appoints an ISO Accredited Service Provider (ZDHC-accepted laboratories) to conduct water sampling and analysis by following the ZDHC Wastewater Guideline as reported in the following: Water Sampling Methodology Wastewater samples shall be collected as composite samples following ISO :2011 (Part 1, 3, 10, 13 and 15): Water Quality Sampling Guidance for the preservation and handling of water samples. To ensure representative samples, composite sampling should be performed for no less than six (6) hours, with no more than one hour between discrete samples. Each discrete sample shall be of equal volume. Sampling using calibrated auto-samplers is preferred, but in instances where national standards do not require auto-sampling, laboratory personnel collecting samples are expected to meet the requirements of national sampling standards. Samples shall be taken by qualified laboratory personnel. Laboratories performing sample collection must maintain a chain-of-custody log for each sample collected to ensure the integrity of the sample. In no circumstance shall samples be taken during times when the production process is not running or the wastewater is diluted due to heavy rainfall, etc. Suppliers are expected to allow for unannounced sampling by ZDHC-accepted laboratories. Incoming water may be a single grab sample. For facilities with multiple incoming water sources, a single grab sample from a common blend tank is acceptable. If no blend tank, one grab sample shall be collected from each incoming source. 4

6 Water Sampling Analysis The complete list of the chemical compounds to analyze is derived from 2016 ZDHC Wastewater Guideline and reported in the attachment named Limits and Test Methods for Targeted Wastewater Parameters. As noted in the ZDHC WASTEWATER GUIDELINES section, sampling of raw wastewater for testing ZDHC MRSL parameters is an alternative requirement by the brands, that is the reason why Benetton is asking for. Raw wastewater testing, in fact, will give further insights into the usage of ZDHC MRSL chemicals which may be diverted into the sludge during wastewater treatment. Chemical substances group to be tested in wastewater of a plant with ETP. PLANT WITH ETP Substances groups Incoming Raw Wastewater Treated Wastewater 1A. Conventional Parameters 1A. Conventional Parameters Temperature Temperature TSS TSS COD COD Total-N Total-N ph ph Color [m-1] (436nm; 526; 620nm) Color [m-1] (436nm; 526; 620nm) BOD5 N/A N/A BOD5 Ammonium-N Ammonium-N Total-P Total-P AOX AOX Oil and Grease Oil and Grease Phenol Phenol Colifrom [bacteria/100ml] Colifrom [bacteria/100ml] Persistent Foam Persistent Foam 1B. Anions 1B. Anions 1B. Anions Cyanide (CN-) Cyanide (CN-) Cyanide (CN-) Sulfide Sulfide Sulfide Sulfite Sulfite Sulfite 1C. Heavy Metals 1C. Heavy Metals 1C. Heavy Metals Antimony (Sb) Antimony (Sb) Antimony (Sb) Chromium (Cr), total Chromium (Cr), total Chromium (Cr), total Cobalt (Co) Cobalt (Co) Cobalt (Co) Copper (Cu) Copper (Cu) Copper (Cu) Nickel (Ni) Nickel (Ni) Nickel (Ni) Silver (Ag) Silver (Ag) Silver (Ag) Zinc (Zn) Zinc (Zn) Zinc (Zn) Arsenic (As) Arsenic (As) Arsenic (As) Cadmium (Cd) Cadmium (Cd) Cadmium (Cd) Lead (Pb) Lead (Pb) Lead (Pb) Mercury (Hg) Mercury (Hg) Mercury (Hg) Chromium VI (CrVI) Chromium VI (CrVI) Chromium VI (CrVI) 2A. Alkylphenol (AP) and Alkylphenol 2A. Alkylphenol (AP) and Alkylphenol 2A. Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs): including all isomers Ethoxylates (APEOs): including all isomers Ethoxylates (APEOs): including all isomers 2B. Chlorobenzenes and Chlorotoluenes 2B. Chlorobenzenes and Chlorotoluenes 2B. Chlorobenzenes and Chlorotoluenes 2C. Chlorophenols 2C. Chlorophenols 2C. Chlorophenols 2D. Dyes - Azo (Forming Restricted Amines) 2D. Dyes - Azo (Forming Restricted Amines) 2D. Dyes - Azo (Forming Restricted Amines) 2E. Dyes-Carcionogenic or Equivalent 2E. Dyes-Carcionogenic or Equivalent 2E. Dyes-Carcionogenic or Equivalent 2F. Dyes-disperse (sensitizing) 2F. Dyes-disperse (sensitizing) 2F. Dyes-disperse (sensitizing) 2G. Flame Retardants 2G. Flame Retardants 2G. Flame Retardants 2H. Glycols 2H. Glycols 2H. Glycols 2I. Halogenated Solvents 2I. Halogenated Solvents 2I. Halogenated Solvents 2J. Organotin Compounds 2J. Organotin Compounds 2J. Organotin Compounds 2K. Perfluorinated and Polyfluorinated 2K. Perfluorinated and Polyfluorinated 2K. Perfluorinated and Polyfluorinated 2L. Phthalates 2L. Phthalates 2L. Phthalates 2M. Poly Aromatic Hydrocarbons (PaHs) 2M. Poly Aromatic Hydrocarbons (PaHs) 2M. Poly Aromatic Hydrocarbons (PaHs) 2N. Volatile Organic Compound (VOCs) 2N. Volatile Organic Compound (VOCs) 2N. Volatile Organic Compound (VOCs) only in case of finding either in Raw Wastewater or in Treated Wastewater 5

7 Chemical substances group to be tested in wastewater of a plant without ETP. PLANT WITHOUT ETP Substances groups Incoming Raw Wastewater 1A. Conventional Parameters 1A. Conventional Parameters Temperature Temperature TSS TSS COD COD Total-N Total-N ph ph Color [m-1] (436nm; 526; 620nm) Color [m-1] (436nm; 526; 620nm) BOD5 N/A BOD5 Ammonium-N Ammonium-N Total-P Total-P AOX AOX Oil and Grease Oil and Grease Phenol Phenol Colifrom [bacteria/100ml] Colifrom [bacteria/100ml] Persistent Foam Persistent Foam 1B. Anions 1B. Anions Cyanide (CN-) Cyanide (CN-) Sulfide Sulfide Sulfite Sulfite 1C. Heavy Metals 1C. Heavy Metals Antimony (Sb) Antimony (Sb) Chromium (Cr), total Chromium (Cr), total Cobalt (Co) Cobalt (Co) Copper (Cu) Copper (Cu) Nickel (Ni) Nickel (Ni) Silver (Ag) Silver (Ag) Zinc (Zn) Zinc (Zn) Arsenic (As) Arsenic (As) Cadmium (Cd) Cadmium (Cd) Lead (Pb) Lead (Pb) Mercury (Hg) only in case of finding in Raw Mercury (Hg) Chromium VI (CrVI) Wastewater Chromium VI (CrVI) 2A. Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs): including all isomers 2A. Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs): including all isomers 2B. Chlorobenzenes and Chlorotoluenes 2B. Chlorobenzenes and Chlorotoluenes 2C. Chlorophenols 2C. Chlorophenols 2D. Dyes - Azo (Forming Restricted Amines) 2D. Dyes - Azo (Forming Restricted Amines) 2E. Dyes-Carcionogenic or Equivalent 2E. Dyes-Carcionogenic or Equivalent 2F. Dyes-disperse (sensitizing) 2F. Dyes-disperse (sensitizing) 2G. Flame Retardants 2G. Flame Retardants 2H. Glycols 2H. Glycols 2I. Halogenated Solvents 2I. Halogenated Solvents 2J. Organotin Compounds 2J. Organotin Compounds 2K. Perfluorinated and Polyfluorinated 2K. Perfluorinated and Polyfluorinated 2L. Phthalates 2L. Phthalates 2M. Poly Aromatic Hydrocarbons (PaHs) 2M. Poly Aromatic Hydrocarbons (PaHs) 2N. Volatile Organic Compound (VOCs) 2N. Volatile Organic Compound (VOCs) Regarding plants with no ETP, i.e. plants using a Common ETP (CETP), they should have at least an inspection point from which the samples can be picked, being considered as raw wastewater, coming out only from the production plant under evaluation. In this case, regarding Conventional Parameters (Table 1A), it could appear without any sense to test them: some of those parameters, in fact, are often related to environmental pollution and, logically, they should be tested after the Treatment Plant (either ETP or CETP). In case of a CETP, obviously, even supposing to find (in the treated water) values over the allowed limits, it will not be possible to identify which mill is causing the problem. For the same reason, usually the CETP management (e.g., the consortium, the municipality or whatever else ) settle the limits to be respected to discharge the raw wastewater to the CETP, otherwise accepting everything the CETP could be affected and damaged with consequent failure of the whole treatment process. This is the reason why, in the case of CETP, as per the below schema we suggest to test Conventional Parameters too. 6

8 Data Reporting Water Test Reports will be sent to Benetton that, after permission (i.e., Authorization to release information) from facility side 1, will publish them into its own website. Moreover, as described in the ZDHC WASTEWATER GUIDELINES, after permission from suppliers, test reports will be reported directly by ZDHC-accepted laboratories to ZDHC contributors via the ZDHC Gateway 2, making best use of available data standards. For any additional testing that may occur (beyond these guidelines), the facility is encouraged to upload the data to the ZDHC Data & Disclosure Platform. Note that, in order to optimize wastewater testing across the value chain, test report uploaded in ZDHC Data & Disclosure Platform might be shared with other industry organizations such as the Sustainable Apparel Coalition (SAC), the Outdoor Industry Association (OIA) and the Institute of Public & Environmental Affairs (IPE). Regarding the uploading in the ZDHC Gateway, there are two deadlines: all test report referring to wastewater analysis performed from November to April has to be uploaded by April 30, while all test report referring to wastewater analysis performed from May to October has to be uploaded by October 31. IPE (Institute of Public & Environmental Affairs) Disclosure When explicitly requested, water test data have to be disclosed into the IPE DETOX website ( HIGG INDEX FACILITY ENVIRONMENTAL MODULE (Higg FEM) The Higg Facility Environmental Module (Higg FEM) is a sustainability assessment tool that standardizes how facilities measure and evaluate their environmental performance, year over year. The Higg FEM is designed to: Measure and quantify the sustainability impacts of a facility Reduce redundancy in measuring and reporting sustainability performance Drive business value through reducing risk and uncovering efficiencies Create a common means and language to communicate sustainability to stakeholders. The Higg Facility Environmental Module can be considered as: 1. A facility-level self-assessment tool that enables rapid learning through identification of environmental sustainability hot spots, existing level of performance and improvement opportunities. 2. A starting point of engagement, education, and collaboration among stakeholders in advance of more rigorous assessment efforts. The ultimate goals of the Higg Index are to inform organizations of their strengths and weaknesses, drive business value throughout the value chain by presenting opportunities for cost-savings and innovation, and catalyze sustainability education and collaboration. 1 The permission needs to be signed only once. If the facility has already signed it in the past and no any data is changed, there is not any need to sign it again. 2 For information and updating please refer to ZDHC website ( 7

9 The facility should complete and post one Higg FEM per year and share, within the Higg platform, its module with Benetton. The Benetton s Higg Account Name is Benetton Group S.r.l. The reporting period for the Higg FEM runs every year from January 1 to May 31 and refer to data of the previous year. All modules must be posted by the May 31 deadline. Within the FEM, in the Wastewater/Effluent Section, there is mention of various industry standards, such as the ZDHC Wastewater Guideline. In particular, even if it is not a mandatory requirement for the FEM, the lacking of any wastewater standard to report will penalize the final score of the facility. This is the reason why Benetton invites all the suppliers to perform the Wastewater test by themselves. Kindly note that since the FEM is a self-assessment, to have a legal force it has to be verified by a SAC approved verifier, appointed by the facility. Verification can be made within a limited period, usually from February to October, following the submission of the annual FEM. For more information about the Higg FEM please refer to howtohigg.org. SUMMARY The Benetton Detox Programme can be then summarize as follow: BENETTON DETOX PROGRAMME what to do how to do when how often Wastewater analysis Sustainability evaluation by appointing an ISO certified Laboratory and by following ZDHC WW Guideline self-assessment using the HIGG FEM + verification made by appointing a SAC approved verifier anytime within the calendar year self-assessment: from January to May verification: from February to October 1 or 2 times per year 1 time per year 8