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C99 Environmental, Chemical and Factory Minimum Standards for Dyeing, Printing and Finishing Clothing and Textiles
November 2006
Replaces ECOP Issue No. 5 dated September 2004

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

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What you will find in this document

An explanation of our corporate policies and general requirements relating to worker safety, environmental compliance and customer safety, and why they are important to us. Step by step guidance for supplier compliance. Details of our minimum standards requirements. A simple, one-page Self Audit document to demonstrate compliance (also available as a separate word document). A table containing all necessary information regarding chemicals that we must eradicate or control (including test methods and permitted limits). Explanatory notes to give guidance on selection of dyes and chemicals to ensure compliance. Several appendices - containing detailed lists of controlled chemicals, information on who is responsible for meeting the minimum standards and detailed best practice to meet minimum standards.

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These standards apply to: Dyehouses Printworks Finishing Facilities Laundries Tanneries The Chemicals used within them The Products they produce
Facilities that process products with Marks & Spencer labels attached will also require a social compliance audit. Additional componentry such as zips, threads and interlinings must comply with the standards relating to chemicals on finished product and the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied. Although chemical use is limited in knitting, weaving and garment making facilities the principles of worker safety, environmental compliance and responsible chemical usage detailed in this document should be applied.

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

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What Next? How to demonstrate compliance: 1. 2. 3. 4. 5. 6. 7. 8. Confirm receipt of this document to Colour.Management@marks-and-spencer.com stating your company name, the nature of your business, the garment/product maker and M&S departments you are supplying Read all the information in this document including appendices Select dyes from suppliers compliant dyes and chemicals list or get confirmation from suppliers that dye and chemical inventory complies with these minimum standards. Gather information regarding effluent, discharge and disposal consents and recent test results to confirm compliance. Ensure factory meets minimum standards for worker safety and QA procedures. Carry out risk-based checks on raw materials and finished product to confirm compliance. Complete Minimum Standards Self Audit form (available as stand alone document on Quality Standards website and send to Colour.Management@marks-and-spencer.com as a Word document or fax to +44 20 87187725. Please do not send scans with file size > 0.5 Mb. Read and follow best practices in Appendix 2 to build ongoing compliance into normal working procedures.

How Marks & Spencer Monitors Compliance with Minimum Standards Worker Safety and Quality Systems Site-visit by garment/product manufacturers or Marks & Spencer personnel is required to verify self audits. Failures will be addressed by either action plans for minor discrepancies, or termination of business for severe failures. Environmental on site visits by Marks & Spencer personnel or independent environmental auditor to verify self audits. Chemicals on Product Risk based product testing. Failures will need to be discussed with Marks & Spencer and will result in either an action plan for eradication or products being removed from stores depending on the circumstances. Chemical testing may be demanded at the time of technical submission by Marks & Spencer technologists.
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Minimum Standards Policy

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

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

Chemicals on Garments/Product
Marks & Spencer will not sell products if The chemical content renders them illegal or harmful to customers. Anyone in the supply base has broken any laws regarding the use or disposal of specific chemicals. Anyone in the supply base has wilfully failed to adhere to our policies regarding the use or disposal of specific chemicals.

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

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Minimum Standards Detail

Factory / Worker Safety
All fire exits must be marked, unlocked and not obstructed Adequate and appropriate fire fighting equipment must be available and be clearly marked and accessible No smoking in working areas of factory No eating or drinking in areas where dyes or chemicals are handled Housekeeping, building construction and working environment must be to a standard that does not compromise worker safety Working dye and chemical stores must be indoors, dry and tidy An authentic material safety data sheet for every dye and chemical must be available in the local language in the vicinity of where dyes and chemicals are handled Dyes and chemicals must be labelled and stored in accordance with detailed information in the MSDS Appropriate personal protective equipment must be worn All machines must be electrically and mechanically safe Factory must comply with local health, safety and employment law

Environment
Untreated effluent must not be discharged directly into water courses Water must be treated on-site, in a communal water treatment plant or by a local authority water treatment plant Measures must be taken to avoid emission of noxious fumes into the air from stored chemicals and solvents, textile processing, utilities (steam production, generators etc) or incineration of waste Solid waste must be disposed of according to local government recommendations and regulations Packaging must be disposed or recycled in accordance with local legislation The natural balance of the surrounding area should not be disturbed e.g. over-abstraction of water Suppliers must demonstrate ongoing compliance with local government discharge and emission (consent) limits. Although we do not have any specific standards regarding water and energy consumption we do expect suppliers to take all reasonable steps to minimise wastage. The major source of wastage is the inability to meet standards without re-dyeing or refinishing.

Chemicals on Garments/Product
The following chemicals must not be deliberately used and must not be present on final product at concentrations above those specified Banned Azo dyes 30 ppm Skin sensitising dyes 30 ppm Apeos 1000 ppm Organo Tin 0.05 ppm PCPs 0.05 ppm Mercury 2 ppb Moth-proofing 10 ppm PFOS 1 ppm 1 ppm PFOA Carriers 1 ppm Processes using the following chemicals must only be used with written consent of a Marks & Spencer technologist and must not be present at concentrations above those specified: Chromium VI 3 ppm Organic Solvents limit of detection The following chemicals are only permitted above the specified concentrations if their use has been authorised by Marks & Spencer Biocidal Finishes see table p.9-12 Applied Flame Retardants 5 ppm PVC / Phthalates see table p.9-12 The following chemicals must not be present above the specified concentrations: Formaldehyde 75 ppm (free), 300 ppm (released) Pesticides/Insecticides 0.5 ppm (wool), 0.05 ppm (cotton) See chemicals on finished product table for detail additional detail for leather and childrens wear

QC Systems
All dyes and chemicals must be accurately weighed or measured (not approximated using scoops etc) Scales must be clean, dry and calibrated Must have an Indoor greige area that is clean, dry and tidy Written procedures must be available for all processes Batch cards must accompany every batch of production Must have light box and basic QC tests on-site Records of colour continuity and test results must be kept for every batch Raw materials must be checked, finished production must be examined prior to dispatch and records must be kept Must have access to Marks & Spencer quality standards website

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Minimum Standards Self Audit Please see Quality Standards website for stand alone document in Word format.
Factory / Worker Safety
All fire exits are marked, unlocked and not obstructed Adequate and appropriate fire fighting equipment is present in all areas of factory and is clearly marked and accessible No smoking in working areas of factory No eating or drinking in areas where dyes or chemicals are handled Housekeeping, building construction and environment is to a standard that does not compromise worker safety Dye and chemical stores are indoors, dry and tidy A material safety data sheet for every dye and chemical is available in the local language in the vicinity of where dyes and chemicals are handled Dyes and chemicals are labelled with appropriate safety clauses and stored in accordance with MSDS information Appropriate personal protective equipment and closed shoes are worn as detailed in the MSDS All machines have been checked and are electrically and mechanically safe The company complies with local health, safety and employment legislation Effluent pass rate for past 12 months pH COD BOD Suspended Solids Temperature Metals Toxins / Restricted substances No. of Tests %

Environment
Production volume for past 12 months (tonnes) % of batches topped up, re-dyed or refinished Confirm no breaches of air emission consent limits in previous 12 months Confirm all solid waste is disposed in accordance with local government recommendations Untreated effluent is not discharged directly into water courses

Chemicals on Garments/Product
All dye and chemical suppliers have confirmed that their products being used for M&S production meet these minimum standards Please confirm that the following chemicals are not knowingly applied or brought in via raw materials at concentrations above those stated in the Marks & Spencer minimum standards Banned azo dyes Skin sensitising dyes APEO's Organo tin PCP's Mercury Moth proofing PFOS based fluorocarbons PFOA containing fluorocarbons Carriers Pesticides / Insecticides

Any additional information:

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

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

Not Used

Used by Consent

Scales are clean, dry and calibrated Indoor greige area Written procedures for all processes Batch cards accompany every batch of production Capable of basic QC tests on-site
Records of colour continuity and test results kept for every batch

Chromium VI Organic Solvents PVC Phthalates Biocidal Finishes FR Finishes

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

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Chemicals on Finished Product

Chemical
Banned Azo dyes No deliberate use

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

All fibre types

What is the origin of the controlled chemical?

Banned amines listed in appendix 7. Examples of dyes that can form such amines listed in appendix 6 Disperse Dyes listed in appendix 8

Why is it nasty?
Dyes can split to form carcinogenic amines

Retail legal status

Sale of products containing > 30 ppm is illegal

Supply base legal status

Use of products containing > 30 ppm is illegal

Acceptable limit on finished product

30ppm

Limit of Detection
10 ppm

Test method
Textiles: C62a (refers to EN 14362 part 1 and 2) Leather :C62b (CEN ISO/TS 17234:2003) DIN 54231

Skin Sensitising Dyes No deliberate use Alkyl phenyl ethoxylates (APEO's) No deliberate use APEO notes Organo tin compounds. No deliberate use

PCP pentachlorophenol and derivatives No deliberate use Mercury No deliberate use

1 ppm C65 1000 ppm* Use of temporary formulations GCMS or LCMS standard containing over 0.1% of NPEO is illegal in Europe NPEO (nonyl phenyl ethoxylate) is the APEO that causes greatest concern. It is anticipated that legislation regarding its use will harmonise worldwide and we will then lower the standard. Current EU legislation is Marketing and Use Directive 2003/53/EC 0.05 ppm 0.05 ppm Textiles: Solvent Use is effectively could be governed Tributyl tin is All fibre types Preservative for (in extract) extraction + gcms prohibited via by biocidal highly toxic and fabrics and chemical (in-house methods) water authority substances related products formulations. Leather: SATRA regulations directive have toxicity issues Occasionally used as TM277 stabilizers and catalysts 0.1ppm Textiles: water/steam 0.05ppm Use is effectively Highly Toxic could be governed Cotton, Viscose Preservative for distillation (in-house (in extract) prohibited via by biocidal cotton and viscose. methods) water authority substances Main risk is on Leather: EN TS Leather 0.5ppm regulations directive imported greige 14494:2003 2 ppb 2 ppb Any appropriate Use is effectively Cotton Caustic soda that is Highly toxic could be governed technique e.g. prohibited via made by the 'mercury by biocidal Combustion water authority cell process' substances amalgamation with regulations directive cold vapour detection In widespread use as detergents, Wetting agents and as emulsifying agents No Legal restriction

Polyester, Acetate, disperse-dyed nylon All fibre types

Once sensitised to a dye people can react violently to trace quantities Endocrine disruptors (sex change chemicals) for aquatic species

No Legal restriction

No Legal restriction

30 ppm (2 ppm in extract)

2 ppm

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What M&S products are most likely to be affected?
Wool, (Cashmere, Angora) All fibre types

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What is the origin of the controlled chemical?
Commonest chemical is permethrin - found on wool and cashmere Water-repellent 8chain fluorocarbon finishes based on electrofluorination (old generation Products) Water-repellent finishes based on telemerisation

Chemical
Mothproofing No deliberate use PFOS No deliberate use

Why is it nasty?
Nerve agent and toxic to aquatic species proven health risks and persistent in the environment

Retail legal status

No Legal restriction

Supply base legal status

Use is effectively prohibited via water authority regulations No Legal restriction

Acceptable limit on finished product

Contamination limit 10ppm

Limit of Detection
1 ppm

Test method
Analytical -HPLC

Legislation restricting PFOS has been proposed

1 ppm (in extract)

1 ppm

solvent extraction + lc-ms

PFOA No deliberate use PFOA notes Dye Carriers No deliberate use

All fibre types

No Legal No Legal 1 ppm 1ppm solvent extraction + Persistent in the restriction restriction (in extract) lc-ms environment and suspected health risks PFOA (perfluorooctanoic acid) is used in the manufacture of the building blocks for fluorocarbons that are applied to textiles. Users of fluorocarbon finishes should get written confirmation from the manufacturer that traces of PFOA and materials that can theoretically form PFOA have been minimised. Used to dye polyester and blends at low temperatures in machinery not capable of being pressurised Chromium compounds used in 2-stage 'after-chrome' wool dyeing Used in some adhesives, print formulations, solvent scouring and spot cleaning Various depending on type of carrier generally toxic, irritants or carcinogens No Legal restriction Some chemical types are prohibited 1 ppm For halogenated aromatic hydrocarbons, trichlorobenzene, biphenyl or ortho phenyl phenol 3 ppm Leather 10ppm 1 ppm solvent extraction gcms

Polyester

Chromium VI. Consent Required

Wool, (Cashmere, Angora)

Highly toxic / carcinogenic both to humans and aquatic species Various depending on type of solvent

No Legal restriction

Organic solvents Consent Required

Panel Printed or solvent-scoured fabrics

Some solvents are restricted

Large scale use is effectively prohibited via water authority regulations Some solvents are banned - e.g. ozone depleting substances, carcinogens

3 ppm CEN 14495 = 10ppm Varies according to chemical type

Textiles: C60 (refers to BS 6810) Leather: CEN/TS 14495:2003 GCMS + Head Space

Limit of detection

Organic solvent notes

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

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

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What is the origin of the controlled chemical?
Deliberate application

Chemical
Biocidal Finishes Consent Required Not permitted in Childrenswear Biocidal finish notes Flame retardants Consent Required Not permitted in Childrenswear Flame retardant notes PVC Consent Required Not permitted in Childrens clothing Phthalates Consent Required for PVC Not permitted in Childrens clothing PVC and Phthalate notes Formaldehyde Not permitted in Childrens underwear or any babywear Pesticides / Insecticides

Why is it nasty?
Toxic

Retail legal status

Some chemical types are restriced

Supply base legal status

Acceptable limit on finished product

Limit of Detection

Test method

varies Analytical - HPLC Limit of detection Some chemical according to types are restricted unless agreed in type writing by by water technologist authorities Biocidal finishes must be permanent, non-leaching, work only on the fabric and not on customers skin and must not be implicated in antibiotic resistance. Biocidal finishes should not be confused with odour absorbers such as cyclodextrins or Dew White. Deliberate application

Cotton

5 ppm solvent extraction + Certain chemical 5ppm for penta-, Performance is Depends on exact gc-ms or lc-ms types are restricted hexa- and octa governed by chemistry - Toxic, brominated legislation. Certain not biodegradable biphenyl ethers chemical types are and suspected restricted health risks Flame retardant finishes should only be applied where there is a legislative need with written consent from M&S. Penta, Hexa and Octa brominated types must not be deliberately applied and must not be present above 5 ppm. Suppliers using Deca brominated types should follow VECAP best practice http://www.bsef.com/product_stew/vecap/ No Legal Strict controls on Qualitative test qualitative C64 - qualitative Deliberate use Not biodegradable, Mock leather restriction disposal (Belstein test) releases dioxins on and plastisol then/or FTIR for combustion prints. Sequins confirmation Used to soften rigid PVC Suspected sex change chemicals /suspected carcinogen 1000 ppm for the 6 legislated phthalates 1 ppm C61 Solvent extraction + GCMS

No Legal 6 phthalates now restriction at illegal in certain present articles in Europe restrictions Directive expected 2005/84/EC It is essential that all suppliers who are using PVC based products familiarise themselves with, and comply banned above 1000ppm in all childcare articles and toys. DINP, DIDP and DOP are banned above 1000ppm can be mouthed. No Legal Controls on Known irritant to Resinated Naturally occurring restriction workplace skin and mucous Cotton and but most commonly airborne quantities membranes. Viscose found in resinated Recently products (and in reclassified as lower levels in fixing carcinogen by agents for cotton and WHO nylon) Selected chemicals Strict controls on Wool (and Used to protect sheep Toxic are banned under effluent lower levels on and cotton crops from POP convention cotton) parasite infestation. See appendix 5 PVC mock leather and plastisol prints

with the current M&S PVC policy. DEHP, DBP and BBP are in articles that are intended for children under 36 months and Free and hydrolysable 75ppm Released 300ppm Babywear 20ppm Total 0.5ppm for wool Total 0.05ppm for cotton 0.05 ppm Analtyitcal HPLC or GCMS Background levels are approx 20 ppm Textiles:C18B and C18C Leather: EN ISO TS 17226 HPLC

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

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What is the origin of the controlled chemical?
Deliberate application

Chemical
Chlorine based bleach

Why is it nasty?
Toxic in high concentrations. Concerns over AOX formation in effluent Toxic

Retail legal status

No Legal restriction

Supply base legal status

No Legal restriction. May form AOX in effluent and these are controlled Strict controls on effluent Strict controls on effluent

Acceptable limit on finished product

No limit specified Best practice is to use peroxide based systems 0.5 ppm

Limit of Detection
N/A

Test method

Cadmium

Nickel See nickel policy Heavy Metals

Various including components Various including components Various including components Denim

Used in pigments, alloys, some dyes and some fibres Present in some green and turquoise dyes Used in pigments, alloys, some dyes and some fibres Used as a localised bleaching agent usually as a spray Used as an additive for softening water

EN 71 + Cadmium directive See nickel policy

0.5ppm

Solvent extraction methods - MS Nickel Release EN 1811

Allergenic

Toxic

EN 71

Strict controls on effluent

Dyes best practice Metal components see nickel policy Antimony 2 ppm Arsenic 1 ppm Lead 1ppm Best Practice to use permanganate free process No limit specified

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

Potassium Permanganate Some Sequesterants e.g. EDTA

Toxic for workers

No Legal restriction No Legal restriction

No Legal restriction Some restriction on some products eg EDTA

All products

Can upset the balance of water courses

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

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Marks & Spencer Dye and Chemical Selection Avoidance of non-compliance

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With the exception of some contaminants that are brought in on raw materials most chemical safety and environmental issues are caused by the dyes and chemicals that are deliberately used for the manufacture of products. Dyehouses, printers, finishers, laundries and tanneries must take care to select products that do not harm textile workers, the environment or Marks & Spencer customers. To minimise the risk of non-compliance Marks & Spencer recommend that dyes from ETAD member companies are used. ETAD member companies work to a voluntary code of conduct to minimise the negative health and environmental effects arising from the manufacture and use of dyes and pigments. (member companies in appendix 5 or www.etad.com). There are however several reputable dye manufacturers and distributors who have declined ETAD membership and there is no analogous organisation for textile chemicals. With this in mind Marks & Spencer are developing a directory of dyes and chemicals that meet the minimum standards laid out this document to minimise the risks to customers, textile workers and the environment. All worldwide dye and chemical suppliers will be able to register their compliant chemicals free of charge under a self certification arrangement. (Contact phil.patterson@marks-and-spencer.com for details). An up-to-date list is available on the Quality Standards website. Ultimately it is expected that production for Marks & Spencer will have to use these registered chemicals otherwise finished products will have to be subjected to exhaustive chemical compliance tests.

Compliant dyes and chemicals Products selected from the following lists will not give rise to non-compliance if applied appropriately.
Dystar dyes and pigment formulations in brochure format (ref 09.0047-00) or at www.dystar.com. Ciba dyes and chemicals at www.cibasc.com. Clariant dyes and chemicals at www.clariant.com. CHT Chemicals at www.cht-group.com. Magna print and speciality chemicals at www.magnacolours.com Basf chemicals at www.basf.com

Childrenswear Panel Prints

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

Magna Zydex

Print Kimya CHT

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Appendices
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. General Requirements why we impose minimum standards. Best practice. Who is responsible for managing compliance with minimum standards? Managing failure. ETAD member companies. Banned Amines. Examples of dyes that can cleave to form banned amines. Skin sensitising dyes. Pesticides / Insecticides. Chemicals of concern. Test methods and techniques. Kidswear requirements.

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Appendix 1 General Requirements Factory / Worker Safety

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

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

Chemicals on Garments/Product
Dyes and chemicals are essential to produce saleable products but we do have a duty to ensure that our customers, and workers involved in manufacture, are not exposed to risks arising from their use. We control (and test for the presence of) the chemicals specified in this document for the following reasons: It is illegal to sell merchandise containing certain chemicals above specified levels. Certain chemicals, although legal in terms of use and sale, are known to be harmful to customers and workers involved in the manufacture of our products In certain parts of the world there are laws regulating the use/disposal of certain chemicals above specified levels. Although it is legal for us to sell the final product, detection of such chemicals indicates that they have been used at some stage of manufacture.

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

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

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Appendix 2 Best Practice

Factory / Worker Safety
Health and safety policy from the CEO. Appoint trained safety and fire officer. Individual training for all factory workers. Inter-departmental auditing within a factory. Selection of safest form of dyes and chemicals (liquids, low dusting powders) Use engineering controls to minimise exposure to harmful chemicals. Reduced impact of manual handling. Planned maintenance of machinery.

Environment
Environmental policy from CEO on display. Appoint environmental officer. Put in place an environmental management system Training for all workers on chemical knowledge. Display performance indicators in all areas of factory (details of licences, breaches of consent, energy and water consumption). Display cost benefits of reduced re-dye / refinish with respect reduced water and energy consumption.

Chemicals on Product
Chemical policy from CEO. Formalised risk assessment of all dyes and chemicals used on site. Single point accountability for dye and chemical inventory. Up to date inventory of all dyes and chemicals with supporting MSDS (including locally purchased process chemicals). Do not buy chemicals from companies who refuse to supply MSDS. Letters of ECOP-compliance for all chemicals from their manufacturer. Formalised due diligence programme for incoming raw materials, dyes and chemicals. Formalised due diligence programme for outgoing production.

Further information at www.hse.gov.uk QC Systems Quality policy from CEO Appoint quality assurance manager Systems for checking consistency of water and raw materials Work to standard operating procedures Use examination department and labs to collect information not just to pass/fail Visual display of quality indicators for all areas Visual display of cost of non-conformance

ISO 14001 is a very good indicator of environmental competence. Bluesign technologies ag are leaders in the field of environmental compliance and resource management. Suppliers will benefit from a full factory and chemical inventory audit by bluesign's experts and their recommendations will invariably lead to lower costs due to improved efficiency and productivity as well as reduced risk of noncompliance. http://www.bluesign-tech.com

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

ISO 9001 gives some measure of competence.

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

Factory / Worker Safety
Self Audit is the minimum requirement before orders are placed. Garment/product manufacturer assessment is required by time of first production (It is recommended that all garment suppliers have a technical resource capable of managing compliance where Marks & Spencer have agreed to place business with suppliers who lack this resource the Marks & Spencer technologist is responsible for factory audit). Marks & Spencer technologists reserve the right to visit any production facility at any time. Dyeing and finishing specialists will also take cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.

Environment
Self audit to report on meeting local consent limits. Marks & Spencer reserve the right to carry out or commission a detailed environmental audit (at our cost) to check raw data used for self audit.

Chemicals on Product
Dyer, printer or finisher is responsible for collating data on raw materials, dyers and chemicals. Dyer, printer or finisher is responsible for selecting dyes and chemicals to comply with Marks & Spencer requirements. Dyer, Printer or Finisher to decide with garment maker at pre-production what is required and who is responsible for compliance testing. Garment maker to carry out additional due diligence checks risk assessment in collaboration with Marks & Spencer Dyeing and Finishing Specialists. Marks & Spencer to carry out due diligence checks.

QC Systems
Self Audit is the minimum requirement before orders are placed. Garment/product manufacturer assessment is required by time of first production. Marks & Spencer technologists reserve the right to visit any production facility at any time. Dyeing and finishing specialists will also take cognisance of respected 3rd party reports e.g. major dye and chemical suppliers.

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Appendix 4 Managing Failure

Factory / Worker Safety
Compliance with minimum standards must be demonstrated before production commences.

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

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

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

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

Albion Colours Ltd Aliachem a.s. ATUL Limited Avecia Ltd BASF AG BASF Corporation Bezema AG Cappell Pigments n.v. Carey Industries Inc. Ciba Speciality Chemicals Corporation Ciba Speciality Chemicals Inc. Clariant (Schweiz) AG Clariant Corporation Dainichiseika Dainippon Ink & Chemicals Inc. Dystar L.P. Dystar Textilfarben GmbH & Co. Deutschland KG E C Pigments Everlight Chemical Ind. Corporation Everlight USA Inc. Francolor Pigments SA Heubach GmbH Hodogaya Chemical Co Ltd Kyung-In Synthetic Corporation Lanxess Lanxess Corp M Dohmen GmbH Mike Dyes Works Ltd. Mitsubishi Chemical Corporation Nippon Kayaku Co Ltd. Oh Young Ind. Co. Ltd. Oriental Giant Dyes & Chemical Ind. Corporation RIFA Ind. Co. Ltd Rohm & Haas Company Sanyo Color Works Ltd Sensient Colours Inc. Sestas Kimya Sanayi A.S. Stahl International b.v. Sun Chemical A/S T&T Industries Corporation Tennants Textile Colours Limited TFL Ledertechnik Gmbh & Co. KG Thai Ambica Chemicals Co., Ltd Toyo Ink Mfg. Co. Ltd (formerly Bayer)

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Appendix 6 Aromatic Amines Specified in EC 2002/61

CAS Number
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 92-67-1 92-87-5 95-69-2 91-59-8 97-56-3 99-55-8 106-47-8 615-05-4 101-77-9 91-94-1 119-90-4 119-93-7 838-88-0 120-71-8 101-14-4 101-80-4 139-65-1 95-53-4 95-80-7 137-17-7 90-04-0 60-09-03 612-035-00-4 611-088-00-4 612-091-00-X 612-099-00-3 612-078-00-9 612-051-00-1 612-068-00-4 612-036-00-X 612-041-00-7 612-085-00-7 612-022-00-3 611-006-00-3

Index Number
612-072-00-6 612-042-00-2

EC Number
202-177-1 202-199-1 202-441-6 202-080-4 202-591-2 202-765-8 203-401-0 210-406-1 202-974-4 202-109-0 204-355-4 204-358-0 212-658-8 204-419-1 202-918-9 202-977-0 205-370-9 202-429-0 202-453-1 205-282-0 201-963-1 200-453-6

Substances
Biphenyl-4-ylamine 4-aminobiphenyl xenylamine Benzidine 4-chloro-o-toluidine 2-naphthylamine o-aminoazotoluene 4-amino-2, 3-dimethylazobenzene 4-o-tolylazo-o-toluidine 5-nitro-o-toluidine 4-chloroaniline 4-methoxy-m-phenylenediamine 4,4-methylenedianiline 4,4-diaminodiphenylmethane 3,3-dichlorobenzidine 3,3-dichlorobiphenyl-4,4-ylenediamine 3,3-dimethoxybenzidine o-dianisidine 3,3-dimethylbenzidine 4,4-bi-o-toluidine 4,4-methylenedi-o-toluidine 6-methoxy-m-toluidine p-cresidine 4,4-methylene-bis-(2-chloro-aniline) 2,2-dichlor-4,4-methylene-dianiline 4,4-oxydianiline 4,4-thiodianiline o-toluidine 2-aminotoluene 4-methyl-m-phenylenediamine 2,4,5-trimethylaniline o-anisidine 2-methox aniline 4-amino azobenzene *no test available

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Appendix 7 Examples of Dyes which Potentially Cleave to form Aromatic Amines (listed in Appendix 6) under reducing conditions
CI Acid Orange 45 CI Acid Red 24 CI Acid Red 85 CI Acid Red 114 CI Acid Red 115 CI Acid Red 128 CI Acid Red 148 CI Acid Red 158 CI Acid Red 167 CI Acid Red 265 CI Acid Black 29 CI Acid Black 209 Azoic Diazo Component 12 Basic Brown 4 (= Solvent Brown 12) Developer 14 (=Oxidation Base 20) Direct Yellow 1 Direct Yellow 24 Direct Yellow 48 Direct Orange 1 Direct Orange 6 Direct Orange 7 Direct Orange 8 Direct Orange 10 Direct Orange 108 Direct Red 1 Direct Red 2 Direct Red 7 Direct Red 10 Direct Red 13 Direct Red 17 37105 21010 76035 22250 22010 23660 22370 23375 23380 22130 23370 29173 22310 23500 24100 22145 22155 22150 18129 22195 16140 22245 23635 27200 24125 26665 20530 Direct Red 21 Direct Red 22 Direct Red 28 Direct Red 37 Direct Red 39 Direct Red 44 Direct Red 46 Direct Red 62 Direct Red 67 Direct Red 72 Direct Violet 1 Direct Violet 12 Direct Violet 21 Direct Violet 22 Direct Blue 1 Direct Blue 2 Direct Blue 3 Direct Blue 6 Direct Blue 8 Direct Blue 9 Direct Blue 10 Direct Blue 14 Direct Blue 15 Direct Blue 22 Direct Blue 25 Direct Blue 35 Direct Blue 76 Direct Blue 151 Direct Blue 160 23560 23565 22120 22240 23630 22500 23050 29175 23505 29200 22570 22550 23520 22480 24410 22590 23705 22610 24140 24155 24340 23850 23790 24280 23790 24145 24411 24175 Direct Blue 173 Direct Blue 192 Direct Blue 201 Direct Blue 215 Direct Blue 295 Direct Green 1 Direct Green 6 Direct Green 8 Direct Green 8.1 Direct Green 85 Direct Brown 1 Direct Brown 1:2 Direct Brown 2 Direct Brown 6 Direct Brown 25 Direct Brown 27 Direct Brown 31 Direct Brown 33 Direct Brown 51 Direct Brown 59 Direct Brown 79 Direct Brown 95 Direct Brown 101 Direct Brown 154 Direct Brown 222 Direct Black 4 Direct Black 29 Direct Black 38 Direct Black 154 30387 30045 30110 22311 30140 36030 31725 35660 35520 31710 22345 30056 30145 31740 30120 30368 30245 22580 30235 24115 23820 30280 30295 30315

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

CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI CI Disperse Blue Disperse Blue Disperse Blue Disperse Blue Disperse Blue Disperse Blue Disperse Blue Disperse Blue Disperse Yellow Disperse Yellow Disperse Yellow Disperse Yellow Disperse Yellow Disperse Orange Disperse Orange Disperse Orange Disperse Orange Disperse Red Disperse Red Disperse Red Disperse Brown 1 3 7 26 35 102 106 124 1 3 9 39 49 1 3 37 76 1 11 17 1

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Appendix 9 Pesticides / Insecticides

Cotton and Natural Cellulosic Fabrics; Blends of these with Other Fibres Maximum Limits for each Product Listed - 0.05 ppm Aldrin Captafol Chlordane DDT Dieldrin Endrin Heptachlor Hexachlorobenzene Hexachlorocyclohexane (total Isomers) 2,4,5,T 2,4 D Chlordimeform Chlorobenzilate Dinoseb (and its salts) Monocrotophos Wool and Other Keratin Fabrics; Blends of these with Other Fibres The Sum Total should Not Exceed 0.5ppm Alpha-Hexachlorocyclohexane Beta-Hexachlorocyclohexane Gamma-Hexachlorocyclohexane Lindane Aldrin Endrin Dieldrin DDT DDD Propetamphos Diazinon Dichlofenthion Fenchlorphos Chlorfenvionphos Cyhalothrin Cypermethrin Deltamethrin Fenvalerate

In addition to due diligence testing of finished products, we would recommend that documentary evidence should be obtained from the raw material suppliers that these chemicals are not present. It is our intention in the future to specify these standards back to the raw material, i.e., fibres. Environmental, Chemical and Factory Minimum Standards November 2006 Page 23 of 27

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Appendix 10 Summary : Chemicals for Concern

CHEMICALS
1,2,3 trichlorobenzene 1,2,4 trichlorobenzene 1,2-Dichloroethane 1,3 Cyclopentadiene 1,3,5 trichlorobenzene 4-tert-butyltoulene Alachlor Aldrin All isomers of DDT All isomers of hexachlorocyclohexane All isomers of trichlorobenzene Anthracene Atrazine Azinphos-methyl Benzine Brominated diphenylether Brominated flame retardants C10-13-chloroalkanes Cadmium Cadmium and its compounds Certain Phthalates- Dibutylphthalate & Diethylhexylphthalate Chlorfenvinphos Chlorpyrifos Di(2-ethylhexyl) phthalate (DEHP) Dichloromethane Dichlorvos Dicofol Dieldrin Diuron Dodecylphenol Endosulfan Endrin Fenitrothion Hexachlorobenzene Hexachlorobutadiene

EU Water Framework
Directive

UK Environmental
Protection Act

OSPAR List for

Priority Action

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CHEMICALS
Hexachlorocyclohexane Hexachlorocyclohexane (total Isomers) Hexamethyldisiloxane Isoproturon Lead and its compounds Lead and organic lead compounds Malathion Mercury and its compounds Methoxychlor Musk xylene Naphthalene Nickel and its compounds Nonylphenol/ethoxylates (NP/NPEs) and related substances Nonylphenols Octylphenol Organic tin compounds Pentachlorobenzene Pentachlorophenol and its compounds Polyaromatic hydrocarbons (PAHs) Polychlorinated biphenyls (PCBs) Polychlorinated dibenzodioxins (PCDDs) Polychlorinated dibenzofurans (PCDFs) Short chained chlorinated paraffins (SCCP) Simazine Tetrabromobisphenol A Tributyltin compounds Trichlorobenzenes Trichloromethane (Chloroform) Trifluralin Triphenyltin compounds

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EU Water Framework
Directive

UK Environmental
Protection Act

OSPAR List for

Priority Action

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Appendix 11 Chemical Testing Notes

General Remarks
Chemicals can be detected in amounts that fall into 3 categories: Background levels amounts found in nature Contamination low levels present Deliberate application higher levels present There are two broad types of test: Qualitative tells you something is definitely there in high low or medium amounts. Quantitative tells you exactly what is there. For any test there will be a limit of detection below which a chemical cannot be detected. (Where methods use solvent extraction the limits of detection and permissible levels may refer to the extract and not the test fabric/component see chemicals on product table). In some instances the M&S Acceptable limit refers to the acceptable limit in the solvent extract and not the total amount on the fabric under test.

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

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Appendix 12 Kidswear : Clarification of Chemical Restrictions

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

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