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APEO/ AP Investigation Summary Report December 2011
BACKGROUND
In September 2011, Greenpeace released the report ‘Dirty Laundry II: Hung out to dry’. They drew out 6 samples from different H&M stores globally and tested them for toxic substances; Nonylphenol Ethoxylates (NPE).
NPEs are commonly used a detergents in textiles production. When broken down to Nonylphenol, it becomes a toxin that has persistent and hormone disrupting properties.
Since 4 out of 6 samples were tested positive for NPE, we proceeded with an investigation to find the source of contamination.
Case Thumbnail Information from Greenpeace
Polo T Shirt Purchased in China
Made in China
19 ppm
Bird Shirt
Purchased in Netherlands
Made in Bangladesh
21 ppm
Shirt Purchased in Switzerland
Made in Bangladesh
3.1 ppm
Snoopy Purchased in Russia
Made in Bangladesh
5 ppm
Introduction
Restricted substance Limit
Alkylphenol Ethoxylates / Alkylphenols (APEO/AP)
Nonylphenol Ethoxylates (NPE) 100 ppm
Octylphenol Ethoxylates (OPE) 100 ppm
Nonylphenol (NP) Not detected
Octylphenol (OP) Not detected
It is important to note that all 4 cases comply with our current RSL.
WHAT ARE NPEs?
NPEs/ OPEs are included in the group of non-ionic surfactants called alkylphenolethoxylates (APEOs). NPEs and OPEs can degrade to NP and OP respectively.
APEOs CAN BE USED IN FOR EXAMPLE:
Detergents
Sourcing agents
Wetting agents
Softeners
Emulsifier/ dispersing agents
Impregnating agents
Degreasing agents for leather
Finishing
De-gumming for silk production
Dyes and pigment preparations
Introduction
Error: Country of manufacture is Bangladesh
SAMPLES TESTED BY GREENPEACE
TEST LAB Bureau Veritas (BV) DETECTION LIMITS The detection limits are not the usual parameters used in current H&M testing. They were developed especially for this investigation by BV to test samples at much lower frequencies. Detection limit for fabric: OP/NP: 1ppm OPEO/ NPEO: 1ppm Detection limit for chemicals: OP/NP: 1ppm OPEO/ NPEO: 1ppm Detection limit for water: OP/NP: 1ppb OPEO/ NPEO: 10ppb
Methodology
Pre-assessment Assessment Evaluation
PRE-ASSESSMENT Documentation We requested the suppliers and their processing units who produced the 4 garment styles to fill out 2 documents. We also requested for them to submit their processing recipes.
1. Self Assessment 2. Chemical Inventory 3. Processing Recipes
We used this information to better prepare for our next step which is to assess the production line. Test the same garment styles Greenpeace tested During pre-assessment, we also retrieved the same garments where possible, and tested them. As all garments are constructed with different parts and components, we tested different sections of the garment (e.g. body, sleeve, collar) and components to understand the concentration of APEO at different parts of the garment. ASSESSMENT We then tried to identify the possible sources of APEO. The depth of the investigation differed case by case. The difference highly depended upon how each garment was produced. However, for each case, we prioritized testing at the tier closest to us first- our suppliers. Then, depending upon the test results, we made decisions as to how to proceed further in the investigation- whether to select more samples from the same tier, or go further down the supply chain to search for the source of APEO contamination. EVALUATION After analysing all information gathered from the pre-assessment stage and the assessment stage, we made evaluations and have drawn some next steps for action.
Methodology
Factory Wastewater Treatment
Plant Incoming water
Wastewater Discharge &
Sludge
Production Units
TESTING PRIORITY
Internal Wet Processing
Washing Unit
Printing Unit
Fabric Mill
1st Priority 2nd Priory
WHAT ARE WE TESTING?
All incoming water sources
e.g. River/ Ground water
Based on recipe: Select Relevant chemicals with potential APEO content based Other chemicals onsite: Select other chemicals on site that potential of APEO content
Wastewater quality test
Sludge Quality test
LIMITATIONS The biggest limitation foreseen for this investigation was the period difference between the time when the products were produced, and when this investigation began. Having had the products been produced approximately one year prior, we expected for some evidence to be loss, no longer traceable or containing different properties (e.g. incoming water and wastewater are unlikely going be the exact same/ near same quality as the quality used and discharged one year ago).
# Tested positive Result
1 Softener NPE 3470 ppm; NP 14.3 ppm
2 Softener NPEO: 4.0 ppm OPEO: 2.0 ppm
3 Softener NPEO: 4.0 ppm OPEO: 3.2 ppm
4 Binder NPEO: 12.5 ppm
5 Binder NPEO: 4 ppm OPEO: 4 ppm
6 Formulated Pigment NPEO: 322 ppm OPEO: 2780 ppm
7 Formulated Pigment NPEO: 1.8 ppm OPEO: 1.05 ppm
8 Formulated Pigment NPEO: 5.05ppm
9 Wetting Agent NPEO: 4.6 ppm OPEO: 2.6 ppm
10 Sequestering agent NPEO: 4.8 ppm OPEO: 2.6 ppm
11 Soaping agent NPEO: 4.6 ppm OPEO: 2.0 ppm
12 Anti-Back staining OPEO 1ppm
Results
Incoming water Chemical Products Wastewater Discharge Sludge
Number of positive results
2 out of 10 (20%)
12 out of 35 (34%)
1 out of 14 (0.07%)
2 out of 7 (30%)
Result range for positive results
1.4ppb to 65 ppb
1 ppm to 3470 ppm See below table.
69.9 ppb 1.51 ppb 28.7 ppb
Number of positive results across all 4 investigations (in Bangladesh and China):
Number of positive results across all 4 investigations (in Bangladesh and China):
All chemicals tested except 1 (#1) comply with EU regulations (EC No. 1907/2006)
Results- Polo Shirt, Produced in China
External Washing
Finishing Yarn Dyeing
Incoming Water NP: 1.4μg/l ND ND
Chemical Products used
Silicon Oil: NPE 3470 ppm1; NP 14.3 ppm
ND ND
Wastewater Discharge
ND ND NPE 69.9 μg/l
Sludge ND NP: 28.7 μg/l NPE 14.9 μg/l; NP 1.51 μg/l
Greenpeace Result: 19 ppm
WATER & CHEMICAL TESTS AT PROCESSING UNITS
1. Silicon oil was found onsite, however, it was not being used, nor was there evidence showing that it was in use.
MATERIAL TESTS
Result
Finished Product Body NPE 3.57ppm; OPE 1.62ppm; NP 2.02 ppm
White part of collar
NPE 3.24ppm
Blue stripe on collar
NPE 16.69ppm; NP 1.74 ppm
Greige Yarn Yarn NPE 1.34 ppm; NP 1.88 ppm
Results- Shirt, produced in Bangladesh
Greenpeace Result: 3.1 ppm
Washing Dyeing
Incoming Water
ND ND
Chemical Products used
Anti-back staining: OPEO 1ppm
Wetting Agent NPEO: 4.6 ppm OPEO: 2.6 ppm
Sequestering Agent NPEO: 4.8 ppm OPEO: 2.6 ppm
Soaping Agent NPEO: 4.6 ppm OPEO: 2.0 ppm
Softener NPEO: 4.0 ppm OPEO: 2.0 ppm
Softener NPEO: 4.0 ppm OPEO: 3.2 ppm
Wastewater Discharge
ND ND
Sludge ND ND
WATER & CHEMICAL TESTS AT PROCESSING UNITS MATERIAL TESTS
Result
Finished Product NPEO: 4.0ppm OPEO: 2.0 ppm
Results- Bird Shirt, produced in Bangladesh
Greenpeace Result: 21 ppm
WATER & CHEMICAL TESTS AT PROCESSING UNITS
MATERIAL TESTS
Printing Unit 1 Printing Unit 2
Incoming Water
Not detected
Not detected
Chemical Products used
Sapamine Not detected Binder WST Not detected
Optical
Brightener
agent
Not detected Binder
NPEO: 4 ppm
OPEO: 4 ppm
Optical
Brightener
agent
Not detected Pink pigment NPEO:
5.05ppm
Softener Not detected
Detergent Not detected
Binder NPEO: 12.5
ppm
Foil glue Not detected
Fixing agent Not detected
Green Pigment NPEO: 322
ppm OPEO:
2780 ppm
Black Pigment Not detected
Wastewater Discharge
Not detected Not detected
Result
Finished Product from Factory 1
Lt Green print with
white fabric
NPEO: 10 ppm
OPEO: 1.6 ppm
Green print with
white fabric
NPEO: 8.0 ppm
OPEO: 6.0 ppm
Black print with
white fabric
NPEO: 8.0 ppm
OPEO: 4.2 ppm
Yellow print with
white fabric NPEO: 6.0 ppm
Gold foil print with
white fabric
NPEO: 4.0 ppm
OPEO: 2.0 ppm
Pink print with
white fabric NPEO: 6.0 ppm
White shell fabric NPEO: 2.0 ppm
Finished Product from Factory 2
Lt Green print with
white fabric
NPEO: 4.0 ppm
OPEO: 4.0 ppm
Green print with
white fabric
NPEO: 4.0 ppm
OPEO: 4.0 ppm
Black print with
white fabric
NPEO: 2.0 ppm
OPEO: 2.0 ppm
Yellow print with
white fabric
NPEO: 1.8 ppm
OPEO: 1.2 ppm
Gold foil print with
white fabric
NPEO: 3.0 ppm
OPEO: 1.0 ppm
Pink print with
white fabric
NPEO: 16 ppm
OPEO: 8.0 ppm
White shell fabric NPEO: 3.0 ppm
OPEO: 1.6 ppm
Results- Snoopy T- Shirt, produced in Bangladesh
Greenpeace Result: 5 ppm
Dyeing Printing
Incoming Water
ND NPEO: 65 ppb
Chemical Products used
Stabilizer Not detected Clear effect Not detected
Wetting
agent
Not detected White Paste
Not detected
Stabilizer Not detected Orient Paste Not detected
Black Pigment NPEO: 1.8 ppm
OPEO: 1.05 ppm
Wastewater Discharge
ND ND
Sludge ND ND
WATER & CHEMICAL TESTS AT PROCESSING UNITS MATERIAL TESTS
Result
Finished Product Black print with
grey fabric
NPEO: 8.0 ppm
OPEO 1.2 ppm
White print with
grey fabric
NPEO: 4.0 ppm
OPEO 1.2 ppm
Grey fabric (body) NPEO: 10 ppm
OPEO 2.0 ppm
Greenpeace Results
19ppm 21ppm 3.1ppm 5ppm
Sample
H&M Results
- Highest content NPE from collar strip (blue)
- Incoming water at 1.4ppb
- High possibility of contamination from Silicon oil found in washing unit at NPE 3470 ppm (but no evidence or indication that it is in use)
- Highest APEO concentrations found in areas of print
- 2 out of 3 formulated pigments were tested positive
- We believe the main APEO source is from the binders (also found in formulated pigments)
- APEO was found in shell fabric when tested as a finished garment
- APEO found in a mix range of auxiliaries used, ranging in concentrations from 4.0 ppm to 4.6 ppm
- 1.8 ppm was found in the black pigment
- Assumption is that the body fabric is already contaminated before entering production (as there was no washing or dyeing in our production scope therefore could not add contamination)
- APEO found in in-coming ground water at 65 ppb
Key Findings: 1. APEO has been detected across the production chain at different tiers by different sources. 2. Main sources: Softeners, Binders and formulated pigments.
Results- Source of APEO overview
Next Step
This APEO investigation has provided us a snapshot towards the sources of APEO contaminations. Results have indicated that there is no intentional of APEO in our products, and that in most cases, the detected levels are at background levels. BARRIERS The definition of Zero. Right now, background concentrations of hazardous chemicals can be detected, for example, in the incoming water of factories. Currently, our chemical supplier's ability to ensure of APEO free means ‘not intentionally used’. Coverage beyond Tier 1 and 2 suppliers. Right now, our direct business partners are what we call Tier 1 suppliers. We need to configure how we deal with suppliers beyond our direct influence. NEXT STEPS As all contamination sources comes primarily from chemicals, we will work and communicate with some major chemical suppliers to see what is possible in terms their ability to supply “Zero” APEO products. Overall, the industry needs to work in a collaborative way; Cover efforts with our business partners no matter direct or indirect. This includes the involvement of our suppliers (1st and 2nd tier suppliers), chemical suppliers, service providers (e.g. BV), and the government. BEYOND APEO In line with our zero discharge of hazardous chemicals by 2020 commitment, we will in the next 18 months expand beyond this study, and make investigations on the presence of other hazardous chemicals in our supply chain. Until then, we are able to grasp a better picture towards how to plan and scale up, and reduce negative environmental impact across our supply chain.
