LWG ENVIRONMENTAL AUDIT SUMMARY REPORT 3 Measuring Packing ... Dimethyl Fumarate to be included in the company’s internal RS list. ... BLC conditions of contract for this audit require

RCM 15-16-099

LWG ENVIRONMENTAL AUDIT

SUMMARY REPORT Protocol Issue 6.3.0

CPL Group Public Co., Ltd. 700 M00 6, Sukhumvit Road

Tambol Bangpoo Mai Ampur Muang, Samutprakan

10280 Thailand.

May 2016

pany logo

CPL Group Public Company Limited RCM 15-16-099

Audited by BLC Leather Technology Centre Ltd Page 2 of 15

AUDIT REPORT

For Kitichai Wongcharoensin

by

Auditor

STRICTLY CONFIDENTIAL

Audited by BLC Leather Technology Centre Ltd

Audit Result Summary

CPL Group Public Co., Ltd. % Score Rating

Environmental Performance 84.75 Silver

Material Traceability Grade- B The primary processing scope for this tannery audit Category C – Raw hides to finished leather

The tannery also undertakes the following activities Category D – Tanned hides to finished leather

The types of leathers produced are Foot wear / Athletic footwear

Checked on IPE web-site Not applicable

The number of sub-contractors used is X

To achieve the rating of Gold, Silver or Bronze it is necessary to gain the minimum score required for that award as an overall percentage and in all critical sections.

Gold Silver

Bronze

Overall

Possible Score 1345

Actual Score 1139.9 Minimum Score

Critical Sections

Operating permits 100 85.0 75.0 65.0

Tannery data 96.75 85.0 75.0 65.0

Environmental management systems 86 85.0 75.0 65.0

Restricted substances 84.5 85.0 75.0 65.0

Energy consumption 78.6 85.0 75.0 65.0

Water usage 86.2 85.0 75.0 65.0

Air & noise emissions 93 85.0 75.0 65.0

Waste management 90.71 85.0 75.0 65.0

Effluent treatment 94 85.0 75.0 65.0

Emergency plans 90 85.0 75.0 65.0

Non Critical Sections

Housekeeping 78

Manufacturing processes 41.64

Beam house processes 32

Post tanning processes 29

Finishing processes 39.5

Complaints and public relations 20

Audit completed by BLC Leather Technology Centre Ltd

Auditor Raj Rangarajan

Date the audit was conducted 9th & 10th May 2016

The next audit is due 9th November 2017

Audit protocol * LWG - Issue 6.3.0, June 2015

*The audit was conducted in accordance with the procedures and guidelines specified in the “Tannery Environmental Auditing Protocol”

prepared and issued by the Leather Working Group: Issue 6.3.0 June 2015. The assessment was based on sampling and therefore

nonconformities may exist which have not been identified.



Key Comments and Observations

This was the sixth LWG audit for CPL and the team showed their awareness and implemented

several environmental improvements to meet LWG requirements. This is a category-C/D

tannery. Though CPL managed to maintain annual production level close to previous audit

despite prevailing difficult market conditions, tanned on site has reduced from 70% to 53%. At

times buying wet blue gives better grading than from making wet blue from raw hides.

This tannery is located in tannery zone Km 34 Samutprakarn. They have chrome recovery plant

and the chrome cake sent to Diachrome Company to produce basic chromium sulphate which

is supplied back to tanneries. The treated waste water is discharged to CETP (run by sub-

contractor ‘Sahapornprom Co., Ltd.’) for treatment and treated water discharged to sea located

very close to the plant after meeting regulatory limits.

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Figure 1 Factory Entrance

General comments on overall management

The finished leather production is about 1.97 million square meters catering to brands like

Timberland, Adidas, Reebok, Lacoste etc. 60% of production is Nubuck water proof type and

the rest is made up of Crazy horse type, full grain softy and pigmented leather.

CPL have ISO 9001 quality management system, ISO 14001 Environmental management

system and their lab is SATRA accredited. They have representative offices in China, USA,

Vietnam and Indonesia.



Figure 2 Finished Leather Display

Figure 3 Measuring Packing area

Operating permits

All the operating permits are in order.



Figure 4 Production Floor

Tannery data

About 47% of wet blue sourced from medal rated tanneries. The wet blue production is

controlled by recording weekly results of chrome content of wet blue and exhaust chrome

liquor. Percentage of chrome utilization and chrome incorporated in to product were presented.

Scored well in this section.

Figure 5 Chrome recovery area



Figure 6 Various Environmental awards

Raw Material Traceability

CPL have written traceability system and about 80% of raw hides imported from USA are

traceable to slaughter houses. Scored Grade-B in this section.

Figure 7 Raw hides store

Environmental management systems

They have valid ISO 14001: 2004 EMS system and presented requisite documents including

evidences.



Figure 8 Physical Testing Laboratory

Restricted substances

They have written restricted substances policy and conduct third party lab tests and presented

records. Scored silver in this section.

Figure 9 Chemical store



Energy Consumption

Scored silver in this section.

Figure 10 Boiler

Water usage

They have bore holes at the site and water used recorded every month. Scored well in this

section.

Figure 11 Incoming water meter



Figure 12 Drum area

Air & noise emissions

CPL have completed air emission inventory listing all emission points in a diagram. They have

documented periodical preventative maintenance program for all emission control devices.

Regular monitoring of boiler, spray machine stack emissions performed and test reports

presented. Scored well in this section.

Waste Management

CPL have developed formal waste management procedure for both hazardous and non-

hazardous wastes generated in the tannery. They have documented all national, regional and

local laws and regulations and comply with all requirements. Documented all hazardous and

non-hazardous wastes and disposal arrangements. Scored well in this section.

Effluent treatment

The management company ‘Sahapornprom Co., Ltd.’ was able to demonstrate compliance to

all environmental regulatory limits. Scored well in this section.



Figure 13 Waste water Discharge point

Figure 14 Treated water from CETP

Emergency plans

They have formal fire and environmental protection plan addressing all emergency situations

like fire, toxic chemical release, explosion etc. Their emergency response team members hold

external certification by third party and conduct regular emergency practice drills.



Figure 15 Emergency Evacuation plan

Beam House

They use biodegradable wetting agents and use hair burn liming system. They have installed

hydrogen sulphide alarms in beam house to monitor the gas. Scored well in this section.

Figure 16 Beam House Operation

Recommendations

Management reviews to be undertaken on quarterly basis.

Internal audits to be conducted on monthly basis.

Dimethyl Fumarate to be included in the company’s internal RS list.



Procedure to be developed and documented whenever a chemical in a process

substituted by an alternative and restricted substances risk analysis to be carried out.

Possibility of introducing renewable energy resources to be explored.

At least 2 major waste streams generated per unit of leather produced to be monitored

so as not to exceed specific limits.

The housekeeping of CETP to be upgraded.

The waste water going to CETP through open channels should be closed ASAP to

ensure it does not over flow during forthcoming heavy rain season.

Documents provided and filed with the report:

Site plan

Production data

Restricted substances test report

List of emissions inventory

List of operating permits

Energy / Water consumption data

Treated waste water test reports



Graphical Performance

Radar Graph 1, “Critical Sections” scores in comparison with Gold, Silver and Bronze targets

Radar Graph 2 Scores as a percentage of the possible total.

50.0

60.0

70.0

80.0

90.0

100.0

Operating permits

Tannery data

Environmental management

systems


Energy consumption

Water usage Air & noise emissions

Waste management

Effluent treatment

Emergency plans

Total

Critical Sections CPL Group Public Co., Ltd.

Silver

50.0

60.0

70.0

80.0

90.0

100.0

Operating permits

Tannery data

Environmental management …


Energy consumption

Water usage

Air & noise emissions

Waste management Effluent

treatment Emergency plans

Housekeeing

Manufacturing processes

Beamhouse processes

Post tanning processes

Finishing processes

Complaints and public relations

Total

Category "C" all sections CPL …



These graphics are best viewed on computer screen or when printed in colour. Notes The assessment was based on sampling and therefore nonconformities may exist which have

not been identified.

If you wish to distribute copies of this report external to your organisation, then all pages

must be included.

Regulatory Compliance

BLC conditions of contract for this audit require that BLC be informed of all regulatory non-

compliance or incidents that require notification to any regulatory authority. Acceptance of

this report by the client signifies that all such issues have been disclosed as part of the

assessment process and agreement that any such non-compliance or incidents occurring

after this visit will be notified to the auditor as soon as is reasonably practical.