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1511 Wisconsin Avenue, NW Washington, DC 20007 Telephone 202-338-3131 Fax 202-338-2800 Email Web http://MTS.sustainableproducts.com _____________________________________________ MEMBER BALLOT Sustainable Textile Standard 17th Draft 10-13-02 Contents Page 1.0 Purpose, Overview, & Requirements/Achievements for Standard 2 2.0 Background, Increased Profitability & Revision 4 3.0 Definitions 5 5 3.1 Textile 5 3.2 Biological & technical nutrients 6 3.3 Cradle to cradle thinking 6 3.4 Reuse 6 3.5 Sustainable Reuse 6 3.6 Recycle 6 4.0 Requirements/Achievements of Standard 7 Fostering & Accelerating the Global Market Transformation to Sustainability printed on recycled paper 1

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Page 1: mts.sustainableproducts.commts.sustainableproducts.com/downloads/mmbrltv.doc  · Web viewSuppliers and manufacturers adhering to this standard expressly warrant in a certification

; 1511 Wisconsin Avenue, NW Washington, DC 20007

Telephone 202-338-3131 Fax 202-338-2800 Email [email protected] Web http://MTS.sustainableproducts.com _____________________________________________

MEMBER BALLOT

Sustainable Textile Standard 17th Draft 10-13-02

Contents Page

1.0 Purpose, Overview, & Requirements/Achievements for Standard 2

2.0 Background, Increased Profitability & Revision 4

3.0 Definitions 5 5

3.1 Textile 5

3.2 Biological & technical nutrients 63.3 Cradle to cradle thinking 63.4 Reuse 63.5 Sustainable Reuse 63.6 Recycle 6

4.0 Requirements/Achievements of Standard 7

4.1 Benefits 74.2 Goal 74.3 Prerequisites 74.4 Sustainable uses/applications 7

4.5 Guiding principles 74.6 Sustainably reused textile products 74.7 Sustainable agricultural products 7

4.7.1 General principles 84.7.2 Requirements 9

a. Sustainable fertilizer & pest control 9

b. Adhere to EPA best management practices 12c. Accurately communicate biodegrability 12

4.8 Global Reporting Initiative social equity indicators 134.9 Use Green-e power 13

4.10 Reportable sustainable attributes 13

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4.11 Express warranty or FTC certification 15

Table 1 3Table 2 16Appendix 1 Examples & Supplemental Information 20Figure 1 attached

1.0 Purpose, Overview, & Requirements/Achievements of Standard

The purpose of this standard is to make available to manufacturers and suppliers, tools allowing them to provide environment product information to their customers. It is intended for internal and external corporate use, as well as by other interested parties, including textile purchasers and specifiers. The standard is inclusive with graduated requirements for greatest possible participation. It is based on life cycle assessment (LCA) principles, life cycle thinking and “cradle to cradle thinking,” and requires for the production of textile goods, disclosure of environmental product information, and use of agricultural based feedstock, or feedstock consisting of continual closed loop materials reuse/reutilization, i.e., feedstock that can be petro-chemical based, but must be continually reused protecting public health and environment. It can be used to provide fabric consistent with the Clean Vehicle Standard, see http://mts.sustainableproducts.com/standards.htm.

This standard provides for supplier documentation for sustainable textile, and is intended as a model for additional MTS Sustainable Products Standards. It identifies sustainable raw material options that utilize agricultural products or continual closed-loop materials flows for products, LCA and chemical reporting requirements, and express warranty/certification of data and information governed by this standard. LCA is the identification of a product’s environmental benefits and impacts over a product’s life, from raw materials manufacturing to final disposition. See Figure 1. It is intended to help manufacturers who are receiving more requests for environmental product information, and to simplify the complexity of the supply chain for environmental product information. It also provides textile users a Standard to specify more sustainable and sustainable product.

This standard is voluntary and maintains the confidentiality of proprietary business information through confidentiality agreements set forth in Option 2 in section 4.10 & the express warranty in section 4.11. It has been developed because textile customers want this information and leading manufacturers are striving to be sustainable.

A number of important entities in the textile business participated in the development and dissemination of this standard to effect substantial near term market penetration of the standard supporting MTS’ goals. The scope of the standard is intended to allow inclusive participation and encourage the progressive movement of the textile industry to sustainability.

Except where it is clearly unsustainable, no products or processes are prevented from participating in this standard, and performance requirements for participation are set forth protecting public health and environment. This standard does not apply to packaging of sustainable textile.

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Table 1 below sets forth requirements/achievements for the standard. Table 2 at the end of this standard provides five hypothetical examples of textile qualifying with this standard. Appendix 1 provides examples of textile meeting provisions of this Standard.

Must be documented, & certified or warranted pursuant to section 4.11

Achievements/ Requirements

Minimum Certification Requirements for ALL Sustainable Textile

Report GRI Social Equity Indicators over supply chain §4.8 1% (initially) Green-e Power §4.9 Public disclosure of supply chain (LCA) benefits/impacts

§4.10 Economic benefits recognition- see section 2

Minimum ADDITIONAL Certification Requirements for Petroleum Based Textile §4.6

Virgin petroleum-based textile could be used if completely reused or recycled after end of life, with no or deminimus material to landfill or incinerator. Greatest Priority/Credit Given for Petroleum Based Textile is SustainablyReused

(Level 5)

Minimum ADDITIONAL Certification Requirements for Biobased Textile §4.7

1% (initially) organic production 8 EPA/Purdue/CTIC Best Management Practices

Six levels of achievement below are still available for reused/reutilized textile, certified organic textile and Green-e

Power

Levels Date Phase in requirements for reused/reutilized textile, certified organic textile and Green-e Power

1% (by weight or % usage for power)

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Table 1

Graduated & Inclusive Sustainable Textile Achievements/Requirements

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Prerequisites 2004

2005 2%

1Any date, as of the first effective date of this Standard. The percentage requirements in

these levels will be increased in the

first revision of this Standard.

2% - 20%

2 21% - 40%

3 41% - 60%

4 61% - 80%

5 81% - 100% Consistent with USDA National Organic Rules requiring full compliance by Oct. 21, 2002, users

certifying compliance to this Standard can use the words Sustainable Textile and Made Using Sustainable Textile Practices where they achieve, respectively, a Level 5 100% Reportable Sustainable Attribute, and

a Level 4 or 5 Attribute, and comply with all other provisions of this Standard. Users certifying to any other Level must use the words Transitional Sustainable Textile.

For example, Transitional Sustainable Textile is achieved by the manufacturers:

1. Warranting/Certifying either to Option 1 or 2 of section 4.10,

2. Warranting/Certifying it achieves any of the four stated levels, that from 1% to 60% of the processes making the product using Green-e Power, and:

3. Warranting/Certifying it achieves any of the four stated levels or percentages, that from 1% to 60% of the textile is made with either sustainably reused petroleum based textile pursuant to section 4.6, or

for agricultural product textile achieving any of the four stated levels or percentages, that from 1% to 60% of the product is made with certified organic product by weight, and meets all other provisions of section 4.7 for agricultural products.

2.0 Background, Increased Profitability for Sustainable Textile, & Revision of this Standard

2.1 Background: MTS is comprised of leading environmental groups, governments, and manufacturers fostering and accelerating the global market transformation to sustainability by increasing sustainable products’ market penetration to 30% by 2007 and 90% by 2015. MTS has identified 12 Sustainable Products Standards that are

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transparent, life cycle and consensus-based. These Standards and MTS’ Brochure/Strategic Plan can be viewed at http://MTS.sustainableproducts.com, and its definition of sustainable products is:

Sustainable products provide environmental, social and economic benefits, and protect and enhance the needs of future generations, public health, welfare, and environment over their full commercial cycle, from the extraction of raw materials to final disposition.

2.2 Increased Profitability: Sustainable textiles and other sustainable products are more profitable than comparable, conventional products for a variety of reasons, as identified on page 11 of the MTS Brochure and more extensively in Chapter 3 of the peer-reviewed MTS Sustainable Products Training Manual©:

Faster product time to market Fewer regulatory constraints Documented public demand due to global health & environmental benefits. Reduced costs for raw materials and manufacturing Reduced liability Deliver added value to consumers Improved corporate good will, product position, competitive advantage, brand

recognition, stock value Provide “halo effect” to other company products Improved employee health & safety Increased worker productivity through reduced time for compliance & liability issues

This information is documented in more detail in MTS’ Draft Economic Benefits Standard and Background Document at http://mts.sustainableproducts.com/standards.htm

2.3 Revision of this Standard: This Standard will be revised and republished as needed, but no later than every three years from the initial date of approval by MTS Members.

3.0 Definitions

3.1 Textile: 1) natural and man-made filaments (and fibers) for use in yarns, 2) the filaments and fibers used in the preparation of woven, knitted, tufted, non-woven and other fabrics and materials, including backings and coatings 3) fabrics and other materials made from filaments, fibers and yarns and 4) apparel and other use articles made from the above materials. See Textile Fibers, Dyes, Finishes and Processes – A Concise Guide, (Needles 1986).

3.2 Biological & Technical Nutrients : A biological nutrient is a material or chemical input, component, by product or other aspect of a sustainable product flowing through an industrial system and safely back to biological systems during product use or by mechanical or chemical separation at end of product use, in a manner beneficial to and protective of public health and environment and future generations. See example in Appendix 1.

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A technical nutrient is a material or chemical input, component, by product or other aspect of a sustainable product flowing through an industrial system and safely back to an industrial system by mechanical or chemical separation at the end of product use, in a manner beneficial to and protective of public health and environment and future generations. A technical nutrient can be continually reused in a closed loop system in a manner beneficial to and protective of public health and environment. See example in Appendix 1.

3.3 Cradle to Cradle Thinking : A process encouraging and implementing materials and life cycles making use of improved environmental product design including use of technical nutrients and/or biological nutrients. Sustainable materials are derived from cradle to cradle thinking or design, and are reused by industrial and natural systems and protect public health and environment and future generations. Cradle to Cradle Thinking and Design results in products with very positive LCAs with few environmental and health burdens over all stages for all 12 environmental impacts the Standard lists for LCAs in section 4.10. A result of Cradle to Cradle Thinking is Climatex in Appendix 1.

3.4 Reuse : “Use a product more than once, either for the same purpose or for a different purpose. Reusing, where possible, is preferable to recycling because the item does not need to be reprocessed before it can be used again” (http://www.epa.gov/epaoswer/non-hw/muncpl/reduce.htm#reuse).

3.5  Sustainable Reuse:  As distinguished from reuse, sustainable reuse includes social supply chain considerations specified in section 4.8, and is where the product is EITHER:

reused indefinitely, maintaining performance and quality characteristics and environmental integrity without harmful releases to health or environment, as part of  continuous closed loop system or takeback programs, so the reutilized product does not go to landfill or incinerator, OR

reused, and then returned safely to natural systems without any adverse effects to public health and environment.

Sustainable reuse requires cradle to cradle life cycle thinking selecting materials and processes which safely retain value in closed industrial loops, or return safely back to natural systems.  In this way, these materials are sustainably reused in a variety of ways, over and over again, to the benefit of industrial and natural systems protecting -even enhancing-- public health & environment.  Nylon 6 carpet fiber is an example of sustainable reuse via closed loop chemical processes that returns the material to its 'monomer' building blocks and then back to Nylon 6 for more carpet fiber---again and again.  Forest Stewardship Council (FSC) certified lumber can be easily part of sustainable reuse.  When FSC wood byproducts are composted and used as garden or agricultural soil amendments, these biological nutrients are “sustainably reused” by natural systems in a permanently healthy and way, in contrast to unsustainable reuse of a conventional non FSC wood harvest which can permanently deplete forest and habitat resources.

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3.6 Recycling : “Recycling is a series of activities that includes collecting recyclable materials that would otherwise be considered waste, sorting and processing recyclables into raw materials such as fibers, and manufacturing raw materials into new products” (http://www.epa.gov/epaoswer/non-hw/muncpl/recycle.htm).

4.0 Requirements/Achievements of Sustainable Textile Standard

4.1 Prerequisites: Quality shall be equal to or better than conventional textile. Cost should meet consumer price needs.

4.2 Benefits: Economic, Environmental & Social Benefits are provided throughout the supply chain over all product stages- raw materials to final use or reuse.

4.3 Goal : Improve the sustainability of textiles to protect the needs of future generations, public health, environment, and welfare.

4.4 Sustainable uses/applications of textile are set forth by this standard.

4.5 Guiding principles: replicable, inclusive, simple, collaborative, practical, & performance-based

4.6 Sustainabl y Reused Textile Products : Sustainable Textile can be from reused petroleum and agricultural/biobased feedstock and products, but must provide continual closed loop reuse so that the technical nutrient does not need to use virgin petrochemical or other unsustainable feedstock including from agriculture. Continual closed loop reuse means the product can be reused continually protecting public health and environment and future generations, without the need to add virgin petrochemical product or unsustainable agricultural product. By 2004, 1% by weight of all petrochemical-based textile must utilize components that protect public health and environment, are positively identified to foster healthy and prosperous conditions for human and ecological systems, and warranted pursuant to section 4.11 below with publicly reviewable documentation. See Table 1 for all levels of participation and achievement. Deminimis amounts of virgin product can be included in Sustainably Reused Textile, which means 1% or less by weight and volume, as long as the virgin product over its life cycle protects public health and environment, is positively identified to foster healthy and prosperous conditions for human and ecological systems, and warranted pursuant to section 4.11 below with publicly reviewable documentation.

Reuse includes manufacturer “takeback,” leases or other contracts, purchase, or reuse with nonprofits, retailers, and contractors. The Pacific Northwest Pollution Prevention Resource Center provides guidance on setting up a company takeback program: http://www.pprc.org/pubs/topics/epr/takeback.html. Nonprofit reuse programs include REDO, the Reuse Development Organization http://www.redo.org/body_index.html. See Appendix 1 for examples of successful company reuse/reutilization programs.

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4.7 Sustainable Agricultural Products: Other than section 4.6 above, Sustainable Textile Must Use Agricultural Product Feedstock Consistent With the General Principles and Requirements Below. Bio-based textile feedstock is available. This requirement is an important part of this standard because on a life cycle basis as indicated below, organic bio-based textile feedstock outperforms virgin petroleum based feedstock:

Unless documented otherwise by the manufacturer, petroleum-based plastic can generate endocrine disruptors threatening human health upon exposure through food and water contained in plastic (Sustainable Products Training Manual©). The greatest risks likely come from ingestion and exposure to sensitive receptors including children due to releases primarily at the textile feedstock manufacturing stage. Textile products and feedstocks that do not take these exposure routes, present little risk and thus can easily be warranted or certified as such by the manufacturer as required in section 4.11. Adverse exposures to biota can also occur. So many plastics are implicated that we can not with any certainty identify ones that do not have this effect, and thus a precautionary approach is warranted (T. Colborn, World Wildlife Fund May 2002). Petrochemical-based feedstock can be sustainable as provided for in section 4.6 above;

Virgin petroleum-based textile is unsustainable as a feedstock due in part to limited supply of petroleum reserves estimated by the government to be substantially depleted by as early as 2060 (Longterm World Oil Supply 7/7/2000, J Wood & G Long, Energy Information Agency, DOE, slide 19).

4.7.1 General Principles: Sustainable Agriculture for textile products must:

a. Follow MTS’ sustainable products definition in § 2.1 above : “products providing environmental, economic, and social benefits, and protecting and enhancing the needs of future generations, public health, welfare and environment over their full commercial cycle, from raw materials extraction to final disposition (MTS Brochure).”

b. Ensure that non food agricultural products do not deplete food supply reserves or degrade local ecosystems. In the US, there is sufficient production of agricultural products so this is not currently or projected to be a problem. In fact, the US government is currently making substantial payments to many farmers just to keep pre-existing agricultural land out of production. In other countries, this issue needs to be examined on a case by case basis.

c. Be transparent in disclosing all impacts and benefits to the environment, economy, & social welfare. For example, users of this standard relying on the express warranty/certification of section 4.11, will be clearly provided the environmental, social, and economic benefits of sustainable textile.

d. Use life cycle assessment (LCA) to identify environmental priorities . LCA is part of the competent scientific evidence requirement for use of the word sustainable, pursuant to Federal Trade Commission (FTC), EPA, & Attorneys Generals product marketing requirements. In this scope and the Sustainable Textile Standard, LCA is used to identify environmental benefits and areas for

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improvement in the supply chain for all environmental media, including local environmental issues in the production of agricultural products. See Figure 1. The FTC Environmental Marketing Guides are at http://www.ftc.gov/bcp/grnrule/guides980427.htm. See also Appendix 1.

e. Provide continuous improvement . Continuous improvement is a process used in total quality management, where a company through its routine course of business, continuously improves its products and processes.

f. Be effective across all product stages, i.e., the sustainable attributes of a product must exist in all product stages. See Figure 1.

g. Provide sufficient supply and quality of raw material for sustainable textiles .

h. Maximize CO2 & Climate Change Gas Storage & Minimize Emissions . This issue has impacts and benefits at all product stages.

4.7.2 Requirements: Sustainable Agriculture for textile products must:

a. Use Sustainable Fertilizer and Pest Control Practices.

These practices shall have little or no detrimental impact by LCA/life cycle inventory (LCI) techniques throughout the complete life cycle, and be economically viable at the very large scale required for industrial products, in other words, the technique to be viable must not be unreasonably expensive. Sustainable agriculture requires low till or no till, ground & surface water protection & conservation, no persistent pollutants, and no carcinogens, mutagens, & teratogens, toxins. Any genetically modified organisms used must be warranted in Section 4.11 below to protect health, safety, environment and habitat and land suitable for agriculture. A number of systems are used:

(1) Certified Organic Production. Certified Organic Products is an MTS Sustainable Products Standard defined at http://mts.sustainableproducts.com/standards.htm with a link to the USDA Organic Program & Organic Trade Association. By statute and USDA final rule at 7 CFR Part 205, organic prohibits use of genetically modified organisms (GMOs), pesticides, hericides, rodenticides, sewage sludge and fertilizers. Adherence to this MTS Sustainable Product Standard provides environmental and health benefits at all product stages.

By 2004, 1% by weight of all biobased sustainable chemical feedstock covered by this subsection, must be organic, and by 2005, 2% must be organic, and warranted pursuant to section 4.11 below. See Table 1 above for all levels of requirements/ achievements.

There are certified organic programs in about 20 states, and the USDA certified organic label will be on certified organic agricultural products at the point of consumption by October 2002. By this date, federal law requires both State and private certification organizations to be accredited by USDA, and all producers and processors of organic ingredients or products be certified by one of those accredited

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USDA certifiers. The USDA label is anticipated to increase organic supply beyond the 20% average supply increase per year and current $22 billion/yr. global sales for organic food.

Organic Suppliers & Brokers. See Appendix 1 for a list of organic suppliers and brokers.

Background on Organic. On a life cycle assessment (LCA) basis, certified organic products are required to be grown without pesticides, herbicides, rodenticides, fertilizers, sewage sludge & genetically modified organisms (GMOs), and have the following environmental advantages over conventional agricultural products by avoiding these problems: pesticides, rodenticides, and fertilizers have large impacts on water quality and habitat from extraction of raw materials, e.g., phosphate mines. Pesticide and fertilizer manufacturing generate large volumes of hazardous waste, pesticide application has been linked to endocrine disruptor and other chronic health impacts to biota, and pesticide and fertilizer application can adversely affect water quality. See MTS Sustainable Products Training Manual© Chapter 4 on LCA. In addition, organic production avoids embodied energy from fuels use for pesticide and fertilizer mining and manufacturing.

To date organic systems have focused on niches in the market place. Costs of large scale organic farming systems and its related infrastructure other than cotton, required for large-scale industrial products (polymers and synthetic fibers made from renewable resources) have not been evaluated for economic viability nor for their impact on related agricultural systems. Accordingly, this standard initially requires by 2004 and 2005, only 1% and 2% respectively, of biobased feedstock be organic. As knowledge and practice are gained, this percentage will be increased in mandatory tri-annual revisions of this standard.

Corn provides a good example of the issues. According to the USDA there were about 5 million bushels of organic corn produced per year as of 2000. (National Agricultural Statistical Service). A niche fiber material could require 200 million bushels of corn annually by the next ten years. The cost requirement of the corn is less than $2.50 a bushel, or the fiber products won’t be adopted in the market place, unless the consumer product manufacturers using organic feedstock communicate the added value to their customers like what is being done for FSC Certified Wood, Green-e Power, clean vehicles, and green buildings. What are the implications of an organic farming system 40 times larger than the existing system? This question must be addressed in the experience in implementing this standard and initial phased in organic production over the next three to six years.

Cost is determined by supply, duration of supply contracts, and demand- including adequate distribution. A phase in of organic production requirements is needed as set forth in this standard, to ensure sufficient organic feedstock in an economically viable manner. Accordingly, the organic requirement is substantially limited in their percentage requirements and they do not become effective until 2004 and 2005. To obtain competitive prices and sufficient supply, it is recommended that a purchase order for organic feedstock be prepared and estimates obtained from brokers/suppliers

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and cooperatives. Organic fiber feedstock is made by Patagonia, Nike, their contractors, and other textile manufacturers.

(2) Sustainable Agricultural Farming

Precision farming. This emerging farming practice delivers just the right amount of nutrients and pesticides to the soil and is important for non-organic feedstock. However, adverse environmental impacts from pesticides and fertilizers may occur at the all product stages, thus this practice may not be as environmentally beneficial as organic production unless demonstrated. Accordingly, for non organic precision farming use pursuant to this standard, the express warranty in section 3.16 must assert that pesticide and fertilizer raw materials extraction, manufacturing, and application protects public health and environment including water quality and habitat, and over their life cycle, do not generate hazardous waste, endocrine disruptors, have carcinogenic, mutagenic, teratogenic, or long term chronic health hazards to public health or environment. Precision farming using genetically modified organisms must assert in section 4.11, that there is no acute or long term adverse risk to public health and environment including habitat alteration.

Integrated Pest Management. This practice covers multiple ways of addressing pests including pesticide use. Adverse environmental impacts from pesticides may occur at the all product stages, thus this practice may not be as environmentally beneficial as organic production unless demonstrated. Accordingly, for non organic integrated pest management use pursuant to this standard, the express warranty in section 3.16 must assert that pesticide raw materials extraction, manufacturing, and application protects public health and environment including water quality and habitat, and over their life cycle, do not generate hazardous waste, endocrine disruptors, have carcinogenic, mutagenic, teratogenic, or long term chronic health hazards to public health or environment. Integrated pest management using genetically modified organisms must assert in section 4.11, that there is no acute or long term adverse risk to public health and environment including habitat alteration.

Lignocellulosic biomass raw materials. These are any of several closely related substances constituting the essential part of woody cell walls, and consisting of cellulose intimately associated with lignin, including trees, pulp, paper, grain and natural fibers. Raw materials such as crop residue and grasses are being developed as raw materials for industrial chemical products. Studies published by NREL, ORNL and others indicate these raw materials provide certain positive economics and LCA profiles. However, adverse environmental impacts from pesticides and fertilizers may occur at all product stages, thus this practice may not be as environmentally beneficial unless demonstrated. Accordingly, for non organic lignocellulosic biomass raw materials use pursuant to this standard, the express warranty in section 4.11 must assert that pesticide and fertilizer raw materials extraction, manufacturing, and application protects public health and environment including water quality and habitat, and over their life cycle, do not generate hazardous waste, endocrine disruptors, have carcinogenic, mutagenic, teratogenic, or long term chronic health hazards to public health or environment. Lignocellulosic biomass raw materials using genetically modified organisms must assert in section 4.11, that there is no long term adverse risk to public health and environment including habitat alteration.

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(3) Sustainable Natural Animal Textiles

Sustainable textile may be from natural animal fiber provided that EPA best management practices are followed for grazing management, conservation buffers, and animal feeding operation management, organic feed is used, and the animal is not harmed to obtain the fiber, as warranted by the supplier pursuant to section 4.11 below.

b. Adhere to EPA Best Management Practices for Soil Erosion & Runoff Control .

These practices improve soil productivity and prevent water pollution that adversely affects biota including spawning grounds. This issue has impacts and benefits at the raw materials extraction stage. These practices developed by EPA, Purdue University, and Conservation Technology Information Center, can be viewed at http://www.epa.gov/watertrain/agmodule/ with detailed descriptions, manuals, and photos of practices. They are summarized as follows:

Conservation Tillage - leaving crop residue (plant materials from past harvests) on the soil surface reduces runoff and soil erosion, conserves soil moisture, helps keep nutrients and pesticides on the field, and improves soil, water, and air quality;

Crop Nutrient Management for nonorganic fields - fully managing and accounting for all nutrient inputs helps ensure nutrients are available to meet crop needs while reducing nutrient movements off fields. It also helps prevent excessive buildup in soils and helps protect air quality;

Pest Management - varied methods for keeping insects, weeds, disease, and other pests below economically harmful levels while protecting soil, water, and air quality;

Conservation Buffers - from simple grassed waterways to riparian areas, buffers provide an additional barrier of protection by capturing potential pollutants that might otherwise move into surface waters.

Irrigation Water Management - reducing nonpoint source pollution of ground and surface waters caused by irrigation systems;

Grazing Management where manure is used for fertilizer - minimizing the water quality impacts of grazing and browsing activities on pasture and range lands;

Animal Feeding Operations (AFOs) Management where manure is used as fertilizer - minimizing impacts of animal feeding operations and waste discharges through runoff controls, waste storage, waste utilization, and nutrient management;

Erosion and Sediment Control - conserving soil and reducing the mass of sediment reaching a water body, protecting both agricultural land and water quality and habitat.

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c. Accurately Communicate Biodegrability & Compostability . This issue has impacts and benefits at all product stages. Sustainable agricultural products at the point of final product disposition whether in a landfill or composted, degrade or are changed into non toxic and nonpolluting degradation products, consistent with the Federal Trade Commission definitions in its Environmental Marketing Guidelines. http://www.ftc.gov/bcp/grnrule/guides980427.htm. Substantiation of this fact is at http://www.CargillDow.com or http://mts.sustainableproducts.com. These products are not recommended for incineration. For compostability, the Guides require the qualification that municipal composting facilities are not available to a substantial majority of consumers for products sold throughout the US (Part 260.7(c)).

4.8 G lobal Reporting Initiative (GRI) Social Equity Indicators (MTS Sustainable Product Standard). Manufacturers must report the indicators as identified at www.sustainableproducts.com/standards . htm GRI Social Equity Indicators to users of this Standard upon request. At this time they will not be published because social equity indicators are not as well developed as environmental indicators and are more subjective, e.g., manufacturers must report the number of jobs accepted vs. offered.

4.9 Use 1% Green-E Power Sources by 2004 and 10% by 2005.

The 1% and 10% requirements are for electric energy use at the textile manufacturing stage. This issue has impacts and benefits at the raw materials extraction, manufacturing, & transportation stages. For example, on an LCA basis, sustainable agricultural products use 20-50% less energy, & generate less CO2 than competitive petroleum based products. See http://www.CargillDow.com/natureworks.asp. Green-e Power is an MTS Sustainable Products Standard and consists of wind, solar, geothermal, and low impact hydro sources. See http://mts.sustainableproducts.com\standards.htm. See Table 1 above for all levels of participation and achievement.

4.10 Reportable sustainable attributes by product stages (raw materials extraction, transportation, manufacturing, final use/reuse). As set forth in Table 1, for Sustainably Reused Textile, Certified Organic Textile, and use of Green-e Power, and consistent with USDA National Organic Rules, 7 CFR Part 205, requiring full compliance by Oct. 21, 2002, users certifying compliance to this Standard can use the words Sustainable Textile and Made Using Sustainable Textile Practices where they achieve, respectively, a Level 5 100% Reportable Sustainable Attribute, and a Level 4 or 5 Attribute, and comply with all other provisions of this Standard. Users certifying to any other Level must use the words Transitional Sustainable Textile.

Performance Standard. Sustainable textile products must meet or exceed today’s

quality, performance and economic standards. These prerequisites are part of sustainable products manufacturers’ responsibility and leadership in eliminating or internalizing, formerly externalized costs (cost of pollution), of previous, suboptimial designs. In other words, sustainable textile manufacturers are making products that do not place the economic costs of pollution on society. For conventional products, either government tax dollars are paying for the resulting

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pollution cleanup, or the economic value and other values of natural resources are degraded by pollution from their production throughout the supply chain.

As noted in section 4.11 below, confidentiality agreements can be executed to protect confidential data reported pursuant to this section, including through attorney/client privilege.

Suppliers must report 4.10.1 – 4.10.8 below through either of the following options:

OPTION 1: Publicly available life cycle assessment (LCA) results on the supplier individual products for the following environmental impacts/ benefits : climate change, acid rain, smog, solid and hazardous waste, indoor air quality, human toxicity, ecological toxicity, stratospheric ozone depletion, water pollution, resource depletion, habitat alteration, & embodied energy (fuel & energy use/efficiency). These are benefits that society has determined are important through laws & policies. Society has also deemed all of these benefits equally important, i.e., no one can be diminished to the preference of another, e.g., clean air requirements are equally as important as those for clean water, and one can not be offset by the other. Thus, these benefits are not normalized or weighted in the LCA results. The LCA tool used must comply with the ISO LCA General Principles Standard and be publicly validated and peer-reviewed to ensure maximum accuracy. These requirements are consistent with the requirements of the Sustainable Products Purchasers Coalition comprised of government and private sector purchasers and specifiers in the Portland Oregon metropolitan area, see http://www.sppcoalition.org, and the US Green Building Council LEED Rating System credits.

An example of a publicly disclosed LCA is Dupont Antron: http://antron.dupont.com/content/sustainability/ant08_01.shtml DuPont Antron(r) nylon has certified its product pursuant to EPA

Environmentally Preferable Product (EPP) Guidance. This certification is based on ISO 14000 standards including life-cycle impact assessment as defined in ISO 14042 and the 1999 EPA EPP Guidance.

OPTION 2: Disclosure to the purchaser of all of the compounds in the product by

CAS number. The purchaser can execute a confidentiality agreement, however, the LCA environmental benefits of the suppliers’ products will be publicly available and identified by the purchaser. The CAS number, chemical formula, and other confidential business information will not be disclosed. If this option is pursued, the manufacturer selling the product in commerce has the final responsibility for publicly describing the sustainable attributes of textile including those listed in Option 1, consistent with all the provisions of this standard. CAS numbers can be used by the manufacturer selling the product to identify sustainable attributes. This responsibility includes describing the environmental benefits of the product over all its stages for all of the environmental impacts/benefits described in Option 1 above.

Option 2 helps obtain more preferable actual data and avoid industry average data for describing LCA impacts/benefits.

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4.10.1 Raw Materials/Feedstock 4.10.2 Process Fiber

4.10.3 Process Yarn

4.10.4 Colors, Auxiliaries, Coatings, including dyes, finishings, topical treatments, & surfactants.

4.10.5 Process Fabrication

4.10.6 Use/Maintenance. Increased Durability and Extended Product Life generally improve an LCA result.

4.10.7 End of Use

- Disassembly & reuse- material deployment, i.e., downcycle, compost, recycle

4.10.8 Attributes/Criteria Questions to Suppliers About Their Materials

- Energy – green power, efficiency. What is the current use?- Pollution prevention, waste reduction, reuse, recycle, recyclable, compostable.

What are current practices?- Health: human & ecological (air, water, land & habitat). How are these impacts

addressed?- R esource depletion. How is depletion of raw materials addressed? - Material substitutes & redesign for environmental improvement. Have these

practices been implemented?- Extended product life. Is this addressed? This covers the sustainability of the

textile after the use and reuse stage, to ensure it doesn’t go to the landfill. Supplier takeback programs should work in the market. This will also force suppliers to avoid downcycle materials that have no useful value, because the supplier will not want to take them back.

- Eco efficiency & effectiveness: Minimize product use, doing more with less while ensuring that overall “LCA environmental footprint” is less. How is this addressed?

- Cost, performance & aesthetics. These issues are prerequisites for this standard.

4.11 Express Warranty or Equivalent Option on sustainable materials’ attributes. Suppliers and manufacturers adhering to this standard expressly warrant in a certification submitted along with the sustainable attributes (section 3.16) about their products as part of the purchase agreement of the product: "The vendor/manufacturer expressly warrants as part of its purchase agreement, that the data and responses to the information requests of this standard are accurate and reliable to the best of the vendor's/manufacturer's knowledge." Confidentiality agreements can be executed to

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protect confidential data including through attorney/client privilege for work the attorney may perform ensuring compliance with this standard.

This express warranty is a general requirement for adherence to this standard, and specifically referenced above in sections 4.6 (sustainably reused textile products), 4.5 (guiding principles), 4.7 (sustainable agriculture), & 4.10 (sustainable attributes). Further, such a warranty and its documentation will be publicly available.

Equivalent Option. An equivalent option can be used satisfying § 4.11, in lieu of providing the express warranty above for general adherence to this standard and specifically for sections 4.5, 4.6, 4.7, 4.10. To do this, suppliers and manufacturers must certify in writing that its communications regarding this standard and applicable sections, comply with the Federal Trade Commission Environmental Marketing Guides at 16 CFR Part 260 (1998) for accurate, reliable, and documented communications: http://www.ftc.gov/bcp/grnrule/guides980427.htm.

This certification must also state that "both the express and implied meaning of the certification about the data, responses to information, and provisions of the standard, is reasonable and based on competent and reliable scientific evidence prepared by qualified professionals in the relevant area, using procedures to produce accurate and reliable results." See 16 CFR § 260.5. Further, such certification and its documentation will be publicly available.

Product Sustainable Attributes

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Table 2

Hypothetical Examples of Textile Qualifying with the Standard

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Example 1 – Sustainable raw material feedstock either natural or synthetic

REPORTABLE SUSTAINABLE ATTRIBUTES

Supplier meets either Option 1 or 2 of section 4.10 and provides warranty in section 4.11.

Example 2 -- Synthetic based reused carpet tiles

RAW MATERIALS

Fiber Reused carpet tiles meeting definition of Sustainably Reused Textile in section 4.6.

Dyes Synthetic/Petrochemical – Meets one of the disclosure requirement options of section 4.10.

PRODUCT MANUFACTURE

Cleaning, trimming, redying & Energy Product meets one of the disclosure requirement options of section 4.10.

PRODUCT USE

OEM Use & Product naturally wears or degrades with no harmful offgassing.

User

PRODUCT MATERIALS REUSE & REMANUFACTURE

Pursuant to section 4.6, no adverse health or environmental effects from reuse, and manufacturer has national reuse program applicable to user anywhere and meets prerequisites for percent product reuse.

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Example 3 -- Certified organic natural biobased fiber

RAW MATERIALS

Fiber Certified organic pursuant to state law or USDA rules in section 4.7..2a and meets BMPs in section 4.7.2b (3).

Dyes Product meets one of the disclosure requirement options of section 4.10.

Auxiliaries Synthetic/Petrochemical – Product meets one of the disclosure requirement options of section 4.10.

PRODUCT MANUFACTURE

Weaving, Finishing & Energy Product meets one of the disclosure requirement options of section 4.10.

PRODUCT USE

OEM Use & Product naturally wears or degrades with no harmful offgassing.

User

PRODUCT MATERIALS REUSE & REMANUFACTURE

Pursuant to section 4.6, no adverse health or environmental effects from reuse, and manufacturer has national reuse program applicable to user anywhere and meets prerequisites for percent product reuse.

Example 4 – 100% biobased corn fiber

Product meets standard requirements for organic level 1 for 2% -20% organic in section 3.13.2 a (1).

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Example 5 – 100% animal natural fiber upholstery fabric

RAW MATERIALS

Fiber Agriculture/Renewable – Meets BMPs section and doesn’t harm or kill animals during fiber acquisition pursuant to section 4.7.2 b (3). Product meets one of the disclosure requirement options of section 4.10.

Dyes Synthetic/Petrochemical – Product meets one of the disclosure requirement options of section 4.10.

Textile Auxiliaries Synthetic/Petrochemical – Product meets one of the disclosure requirement options of section 4.10.

PRODUCT MANUFACTURE

Weaving, Finishing & Energy Product meets one of the disclosure requirement options of section 4.10.

PRODUCT USE

OEM Use & Product naturally wears or degrades with no harmful offgassing.

User

PRODUCT MATERIALS REUSE & REMANUFACTURE

Pursuant to section 4.6, no adverse health or environmental effects from reuse, and manufacturer has national reuse program applicable to user anywhere and meets prerequisites for percent product reuse.

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Appendix 1Examples of Biological & Technical Nutrients From § 3.2

An example of a biological nutrient is Climatex®Lifecycl.™ http://www.greenwave.com/products/homeimprovement/carpet/3104. An example of a technical nutrient is Victor Innovatex Eco Intelligent ™ Polyester Fabrics, http://www.victor-innovatex.com/en/prod/index.htm.

Examples of Successful Reuse Programs, § 4.6

Xerox saved $200m in the first four years of its takeback and remanufacturing program, redefining old equipment as assets and not waste. Other successful programs include Apple Computer, Digital, Hewlett-Packard, IBM, Milliken, Siemens, Sony. See http://www.cutter.com/envibusi/reports/prodstew.htm.

Milliken’s Earth Square Carpet is 99% reused carpet tile that is cleaned and redyed in a closed loop system. The raw material is used carpet tiles. See http://www.earthsquare.com/main.html.

Life Cycle Assessment. See § 4.7 1d

Herman Miller and Shaw recently completed LCAs for the Aeron Chair and Shaw Carpet. Forbo and Philips have LCAs they disclose on their linoleum and lamps respectively. The average time commitment to complete an LCA is 40-80 hours for an engineering student to compile the data. The cost for an ISO compliant LCA is as low as $15k. LCA has been substantially streamlined for 12 environmental impacts by local government purchasers including the City of Portland and surrounding counties, Austin and Santa Monica. See http://www.sppcoalition.org. Finally, LCA, including LCA Thinking or Cradle to Cradle Thinking, are the only accurate means to identify the environmental components of sustainable products.

Organic Feedstock Suppliers & Brokers From § 4.7.2 (1)

Suppliers and brokers of all organic products can be identified by the Organic Trade Association, http:// www.ota.com , Scoular Company http:// www.scoular.com , & Heartland

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Organic Marketing Cooperative Inc. [email protected]. For organic cotton, contact the Organic Cotton Value Chain c/o [email protected], or the Organic Trade Association, http:// www.ota.com .

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