Dirty Fashion

Brands must proactively communicate to manufacturers that operating legally – with all relevant permits and in compliance with national and local legislation – is a key expectation, and crucial to maintaining an ongoing commercial relationship.

Correct management of chemicals and prevention of discharges into the environment are key components of responsible viscose manufacturing. Brands should ask producers to regularly monitor air quality, minimise air pollution and control wastewater through a waste management plan.

Brands should also request that suppliers demonstrate that an appropriate chemical management system is in place through third party verification that examines suppliers’ management records, a full inventory of chemical inputs, a mass balance of the process identifying all losses and documentation of chemical releases (to air, water and in the form of solid waste).

Brands should urge their suppliers to continuously improve their operations, with the aim of achieving closed-loop manufacturing in line with the best practices laid down in the EU’s BAT Reference Document (BREF) on Polymers. The document was published in 2007 and defines the most effective techniques for achieving environmentally responsible production of synthetics and cellulose-based fibres, including viscose, in line with the following parameters:

Workers should wear protective gear at all times, and companies should ensure they are properly trained on health and safety procedures. Adequate air treatment measures should be in place to prevent workers being exposed to toxic chemicals during production. Brands should also ensure that other social issues are addressed: that workers are being paid a living wage, that their freedom of association is respected, etc. For examples of robust corporate accountability initiatives, please refer to the following document: FUTURE OF FASHION: Worker-Led Strategies for Corporate Accountability in the Global Apparel Industry.

Brands should also ensure that inhabitants of areas surrounding viscose factories are not exposed to dangerous chemicals and that the facility has created an effective, timebound and transparent grievance mechanisms. Best practices are outlined in the OECD Guidance for Responsible Supply Chains for the Garment and Footwear Sector (please see page 96 for core criteria for operational-level grievance mechanisms and examples).

Companies should properly manage their processes to save energy and cut greenhouse gas (GHG) emissions. Brands should set targets and transparently report on achievements measured against an established baseline. Viscose manufacturers should set their own GHG reduction targets and pathways to achieve them, especially via increased energy efficiency, for example through heat recovery, and a move towards sustainable renewable energy sources. The recommended approach here would be for brands to disclose supplier-level energy usage and GHG emissions data on an annual basis to show how suppliers are performing relative to targets.

Many factories are responsible for significant historical pollution in the areas where they operate. Brands should encourage manufacturers to engage with local communities and authorities and consult with them on the best ways to remedy any damage caused to their livelihoods and health. This could include corrective actions to ensure healthy water for drinking, personal use and irrigation (i.e. testing the quality of water, improving monitoring and reporting and ensuring corrective action if pollutants are detected), actions to restore ecosystems (i.e. cleaning up local water bodies and soil, and removing solid waste), etc.

For further questions regarding remediation please consult the Worker Rights Consortium website.

In order for brands to ensure transformation takes place, they should regularly monitor and verify how supplier policies are being actioned. This process should be independent, regular and transparent about how brands are fixing the problems and how suppliers are addressing and mitigating the identified risks.

Independent auditing should investigate:

• chemical management and emissions to water and air;
• workers’ health and safety at production sites;
• potential impacts on local communities.

The auditor should also provide recommendations for improvement/remediation. The audit should be publicly available.

For guidelines on social auditing, please see a set of recommendations by the Clean Clothes Campaign in the Fig Leaf for Fashion report (page 9)