applicable governing agencies available for review by LS&CO� personnel�

5� Conduct laboratory analysis of effluent industrial wastewater to demonstrate that it complies with applicable governing agency requirements and LS&CO�’s Global Effluent Requirements limits, whichever are stricter�

a� Sample the effluent wastewater at least twice per year� By April 30th of each year, submit analytical data on LS&CO�’s Global Effluent Requirements “traditional” parameters (pH, temperature, biological oxygen demand, chemical oxygen demand, total suspended solids, and color)� By October 1st of each year, submit analytical data on all Global Effluent Requirements parameters (traditional and metals)� The first time a factory submits analytical data on effluent wastewater to LS&CO� it must include all Global Effluent Requirements parameters (traditional and metals) as well�

b� Arrange for a neutral party (a qualified independent contractor, not a factory manager or worker) to collect industrial wastewater samples� Factory personnel may collect samples for in-house analysis of pH and temperature� If factory personnel must collect other

1� Escort LS&CO� personnel (or individuals designated by LS&CO�) to appropriate locations to inspect and photograph all wastewater treatment equipment, associated piping, and factory and wastewater treatment system discharge points�

2� Factories must not install piping that allows process water to bypass waste water treatment�

3� Develop an industrial wastewater emergency plan to be used in case the factory’s wastewater treatment process breaks down or the local wastewater treatment facility (POTW) breaks down� The emergency plan must identify emergency response team members, and include emergency shutdown procedures (to shut down the operation until the problem is fixed) and/or procedures to send untreated wastewater to a holding tank that is large enough to hold at least 50% of the volume of the initial sedimentation tank until the problem is fixed�

4� Effluent wastewater must meet the stricter of:

• All applicable governing agency requirements, including discharge limits and permit requirements

• LS&CO�’s Global Effluent Requirements

note: If requested, factories must make valid permits from

2. Global Effluent requirements (GEr)

Application The Global Effluent Requirements apply to industrial wastewater discharges from all factories that finish or launder garments for Levi Strauss & Co� (LS&CO�)� For information regarding domestic wastewater, please see Domestic Wastewater Requirements�Exception Sewing facilities that wash or rinse insignificant volumes of non-denim LS&CO� garments using only detergents or softeners are excluded from LS&CO�’s Global Effluent Requirements� “Insignificant volumes” means fewer than 1000 garments per day� The industrial wastewater from these facilities must be managed according to local legal requirements� See Appendix E for a detailed definition of this exception�PurposeUntreated wastewater discharged from garment operations directly to the environment—such as to rivers, lakes and creeks—may impact surrounding ecosystems and communities� The purpose of this section is to describe LS&CO�’s Global Effluent Requirements program, which aims to reduce environmental, health and safety impacts from wastewater effluent�

factories that discharge directly to the environment (“direct dischargers”) must comply with the following requirements:

continued on next page

wastewater samples because a neutral party is not available, ensure they are trained and follow the procedures in the Appendix, Topic 2�2 for conducting wastewater sampling� Every sample must have a chain-of-custody document that is signed by the individuals who collect and transport the sample and by the individuals who receive and analyze the sample at the laboratory� (See the Appendix, Topic 2 for more information�)

c� Use qualified laboratories (from the list provided in Appendix E, Topic 2�5) and standard test methods� If distance or local regulations prevent a factory from using one of the approved, qualified laboratories, follow the procedure in Appendix E, Topic 2�6 to qualify an independent laboratory�

d� Require the analytical laboratory to provide a report of industrial wastewater test results� Such reports must include test methods, detection limits, and other information that is standard on laboratory reports, and shall include the laboratory’s contact information and certifications� Provide original copies of the independent laboratory’s analysis to the LS&CO� representative, along with a copy of the chain-of-custody document, upon request�

6� Measure incoming volume of fresh water supplied to the factory from all sources and volume of effluent (outgoing) wastewater, using a flow meter� Keep a daily log of flow meter readings of incoming water and outgoing wastewater�

7� Enter all the water and wastewater data into the Information Management System (IMS), as required�

8� Maintain the following minimum laboratory equipment to ensure the wastewater treatment process is working properly: Imhoff settling cones, DO (dissolved oxygen) meter, pH meter, thermometer, and beakers� (See Appendix E�)

9� Conduct laboratory analysis of influent process wastewater once each year, as described in Appendix E, Topic 2�2� This shall include “traditional” parameters (pH, temperature, biological oxygen demand, chemical oxygen demand, total suspended solids, and color) as well as metals� Submit this data by October 1st of each year to the SES Assessor�

10� Maintain an up-to-date flow diagram of the industrial wastewater treatment system, as well as a current list of all chemicals used in the wastewater treatment process� Document in the IMS any changes made to the industrial wastewater treatment system (e�g�, dismantling the sedimentation tank, adding biological treatment, using a new coagulant or flocculent chemical)�

11� Maintain a log that indicates when, why, and how long industrial wastewater treatment units are shut down for major service and repair work such as cleaning, repairing leaking pipes or malfunctioning equipment, or seeding biological treatment� See the Appendix E, Topic 2�9, for a sample maintenance log�

12� Make sure that recycled, treated wastewater meets all applicable legal requirements along with the LS&CO� Global Effluent Requirements parameter limits for final discharges listed in Table 1 below� Treated wastewater to be used for irrigation shall be managed within an approved irrigation program, following all legal requirements� Refer to the LS&CO� Reuse-Recycle Guidelines�

continued on next page

factories that discharge directly to the environment (“direct dischargers”) must comply with the following requirements [continued]:

factories that discharge industrial wastewater to a privately or publicly-owned treatment works (“POTW discharger”) must comply with the following requirements:

1� Measure the volume of (a) incoming fresh water supplied to the factory and (b) effluent (outgoing) wastewater�

2� Enter all the water and wastewater data into the Information Management System (IMS), as required�

3� Develop an industrial wastewater emergency plan to be used in case the factory’s wastewater treatment process breaks down or the local wastewater treatment facility (POTW) breaks down� The emergency plan must identify emergency response team members, and include emergency shutdown procedures (to shut down the operation until the problem is fixed) and/or procedures to send untreated wastewater to a holding tank that is large enough to hold 50% of the volume of the initial sedimentation holding tank until the problem is fixed�

4� Have a current and valid permit to discharge to the POTW from all applicable governing agencies� Show the permit(s) to the LS&CO� representative upon request�

5� Comply with all POTW permit requirements�

6� Request and receive documentation of the POTW’s compliance with local, state, provincial or federal discharge regulations� Provide this documentation to the LS&CO� representative� (See Appendix E, Topic 2�11 for a sample form letter�)

7� Provide the LS&CO� representative with the name and address of the POTW to which it discharges� If the LS&CO� representative requests it, arrange for a visit to and tour of the POTW�

Good practice: Measure influent and effluent with flowmeters attached to incoming water and outgoing wastewater pipes.

Table 1: Global Effluent requirements (GEr) limits

GERAcceptable:

Lower Limit (GER Limit)

Continuous Improvement BandImmediate Action:

Upper LimitNotes

Greater than:Less than or equal

to:

pH 6�0 – 9�0 N/A N/A N/A Acceptable if within the given pH range; not acceptable if out of range

Temp 37�0 °C N/A N/A N/A See exception below�*

TSS 30 mg/l 30 mg/l 45 mg/l >45 mg/l

BOD 30 mg/l 30 mg/l 45 mg/l >45 mg/l

COD Test, Monitor & Report

N/A N/A N/A

Color Qualitative observation

N/A N/A ** See guidance below�**

Foam Not persistent N/A N/A N/A See guidance below�***

Hg 0�01 mg/l 0�01 mg/l 0�015 mg/l >0�015 mg/l Mercury

Cd 0�01 mg/l 0�01 mg/l 0�015 mg/l >0�015 mg/l Cadmium

Pb 0�10 mg/l 0�10 mg/l 0�15 mg/l >0�15 mg/l Lead

As 0�01 mg/l 0�01 mg/l 0�015 mg/l >0�015 mg/l Arsenic

Cu 0�25 mg/l 0�25 mg/l 0�375 mg/l >0�375 mg/l Copper

Ni 0�20 mg/l 0�20 mg/l 0�30 mg/l >0�30 mg/l Nickel

Cr 0�10 mg/l 0�10 mg/l 0�15 mg/l >0�15 mg/l Chromium

Zn 1�0 mg/l 1�0 mg/l 1�50 mg/l >1�50 mg/l Zinc

Cn 0�20 mg/l 0�20 mg/l 0�30 mg/l >0�30 mg/l Cyanide

Co 0�02 mg/l 0�02 mg/l 0�03mg/l >0�03 mg/l CobaltApplicable to non-denim facilities only

* Exception for GEr Temperature limit: For facilities in geographic regions that experience high ambient air temperatures (e�g�, >40° C), wastewater temperature must not be greater than the temperature of the receiving water body�

** Guidance for GEr Color limit: Currently, GER color results are based on visual observation at the discharge point (not on laboratory analysis)� Color is generally accepted to be an aesthetic pollutant by technicians and scientists� Further review of incidents of color should be carried out if local regulatory requirements are not met�

1. If color has been observed in two consecutive sampling events within the year, the factory shall consider this a item and the causes must be addressed to resolve the color issue�

2. If color has been observed in three or more sampling events in two consecutive years, the color incidents are persistent and must be addressed as an item� The factory must agree to and implement a well-studied Corrective Action Plan to resolve the color issue� (See Appendix E, Topic 2�3 for information on color testing�)

*** Guidance for GEr foam limit: Foam is measured by a visual observation at the discharge point; it is not necessary to request a laboratory test for foam�

Training, Rules, and Record Keeping• Managers with responsibility for making sure that the factory

complies with industrial wastewater requirements must be competent and trained on the specifics of LS&CO�’s Global Effluent Requirements program, as well as on the requirements contained in the facility’s discharge permit�

• Supervisors and managers must communicate the specific procedures for meeting the factory’s industrial wastewater requirements (applicable governing agency requirements and Global Effluent Requirements) to workers, contractors and vendors before they begin any work involving the wastewater�

• Factories must train workers whose job duties include working with industrial wastewater and/or wastewater treatment sludge� Training should include proper and safe operation of industrial wastewater collection and treatment equipment, emergency procedures, and proper protective equipment and practices�

• Factories must keep written records to show that training has been completed�

• All wastewater reports shall include the original laboratory report� Test results from in-house sample analyses must include the information listed in Appendix E, Topic 2�7�

Hazard Assessment• When deciding whether a POTW is qualified to handle the

factory’s industrial wastewater, factory managers (or their designated representatives) should visit the POTW and use the survey form in Appendix E, Topic 2�11 to decide whether the equipment is capable of treating industrial wastewater�

• Factories should consider all likely emergency scenarios when preparing their wastewater emergency plans� Examples include earthquakes, typhoons, floods, damaged pipes, on-site treatment system malfunctions, POTW system malfunctions, inoperable pumps� See Appendix E, Topic 2�12 for a sample emergency plan�

Hazard Controls• Factories should have a proper emergency plan in place to

manage factory wastewater so as to protect the surrounding environment and communities until the emergency situation is resolved� The emergency plan may include, for example, provisions for shutting down operations, diverting wastewater to a POTW, or diverting wastewater to a holding tank� Note: All the wastewater kept in a holding tank must, once the emergency has been resolved, be treated properly (if a direct discharger) or discharged to the POTW� The emergency plan shall identify individuals responsible for putting the plan into action� (See Appendix E, Topic 2�12 for a sample plan�)

• Factories should regularly inspect and maintain equipment needed for the emergency plan, especially any wastewater holding tank(s) and associated piping and pumps�

Implementation of Global Effluent Requirements

Bad Practice: Factorywastewatermustnotbypasstreatment.

Program Strategy for managing Wastewater Effluent

• Identify applicable governing agency requirements and those Global Effluent Requirements that apply to the factory’s industrial wastewater� (All)

• Prepare a plan to meet those requirements, including (a) maintaining proper permits, (b) treating wastewater, and (c) contracting with qualified laboratories to conduct wastewater sampling and analysis� (Direct Dischargers only)

• Prepare a plan to meet applicable governing agency requirements and Global Effluent Requirements, including (a) maintaining proper permits, and (b) evaluating how efficiently the POTW treats the wastewater� (POTW Dischargers only)

• Develop an emergency plan to be used in case the water treatment system (factory or POTW) breaks down� (All)

• Obtain and keep up-to-date permits for wastewater discharge from all applicable governing agencies� (All)

• Train managers and employees regarding safe work procedures for managing industrial wastewater� (All)

• Establish and maintain equipment and systems to treat industrial wastewater� (All)

• Conduct industrial wastewater sampling and analysis twice each year to verify that wastewater meets requirements� Report results to LS&CO� (Direct Dischargers only)

• Periodically, audit the wastewater treatment facility (POTW) to determine that they are managing industrial wastewater properly� (POTW Dischargers)

• Improve industrial wastewater treatment system and/or procedures if sampling and analysis activities or SES Assessment indicates the factory does not meet requirements� (Direct Dischargers only)

• Work with LS&CO� (or others) to evaluate alternatives if POTW fails to effectively treat wastewater� (POTW Dischargers only)

• Re-train and/or discipline employees who fail to follow procedures� (All)

further information• SeeAppendix E�

2.1 ScopeProducts• Branded LS&CO� garments

Production Mode• LS&CO� owned/leased-and-operated factories• Direct finishing factories (includes vertically integrated with

finishing)• Agents sourcing finishing factories (includes vertically

integrated with finishing)• Licensee finishing factories (includes vertically integrated with

finishing)• Fabric mills within LS&CO�’s European Region that have signed

a Master Supply Agreement

Wet-laundry processes including the following techniques:• Finishing of garments (bleaching, stonewashing, detergent,

enzymes, softeners, etc�)• Dyeing and/or over-dyeing of garments

Not included in Scope **• Light washing of non-denim tops and tricot in sewing factories*• Printing shops • Leather finishing• Fabric Mills in LS&CO�’s Americas and Asia/Pacific Region • Sundry Factories

* Light washing, for the purposes of this program, is defined as the rinsing and/or washing with detergent or softeners of insignificant volumes** of non-denim, non-bottoms clothing in machines located in sewing factories only� No other type of wet process shall take place in such machines� The effluent from these machines shall be managed according to local legal requirements and permits� If there are no local legal requirements, light-washing effluent shall be treated together with domestic sewage generated by the factory personnel in a biological treatment process on- or off-site (publicly owned treatment works)� Situations outside of this definition shall be escalated on a case-by-case basis to the SES Regional Manager or SES Assessor�

**Insignificant volumes means fewer than 1000 garments per day�

2. Global Effluent requirements

2.2 Sampling Points and Sample Collection

Sampling PointThe sampling point chosen should be easily accessible and safe�

• Influent Wastewater� For influent wastewater, the sampling point is prior to discharge of the process wastewater to the wastewater treatment system and should be based on an 8-hour composite sample� If this point is not accessible, the sampling point should be within the equalization tank and should be a 2-hour composite sample�

• Effluent Wastewater� If the sampling point is designated by the local authority, then this point shall be acceptable to sample final, treated effluent for LS&CO�

• Typically the sampling point should be as close as possible to the wastewater effluent discharge point in a pit or channel, at a level about two-thirds the depth of the pit or channel�

• The frequency and type of sample to be collected must be determined by a competent, suitably qualified individual, based on an examination of flow conditions which encourage homogeneous mixing of the effluent, so that representative fractions of all pollutants of concern are obtained in the sample, including the solids fraction�

8-Hour Composite SamplingAn 8-hour composite sample shall be used to monitor influent process wastewater (see above)� The 8-hour composite sample shall be composed of grab samples taken at regular intervals of 30 minutes or of samples taken using an automatic composite sampler�

2-Hour Composite Sampling A 2–hour composite sample, or equivalent, shall be used to determine whether effluent wastewater is within LS&CO GER limits� The 2–hour composite sample shall be composed of grab samples taken at regular intervals of 15 minutes or of samples taken using an automatic composite sampler�

Alternatively, the 2-hour composite sample can be taken as follows:

• a minimum of 5 samples shall be taken within a maximum of 2 hours, and

• the time elapsed between each sample must be at least 2 minutes�

Over the period of sample collection, samples must be maintained at 4°C in the dark, pending mixing and preparation of the final sample�

continued on next page

Sampling EquipmentAdequately prepared sampling equipment is indispensable to perform the sampling procedure� There are three considerations for sample equipment: (1) material of which it is made, (2) size, and (3) cleanliness/preparation to avoid interference with the parameter to be measured� The laboratory undertaking the analyses should make sample bottles available for sampling staff� Sample bottles shall be prepared appropriately for the different analyses to be carried out� Sample bottles should be washed thoroughly with a detergent recommended for use in laboratories and rinsed with distilled water� At a minimum, the requirements in the table below shall be met�

note: Although maximum holding times are listed, the best practice is to analyze the sample as soon as possible after taking it�

Sampling PersonnelLS&CO� prefers that an independent third party take the sample; this helps avoid data bias� The identity of the independent sample taker shall be included in the chain-of-custody document (see below) for the laboratory and also written in the final laboratory report�

If it is not possible for an independent third party to take the sample, qualified factory personnel who have been trained in the sampling method by an independent laboratory may perform the sampling procedure� Information regarding this training must be made available to the SES Assessor�

Where factory personnel actually take the sample, this information must also be included on the final laboratory report�

Chain-of-Custody RecordA chain-of-custody record must be completed by the individual taking the samples and must accompany the samples as they are sent to the laboratory for analysis� This record provides the date and time the samples were taken, the type of samples, the analyses requested and other important information� The chain-of-custody record requires the signatures of individuals offering and receiving the samples as they are being transported�

Parameter Volume Required (ml)

Type of Container Preserving method

Maximum Holding Time

Temperature 1000 Plastic or Glass Determine immediately on site

None

pH 25 Plastic or Glass Determine on site 2 hours

Color 500 Plastic or Glass Cool to 4°C 24 hours

TSS 50 Plastic or Glass Cool to 4°C 7 days

BOD 1000 Glass Chill to near freezing

48 hours

COD 50 Glass Sulfuric acid to pH<2, maintain at 4°C

28 days

Metals 100 per metal Plastic Nitric acid to pH<2 6 months

Mercury 500 Plastic or Glass Nitric acid to pH<2 28 days (glass) 13 days (plastic)

Where a chain-of-custody form has been provided by the analytical laboratory, it should be used� If no form has been provided, the sample chain-of-custody record on the following page may be used�

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Minimum Equipment for Direct DischargersDirect dischargers shall maintain the following equipment, at a minimum, to ensure the wastewater treatment system is working properly:

TemperatureThe temperature measurement shall be taken in situ, using the standard methods listed under Analytical Methods� (See Topic 2�4�)

No composite sample is required for this determination; a grab sample shall be taken and measured immediately� A thermometer capable of reading to an accuracy of 0�1°C is required�

pHThe pH shall be taken in situ, using the standard methods listed under Analytical Methods� (See Topic 2�4�)

pH meters used for this purpose shall be maintained and calibrated according to manufacturer’s recommendations�

Visual ColorTo establish visual color to meet the LS&CO GER, the following method (which summarizes Section 2 of EN ISO 7887*, Water Quality—Examination and Determination of Colour) shall be used:

Fill a 1-liter beaker with wastewater collected at the established sampling point� Allow to stand until suspended matter has settled� Hold the beaker up with a white sheet of paper behind� Make observations as to hue (color), and intensity of color (light, dark, colorless)�

The visual color observation must conclude whether color is present.

If color is present, additional, quantitative analysis may be required (see the guidance in Table 1 of the GER on page 162�)� If so, laboratories may use either Section 3 of the EN ISO 7887 method or the American Dye Manufacturers Institute (ADMI) method�

Imhoff Settling Cone Dissolved Oxygen (DO) Meter

pH Meter

Beakers

Thermometers

2.3 In-Situ Measurements

continued on next page

FoamA visual inspection of the final effluent should be carried out to determine whether any foam generated quickly dissipates and thus does not build up in channels or the receiving waters� There should be no floating solids on treated wastewater effluent�

* Note: EN = European Norm; ISO = International Standards Organization)

At effluent discharge points, foam should dissipate quickly� It must not persist and there should be no floating solids�

Flowmeter Reading LogCompany Name

Address

Technician

Name

Title

Data

Date and Time

Water Source

(see key)Flowmeter

LocationUnits (litre, gallon, m3) Influent Effluent Volume

Key

A Municipality

B River/Lake

C Rainwater

D Ground water

Total monthly or yearly:

2.4 Analytical Methods

The analytical methods recommended for use in determining the parameters listed in the LS&CO� Global Effluent Requirements are referenced in the table below� Equivalents of these methods are also acceptable (e�g�, equivalent methods from the country’s Bureau of Standards)�

Analytical methods for Sampling and Parameters

Testing Standards

Parameter Parameter Limit US ePa and Standard methodS

ISO eUroPean and nationaL StandardS

Sampling: ISO 5667-1 ff DIN 38402-A 11 ff

Temperature≤37°C Exception: See Topic 2�2

USEPA 170�1 or SM 2550 DIN 38404-C 4

pH, Standard Units

6�0-9�0 USEPA 150�1 or SM 4500H ISO 10523

Total Suspended Solids (TSS)

≤30�0mg/l USEPA 160�2 or SM 2540D ISO 11923 DIN EN 872

Biological Oxygen Demand (BOD)

≤30�0mg/l USEPA 405�1 or SM 5210 ISO 5815-1, -2 DIN EN 1899-1

Chemical Oxygen Demand (COD) (Indicative values for compulsory monitoring only)

Test, Monitor & Report

USEPA 410�4 or SM 5220B or HACH Method

ISO 6060:1989 DIN 38409-H 41

Arsenic ≤0�01 mg/l USEPA 206�2 or SM 3500 ISO 11885* DIN EN ISO 11885*

Cadmium ≤0�01 mg/l USEPA 213�2 or SM 3500

ISO 5961**, ISO 11885* DIN EN ISO 11885*

Chromium ≤0�10 mg/l USEPA 218�2 or SM 3500

ISO 9174**, ISO 11885* DIN EN 1233**, DIN EN ISO 11885*

Cobalt ≤0�02 mg/l USEPA 219�2 or SM 3500

ISO 8288**, ISO 11885* DIN EN ISO 11885*

Copper ≤0�25 mg/l USEPA 220�1 or SM 3500

ISO 8288**, ISO 11885*

DIN 38406**, DIN EN ISO 11885*

Cyanide ≤0�20 mg/l USEPA 335�2 or SM 4500CNE

ISO 6703-1, -2, -3 DIN 38405-D 13-1

Key

* Inductively coupled plasma atomic emission spectroscopy (ICP-OES)

** Atomic adsorption spectrometry (AAS)

ADMI American Dye Manufacturers Institute

DIN Deutsches Institute für Normung (German Institute of Standards)

EN European Norm

ISO International Standard Organization, complete list of water test methods, technical committee

TC147 http://www�iso�org/iso/en/stdsdevelopment/tc/tclist/TechnicalCommitteeStandardsListPage�TechnicalCommitteeStandardsList?COMMID=3666&INCLUDESC=YES

SM Standard Methods

USEPA United States Environmental Protection Agency

continued on next page

Testing Standards

Parameter VaLUe US ePa and Standard methodS

ISO eUroPean and nationaL StandardS

Lead ≤0�10 mg/l USEPA 239�2 or SM 3500

ISO 8288**, ISO 11885*

DIN 38406**, DIN EN ISO 11885*

Mercury ≤0�01 mg/l USEPA 245�1 or SM 3112

ISO 5666 DIN EN 1483

Nickel ≤0�20 mg/l USEPA 249�1 or SM 3500

ISO 8288**, ISO 11885*

DIN 38406**, DIN EN ISO 11885*

Zinc ≤1�00 mg/l USEPA 289�1 or SM 3500

ISO 8288**, ISO 11885*

DIN EN ISO 11885*

Color Offensive color not acceptable

ISO 7887 (for visible appreciation)

Color (guidance values for monitoring only)

Test and Monitor; no offensive color�

Exception: See Topic 2�3

For ADMI units: USEPA 110�1 or SM 2120E [target≤150ADMIunits]

ISO 7887target: 436 nm: ≤7m-1

525 nm: ≤5m-1

620 nm: ≤3m-1

DIN EN ISO 7887

Other Wastewater Requirements

foam: No visible discharge of floating solids or persistent foam on wastewater effluent�

Key

* Inductively coupled plasma atomic emission spectroscopy (ICP-OES)

** Atomic adsorption spectrometry (AAS)

ADMI American Dye Manufacturers Institute

DIN Deutsches Institute für Normung (German Institute of Standards)

EN European Norm

ISO International Standard Organization, complete list of water test methods, technical committee

TC147 http://www�iso�org/iso/en/stdsdevelopment/tc/tclist/TechnicalCommitteeStandardsListPage�TechnicalCommitteeStandardsList?COMMID=3666&INCLUDESC=YES

SM Standard Methods

USEPA United States Environmental Protection Agency

Additional Information on Analytical Methods

SM: Standard Methods for the Examination of Water and Wastewater, American Public Health Association, American Water Works Association and the Water Environment Federation� 19th Edition, 1995� (To order: +202 789 5600)�

USEPA: Methods for Chemical Analysis of Water and Wastes (EPA-600/4-79-020), US Environmental Protection Agency, EPA-600/4-79-020, 1983� (To order: +703 487 4600 or check http://www�synectics�net/resources/)

ISO: Analytical Methods issued by the International Organization for Standardization (ISO) are recommended� (Tel: +41 22 749 0111; Fax: +41 22 733 3430)

Analytical methods for Sampling and Parameters (continued)

2.5 Analytical Laboratories: List

The following international companies and their collaborative networks of certified laboratories have been identified by Levi Strauss & Co� as resources for suitable laboratories that use standard test methods as listed in Topic 4 (or their equivalents) for wastewater analysis as required by the Global Effluent Requirements� Factories can find their locations globally by consulting the list below�

Organization URL

Bureau Veritas http://www�bureauveritas�com

Intertek—Caleb Brett http://www�intertek-cb�com/newsitetest/whoweare/labservicesolutions�shtml

SGS http://www�sgs�com/environmental_laboratories?serviceId=8608&lobId=5548

The pages that follow contain a list of laboratories that have been validated (as of 2009) to conduct GER sampling and analysis� LS&CO� expects to expand this list in the future�

continued on next page

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General • Governing agency permits or other formal permissions to

operate

• Health and safety guidelines for staff working in the laboratory, including available protective equipment in good working order (e�g�, personal protective equipment of good quality, fume hoods, safety showers, and eye fountains)

• Written procedures and records for calibrating and maintaining instruments, accepting and logging samples, preparing and testing samples, reviewing and reporting data, and storing reports/documentation

• Good housekeeping

• Good ventilation

• Routine inspection of all emergency equipment

• A waste disposal plan which takes into account existing regulations and best practice

Personnel• Trained and experienced personnel, with records of staff

qualifications

• Records documenting staff are trained when a new machine is obtained

• Records documenting staff have taken refresher training

Specific• Calibration records and regular calibration of all instruments

• All machines in a well-maintained state; preventative maintenance programs

• Able to perform the range of tests required, using the test methods specified

• Laboratory reports should be well constructed and signed off by authorized personnel

• Laboratory should be willing to tailor the reporting form to customer needs

2.6 Analytical Laboratories: Choosing a Laboratory

PurposeCompliance with LS&CO�’s Global Effluent Requirements relies, among other things, on wastewater testing results produced by laboratories� Therefore, it is critical that labs produce reliable data, of high quality� Laboratory management systems, documentation control, training, and personnel all need to meet standards in order to allow confidence in the results�

Laboratory Certification/AccreditationInternational and national bodies publish norms and requirements for the quality control of test laboratories� The International Standards Organization (ISO) published a quality assurance norm for test laboratories that parallels the industry quality norms ISO 9001 and ISO 9002� The norm, General Requirements for the Competence of Testing and Calibration Laboratories (EN ISO/IEC 17025), establishes the management procedures to ensure quality laboratory results� Certification according to EN ISO/IEC 17025 includes implementation of management procedures, defined responsibilities and document management practices� The ISO/IEC norm 17025 originates in the German norm DIN EN 45001� Laboratories that are EN ISO/IEC 17025-certified and conduct standard test methods, including those listed in this Appendix (Topic 5), can be considered strong candidates for GER wastewater testing� Additionally, accreditations from government agencies, universities, or international consultancies may also be appropriate�

Locating a Certified LaboratoryNational accreditation bodies are the points of contact to find certified laboratories� A list of national accreditation bodies and their contact information can be found under “Directory” at the website of the International Laboratory Accreditation Cooperative (ILAC) (http://www�ilac�org/)� Some of the listed national accreditation bodies have Internet-based lists of certified laboratories; otherwise the accreditation bodies must be contacted directly�

Additional national certification schemes may also exist� For example, India officially entrusts certain laboratories to conduct analysis under the Indian Environmental Protection Act of 1986� Laboratories that want to conduct tests for compliance with the Act need to be certified and listed in the Gazette of India� A current list can be accessed at http://enfor�nic�ne/legis/env/so728e�htm

Criteria for An Approved LaboratoryIn addition to being accredited/certified, laboratories should have the following: suitably qualified staff; the ability to perform all the tests required; and documented standard operating procedures (SOPs) that are implemented for all laboratory processes� Other criteria that may assist in lab selection include affiliations to international labs and references�

If the laboratory is not accredited but has the following systems in place, it can be considered an approved laboratory:

2.7 Submitting the Laboratory Report: Laboratory Guidelines

This list of requirements must be forwarded to all laboratories used in sampling and analysis for the purposes of monitoring the LS&CO� GER� These LS&CO�-specific laboratory requirements help LS&CO� assure the quality of the reporting being received, and help consolidate reports from almost 150 laboratories globally�

Acceptable laboratory reports shall meet the following requirements:

1� Printed on letterhead paper from the laboratory, complete with all contact information and laboratory accreditations or affiliations

2� Signed by an authorized person affiliated with the laboratory and stamped with the laboratory stamp

3� Include the following information:

a� Date and time of analysis

b� Name and title of analyst

c� Sample origin; how and by whom sample was taken; name of organization with which the sample taker is associated (factory or laboratory); holding time and preservation method

d� Analytical method and equivalence to the methods in the LS&CO� Analytical Methods list (Topic 4)

e� Detection limits, where applicable (laboratories should know in the LS&CO� GER levels in advance in order to be able to use the appropriate methods)

f� Units of measurement (our preference is mg/l where applicable)

4� Include a section that covers the in-situ measurements and any observations made during the sampling� This section shall provide the following information:

a� Date and time of analyses

b� Name and title of sampler/analyst

c� Sample origin; how and by whom sample/analysis was taken; name of organization with which the sample taker is associated (factory or laboratory)

d� Analytical method and equivalence to the methods in the LS&CO� Analytical Methods list (Topic 4)

e� Units of measurement

f� Any observations relating to the conditions under which the sampling and in-situ analyses were carried out

If in-situ measurements are taken by factory’s technical staff, the LS&CO� form shall be used for this report, and signed off by the wastewater engineer or supervisor in charge of the operation of the wastewater treatment plant installation�

The laboratory should prepare at least two original reports as outlined above; one destined for the factory and one destined for LS&CO�’s SES Assessor�

LS&CO. prefers that the sampling and analysis be carried out by a third-party laboratory.

2.8 Submitting the Laboratory Report: Factory Guidelines

Reporting DeadlinesLS&CO� analysis results shall be submitted to the SES Assessor according to the following schedule:

If the prior year’s GER performance is compliant:

• By April 30th and October 1st of each year: original laboratory reports of the traditional wastewater parameters (temperature, pH, BOD, COD, color, foam, and TSS) are to be submitted�

• With consistent GER compliance and upon discretion of LS&CO�, submission of laboratory reports to SES may be reduced to once per year (October 1st of each year); however reports will always be required at least once per year�

If the prior year’s GER performance requires improvement:

• By April 30th of each year: original laboratory reports of the traditional wastewater parameters (temperature, pH, BOD, COD, color, foam, and TSS) are to be submitted�

• By October 1st of each year: original laboratory reports of tests carried out on all parameters included in the LS&CO� GER are to be submitted� With consistent GER compliance for metal parameters and upon discretion of LS&CO�, submission of metal parameters may be dropped, however traditional parameters must continue to be submitted by October 1st (and April 30th) for factories whose GER performance requires improvement�

All factories required to sample and analyze wastewater under the LS&CO� GER program shall meet these reporting deadlines�

Other Reporting Issues: • Only the original laboratory report is acceptable to LS&CO�

Factories are not to create and submit their own document for reporting�

• Factories shall keep an original laboratory report on file for review during the annual SES Assessment or follow-up visit�

• Metal analyses require some lead time before the results can be available; factories should take this into account when scheduling sample and analysis in order to submit their reports on time�

• Factories shall arrange for the original report to be provided to the SES Assessor� They may instruct the laboratory to mail the original report directly to the SES Assessor�

AT All TimES, WASTEWATEr EffluEnTS SHAll COmPly WiTH THE lOCAl rEQuirEmEnTS, rEGulATiOnS And/Or PErmiTS.

2.9 Sample Maintenance Log

A sample Wastewater Management System Inspection & Maintenance Log is provided on the following page� LS&CO� recommends that the wastewater treatment plant and equipment be inspected once a month and serviced once a year�

Recommended Preventive Measure:

The wastewater treatment system will require less frequent maintenance and repair if the factory prevents harmful substances from entering the treatment plant (e�g�, medical substances, cigarettes, sanitary napkins, diapers, large amounts of milk or grease, chemical drain openers, chlorine, anti-bacterial detergent, solvents, oil, paint)�

Useful Maintenance Resources:

The facility should keep the following documents readily available to facilitate maintenance work:

• A list of pre-arranged outside service or repair contacts

• A list of the equipment requiring maintenance, including the manufacturer’s name, serial number, and availability of spare parts

• A schedule for lubrication and other preventive maintenance tasks

• Records of past corrective work, problems and services for the equipment

• Spare parts inventory

• A reference list of equipment handbooks

• Emergency equipment inventory

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2.10 Standard Letters and Forms: In-Situ Measurements

Note: These are to be used only if the factory’s technical staff conducts the in-situ measurements�

LS&CO� prefers for measurements to be taken on site by a third-party laboratory, according to the relevant standard analytical method� However, in some situations, this is not achievable� In this case, qualified factory staff must be trained by a third-party laboratory to take the measurements and must use well-maintained and calibrated instruments� The final results shall be recorded on the standard LS&CO� form on the following page� Training records for factory personnel who conduct in-situ measurements must be made available to the SES Assessors�

Factory

Name

Address

Factory Wastewater Technician

Name

Title

Sampling Event

Sampling Date

Sampling Time

Sample Location

In-Situ Sampling and Analysis

Parameter Result Units Analytical Method Remarks

Temperature °C

Temperature of receiving water body (If temperature of the effluent is >37ºC)

°C

pH

Visible Color Hue (color) (e�g�, yellowish, reddish, brown, blue)

Intensity (e�g�, light, dark, very dark, opaque)

Determination ❏ Offensive ❏ Not Offensive

Foam Observation Floating solids ❏ Some

❏ None

Foam ❏ Some foam generated but immediately dissipates

❏ Persistent foam build-up at effluent discharge point

Determination ❏ Foam ❏ No Foam

Comments:

lS&CO. Global Effluent requirements monitoring Program in-Situ Sampling and Analysis form

2.11 Standard Letters and Forms: Publicly Owned Treatment Works (POTW)/Municipal Wastewater Treatment Facilities

The purpose of the standard letter and form is to obtain high-level information on whether the POTW is adequately equipped for LS&CO. purposes. “Adequately equipped” means that the treatment facility is designed to carry out secondary or biological treatment, and that the equipment is working.

Ideally, the attached standard letter and accompanying form are communicated to the POTW by the Factory Contact for SES� The completed form, on return from the POTW, shall be copied and forwarded to the SES Assessor� The factory shall keep this information in its environmental files�

The letter and the form may be translated by the factory, alongside the English version, which must remain in order to facilitate processing within LS&CO�

The standard letter may or may not be used, depending upon how the factory decides to approach the POTW� The survey form may instead be completed during a site visit and interview with POTW personnel�

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{Name and Title of Factory Contact} {Factory Name and Address}

{Date}

{POTW Name and Address}

Dear Sir/ Madam:

Please find attached a short survey form, requesting information on the municipal treatment works that our Company {Factory Name} uses for the final treatment of our wastewater�

This information is being requested by our customer, Levi Strauss & Co�, as part of their LS&CO� Global Effluent Requirements Program, and will be treated as confidential company information for internal use only�

Please complete the form and return it to the address above� I am expecting to communicate this to LS&CO� by {date}�

If you have any questions, or if any clarifications are required, please do not hesitate to call at {Telephone Number of Factory Contact}�

We look forward to receiving the completed form�

Thank you�

Sincerely,

{Name of Factory Contact}

Encl�: {Description of enclosed documents}

Publicly-Owned Treatment Works / municipal Wastewater Treatment facility Survey

Please complete information in empty fields, otherwise check where appropriate�

Factory Name {To be completed by Factory}

Factory Address {To be completed by Factory}

Name of Municipal Treatment Works {From this point forward, to be completed by Factory or POTW}

Address of Municipal Treatment Works

Country

Daily Treatment Capacity (m3)

Treatment Categories Primary Secondary Tertiary

List Treatment Processes

Final Effluent Quality q Good q Average q Bad

Final Effluent Appearance q Yellow q Pale q Floating matter

q Red q Dark q Foam

q Green q Clear

q Brown q Cloudy

q Colorless q Opaque

Treatment process performs as designed q At all times q Most of the times (>75%)

q Seasonally

Major operating challenges ❏ Industrial user effluent out of specifications

❏ Technical know-how

❏ Process overload

❏ Funding

❏ Environmentally sensitive receiving waters

❏ Community relations

Receiving Waters ❏ Stream

❏ Lake

❏ Underground water

❏ River

❏ Sea

Additional Comments

This template can be used for translation�

COnfidEnTiAl POTW infOrmATiOn for lS&CO’s internal use only

Publicly-Owned Treatment Works / municipal Wastewater Treatment facility SurveyPlease complete information in empty fields, otherwise check where appropriate�

Factory Name {To be completed by Factory}

Factory Address {To be completed by Factory}

Name of Municipal Treatment Works {From this point forward, to be completed by Factory or POTW}

Address of Municipal Treatment Works

Country

Daily Treatment Capacity (m3)

Treatment Categories Primary Secondary Tertiary

List Treatment Processes

Final Effluent Quality q Good q Average q Bad

Final Effluent Appearance q Yellow q Pale q Floating matter

q Red q Dark q Foam

q Green q Clear

q Brown q Cloudy

q Colorless q Opaque

Treatment process performs as designed

q At all times q Most of the times (>75%)

q Seasonally

Major operating challenges ❏ Industrial user effluent out of specifications

❏ Technical know-how

❏ Process overload

❏ Funding

❏ Environmentally sensitive receiving waters

❏ Community relations

Receiving Waters ❏ Stream

❏ Lake

❏ Underground water

❏ River

❏ Sea

Additional Comments

Emergency Resolution: Once the emergency situation has been resolved, the facility will take the following steps to return wastewater management system to normal operation:

[Liststepstotaketostartupthesystem.Besuretoincludetreating any wastewater that was stored in holding tanks during theemergencybeforedischargingit.]

Responsibilities: [Assignresponsibilitiestomakesureprocedures are followed smoothly during an emergency� List the responsibilities for Management, Supervisors, Wastewater Technicians,SafetyAdvisorsandothers,asapplicable.]

2.12 Sample Wastewater Emergency Plan

note: This document is intended to serve as a guide for factories as they prepare their own Wastewater Emergency Plans� Thetextinbrackets[]shouldbereplacedwiththefactory’s own information�

Purpose: The [facilityname] Wastewater Emergency Plan describes the facility’s procedures, equipment and personnel responsibilities established to respond to emergencies involving the wastewater management system�

Scope: The following types of emergency situations are addressed in this Emergency Plan:

• [Describethetypesofemergenciesconsideredforthisplan—power outage, equipment breakdown, flooding, POTWbreakdown,etc.]

Wastewater Treatment System Information: [Describethefacility’s wastewater treatment system� Is it a combined domestic and industrial wastewater system, or are these separate systems? Does the facility treat its wastewater and then discharge directly to a body of water or does the facility discharge its wastewater to a privately or publicly owned treatment works (POTW)? Attach documents that describe the system in detail, such as schematics, photos, drawings, etc� Include the location and operation of emergency power switches.]

Emergency Equipment Information: [Includealistoftheemergency equipment that would be necessary to respond to the emergencies described in the scope, along with their location� Examples of emergency equipment include: emergency generators, emergency lighting, emergency holding tankorreservoir,etc.]

Personal Protective Equipment: Emergencies involving the facility’s wastewater management system may present chemical and biological hazards to workers contacting the wastewater� [Describethepersonalprotectiveequipment(PPE)that workers would be required to wear if there is a wastewater system emergency and include locations where this PPE is available.]

Managing Wastewater in Emergency: [Describetheproceduresto follow to safely manage wastewater in all of the emergency situations listed in the Scope� If, for example, the facility has anemergency holding tank, describe how the wastewater is diverted to the holding tank� (The capacity of this holding tank should be at least 50% of the initial sedimentation holding tank�) If instead, the facility would discharge its wastewater to a POTW, describe how the pipes and associated equipment would be checked to ensure their integrity and the POTW would be notified before the discharge occurred� If the facility’s only option is to shut down operations until the emergencysituationisresolved,describetheshutdownprocedure.]