lwg versus iso 14001

8/11/2019 LWG Versus ISO 14001

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G:\USERS\general\Environmental Audit\EMS\LWG versus ISO 14001.doc

ISO 14001 versus LWG audit protocol Key differences

ISO 14001 and the LWG audit do not assess environmental performance in the same terms.The LWG audit quantifies environmental performance whereas the ISO standard does not.The LWG protocol is an industry specific standard that makes direct reference to quantifiableprocedures; it measures and records the degree to which environmental performance isdemonstrated. The importance of an Environmental Management System is recognised andis a component part of the LWG protocol. The operation of ISO 14000 or other recognisedstandard is recognised over and above internally derived Environmental ManagementSystems but is not considered an alternative to the LWG protocol for several reasons:

1. The LWG protocol is designed to ensure that the entire supply chain of leathermanufacture can be shown to have attained a measurable level of environmentalperformance. Although some tanners process from raw hide to finished leather manyprocess only some of the stages, i.e. wet blue to finished leather or crust to finishedleather. The assessment and scoring of LWG is designed to encourage and reward

upstream environmental performance. ISO 14000 relates only to the organisationbeing assessed, an organisation that could conceivably be obtaining inputs frompolluting suppliers. The higher grades in the LWG rating mechanism can only beattained if the entire supply chain starting from raw hides has attained a common andmeasurable level of performance.

2. The ISO standard relates to the management system and is explicit in not attemptingto quantify environmental performance, indeed, in the introduction it states

This International standard does not establish absolute requirements forenvironmental performance beyond the commitments, in the environmentalpolicy, to comply with applicable legal requirements and with other requirements

to which the organisation subscribes, to prevention of pollution and to continualimprovement. Thus, two organisations carrying out similar operations but havingdifferent environmental performance can both conform to its requirements (ouritalics).

In contrast the LWG rating system is expressly designed to measure and rateenvironmental performance. The LWG audit proclaims

The purpose of this [LWG] tannery auditing protocol is to evaluate theenvironmental performance of tannery operations

The LWG protocol assesses tannery operations in absolute terms, for exampleenergy requirement to produce a square foot of leather, proportion of wastesrecycled etc.

3. The introduction to ISO further statesadoption of this standard will not in itself guarantee optimal environmentaloutcomes.

The scoring and rating system within the LWG protocol, using questions aligned toindustry specific technologies, is designed to enable tanneries to measureenvironmental performance, benchmark themselves against their peers, identifystrengths and weaknesses in environmental performance and thereby enable themto identify the actions required to attain optimal environmental outcomes.


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4. The ISO standard makes no demands on an organisation to achieve a recognisedlevel of performance

1 Scope It does not itself state specific environmental performance criteria.As indicated above, the LWG protocol is based on tanneries attaining specificperformance criteria to gain a rating.

5. The ISO standard indicates that results can be measured against the companysownstandards

3 Terms and definitionsNOTE In the context of environmental managementsystems (3.8), results can be measured against the organization's (3.16)environmental policy (3.11), environmental objectives (3.9), environmental targets(3.12) and other environmental performance requirements

This would not lead to transparency for customers unless those standards areexpressly quantified and stated. In contrast LWG results are measured againstcommon performance guidelines, not against the variable measures that occur whenorganisations define their own objectives or requirements.

6. Both audit protocols make reference to legal compliance although the ISO standardis worded less strongly, referring to commitmentto comply rather than a requirementto comply;

Section 4.2 Environmental policy subsection (c) includes a commitment tocomply with applicable legal requirements and with other requirements to whichthe organization subscribes which relate to its environmental aspects

LWG goes beyond a commitment to comply with applicable legal requirements andinsists on actual compliance with the requirements of operating permits and otherlegal requirements. Several ISO certified companies have failed the LWG audit forfailing to comply with legal requirements. During the course of some of these LWG

audits, when questioned as to how the company managed to attain ISO certificationdespite failing to act in accordance with permit/legislative requirements or bydischarging untreated affluent it was confirmation was given of ISO certificationhaving been awarded due to the companys commitmentto future compliance.

7. The phasing and with other requirements to which the organization subscribes limits the compliance requirements of the company. For example, a major impact onthe global environment is threatened by the continual destruction of the Amazonianbiome. This threat has been identified by many organisations and initiatives havebeen developed to halt deforestation and the associated human rights abuses in theareas where it is occurring. Unless specifically requested by the customer there is

limited requirement outside of LWG to declare the extent of traceability of rawmaterial and therefore the potential impact of this aspect of a companys operationscould be, and frequently is, overlooked. It is a requirement of the LWG protocol thatthe degree and method of traceability of raw material is demonstrated. The gradingsystem allows comparison of the extent and robustness of traceability within thesupply chain.


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8. Legal requirements vary considerably from country to country and often from state tostate within countries. Legal compliance imparts no information about environmentalperformance other than with respect to the country in which the organisation isoperating.

4.3.2 Legal and other requirementsThe organization shall establish, implement and maintain a procedure(s)a. To identify and have access to the applicable legal requirements and other

requirements to which the organization subscribes related to itsenvironmental aspects, and

b. To determine how these requirements apply to its environmental aspects.

A.3.2 Legal and other requirementsThe organization needs to identify the legal requirements that are applicable to itsenvironmental aspects.Examples of other requirements to which the organization may subscribe include,if applicable agreements with customers

It cannot be argued that ISO 14000 is an alternative to the LWG protocol. On thecontrary, as the ISO standard indicates4.3.2 Legal and other requirementsThe organization shall establish, implement and maintain a procedure(s)

to identify and have access to the applicable legal requirements and otherrequirements to which the organization subscribes related to itsenvironmental aspects, andto determine how these requirements apply to its environmental aspects.

The organization shall ensure that these applicable legal requirements andother requirements to which the organization subscribes are taken intoaccount in establishing, implementing and maintaining its environmental

management system.This requirement of ISO 14000 indicates that if the customer requires the supplier toundergo an LWG audit so as to quantify environmental performance it is a conditionof ISO certification that the supplier takes this requirement into account.

9. The ISO certification requires the setting of targets; however these can be setinternally by the tannery and do not necessarily have any relationship with targetsattainable generally within the industry.

4.3.3 Objectives, targets and programme(s)Theorganization shall establish,implement and maintain documented environmental objectives and targets, atrelevant functions and levels within the organization. The objectives and targetsshall be measurable, where practicable, and consistent with the environmental

policy, including the commitments to prevention of pollution, to compliance withapplicable legal requirements and with other requirements to which theorganization subscribes, and to continual improvement.

LWG goes beyond targets and defines specific environmental performance. Withoutexpressly comparing and reporting performance data against companies undertakinga similar range of operations the attainment of ISO certification provides littleinformation to stakeholders. For example, a tanner using 100MJ per square ft. ofleather produced could have a stated aim to achieve a 10% reduction, and may doso, fulfilling the requirements of ISO certification! However this imparts no usefulinformation to stakeholders. ISO certification in this case could even be consideredmisleading if the majority of tanners undertaking the same range of operations werealready operating at an average of 50 MJ per square foot of leather produced. LWGprovides transparency and awards achievement (i.e. low energy usage) as opposedto intention (i.e. to reduce energy usage).


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10. The rating of the companies audited is dependent upon a defined level ofperformance across all environmental aspects. Tanners who have attained ISO14000 generally score better in the LWG audit than tanners who have not (41% ofaudited tanners with ISO 14000 scored Gold in LWG compared to an overall averageof 21.5% of tanners attaining Gold). However failure of the LWG audit can also occur,but only on two counts

a. failure to comply with permit conditions or legislationb. Discharge of untreated effluent to water courses

Of the 10 companies that have failed the LWG audit, 7 had ISO 14000certification. Although this may be the fault of individual auditors rather than ISO1400 per se, this is perhaps the most damning illustration that ISO 14000 is notcompletely fulfilling the requirements of the brands.

lwg versus iso 14001

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