WATER DISCHARGE REPORT II
PART OF THE G-STAR ZERO DISCHARGE OF HAZARDOUS CHEMICALS COMMITMENTDECEMBER 2013

TABLE OF CONTENTS
1.

INTRODUCTION

PAGE 3

2.

FACTORY INFORMATIONPAGE 5

3.

METHOD

PAGE 94.

EXPLANATION OF THE RESULTS

PAGE 13

5.

CONCLUSIONSPAGE 15

6.

FOLLOW UP ACTIONSPAGE 16

APPENDIX I

PAGE 172

1. INTRODUCTION
G-Star is committed to eliminate industrial releases of hazardous chemicals into the environment, and set thetarget to reach zero discharge of hazardous chemicals (ZDHC) from all our products and production
processes by 2020.
G-Star has taken several steps to reach this target as outlined below.
The basis of our Responsible Supply Chain policy is the G-Star Supplier Code of Conduct (CoC) that clarifies
and elevates the expectations we have of suppliers we work with and lays down the minimum Social andEnvironmental, Health & Safety (EHS) standards we expect each factory to meet.
The CoC refers to the G-Star Restricted Substances List (RSL) that is the basis for monitoring the use ofchemicals in G-Star products, and follows strict national and international laws. We do not allow the use ofchemicals in our products that can have a harmful effect on health or the environment. Our Textile Engineers
and Chemical Specialists work together with suppliers on proper use of chemicals and compliance with the
RSL. To check compliance of our products with the RSL, we perform risk assessments, auditing and testing ofour products.
Secondly, cooperation across the entire industry is essential. Therefore, G-Star has taken the initiative tocollaboratively work with a large number of world leading brands towards zero discharge of hazardous
chemicals by 2020. This so called ZDHC Joint Roadmap Group has set specific actions and timelines torealise this shared commitment and to set the right standard of environmental performance for the global
apparel and footwear industry. G-Star supports and puts effort in the group’s activities to collectively find safe
substitutions for hazardous chemicals used in the apparel industry and work towards zero discharge ofhazardous chemicals by 2020. More information can be found on the ZDHC Joint Roadmap website.
At the same time, we have published our individual action plan that lists all measures and actions necessary toreach our ZDHC commitment. The progress G-Star makes is published each year in a progress report.
In addition, we are a system partner of bluesign technologies ag. We are committed to implement theirbluesign® standard in our supply chain. This is an independent standard that guarantees that products arefree of hazardous chemicals. By joining bluesign technologies ag we support our environmental goals andencourage suppliers in our entire textile production chain, from raw materials to textile manufacturers, to cometo a healthy, safe and environmentally friendly production process.
G-STAR WATER DISCHARGE REPORT II
In August 2013, G-Star published the G-Star Water Discharge Report I. This report described the results ofwater tests executed at our Global South suppliers accounting together for a minimum of 25% of our global
production. Now, in December 2013, we have published the G-Star Water Discharge Report II showing thewater discharge data of our suppliers accounting for 80% of our global production. The results of thesereports allow us to obtain an understanding of the use and discharge of the 11 priority chemicals during
production and form a baseline assessment of the presence of the 11 priority chemicals in our supply chain.
For this second report, Bureau Veritas CPS collected and tested water samples on the presence of thefollowing 11 priority chemical groups:
1. Alkylphenols
2. Phthalates
3. Brominated and chlorinated flame retardants
4. Azo dyes
5. Organotin compounds
6. Perfluorinated chemicals
7. Chlorobenzenes
8. Chlorinated solvents
9. Chlorophenols
10. Short chain chlorinated paraffins
11. Heavy metals
3The goals of the research of which the results are shown in this report are the following:
1. Do a baseline assessment of the quality of the water discharged by the factories where G-Star products or
fabrics are produced.
2. Identify whether analytes from the 11 priority chemical classes are present in the water discharges at
supplier locations and at what level.
3. Better insight in the chemical use in the production process at the factories and possible interrelation withchemicals after treatment of the water.
4. Formulate, prioritise and coordinate follow up activities with suppliers to reach our target.
5. To work towards zero discharge of hazardous chemicals by 2020.
As G-Star and all suppliers included in this report acknowledge the ‘right to know principle’, we encourage
and support our suppliers to publicly disclose the water discharge data. The majority of our Chinese suppliers
that are included in the baseline assessment agreed to disclose the water discharge data on the website of
the Chinese Institute of Public & Environmental Affairs (IPE), a Pollutant Release and Transfer Register(PRTR) platform in China. Where our suppliers decided not to publicly disclose via the IPE website, we willcontinue to encourage and support them to do so.
To view the results of the water tests we refer to the following locations:• For the discharge data of the factories in China please go to the IPE discharge platform website.
• For all other factory discharge data we refer to Appendix I of this report.

4

2. FACTORY INFORMATION
For this report G-Star selected suppliers from China, Bangladesh, Vietnam and India. Together with the
suppliers selected for the Water Discharge Report I, these suppliers account for a minimum of 80% of ourglobal production volume. In this chapter both the type of the factory and the business relationship with G-Starare explained.
The test results of our water tests can be either found on IPE or in Appendix I of this report. In line with the‘right to know principle’, some Chinese factories publicly disclosed the discharge data on the IPE discharge
platform website. Other Chinese suppliers are currently not disclosing the water discharge data on the IPE
website. G-Star will continue the dialogue with these suppliers in this regard. The reports of these suppliers
can be found in Appendix I of this report. Up till now there is no proper platform for disclosure of discharge
data available that is known and used by communities in Bangladesh, Vietnam and India. Disclosing single test
results outside of a proper framework is inadequate. Both G-Star and the suppliers are pushing for afunctioning and known PRTR platform for these countries. As soon as a proper platform for disclosure isavailable, the dialogue on disclosure of water discharge data will be continued. Until that time, the water test
results of all suppliers from Bangladesh, Vietnam and India are disclosed via Appendix I of this report.
G-Star does not publicly share its supplier details because this is competitively-sensitive information.
Therefore, the names of the suppliers are anonymised in this report. For reference we numbered the factories
and indicated the country of production in line with the annotation of the Waste Discharge Report I. In the firstreport we shared the discharge results of five Chinese factories (coded: Factory 1-5 China) and one Indianfactory (coded: Factory 1 India). In this report we share the results of Chinese Factory 6–9, Vietnam 1,
Bangladesh 1-5 and India 2. Below the suppliers and the relationship to G-Star is explained.
FACTORY 6 CHINA
Sector: Textile
Subsector: MillThe factory is located in Hangzhou Province in China. It is specialised in fabric making. The main processes
are warping, sizing, beaming, weaving, dyeing and finishing. The factory is located in an industrial zone andshares the effluent treatment plant with other companies.
The relationship between G-Star and the factory is depicted below:

FACTORY 7 CHINA
Sector: Apparel
Subsector: Washing
The factory is located in Guangdong Province in China. It is specialised in the washing of garments. The mainprocesses are garment washing and garment dyeing. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

5

FACTORY 8 CHINA
Sector: Textile
Subsector: MillThe factory is located in Guangdong Province in China. It is specialised in fabric making. The main processes
are knitting, dyeing and finishing. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

FACTORY 9 CHINA
Sector: Textile
Subsector: MillThe factory is located in Jiangsu Province in China. It is specialised in fabric making. The main processes are
spinning, weaving and dyeing. The factory is located in an industrial zone and shares an effluent treatment
plant with other companies.
The relationship between G-Star and the factory is depicted below:

FACTORY 1 BANGLADESH
Sector: Apparel
Subsector: Multiple processes
The factory is located in the Dhaka division in Bangladesh. It is a vertically integrated supplier. The mainprocesses are spinning, yarn dyeing, knitting, fabric dyeing, fabric finishing, cutting, printing, embroidery,sewing, washing, finishing and packaging. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

6

FACTORY 2 BANGLADESH
Sector: Apparel
Subsector: Multiple processes
The factory is located in the Dhaka division in Bangladesh. It is a vertically integrated supplier. The mainprocesses are fabric dyeing, fabric finishing, cutting, sewing, finishing, dyeing, laundry, embroidery andprinting. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

FACTORY 3 BANGLADESH
Sector: Apparel
Subsector: Washing and finishing
The factory is located in the Dhaka division in Bangladesh. It is specialised in the washing of garments. The
main processes are spinning, knitting, fabric dyeing, printing, cutting, sewing finishing, dyeing, laundry andprinting. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

FACTORY 4 BANGLADESH
Sector: Apparel
Subsector: Multiple processes
The factory is located in the Dhaka division in Bangladesh. It is a vertically integrated supplier. The mainprocesses are knitting, fabric dyeing, cutting, embroidery, sewing, finishing, dyeing, laundry and printing. The
factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

FACTORY 5 BANGLADESH
Sector: Apparel
Subsector: Multiple processes
The factory is located in the Chittagong division in Bangladesh. It is a CMT supplier. The main processes are
cutting, sewing, laundry and finishing. The factory is located in an industrial zone and shares an effluent
treatment plant with other companies.
The relationship between G-Star and the factory is depicted below:

7

FACTORY 1 VIETNAM
Sector: Apparel
Subsector: Multiple processes
The factory is located in Dong Nai Province in Vietnam. It is a CMT supplier. The main processes are sewing,
printing, finishing, laundry. The factory makes use of a closed water system therefore no water is released into
the environment after usage. Fresh water is added when necessary.
The relationship between G-Star and the factory is depicted below:

FACTORY 2 INDIA
Sector: Textile
Subsector: Dyeing
The factory is located in Gurajat State in India. It is specialised in fabric making. The main processes are yarndyeing, warping, sizing, weaving and fabric processing. The factory has its own effluent treatment plant.
The relationship between G-Star and the factory is depicted below:

83. METHOD 1
LABORATORY SELECTION
For the second batch of water sampling and testing as described in this report G-Star chose Bureau Veritas
CPS (hereafter BV) as service provider. G-Star selects service providers among other factors on the basis of
their quality, capabilities, experience, reputation and laboratory presence.
BV is a global leader in the conformity assessment industry of consumer products and its supply chains. Theirservice portfolio includes testing, inspection, audit, consultation and certification relating to consumer
products. They have over 70 laboratories and over 10,000 staff located in Asia, Europe, Central Africa, andAmericas. For more information we refer to the BV website.
Since the samples were taken from factories in China, Bangladesh, Vietnam and India several offices wereinvolved in the sample collection and testing, namely Bureau Veritas Consumer Products Services (Shanghai),
Bureau Veritas Consumer Products Services (Guangzhou), Bureau Veritas Consumer Products Services (BD)
Ltd. L, Bureau Veritas Consumer Products Services Vietnam Ltd. L and Bureau Veritas Consumer Products
Services (I) Pvt. Ltd. L.
SAMPLING METHOD
BV collected composite samples of wastewater before treatment and waste water after treatment from theselected factory sites. A composite sample is a combination of a series of grab samples taken at specific timeintervals. Composite samples represent the water stream over a period of time more accurately and arereflective of the daily condition of the factory as long as the factory and the treatment plant are operating
normally when samples are taken. In some cases the incoming water was also tested. In most cases the
samples were collected between 2 and 5 pm.
In the table below the sample and the sampling point are indicated.
No. ofsample1

SampleLocation of sampling point

Incoming water

Water source or water tank to feed into the factory

1

Wastewater before treatment

1

Wastewater after treatment(water at discharge point)

Wastewater after going through the sieve
removing large debris before treatment
Wastewater pipe to discharge the effluent

The factories were instructed to ensure normal operations on the sampling day in order for the sample toreflect the general daily conditions of the factory’s discharges and ensure that the wastewater treatment plant
worked properly.
TESTING METHOD AND DETECTION LIMITSAs per our public commitment towards Zero Discharge of Hazardous Chemicals, G-Star requested to test the2samples to the limits of current technology . Bureau Veritas has guaranteed that the testing reports represent
the lowest detection limit of each lab capacity at this moment. The labs will further develop to reach lower
detection limit as part of continuous improvement.
Please see the table below for a list of the tested chemicals, the detection limits and test methods.
List of Phthalates :

1

2

No.

Test Method

Reporting Limit

Unit

1

With reference to U. S. EPA 8270D. (For Wastewater)

Each: 0.001

Ppm

All information of this chapter is provided by Bureau Veritas.
Please see the table below column reporting limit and Unit for the detection limit per substance.
9

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.

1234Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Di-2-ethylhexyl phthalate (DEHP)
Di-n-octyl phthalate (DNOP)

85-68-7
84-74-2
117-81-7
117-84-028553-12-0 &68515-48-0
26761-40-0 &68515-49-1
131-11-3
84-66-2

9
10
11
12

Di-n-propyl phthalate (DPRP)
Di-iso-butyl phthalate (DIBP)
Di-cyclohexyl phthalate (DCHP)
Di-n-hexyl phthalate (DnHP)

131-16-8
84-69-5
84-61-7
84-75-3

5

Di-iso-nonyl phthalate (DINP)

13

Dinonyl phthalate (DNP)

84-76-4

6

Di-iso-decyl phthalate (DIDP)

14

Di-iso-octyl phthalate (DIOP)

27554-26-3

78

Dimethyl phthalate (DMP)
Diethyl phthalate (DEP)

15-

Dimethoxyethyl phthalate (DMEP)-

117-82-8-

Reporting Limit

Unit

1

With reference to U. S. EPA 527 and with reference to U.
S. EPA 8321B. (For Wastewater)

Each (PBBs & PBDEs): 0.00005;
Each (TRIS, TBBPA & HBCCD):
0.0005;
Each (Others): 0.025

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

1

Polybromobiphenyls (PBBs)

Various5

126-72-7

6

Various7

79-94-7-

List of Brominated Flame Retardants :
No.

2
3
4

Test Method

Tris(2,3-dibromopropyl)
phosphate (TRIS)
Polybromodiphenyl ethers(PBDEs)
Tetrabromobisphenol A (TBBPA)

Bis(2,3-dibromopropyl)
phosphate
Hexabromocyclododecane(HBCDD)
2,2-Bis(bromomethyl)-1,3propanediol (BBMP)-

CAS-No.
5412-25-9
3194-55-6
3296-90-0-

List of Chlorinated Flame Retardants :No.

Test Method

Reporting Limit

Unit

1

With reference to U. S. EPA 527 and with reference to U.
S. EPA 8321B. (For Wastewater)

TCEP: 0.00005; TDCP: 0.0005

Ppm

No.

Name of Analytes

No.

Name of Analytes

CAS-No.

1

Tris(2-chloroethyl) phosphate(TCEP)

2

Tris(1,3-dichloro-isopropyl)
phosphate (TDCP)

13674-87-8

CAS-No.
115-96-8

List of Aromatic Amines in Azo Colorants :No.

Test Method

Reporting Limit

Unit

1

With reference to German Standard DIN 38407-16, withreference to European Standard EN 14362-1
incorporating Corrigendum and with reference toEuropean Standard EN 14362-3. (For Wastewater)

Each: 0.0001

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.

14-Aminodiphenyl(Biphenyl-4-ylamine or
Xenylamine)

92-67-1

14

p-Cresidine(6-Methoxy-m-toluidine)120-71-8

2

Benzidine

92-87-515

3
4

4-Chloro-o-toluidine
2-Naphthylamineo-Aminoazotoluene(4-Amino-2`,3-dimethylazobenzne
or 4-o-tolyazo-o-toluidine)
5-nitro-o-toluidine(2-Amino-4-nitrotoluene)
4-Chloroaniline(p-Chloroaniline)

95-69-2
91-59-8

16
17

97-56-318

o-Toluidine(2-Aminotoluene)95-53-4

99-55-8

19

4-Methyl-m-phenylenediamine(2,4-Toluenediamine)

95-80-7

106-47-8

20

2,4,5-Trimethylaniline

137-17-7

5
6
7

10

4,4`-Methylene-bis-(2chloraniline)(2,2`-Dichloro-4,4`-methylenedianiline)
4,4`-Oxydianiline
4,4`-Thiodianiline

101-14-4
101-80-4
139-65-1

4-Methoxy-m-phenylenediamine(2,4-Diaminoanisole)
4,4`-Diaminodiphenylmethane
9(4,4`-Methylenedianiline)
3,3`-Dichlorobenzidine
10(3,3`-Dichlorobiphenyl-4,4`ylenediamine)
3,3`-Dimethoxybenzidine
11(o-Dianisidine)
3,3`-Dimethylbenzidine
12(4,4`-Bi-o-tolidine)
4,4`-Methylenedi-o-toluidine
13(3,3`-Dimethyl4,4`-diaminodiphenylmethane)
List of Organotin Compounds :8615-05-4

21

101-77-922o-Anisidine(2-Methoxyaniline)
4-Aminoazobenzene(p-Aminoazobenzene)

91-94-1

23

2,4-Xylidine(2,4-dimethylaniline)

95-68-1

119-90-4

24

2,6-Xylidine(2,6-dimethylaniline)

87-62-7

119-93-725

Aniline62-53-3

838-88-0-

90-04-0
60-09-3--No.

Test Method

Reporting Limit

Unit

1

With reference to European Standard EN ISO 17353.
(For Wastewater)

Each: 0.00001

Ppm

No.

Name of Analytes

1
2
3
4

Monobutyltin (MBT)
Dibutyltin (DBT)
Dioctyltin (DOT)
Tributyltin (TBT)

CAS-No.

No.

Name of Analytes

CAS-No.

Various

5
6
7
8

Triphenyltin (TPhT)
Tricyclohexyltin (TCyHT)
Trioctyltin (TOT)
Tripropyltin (TPT)

Various

List of Chlorobenzenes :No.

Test Method

Reporting Limit

Unit

1

With reference to U. S. EPA 8260B and with reference to
U. S. EPA 8270D. (For Wastewater)

Each: 0.00002

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.

1

Chlorobenzene
1,2-Dichlorobenzene

108-90-7
95-50-1

6

1,3,5-Trichlorobenzene

108-70-3

7

1,2,3,4-Tetrachlorobenzene

634-66-2

1,3-Dichlorobenzene,
1,4-Dichlorobenzene

541-73-1,
106-46-7

8

1,2,3,5-Tetrachlorobenzene,
1,2,4,5-Tetrachlorobenzene

634-90-2,
95-94-3

1,2,3-Trichlorobenzene
1,2,4-Trichlorobenzene

87-61-6
120-82-1

9Pentachlorobenzene

608-93-5

10Hexachlorobenzene

118-74-1

2
3
4
5

List of Chlorinated Solvents :No.

Test Method

1

With reference to U. S. EPA 8260B. (For Wastewater)No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.

123
4

1,2-Dichloroethane
1,1-Dichloroethylene
Methylene Chloride

107-06-2
75-35-4
75-09-2

cis-1,2-Dichloroethylenetrans-1,2-Dichloroethylene
Chloroform

156-59-2
156-60-5
67-66-3

7
8
9
10

1,1,1-Trichloroethane
Carbon Tetrachloride
Trichloroethylene
1,1,2-Trichloroethane

71-55-6
56-23-5
79-01-6
79-00-5

11
12

1,1,1,2-Tetrachloroethane
Tetrachloroethylene630-20-6
127-18-4

56Reporting Limit
Each: 0.1

Unit

Ppm

List of Chlorophenols :No.

Test Method

Reporting Limit

Unit

1

With reference to U. S. EPA 8270D. (For Wastewater)

Each: 0.0005

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.
609-19-8,
15950-66-0
576-24-9
95-77-2

1

Pentachlorophenol

87-86-5

8

2

2,3,4,5-Tetrachlorophenol
2,3,4,6-Tetrachlorophenol

4901-51-3
58-90-2

9

3,4,5-Trichlorophenol,
2,3,4-Trichlorophenol
2,3-Dichlorophenol

10

3,4-Dichlorophenol

3

11

4

2,3,5,6-Tetrachlorophenol

935-95-5

11

5
6
7

2,4,6-Trichlorophenol
2,3,5-Trichlorophenol
2,4,5-Trichlorophenol

88-06-2
933-78-8
95-95-4

12
13
14

2,4-Dichlorophenol,
2,5-Dichlorophenol,
2,6-Dichlorophenol,
3,5-Dichlorophenol
2-Chlorophenol
3-Chlorophenol
4-Chlorophenol

120-83-2,
583-78-8,
87-65-0,591-35-5
95-57-8
108-43-0
106-48-9

List of Short Chain Chlorinated Paraffins :No.

Test Method

Reporting Limit

Unit

1

With reference to International Standard ISO 12010. (For
Wastewater)

0.0004

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

1

Short Chain ChlorinatedParaffins

85535-84-8

-

-

-

Reporting Limit

Unit

Cd: 0.0001; Hg: 0.00005;
CN : 0.02
Each (Others): 0.001

Ppm

CAS-No.

List of Heavy Metals :No.

Test Method

1

With reference to U. S. EPA 3015A and with reference to
U. S. EPA 6020A./ With reference to U. S. EPA 7196A./
With reference to APHA 4500 CN- C:2012 & APHA
4500 CN- E:2012 (For Wastewater)No.

Name of Analytes

1
2
3
4
5

Arsenic (As)Cadmium (Cd)Mercury (Hg)
Lead (Pb)

67

CAS-No.

Various

Antimony (Sb)
Cobalt (Co)
Nickel (Ni)No.

Name of Analytes

8
9
10
11
12

Copper (Cu)Zinc (Zn)
Chromium (Cr)Manganese (Mn)
Chromium VI (Cr VI)

13-

Cyanide (CN )CAS-No.

Various--

List of Alkylphenols & Alkylphenol Ethoxylates :No.

Test Method

1

With reference to ASTM International Standard ASTM
D7065. (For Wastewater)No.

Name of Analytes

12Octylphenol (OP)Octylphenolethoxylates (OPEOs)

Reporting Limit

Unit

Each (OP & NP): 0.001;
Each (OPEOs & NPEOs): 0.005

Ppm

CAS-No.

No.

Name of Analytes

CAS-No.

Various3
4Nonylphenol (NP)
Nonylphenolethoxylates (NPEOs)

Various

List of Perfluorinated Chemicals :No.

Test Method

Reporting Limit

Unit

1

In house method and analysis by Liquid Chromatograph
Mass Spectrometer (LC-MS). (For Wastewater)

Each: 0.00001

Ppm

No.

Name of Analytes

CAS-No.

No.

Name of Analytes

CAS-No.

1

Perfluorooctanoic acid (PFOA)

335-67-1

4

Perfluorohexane sulphonates(PFHxS)3871-99-6

2795-39-3

5

Perfluorobutanoic acid (PFBA)

375-22-4

307-24-4

6

Perfluorobutane sulphonates(PFBS)

29420-49-3

2
3

Perfluorooctane sulphonates(PFOS)
Perfluoro-n-hexanoic acid
(PFHxA)• U. S. EPA = United States Environmental Protection Agency• APHA = American Public Health Association
For clarification, please see the unit comparison below:• PPM (part per million) = mg/L (milligrams per liter), mg/kg (milligrams per kilogram)• PPB (part per billion) = μg/L (micrograms per liter), μg/kg (micrograms per kilogram)• PPT (parts per trillion = ng/L (nanograms per liter), ng/kg (nanograms per kilogram)
12

4. EXPLANATION OF THE RESULTS
G-Star considers the results of these water tests a baseline assessment of the use and discharge of the 11priority chemicals in our supply chain. Although it is difficult to draw conclusions from a baseline assessment,
some general remarks can be made.
GENERAL BASIC REMARKS
Bureau Veritas found that the results of the samples tested for this batch were all within the legal limits of the3
applicable local laws. Bureau Veritas tested the samples against the lowest detection limits available.
For this batch water samples were taken in four different countries: China, Bangladesh, India and Vietnam.
According to Bureau Veritas the water discharge results differ per country. In general, they state that the water
discharged in Bangladesh and Vietnam contains fewer chemicals than in China and India. Although G-Star did
not test a representable sample to confirm this statement, the results of our baseline assessment are in linewith this general remark.
The three most detected substances in the output water were:4

Heavy metals
There are many explanations for the presence of heavy metals in the waste water after treatment. For example,
metals are commonly used in pigments, dyes, heat stabilizers, leather tanning, surface treatments, pesticides,
and catalysts. They can be found in natural fibres, synthetic fibres, natural leather, synthetic leather, plastics,
rubber, paints, surface coatings and metal trims. They can also be present in metal piping, machines andmetal trims. Therefore, finding the root cause of heavy metal contamination is challenging and can only bedone through further investigation.
5

Phthalates
Phthalates are man-made chemicals that are frequently used in the production processes of garments or are
the result of a degradation product. Phthalates are mainly used as softeners and sometimes in the printing
process. They can be used in the plastic plumbing pipes of the production plant, which can also result in a
possible contamination. Furthermore, they can be incorporated as an additive to modify the performance of thematerial. Since there is no chemical bond holding them in place, phthalates can migrate out of the intended
material and become available to the user or environment.
6

APs and APEOs
APEOs and their derivatives are a group of man-made chemicals that do not occur naturally. They are synthetic
non-ionic surfactants used in some detergents and cleaning products. Surfactants are a functional class ofchemicals that provide increased surface activity and reduce the surface tension of water, allowing easierspreading, wetting and better mixing of liquids. APEOs, especially Nonylphenol Ethxylates (NPEOs) are widelyused and important surfactants for more than fifty years. They are used as wetting agents, emulsifiers, anddispersants in paints and coatings, residual and commercial cleaning products, in crop protection chemicals
and textile manufacturing and pulp and paper processing. In the apparel industry they are commonly used asdetergents in the textile wet processing industry but they are also used in small quantities as emulsifiers or
wetting agents in some dyestuff and pigment preparations.
G-Star has banned the use of Phthalates, APs and APEOs since July 2012.The majority of these chemicals
detected in this batch originate from second tier suppliers and no traces of these chemicals are found on theready-made garments. G-Star is keen on finding the root cause of these detected substances as soon as
possible.

3

Please see column Testing methods and detection limits on page 9 in chapter 3 Method.

4 Textile Exchange, Textile Exchange Chemical Snapshot, Heavy metals, Version 1 – July 2013.
5

Textile Exchange, Textile Exchange Chemical Snapshot, Phthalates, Version 1 – July 2013.
Textile Exchange, Textile Exchange Chemical Snapshot, Alkylphenols & Alkyphenol Ethoxylates (AP & APEOs), Version 2– January 2013.

613

FACTORY SPECIFIC REMARKS
Factory 1 Vietnam
This factory is located in a green zone and makes use of a closed circuit water system. This means it does notrelease any water into the environment after usage. The water used is recycled for 100%. Even though theimpact of the results of this factory is different because these chemicals will not be discharged, the factory
took immediate action after receiving the test results. A treatment step, waste water treatment by electro
coagulation and flotation, is added in order to reduce the presence of COD, BOD and heavy metals in thewater after treatment. In addition, they have already replaced some chemicals which contain Phthalates andheavy metals. In addition, this factory makes bricks from the sludge that is created during the production
process and those are used for the construction of buildings.
Factory 6 China, Factory 9 China & Factory 5 Bangladesh
These factories are located in an industrial zone and make use of a centralized effluent treatment plant. When
studying the development of the presence of chemicals in the different tested stages (incoming water, waste
water before treatment and waste water after treatment) one can conclude that some chemicals were addedby other factories making use of the same centralized effluent treatment plant. This means that certain
chemicals were not found in the incoming water and waste water before treatment, but were detected in (ahigher level in) the waste water after treatment. This doesn’t mean however that these factories should not bealerted by these results.

14

5. CONCLUSIONS
The goal of this research was to do a baseline assessment of the use and discharge of the 11 priority
chemicals in G-Star’s supply chain. Water Discharge Report I and II present the results of this baseline
assessment. With help of this assessment, G-Star obtained a basic idea of the presence of the 11 priority
chemicals in 80% of our supply chain.
G-Star learned that traces of the 11 priority chemicals were found in the wastewater after treatment of thetested factories. Heavy metals were found most often in the waste water after treatment. The results indicatethat somewhere in the production process of garments the detected chemicals were used or came in contact
with the water used. Since G-Star is committed to the goal of zero discharge of hazardous chemicals it will
research the root cause for the presence of the chemicals detected and will undertake the appropriate
corrective actions.
As G-Star acknowledges the importance of the ‘right to know principle’ it will keep pushing for a functioning
and known PRTR platform for all our production countries except for China where the platform IPE is in place
already. As soon as a proper platform for disclosure is available for the remaining countries, the dialogue on
disclosure of water discharge data with our suppliers will be continued.
Reaching the target of ZDHC by 2020 cannot be achieved alone; this is an industry effort. Looking at theseresults it can be noted that the input water plays part in the contamination of the water after treatment. Thisshould be addressed together with all industry stakeholders.
In the prior chapter some general and factory specific remarks were made about the test results. However, it isevident that further root cause investigation at factory level is necessary. Our Chemical Specialists are working
from the very start of the production with the factories, not only from G-Star’s side but also with bluesign
technologies ag and the ZDHC Joint Roadmap. They check the use of chemical products, search forenvironmentally friendly substitutes for hazardous chemicals and work with suppliers towards phasing out
harmful chemicals from their production processes.
Although the water testing is an important step of knowledge building, G-Star is aware that still many steps
need to be taken to understand the contamination of water by chemicals and come to zero discharge ofhazardous chemicals.

15

6. FOLLOW UP ACTIONSAs stated before, although it is difficult to draw definite conclusions from a baseline assessment, the results inthis report do allow us to formulate, prioritise and coordinate follow up activities with suppliers to reach our
ZDHC target.
G-Star acknowledges that the road towards zero discharge of hazardous chemicals is complex. It is important
to stay flexible and make adjustments over time. We see this as a process of continuous learning andimprovement.
Some follow-up actions that we take up are:• After publication of the Water Discharge report I G-Star and the suppliers took action on the findings ofthis report. Root cause investigation was initiated at all factories, but has not been fully completed. Root
cause investigation on the detected substances for those suppliers included in the this report will bestarted following our policy to eliminate hazardous chemicals.
• It is clear that root cause investigation at factory level is essential. Our Chemical Specialists are working
together with the suppliers in finding the root causes of the chemicals detected and performing theappropriate corrective actions. This process can involve the following steps (every factory has its own
roadmap towards zero discharge of hazardous chemicals therefore it’s not possible to describe one
general applicable roadmap): self-assessments, chemical inventory and Material Safety Data Sheetinvestigation, environmental audits via the ZDHC Joint Roadmap, assessments of bluesign technologies
ag, chemical and environmental management training and auditing. G-Star is of the opinion that it isimportant to work from both ends of our supply chain (raw material and end product: with our own teams,
bluesign technologies ag and the ZDHC Joint Roadmap. Our Chemical Specialists are actively working
on banning and replacing chemicals for environmental and human friendly alternatives together with our
suppliers and the chemical industry.
• G-Star encourages suppliers to become a bluesign system partner.
• G-Star supports suppliers to publicly disclose their water discharge data via a PRTR platform.
• G-Star is in the processes of finalising and implementing a Manufacturing Restricted Substance List
throughout our supply chain (expected Q1 2014).
• G-Star will continuously work on all of the points of our Detox Solution commitment, update our individual
action plan and report on our individual actions (expected January 2014) and work on the ZDHC Joint
Roadmap actions.

16

APPENDIX IBUREAU VERITAS TEST REPORTS

17

November 18, 2013

Page 18 of 11
Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 6 China

Sample Description:

Sample(s) received is/are stated to be:I001) Composite liquid (Wastewater before treatment)I002) Composite liquid (Wastewater after treatment)///
Grab Sample & Time-Weighted Composite Grabbed Samples*
November 5, 2013
November 6, 2013 to November 18, 201318

Photo of the Sample/ Sampling Location
I001)

I002)

19

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I002

•

•

ο

ο

ο

ο

ο

ο

ο

•

ο

ο

•

•

ο

ο

•
•

•
•
•

ο

Note / Key :-I001• – Detectedο – Not Detected20

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

21

Test Result
11 Priority Chemical Groups
Phthalates
Test results of Phthalates are as below.
Phthalates
BBP
DBP
DEHP
DNOP
DINP
DIDP
DMP
DEP
DPRP
DIBP
DCHP
DnHP
DNP
DIOP
DMEP

I001
ND
ND
0.0515
ND
ND
ND
ND
ND
ND
0.00596
ND
ND
ND
ND
ND

I002
ND
ND
0.0200
ND
ND
ND
ND
ND
ND
0.00364
ND
ND
ND
ND
ND

I001
ND
ND

I002
0.00072
ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND
ND

ND
ND

Chlorobenzenes
Test results of Chlorobenzenes are as below.
Chlorobenzenes
Chlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene,
1,4-Dichlorobenzene
1,2,3Trichlorobenzene
1,2,4Trichlorobenzene
1,3,5Trichlorobenzene
1,2,3,4Tetrachlorobenzene
1,2,3,5Tetrachlorobenzene,
1,2,4,5Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene

22Test Result
Chlorophenols
Test results of Chlorophenols are as below.
Chlorophenols
Pentachlorophenol
2,3,4,5-Tetrachlorophenol
2,3,4,6-Tetrachlorophenol
2,3,5,6-Tetrachlorophenol
2,4,6-Trichlorophenol
2,3,5-Trichlorophenol
2,4,5-Trichlorophenol
3,4,5-Trichlorophenol,
2,3,4-Trichlorophenol
2,3-Dichlorophenol
3,4-Dichlorophenol
2,4-Dichlorophenol,
2,5-Dichlorophenol,
2,6-Dichlorophenol,
3,5-Dichlorophenol
2-Chlorophenol
3-Chlorophenol
4-Chlorophenol

I001
0.00607
ND
ND
ND
0.00058
ND
ND

I002
0.00057
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND

0.00152
ND
ND
ND

ND
ND
ND

Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
0.02300.000500.000070.004140.06520.00461
0.006640.04340.259
0.0665
0.336
ND
ND

I002
0.00139
ND
ND
ND
0.0368ND
0.00884
0.0112
0.09850.00359
0.135
ND
ND

I001
ND
0.00412
ND
0.123

I002
ND
0.00452
ND
ND

APs and APEOs
Test results of APs and APEOs are as below.
APs and APEOs
OP
NP
OPEOs
NPEOs

23

Test Result
Perfluorinated Chemicals
Test results of Perfluorinated Chemicals are as below.
PerfluorinatedChemicals
C8:
PFOA
PFOS
C6:
PFHxA
PFHxS
C4:
PFBA
PFBS

I001

I002

ND
ND

0.00014
ND

ND
ND

ND
ND

ND
ND

ND
ND

Others Priority Chemical Groups

Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorinated Solvents
Short-Chained Chlorinated Paraffins

I001
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

24Dec 05, 2013
Date Received:

Nov 09, 2013

Page 25 of 7

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 8 China///
Grab Sample & Time-Weighted Composite Grabbed Samples*
Nov 08, 2013
Nov 09, 2013 to Nov 26, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Composite liquid - Wastewater before treatmentI002) Composite liquid - Wastewater after treatment

25

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

•

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

26

Test Result
11 Priority Chemical Groups
Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
0.00416ND
ND
0.00268
ND
ND
ND
0.003540.0284ND
0.00571
ND
ND

I002
ND
ND
ND
0.00182
ND
ND
ND
0.00247
ND
ND
0.00489
ND
ND

Others Priority Chemical Groups
I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
APs and APEOs
Perfluorinated Chemicals

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix.
ND = Not detected (Please refer to reporting limit shown in Appendix.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

27

November 15, 2013

Page 28 of 10
Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 9 China

Sample Description:

Sample(s) received is/are stated to be:I001) Composite liquid (Wastewater before treatment)I002) Composite liquid (Wastewater after treatment)///
Grab Sample & Time-Weighted Composite Grabbed Samples*
November 5, 2013
November 5, 2013 to November 15, 201328

Photo of the Sample/ Sampling Location
I001)

I002)

29

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals
Note / Key :-• – Detectedο – Not Detected

30

I001

I002

•

•

ο

ο

ο

ο

ο

ο

ο

•

ο

ο

ο

ο

ο

ο

•
•

•

ο

ο

ο

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

31

Test Result
11 Priority Chemical Groups
Phthalates
Test results of Phthalates are as below.
Phthalates
BBP
DBP
DEHP
DNOP
DINP
DIDP
DMP
DEP
DPRP
DIBP
DCHP
DnHP
DNP
DIOP
DMEP

I001
ND
ND
0.0384
ND
ND
ND
ND
ND
ND
0.00460
ND
ND
ND
ND
ND

I002
ND
ND
0.0159
ND
ND
ND
ND
ND
ND
0.00228
ND
ND
ND
ND
ND

I001
ND
ND

I002
0.00054
ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND
ND

ND
ND

Chlorobenzenes
Test results of Chlorobenzenes are as below.
Chlorobenzenes
Chlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene,
1,4-Dichlorobenzene
1,2,3Trichlorobenzene
1,2,4Trichlorobenzene
1,3,5Trichlorobenzene
1,2,3,4Tetrachlorobenzene
1,2,3,5Tetrachlorobenzene,
1,2,4,5Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene

32Test Result
Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
ND
ND
ND
0.06770.00637ND
0.00487
0.006890.03750.00157
0.0326
ND
ND

I002
ND
ND
ND
ND
0.00428ND
0.00335ND
0.0283ND
0.0464
ND
ND

I001
ND
0.0147ND
0.0160

I002
ND
ND
ND
ND

APs and APEOs
Test results of APs and APEOs are as below.
APs and APEOs
OP
NP
OPEOs
NPEOs
Others Priority Chemical Groups
I001
ND
ND
ND
ND
ND
ND
ND

Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Perfluorinated Chemicals

I002
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

33

Date Received:

November 06, 2013
Page 34 of 8

October 26, 2013

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 1 Bangladesh///
Grab Sample & Time-Weighted Composite Grabbed Samples*
October 26, 2013
October 26, 2013 to November 06, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Incoming waterI002) Wastewater before treatmentI003) Wastewater after treatment

34

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

•

•

ο

ο

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected

35

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

36

Test Result
11 Priority Chemical Groups
Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.0067
ND
ND
ND

I002
0.00180.00116ND
0.00740.012
ND
ND
0.0946
0.421
0.01
0.025
ND
ND

I003
ND
0.00013ND
0.00130.0104ND
ND
0.08380.28
0.00970.0191ND
ND

Others Priority Chemical Groups

Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
APs and APEOs
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

37

Date Received:

November 20, 2013
Page 38 of 9

November 10, 2013

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 2 Bangladesh///
Grab Sample & Time-Weighted Composite Grabbed Samples*
November 10, 2013
November 10, 2013 to November 20, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Incoming waterI002) Wastewater before treatmentI003) Wastewater after treatment

38

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

ο

ο

ο

ο

ο

ο

ο

ο

ο

•
•

ο

ο

ο

ο

ο

ο

ο

ο

ο

•
•

•
•

•
•

ο

ο

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected39

οObjective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

40

Test Result
11 Priority Chemical Groups
Azo Dyes
Test results of Azo Dyes are as below.
Amines4-Aminodiphenyl
Benzidine
4-Chloro-o-toluidine
2-Naphthylamineo-Aminoazotoluene
5-nitro-o-toluidine
4-Chloroaniline
4-Methoxy-mphenylenediamine
4,4`Diaminodiphenylmet
hane
3,3`Dichlorobenzidine
3,3`Dimethoxybenzidine
3,3`Dimethylbenzidine
4,4`-Methylenedi-otoluidine
p-Cresidine
4,4`-Methylene-bis(2-chloraniline)
4,4`-Oxydianiline
4,4`-Thiodianiline
o-Toluidine
4-Methyl-mphenylenediamine
2,4,5Trimethylaniline
o-Anisidine
4-Aminoazobenzene
2,4-Xylidine
2,6-Xylidine
Aniline

I001
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND
ND

ND
ND

ND
ND

ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND

ND

ND

ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
0.0184

ND
ND
ND
ND
ND

I001

I002

I003

ND
ND
ND
ND
ND
ND
ND
ND

0.00007
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND

Organotin Compounds
Test results of Organotin Compounds are as below.
Organotin
Compounds
MBT
DBT
DOT
TBT
TPhT
TCyHT
TOT
TPT

41

Short-Chained Chlorinated Paraffins
Test results of Short-Chained Chlorinated Paraffins are as below.
I001
0.0459SCCPs

I002
0.0587I003
0.0147

I002
ND
ND
ND
0.023
0.20070.004
0.00520.01180.17710.0364
0.042
ND
ND

I003
ND
ND
ND
0.00350.12840.0011
ND
ND
ND
0.012
0.03
ND
ND

Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.00130.0421ND
ND

Others Priority Chemical Groups

Phthalates
Brominated and Chlorinated Flame Retardants
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
APs and APEOs
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.

42

Date Received:

November 12, 2013
Page 43 of 8

November 02, 2013

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 3 Bangladesh///
Time-Weighted Composite Grabbed Samples*
November 02, 2013
November 02, 2013 to November 12, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Wastewater before treatmentI002) Wastewater after treatment

43

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

•
•

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected

44

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

45

Test Result
11 Priority Chemical Groups
Short-Chained Chlorinated Paraffins
Test results of Short-Chained Chlorinated Paraffins are as below.

SCCPs

I001
ND

I002
0.0083

I001
ND
ND
ND
ND
ND
ND
ND
0.10020.08160.032
0.0404
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.008
0.002
ND
ND

Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

Others Priority Chemical Groups

Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
APs and APEOs
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.

46

Date Received:

November 27, 2013
Page 47 of 8

November 16, 2013

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 4 Bangladesh///
Grab Sample & Time-Weighted Composite Grabbed Samples*
November 16, 2013
November 16, 2013 to November 27, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Incoming waterI002) Wastewater before treatmentI003) Wastewater after treatment

47

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

•

•

ο

ο

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected48

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals, and below Global Effluent Requirements.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

49

Test Result
11 Priority Chemical Groups
Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.005
ND
ND
ND

I002
ND
ND
ND
0.008
0.0274ND
ND
0.04020.11660.00420.0055
ND
1.645

I003
ND
ND
ND
0.01
0.009
ND
ND
0.03050.14680.005
0.0327ND
ND

Others Priority Chemical Groups

Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
APs and APEOs
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.

50

Date Received:

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:
Sample Description:

December 09, 2013
Page 51 of 9

November 23, 2013

Factory 5 Bangladesh///
Grab Samples*
November 23, 2013 (Sample I001 & I002)
December 01, 2013 (Sample I003)
November 23, 2013 to December 09, 2013
Sample(s) received is/are stated to be:I001) Incoming Water
I002) Wastewater before treatmentI003) Wastewater after treatment from CETP Outlet

51

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•
ο

•
•

•
•

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected

52

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

53

Test Result
11 Priority Chemical Groups
Organotin Compounds
Test results of Organotin Compounds are as below.
Organotin
Compounds
MBT
DBT
DOT
TBT
TPhT
TCyHT
TOT
TPT

I001

I002

I003

ND
ND
ND
ND
ND
ND
ND
ND

0.00180.0001
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND

I002
0.0032
ND
ND
ND
ND
0.00250.00770.0205ND
0.022
0.5715
ND
ND

I003
ND
ND
ND
0.0015ND
ND
ND
ND
0.0132
0.002
0.69
ND
ND

I002
ND
ND
ND
0.11

I003
ND
ND
ND
0.0076

Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
0.0018
ND
ND
ND
ND
ND
ND
ND
ND
0.00130.79
ND
ND

APs and APEOs
Test results of APs and APEOs are as below.
APs and APEOs
OP
NP
OPEOs
NPEOs

I001
ND
ND
ND
ND

54

Others Priority Chemical Groups

Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.

55

12/13/2013
Date Received:

11/12/2013

Page 56 of 10

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

Factory 1 Viet Nam///
Grab Sample & Time-Weighted Composite Grabbed Samples*
11/11/2013
11/12/2013 – 11/25/2013

Sample Description:

Sample(s) received is/are stated to be:I001) Water before biological treatment.
I002) Water after biological treatment.
I003) Water before reverse osmosis.
I004) Water after reverse osmosis.

56

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

I004

•

•

•

•

ο

ο

ο

ο

•
•

•
•

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

ο

•

•

ο

ο

ο

ο

•

•

•

•

ο

ο

ο

ο

ο

ο

ο

ο

Note / Key :-• – Detectedο – Not Detected57

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

58

Test Result
11 Priority Chemical Groups
Phthalates
Test results of Phthalates are as below.
Phthalates
BBP
DBP
DEHP
DNOP
DINP
DIDP
DMP
DEP
DPRP
DIBP
DCHP
DnHP
DNP
DIOP
DMEP

I001
ND
ND
0.0086
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
0.0056
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
0.0014
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I004
ND
ND
0.0029
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Azo Dyes
Test results of Azo Dyes are as below.
Amines4-Aminodiphenyl
Benzidine
4-Chloro-o-toluidine
2-Naphthylamineo-Aminoazotoluene
5-nitro-o-toluidine
4-Chloroaniline
4-Methoxy-m-phenylenediamine
4,4`-Diaminodiphenylmethane
3,3`-Dichlorobenzidine
3,3`-Dimethoxybenzidine
3,3`-Dimethylbenzidine
4,4`-Methylenedi-o-toluidine
p-Cresidine
4,4`-Methylene-bis-(2-chloraniline)
4,4`-Oxydianiline
4,4`-Thiodianiline
o-Toluidine
4-Methyl-m-phenylenediamine
2,4,5-Trimethylaniline
o-Anisidine
4-Aminoazobenzene
2,4-Xylidine
2,6-Xylidine
Aniline

I001
ND
ND
ND
ND
ND
ND
0.0051
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I004
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
0.0694

ND
ND
ND
ND
ND
0.0107

ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND

59

Organotin Compounds
Test results of Organotin Compounds are as below.
Organotin
Compounds
MBT
DBT
DOT
TBT
TPhT
TCyHT
TOT
TPT

I001

I002

I003

I004

0.00021
ND
ND
ND
ND
ND
ND
ND

0.00005
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND

I001
ND

I002
ND

I003
ND

I004
ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND
ND
ND

ND
ND
ND

0.0021ND
ND

0.0018
ND
ND

ND

ND

ND

ND

ND
ND

ND
ND

ND
ND

ND
ND

ND

ND

0.0006

ND

ND
ND
ND

ND
ND
ND

ND
ND
ND

ND
ND
ND

I002
0.001
0.0004
ND
0.012
0.003
ND
0.008
0.027
0.270
0.025
0.718
ND
ND

I003
0.001
0.0002
ND
0.007
0.002
ND
0.004
0.014
0.162
0.004
0.012
ND
ND

I004
ND
0.0004
ND
0.008
0.010
ND
0.001
0.017
0.192
0.004
0.016
ND
ND

Chlorophenols
Test results of Chlorophenols are as below.
Chlorophenols
Pentachlorophenol
2,3,4,5Tetrachlorophenol
2,3,4,6Tetrachlorophenol
2,3,5,6Tetrachlorophenol
2,4,6-Trichlorophenol
2,3,5-Trichlorophenol
2,4,5-Trichlorophenol
3,4,5-Trichlorophenol,
2,3,4-Trichlorophenol
2,3-Dichlorophenol
3,4-Dichlorophenol
2,4-Dichlorophenol,
2,5-Dichlorophenol,
2,6-Dichlorophenol,
3,5-Dichlorophenol
2-Chlorophenol
3-Chlorophenol
4-Chlorophenol
Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
0.001
0.0005
ND
0.013
0.003
ND
0.005
0.033
0.333
0.045
0.104
ND
ND

60

Others Priority Chemical Groups

Brominated and Chlorinated Flame Retardants
Chlorinated Solvents
Chlorobenzenes
Short-Chained Chlorinated Paraffins
APs and APEOs
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND

I004
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

61

December 12, 2013
Date Received:

December 04, 2013

Page 62 of 9

Factory Company Name:
Factory Address:
Project No.:
Client Reference No.:
Sample Type:
Sample Pick Up Date:
Test Period:

FACTORY 2 INDIA///
Grab Sample & Time-Weighted Composite Grabbed Samples*
November 30, 2013
December 04, 2013 to December 12, 2013

Sample Description:

Sample(s) received is/are stated to be:I001) Incoming waterI002) Wastewater before treatmentI003) Wastewater after treatment

62

Executive Summary
11 Priority Chemical Groups
Phthalates
Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorobenzenes
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Heavy Metals
APs and APEOs
Perfluorinated Chemicals

I001

I002

I003

•
ο

ο
ο

ο
ο

ο

ο

ο

ο

ο

ο

•

•

ο

ο

ο
ο

ο

ο

ο

ο

ο

ο

•
•

•
•

•

ο

ο

Note / Key :-• – Detectedο – Not Detected

63

ο
ο

Objective
The environment samples were tested for below 11 Priority Chemical Groups according to the Joint Roadmap: Toward Zero
Discharge of Hazardous Chemicals.
11 Priority Chemical Groups
1) Phthalates
2) Brominated and Chlorinated Flame Retardants
3) Azo Dyes
4) Organotin Compounds
5) Chlorobenzenes
6) Chlorinated Solvents
7) Chlorophenols8) Short-Chained Chlorinated Paraffins9) Heavy Metals
10) APs and APEOs
11) Perfluorinated Chemicals

64

Test Result
11 Priority Chemical Groups
Phthalates
Test results of Phthalates are as below.
Phthalates
BBP
DBP
DEHP
DNOP
DINP
DIDP
DMP
DEP
DPRP
DIBP
DCHP
DnHP
DNP
DIOP
DMEP

I001
ND
ND
0.006
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

I001
0.037
ND

I002
0.043
ND

I003
ND
ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND
ND

ND
ND

ND
ND

Chlorobenzenes
Test results of Chlorobenzenes are as below.
Chlorobenzenes
Chlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene,
1,4-Dichlorobenzene
1,2,3Trichlorobenzene
1,2,4Trichlorobenzene
1,3,5Trichlorobenzene
1,2,3,4Tetrachlorobenzene
1,2,3,5Tetrachlorobenzene,
1,2,4,5Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene

65

Heavy Metals
Test results of Heavy Metals are as below.
Heavy Metals
As
Cd
Hg
Pb
Sb
Co
Ni
Cu
Zn
Cr
Mn
Cr VI
CN

I001
ND
ND
ND
ND
ND
ND
ND
0.00269
0.01100.01720.0093
ND
ND

I002
ND
ND
ND
0.0051
ND
ND
0.00760.0772
0.05680.03020.0389
ND
ND

I003
ND
ND
ND
0.0015ND
ND
0.00400.01500.02230.01620.0231
ND
ND

I002
ND
ND
ND
0.024

I003
ND
ND
ND
ND

APs and APEOs
Test results of APs and APEOs are as below.
APs and APEOs
OP
NP
OPEOs
NPEOs

I001
ND
ND
ND
0.040

Others Priority Chemical Groups

Brominated and Chlorinated Flame Retardants
Azo Dyes
Organotin Compounds
Chlorinated Solvents
Chlorophenols
Short-Chained Chlorinated Paraffins
Perfluorinated Chemicals

I001
ND
ND
ND
ND
ND
ND
ND

I002
ND
ND
ND
ND
ND
ND
ND

I003
ND
ND
ND
ND
ND
ND
ND

Remark :-Test method, reporting limit and list of chemical are summarized in tables of Appendix A.
ND = Not detected (Please refer to reporting limit shown in Appendix A.).
All results are in ppm as unit.
ppm = part(s) per million.

Discussion
According to the test results, the priority chemical groups are found. It is suggested that further factory audit is required to
identify the source of pollutants in the inventory.
END

66