O o d h e a d p u b L i s h I n g L i m I t e d

3.5
EU eco-label processing in practice
3.5.1
What are the residue targets for EU
eco-label wool?
In the 2002 revision of the EU eco-label, there was alignment of the eco-
label criteria with the environmental risk assessment processes that were
being conducted in Australia on pesticide residues in raw wool. In 1998
Savage reviewed the available knowledge on the occurrence of pesticide
residues on Australian wool and on the downstream environmental
consequences that resulted when that wool was scoured internationally (Savage,
1998; Russell, 2000). A generic wool scouring risk assessment model was
developed based on a single wool scouring line located on a small river
system. The effluent was treated on-site and then in a municipal sewage
treatment system. The model was used to back-calculate from environmental
‘no-effect’ pesticide concentrations in the river (based on the most sensitive
aquatic organism in the ecosystem) to determine the pesticide residues on
the greasy wool that could be scoured without causing environmental
harm.
The EU eco-label technical groups generally adopted the Australian risk
assessment process (with some rounding and grouping of data) to establish
the following wool residue targets; dicyclanil was included in the 2008
revision of the EU eco-label:
• Total synthetic pyrethroids – 0.5 mg/kg.
• Total organophosphates – 2 mg/kg.
• Diflubenzuron, triflumuron, dicyclanil – 2 mg/kg.
• Total organochlorines – 0.5 mg/kg.
The EU eco-label offers a generic low-residue target/standard for wool.
There are two practical applications of these concentrations for wool:
1.
Wool that meets these low-pesticide requirements will be able to enter
eco-sustainable supply chains and, if the EU eco-label processing
requirements are followed through to final product, be converted into
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products that can be awarded the EU eco-label (or other Type 1 eco-
label) and be identified to consumers as environmentally preferred.
2.
International scourers who purchase compliant wools will be able to
demonstrate that pesticides released in their scouring operation will have
no impact on the environment, even if they have only a minimal on-site
effluent treatment system (such as chemical coagulation/flocculation)
and discharge to a central effluent treatment system.
This process will become important in Europe after October 2007 and
when the IPPC legislation is operational. Under this legislation, there
are no defined national or EU-wide pesticide residue standards. Individual
scour operators must prove on an ongoing basis that they have not
contaminated the environment (i.e. prove that they have not exceeded
applicable environmental quality standards), and must submit processing
and discharge data to public access databases. The value of a generic
low residue standard is that it removes the need for detailed residue data
to be provided on each lot of wool purchased.
The same IPPC legislation will apply to wool dye houses and again
they must supply information on the residue status of the wool that they
process. This is a supply chain issue, as the concentration on the scoured
wool that enters dyeing will be directly related to the concentration on
the original raw wool. Even if a scour is able to process high-residue
greasy wools because it has a total containment effluent treatment process,
the high-residue scoured wool will remain as a potential problem
downstream.
3.5.2
How to produce EU eco-label low-residue wool
This discussion will be based on Australian sheep farming practices, since
this is where the most research has been conducted, although similar general
trends will be applicable in all other wool-producing countries. Pesticides
are applied externally to sheep to protect them from attack by insects. In
Australia, the main pests are sheep blowfly and sheep lice. Blowfly attack
has the potential to kill sheep rapidly and painfully as the flies lay their eggs
in moist areas or in dung-coated skin. Lice cause the sheep to lose condition
and to entangle the wool as the sheep rub against fences to reduce the itch.
The main factors that control the concentration of residual pesticides on
sheep at shearing are
• the mass of pesticide applied;
• the rate of degradation of the pesticide; and
• the time between treatment and shearing to allow degradation and
weathering to occur (Campbell et al., 1998).
Two situations produce wool with high-pesticide residues:
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1.
poorly degradable pesticides applied at any stage in the growing season;
and
2.
readily degradable pesticides applied late in the growing season to control
pests.
Specific advice is available in Australia from the various State Departments
of Agriculture and from Australian Wool Innovation on methods to control
pests without leaving high residues on wool (LiceBoss, 2008; Newell, 2007).
However, it is important to note that compliance with the EU eco-label low-
residue requirements is voluntary, and, unlike organic programmes, there are
no penalties associated with leaving the programme for a year or more to
attack the pests with the full armoury of available chemicals. Growers may
choose to declare that their wool meets EU eco-label conditions on a mob-
by-mob basis or year-by-year basis based on treatment records. A key
requirement is that aspiring EU eco-label participants maintain good
treatment records and understand the residue consequences of their chemical
use.
3.5.3
Preparing processing consignments of
EU eco-label wool
Australian Wool Innovation conducts an annual survey of pesticides on 600
randomly selected Australian fleece wools offered for sale. This survey currently
shows that around 40% of wools meet the EU eco-label criteria. However, it
is important to note that this does not mean that 40% of wool processing
consignments will meet the EU eco-label requirements. Australian wool is
predominantly sold at open-cry auctions in quantities of less than 1 tonne
(on average). This system allows buyers to purchase wools from different
properties in order to compile a processing lot of 20–50 tonnes that will meet
a given clean fibre specification at sliver stage (micron, yield, strength,
colour) at minimum cost. In fact the probability of such a consignment of
wools chosen at random meeting the EU eco-label residue requirement is
less than 1 in 1000. If even a single line of highly contaminated wool is
present in the consignment, the average residue will potentially exceed the
residue target.
Australia is therefore developing systems to reliably identify supplies of
low-residue wools for the EU eco-label market at minimum cost. If all the
lines of wool in a single consignment are individually tested for chemical
residues, the cost is expensive (upwards of US$3000) per consignment. The
problem is made difficult because the individual lines of wool for a processing
consignment may reside in different wool stores across the country. They are
not shipped to the scour until a scouring date is available, and the whole
consignment is only assembled immediately prior to scouring. Even if all
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bales of wool could be sampled at that point, there is no time to perform the
analysis before scouring begins.
Two schemes are currently in operation in Australia to identify the residue
status of wool before sale. These schemes allow the wool buyers to make a
purchase based on the residue status of the wool as well as on the other
traditional specifications. Both schemes operate on the ability to test several
sale lots of wool as a ‘composite’ sample.
The original scheme operates in Tasmania through the dominant broker.
Growers make a declaration that they have not used certain chemical treatments
on their sheep, and a single line of wool is chosen at random from that
property annually for residue testing. If the test shows that the wool is
compliant, all of the wool from the property is identified in the catalogue
(Russell et al., 2003). Growers who make a false declaration are visited and
their wool is not identified in the catalogue. The problem remains that occasional
high-residue wools may slip through and the new owner of the wool is still
required to test the wool they have purchased. This can be done by combining
pre-sale core samples of the wool if they are still present at the wool testing
centre, or, alternatively, because all of the wool is present in a single wool
store in Tasmania, the remainder of the wool can be resampled and again
tested as a composite sample.
The more recent scheme operates on mainland Australia (and increasingly
in Tasmania) where a farmer arranges a composite sample to be prepared
from all of the wool from his property that is delivered to the wool store in
a single shipment. This wool is likely to be broken up into several different
sales lines representing wool of different qualities; however, the residue test
certificate can apply to all of the separate lines of wool. Linkages between
the residue test certificates and the lots of wool offered for sale (‘chain of
custody’) are provided through the Australian Wool Testing Authority (AWTA)
(Billing, 2008). While testing of composite samples costs more than analysis
of single wool lines at present, there are still significant savings.
In other countries, wool selling systems are quite different. In the United
Kingdom, wool is sold in large 8000 kg offerings based on the wool style.
Single fleeces with common fleece characteristics are assigned to these large
consignments and each fleece may have a different pesticide treatment history.
The large consignments may contain wool from perhaps a thousand farms so
that residue contents will probably represent an average for that region.
3.5.4
Wool scouring requirements
Implementation of the EU eco-label in processing chains can appear daunting
for processors, with a multitude of complex compliance forms available,
only a few of which are essential for each processing stage. The CSIRO
strategy for introduction of the EU eco-label in wool supply chains has been
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to issue each processor with a checklist and to provide only the minimum set
of forms to cover the specific operations of the mill.
For wool scouring, it is the responsibility of the mill management to sign
off on the pesticide residue content of the wool consignment that is being
processed. In practice, however, it is the responsibility of the owner of the
consignment of the wool to ensure that an analysis certificate is available for
each line of wool, in the same way that they ensure that other details of the
wool are provided such as wool types, number and weights of bales of wool
from each property, micron and yield.
Other requirements for EU eco-label wool scouring are common to other
wet processing stages. The following documentation is required:
• A list of all chemicals that have been used on the fibre or in the process,
along with statements of compliance from the chemical manufacturer
that each of the chemicals meets all of the requirements of biodegradability
and absence of toxic additives. Most mainstream suppliers of textile
chemicals now have lists of compliant formulations and will supply the
necessary documentation.
• A statement on the fate of the effluent leaving the factory, whether to the
sewer or to the environment, is required.
• A measurement of COD concentration in the effluent leaving the factory
is required, to be conducted by an independent laboratory accredited to
ISO 17025. If the effluent is discharged directly to surface waters,
temperature and pH measurements are required, as well as calculations
to show that the COD discharge was reduced below the target mass of
COD/kg of fibre processed. If the effluent is discharged to sewer, additional
data on the efficiency of operation of the central sewage treatment plant
must be provided. Similar information is required for other wet processing
stages.
• A statement is required that no transportation preservatives based on
chlorophenols, polychlorinated biphenyls (PCBs) or organotins have been
added to the fibre leaving the mill.
Although this is initially complex, experience has shown that mills are
easily able to manage the process after the first batch or two of eco-label
processing is conducted. Some changes to established processing chemicals
may be needed and it may be necessary to check with downstream customers
to verify that any change, for example, to softeners, does not cause problems
in subsequent dyeing operations.
A significant change for many international wool scours is that alkylphenol
ethoxylate (APEO) detergents may not be used for scouring of greasy wools.
The alkylphenol ethoxylate scouring detergents are cheaper than the so-
called biodegradable detergents and are used extensively internationally, but
they are restricted in Europe. In the environment, the APEOs degrade under
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anaerobic conditions to the parent alkylphenol and these act as potent oestrogen
mimics. The GOTS also bans use of APEOs, and additionally requires that
all processing agents meet certain aquatic toxicity and biodegradability
requirements.