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

The licensed operator is expected to undertake residue testing according
to a risk assessment of contamination. … Samples for residue testing
may also be taken by the inspector during the inspection visit required
for certification, either as back-up to the inspection process or in
case of suspicion of contamination or non-compliance.
Unfortunately, because of the uneven distribution of pesticides on greasy
wool, it is impossible to obtain representative samples of wool for residue
testing from a processing consignment of wool during an inspection
visit. A systematic risk-based sampling programme is required, linked to
representative core samples taken from the supply chain in the same
manner as the sampling regime in the EU eco-label.
2.
The GOTS shares a common specification with the EU eco-label for
textiles (2002–2007) which requires that all textile processing plants
discharge effluents with a chemical oxygen demand (COD) of less than
25 g/kg of textile output. Unfortunately the GOTS exempts greasy wool
scouring sites from this requirement and there are no further effluent
treatment requirements for wool scours. This is presumably an oversight
© 2009 Woodhead Publishing Limited

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Wool as a natural renewable fibre
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as wool scours without effluent treatment produce large quantities of
oxygen-depleting substances in waterways. Other organic standards are
similarly silent or non-specific on the need for treatment of wool scouring
effluents (NASAA, 2004). In contrast the EU eco-label includes very
strict effluent treatment requirements for wool scours.
There would be benefit for wool if there was further alignment of the GOTS
with the EU eco-label criteria. Certainly some of the current uncertainty in
the processing trade would be reduced.