Version 3 11 July 2017
LWG Audit Protocol 6
Section 3, Question 14a
14a What percentage of the chrome purchased by the tannery for use in tanning of raw hides/skins
is utilised or treated in such a way that it does not enter the environment?
The chrome discharged into the environment (directly into water courses or onto land) must be taken
into account. The chrome waste that is rendered safe (i.e. by being deposited into regulated landfill,
used in cement manufacture etc.) may be excluded.
% chrome score
utilisation
score = ((% utilised x 4.2553) – 342.98) x % of total output chrome tanned onsite
100
MAX Score = 80 x % of total output chrome tanned onsite
100
Guidance note
All the chrome tanning agent issued into work by the tannery in the audit period must be
taken into account. All of the chrome leaving the tannery (as a result of the tanning process
must) be taken into account.
By entering into the environment waste chrome would be capable of interacting with
biological organisms. Waste chrome that is incapable of interacting with biological organisms
may be deemed to have been rendered safe. The following are examples and is not
necessarily an exhaustive list:
Chrome that does not enter the environment as a waste includes
• Chrome contained in leather that is sold on to customers
• Chrome in trimmings, shavings, buffing dust that is used in products
Chrome waste that does not enter the environment by virtue of being rendered safe includes
• Chrome in trimmings, shavings, buffing dust that is deposited in regulated landfill*
• Chrome in sludge that is deposited in regulated landfill*
• Chrome in trimmings, shavings, buffing dust & sludge that is treated in a licenced co-
processing plant*
• Chrome permitted to be deep-well injected into certified geological stratum
• Chrome in trimmings, shavings, buffing dust & sludge that is treated in a licenced
incineration plant*
Chrome waste that enters the environment includes
• Chrome containing waste streams discharged into water courses
• Chrome containing waste streams discharged onto land
• Chrome containing waste streams discharged to an unlicensed disposal agent**
Version 3 11 July 2017
* The scope of the audit is limited to tannery operations. The transport of waste should be
made using licenced carriers; the disposal or treatment of wastes should be undertaken by
licenced agents. What happens to the wastes after they have been received by licenced
operators is beyond the scope of the LWG audit.
**The use of unlicensed carriers or disposal agents is likely to lead to failure of the audit in
other sections of the protocol
Chrome wastes that do not pass through a third party licenced agent and which enter the
environment by any of the routes listed above, even if permitted by licence, even if required
by the authorities, must not be included in the proportion of chrome “…utilised or treated in
such a way that it does not enter the environment…”
The calculations below give guidance on how the amounts of chrome may be calculated
1. Wastewater amount (m³/year) x chrome concentration (mg/l) in effluent before being
discharged into a water body = kg Chrome entering the environment
2. Sludge which is permitted for agriculture or composting use: mg Cr/kg Dry Solids x kg
Sludge (Dry Solids)/year going to agriculture/composting = kg Chrome entering the
environment
3. Irrigation water (m³/year) x chrome concentration (mg/l) = kg Chrome entering the
environment
4. Shavings converted to fertilizer mg Cr/kg Dry Solids x kg shavings (Dry Solids)/year = kg
Chrome entering the environment
5. The kg Cr used in the tannery (by invoices) /year - the kg Chrome, enter the environment
= kg utilised by the tannery
