PATAGONIA TRACEABLE DOWN STANDARD
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- Melvyn Henry
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1 I. INTRODUCTION PATAGONIA TRACEABLE DOWN STANDARD Patagnia surces dwn, which is a highly effective insulatin material. Dwn is cnsidered a by- prduct f the waterfwl meat industry where the meat is the primary surce f revenue. Nnetheless, brands making prducts using dwn have an impact n the welfare f animals, the envirnment, and the cmmunities in their dwn supply chain. Patagnia has established clear standards and a rbust methdlgy fr surcing dwn in an effrt t prevent unnecessary harm t the animals invlved, thereby, affecting the envirnment and the cmmunities in which we perate. Our Traceable Dwn standard was driven by ur cmpany s values, lcal and internatinal regulatins, cnsumers and NGO grups. The standard was created t ensure all independent third- party verificatin and certificatin audits are cmpleted t the same principles, scpe, and methdlgy. Patagnia acknwledges that implementing a Traceable Dwn standard is new t sme suppliers. We are cmmitted t wrking clsely with them t cntinuusly imprve their systems. In turn, suppliers must demnstrate full transparency and cmmitment t cntinuus imprvement in rder t remain a Patagnia Traceable Dwn supplier. Thrugh this partnership, we can prvide cnsumers with the mst transparent and rbust cntents claims assurance available in the industry. This standard is the framewrk f Patagnia s dwn supply chain animal welfare and traceable cntent claims assurance prgram. This standard will be revised as new traceability and animal welfare legislatin and best practices emerge. II. PRINCIPLES Belw are the principles that frm the basis f Patagnia s Traceable Dwn standard. A. Dwn and feather must nt be remved frm live animals. Animals must nt have been live plucked r mlt harvested at any stage in the supply chain. B. Dwn and feather must nt be frm animals that are frce fed during their life fr any reasn including the prductin f fie gras. C. Principles A and B are zer- tlerance issues and must be met in rder t becme r cntinue t be a Patagnia Traceable Dwn supplier. D. All suppliers must meet r exceed lcal regulatins fr animal welfare farming and prcessing f animals and animal prducts. Where law is silent, best practices based n Internatinal Finance Crpratin Gd Practice Nte n Animal Welfare in Livestck Operatins shall be fllwed (see summary in Appendix B). 1
2 E. All levels f the dwn supply chain must maintain recrds that prve chain f custdy. F. All new dwn supply chains must underg and pass a full traceability internal audit and a third- party verificatin audit prir t incrprating the material within ur Traceable Dwn prduct line. G. All apprved Traceable Dwn suppliers are subject t annunced and unannunced re- audits t verify sustainable remediatin f identified crrective actins. H. Third- party verificatin and certificatin audits must be based n Textile Exchange Cntent Claims Standard r anther traceability standard pre- apprved by Patagnia. I. All links in the supply chain must als adhere t ur Cde f Cnduct standards and benchmarks n animal welfare and traceability (see appendix A). J. Suppliers must demnstrate full transparency and cmmitment t cntinuus imprvement in rder t remain a Patagnia Traceable Dwn supplier. K. Patagnia s apprach t Traceable Dwn standard implementatin is ne f cllabratin and mutual respect with a fcus n educatin, transparency and sustainable remediatin. III. SCOPE OF STANDARD Patagnia believes in prviding ur custmers with the highest assurance that the dwn in their garments cmes frm a respnsible surce that respects animal welfare. The nly way t achieve this is t evaluate every link in the supply chain frm the parent farm t the garment factry fr: 1. animal welfare including nn- frce feeding and nn- live plucking, 2. traceability management systems including dcuments shwing an unbrken chain f custdy f the dwn. Animal Welfare : The Traceable Dwn standard prvides prduct cntent claims assurance that dwn and feather material have been prduced withut causing unnecessary harm t animals and fcuses n cmpliance with lcal legal animal welfare regulatins and ensuring that ur dwn des nt cme frm farms that engage in frce feeding r live plucking. Animal welfare is evaluated frm the parent farm thrugh t the slaughterhuse. Traceability: The Traceable Dwn standard lks fr and evaluates traceability systems in place thrughut the entire supply chain, including, but nt limited t, parent farms, hatcheries, breeding and intermediary farms, slaughterhuses, dwn prcessrs, dwn whlesalers, and garment factries and assesses the fllwing critical imprtant areas: Traceability management systems, which includes: plicies, prcedures, accuntability, training, implementatin, cmmunicatin, mnitring, and cntinuus imprvement. Linking chain f custdy dcuments frm parent farm t finished gds factry. 2
3 Labeling Traceable Dwn at every stage f the supply chain. Segregatin/Separatin f Traceable Dwn at every level f the supply chain. Management and wrker training and educatin at every level f the supply chain. Visual verificatin f animal welfare at time f time f bird raising and slaughtering, including n frce feeding r live plucking. Animal welfare lcal legal cmpliance and, where law is silent, best practices based n Internatinal Finance Crpratin Gd Practice Nte n Animal Welfare in Livestck Operatins (see summary in Appendix B) The standard des nt measure the perfrmance r quality f the dwn. Quality is addressed separately. Supplier Educatin Educatin f ur suppliers regarding gd traceability and animal welfare practices is key t the success f ur standard. Training and educatin ccur thrughut the business partnership, including during assessments at every level in the supply chain. Educatin includes guidance n hw t imprve supplier s traceability and animal welfare systems, and fsters sharing f best practices within and between supply chain links. Nte n Cllectr- Based Supply Chains: At this time, Patagnia des nt accept cllectr- based dwn in ur Traceable Dwn supply chain, thus it is currently ut f scpe. Cllectr- based supply chains are usually fund within the infrmal sectrs f a given cuntry and wuld require a change in culture as well as business practices. Shuld Patagnia decide t expand int cllectr- based supply chains, we wuld update this standard. III. AUDIT METHODOLOGY The fllwing are key cmpnents t the audit methdlgy used when assessing ur dwn supply chain fr traceability and animal welfare. Our apprach is ne f cllabratin and mutual respect with a fcus n educatin and sustainable remediatin: PRE- AUDIT PREPARATION Lcal law and animal welfare research is cnducted in preparatin fr the Traceable Dwn audit. All dwn supply chain sites are disclsed by the direct supplier t Patagnia s a third- party auditr can strategically select sites t visit. Patagnia and ur selected third- party expert educate suppliers n ur standards and what t expect during audits. VISUAL INSPECTION Visual inspectins f the treatment f birds and their envirnment are cnducted at strategically sampled sites frm parent farms t slaughterhuses. Strategically sampled slaughterhuses and prcessrs are visually inspected fr labeling, segregatin, separatin, and prcess implementatin. 3
4 All garment factries are visually inspected fr labeling, segregatin, separatin, and prcess implementatin. DOCUMENT REVIEW Review f all relevant chain f custdy dcumentatin, animal welfare legal cmpliance dcuments and ther paperwrk at each level in the supply chain that prve the presence f traceability management systems and emplyee training. MANAGEMENT & WORKER INTERVIEWS Private management and wrker interviews in the lcal language at all levels f the supply chain t assess prper implementatin f traceability plicies, prcedures, dcumentatin, training and animal welfare legal cmpliance. IV. SUPPLY CHAIN APPLICABILITY AND REQUIREMENTS A. Farms Parent farms, hatcheries and breeding farms that raise animals until they are ready fr slaughter, prcessing as meat prducts, dwn and feather, and ther by- prducts. Requirements 1. Farms must be audited and verified t the Traceable Dwn standard. 2. Dwn and feather must nt be remved frm live animals. Animals must nt have been live plucked r mlt harvested at any stage in the supply chain. 3. Animals are nt frce fed fr any reasn including the prductin f fie gras. 4. Dcumentatin frm lcal gvernment authrities indicating that lcal animal welfare regulatins are met r exceeded must be prvided. 5. Chain f custdy dcumentatin shwing the mvement f eggs r birds frm farm t farm is maintained nsite and available fr review by the traceability auditrs. 6. Annunced and unannunced visits frm auditrs and Patagnia representatives are allwed. 7. Full access t all sites, buildings and peratins are permitted, and private interviews with wrkers are allwed. 8. Farms must be cmmitted t cntinuus imprvement and implement all crrective actin items fund in the audit prcess in a mutually agreed upn timeframe. B. Slaughterhuses Purchase live animals frm farms and prcess them int meat prducts, raw feather and dwn, and ther by- prducts. Washes and sterilizes raw feather and dwn and sells t dwn prcessrs. 4
5 Requirements 1. Slaughterhuses must be audited and verified t the Traceable Dwn standard. 2. Dwn and feather must nt be remved frm live animals. Animals must nt have been live plucked, r mlt harvested at any stage in the supply chain. 3. Material that has been remved frm live animals is nt cllected, purchased r sld as Traceable Dwn. 4. Animals being prcessed have nt been frce fed fr any reasn, including the prductin f fie gras. 5. Dcumentatin frm lcal gvernment authrities indicating that lcal animal welfare regulatins are met r exceeded must be prvided. 6. Chain f custdy dcumentatin shwing the mvement f birds frm farm t slaughterhuse, and f feathers frm slaughterhuse t prcessrs, is maintained nsite and available fr review by the traceability auditrs. 7. Annunced and unannunced visits frm auditrs and Patagnia representatives are allwed. 8. Full access t all buildings and peratins are permitted, and private interviews with wrkers are allwed. 9. At a minimum, slaughterhuses shall have fully mapped all farm sites that supply birds and maintain adequate dcumentatin n site t prve they d nt accept live plucked r frce fed birds. As an added measure, slaughterhuses shall have, r shall wrk tward implementing, written cntracts with all supplying farms. Cntracts must cntain language that requires the farms t nt live pluck r frce feed the birds. 10. All dcumentatin must be available fr review by the auditrs. 11. Slaughter huses must be cmmitted t cntinuus imprvement and implement all crrective actin items fund in the audit prcess in a mutually agreed upn timeframe. C. Dwn Prcessrs Purchases washed dwn frm slaughterhuses and further washes, sterilizes, and srts it t sell t dwn whlesalers. Requirements 1. Dwn prcessrs must be audited and verified t the Traceable Dwn standard. 2. Dwn prcessr is pre- apprved by Patagnia and agrees t fllw and implement the Traceable Dwn standard thrughut its supply chain. 3. Fr all Traceable Dwn materials and prducts, dwn prcessrs must nly use input materials verified t the Traceable Dwn standard. 4. If the dwn prcessr purchases r sells material that is remved frm live animals and/r frm animals frce fed fr the prductin f fie gras, the Traceable Dwn material must be segregated during all phases f prcessing, including arrival f raw material t the facility thrugh t shipping t next lcatin. The dwn prcessr must visually shw segregatin thrugh labeling and r ther clear identificatin methds in the strage areas, n 5
6 machinery and during facility dwn material entry and exiting prcesses. Relevant written plicies and prcedures, chain f custdy dcumentatin, and emplyee training must als be maintained n site. 5. Dwn prcessr maintains cntracts with all lcal and internatinal prcessing facilities and slaughterhuses supplying raw and/r washed dwn. Cntract shall cntain language creating awareness that certain custmers have requirements that animals are nt live plucked, mlt harvested r frce fed, and that lcal regulatins regarding animal welfare are met. Dwn prcessr prvides the abve dcumentatin fr verificatin during the audit. 6. Annunced and unannunced visits frm auditrs and Patagnia representatives are allwed. 7. Full access t all buildings and peratins are permitted, and private interviews with wrkers are allwed. 8. Prcessrs must allw randm testing at Patagnia s request fr evidence f live plucking. 9. Prcessrs must be cmmitted t cntinuus imprvement and implement all crrective actin items fund in the audit prcess in a mutually agreed upn timeframe. D. Dwn Whlesalers Purchases washed and srted dwn, further washes, sterilizes, srts it, and sells finished dwn t garment factries. Requirements 1. Dwn whlesaler must be audited and verified t the Traceable Dwn standard. 2. Dwn whlesaler is pre- apprved by Patagnia and agrees t fllw and implement the Traceable Dwn standard thrughut its supply chain. 3. Fr all Traceable Dwn materials and prducts, dwn whlesaler must nly use input materials verified thrugh the Traceable Dwn standard. 4. If the dwn whlesaler purchases r sells material that is remved frm live animals and/r frm animals frce fed fr the prductin f fie gras, the Traceable Dwn material must be segregated during all phases f prcessing, including arrival f raw material t the facility thrugh shipping t next lcatin. The dwn whlesaler must visually shw segregatin thrugh labeling and r ther clear identificatin methds in the strage areas, n machinery and during facility entry and exiting prcessing. Relevant written plicies and prcedures, chain f custdy dcumentatin and emplyee training must als be maintained n site. 5. Dwn whlesaler maintains cntracts with all lcal and internatinal prcessing facilities and slaughterhuses supplying raw and/r washed dwn. Cntract shall cntain language creating awareness that certain custmers have requirements that animals are nt live plucked, mlt harvested r frce fed and that lcal regulatins regarding animal welfare are met. Dwn whlesaler prvide this dcumentatin fr verificatin during the audit. 6. Annunced and unannunced visits frm auditrs and Patagnia representatives are allwed. 6
7 7. Full access t all buildings and peratins are permitted, and private interviews with wrkers are allwed. 8. Whlesaler must allw randm testing fr evidence f live plucking based n the risk f their supply chain. 9. Whlesaler must be cmmitted t cntinuus imprvement and implement all crrective actin items fund in the audit prcess in a mutually agreed upn timeframe. 10. Dwn whlesaler must ensure clear cmmunicatin and educatin n Traceable Dwn standards thrugh all levels f the supply chain, and where applicable, must als facilitate and manage the audit crrective actin plan prcess thrughut the supply chain, including its wn sites. E. Garment Factry Purchases finished Patagnia Traceable Dwn material, manufactures it int garments, and sells these prducts t Patagnia. Requirements 1. Factry must be audited and verified t the Traceable Dwn standard. 2. Factry is pre- apprved by Patagnia and agrees t fllw and implement the traceable Dwn standard thrughut its supply chain. 3. Fr all Traceable Dwn materials and prducts, factry must nly use input materials verified thrugh the Traceable Dwn standard. 4. The prductin f garments using Traceable Dwn material must be well labeled and segregated during all phases f prductin frm dwn material entry thrugh packing the garments fr shipment. 5. Wrkers using Traceable Dwn during prductin must be trained n traceability prcesses fr garment factries set frth by Patagnia and n segregatin methds t prevent mixing with nn- traceable dwn frm their ther custmers. These required traceability prcesses include, but are nt limited t: A. Factry will issue purchase rder t dwn suppliers requiring they fill Patagnia's rders separately frm thse f ther brands. B. When Patagnia s Traceable dwn shipments are delivered t the factry, material will be stred and prcessed separately frm shipments f ther brands. C. Factries shall maintain the fllwing dcuments fr each Patagnia Traceable Dwn rder: i. Factry PO t Patagnia Traceable Dwn supplier ii. Cpies f suppliers invices, packing lists and imprt dcuments iii. Supplier's prductin lt number is clearly indicated in dcumentatin prvided iv. Factry receiving recrds v. Factry s strage and segregatin recrds f received material vi. Up t date exit recrds f Traceable Dwn material frm strage rm t prductin line vii. Lgs identifying garment style numbers being prduced with specific shipment material 7
8 viii. Factry- created and implemented wrker training materials regarding Patagnia s traceability prcesses ix. All dcuments shall be available n site and prvided t the auditr r any Patagnia persnnel fr review. 6. Factry maintains up t date wrker training attendance lgs and cnducts new- hire training and refresher trainings every 6 mnths r as needed. 7. If raw dwn materials and/r finished gds dwn prducts are mved fr strage int a lcatin separate frm the apprved facility, Patagnia s Surcing and Scial and Envirnmental Respnsibility departments must be ntified befre the mve takes place. The new strage site must be assessed prir t placing the raw materials r finished prducts there. 8. Annunced and unannunced visits frm auditrs and Patagnia representatives are allwed. 9. Full access t all buildings and peratins are permitted and private interviews f wrkers are allwed. 10. Factry must be cmmitted t cntinuus imprvement and implement all crrective actin items fund in the audit prcess in a mutually agreed upn timeframe. 8
9 APPENDIX A Patagnia Supplier Cde f Cnduct Animal Welfare and Traceability Requirements 9
10 APPENDIX B Summary f Best Practice Animal Welfare Standards The fllwing best practices in animal welfare were taken frm the Internatinal Finance Crpratin s Gd Practice Nte n Animal Welfare in Livestck Operatins. Where lcal law is silent, the Patagnia Traceable Dwn standard uses the IFC s standards as the basis fr the evaluatin f animal welfare. The higher standard mre in favr f the animals is applied. Feed and Water Animals shuld receive a daily diet adequate in cmpsitin, quantity and cntaining apprpriate nutrients t maintain gd health, meet their physilgical requirements and avid metablic and nutritinal disrders. Animals shuld have an adequate daily supply f water that is palatable and nt harmful t their health. Fd and water shuld be prvided in such a way that all animals have an pprtunity t feed r drink withut undue cmpetitin and injury. Husing Systems Animal accmmdatin shuld be designed, cnstructed and maintained t allw all animals space t stand, turn arund, stretch, sit and/r lie dwn cmfrtably at the same time. They shuld als allw all animals t directly interact with herd r flck mates, unless islated fr veterinary reasns. All animals shuld have access t a clean and dry place. Effluent and waste shuld nt be allwed t build up where it leads t discmfrt and cmprmised welfare. Animals shuld be prtected frm extreme temperatures r abrupt temperature fluctuatins, cld draughts and frm predatrs, vermin and excessive nise. Animals with access t, r living, utdrs shuld have access t shade and shelter and prtectin frm predatrs. Husbandry Practices Handling and restraining techniques shuld minimize distress and avid injury. Health & Disease Persnnel respnsible fr the care and management f animals shuld have an apprpriate level f knwledge f the nrmal health and behavir f the animals in their care s as t be able t recgnize pr health and welfare. Animals shuld be inspected regularly, at least daily, and mre frequently during perids f significant risk t health and welfare. Animals must be maintained in gd bdy cnditin and remedial actin (veterinary attentin, imprved nutritin r husbandry) taken when in pr cnditin, r when there are signs f significant distress, ill- health, disease r injury. Transprt Animals shuld be neither t lsely nr t tightly laded s as t reduce the risk f excessive mvement r vercrwding resulting in injury. 10
11 Slaughter During transprt, animals shuld be prtected frm extremes f heat and cld and prvided with adequate ventilatin. Prir t slaughter, prper handling techniques and lighting, space and ventilatin shuld be used t keep the animals calm. Animals shuld be slaughtered as sn as pssible after arriving at the slaughter facility. In cases where animals are kept fr lng perids prir t slaughter, feed and water must be prvided. All animals must be handled and restrained, rendered uncnscius and slaughtered in the least distressing and mst pain- free manner pssible by trained and cmpetent staff. All animals shuld be rendered uncnscius by a means which causes uncnsciusness t persist until death ccurs. The full dcument can be fund at this link: 11
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