VOLUNTARY PROPOSAL TO REDUCE THE RISKS FROM NONYLPHENOL, OCTYLPHENOL AND THEIR ETHOXYLATES

Focus Commitment

As a major national retailer of DIY and gardening products, Focus is fully committed to the protection of the environment and to developing its business in a sustainable way.

Focus recognises that some of the substances used in the manufacture of its products and their packaging may, when released into the environment, have the potential to cause long-term harm to ecosystems or to human health.

In April 2002, Focus embarked upon a long-term strategy, ‘Action on Chemicals’, that commits the company to the responsible management of chemicals used in the manufacture and packaging of its products.

To mark the first year of ‘Action on Chemicals’, Focus signed the Friends of the Earth Retailer Pledge. The Pledge seeks a commitment from retailers to find out which products contain chemicals of concern, to set up a programme with the aim of phasing them out from own-brand products by the end of 2008 and to report on progress on an annual basis.

Focus acknowledges the conclusions of the EU risk assessment and the recommendations for risk reduction and marketing and use restrictions for NP and NPE.

Focus acknowledges the commitment of the supply industry, as represented by GOSIP (the CIA Sector Group for Organic Surfactants and Intermediate Products), CEPAD (the European industry body representing, in this instance, the producers and suppliers of nonylphenol ethoxylates), BCDTA (British Chemical Distributors and Traders Association) and BACS (British Association of Chemical Specialties) to promote awareness and to encourage the use of alternatives to those chemicals.

Focus Agreement

Focus agrees to:

1. On an ongoing basis, contact all suppliers who have reported their use of NP/E and/or OP/E in a Focus Chemical Questionnaire, to make them aware of the voluntary agreement, which relates to particular uses. Suppliers are required to report use of NP/E and OP/E in manufacturing processes and packaging, as well as in the final product, and to seek information from upstream users where necessary.
   
2. Ask suppliers to respond to the following questions:
   • do you still use Nonylphenol, Octylphenol or their Ethoxylates?
   • have they already been removed or reduced?
   • do you have plans in place to phase them out?
   • do you conform to any relevant sector agreements on the use of NP/E or OP/E?
   
   (Focus has been contacting suppliers with regards to NP/E and OP/E since June 2003)
   
   
3. Focus has a long-term commitment to managing chemicals of concern used in the manufacture of, and present in, consumer products.
   
   Our target for replacing NP/E and OP/E in domestic cleaning products, textiles and leather, metal working fluids, pulp and paper products, cosmetic products and other personal care products is the end of 2004.
   
   Our target for replacing NP/E and OP/E used in co-formulants in pesticides and biocides is the end of 2006.
   
   
4. To measure progress over time, from December 2003, we will report annually on our website (www.focusdiy.co.uk/about/environment.htm) against the following indicators:
   
   

• number of suppliers contacted per year* regarding the Voluntary Agreement
• number of suppliers reducing the use of NP/E and OP/E in products supplied to Focus, per year*
• number of suppliers replacing the use of NP/E and OP/E in products supplied to Focus, per year*

(* year = Focus financial year which is November to October)

November 2003

Progress Report December 2003

Between April 2002 and June 2003, all Focus suppliers were asked to complete a questionnaire about the chemicals used in their products.

The survey responses indicated that sixteen of our suppliers were using Nonylphenol, Octylphenol or their Ethoxylates (NP/E and/or OP/E) in their products. All sixteen were contacted with regards to the initiative by the Department for Environment, Food and Rural Affairs concerning a voluntary proposal to reduce the risks from these chemicals. The results are given below.

Results:

Number of suppliers reporting NP/E and/or OP/E in the Focus Chemicals Questionnaire	16
Number of suppliers contacted regarding the voluntary proposal	16
Number of suppliers reducing the use of NP/E and OP/E in products supplied to Focus	2
Number of suppliers replacing the use of NP/E and OP/E in products supplied to Focus	6

Half of those suppliers who reported using NP/E and/or OP/E are already taking action to reduce or replace these chemicals in their products. We will be holding discussions with the remaining eight suppliers over the coming months concerning their proposals for reducing or replacing these chemicals.

Note: As part of the Focus Action on Chemicals strategy, the collection of chemical information (by product) will be made a routine process in 2004.

Progress Report December 2004

In line with the voluntary agreement, Focus Wickes continued to collect information from suppliers on their use of nonylphenols, octylphenols and their ethoxylates (NP/Es and OP/Es) in products and packaging during 2004.

42 responses were received from suppliers and the results are shown below.

Results:

Question	Response
	Yes	No	Not Applicable
Do you use nonylphenol, octylphenol and their ethoxylates in any products or packaging supplied to Focus or Wickes?	11	31
Have they already been removed?	9	6	27
Have they already been reduced?	4	5	33
Do you have plans in place to phase them out?	9	2	31
Does your company conform to any relevant sector agreements on the use of nonylphenol, octylphenol and their ethoxylates?	8	34

The survey responses indicated that 11 of our suppliers were using Nonylphenol, Octylphenol or their Ethoxylates (NP/E and/or OP/E) in their products or packaging.

By reviewing the industrial sectors of these suppliers, it has been determined that no NP/Es were used in products or packaging manufactured in sectors restricted by the marketing and use controls on NP/Es that came into force on 17th January 2005.

Only two suppliers do not have action plans in place to phase the chemicals out. Focus understands that this is due to the lack of cost effective alternative substances at this time. The situation with these suppliers will be reviewed periodically.

Last updated 18.11.05