Broken Needle and Metal Contamination Policy Softgoods.

Copyright 2010 by Big W. All rights reserved. No part of this document may be presented, reproduced or copied in any form or by any means (graphical, electrical or mechanical including photocopying, recording tape or by any information storage and retrieval system) without the express written permission of Big W. Broken Needle Policy Version 1.0 Created by Big W Quality Assurance Quality Specialist Footwear. Created on 21/08/2010 6:25 PM

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Aim:
The aim of this document is to inform our business associates of the procedures and requirements they shall follow in relation to broken needles, sharps, tacks and nails used in the manufacture of Apparel and Footwear for Big W. All vendors and manufacturers shall comply with the requirements detailed in this document.

Needle & Metal Contamination Control Policy.

At Big W we must ensure that our products are safe for our customers and that our procedures will ensure we meet or exceed this requirement. In this context we have adopted a pro-active approach to ensuring our products are not contaminated with needle or other metal fragments or objects during the manufacturing and supply process. The WOW policy outlined here is our effective Needle and Metal Contamination Control Practice and has been implemented as a condition of supply to all our vendors and in facilities where our products are manufactured. This policy applies to all products supplied to the Softgoods division of Big W and General Merchandise of Supermarkets and PEL New Zealand. The Needle and Metal Contamination Control Policies cover as a minimum (but limited to) include: Broken needle fragments Razor, scalpel and other sharp bladed instruments fragments Pins, tacks and nails Scissors and other cutting instruments Syringe needles (whole and fragments) stitch unpickers and similar sharp pointed instruments and Use of metal detector equipment Control of sharp Instruments in packing and dispatch areas. The Minimum requirements of an effective Needle and Metal Contamination Control system which WOW requires all vendors and factories to incorporate within their processes includes: Manufacturers adopt a proactive attitude towards the removal (as far as possible) of processes, which bring any foreign metal objects into contact with garments and footwear during manufacture. Designated individuals should be responsible for a needle issue procedure and they must account for all needles. Stored needles must be under lock and key and accessible only by the designated person(s). Designated individuals should be responsible for the replacement issue of all sharp instruments (needles, tacks, metal instruments, objects or blades) must be collected, assembled and attached to a record sheet to ensure that the instrument, object or blade is complete before a replacement is issued. If all broken needles/sharps pieces or metal fragments cannot be accounted for, than a metal detector test (if available) must be carried out to find the metal compounds. If no metal fragments are detected, then the footwear can continue to be processed. In the event of no metal detector, 100% inspection must be carried out on all apparel and footwear in the batch (a) that would or could have been contaminated, before the footwear can be released for further processing. If fragments cannot be found suspect apparel or footwear are to be destroyed.

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All pins, tacks and nails used in production processes shall be stored in suitable receptacles to prevent such objects spilling or migrating to product. Wherever possible, the objects shall be of sufficient size or colour to allow for easy identification in product. Traceability procedures to account for broken needles, metal sharp objects, instruments and blades must be in place. It is required that where metal detection equipments are available it must be used as a final inspection process to complement needle control procedures. The metal detector report relating to each production order shall be copied and attached to the inline/Preshipment inspection report. The only sharp instrument permitted in the Packing and Dispatch areas is scissors (firmly attached to benches).

In order to ensure that these policies are implemented satisfactorily, the following procedures must be followed; Prior to commencing any supply agreement with a new manufacturer or supplier, the buyer must ensure a copy of the needle and Metal Contamination Policy used within that manufacturer is supplied to WOW QA. A copy of this document must also be provided to the supplier. Guideline to Broken Needle Control Procedures. Sufficient procedural controls are required to ensure that all apparel and footwear is not contaminated with needles or needle fragments during manufacturing. To assist in the compliance of this requirement, please find outlined here a guideline to elements that should be implemented within the manufacturers needle control procedure. The procedure and the actions taken shall be in written form enabling that system to be independently audited. A designated individual (per work area) be responsible for the issuing of needles. All new and broken needles are to be kept under lock. No new needles or broken needles are to be stored in sewing machinists work area. Access to needles is limited only to the designated individual/s. New needles to be only issued upon receipt of old needle. In the event of a needle breakage all pieces of the broken needle are to be retrieved for the product, collected and all fragments assembled and attached to a record sheet to ensure that needle is complete. If the entire needle cannot be re- assembled and all fragments removed from the product, than all products in the immediate work area are to be subject to a metal detector test (if available) to ensure no fragments are in any product. If a metal detector is not available, than all products in the immediate area should be 100% inspected. In the event of the missing needle fragments(s) not being found suspect products should be destroyed. All incidents of broken needles are to be recorded and details of actions taken in the event of missing fragments being documented.

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See example of recording required for auditing purposes

NAME/ OPERAT E NO; J CITIZEN P BROWN DATE MACHIN E NO: BATCH/ORDER/ STYLE NUMBER TYPE OF MACHINE SIGNED ACTUAL BROKEN NEEDLE PIECES _____ ACTION TAKEN

30/12/ 08 2/1/09

6 12

5241-DFT12587 07521-SD12458

PLAIN OVERLOCK

JJM JJM

M SMITH

1/1/09

06002h a0245

TWIN NEEDLE COVER STITCH

JJM

HAND HELD METAL DETECT OR - OK PRODUC T DESTRO YED

Baby Apparel Needle Detector.

Any manufacturer audited for supply of any apparel for Babies (which applies to garments suitable of use on children up to two years of age) MUST have a Needle Detector in operation on the site of manufacturer. The company shall apply the best practice and establish critical limits of detections, ensuring accurate detection and operation of the detector. This Needle Detector system must be serviced regularly calibrated and staff trained in its operation. All garments MUST pass though the needle detector machine whilst in operation and a copy of the resulting report shall be submitted with a Preshipment Inspection report to WOW. Any defective product must be diverted and isolated.

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Tacks and Nails. - Footwear

WOW shall require all factories producing product for our stores to employ a No Tack Policy. This means: No tacks used in the attachment of insoles to lasts. Lasts must have a steel heel plate to ensure that if nails are required in heel attachment, they cannot penetrate though the innersole to shoe interior. Where heel nails are required, a more visible type should be used (e.g. Use pins with large coloured heads). If substitution is not possible due to the method of construction, the following must occur: All waste nails, tacks or pins must be stored in a secure receptacle that cannot be knocked over or nails, tacks or pins spill from. All footwear shall be subject to Metal Detector testing after the use of nails /tacks or pins are used in the process. If a metal detector is not on the premises, WOW Ltd recommends that the manufacturer endeavour to procure one as soon as possible. The metal detector shall be in good operating order at all times. All internal cavities of footwear must be thoroughly inspected by hand to ensure that heel nails have not penetrated though into the shoe interior.

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