Download as pdf or txt
Download as pdf or txt
You are on page 1of 119

Higg FEM 3.

0 Training

Target RS&S

Now it’s playing background music.


fall leadership
Training will besummit
started•soon.
2019
Environmental
Projects
Environmental Program Overview
Target’s Environmental Program follows a continuous improvement approach
where factories make progress over a maturity curve of 12-18 months

Measured improvements
reflected Target Forward Higg FEM completed
Opportunity / Results annually
goals and in following Assessment
year Higg FEM

Recognize and Report


Hot Spot Analysis Benchmark
Impact
assessment of facility
performance to surface
Ongoing coaching and opportunities for
support (in person and continuous
online) offer multiple improvement.
opportunities for
growth.

Project Environmental
Implementation Capability Building

Performance Review quality of Higg


Aii Programs - On-site Improvement Program FEM data, training and
improvement efforts are led by Nomination communication action
approved technical experts who plan
serve as a trusted advisor.
Environmental Standards - SOVE

Environmental Management and Monitoring Systems


Suppliers must have environmental monitoring systems which accurately measure and track operational and production
impacts to air, water and any other environmental system which may be deemed necessary.

Water Stewardship
Suppliers must identify, characterize and inventory all wastewater streams on an ongoing basis. In addition, suppliers must install and maintain
appropriately sized wastewater treatment systems to ensure pollutants are at or below legally required levels. We will not tolerate suppliers with
undersized, bypassed, or inoperable wastewater treatment systems.

Waste Reduction & Disposal


Suppliers must handle, store, transport, and dispose of hazardous waste legally. We seek suppliers who demonstrate they actively work to reduce
waste throughout the production process. We will not tolerate suppliers that engage in illegal waste dumping.

Energy Management
With respect to both production facilities and processes, suppliers must identify all applicable energy sources and energy consumption. Suppliers
must also periodically set clear goals to improve energy efficiency and document progress made toward achieving those goals.

Emissions to Air
With respect to both production facilities and processes, suppliers must monitor and document all air emissions in
accordance with the applicable regulatory requirements. In addition, suppliers must install and maintain appropriate air emissions control
devices to ensure air emissions’ pollutants are at or below legally required levels.

Licenses and Permitting


Suppliers must acquire and maintain all legally required environmental permits and business operating licenses necessary
for the production of their products and operation of their facilities. We will not tolerate suppliers operating without valid current permits.
Higg Tools
Brand Retailer Facility Product
Module Modules Modules

Company Facilities Facilities Social Product


Brand Retailer Environmental Labor Module Module
Module Module (FEM) (FSLM) (Design)

• Target completes this • Since 2012 we have utilized • Connected with • Managed through
module across the the Higg FEM module with SLCP gateway design/development
enterprise. our tier 1 and tier 2 supply • Accepted scheme team
• Required as a part of chains. as a part of EQ • Looking to see how
our Sustainable • As part of our responsible • Adopt and scale in the module can
Apparel Coalition sourcing program we have A&A + Tier 2 connect to our
membership adopted the Higg internal product
framework as our development system,
environmental oversight not fully scaled
model.
• Higg is used as a baseline
data collection for our RS
goal work
• 2020 Target has made Higg
FEM self-assessment a
requirement included in our
EQ scheme protocol
Who Completes Higg FEM

All product categories & all countries of production

Home Hardlines Accessories Essentials Footwear Apparel Tier 2

Included
(All product categories) Excluded

All Factories All tier 2 Factories Factories


factories producing facilities producing regulated
registered owned brand authorized NBIOR by the
in VMM product for in VMM FDA or USDA
Target
Conduct and Submit Higg FEM
Factories are required to complete the Higg FEM self-assessment as a part of doing business with Target. This has
been a request to factories since 2012 and will now be an annual requirement as a part of Target's Equivalency
program.

Factories in scope include partners that produce Target Owned Brand, National Brand where Target is the
importer of record, and authorized factories that produce tier 2 fabric, trim and packaging.

Conduct
Step 1: Registration • Register for an account on Higg.org or login to your existing account
Step 2: Purchase self-
assessment • Complete the FEM self-assessment

Submit
Step 1: Ensure that
self-assessment is • Post and share the module with Target Corporation (Higg ID 489)
shared

Step 2: Complete • In Inspectorio, you will be prompted to enter the Higg ID


Inspectorio Section • Target will use the number to verify completion

Please note: Factories that choose to complete Higg FEM verification will not be required to complete the
environmental questions within the disclosure section in Inspectorio. Please ensure that your verification report is posted
and shared with Target, otherwise it may lead to critical issue in your audit report.
Conduct and Submit Higg FEM
Which subscription should I choose?

Facility Environmental: This subscription includes access to the standard Higg FEM self-
assessment. Facilities that are required by Target to complete ONLY the Higg FEM should
choose this subscription. As we continue to develop our program requirement, we encourage
tier 2 fabric mills to purchase the FEM verification module in addition to the FEM self-
assessment.

Facility Plus: This subscription includes access to the standard Higg FEM self-assessment and
the Higg FSLM self-assessment; this option also includes access to the FEM Communication
Toolkit, Benchmarking, CSV exports, and SLCP verified transfer. Facilities that are required by
Target to complete BOTH the Higg FEM and SLCP, could choose this subscription if they
would like to leverage Higg platform as an Accredited Host for SLCP.
Target’s Annual Requirements
Process Requirements- module year
The self-assessment must be completed, posted and shared with Target annually. Failure to
complete the Higg FEM self-assessment will result in a 6-month deactivation of the factory.​
Starting from January of each year, we will only accept Higg FEM self-assessment from the
current available module, e,g. starting from January, the FEM subscription in 2023 would be
the module of 2022. More examples could be referred as below.

Disclosure Year Acceptable Higg FEM for Target


2022 2021
2023 2022
2024 2023

Reminder: please ensure the facility’s name and address in Higg are aligned with the ones in VMM.
Target’s Annual Requirements

Process Requirements - assessment due date


As a part of Target's Responsible Sourcing and Sustainability Audit Program, the Higg FEM
self-assessment and approved social scheme audit are due to be disclosed in Inspectorio
RISE at the same time.
• If you haven’t completed assessment disclosure in Inspectorio RISE before and you have
been notified of disclosure due date from our mail, please stick to that due date in order to
successfully complete assessment disclosure in Inspectorio RISE. Though Target's Higg
FEM self-assessment due date might be earlier than the Higg industry adoption due date.
• If you have completed assessment disclosure in Inspectorio RISE in the past, then each year
your Higg FEM self-assessment due date is the annual date of your disclosure for social
scheme audits.
• Please ensure you purchase the module before October of each year otherwise the module
of current year will not be available for purchase after October.
Benefits and Use

What are the benefits for factories for completing How does Responsible Sourcing uses the information?
the Higg Index?
• Develop a baseline energy inventory of our supply
• Understand the full environmental impacts at chain which will help us establish a Science Based
their factory Target that we have committed to through our
climate policy goals
• Develop comprehensive strategies and policies
to manage environmental performance • Identify high impact categories and incorporate
performance improvement programs
• Identify opportunities to improve performance
and gain efficiencies • Global risk mapping by impact area (for example
water scarce regions)
• Benchmark results against industry peers
• Ability to do much more analysis in future
• Easily share the results of one assessment with
numerous customers or supply chain partners
Frequently Asked Questions

• What are the expectations for completing Higg FEM Verification?


• Higg FEM Verification is not required at this time. Factories that choose to complete Higg FEM verification will not be required
to complete the environmental questions within the disclosure section in Inspectorio.
• Additionally we are working to rollout a pilot for Higg FEM verification in Inspectorio in 2023, you will be contacted if you are a
part of this pilot.
• How does Target view Higg FEM score and results?
• Today we are focused on adoption of the tool and continuous improvement year over year. There is no a minimum score that
should be reached as a part of Target’s requirements.
• Please enter the accurate data for water use, energy use and production volume in your self assessment.
• The next year’s FEM module starts from November each year and there is a limitation in the Higg platform that in
November and December FEM module couldn’t be post until January of next year. Does this impact the disclosure
process in Inspectorio RISE?
• If the factory was not requested to complete the module of current year and has not completed it, it’s accepted that factory
complete the self-assessment of next year as much as it can at that time and then post it until the January of next year.
• If I am FDA/USDA regulated factory, how can I inform Target for the exemption of Higg FEM?
• You don’t need to inform Target through email or any other offline communications. You can just follow system instructions to
upload FDA/USDA certificate or documents in the designated place during the process of disclosure. Target will follow up and
verify this accordingly.
• Are training materials and more resources available for learning?
• All references and resources can be found here in POL Link, search “Higg” on POL
How to Higg Guide
(2021)
https://howtohigg.org/resources/resources-library/
Section Overview

• Section 0: Site Information & Permits Structure of guidance


• Section 1: Environmental Management System for each question in
“How to Higg Guide”
• Section 2: Energy & GHG
• Question
• Section 3: Water Use • Suggested uploaded
documents
• Section 4: Wastewater • Answering guidance
• Section 5: Air Emissions • What is the intention of
the question?
• Section 6: Waste • Technical guidance
• How this will be verified?
• Section 7: Chemical Management
Section 0 - Site Info & Permits

Question and Guidance Common Mistakes


Country or Region
Industry Sector
Facility Type
o Please select all types that apply to your site Choose one type only when
• Example for Apparel: If you are a Cut-Sew facility that also does screen printing or there are more than 2 types.
wet processing on site you would select both Final Product Assembly AND Printing,
Product Dyeing and Laundering.
• Example for Hardgoods: If you are a facility that undertakes final product assembly
and manufactures hard components on site, you would select both Final Product
Assembly AND Hard Product Component & Trim Production (Plastic, Metal, Wood).
Facility Processes
Material Types
Section 0 - Site Info & Permits
Question and Guidance Common Mistakes
How many days did your facility operate in this reporting year?
• Operating days are considered days when production and/or production related activities (e.g. Do not have reliable records to
product/raw material loading/shipment) were conducted at the facility. support the number.
• Any operating day where the number of hours in operation OR the number of workers is less
than 50%, then count the day as 0.5 day. Where it is greater than 50%, then count the day as 1 Count as 1 day by mistake for
day. those cases of 0.5 day only.
Total Number of Employees
o Please enter the average number (not a range) Enter the employee number for
• Example: the total number of employees your facility paid in all pay periods during the year December of the last year.
divided by the number of pay periods your facility had during the year, like (N1+N2+…+N12) / 12.
What was your facility's annual volume? Enter a rough number like
• Report the total amount of product shipped/sold in the last calendar year. Total amount of product 1,000,000.
shipped/sold should not include the total amount of rejects in the last calendar year. Enter production volume

Why we use shipped/sold quantity instead of annual production output?


The main rational is to create a consistent production metric that all facilities are able
to track and the data are more comparable for industry benchmarking at the end.
Besides, using shipped/sold amount as the metric is to discourage excessive or
unnecessary production including leftover, semi-products, samples and rejects which
are also an environmental concern.
Section 0 - Site Info & Permits
Question and Guidance Common Mistakes
How many days did your facility operate in this reporting year?
• How can wedays
Operating calculate the totaldays
are considered volume
whenfor differentand/or
production typesproduction
of products when
related they (e.g.
activities Do not have reliable records to
product/raw
consume material
different loading/shipment) were
energies/resources conducted at the facility.
significantly? support the number.
• TheAny operating
unit day Allowed
Standard where theMinute
number(SAM)
of hoursisinprovided
operationin
OR theoptions,
the number which
of workers is less
is, calculating
thethan 50%, then count the day as 0.5 day. Where it is greater than 50%, then count the day as 1
INDIVIDUAL SAM of each product then multiple it with quantities and come out with Count as 1 day by mistake for
day. those cases of 0.5 day only.
TOTAL SUM of SAM for all products finally. More details can be referred in “Guide”.
Total Number of Employees
o Please enter the average number (not a range) Enter the employee number for
• Example: the total number of employees your facility paid in all pay periods during the year December of the last year.
divided by the number of pay periods your facility had during the year, like (N1+N2+…+N12) / 12.
What was your facility's annual volume? Enter a rough number like
• Report the total amount of product shipped/sold in the last calendar year. Total amount of product 1,000,000.
shipped/sold should not include the total amount of rejects in the last calendar year. Enter production volume

Why we use shipped/sold quantity instead of annual production output?


The main rational is to create a consistent production metric that all facilities are able
to track and the data are more comparable for industry benchmarking at the end.
Besides, using shipped/sold amount as the metric is to discourage excessive or
unnecessary production including leftover, semi-products, samples and rejects which
are also an environmental concern.
Section 0 - Site Info & Permits
Question and Guidance Common Mistakes
Does your facility have onsite water treatment (i.e. Pre-treatment and/or Wastewater
treatment)?
(NEW) Has your facility participated in industry programs related to sustainability or have
sustainability related certificates valid during the reporting year?
o Apparel Impact Institute’s Clean by Design (CbD), Textile Exchange’s Global Recycled
Standard (GRS), ZDHC CleanChain, Bluesign System Partner, etc.
Does your factory site have a valid operating license, if required by law?
o If you answer "No" or “Unknown” to “Does your factory site have a valid operating
license?”, you will score ZERO points for the entire Facility Environmental Module.
o If you have an expired operating license, you must answer “No” to this question, even if you
are in the process of updating your operating license.
Did your facility receive any government-issued environmental violation records in 2021? Choose “No” without verification.
• If yes, please describe the violation and your site's action plan to improve
Does your facility currently have any records in the Institute of Public & Environmental
Affairs (IPE) database?
• If yes, has your facility supplied enterprise feedback to the database and/or taken
steps to remove the record(s) from the database?
• If based in China, here is the link to the IPE Database references in this question:
http://www.ipe.org.cn/IndustryRecord/Regulatory.aspx
• If your site has a violation record and would like to supply enterprise feedback to IPE and/or take
steps to remove the record from the database, please contact [email protected]
Section 0 - Site Info & Permits

Question and Guidance Common Mistakes


Please complete the following questions to provide details on your facility’s environmental
permits requirements and compliance status
● Water use ● Water discharge ● Wastewater treatment ● Chemical use and management Neglect permits for water intake,
● Air emissions ● Solid waste discharge ● Other environmental permits water discharge and others
• Permit example for Chemical use and management:
● Requirements for chemical management permit or agreement, such as an approved
chemical list, chemical classification system, safe chemical handling procedures or chemical
disposal (ZDHC Chemicals Management Manual)
● Compliance with REACH (ZDHC Chemicals Management Manual)
● Include compliance or all laws / regulations / permits needed for specific chemicals. For Neglect permits for chemical
example: Potassium Permanganate is controlled for purchasing and registration with police purchasing and registration
office is required in some locations. This is not a permit, but registration required by law -
therefore it must be included here.
• Permit example for Air emissions:
● Include permits or requirements for air emissions from stacks of utilities (boilers, diesel
generators, etc.)
• Permit example for Solid waste discharge:
● Please note that licenses/permits for hazardous waste contractors will be requested in the
Waste section.
Section 1: Environmental Management System
Question and Guidance Common Mistakes
1. Are one or more employees at your facility responsible for coordinating your
facility’s environmental management activities?
o Answer Yes if you have any full-time, half-time, part-time, seasonal or contract
employees working on environmental management in your facility.
• Facilities should have clearly defined roles and responsibilities for any staff No specific organization
responsible for coordinating environmental management activities at the facility. chart and job descriptions
2. Does your facility have a company environmental management strategy that
guides long-term decision-making on environmental management?
Select all topics covered by this strategy:
o Energy o Water o Wastewater o Air o Waste o Chemical Management
• A good environmental strategy should: Do not address significant
1) address your facility’s significant environmental impacts and compliance obligations as environmental impacts
prioritized in your environmental impact assessment;
2) be supported by facility leadership;
3) be communicated to all employees. To ensure environmental objectives are carried out, your Not signed off by factory
strategy should include plans for achievement that detail: what will be done, what resources management
will be required, who will be responsible, when it will be completed, and how results will be
evaluated (reference: ISO 14001).
4) If you have an environmental strategy that aligns with requirements in ISO 14001 and plans Not a long-term strategy
for 3+ years into the future, you may answer Yes to this question.
Section 1: Environmental Management System
Question and Guidance Common Mistakes
3. Has your facility identified the significant environmental impacts associated
with current operations within the factory premises?
• A facility should check laws and regulations to determine whether their local Has initial EIA but no
government has rules governing the process of evaluating likely environmental expansion EIA in case of
impacts of the facility’s operation (i.e. Environmental Impact Assessment) that expansion projects
should be followed.
o If there are no local regulations, an impact assessment can be conducted Has “Environmental Factor
following an internationally recognized EMS framework. Identification” but no update
4. Does your facility have a program or system in place to review and monitor
environmental permit status and renewal (where appropriate) and ensure
compliance?
• At a minimum it is advised to create a regularly updated document that tracks your
environmental permit review and update approach on a set schedule.
o The content of the tracking document can include environmental impact areas, Do not include all
permit name, permit status, permit number, valid period, requirements, key environmental permits
responsible person for ensuring compliance, etc.
o Example template: https://howtohigg.org/resources/resources-library/#section1
• You may also go further and create a detailed standard operating procedure to No written procedure
monitor compliance of all the permit requirements.
Section 1: Environmental Management System
Question and Guidance Common Mistakes
5. Does your facility maintain a documented system to identify, monitor and
periodically verify all laws, regulations, standards, codes and other legislative
and regulatory requirements for your significant environmental impacts?
Select all topics covered by the system: Do not cover all the relevant
● Energy ● Water ● Wastewater ● Air ● Waste ● Chemicals topics
Are the findings used to set an improvement plan that is regularly reviewed?
• Setting up a process for identifying, monitoring and verifying environmental
compliance should be part of your formal environmental management system. Periodic review is not
• Periodic review and updates of environmental regulations have to be conducted and performed
documented.
Example template: https://howtohigg.org/resources/resources-library/#section1
(NEW). Does your facility have documented procedures that enable workers to
report environmental emergencies/violations?
• The facility needs to set up and document a procedure which allow workers to report
environmental emergencies/violations. The document should clearly mention the
steps and responsible contacts the workers can report to.
• The facility should also make a statement to guarantee there will be no workers
punished or retaliated against for reporting truthful information to a law enforcement.
Section 1: Environmental Management System
Question and Guidance Common Mistakes
6. Does your facility have a process and schedule to maintain all equipment?
• All equipment for production and operation should be maintained regularly in order to Maintenance plan do not
ensure compliance and reduce environmental impact. cover all equipment
• Appropriate maintenance of equipment can be ensured through the following steps:
1) Appoint at least one facility engineer or technician to be responsible for
managing equipment maintenance.
2) Define maintenance scope and schedule for all equipment.
3) Establish a regular process to maintain all production and operational No written procedure
equipment.
4) Compile and keep maintenance logs.
7. Does your facility review the environmental management strategy with your
facility’s managers each calendar year?
• Having a set schedule for regular management meeting (such as on quarterly basis)
is recommended.
• At least one full management review is recommended annually. No annual management
o The meeting should review information such as results of verification and legal review
compliance, environmental performance, status of objective and targets, status
of preventive & corrective actions, recommendations for improvements, etc.
Section 1: Environmental Management System
Question and Guidance Common Mistakes
8. Do employees at your facility responsible for environmental management have
the technical competence required to do their job?
• Hiring someone with a background in engineering or another technical areas is No proof of competency
valuable to effectively manage environmental impacts at a facility.
o If hiring a technical expert is not an option, investing in technical training for
existing employees (e.g. Certificate in ANSI/ISO14001: Standard),
demonstrating how technical expertise has been cultivated over-time.
o Or hiring a consultant/advisor with technical expertise are other solutions.
• Ensure environmental employees are evaluated for competence on an annual basis. No annual evaluation
9. Does your facility promote awareness of the environmental strategy to
employees?
• As a first step a facility should set up an internal communication plan which identifies No internal communication
different ways of communicating the facility’s environmental strategy. plan or promotion
o An example of communications includes posters in a visible place that
communicate preferred behaviors or strategies (e.g., How to conserve energy
and water in dorms/kitchens/toilets, or appropriate waste disposal procedures
such as what can be recycled).
o More advanced examples of such communication include having formal
meetings, reviews and training sessions to inform employees of progress
against key performance indicators (KPI’s) defined by the environmental
policy/strategy.
Section 1: Environmental Management System

Question and Guidance Common Mistakes


10. Does your facility monitor, evaluate, and/or engage with your subcontractors
on their environmental performance using the Higg Index? No subcontractor list
• Ways to engage subcontractors involves leveraging the Higg Index to educate,
evaluate performance and identify improvement opportunities. You can invite your No evidence kept for
subcontractors to complete the Higg FEM and share their results with you. communication
• Any engagement and partnership should be continuous so that improvement is
monitored and managed over time. More details can be referred in “Guide”.

A subcontractor is usually an entity hired by a manufacturer to complete specific tasks


How is which are also considered special tasks or manufacturing process steps. (Even though
subcontractor subcontractors may have direct ownership connection to the manufacturer.)
defined in the Finished goods facilities that perform the complete manufacturing process, should not be
Higg FEM? considered or termed as a subcontractor in the Higg FEM context. (Even though
subcontractors may not have direct ownership connection to the manufacturer. )
Section 1: Environmental Management System
Question and Guidance Common Mistakes
11. Does your facility engage in environmental improvement in your local
context?
Select the ways in which your facility engages in environmental improvement:
● We support (financially or otherwise) conservation or improvement projects for No evidence kept
environmental issues (e.g. preserving wetlands). ● We work with other similar
businesses to share best practice for environmental management. ● We engage in
dialogue with local communities to understand their views on how we as a company
should manage our environmental impacts. ● We work within a group of other local
stakeholders including government and communities, to understand and address local
environmental issues together. ● We engage directly with local or national governance
bodies on environmental regulation or management issues. ● We work together in a
group with other local stakeholders, to engage with local or national governance bodies
on environmental regulation or management issues. ● Other
12. Does your facility monitor, evaluate, and/or engage with your upstream
suppliers using the Higg Index?
If yes, which type of suppliers?:
• Chemical suppliers • Raw material suppliers • Other suppliers, please describe No upstream supplier list
• Ways to engage upstream suppliers involves leveraging the Higg FEM to educate,
evaluate performance and identify improvement opportunities. You can invite your No evidence kept for
subcontractors to complete the Higg FEM and share their results with you. communication
• Any engagement and partnership should be continuous so that improvement is
monitored and managed over time. More details can be referred in “Guide”.
Section 2: Energy & GHG

Question and Guidance Common Mistakes


1. Select all sources of energy for your facility:
● Coal ● Natural Gas ● Petrol ● Diesel ● Fuel Oil ● Propane ● LPG ● LNG ● Biomass ● Solar Neglect vehicles owned by
Photovoltaic ● Solar Thermal ● Geothermal ● Hydro ● Micro-Hydro ● Wind ● Purchased factory
electricity ● Purchased chilled water ● Purchased steam ● Purchased Renewables
Energy Use in Your Factory
● Does your facility track its energy use from this source?
● What quantity of energy was used by this source during this reporting year? Wrong calculation of steam
● Unit of Measure ● Which method was used to track this energy source? quantities when no
● What was the frequency of measurement? ● Provide any additional comments applicable unit is available
• Map out business and operational processes to identify sources of energy use.
• Collect and track energy use data:
o Use utility bills to determine the quantity of purchased electricity, steam and heat used.
o Track other fuels used for onsite energy generation such as diesel in generators and coal in
boilers owned or controlled by the facility.
o Track fuels used for mobile combustion sources owned or controlled by the facility such as
private cars and fork lifts.
o Install sub-meters to track the amount of renewable energy generated, if renewable energy is
generated in-house.
o If estimation techniques are used, the calculation methodology should be clearly defined and No tracking of cylinder when
be supported by verifiable data. estimating LPG quantities
Section 2: Energy & GHG

Question and Guidance Common Mistakes


1. Select all sources of energy for your facility:
● Coal ● Natural Gas ● Petrol ● Diesel ● Fuel Oil ● Propane ● LPG ● LNG ● Biomass ● Solar Neglect vehicles owned by
How to define
Photovoltaic boundary
● Solar Thermalwhen mapping●out
● Geothermal business
Hydro and operational
● Micro-Hydro ● Wind ●processes?
Purchased factory
Energy consumed
electricity ● Purchasedby facilities
chilled or ●tenants
water on-site
Purchased that● are
steam NOT owned
Purchased or controlled
Renewables
by your
Energyfacility
Use inshould be excluded for your energy reporting in the Higg FEM. For
Your Factory
● Doesenergy
example, your facility track its
consumed byenergy use from
an onsite this source?
canteen/food service provider that is not
● Wrong calculation of steam
owned or controlled by your facility should be excluded. this reporting year?
What quantity of energy was used by this source during
● Unit of Measure ● Which method was used to track this energy source? quantities when no
● What was the frequency of measurement? ● Provide any additional comments applicable unit is available
• Map out business and operational processes to identify sources of energy use.
• Collect and track energy use data:
o Use utility bills to determine the quantity of purchased electricity, steam and heat used.
o Track other fuels used for onsite energy generation such as diesel in generators and coal in
boilers owned or controlled by the facility.
o Track fuels used for mobile combustion sources owned or controlled by the facility such as
private cars and fork lifts.
o Install sub-meters to track the amount of renewable energy generated, if renewable energy is
generated in-house.
o If estimation techniques are used, the calculation methodology should be clearly defined and No tracking of cylinder when
be supported by verifiable data. estimating LPG quantities
Section 2: Energy & GHG
Question and Guidance Common Mistakes
2. Has your facility set baselines for energy use?
If yes, select all sources of energy for which your facility has set a baseline.
• Source • Have you set a baseline for this source? • Is the baseline absolute or
normalized? • What is the baseline quantity? • Unit of Measure • Enter the baseline year
• How was your baseline calculated? • Was the baseline verified?
• Confirm the energy source data is stable, and sufficient to be used to determine a baseline. In the
Higg FEM, a baseline should generally comprise of a full calendar year’s data.
o Note: If your factory has undergone major structural or operational changes such as
acquisition or changes in product type, in general, you should establish or reset a baseline
after those changes have been completed. Misunderstanding on
• Determine if the baseline will be Absolute or Normalized (Normalized baselines are preferred) “absolute” and “normalized”
• Verify the source data and normalizing metrics data is accurate.
o Energy and production volume data from previous Higg FEM 3.0 verifications, internal or
external audits conducted by qualified personnel are acceptable sources of data verification.
Choose “Yes” without
• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen verification
normalizing metric 1,500,000 kWh per 1,000,000 pieces = 1.5kWh/piece)
o Note: For energy consumption that is not related to production, other normalizing metrics
should be used where appropriate (e.g. Natural gas consumption in the canteen can be
normalized per meal served or per worker)
Section 2: Energy & GHG
Question and Guidance Common Mistakes
2. Has your facility set baselines for energy use?
If yes, select all sources of energy for which your facility has set a baseline.
What • Source • Have
is absolute you set a
baseline baseline
and for thisbaseline?
normalized source? • Is the baseline absolute or
normalized? • What is the baseline quantity? • Unit of Measure • Enter the baseline year
In the Higg FEM, baselines can be “absolute” (total consumption for a reporting
• How was your baseline calculated? • Was the baseline verified?
year.
• Confirm e.g.
the1,500,000
energy source kWh perisyear)
data “normalized”
stable,orand to used
sufficient to be a product or operational
to determine a baseline. In the
metric
Higg FEM, (e.g. 0.15 kWh
a baseline shouldpergenerally
unit of production).
comprise of a full calendar year’s data.
Datao normalization is recommended
Note: If your factory has undergone to account
major for or
structural operational
operationalfluctuations
changes suchasasthis
provides for better
acquisition year-over-year
or changes comparison
in product type, in general,ofyou
data and establish
should therefore or more
reset auseful,
baseline
and after those changes
actionable have been completed.
analytics. Misunderstanding on
• Determine if the baseline will be Absolute or Normalized (Normalized baselines are preferred) “absolute” and “normalized”
• Verify the source data and normalizing metrics data is accurate.
o Energy and production volume data from previous Higg FEM 3.0 verifications, internal or
external audits conducted by qualified personnel are acceptable sources of data verification.
Choose “Yes” without
• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen verification
normalizing metric 1,500,000 kWh per 1,000,000 pieces = 1.5kWh/piece)
o Note: For energy consumption that is not related to production, other normalizing metrics
should be used where appropriate (e.g. Natural gas consumption in the canteen can be
normalized per meal served or per worker)
Section 2: Energy & GHG

Question and Guidance Common Mistakes


3. Does your facility know what facility processes or operations use the most
energy?
What are the highest energy use factors at your facility? (These can be any factors in
production such as machines, processes, or sections.)
● Identifying individual machines that consume energy by creating a machinery list
● Analyzing the power ratings of equipment multiplied by the hours of operation to Wrong estimation method
estimate energy use
● Installing electronic devices to track energy usage over time (e.g., data loggers,
data recorders, or sub-meters)
● Hiring a certified professional energy engineer to conduct an energy assessment
 Any of the options listed above on how to get started in identifying your highest energy
consuming operations or processes are acceptable.
● Consolidate the energy consumption per manufacturing process/machine type and
sort them from highest consumption to lowest consumption
Section 2: Energy & GHG
Question and Guidance Common Mistakes
4. Has your facility set targets for improving energy use?
If yes, select all sources of energy for which your facility has set an energy reduction target.
● Source ● Have you set a target for this source? ● What is your target for change in
energy use from this source? ● Unit of Measure ● Enter the target year ● Is this a
normalized or absolute target? ● Describe the measures planned to achieve this target
(how you will achieve the target)
o You will receive Full Points if you set targets for energy sources that make up 80% or more
of your total energy use. Misunderstanding on the
o You will receive Partial Points if you set targets for energy sources that make up 50-79% of meaning of percentage here
your total energy use.
• Targets can be long-term or short-term (Short-term = less than 3 years, Long-term = more than 3
years).
• Enter a negative percentage for a reduction target (e.g. -5 for a 5% reduction), and a positive
percentage for an increased usage target.
Enter a positive percentage
• A target can use absolute or normalized metrics to drive quantifiable improvements by a set date for a reduction target
compared to the baseline. For Higg FEM, reduction targets may be normalized to the annual
volume unit (selected in Site Info section: Annual volume unit) or another appropriate operational
metric. An example of a normalized target is kWh of energy used for the production of one
kilogram of sellable product (kWh/kg).
• Provide sufficient details on how the target will be met in the “Describe the measures planned to
achieve this target:” field (e.g. Achieve a 3% reduction in normalized electricity consumption by
replacing 500 T8 lights with LED lights).
Section 2: Energy & GHG
Question and Guidance Common Mistakes
4. Has your facility set targets for improving energy use?
If yes, select all sources of energy for which your facility has set an energy reduction target.
● Source ● Have you set a target for this source? ● What is your target for change in
energy use from When ● Unit ofset
will a factory
this source? ● Entertarget?
an increase
Measure the target year ● Is this a
normalized or absolute target? ● Describe the measures planned to achieve this target
(how you will achieve the target)
o You will receive Full Points if you set targets for energy sources that make up 80% or more
If you switch your energy sources from one to another (e.g. replacing electricity with Misunderstanding on the
of your total energy use.
solaro PV),
Youplease set Partial
will receive a positive
Pointstarget
if youfor
setsolar PV
targets forto indicate
energy you that
sources utilize more
make energyof
up 50-79% meaning of percentage here
generatedyourfrom solar PV
total energy and set a negative target for electricity to indicate you target
use.
• to Targets
use less
canofbethis source.or short-term (Short-term = less than 3 years, Long-term = more than 3
long-term
years).
• Enter a negative percentage for a reduction target (e.g. -5 for a 5% reduction), and a positive
percentage for an increased usage target.
Enter a positive percentage
• A target can use absolute or normalized metrics to drive quantifiable improvements by a set date for a reduction target
compared to the baseline. For Higg FEM, reduction targets may be normalized to the annual
volume unit (selected in Site Info section: Annual volume unit) or another appropriate operational
metric. An example of a normalized target is kWh of energy used for the production of one
kilogram of sellable product (kWh/kg).
• Provide sufficient details on how the target will be met in the “Describe the measures planned to
achieve this target:” field (e.g. Achieve a 3% reduction in normalized electricity consumption by
replacing 500 T8 lights with LED lights).
Section 2: Energy & GHG
Question and Guidance Common Mistakes
(NEW). Has your facility set targets for reducing your facility overall GHG
emissions?
● Enter the base year ● What is your target for reducing your facility’s overall GHG
emissions? ● Unit of Measure ● Enter the target year ● Is this a normalized or absolute
target? ● Describe the measures planned to achieve this target (how you will achieve
the target)
• The general target setting process is quite similar to that of energy.
• An example of a normalized target is kgCO2e released during production of one
kilogram of sellable product (kgCO2e/unit).

Greenhouse Gases (GHGs) are gases in the Earth’s atmosphere that absorb/trap some of
the Earth’s outgoing radiation, causing the atmosphere to warm up (called the ‘greenhouse
effect’).
What’s the Your factory’s energy use generates direct and indirect GHG emissions. The GHG Protocol
connection categorizes these emissions into three broad “scopes”:
between energy ● Scope 1: All direct GHG emissions.
use and GHG ● Scope 2: Indirect GHG emissions from consumption of purchased electricity, heat or steam
emissions? ● Scope 3: Other indirect emissions, such as the extraction and production of purchased
materials and fuels, transport-related activities, electricity-related activities (e.g. T&D losses)
not covered in Scope 2, outsourced activities, waste disposal, etc.
Section 2: Energy & GHG

Question and Guidance Common Mistakes


5. Does your facility have an implementation plan to improve energy use and/or
GHG Emissions?
o You will receive full points if energy reduction plan listing specific projects, target
reductions, dates, and progress that covers 80% or more of total energy use.
o You will receive partial points if energy reduction plan listing specific projects, target
reductions, dates, and progress that covers 50-79% or more of total energy use
Steps for action should include:
1. Identify energy saving opportunities through internal assessment by qualified
personnel or third-party energy assessment
2. Evaluate energy saving alternatives and calculate return on investment
3. Approve funds/budget for chosen solution
4. Implement the solution and realize reductions
5. Conduct regular review on the action plan to check progress
o In addition to reporting energy efficiency actions, you can also report actions which
Do not include actions for
contribute to GHG reduction. For example, if your facility has switched to lower
GHG reduction
carbon energy sources or has taken other measures to reduce GHG emissions
besides reducing energy use, you can also report in your action plan.
Section 2: Energy & GHG
Question and Guidance Common Mistakes
6. Has your facility improved energy consumption compared with its baseline in
the last calendar year?
If yes, select all sources of energy that have been improved.
• Source • Has your facility improved energy consumption for this source compared
with its baseline? • Select a baseline year • Indicate your facility’s change in energy use
from this source (quantity, unit of measure, Percent Change) • Is this normalized or
absolute? • Describe the strategies used to achieve this improvement
o You will receive full points if you made reductions in the last calendar year for energy
sources that make up 80% or more of your total energy use.
o You will receive partial points if you made reductions in the last calendar year for energy
sources that make up 50-79% of your total energy use.
• Review the improvement data to ensure that the information is accurate.
• Enter the improvement quantity either as an absolute or normalized value. This is the year over
year change in energy use for the source. Make sure to enter a negative number for a reduction
and a positive number for an increase.
• If the appropriate units are not available, list the units in the “Describe the strategies used to
achieve this improvement:” field.
• Input the percent (%) change in the energy use of the source from the previous year. Make sure
to enter a negative percentage for a reduction and a positive percentage for increased usage.
• Do not report improvement that were not achieved in the FEM reporting year. Insufficient evidence
• Historical improvements achieved more than 1 year ago should not be reported.
Section 2: Energy & GHG

Question and Guidance Common Mistakes


7. Were your facility’s annual Scope 3 greenhouse gas (GHG) emissions
calculated during this reporting year?
Report your facility's annual Scope 3 GHG emissions in co2e here
Describe your Scope 3 calculation here
• GHG Protocol Corporate Value Chain (Scope 3) Standard allows companies to
assess the emission impact of its entire value chain.
• The Scope 3 standard focuses on the following:
• Upstream emissions which are indirect GHG emissions related to purchased or
acquired goods and services.
• Downstream emissions which are indirect GHG emissions related to sold goods
and services.
• The GHG Protocol Scope 3 Evaluator(http://www.ghgprotocol.org/scope-3-evaluator)
is a tool that can be used to help identify and estimate GHG emissions from Scope 3
Sources.
Section 2: Energy & GHG

Question and Guidance Common Mistakes


7. Were your facility’s annual Scope 3 greenhouse gas (GHG) emissions
calculated during this reporting year?
Report your facility's annual Scope 3 GHG emissions in co2e here
What are
Describe theScope
your upstream and downstream
3 calculation here sources in GHG Scope 3?
• GHG Protocol Corporate Value Chain (Scope 3) Standard allows companies to
assess the emission impact of its entire value chain.
• The Scope 3 standard focuses on the following:
• Upstream emissions which are indirect GHG emissions related to purchased or
acquired goods and services.
• Downstream emissions which are indirect GHG emissions related to sold goods
and services.
• The GHG Protocol Scope 3 Evaluator(http://www.ghgprotocol.org/scope-3-evaluator)
is a tool that can be used to help identify and estimate GHG emissions from Scope 3
Sources.
Section 2: Energy & GHG

Question and Guidance Common Mistakes


8. Has your facility set a Science-Based Target according to the SBTi?
o This question is not scored in both 2020 Higg FEM and 2021 Higg FEM reporting year.
Score may be applied in future reporting years.
If No, Is your facility preparing to set a Science-Based Target according to the SBTi?
o If your company has committed to the SBTi but has not yet established or submitted a
target for approval, or if your target is under review, you should answer Yes to the question.
• Formal commitment to the SBTi is required (e.g. submitting the commitment letter and paying the
applicable fees)
• Setting your company’s GHG target and having it validated and approved by the SBTi.
o More details can be found here: https://sciencebasedtargets.org/stepby-step-guide/

What is SBTi(Science Based Targets initiative)?


The Science-Based Target (SBTi) was initiated by CDP, WRI, WWF and UNGC.
It provide a clearly defined pathway for companies and financial institutions to reduce
greenhouse gas (GHG) emissions in line with what the latest climate science deems
necessary to meet the goals of the Paris Agreement, which is to limit the rise in global
average temperatures to below 2 degrees Celsius above pre-industrial levels by the
end of this century, and to pursue efforts to limit it to 1.5 degrees.
Section 3: Water Use
Question and Guidance Common Mistakes
Applicability Test
At the beginning of this section you will be asked to evaluate your water risk using either
the WRI Aqueduct Tool or the WWF Water Risk Filter.
o Facilities with high water use (more than 35m3 daily) and those located in
areas of high/very high water risk will be asked to complete the full Water
section to ensure appropriate water management.
o Facilities with low water use that are located in areas of low water risk will only
need to answer Level 1 questions.
The WRI Aqueduct Tool and the WWF Water Risk Filter are simple and similar tools to Choose low risk without
assess water scarcity risks. searching in the tool
• If using the WRI Aqueduct Tool go to the home page and select explore global water
risk maps and select Enter Address at the bottom of the screen to search using your
facility address. Facility should select default weighing scheme. “Low risk”, “Low to
medium risk” and “Medium to high risk” are defined as “Low risk” in FEM. “High risk”
and “Extremely high risk” are defined as “High risk” in FEM.
• If using WWF Water Risk Filter, scroll to your country and location, and look at the
color-coding of the map. This link locates the explanation about the WWF method
and on page 3 the risk rating and color-coding is explained.
Section 3: Water Use

Question and Guidance Common Mistakes


1. Select all water sources used by your facility
• Source • Does your facility track its water use from this source? • What quantity of water
from this source was used during the reporting year? • Unit of Measure • Which method was
used to track water use from this source? • What was the frequency of measurement?
• Map out business and operational processes to identify water sources,
areas/processes that consume water.
• Collect and track water use data:
o Use utility bills to determine the quantity of purchased water
o Determine methods to track water consumption from other applicable sources,
such as rainwater, recycled water, etc.
o Install sub-meters to track the amount of water used on-site.
o If estimation techniques are used to determine water use, the calculation
methodology should be clearly defined and be supported by verifiable data.
Section 3: Water Use
Question and Guidance Common Mistakes
2. Has your facility set baselines for water use?
If yes, select all water sources for which your facility has set a baseline.
• Is the baseline absolute or normalized? • What is the baseline quantity and unit of measure?
• Enter baseline year • How was your baseline calculated? • Was the baseline verified?
• Confirm the water usage data is stable, and sufficient to be used to determine a baseline. In the
Higg FEM, a baseline should generally comprise of a full calendar year’s data.
o Note: If your factory has undergone major structural or operational changes such as
acquisition or changes in product type, in general, you should establish or reset a baseline
after those changes have been completed.
• Determine if the baseline will be Absolute or Normalized (Normalized baselines are preferred)
• Verify the source data and normalizing metrics data is accurate.
o Water and production volume data from previous Higg FEM 3.0 verifications, internal or
external audits conducted by qualified personnel are acceptable sources of data verification.
• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen
normalizing metric 150,000 m3 per 1,000,000 pieces = 0.15m3/piece)
o Note: For water consumption that is not related to production, other normalizing metrics
should be used where appropriate (e.g. Domestic only water use can be normalized per
person)
Section 3: Water Use

Question and Guidance Common Mistakes


3. Does your facility know what facility processes or operations use the most
water? What are the highest water use factors at your facility?
• One way to start is to create a water audit template. This involves manually listing
out all equipment on site that uses water and then identifying through meters, quick
tests, or estimates how much water each item on the list uses. Once complete, like
items can be combined and totaled to enable comparing bathrooms to dye
equipment for instance. More details can be referred in “Guide”.
• Sites may want to invest in portable water meters to allow water measurement
readings throughout the facility. Both battery operated digital in-line meters as well
as non-invasive mount around the pipe ultrasonic meters are available.
Section 3: Water Use
Question and Guidance Common Mistakes
4. Has your facility set targets for reducing water use from any sources?
If yes, select all sources of water for which your facility has set a reduction target.
• Has your facility set a target for reducing water use from this source? • What is your target
for change in water use from this source? • Enter the target year • Is this a normalized or
absolute target? • Describe the measures planned to achieve this target
o You will receive Full Points if you set targets for water sources that make up 80% or more
of your total water use.
o You will receive Partial Points if you set targets for water sources that make up 50-79% of
your total water use.
• Targets can be long-term or short-term (Short-term = less than 3 years, Long-term = more than 3
years).
• Enter a negative percentage for a reduction target (e.g. -5 for a 5% reduction), and a positive
percentage for an increased usage target.
• A target can use absolute or normalized metrics to drive quantifiable improvements by a set date
compared to the baseline. For Higg FEM, reduction targets may be normalized to the annual
volume unit (selected in Site Info section: Annual volume unit) or another appropriate operational
metric. An example of a normalized target is cubic metres of water used for the production of one
kilogram of sellable product (m3 /kg).
• Provide sufficient details on how the target will be met in the “Describe the measures planned to
achieve this target:” field (e.g. Achieve a 5% reduction in normalized municipal domestic water
consumption per person by installing low flow fittings and self-closing taps on all taps in facility
lavatories).
Section 3: Water Use
Question and Guidance Common Mistakes
5. Does your facility have an implementation plan to improve water use?
o You will receive Full Points if water reduction plan listing specific projects, target
reductions, dates, and progress that covers 80% or more of total water use.
o You will receive partial points if water reduction plan listing specific projects,
target reductions, dates, and progress that covers totaling 50-79% of total
water use.
Steps for action should include:
1. Identification of water saving opportunities
2. Evaluate water saving alternatives, investment and return on investment (ROI)
3. Approve funds for chosen solution
4. Implement the solution and track reductions
5. Conduct regular review on the action plan to check progress
o Water savings opportunities can be identified by individual employees, water audits,
and water balances to name a few. Some simple saving alternatives are related to had maintenance but did not
maintenance such as fixing leaks. Other saving alternatives may be more complex take records
requiring changes to process or replacement of equipment/chemicals. More details
can be referred in “Guide”.
Section 3: Water Use
Question and Guidance Common Mistakes
6. Has your facility reduced water withdrawal for any sources, compared with
your baseline?
Select all water sources that have been reduced.
• Select baseline year • Indicate your facility’s change in water withdrawal from this source
(Quantity, Unit of Measure and Percentage change) • Describe the strategies used to achieve
this improvement
o You will receive Full Points if you made reductions in the last calendar year for water
sources that make up 80% or more of your total water withdrawals.
o You will receive Partial Points if you made reductions in the last calendar year for water
sources that make up 50-79% of your total water withdrawals.
• Review the reduction data to ensure that the information is accurate.
• Enter the improvement quantity either as an absolute or normalized value. This is the year over
year change in energy use for the source. Make sure to enter a negative number for a reduction
and a positive number for an increase.
• If the appropriate units are not available, list the units in the “Describe the strategies used to
achieve this improvement:” field.
• Input the percent (%) change in the water use of the source from the previous year. Make sure to
enter a negative percentage for a reduction and a positive percentage for increased usage.
• Do not report improvement that were not achieved in the FEM reporting year.
• Historical improvements achieved more than 1 year ago should not be reported.
Section 3: Water Use

Question and Guidance Common Mistakes


7. Has your facility implemented a water balance or another analysis to evaluate
the traceability of water intake vs. usage (i.e. which processes) and output (i.e. to
wastewater treatment plant)?
o Answer Partial Yes if you have completed a partial water balance but have an
action plan to complete all requirements.
A comprehensive water balance includes: Wrong water balance
• The incoming water in the facility: amount and water sources methodology adopted
• The quantity of water used during the production process
• The quantity of water recycled/reused in the facility
• The quality of wastewater generated
• The wastewater generated in the facility
• The volume of water discharged after the own treatment
• The frequency which the water balance is updated
o More details can be referred in “Guide”.
Section 3: Water Use

Question and Guidance Basic water balance takes Common Mistakes


into account the
7. Has your facility implemented a water balance or another analysisfacility property boundary and identifies all
to evaluate
Example
the traceability of basic
of water water
intake vs.balance water
usage (i.e. which processes) and coming
output (i.e.into
to the facility from external
wastewater treatment plant)? sources (includes on-site wells), and all water
leaving
o Answer Partial Yes if you have completed a partial water balance the facility
but have an from wastewater and sewer
action plan to complete all requirements. discharges.
A comprehensive water balance includes: In an ideal environment
Wrong watertherebalance
are no
• The incoming water in the facility: amount and water sources losses so influent – effluent =adopted
methodology 0. However,
• The quantity of water used during the production process in the practical situation, the difference
• The quantity of water recycled/reused in the facility between influent and effluent can hardly
• The quality of wastewater generated be zero. Difference is possibly result from
• The wastewater generated in the facility leakage, evaporation (intended or
• The volume of water discharged after the own treatment unintended), error of measurement (1-
• The frequency which the water balance is updated 10%), etc. Difference less than 15% of
o More details can be referred in “Guide”. total water use is normal.
More advanced water balances move the
boundary being looked at from a facility
property to a building boundary, manufacturing
process boundary, or even a tool/equipment
specific boundary.
Section 4: Wastewater
Question and Guidance Common Mistakes
Applicability Test
Does your facility generate industrial wastewater?
Does your facility have Zero Liquid Discharge? Misunderstanding on “ZLD”
Do you treat industrial and domestic wastewater together?
Where is your industrial/domestic/combined wastewater treated? Neglect the offsite CETP

What is Zero-liquid discharge (ZLD) ?


Zero-liquid discharge (ZLD) is a
treatment process that design for no
water leaves a facility in liquid form. At
a facility with on-site ZLD treatment
system, almost all wastewater is Wastewater
treated and recovered such that the categorization
only water discharged from the facility
exists by evaporation or as moisture
in the sludge from treatment plant
operations.
Non-
wastewater
Section 4: Wastewater
Question and Guidance Common Mistakes
1. Does your facility track its wastewater volume?(Industrial/Domestic/Combined)
• What was the total quantity of wastewater discharged from your facility in 2018? • Which Use intake quantity as
method was used to track wastewater volume? • What was the frequency of measurement? • discharge quantity directly
How many wastewater discharge points do you have? • Have you labelled all wastewater
discharge points? • Do you monitor all identified wastewater discharge points? • What was
the final discharge point for your facility’s wastewater? • Provide any additional comments
o Wastewater tracking should include both domestic and industrial wastewater where
applicable and include water that is either discharged, reclaimed/recycled or reused at your
site, that is generated from all manufacturing and/or commercial activities within your
facility.
• Map out facility areas and processes to identify where wastewater is generated and
discharged.
• Collect and track wastewater data:
o Install on-site meters or use metered invoices from off-site treatment facilities.
o If estimation techniques are used to determine the amount of wastewater
generated, the calculation methodology should be clearly defined and be
supported by verifiable data.
Section 4: Wastewater
Question and Guidance Common Mistakes
1. Does your facility track its wastewater volume?(Industrial/Domestic/Combined)
How
• What was the total quantity to estimatedischarged
of wastewater the quantity of your facility in 2018? • Which
from Use intake quantity as
domestic wastewater
method was used to track wastewater discharged?
volume? • What was the frequency of measurement? • discharge quantity directly
How many wastewater discharge points do you have? • Have you labelled all wastewater
discharge points? • Do you monitor all identified wastewater discharge points? • What was
the• final
If domestic point for your
dischargewastewater facility’s metering
discharge wastewater?data• Provide any
or actual discharge
additionaldata is not
comments
oavailable,
Wastewater tracking
factory should
could include
consider both domestic
estimating and industrial
wastewater wastewater
discharge basedwhere
on the
sites total water use, the estimated amount used for domestic purposes and at your
applicable and include water that is either discharged, reclaimed/recycled or reused
thensite, that isan
minus generated from
estimated all manufacturing
amount and/or(e.g.
due to losses commercial activitiesFor
evaporation). within your
example,
facility.
a site with domestic only wastewater who used 150m3 of municipal water per
• Map out facility areas and processes to identify where wastewater is generated and
month estimates that 10% of the water is lost due to evaporation and leaks
discharged.
would report 135m3 of wastewater discharged (150m3 – 10%).
• Collect and track wastewater data:
• Water use in a facility can also be estimated by number of persons, number and
o Install on-site meters or use metered invoices from off-site treatment facilities.
types of facilities, taps, toilets, shower, irrigation etc based on any available
o If estimation techniques are used to determine the amount of wastewater
local/regional data or manufacturer’s specifications (e.g. rated litres per flush for
generated, the calculation methodology should be clearly defined and be
toilet fixtures).
supported by verifiable data.
Note: If an estimation technique is used, this should be fully documented, applied
consistently and based on reasonable estimation factors that are derived from
relevant sources (e.g. manufacturer’s specifications, regional data on sewerage
volume per person/day, etc.)
Section 4: Wastewater
Question and Guidance Common Mistakes
(NEW). Does your facility have a mechanism to prevent wastewater from mixing
with storm water in the storm drain systems?
o This question is not scored in both 2020 Higg FEM and 2021 Higg FEM
reporting year. Score may be applied in future reporting years.
How to maintain the mechanism –
1) Code and label all the storm water and wastewater collection points and drainage
systems, and assign designated responsible department or person for regular
management
2) Develop a storm water and wastewater drainage map with the information of
location, uses, code and responsible person. Post the drainage map in a location where
it is accessible for most of the employees. Note: The facility’s wastewater collection and
storm water drainage system may be included on facility structural engineering/utility
drawings.
3) Provide training to all responsible persons on the different uses of each collection
system.
4) Regularly check (e.g. daily, monthly, etc) on all stormwater and wastewater collection
points and drainage systems to ensure there is no mixing or damage to the systems.
Section 4: Wastewater
Question and Guidance Common Mistakes
2. Do you have the name and contact information of the offsite wastewater
treatment plant?
3. Does your facility have a back-up plan if there is an emergency situation
related to wastewater?
• Does your facility have a process to contact appropriate government authorities or
agencies as legally required in case of accidental discharge?
• Does your facility provide training to all relevant employees regarding the backup plan?
• How many employees were trained? • How frequently do you train your employees?
• Select all strategies included in your facility's back-up plan for wastewater:
• Emergency Production Shutdown • Holding Tank • What is the size of your facility’s Incomplete backup plan
holding tank? • Secondary Treatment (biological and advanced chemical treatment—
excluding coagulation, flocculation, neutralization, clarification/sedimentation process)
• Discharge to Offsite Water Treatment Plant • Other Backup Process
• What is your facility’s wastewater treatment handling peak / max average capacity?
• 1) No pre-treatment in facility: facility has an additional holding tank which can hold the quantity Insufficient capacity of
of wastewater equal to one day’s production as a minimum. 2) Pre-treatment in facility: the facility
should have a larger collection tank with capacity to hold more than the volume of the
holding tank
wastewater generated currently, and it should additionally hold at least 1 day’s production volume
in addition to the existing volume or residence time.
• The facility will shut down the production until the situation is back to normal. However, this
response should be backed up by some kind of documented emergency response process rather
than stating simply that they will stop production.
Section 4: Wastewater

Question and Guidance Common Mistakes


(NEW). Can you confirm that there is no leaking or bypassing of wastewater?
o This question is not scored in both 2020 Higg FEM and 2021 Higg FEM
reporting year. Score may be applied in future reporting years.
4. Is hazardous sludge (chemical / industrial) disposed of properly?
Does your facility provide training to all relevant employees regarding the disposal
method of hazardous sludge?
• How many employees were trained? • How frequently do you train your employees?
How is your hazardous sludge disposed of?
• Hazardous Waste Treatment • Incinerated controlled conditions • Landfilled
• Open burning • Fuel Blended • Composted • Fertilizer (applied to land)
• Sludge should be properly disposed through authorized agent or facility should be
licensed by local pollution board to decompose it in premises.
• Chemicals should be handled and disposed of in accordance with MSDS section 13.
• In cases where the local government has classified the sludge under non-hazardous
waste then the test report of sludge analysis may not be necessary. However,
landfilling and open burning activity in-house may not be appropriate unless it is
clearly identified through sludge analysis that the sludge is non-hazardous in nature.
Section 4: Wastewater

Question and Guidance Common Mistakes


5. Is non-hazardous sludge disposed of properly? (Domestic wastewater only)
Does your facility provide training to all relevant employees regarding the disposal
method of non-hazardous sludge?
• How many employees were trained? • How frequently do you train your employees?
How is your non-hazardous sludge disposed of?
• Hazardous Waste Treatment • Incinerated controlled conditions • Landfilled
• Open burning • Fuel Blended • Composted • Fertilizer (applied to land)
• Sludge should be properly disposed through authorized agent or facility should be
licensed by local pollution board to decompose it in premises.
Section 4: Wastewater

Question and Guidance Common Mistakes


6. Does your facility treat wastewater using Septic before it is discharged?
Does your facility provide training to all relevant employees regarding the disposal
method of septic waste?
• How many employees were trained? • How frequently do you train your employees?
How does your site unload your septic tank once full?
• Describe where it is discharged • Describe how it is treated after discharge
• Please upload documentation if available
Do you have a plan to upgrade your septic tank to a more modern wastewater treatment
approach?
• Establish a process to ensure that septic wastewater is treated before it is
discharged.
• Appoint a responsible person to manage and monitor the septic wastewater.
• Contract with approved third party to unload the septic tank contents and keep the Do not keep the
disposal record/invoices. record/invoices
Section 4: Wastewater

Question and Guidance Common Mistakes


7. Are you reporting against a wastewater standard? Enter the testing result from
• ZDHC Wastewater Guideline • BSR • IPE • Customer/Brand legal monitoring report
• If other, please describe (excluding local law and regulations)
Have you tested and met all parameters specified in the standard?
Are your parameter results available on the standard's platform? (e.g. ZDHC Gateway or
IPE database)
If ZDHC Wastewater Guideline was selected: Does your test result also show no detection
of parameters in Table 2A-N Chemical Groups?
• Report all parameters for which you have found a detection / are over the limit from
the test reports generated from 3rd party approved laboratories during previous year
or in-house monitoring reports.
Section 4: Wastewater

Question and Guidance Common Mistakes


7. Are you reporting against a wastewater standard? Enter the testing result from
• ZDHC Wastewater Guideline
What are the common • BSR • IPE • Customer/Brand
indicators for wastewater? legal monitoring report
• If other, please describe (excluding local law and regulations)
Have you tested and met all parameters specified in the standard?
Are your parameter results available on the standard's platform? (e.g. ZDHC Gateway or
IPE database)
If ZDHC Wastewater Guideline was selected: Does your test result also show no detection
of parameters in Table 2A-N Chemical Groups?
Report all parameters for which you have found a detection / are over the limit from the
test reports generated from 3rd party approved laboratories during previous year or in-
house monitoring reports.
Section 4: Wastewater

Question and Guidance Common Mistakes


8. Have you requested wastewater quality test results from the offsite wastewater
treatment plant?
o If the offsite wastewater party treatment plant refused, your facility will get credit Do not keep records
for this question as long as you can provide proof of request and denial.
o If the 3rd party wastewater treatment plant posts their effluent online, the
factory can answer "Yes" to this question.
• If you requested results and found that the 3rd party wastewater treatment plant is
not in compliance with limits, please describe whether your facility has contributed to
the non-compliance. If yes, how has your facility resolved it?
Section 4: Wastewater

Question and Guidance Common Mistakes


9. Does your facility reuse and/or recycle process wastewater as process water
(closed loop)?
• Enter the percentage of wastewater treated and recycled back into your production
processes
• Answer Yes if you have wastewater treatment in place to reuse and/or recycle 50% or more Answer Yes but do not
of your production wastewater back into production processes.
o The reused and/or recycled water must be used in production processes - other uses
achieve 50% above
like irrigation, toilets are excluded.
• A facility which is treating the waste water using Reverse Osmosis (RO) and
nanofiltration technologies and reusing 80% of the waste water but the rejected
water from the membrane are being sent to offsite ETPs are not considered as ZLDs
as the TDS of the rejected water from the membrane technologies is considered
more hazardous than the usual waste water discharged.

What are water reuse and recycle?

Reuse: the wastewater from one process may still meet quality criteria for use in a
second process without additional treatment.
Recycle: a facility treats this wastewater (either chemically or biologically) to meet
quality specifications for another process in the facility.
Section 5: Air Emissions

Question and Guidance Common Mistakes


Applicability Test
1. Does your facility contain any of the following operations equipment?
● Boiler ○ If selected, tell us size:
■ Small: less than 50 MW ■ Medium: 50 MW - 300 MW ■ Large: more than 300 MW
● Generators ● Combustion Engines (e.g. gasoline powered pumps) ● Industrial Ovens (for
heating/drying/curing) ● Combustion Heating (Furnace) ad ventilation ● Refrigerant containing
device (other than air conditioning system) ● Air conditioning (Cooling) ● Other sources of known air
emissions from facility operations ● Other sources of volatile organic compounds (VOCs)

2. Does your facility conduct any of the following processes or use any of the following
substances?
• Yarn spinning or synthetic fiber manufacturing • Finishes (any mechanical or chemical process that
occurs after dying to affect the look, performance, or feel of the product) • Solvents
• Adhesives/cementing • Printing • Dyeing • Tenterframes or other heating process • Spot cleaners
• Sprayed chemicals or paints • Other sources of ozone depleting substances (ODSs)
Section 5: Air Emissions

Question and Guidance Common Mistakes


1. Do you track your air emissions from operations?
Select all sources of air emissions relevant to your facility's operations
• Source • Are there emissions from this source? • Do you track emissions from this source?
• What equipment is this source linked to? • What pollutants are found in this source?
• Are the pollutants regulated by a government agency? • If the pollutant is regulated by a
permit, is it in compliance with the permit? • If your facility is out of compliance, update the
action plan for the substance detected • If you cannot upload a copy, please describe the
action plan • If applicable, upload emissions test report(s). • Additional comments
• In the future version, Higg FEM will require detailed tracking and reporting of emissions
data. More details can be referred in “Guide”.
• An air inventory is needed for the facility to track and manage emissions and their Incomplete inventory
sources. This inventory should include emissions sources regulated by permit as
well as those not currently regulated.
• Regular review should be carried out to make sure the inventory is up-to-date.
• Example inventory: https://www.sumerra.com/wp-content/uploads/Air-Emissions-
Inventory.xls
Section 5: Air Emissions

Question and Guidance Common Mistakes


1. Do you track your air emissions from operations?
Select all sources of air emissions relevant to your facility's operations
• Source • Are there emissions from this source? • Do you track emissions from this source?
• What equipment is this source linked to? • What pollutants are found in this source?
• Are the pollutants regulated by a government agency? • If the pollutant is regulated by a
permit, is it in compliance with the permit? • If your facility is out of compliance, update the
action plan for the substance detected • If you cannot upload a copy, please describe the
action plan • If applicable, upload emissions test report(s). • Additional comments
• In the future version, Higg FEM will require detailed tracking and reporting of emissions
data. More details can be referred in “Guide”.
• An air inventory is needed for the facility to track and manage emissions and their Incomplete inventory
sources. This inventory should include emissions sources regulated by permit as
well as those not currently regulated.
• Regular review should be carried out to make sure the inventory is up-to-date.
• Example inventory: https://www.sumerra.com/wp-content/uploads/Air-Emissions-
Inventory.xls

What are the common pollutants in Air Emission?


Section 5: Air Emissions
Question and Guidance Common Mistakes
2. Do you track your air emissions from productions?
Select all sources of air emissions that result from production processes
• Processes • Are there emissions from this source? • Emissions source title • Do you track
emissions from this source? • What pollutants are found in this source? • Are the pollutants
regulated by a government agency? • If the pollutant is regulated by a permit, is it in
compliance with the permit? • If your facility is out of compliance, update the action plan for
the substance detected • If you cannot upload a copy, please describe the action plan • If
applicable, upload emissions test report(s). • Additional comments
• All process emissions should be tracked, regardless of if they are captured and Incomplete inventory
discharged in a stack/chimney. These may include non-point sources such as drying
rooms, or fugitive emissions such as outdoor dust.

What are Point Source Emissions and Non-Point/Fugitive Source Emissions?


● Point Source Emissions - air flow which is controlled in some way and released into
the atmosphere from a single source such as stack. These emissions can be facilities
related, such as emissions from boilers, or process related, such as exhaust systems
for volatile chemical use.
● Non-Point Source or Fugitive Emissions - for the Higg FEM, these sources of air
emissions are those that are released into the general indoor or outdoor environment.
These types of emissions are typically process related such as screen printing, spot
cleaning, dyeing, etc.).
Section 5: Air Emissions
Question and Guidance Common Mistakes
3. Did your facility add additional refrigerants to any existing equipment during
this reporting year?
Do you track refrigerant use/emissions?
If yes, select all refrigerants added to existing equipment
• Refrigerant • Quantity of refrigerant added to existing equipment in the this
reporting year • Unit of measure • What method was used to track emissions from
this source? • What is your plan for fixing this leak?
o ONLY answer NO if you did not add additional refrigerants to any existing
equipment in the reporting year. Full Point will be granted. Do not know for this
• Map out all facility equipment (production and operational equipment) to identify question, “No” will get score.
equipment that contain refrigerants.
• Track how much refrigerant is released (e.g. through leaks, disposal, etc).
o In general, the amount of refrigerant released is equal to the amount of No refrigerant adding record
Refrigerant that is added to the equipment
o Refrigerant purchase invoices, or service records may also be helpful in
determining quantities released.
o If estimation techniques are used, the calculation methodology should be clearly
defined and be supported by verifiable data.
Section 5: Air Emissions
Question and Guidance Common Mistakes
3. Did your facility add additional refrigerants to any existing equipment during
Whyreporting
this caring aboutyear? adding refrigerants?
DoHaving to addrefrigerant
you track refrigerantsuse/emissions?
to existing equipmentIf yes,indicates
select allthe system hasadded
refrigerants a leak.to
If
CFC-based
existing refrigerants are maintained in the building, you must reduce annual
equipment
• leakage
Refrigerantto 5% or lessofand
• Quantity reduce added
refrigerant the total leakageequipment
to existing over the remaining
in the this life of the year
reporting
• equipment
Unit of measure • What
to less thanmethod
30% ofwas used to track
its refrigerant emissions from this source? • What is
charge.
your
Theplan for fixing
leakage rate this leak? expressed as the percentage of a full charge that would
is typically
o ONLY
be lost in a 12-answer
monthNO if youHow
period. did to
notcalculate
add additional
it can berefrigerants
referred into“Guide”.
any existing Do not know for this
equipment in the reporting year. Full Point will be granted. question, “No” will get score.
• Map out all facility equipment (production and operational equipment) to identify
What are the
equipment thathazards of using refrigerants?
contain refrigerants.
• Refrigerants
Track how much are ozone depleting
refrigerant substances
is released that canleaks,
(e.g. through be harmful contributors
disposal, etc). to
No refrigerant adding record
GHG emissions
o In general, and climate change
the amount due toreleased
of refrigerant the relatively hightoglobal
is equal warming
the amount of
potentials (GWPs) common refrigerants
Refrigerant that is added to the equipment have. Refrigerants are often emitted through
equipment leaks, purchase
o Refrigerant servicing and disposal.
invoices, or service records may also be helpful in
If refrigerants are used on-site,
determining quantities released. solutions to phase out these gases should be
considered. One other
o If estimation solutionare
techniques is to use the
used, refrigerants
calculationwith lower globalshould
methodology warming be clearly
potentials
defined(GWP)
and besuch as HFO’s
supported in the applications
by verifiable data. of refrigerants, aerosol
propellants and foam blowing agents.
Section 5: Air Emissions

Question and Guidance Common Mistakes


4. Does your facility have control devices or abatement processes for on-site
point source air emissions?
If yes, select all point sources of air emissions that have control devices or abatement
processes.
• Source • Do you have control devices/abatement process for this source?
• What control device, abatement process, or safety equipment was used for this source
of air emissions? • What was the frequency of monitoring?
o The effectiveness and efficiency of your control devices is typically evidenced through Answer “Yes” without
monitoring/testing data. Therefore in the case that no regular monitoring is conducted, monitoring
facilities should answer No to this question.
• This question primarily applies to point source/stack emissions. For example, this
may include boilers from facilities, or other stacks from process exhausts. Controls
on these emissions may include dust collectors, scrubbers, incinerators, etc.
• Monitoring and maintenance of control and abatement devices should be included in
your factory’s preventative maintenance program and in the checklists for ongoing
visual inspections so that any problems can be identified promptly.
Section 5: Air Emissions

Question and Guidance Common Mistakes


5. Does your facility have control devices or abatement processes for on-site
fugitive/non-point source air emissions?
If yes, select all fugitive/non-point sources of air emissions that have control devices
or abatement processes.
• Source • Do you have control devices/abatement process for this source?
• What control device, abatement process, or safety equipment was used for this
source of air emissions? • What was the frequency of monitoring?
• This question primarily applies to any non-point sources that generate emissions,
and may impact both indoor air quality and the environment.
• Monitoring and maintenance of control and abatement devices shall be included in
your factory’s preventative maintenance program and also in the checklists for
ongoing visual inspections and other required testing so that any problems could
be identified promptly.

What kind of controls might be for non-point source emissions?


Controls for these emissions may include fume hoods or local exhaust ventilation
with additional control devices or abatement processes, solvent recovery systems,
adsorption devices, or filters/bag houses capturing the dust / flock etc.
Section 5: Air Emissions

Question and Guidance Common Mistakes


6. Has your facility gone beyond permit requirements to achieve a higher level of
air performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx), and Particulate Misunderstood as Legal
Matter (PM)? limit’s requirements.
If yes, specify the level.
o Higg FEM encourages air emissions performance that goes beyond
compliance. However, there is not currently an air standard that exists for the
apparel, footwear, and textiles industry.
• The Higg FEM Air section encourages you to reduce pollutant limits as far as
possible by setting three levels of limits for combustion devices (e.g., boilers and
generator) emitting Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate
Matter (PM).
Section 5: Air Emissions

Question and Guidance Common Mistakes


6. Has your facility gone beyond permit requirements to achieve a higher level of
air performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx), and Particulate Misunderstood as Legal
Matter (PM)? limit’s requirements.
If yes, specify the level.
o Higg FEM encourages air emissions performance that goes beyond
compliance. However, there is not currently an air standard that exists for the
apparel, footwear, and textiles industry.
• The Higg FEM Air section encourages you to reduce pollutant limits as far as
possible by setting three levels of limits for combustion devices (e.g., boilers and
generator) emitting Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate
Matter (PM).

There are Air Standard for Boilers and


Generators in the Higg FEM:
Section 5: Air Emissions

Question and Guidance Common Mistakes


7. Do you have a process for implementing modernized equipment to reduce or
eliminate air emissions and indoor air quality issues at your facility?
o Modernizing machinery means retrofitting existing machinery with newer
technologies or purchasing new equipment with more advanced technologies
for controlling air emissions.
• One example of modernizing machinery is to upgrade refrigeration and/or air
conditioning systems so that they may use refrigerants with lower GWP or
substituting ODS with more environmental friendly refrigerants.
• Another example is the procurement of a new boiler or generator powered by
cleaner fuels and thus results in less air emissions.
Section 6: Waste
Question and Guidance Common Mistakes
1. Which non-hazardous waste streams does your site produce?
Select all that apply:
• Material • Metal • Plastic • Paper • Cans • Food • Glass • Cartons • Wastewater Treatment
Sludge (Non-Hazardous) • Other (please specify) • All domestic waste combined
Do you track your non-hazardous waste streams?
• Do you track this source? • Description • Quantity • Unit of Measure • Which method was
used to track this waste source? • How was this waste disposed of? • Describe your waste
management and disposal processes for this source:
• Map out business and operational processes to identify where waste is being
generated and all the type of wastes that are generated.
• Collect and track waste data:
o Use on-site scales, waste invoices/manifests, receipts for waste materials that
are sold, etc. to determine the amount of waste generated.
o If estimation techniques are used, the calculation methodology should be clearly
defined and be supported by verifiable data.

What should be considered when estimating waste quantities?


In some cases, calculating waste quantity requires estimation. Estimation requires a
documented methodology that includes: ● Calculations and methodology ● Date used
you calculated the estimate ● Frequency of updates to calculations and methodology
More details can be referred in “Guide”.
Section 6: Waste
Question and Guidance Common Mistakes
1. Which non-hazardous waste streams does your site produce?
What are the
Select main
all that disposal methods for waste?
apply:
•● Recycle:
Material undergoes
• Metal • Plasticprocessing,
• Paper • Cans or •change in physical
Food • Glass form,
• Cartons to be madeTreatment
• Wastewater into another
component
Sludge or product.• Other (please specify) • All domestic waste combined
(Non-Hazardous)
● Reuse:
Do youusedtrackinyour non-hazardous
its current waste streams?
form, multiple times, typically for the same purpose. For
• example:
Do you track this source? • Description • Quantity • Unit of Measure
fabric scraps being reprocessed for padding/stuffing • Which
used method was
for furniture,
used to track this waste source? • How was this waste disposed of? • Describe your waste
mattresses, blankets, toys
management and disposal processes for this source:
● Incinerated with energy recovery: the process of generating energy in the form of
• Map out business and operational processes to identify where waste is being
electricity or heat from the incineration of waste.
generated and all the type of wastes that are generated.
● Biological treatment: usually used for food waste disposal. The common treatments
• Collect and track waste data:
are Anaerobic digestion, biofuel and composting.
o Use on-site scales, waste invoices/manifests, receipts for waste materials that
● Incineration: materials that are collected and managed through an incineration
are sold, etc. to determine the amount of waste generated.
process that meets local and international standards.
o If estimation techniques are used, the calculation methodology should be clearly
● Landfill: materials that are collected and managed through a landfilling process that
defined and be supported by verifiable data.
meets local and international standards.
● Upcycle:
What shouldUpcycling is the when
be considered process of transforming
estimating by-products, waste materials,
waste quantities?
useless
In some and/or
cases, unwanted
calculatingproducts into new
waste quantity materials
requires or products
estimation. of betterrequires
Estimation quality or
a for
better environmental
documented methodology value.that
Recycling
includes: used garments and
● Calculations andfabrics to manufacture
methodology new
● Date used
clothing,
you making
calculated thefabric from ●used
estimate plastic bottles,
Frequency andtoprocessing
of updates calculationscoal
andash from the
methodology
boilerdetails
More room to canmake bricks are
be referred some examples of upcycling.
in “Guide”.
Section 6: Waste

Question and Guidance Common Mistakes


2. Which hazardous waste streams does your site produce?
Select all that apply:
Production Waste:
• Empty chemical drums and containers • Film and Printing Frame • Wastewater treatment
sludge (Hazardous) • Expired / unused / used chemicals (waste oil, solvents, reactants, etc.…)
• Compressed Gas Cylinders (refrigerants, etc.) • Contaminated materials (please specify)
Distinguish “waste oil” of
• Other (please specify) • New Guidance for Hardgoods facilities: enter (e.g. Metal sludge, production waste with
Waste oil and grease (from operations and manufacturing), Disposal of coolant, etc.) “waste oil and grease” of
Domestic Waste: domestic waste
• Batteries • Fluorescent light bulb • Ink cartridges • Waste oil and grease (from cooking)
• Empty containers (cleaning, sanitizing, pesticides, etc...) • Electronic Waste • Coal Distinguish “Empty chemical
combustion residuals (fly ash and bottom ash/coal slag) • Wastewater treatment sludge drums and containers” of
(household) • Other (please specify)
Do you track your hazardous waste streams?
production waste with
• Do you track this source? • Description • Quantity • Unit of Measure • Which method was “Empty containers” of
used to track this waste source? • How was this waste disposed of? • Describe your waste domestic waste.
management and disposal processes for this source:
• To identify your hazardous waste, each country has its own National Hazardous
Waste Inventory and National Hazardous Waste Identification Standard. Please refer
to these standards and inventory.
Section 6: Waste

Question and Guidance Common Mistakes


2. Which hazardous waste streams does your site produce?
Select all that apply:
Production Waste:
• What
Emptyare hazardous
chemical drums waste and non-hazardous
and containers waste? Frame • Wastewater treatment
• Film and Printing
• Hazardous
sludge (Hazardous) • Expired
waste: waste/ unused / used
that could causechemicals
harm to (waste
publicoil, solvents,
health reactants,
and/or the etc.…)
• Compressed Gasbecause
Cylindersof(refrigerants,
Distinguish “waste oil” of
environment its chemical,etc.) • Contaminated
physical, materials
or biological (please specify)
characteristics (e.g., it
• Other (please specify) • New Guidance for Hardgoods facilities: enter (e.g. Metal sludge, production waste with
is flammable, explosive, toxic, radioactive, or infectious).
Waste oil and grease (from operations and manufacturing), Disposal of coolant, etc.) “waste oil and grease” of
• Non-hazardous waste: all the other wastes beyond hazardous wastes.
Domestic Waste: domestic waste
• Batteries • Fluorescent light bulb • Ink cartridges • Waste oil and grease (from cooking)
• Empty containers (cleaning, sanitizing, pesticides, etc...) • Electronic Waste • Coal Distinguish “Empty chemical
How to estimate
combustion residualsthe(fly
weight of drums/barrels?
ash and bottom ash/coal slag) • Wastewater treatment sludge drums and containers” of
If you have• Other
(household) disposed of empty
(please drums, please enter the total weight of all drums in
specify)
production waste with
kilograms
Do youor metric
track yourtons. For example,
hazardous if you disposed of 25 empty steel drums that
waste streams?
• Do • Description • Quantity • Unitcontainers” • Which “Empty containers” of
weighed 20 kilograms
you track this source? each, please choose “Empty of Measure and enter 500 was
method
domestic waste.
used to track(25
kilograms thisdrums 20 kgs •=How
waste xsource? 500was
kgsthis waste disposed of? • Describe your waste
total).
management and disposal processes for this source:
If you have disposed of full drums that contain liquid waste, please enter the volume
• To identify your hazardous waste, each country has its own National Hazardous
of the drum (cubic feet, cubic yard, gallons, meters) or the total weight (kg or metric
Waste Inventory and National Hazardous Waste Identification Standard. Please refer
tons).
to these standards and inventory.
Section 6: Waste

Question and Guidance Common Mistakes


3. Does your facility segregate all waste streams into non-hazardous and
hazardous waste, and store them separately?
• The first step is to make sure that legal requirements in relation to waste generation,
collection and segregation, storage, transportation, treatment and disposal are met.
• There should be procedures for the management (including collection, segregation,
storage and transportation) of hazardous and non-hazardous waste.
• The facility should provide sufficient working instruction or standard operating
procedures and signs for handling and segregating non-hazardous waste.
• Personal protective equipment (PPE) should be provided to employees when
handling waste. Instruction should be provided.
Section 6: Waste

Question and Guidance Common Mistakes


4. Does your facility have well-marked, designated hazardous waste storage
areas and containers?
Hazardous waste storage area requirements:
• The hazardous waste storage area is ventilated, dry and protected from the weather and fire
risk. • The hazardous waste storage area is protected from unauthorized employees (i.e.
locked). • Eating, smoking and drinking are not permitted in these areas. • The hazardous
waste storage area is clearly marked. • Where liquid wastes are stored, the floor is solid and
non-porous, containers have lids, there are no water drains that the liquid could spill into, and
there is no evidence of spilled liquid. • Flammable substances are kept away from sources of
heat or ignition, including the use of grounding and explosion-proof lighting. • Incompatible
waste must be segregated. • Spill response equipment including necessary personal
protective equipment (PPE) must be located near storage areas including accessible
emergency eyewash and/or shower stations. • Employees must use appropriate personal
protective equipment (PPE) when in these areas.
Hazardous waste storage container requirements:
• Storage containers are in good condition, appropriate for their contents, closed and clearly
labeled with their contents. • Containers must have lids • Containers must be secured to
prevent falling and safely stacked • Adequate aisle space must be maintained between
containers
Section 6: Waste

Question and Guidance Common Mistakes


5. Does your facility have well-marked, designated non-hazardous waste storage
areas and containers?
Non-Hazardous waste storage area requirements:
• The non-hazardous waste storage area is ventilated, dry and protected from the weather and
fire risk, and must be stored on impervious surfaces. • The non-hazardous waste storage area
is clearly marked. • Flammable substances are kept away from sources of heat or ignition,
including the use of grounding and explosion-proof lighting. • Employees must use
appropriate personal protective equipment (PPE) when in these areas.
Non-Hazardous waste storage container requirements:
• Storage containers are in good condition, appropriate for their contents, closed and clearly
labeled with their contents. • Containers must be secured to prevent falling and safely
stacked.
Section 6: Waste

Question and Guidance Common Mistakes


6. Does your facility forbid all irresponsible waste disposal actions including
open burning, open dumping, burying and storage tank leaks?
• Burning and dumping waste on facility premises (inside or outside) with no air
emissions control equipment and without special authorization from your
environmental legal agency should be forbidden.
• Any uncontrolled waste landfilling (i.e. landfilling without the appropriate license/
permit) should be forbidden.
Section 6: Waste

Question and Guidance Common Mistakes


7. Does your site provide training to all employees whose work involves
hazardous waste handling (such as maintenance and custodial staff)?
If yes, please select all topics included in your training: Do not cover all topics
• Proper handling • Storage and disposal techniques and procedures • Specific
operational procedures for waste minimization • Use of personal protective equipment
• Other, please specify
How many employees were trained?
How frequently do you train your employees?
Section 6: Waste
Question and Guidance Common Mistakes
8. Has your facility set a baseline for solid waste?
If yes, select all sources of waste for which your facility has set a baseline
● Source of Waste ● Is the baseline absolute or normalized? ● What is the baseline quantity?
● Unit of Measure ● Enter the baseline year ● How was your baseline calculated? ● Was the
baseline verified?
• Confirm the waste source data is stable, and sufficient to be used to determine a baseline. In the
Higg FEM, a baseline should generally comprise of a full calendar year’s data.
o Note: If your factory has undergone major structural or operational changes such as
acquisition or changes in product type, in general, you should establish or reset a baseline
after those changes have been completed.
• Determine if the baseline will be Absolute or Normalized (Normalized baselines are preferred)
• Verify the source data and normalizing metrics data is accurate.
o Waste quantities and production volume data from previous Higg FEM 3.0 verifications,
internal or external audits conducted by qualified personnel are acceptable sources of data
verification.
• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen
normalizing metric 1,500,000 kg per 1,000,000 pieces = 1.5kg/piece)
o Note: For waste sources that is not related to production, other normalizing metrics should be
used where appropriate (e.g. food or other domestic wastes can be normalized per meal
served or per worker)
Section 6: Waste
Question and Guidance Common Mistakes
9. Did you set a baseline for waste disposal methods for your facility's overall
waste?
If yes, indicate which methods:
● Disposal method ● What is the baseline quantity? (Enter a Percentage %) ● Enter the
baseline year ● How was your baseline calculated? ● Was the baseline verified?
• Confirm the waste source data is stable, and sufficient to be used to determine a baseline. In the
Higg FEM, a baseline should generally comprise of a full calendar year’s data.
o Note: If your factory has undergone major structural or operational changes such as
acquisition or changes in product type, in general, you should establish or reset a baseline
after those changes have been completed.
• Calculate the total amount of waste generated at the facility (from all sources) including hazardous
and non-hazardous sources.
• Calculate the total amount of wastes being disposed of using a particular disposal method (e.g.
landfill, recycling. Incineration)
• Divide the total amount of waste disposed of using the same method by the total amount of waste
generated. For example:
o Total waste generated from all sources: 460,555 kg per year
o Total amount of waste recycled (all relevant sources): 255,000kg/year
o Baseline for recycled waste: 55.3% (255,000kg/460,555kg)
Section 6: Waste
Question and Guidance Common Mistakes
10. Does your facility set formal targets to reduce waste quantity?
● Select all sources of waste for which your facility has set a quantity or improvement target.
● What is your target change for waste generated from this source?
● What is the target year? ● Describe the measures planned to achieve this target
o You will receive Full Points if you set targets for waste quantity that make up 80% or more
of your total waste generated.
o You will receive Partial Points if you set targets for waste quantities that make up 50-79%
of your total waste generated.
• Targets can be long-term or short-term (Short-term = less than 3 years, Long-term = more than 3
years).
• Enter a negative percentage for a reduction target (e.g. -5 for a 5% reduction), and a positive
percentage for an increased usage target.
• A target can use absolute or normalized metrics to drive quantifiable improvements by a set date
compared to the baseline. For Higg FEM, reduction targets may be normalized to the annual
volume unit (selected in Site Info section: Annual volume unit) or another appropriate operational
metric. An example of a normalized target is kilograms (kg) of a waste generated for the
production of one unit of sellable product (kg/unit).
• Provide sufficient details on how the target will be met in the “Describe the measures planned to
achieve this target:” field (e.g. Achieve a 3% reduction in normalized cardboard waste generated
by switching to reusable cartons for raw material deliveries).
Section 6: Waste
Question and Guidance Common Mistakes
11. Did you set a target for improving waste disposal methods for your facility's
overall waste?
If yes, indicate which methods.
• Waste disposal method • What is your target change for this method of disposal?
• What is the target year? • Describe the measures planned to achieve this target
• Targets can be long-term or short-term (Short-term = less than 3 years, Long-term = more than 3
years).
• Examples of improvements to disposal methods can include:
• Increase quantity of waste sent to external recycling contractors and biological treatment
(such as non-hazardous production waste recycling and food waste biological treatment) to
divert waste from landfill or incineration without energy recovery.
• Switch to a disposal/treatment method that recovers usable aspects of the waste (e.g., using
incineration with energy recovery as opposed to landfilling)

What are the best ways to disposal wastes?

The following hierarchy can be used (1 being the most preferred option).
1. Waste Source Reduction & Reuse/Upcycle
2. Recycle
3. Energy/Material Recovery (e.g. Incineration with energy recovery)
4. Other Treatment (e.g. Biological treatment, Incinerated without energy recovery)
5. Landfill
Section 6: Waste

Question and Guidance Common Mistakes


12. Does your facility have an implementation plan to reduce waste quantity or
improve type of treatment?
Steps for action should include:
1. Identification of waste improvement opportunities
2. Evaluate waste management alternatives
3. Prioritize the improvement items and with the progressive timelines
4. Approve funds for chosen solution
5. Implement the solution and document reductions
6. Assign a team/staffs to track and monitor the progress
7. Conduct regular review to check progress of improvement projects
Section 6: Waste

Question and Guidance Common Mistakes


13. Has your facility reduced waste quantity or improve type of treatment in this
reporting year, compared with the established baseline?
• Select all sources of waste for which your facility made improvements
• Select baseline year • Quantity • Unit of Measure • Percent Change
• Describe the strategies used to achieve this improvement.
o You will receive Full Points if you made reductions for waste sources that make up 80% or
more of your total waste generated.
o You will receive Partial Points if you made reductions for waste sources that make up 50-
79% of your total waste generated.
• Review the reduction data to ensure that the information is accurate.
• Enter the improvement quantity either as an absolute or normalized value. This is the year over
year change in energy use for the source. Make sure to enter a negative number for a reduction
and a positive number for an increase.
• If the appropriate units are not available, list the units in the “Describe the strategies used to
achieve this improvement:” field.
• Input the percent (%) change in the water use of the source from the previous year. Make sure to
enter a negative percentage for a reduction and a positive percentage for increased usage.
• Do not report improvement that were not achieved in the FEM reporting year.
• Historical improvements achieved more than 1 year ago should not be reported.
Note: Facility construction and demolition (C&D) waste should not be included in the baseline and
reduction performance.
Section 6: Waste

Question and Guidance Common Mistakes


14. Has your facility improved waste disposal methods for overall waste in this
reporting year, compared with the baseline?
If yes, indicate which methods.
• Select baseline year • What was the percentage change?
• Describe the strategies used to achieve this improvement
• Review the reduction data to ensure that the information is accurate.
• Input the percent (%) change in the water use of the source from the previous year. Make sure to
enter a negative percentage for a reduction and a positive percentage for increased usage.
• Provide sufficient details in the “Describe the strategies used to achieve this improvement:” field
(e.g. both fabric and leather waste are now being sent to material recycler instead of landfill).
• Do not report improvement that were not achieved in the FEM reporting year.
• Historical improvements achieved more than 1 year ago should not be reported.
Section 6: Waste
Question and Guidance Common Mistakes
15. Does your facility validate the final disposal and treatment of all hazardous
wastes?
If yes, please upload the supporting documentation.
Describe how you work with your facility’s waste contractors to ensure
appropriate disposal during the waste treatment.
• Facilities should screen, validate and check contractors every three years.
• When evaluating waste management contractor, consider:
● Waste contractor qualifications (such as business license, environment permits, reports) of
the contractor.
● Waste contractor due diligence and legal environment performance (any historic violations)
● Their overall environmental performance
● Cost viability of using the contractor’s services (GSCP)
• Conduct regular assessments after the contract is placed. Things to look for:
● Implement practices to transport waste in a way that is traceable, secure, and waste must
remain segregated and properly labeled at all times
● Have a facility with impermeable surfaces, proper security, and fire/flood protection
● Not engage in illegal dumping or burning either on or off-site
● Implement human health and safety practices such as providing employee access to
personal protective equipment, training, and machine safety
● If they use optimized waste disposal methods (such as recycling hazardous waste or
incinerate hazardous waste with energy recovery) to reduce the impacts to the environment.
Section 6: Waste
Question and Guidance Common Mistakes
16. Has your factory diverted at least 90 percent of all discarded materials from
landfills, incinerators and the environment?
If yes, please upload the supporting documentation.
Please describe how this is implemented.
o Zero waste to landfill is defined as diverting 90% or more of all discarded materials away
from landfills, incinerators and the environment (UL 2799 Zero Waste to Landfill).
17. Does your facility upcycle some of its waste or insert its waste into a circular
economy system?
If yes, please describe how.
• The four aspects of a closed-loop supply chain:
• Source: Use recycled or renewable materials that are responsibly sourced.
• Make efficiently: Design and manufacture products to minimize the use of materials.
• Use for a long time: Design products to be durable, so they can have long lives.
• Contribute: Replenish market supply with an amount of recycled, reclaimed, or renewable
material at least equal to the amount used to make the product.

What is circular economy and linear economy?


Circular economy: a regenerative system in which resource input and waste,
emissions, and energy leakages are minimized by slowing, closing, and narrowing
energy and material loops; this can be achieved through long-lasting design,
maintenance, repair, reuse, remanufacturing, refurbishing, recycling, and upcycling.
Linear economy: a 'take, make, dispose' model of production.
Section 7: Chemical Management

Question and Guidance Common Mistakes


Applicability Test
Select all of the processes performed at your facility:
• Dyeing or other wet processing • Printing • Laundry or washing • Cementing or gluing • Fiber
extrusion or yarn spinning • Slashing during weaving • Leather tanning • Lamination • Extrusion,
assembly, finishing of plastic parts • Metal Finishing (with Chemical use) • Welding • Casting (with
Chemical use) • Degreasing with organic solvents • Painting • Powder Coating (for non-metal use)
• Soldering • Printed Circuit Board electronic automation (with Chemical use) • Other production
processes that require chemicals
o If any are selected, you are a facility that uses chemicals in production processes.
o If none are selected, you are a facility that uses chemicals in facility tooling and/or
operations only
Section 7: Chemical Management
Question and Guidance Common Mistakes
1. Does your facility keep an inventory of chemicals used and the suppliers of
each chemical product?
1a. Check all types of chemicals included in the inventory
● All chemicals used in manufacturing processes (including chemicals in production,
reactants and additives, and wastewater treatment plant chemicals where applicable) ● All Neglect chemicals used in
chemicals used in tooling/equipment (spot cleaners, lubricants and grease) ● All chemicals
used to operate and maintain the facility (aside from WWT which is captured above)
tooling/equipment or
1b. Does your facility's chemical inventory include chemical identification data? Check operation/maintenance
all that apply:
• Chemical name and type • Supplier/vendor name and type • Presence of Safety Data Sheet
(SDS or MSDS) – should include availability and date of issuance • Function • Hazard
classification • Where the chemical is used • Storage conditions and location • Quantities of
chemicals used
1c. Does your facility’s chemical inventory include the following data?
Select all that apply: • CAS number or numbers (when in a mixture) • Lot numbers • MRSL
compliance • Purchase date • Chemical Expiration dates (if applicable)
For data not included in your facility’s chemical inventory, is there an action plan for
obtaining this data?
There could be two different approaches a facility can adopt.
1. maintain the chemical inventory which gets updated monthly.
2. maintain stock data to capture the lot numbers of all incoming chemicals and another sheet
for chemical information log capturing the hazardous information. In the case where there is a
possibility of frequent purchase of chemicals, the second option is required.
ZDHC CIL Template: https://www.roadmaptozero.com/documents
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


Chemical Inventory covers all chemicals used for manufacturing, Same as left.
tooling/equipment, operation and maintenance.
Facility can provide a full year’s list of purchased chemicals and all chemicals Same as left.
purchased are inventoried.
A chemical inventory exists with the minimum information that include Same as left.
Chemical identification data (1b) and Additional data (1c).
Chemical inventory needs to record the usage quantity information and the Nil
quantity needs to be updated at least monthly
A real time tracking system (electronic or manual) needs to be in place at the Nil
storage/warehouse, production, and temporary storage areas to track usage
quantity and amount (in/out log) of chemical
Facility-wide balance check of chemicals (purchased, used) should be Nil
monitored at least every 6 months
The chemical inventory is updated whenever a new chemical is purchased. A Same as left.
new chemical addition initiates a worker training, PPE, review of any hazard
and storage requirements including secondary containment, emergency
planning, and disposal requirements.
New chemicals are not moved into stock or storage until verification takes Same as left.
place: matched to P.O, added into chemical inventory list, CAS no. screened
against MRSL, acceptable for use, assigned to proper storage as per its
hazard class and compatibility, and properly labeled.
Section 7: Chemical Management
Question and Guidance Common Mistakes
2. Does your facility make Safety Data Sheets (SDS) available to employees for all
chemicals used?
Are Safety Data Sheets posted where hazardous chemicals are stored?
Are Safety Data Sheets available in languages workers understand (at least sections
directly related to operational worker safety and storage requirements, such as first aid,
hazard, and flammability information)?
o Safety Data Sheets must be Global Harmonization System (GHS) compliant or equivalent.
SDS is not GHS compliant
• All information provided in all the sections of SDS should be evaluated and checked for the or equivalent
hazard identification and chemical composition information details appropriately.
• Labelling on chemicals boxes and the information declared in the SDS should be correlated and
verified. The labels for all incoming chemicals should be verified and they should be original and
compliant to GHS, CLP or country specific regulations.
• In cases where certain tooling / cleaning chemicals do not have appropriate GHS compliant /
equivalent SDS, look for the label on the product which should provide details of ingredients and
hazard symbols on the label.
• In cases, where appropriate label or SDS is not available, facility should try to obtain as much
information about the chemical as possible.

What is Global Harmonization System (GHS)?


GHS stands for the Globally Harmonized System of Classification and Labelling of
Chemicals (full name). It is a system of hazard communication for chemical hazards
that can be adopted by countries around the world. GHS was developed by a United
Nations (UN) international team of hazard communication experts.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


Complete and updated MSDS/SDS (request updates to chemical supplier at Same as left.
least every 3 years) is available for all chemicals.
MSDS/Safety Data Sheets (SDS) are in language workers understand (at Same as left.
least sections directly related to operational worker safety and storage
requirements such as first aid, hazard, and flammability information).
Key hazard and safety information according to the MSDS/SDS are Same as left.
clearly/visibly displayed at each location designated to each specific
chemical.
MSDS/SDS are Global Harmonization System (GHS) compliant (or MSDS/SDS are Global Harmonization System (GHS) compliant (or
equivalent). equivalent), where applicable i.e. bulk chemicals: oil and lubricants, ETP
chemicals, etc. MSDS/SDS in other formats (non GHS format e.g. product
instruction manual) may be acceptable for chemicals in small quantities i.e.
spot cleaners, spray grease, etc., as long as it has all necessary information,
such as: chemical product information and composition, ...
MSDS/SDS are shared with emergency response team internally and Same as left.
externally so adequate preparation for emergencies are planned.
Workers (including but not limited to: chemical operations and hazardous Same as left.
waste handling) are trained in how to read and understand MSDS/SDS for
personal safety, hygiene, and proper handling of chemicals to which they are
exposed and how to properly dispose when necessary.
Chemical storage areas are properly segregated by physical barriers, by Nil
hazard class, and/or CLP label, with appropriate signage at the entrance and
with storage and workplace and these spaces have appropriate restricted
access.
Section 7: Chemical Management

Question and Guidance Common Mistakes


3. Does your facility train all employees who use chemicals on chemical hazards,
risk, proper handling, and what to do in case of emergency or spill?
If yes, select all topics included in your training:
• chemical hazards and identification • MSDS/SDS • signage • compatibility and risk • proper
storage and handling • personal protective equipment (PPE) and procedure in case of
emergency, accidents, or spill • access restriction to chemical storage areas • potential
environmental impact of the chemicals in tanks • the physical protection provided to
employees in the area(s) where the factory uses, stores and transports these containers
• and their individual duties associated with monitoring and maintaining this protection.
How many employees were trained?
How frequently do you train your employees?
● Trainings held regularly (at least quarterly or in a frequency that allows training all new employees
according to the turnover rate) delivered by competent personnel and are documented.
● All workers responsible for chemical related operations have attended the training.
Section 7: Chemical Management

Question and Guidance Common Mistakes


4. Does your facility have a chemical spill and emergency response plan that is
practiced periodically?
How many employees were trained on this topic?
How frequently do you train your employees on this topic?
Does your facility keep records of all employee and environmental incidents related to
chemical spills and emergency response?
• A written, up-to-date Emergency Response Plan for the facility (covering all workplaces) is
essential.
• Primary and secondary escape routes with simple instructions should be posted at significant
spots, at entrances and near elevators and telephones etc.
• Emergency Response Leaders should be assigned specific duties, such as verifying that all
workers have been evacuated.
• Disabled workers and those with a history of certain medical conditions should be assigned
an Emergency Response Leader to guide them to safety.
• Stairways should be kept free of materials that could block or hinder an evacuation process.
• Important telephone numbers such as emergency, fire department and internal Emergency
Response Leaders should be posted close to every telephone.
• Regular fire drills should be conducted to identify problems before an actual fire occurs and based
on these identified problematic areas, work a corrective and preventive action and implement them.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


Emergency response plan/procedure exists on paper containing the minimum Emergency response plan/procedure exists on paper containing the minimum
guidance provided by referencing the ZDHC Chemical Management System guidance provided by referencing the ZDHC Chemical Management System
Framework Version 1.0 (May 2020) – Chapter 4.3 and the steps to be taken Framework Version 1.0 (May 2020) – Chapter 4.3
to protect the environment if there is an accidental release of these
substances.
Practice/drill is conducted periodically (at least twice a year) and well Nil
documented
All workers are included in the practice/drill Nil
Section 7: Chemical Management

Question and Guidance Common Mistakes


5. Does your facility have appropriate and operable protective and safety
equipment, as recommended by the Global Harmonization System compliant (or
equivalent) Safety Data Sheet, in all areas where chemicals are stored and used?
o Protective and safety equipment: spill response kits (size, type and location
appropriately adapted for the chemical), showers and eyewash tested regularly,
fire extinguishers maintained regularly, adapted Personal Protective Equipment
(PPE) appropriate for the chemical (based on MSDS/SDS) such as appropriate
gloves, protective masks, long handle scoops, etc.
• PPE details are given in Section 8 of MSDS/SDS (ZDHC CMS Framework) and the
details need to be understood and followed appropriately. It is also important that the
PPEs are reviewed periodically and replaced when necessary. This evaluation is
based on the calculation of the time interval where the PPE is being exposed.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


A facility plan should detail the physical areas of the facility’s property Same as left.
involved in chemical storage and usage. The pictorial plan includes a quick
overview of the most critical areas.
Receiving and delivery Same as left.

Chemical storage areas (centralized warehouse and temporary Same as left.


storage areas)
Chemical process areas Same as left.

Manufacturing/production areas Same as left.

Waste chemicals storage (including chemical residues and expired Same as left.
chemicals)
Laboratories, tool shop, maintenance, etc. Same as left.

Protective and safety equipment are available on-site at all times and are Same as left.
strategically located to be easily accessible to workers at relevant areas
Protective and safety equipment are appropriate and in accordance with the Same as left.
Global Harmonization System (GHS) compliant (or equivalent) MSDS/SDS
for each chemical stored/used
Protective and safety equipment are well maintained and checked regularly Same as left.
for its functionality
Section 7: Chemical Management

Question and Guidance Common Mistakes


6. Does your facility have chemical hazard signage and safe handling equipment
in the areas of the facility where chemicals are used?
o The most critical areas for signage include: receiving and delivery, chemical storage areas
(centralized warehouse and temporary storage areas), chemical process areas,
manufacturing/production areas, waste chemicals storage (including chemical residues and
expired chemicals), and laboratories, tool shop, maintenance areas. Handling equipment
should be available at relevant locations and correspond with the safety requirement and
hazard communication/signage for each particular chemical.
• Chemical hazard signage should be displayed appropriately with respect to the
chemicals placed and as per the information given in MSDS/SDS Section 2 or
Section 3.
• The safe handling equipment such as, trolleys, containers must be maintained in
proper condition without any worn-out wheels, ungreased wheels or leakages.
Conduct thorough walk through and inspect the real scenario on shop floor.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


A facility plan should detail the physical areas of the facility’s property Same as left.
involved in chemical storage and usage. The pictorial plan includes a quick
overview of the most critical areas.
Receiving and delivery Same as left.

Chemical storage areas (centralized warehouse and temporary Same as left.


storage areas)
Chemical process areas Same as left.

Manufacturing/production areas Same as left.

Waste chemicals storage (including chemical residues and expired Same as left.
chemicals)
Laboratories, tool shop, maintenance, etc. Same as left.

Signage posted at the storage and chemical operations area depicts the Same as left.
hazard(s) classification of chemicals stored
Signage are clearly visible and understood by relevant employees/workers Same as left.
that are responsible for chemical usage
Handling equipment is available at relevant locations and corresponds with Nil
the safety requirement and hazard communication/signage for each particular
chemical
Section 7: Chemical Management

Question and Guidance Common Mistakes


7. Does your facility select and purchase chemicals based on their hazards and
MRSL / RSL requirements?
If yes, do all chemicals purchased and used in production meet the facility's chemical
purchasing policy?
If no, do you have a process or plan for eliminating chemicals that do not meet the
facility's chemical purchasing policy?
o Facilities typically are aware of Restricted Substance Lists (RSL); however, the
industry has recently evolved to focus on Manufacturing Restricted Substance
Lists (MRSL) to further environmentally-friendly chemical use in addition to
Restricted Substance Lists.
• It is important that the facility should not just rely on the declarations or assurances
from suppliers alone but ensure to put some validation processes in place to ensure
compliance such as test reports from competent ISO 17025 certified laboratories
approved for conducting these tests.
• It is important to discuss with the chemical / material suppliers about their product
details with respect the facility’s operating conditions and its limitations on recipe
concentrations etc.
Section 7: Chemical Management

Question and Guidance Common Mistakes


7. Does your facility select and purchase chemicals based on their hazards and
MRSL / RSL requirements?
If yes, do all chemicals purchased and used in production meet the facility's chemical
What are the MRSL
purchasing policy?and RSL requirements for hardgoods?
In the hardgoods
If no, do you havesector MRSLorand
a process planRSL requirements
for eliminating may not
chemicals bedo
that available.
not meet the
• facility's
All textilechemical purchasing
components in thepolicy?
hardgoods sector (for example, products such as
orucksacks,
Facilitiestents,
typically
etc.)are awareapply
should of Restricted
the MRSLSubstance Lists (RSL); however,
and RSL requirements the
as outlined
industry
in the Higg has
FEM. recently evolved to focus on Manufacturing Restricted Substance
• All Lists
other(MRSL)
componentsto further
shouldenvironmentally-friendly
be governed at least by chemical use inList
a Restricted addition to
regarding
Restricted
their use duringSubstance Lists. The restrictions on the final product, as applied
manufacturing.
• It is important
through that the
an RSL, mayfacility should
especially benot just rely
relevant foronthethe declarations
metal or assurances
processing and
from suppliersindustry,
electronics alone but andensure to putforsome
yet again othervalidation
sectors not processes in place
be relevant. WithtoRSLs
ensure
compliance such asof
the management test reportschemicals
residual from competent ISO product
on the final 17025 certified laboratories
is secured, however
approved
this mayfor conducting
depend on thethese tests.
product and materials used.
• It is important to discuss with
o For manufacturing, the chemical
black, grey and /white
material
listssuppliers
are often about
used. their
As a product
summary
details with
termrespect
we havethe facility’s
chosen operatingLists”.
“Restricted conditions and its limitations on recipe
• Black lists
concentrations etc.contain chemicals that are prohibited in manufacturing,
• Grey lists contain chemicals that should be phased out from manufacturing.
• White lists contain chemicals that may be used.
Section 7: Chemical Management Expectations under two different scenarios
Use chemicals in production processes Use chemicals in facility
operations only
All chemicals meet requirements of MRSL/RSL, and documentation is available to demonstrate this. The ZDHC MRSL Same as left.
conformance levels (1, 2 and 3) from ZDHC Gateway Chemical module should be used for the determination of the
conformity of the chemicals and for the development of approved chemicals lists.
Facility strategically set up their own chemical MRSL based on their hazards and covering all MRSL and RSL Nil
requirements from various brands which they are working with, or alternatively implement a strategy to use compliant
chemicals from an active list that covers all MRSL e.g. the Bluesign® system.
The facility strategically purchases chemicals that are certified to meet the MRSL and RSL when used appropriately such Nil
as bluesign® approved chemistry, Ecopassport by OekoTex. These certifications are checked for validity and updated at
least annually.
If above certifications are not available, the facility should purchase chemicals that are declared to meet the MRSL and Nil
RSL by the chemical provider, accompanied with analytical/test report to substantiate the declaration conducted at an
approved 3rd party laboratory. The declaration and analytical report are checked for validity and updated at least annually.
The facility has internal purchasing policy that is implemented and includes reference to criteria for the selection and use The facility has a process that
of dye and chemical suppliers. The purchasing procedures should include (but not limited to): process of communicating details the necessary criteria for
MRSL / RSL with the chemical suppliers, process to obtain suppliers' confirmation/declaration of MRSL / RSL compliance, selection of a chemical / chemical
collection of up-to-date Positive Lists from chemical suppliers, preference to purchase chemicals in Positive Lists, formulation through the use of
purchase orders with a remark stating that MRSL compliance is mandatory against appropriate version, chemicals technical specifications and
technical specifications and acceptance criteria, actions to be taken in case of defects or deviation from requirements are hazards associated with the
found. purchase.
... Same as left.

… Nil

… Nil

… Same as left.
Section 7: Chemical Management

Question and Guidance Common Mistakes


8. Does your facility have an environmental and occupational health and safety
program specific to chemicals management?
o Please select Partial Yes if your chemicals health and safety program is
complete, but not yet documented in writing.
• Chemicals health and safety programs must have a designated person or team,
meet legal health and safety requirements, and have written procedures for chemical
storage, handling, usage, disposal, and environmental controls for waste or
discharge to the environment.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


The facility has a designated person or team dedicated to chemical management with Same as left.
appropriate qualifications to understand and enact appropriate occupational safety and health
measures indicated in the MSDS/SDS and/or Technical Data Sheets (TDS) to protect workers,
the community and the environment.
Basic chemical risk assessment has been conducted which involves the identification of the Nil
risk and the potential hazard or harm resulting from a specific activity at the facility related to
the use of a chemical. For example, using certain chemical in a proposed amount and manner,
taking into account the chemical's possible routes of exposure. The assessment also needs to
identify different types of chemical and hazardous waste in production processes that are
relevant to the facility that could affect wastewater quality. The chemical risk assessment may
be conducted as standalone or as part of environmental assessment report.
The facility is operating within all permit/law requirements on health and safety related to Same as left.
chemicals with routine monitoring and reporting to senior management.
There are written procedures for safety and health related to chemical storage, handling, Same as left.
usage, disposal, and basic environmental controls for identified potential environmental
impacts from the chemical inventory due to waste or discharge: air, soil, groundwater, noise,
waste and sludge, wastewater. The procedures also need to consider the most likely natural
disaster in the region, for example, areas prone to heavy rain and flooding, earthquake,
typhoon, etc.
Basic health/wellness process is available on site or through a third party when hazardous Same as left.
chemicals are handled, or exposure occurs.
Section 7: Chemical Management

Question and Guidance Common Mistakes


9. Does your facility have well marked, designated chemical storage and
temporary storage areas?
If yes, select all that apply:
• The chemical storage area is ventilated, dry and protected from the weather and fire risk.
• The storage area is protected from unauthorized employees (i.e. locked).
• The chemical storage area is clearly marked.
• The chemical storage area has easy entry and exit in case of any emergencies.
• Storage containers are in good condition, appropriate for their contents, closed and clearly
labelled with their contents.
• Floor in storage area is solid and non-porous, there are no water drains that the liquid could
spill into, and there is no evidence of spilled liquid.
• Secondary containment is available for solid and liquid chemicals in tanks, drums, and
temporary containers (where applicable) to ensure no unintended releases occur.
• Incompatible substances (such as strong acids and strong bases) are stored separately.
• Flammable substances are kept away from sources of heat or ignition, including the use of
grounding and explosion-proof lighting.
• Temporary storage containers are closed and labelled with contents, lot, and hazard class.
o Temporary storage questions only apply to factories that use chemicals in
production processes.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only


Chemical storage area (warehouse and temporary storage including Nil
underground storage) is ventilated, dry, and protected from the direct
exposure of weather (with roof and walls), fire risk, and unauthorized
employees i.e. locked. Access permission is clearly defined.
The chemical storage area has easy entry and exit in case of any Nil
emergencies.
The floor is solid and non-porous, there are no water drains that the Nil
chemicals could spill into, and there is no evidence of spilled liquid
Chemicals are stored to avoid direct contact with floors and walls Same as left.

All chemicals at warehouse and temporary storage areas are clearly marked, Nil
with each chemical properly identified by visible signage with at least the
chemical product name and appropriate hazard warning (Global
Harmonization System (GHS) compliant signs, or equivalent) according to the
MSDS/SDS.
All chemicals containers in warehouse and temporary storage are in good Nil
condition, identified by its original labeling, lot number, product name,
supplier/manufacturer name, and hazard class.
Temporary/sub-containers are properly labeled with accurate information Nil
consistent with the label on original container.
… …
Section 7: Chemical Management

Question and Guidance Common Mistakes


10. Does your facility train employees responsible for the chemical management
system on Restricted Substance Lists (RSLs) and Manufacturing Restricted
Substance Lists (MRSLs)?
Please select all topics included in your training: MRSL ; RSL
Please describe the RSL and MRSL trainings conducted in the last calendar year
How many employees were trained?
How frequently do you train your employees?
• MRSL and RSL trainings must be conducted by a knowledgeable employee and
come with documentation showing who, when, where, and how they were trained on
MRSL and RSL. Additional documentation will be requested during verification: Job
Descriptions.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only (N/A)
There is a designated person(s) responsible for chemical management,
MRSL and RSL compliance, identified by formal job description, including but
not limited to: purchasing, production line and technical managers.
There is a formal system of training that documents who, when, where, and
how they were trained on MRSL and RSL.
Designated person(s) responsible for chemical management are
knowledgeable regarding MRSL and RSL (through interview).
Section 7: Chemical Management

Question and Guidance Common Mistakes


11. Does your facility have a documented process to systematically identify,
monitor and verify compliance with all product Restricted Substance Lists
(RSLs), and segregate chemical formulations materials and products which are
non-compliant with RSL?
Does your facility have a failure resolution process that is followed in the event of an
RSL test failure?
• A complete document containing the Risk Assessment for RSL and MRSL should be
present in the facility and can be prepared on basis of the chemical inventory and
the SDS/MSDS information along with the documents provided by the chemical
suppliers such as Technical Data Sheets, Certificate of Analysis, Certificate of
Conformance, Test reports, etc.
• Reference lists for RSL and/MRSL include:
● REACH SVHC Level 1 ● RoHS ● Prop 65 ● ZDHC priority 11 ● AFIRM ● AAFA
● BLUESIGN® System Substance List ● Oeko Tex 100 ● ZDHC MRSL (most updated version)
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only (N/A)
The facility or its parent/corporate group can provide a written document
specifying a review process that monitors, updates and show compliance to a
RSL.
Process recipes should consider the usage of chemicals according to each
technical data sheet (TDS) to ensure compliance to RSL i.e. chemicals in
process recipe should not exceed the concentrations as suggested by
chemical manufacturer.
All chemicals in the Chemical Inventory are checked against RSL compliance
at least on annual basis.
The facility or its parent/corporate group can provide Letters of RSL
Conformance supported with test/analysis results for all relevant chemicals.
RSL has been formally communicated to upstream suppliers i.e. chemical
suppliers, raw material suppliers, process subcontractors (e.g. washing,
finishing, printing).
Procedure or process to verify the products complies with RSLs such as
testing according to customer’s requirement, or having a program to test the
products based on factories’ own risk assessment (the focus should be the
procedure and process)
The facility or its parent/corporate group should ensure that all the raw
materials (yarn, fabric etc.,) are in compliance with the MRSL / RSL.
Section 7: Chemical Management
Question and Guidance Common Mistakes
12. Does your facility have a documented process to systematically monitor,
update and demonstrate compliance with Manufacturing Restricted Substance
Lists (MRSLs), and segregate chemical formulations materials and products
which are non-compliant with MRSL?
Does your facility require its chemicals suppliers to do the same?
Does your facility require its washing and printing subcontractors to do the same?
o Establishing an effective MRSL program is complicated and may take several years to fully
implement in your factory.
• For all products which are considered to be MRSL compliant, there must be
appropriate process for validating the MRSL present in the facility.
• The process of engaging the subcontractors should involve subcontractor selection,
evaluation and management which essentially includes the same processes that the
facility is following in order to meet all MRSL compliances and chemical
management practices.
• The ZDHC MRSL (latest version) is the global apparel, footwear, and textile industry
recognized chemical MRSL standard for the chemical supply industry and major
retail brands.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only (N/A)
The facility or its parent/corporate group can demonstrate a well-documented (written) chemical
review process that monitors, updates and shows compliance to legislations, customer MRSL
requirements, or the ZDHC MRSL as a standard for the facility, subcontractors and contractors.
The chemical review process against MRSL is aligned and managed properly across functions in
the facility (management, purchasing, lab, production teams) and external parties
(subcontractors, suppliers, testing agency, etc.) and responsibilities are assigned properly.
The process should also demonstrate how chemicals are reviewed / checked against the MRSL
prior to purchase.
Chemical review process/methods are robust, i.e. periodical screening through the ZDHC
Gateway – Chemical Module (with ZDHC Performance InCheck when possible),
certification/Letter of Compliance to MRSL specific to each chemical product with test data/report
to support the claim, or adoption of systems that ensures MRSL conformance e.g. Bluesign, etc.
When non-conforming chemicals are found, a phase out plan is developed accordingly. When
ZDHC Gateway - Chemical Module is used for screening, the facility tracks and monitors the
Level of Conformance of each chemical screened.。
The facility or its parent/corporate group actively communicates the expectations to their dye and
chemical suppliers that formulations supplied to the facility need to be compliant with MRSL.
The facility or its parent/corporate group can demonstrate that the expectation of MRSL
compliance is actively communicated to the upstream supply base and monitored on at least an
annual basis, including subcontracted processing units i.e. washing, printing (if applicable).
The facility or its parent/corporate group actively asks and monitors MRSL compliance of its
suppliers and screen it against Chemical Inventory List (CIL).
Section 7: Chemical Management

Question and Guidance Common Mistakes


13. Can all of your production chemicals be traced from the manufacturing
process back to chemical inventory?
o Chemicals traceability is necessary so that a facility can trace the source of a RSL and/or
MRSL failure and take action.
• In Level 1, the facility should have a traceability of chemicals used in each
manufacturing processes up to the chemical inventory. In other words, the facility
should track: (1) the chemicals available on-site (inventoried); (2) the production
recipe sheets, where each chemical used in every production step that involve
chemicals is listed.

What is the purpose of traceability?


The purpose of traceability is determining whether the chemical components involved
in the production can be traced “backward” (Pick out a finished product, whether it is
possible to trace the chemical components that are used to produce that particular
finished product), and “forward” (Pick out a chemical, whether it is possible to identify
all the particular finished products that are produced by using that particular
chemical).
Ability to do so, would help support root cause investigations in case any quality or
compliance issue occurred due to any particular chemical.
Section 7: Chemical Management Expectations under two different scenarios

Use chemicals in production processes Use chemicals in facility operations only (N/A)
All processes that a product went through that involves usage of chemical are
identified and the corresponding recipe and batch cards at each process are
available and retained.
Wherever chemicals are used there are written instructions for their proper
use including recipe cards, process instructions (where applicable),
formulation sheets, containing all traceable information i.e. chemical name, lot
number, and quantity, which can be linked back to the facility-wide chemical
inventory.
Major production processes and each chemical used and its respective
quantities are covered, and the process instruction including control
parameters and checkpoints are in place.
Where internal blending / mixing of chemicals take place the process has
been documented.
Chemicals listed in each production recipe at each manufacturing step can be
traced consistently to relevant records, including chemical mixing process log,
lab records (e.g. color lab, washing lab) where applicable, and the chemical
information is also recorded in the chemical inventory i.e. chemical /
formulation name, lot number, MRSL and RSL compliance etc. (please refer
to ZDHC CIL and ZDHC CMS Framework version 1.0 – Chapter 5 for
expectations related to chemical inventory).
Section 7: Chemical Management
Question and Guidance Common Mistakes

14. Does your facility have an implementation plan to improve your chemicals management program?

15. Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond
chemicals specified by regulations and/or Restricted Substance Lists / Manufacturing Restricted Substance
Lists?
16. Does your facility source already-approved or preferred chemicals from a positives list beyond chemicals
specified by regulations and/or Restricted Substance Lists / Manufacturing Restricted Substance Lists?
17. Does your facility collaborate with brands and/or chemical suppliers to select chemicals for alternatives
assessment?
18. Does your facility contribute a chemical analysis against human and environmental hazard criteria (e.g.,
persistent, bio-accumulative, and toxic) to this alternatives process?
19. Does your facility contribute an analysis of lifecycle impacts to this alternatives process?

20. Can your manufacturing process chemicals be traced from product lot number back to chemical lot
number?
21. Does your facility have a documented Quality Assurance (QA) Program that includes performance of
chemicals?
22. Do your contractors/subcontractors source already-approved or preferred chemicals from a positives list
to replace chemicals not already included in RSL/MRSL?
23. Does your facility have documented business goals, processes and actions showing commitment (e.g.,
equipment, process, choice of substitute chemicals) to new sustainable chemistry innovation? Does your
facility communicate its goals, processes and actions to Brands and Suppliers?
Section 7: Chemical Management
Question and Guidance Common Mistakes

14. Does your facility have an implementation plan to improve your chemicals management program?

15. Does your facility have an implementation plan to reduce the use of hazardous chemicals beyond
chemicals specified by regulations and/or Restricted Substance Lists / Manufacturing Restricted Substance
Lists?
16. Does your facility source already-approved or preferred chemicals from a positives list beyond chemicals
specified by regulations and/or Restricted Substance Lists / Manufacturing Restricted Substance Lists?
17. Does your facility collaborate with brands and/or chemical suppliers to select chemicals for alternatives
assessment? Question 14 to 23 are Level 2 and Level 3
questions
18. Does your facility contribute a chemical in Section
analysis of Chemical
against human and environmentalManagement.
hazard criteria (e.g.,
persistent, bio-accumulative, and toxic) to this alternatives process?
It would
19. Does your facility contribute beofdisclosed
an analysis when
lifecycle impacts to levelprocess?
this alternatives 1 is achieved.
They
20. Can your manufacturing will
process not bebe
chemicals discussed
traced from product lot during
number backthis training
to chemical lot
number?
given the inapplicability for most of the factories.
21. Does your facility have a documented Quality Assurance (QA) Program that includes performance of
chemicals?
22. Do your contractors/subcontractors source already-approved or preferred chemicals from a positives list
to replace chemicals not already included in RSL/MRSL?
23. Does your facility have documented business goals, processes and actions showing commitment (e.g.,
equipment, process, choice of substitute chemicals) to new sustainable chemistry innovation? Does your
facility communicate its goals, processes and actions to Brands and Suppliers?
Q&A
Thanks for attending the training!

You might also like