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Sustainable Apparel Coalition 11Sustainable Apparel Coalition

Higg FEM Content Training – Part 2Wastewater | Air Emissions | Chemicals

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Sustainable Apparel Coalition 3

Anti-Trust Guidelines

Training Task Team June 2016

Summary: Members are free to exchange or discuss publicly available information. However, the Members should avoid any discussions or joint efforts regarding confidential competitive information such as non-public cost or price information, non-public volume information, strategic plans or other information that is not “reasonably necessary” to achieve SAC’s goals.

Detailed guidelines• Do not agree or discuss how each of the Members will price their own goods or related products;• Do not agree to allocate certain geographic markets (i.e., territories) or product markets (i.e., types of products) among each other;• Do not discuss or agree to the cost or method of pricing products manufactured or sold by each other or otherwise direct each other’s business

activities that are outside the scope of SAC;• Do not not compare cost information that is confidential, such as labor cost, manufacturing costs or other variables affecting pricing;• Do not agree among yourselves to not do business with certain vendors (potential “boycott”) or otherwise pressure other competitors or vendors to

comply with certain pricing or cost policies;• SAC and its Members should not share with each other or discuss confidential, competitive information for individual Members or any information that

might affect the Members’ own day to day business decisions related to cost, price or output of their own products. For example, this confidential competitive information may include: price lists or pricing plans, volume, rebate or refund programs, discount policies, credit policies, advertising credits or program allowances, slotting allowances, product cost variables or profit margins, customer lists or specific complaints, supplier contract terms, current or future marketing plans, bidding plans, purchasing plans, planning strategies, capital improvement plans, terms of sale or other contract terms, or competition in the sale or manufacture of competing products;

• SAC should not facilitate agreements or coordination among Members for the prices they charge for the products they manufacture or sell or other collusive conduct, including market allocation or refusals to deal with suppliers or customers, or organize boycotts against other manufacturers or retailers; and

• SAC should not publish or share any information that would be suggestive or conclusory as to how any individual Member should deal with individual contracting or other third party issues

• SAC or its Members may discuss or share non-confidential, publicly available information or data


Agenda: Higg FEM Content Part 2

1. Quick re-cap of FEM Content Part 1 training

2. Wastewater

3. Air Emissions

4. Chemicals Management

5. Where to learn more


FEM Structure

Continuous Improvement Sections:1. Know your sources

2. Know major drivers of use

3. Baseline your performance

4. Set targets and action plan

5. Demonstrate reductions

6. Demonstrate leading practice


FEM Structure

Pollutant Limits1. Know your sources and volumes

2. Know quality of pollutants (permit/standard)

3. Control quality / take specific actions

4. Demonstrate leading practice (best available equipment, aspirational standard)


FEM Structure

Management Sections1. Have right staff in place

2. Adhere to the rules (regulations, laws, brand requirements)

3. Have long-term, holistic strategies and action plans in place

4. Take specific management actions (e.g., storage, handling, maintain equipment, etc.)

5. Demonstrate leading practice (e.g., engage upstream and with community, innovation, deep traceability)


FEM Applicabilities

Applicabilities:

Only answer questions applicable to your facility type/processes

Light/Heavy water user + water risk

Domestic/industrial wastewater + treatment onsite/offsite

Does facility have operations or production processes that emit air pollutants

Does facility use chemicals in production processes


FEM Performance Level Sections

Level 1Understanding

& Tracking Performance

Level 2Baselining,

Targets/Goals, Reductions

Level 3Leading

Practices

Must achieve Level 1 performance before moving on to Level 2-3


The Higg FEM is comprised of primary and secondary questions. Primary questions are numbered, and secondary questions are listed below the primary questions and colored blue. Question types in the Higg FEM may be one of the following:

• Select one

• Multi-select (select all that apply)

• Enter text

• Enter a number

• Upload a file (please note some file upload questions are required, and others are just suggested – required questions will have a red asterisk * next to the question.)

Note: If you answer “Yes” to a question, additional follow-up questions will appear that you must answer to fully complete the question and earn points.

Introducing “Partial Yes”: Allows facilities to get some credit for partially completed projects/initiatives. This is intended to reward progress instead of withholding all points until the perfect end state has been achieved.

A hint will be provided for all questions with “yes” and/or “partial yes” answer options

Higg FEM Question Types




2. Wastewater

3. Air Emissions




The Higg Wastewater section requires you to:

• Track quantity of wastewater generated from industrial and/or domestic operations (not applicable for factories with only domestic wastewater)

• Report all wastewater quality parameters that were found to not meet permits or industry standard(s), such as the ZDHC Wastewater Guideline, in the most recent quality test

• Report name and quality results from the offsite wastewater treatment plant (if applicable)

• Describe backup process if regular treatment fails (if applicable)

• Ensure proper sludge disposal (if applicable)

• Report whether your site reuses and/or recycles process wastewater as process water (if applicable)

Wastewater


Wastewater Applicability Test

• Does the facility generate industrial wastewater?

• Domestic only: toilets, showers, kitchens, cleaning, etc.• Domestic + Industrial use: production, lubrication, cooling,

blowdown from compressors or boilers, maintenance, cleaning production machines, etc.

• Does your facility have Zero Liquid Discharge (ZLD)?

• Is the domestic/industrial wastewater treated onsite, offsite or both? (if applicable)

• On-site wastewater treatment is the wastewater treatment plant used and managed by the factory only

• Off-site wastewater treatment is a third party enterprise or organization that provides wastewater treatment services (public or regional wastewater treatment facility)

• Is domestic wastewater sent into a septic system? (if applicable)

Wastewater


A few things to note:

All level 1 practices must be met before moving on to Level 2-3

• Note this includes disposing of hazardous sludge (chemical/industrial) through licensed hazardous waste treatment or incineration under properly controlled conditions. Any other treatment does not meet Level 1 requirements.

• Which wastewater guideline(s) you are reporting against:

• Permit

• Wastewater Standard

• This is where you can specify if you are reporting against the ZDHC Wastewater Guideline and share the results of which level you have met.

Wastewater




2. Wastewater

3. Air Emissions




Air Emissions

The Higg Air Emissions section requires you to:

• Track quantity of emissions from facility operations and refrigeration

• If you use refrigerants on-site you will be asked to specify which refrigerants are used. These refrigerants will factor into your GHG emission calculations.

• Track quantity of emissions from production processes

• List control devices / abatement processes and monitoring frequency for operating and refrigeration emissions.

• List control devices / abatement processes and monitoring frequency for production emissions.

• Specify achievements of advanced performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate Matter (PM)

• Specify whether your facility has a process for modernizing equipment to improve air emissions.


Air Emissions

Air Emissions Applicability Test

To determine whether you need to complete the questions in the Air Emissions section, we must evaluate whether your factory has relevant sources of air emissions.

Facility air emissions are commonly generated from:

• Your production processes: production line equipment and manufacturing processes

• Your facility operations: boilers, generators, and cooling systems

The applicability test asks:

• If you have any air-emitting operations (e.g., boilers, generators), you will answer questions about operating emissions in all levels.

• If you have any air-emitting production processes (e.g., solvents or adhesives), you will answer questions about production emissions in the Level 1 section.

• If you do not have any facility operation or production air emissions, you will not need to complete this section.


Air Emissions

Facilities will only be asked to report air emissions that are either:

• Not in compliance with a permit

• Not covered/tracked by a permit

Why? The Higg Index is focused on performance improvement thus it’s not necessary to report on emissions that are already meeting the permit/standard. Focus on the emissions that need to be fixed.

• At this time only emissions quantities will be reported, not emissions quality due to variance between local requirements and lack of a global standard

NOTE: Most fugitive releases of emissions from refrigerants are due to breaks or leaks in equipment.

• The equipment maintenance question from the EMS section is related to this since preventative maintenance is one of the best ways to prevent fugitive emissions.

GHG Calculation:

• Air question 3: Refrigerant leaks in equipment will be used to calculate Scope 1 GHG emissions (launching January 2018)


Air Emissions

Level 2: Going beyond permit requirements for Nox, Sox and Particulate Matter (PM):

• There is no current industry standard for air emissions that goes beyond-compliance

• To drive continuous improvement in emissions, SAC members developing this section have proposed three performance levels (Level 1-3) for Nox, Sox, and PM emissions

• Listed in How to Higg Guide Air section Level 2

• This can be updated if/when an industry standard is available




2. Wastewater

3. Air Emissions




Chemicals Management

The chemicals management section will ask about basic and advanced practices in the following areas:

• Chemicals management policies, compliance procedures, and commitments

• Employee training and communication

• Chemical procurement and purchasing practices

• Chemical handling, use, and storage practices

• Chemical inventory management

• Emergency Response Plan (ERP), accidents and spills remediation plan

• Product quality and integrity

• Chemicals and process innovation

The Higg Chemicals Management section is the result of a joint effort between the SAC, the Outdoor Industry Association (OIA), and the Zero Discharge of Hazardous Chemicals (ZDHC) program to converge their chemicals tools into one common assessment.



Chemicals Management 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• Metal Finishing• Welding• Other production processes that require chemicals

If any are selected, the facility uses chemicals in production processes and will answer all questions in the Chemicals Management section

If none are selected, the facility only uses chemicals in facility tooling and/or operations and will answer a subset of questions (Level 1-3)

*check How to Higg Chemicals Intro section for more detail and examples of chemicals in production vs. tooling/operations



Things to be aware of in the Chemicals section:

• ”Yes” and “partial yes” and “not applicable” answer options: check the question hints & How to Higg guide to answer these correctly

• Chemicals management is a newer/emerging sustainability practice; Implementing all Level 1 practices (able to answer yes/partial yes) may take facilities a year or longer if they are just getting started with chemicals management

• How to Higg guide links to many helpful chemicals management resources

• Quick tip: when uploading multiple large document in the “upload documentation” questions, it’s recommended to compress/zip all the files together and upload the zip file



Chemicals Inventory:

• All facilities will be asked whether they keep an inventory of chemicals used and suppliers of each chemical product

• Does your inventory include:

• Manufacturing processes (e.g. chemicals in production, spot cleaners, and wastewater treatment plant chemicals where applicable)

• Tooling/equipment (e.g. lubricants, grease)

• Facility operations and maintenance (e.g. cleaning products)

• Are you tracking all data for these chemicals? (i.e. supplier/vendor, Safety Data Sheet, MRSL compliance, etc.)

• You can score partial points for this question if:

• You’re inventorying some chemicals

• You’re capturing some data on some chemicals

• Check How to Higg guide, especially “How this will be verified” for detailed information




2. Wastewater

3. Air Emissions




Howtohigg.org – Higg Index Training & Support


New FEM How to Higg GuideHowtoHigg.org/Guide

27

The How to Higg guide will provide comprehensive and detailed guidance for every question in the FEM, including:

• Intent of the question

• Technical guidance and definitions

• How this will be verified

• Links to other relevant supporting resources/templates/organizations


Higg FEM Content Training Webinars

Higg FEM Content Training webinar deck and recording for Part 1 and Part 2 will be posted here:

• HowtoHigg.org/FEMtraining

• If you still have questions on the Higg FEM please review all the training materials and FAQ’s on HowtoHigg.org – especially the FEM How to Higg Guide

• If you cannot find the answer, contact support at HowtoHigg.org/request


Questions?

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