General Introduction
An Environmental Management System (EMS) is a holistic strategy and process to identify, track and manage the environmental impacts of your facility over time. While it’s possible to make incremental environmental improvements at your facility without a comprehensive plan, your facility can only maximize environmental performance by setting a long-term strategy that will inform decision-making on environmental management. The Higg Environmental Management System (EMS) section encourages you to:- Ensure there are dedicated staff responsible for coordinating environmental management activities that have sufficient qualifications and technical knowledge.
- Identify significant environmental impacts associated with facility operations.
- Set a long-term environmental management strategy.
- Develop a system to ensure compliance with all laws, regulations, standards, and other requirements.
- Ensure all levels of staff are aware of the facility’s environmental strategy and programs and how they can support the program.
- Engage with subcontractors and upstream suppliers on environmental performance.
- Engage with local stakeholders on environmental performance improvements.
EMS – Level 1
Answer Yes if: Your facility has any full-time, part-time, seasonal or contract employees that have dedicated responsibilities for coordinating environmental management activities in your facility.
If you select Yes, you will need to complete a table with the following questions to provide details on these employees during the reporting year.
Note: You are required to enter the details of at least one (1) employee and can provide details for up to six employees. If you wish to provide details on more than six employees, these can be uploaded to the FEM in a separate document.
- Name
- Job Title
- Time spent on environmental management.
- Select environmental topic (select all that apply)
- If staff members have multiple responsibilities, you have the option to indicate select topics and provide details in the description section.
- Describe the roles and responsibilities (description of employee’s roles and responsibilities for environmental management)
Suggested Uploads:
- Documentation that supports the environmental management staffing structure at your facility (e.g., organization chart, job descriptions for environmental team members, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they have staff dedicated to managing environmental activities at the facility.
Technical Guidance:
Facilities should have clearly defined roles and responsibilities for any staff responsible for coordinating environmental management activities at the facility. These employees must deal directly with environmental management and have defined roles for that purpose. The roles could be either required in their job description or accountabilities or designated by relevant management system documentation. Maintaining an up-to-date environmental management team organizational chart and clear job descriptions can help with defining clear responsibilities and accountabilities.
Resources:
Additional information on internationally recognized environmental management schemes are provided at the links below.
- ISO 14001:2015 Environmental management systems — Requirements with guidance for use https://www.iso.org/standard/60857.html
- EU Eco-Management and Audit Scheme (EMAS) https://green-business.ec.europa.eu/eco-management-and-audit-scheme-emas_en
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows the environmental management staffing structure at the facility. This may include:
- Environmental management team organization chart.
- Documented job descriptions or accountabilities for environmental staff.
- Other environmental management system documentation.
Interview Questions to Ask:
- Staff responsible for environmental management at the facility can explain the facility’s environmental management and accountability structure.
- Key staff responsible for coordinating environmental management activities understand and can explain their roles and responsibilities.
Inspection – Things to Physically Look For:
Observations onsite indicate that the environment management activities reported by the facility are being implemented and managed in accordance with the facilities procedures and team structure.
Partial Points: N/A
Answer
Answer Yes if: Your facility has performed an environmental impact assessment that covers all environmental aspects to identify significant environmental impacts from current facility operations.
Note: If your facility has a valid environmental management system scheme certification that includes requirements for environmental aspects and impacts assessment such as ISO 14001, you should select Yes to this question.
If you select Yes, you will be asked the following sub questions:
- Please upload documentation, if available
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- Documentation that demonstrates your facility has conducted an assessment to identify the significant environmental impacts associated with current operations (e.g., Environmental Impact Assessment (EIA), environmental aspects and impact aspect evaluation, environmental permits, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they have conducted an assessment to identify significant environmental risks associated with facility operations.
Technical Guidance
An environmental impact assessment is used to identify and characterize potential and actual adverse risks to the environment from all aspects of facility operations. An environmental impact assessment is a comprehensive review of all inputs and outputs of facility operations and production processes to identify potential impact areas, including impact areas covered in the Higg FEM (e.g., energy, water, waste, etc) as well as other impact areas such as legal compliance, environmental noise and vibration. Understanding a facility’s most significant risks helps to prioritize improvement actions to reduce impacts on the environment. After completing the EIA, facilities should compare the risk and impact scores of each activity with each other to ensure scoring is consistent. In addition, significant impacts should be addressed within the environmental strategy. In this way, the EIA and the environmental strategy are linked to each other.
An EIA should also consider any applicable environmental laws and regulations to determine the significance of risk as well as specific legal requirements for conducting the EIA.
Resources:
Several resources are provided below that provide additional information understanding and identifying environmental impacts.
- International Finance Corporation (IFC) Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts https://www.ifc.org/wps/wcm/connect/8804e6fb-bd51-4822-92cf-3dfd8221be28/PS1_English_2012.pdf?MOD=AJPERES&CVID=jiVQIfe
- International Finance Corporation (IFC) Environmental, Health and Safety Guidelines https://www.ifc.org/wps/wcm/connect/29f5137d-6e17-4660-b1f9-02bf561935e5/Final%2B-%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES&CVID=jOWim3p
- American Public Works Association (APWA) EMS Procedure (Example) Environmental Aspects and Impacts Procedure: https://www.apwa.net/library/accreditation/ems/CON-P0001_EMS_Procedure-Environmental_Aspects_with_Templates.doc
- ISO 14001:2015 Environmental management systems — Requirements with guidance for use https://www.iso.org/standard/60857.html
- EU Eco-Management and Audit Scheme (EMAS) https://green-business.ec.europa.eu/eco-management-and-audit-scheme-emas_en
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows the facility has conducted an assessment and identified the significant environmental impacts associated with current operations. This may include:
- Environmental Impact Assessment (EIA) report
- Environmental aspects and impact evaluation,
- Most recent local government environmental assessment report, if applicable
Interview Questions to Ask:
- Staff responsible for environmental management at the facility are aware of all significant environmental impacts.
- Relevant staff can describe the process used to identify and evaluate the significance of environmental impacts associated with facility operations.
Inspection – Things to Physically Look For:
- Observations onsite are consistent with the facility’s identified environmental aspects and impacts (e.g., reported impacts and significance are representative of conditions at the facility)
Partial Points: N/A
Answer
Answer
Answer Yes if: Your facility has a documented environmental policy that is aligned with your organization’s long-term environmental management strategy and is approved by top management.
If you select Yes, you will be asked the following sub question:
- Please upload documentation, if available.
Suggested Uploads:
- A copy of the facility’s environmental policy.
- Other relevant supporting documentation that demonstrates the policy is integrated with the company’s environmental strategy (e.g., environmental objects and targets, employee and stakeholder communications related to the policy etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they have clear environmental policy that outlines commitment to reducing its environmental impacts.
Technical Guidance
An environmental policy demonstrates an organization’s commitment to reducing its environmental impacts. Establishing a clear environmental policy provides a framework for a facility to establish and monitor its environmental programs and communicate its commitments to all internal and external stakeholders.
An environmental policy, as defined by ISO 14001 an Environmental Management Systems certification scheme, is a policy that should:
- Be appropriate to the organisation.
- Include a commitment for continual improvement.
- Include a commitment to comply with relevant legal and other requirements.
- Provide the framework for setting and reviewing environmental objectives and targets.
In general, there is no required format or content for an environmental policy, however it is important to consider key aspects that address environmental problems and outline your organization’s culture around these. The following list provides some examples of aspects that may be included in the policy:
- Describing the importance of environmental issues to the company.
- Your organisation’s environmental objectives and goals (e.g., reduction of resource and material consumption, climate protection, reducing waste, etc).
- It is important that all objectives and goals be supported by performance indicators that allow your organization to demonstrate commitments to the policy, continual improvement, and environmental performance.
- How your organization raises environmental awareness, encourages participation, and trains staff on environmental matters.
- How your organization assesses the environmental impact of operations and supply chains.
- How your organization applies similar environmental expectations for suppliers and contractors.
- How your organization communicates environmental goals and objectives to internal and external stakeholders.
How This Will Be Verified:
Full Points:
Documentation Required:
- A documented environmental policy that is approved (signed) by top management.
- Other supporting documentation that demonstrates the policy aligns with the facility’s environmental management strategy and goals. This may include:
- Details on the facility’s environmental objectives, targets, KPIs and how these are monitored in relation to the policy.
- Records or evidence of stakeholder communications and/or training on the policy
Interview Questions to Ask:
- Staff responsible for environmental management at the facility, including top management, and employees are aware of the facilities policy and can describe the facility’s efforts to meet its stated objectives.
Inspection – Things to Physically Look For:
- Observations onsite are consistent with the facility’s environmental policy (i.e., the policy is relevant to the facility operations and environmental impacts)
- Posting of the environmental policy at the site or other forms of communication to staff.
Partial Points: N/A
Answer
Answer Yes if: Your facility has a documented environmental strategy in place that sets forth environmental priorities and includes defined goals and actions for three (3) years or longer.
Notes:
- Your facility has an environmental strategy that aligns with the requirements of ISO 14001 for objectives and targets that covers 3 or more years, you should answer Yes to this question.
- The 3 year timeline must include the Higg FEM reporting year. For example, for FEM 2024, the strategy must include the 2024 calendar year.
Answer Partial Yes if: Your facility has a documented environmental strategy in place that covers less than 3 years OR sets forth environmental priorities and goals for 3 or more years, but the strategy does not include defined actions that the facility plans to take to achieve the goals. For example, your facility has a goal to reduce energy use by 30% over 3 years but have not identified the specific actions required to achieve this reduction.
If you select Yes or Partial Yes, you will be asked the following sub questions:
- Select all topics covered by this strategy (select all that apply).
- Please upload environmental management strategy, if available
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- A copy of the facility’s environmental strategy.
- Other relevant supporting documentation that supports the environmental strategy (e.g., environmental objects and targets, relevant environmental impacts of the site, list of detailed actions planned together with their responsibilities, timelines, cost, status to achieve the strategy etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they have set an environmental management strategy that defines long term goals and actions to meet the facility’s goals.
Technical Guidance
A documented environmental strategy provides a clear path for an organization to reduce impacts and to improve environmental performance and efficiency. It offers a structured way to incorporate environmental considerations into day-to-day operations and long-term planning.
Before creating an environmental strategy it is important that a facility’s environmental impacts have been identified and prioritized which will allow a strategy to be developed based on a facility’s significant impacts. Once there is a clear understanding of the key environmental impacts, an overarching environmental strategy and measurable environmental targets can be created. Targets should drive continuous improvement of environmental performance in the medium to long term (3 or more years). Additionally, facilities should have procedures in place to review and adjust the strategy periodically, as needed.
Aligning with the requirements (and/or seeking certification) with internationally recognized environmental management system certification schemes (such as ISO 14001 or EMAS) can help provide a structured framework to support facilities with creating a long term environmental strategy and defining actions to improve environmental management.
Resources:
- ISO 14001:2015 Environmental management systems — Requirements with guidance for use https://www.iso.org/standard/60857.html
- EU Eco-Management and Audit Scheme (EMAS) https://green-business.ec.europa.eu/eco-management-and-audit-scheme-emas_en
How This Will Be Verified:
Full Points:
Full Points will be awarded for facilities that have a documented environmental strategy in place that sets forth environmental priorities and includes defined goals and actions for 3 years or longer.
Documentation Required:
- The company’s environmental strategy and all relevant supporting documentation. This should include:
- Strategic Environmental objects and targets that extend 3 or more years into the future.
- A list of detailed actions planned to achieve the strategy.
- Documentation that demonstrates the strategy has been approved and is supported by top management (e.g., budget approval/planning to support the strategy, strategy review meeting minutes).
Note: If information and details on environmental targets and actions (e.g., specific energy targets or action plans) are maintained in separate documentation, they should be available for review and be directly related to the facility’s environment strategy.
Interview Questions to Ask:
- Top management understands the long-term strategy in place and are able to explain their role in ensuring the actions in the strategy are being implemented.
- Relevant staff responsible for managing and implementing the facility’s environmental objectives and targets explain their role in implementing the environmental strategy.
Inspection – Things to Physically Look For:
- Observations onsite are consistent with the facility’s environmental strategy (i.e., the strategy and defined actions to implement the strategy are relevant to the facility operations)
Partial Points:
Partial Points will be awarded for facilities that have a documented environmental strategy in place that covers less than 3 years OR that sets forth environmental priorities and includes defined goals for 3 years or longer, but the strategy does not include defined actions that the facility plans to take to achieve the goals.
Answer
Answer
Answer
Answer Yes if: Your facility has established procedures and defined responsibilities to regularly review environmental permitting requirements, monitor current permit requirements, and renew environmental permits to ensure compliance.
If you select Yes, you will be asked the following sub questions:
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- Documentation that supports the facility’s procedures to review and monitor environmental permit status, and renew permits to ensure you are meeting the legal requirement (e.g., documented permit monitoring procedure, related job descriptions or duties, list of required permits, calendar of permit activities/renewal requirements, etc.)
What is the intent of the question?
The intent of this question is to ensure facilities have established procedures to monitor and maintain compliance with environmental permits.
Technical Guidance
Maintaining compliance with applicable environmental laws and regulations is a fundamental business practice. Facilities should have established procedures and defined responsibilities to ensure permit requirements are well understood and that compliance is maintained.
Environmental permits often require facilities to take action to ensure the facility is operating in compliance with permit requirements which may include:
- Environmental testing or reporting
- Renewing permits that have expirations dates.
- Updating/re-applying for permits based on changes in facility operations or changes to relevant laws and regulations.
For this question in the FEM, having a mechanism in place means that the facility has processes in place to ensure staff are responsible for, and following established practices to review, monitor and renew environmental permits on a defined schedule. This schedule should be defined based on the organizational structure of the facility’s environmental team and the applicable environmental permitting requirements.
Resources:
- Example permit inventory and tracking template: https://howtohigg.org/resources/resources-library/#templates
How This Will Be Verified:
Full Points:
Documentation Required:
- Supporting documentation that shows the facility has procedures to review and monitor environmental permit status and renew permits to ensure you are meeting the legal requirement. This may include:
- Copies of all applicable environmental permits with applicable compliance requirements
- Documented permit monitoring procedures
- Job descriptions or list of responsibilities for relevant staff
- List of required permits with calendar of permit activities/renewal requirements (e.g., a permit tracking document with defined actions to maintain compliance)
- Corrective Action plans (if applicable)
Note: The supporting documentation noted above may be included in various documents, however collectively they must demonstrate that the facility has a mechanism to review, monitor, and renew environmental permits to ensure compliance.
Interview Questions to Ask:
- Staff responsible for environmental management are able to describe the facility’s processes for ensuring permit requirements are being complied with.
- Key staff involved in permit monitoring and renewal processes are able to describe their role and responsibilities for ensuring compliance with all environmental permits.
Inspection – Things to Physically Look For:
- Observations onsite confirm the applicable environmental permitting requirements are being complied with (e.g., scope of facility operations, environmental impacts or discharges that require permits, etc.)
Partial Points: N/A
Answer
Answer
Answer Yes if: Your facility has documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts and the facility is in compliance with all applicable legal and/or other requirements.
Answer Partial Yes if: Your facility has documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts, but you are currently not in compliance with one (1) or more legal and/or other requirements and you have a documented plan to correct the non-compliance(s).
Notes:
- These procedures may be implemented at the manufacturing groups level, but facilities must be able to demonstrate how these procedures are aligned with at the facility level.
- This question is not inclusive of the mechanism for monitoring and renewing legally required permits covered in the Higg FEM question “Does your facility have a mechanism in place to regularly review and monitor environmental permit status and renewal (where appropriate) and ensure compliance?”
- For this question, significant impacts relates to impacts that have been identified and determined to be significant based on the criteria and guidance for the Higg FEM question “Has your facility identified the significant environmental impacts associated with current operations within the factory premises?”
If you select Yes, you will be asked the following sub questions:
- Select all topics covered by the system (select all that apply)
- Are the findings used to set an improvement plan that is regularly reviewed?
- Please upload documentation, if available
- If you cannot upload the documents, please describe here:
Suggested Uploads:
- Documentation that supports the facility’s procedures to review and monitor environmental permit status, and renew permits to ensure you are meeting the legal requirement (e.g., documented legal and other requirements monitoring procedure, related job descriptions or duties, list of applicable requirements (legal and other), calendar of review and monitoring activities, corrective action plans, etc.)
What is the intent of the question?
The intent of this question is to ensure that facilities are systematically and proactively identifying and reviewing requirements in applicable laws, regulations, standards, codes and other requirements for their significant environmental impacts.
Technical Guidance
Understanding, identifying, monitoring, and verifying environmental compliance requirements for legal and other requirements for a facility’s significant environmental impacts is important to ensure a facility is operating in compliance with legal and other requirements. Having established procedures should be part of a facility’s or manufacturing group’s formal environmental management system. These processes should be documented (for example, through a standard operating procedure), maintained and implemented by qualified staff that have a good understanding of environmental regulations and other requirements. Requirements may include:
- Legal and other regulatory requirements
- Industry or client brand requirements (e.g., industry stakeholder initiatives, brand code of conduct requirements or expectations)
A facility’s procedures should include systematic processes to:
- Identify, review, and monitor the scope of regulatory and other requirements for the facility’s significant environmental impacts.
- Define Responsible staff/departments and specific duties to ensure implementation.
- Establish formal internal review & tracking procedures and documentation (e.g., legal, and other requirements register)
- Define a review and monitoring schedule and frequency to identify changes in requirements.
- Define processes to address any identified non-compliances or actions required to maintain compliance
Periodic review and updates of environmental regulations should be conducted and documented. This review schedule should be defined based on the organizational structure of the facility’s or manufacturing group’s environmental team and the applicable environmental regulatory and other requirements.
Resources:
Example regulatory and other requirement tracking template: https://howtohigg.org/resources/resources-library/#templates
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts and the facility is in compliance with all applicable legal and/or other requirements..
Documentation Required:
- Supporting documentation that shows the facility has documented procedures to identify, monitor, and verify environmental compliance requirements for legal and other requirements for the facility’s significant environmental impacts. This may include:
- A list of applicable legal and other requirements (e.g., legal and other requirements tracking registry)
- Job descriptions or list of responsibilities for relevant staff
- Documented procedures for the review and monitoring processes that include the review process and frequency.
- Corrective Action Plans, if applicable
Notes:
- These procedures may be implemented at the manufacturing groups level, but facilities must be able to demonstrate how these procedures are aligned with at the facility level.
- The supporting documentation noted above may be included in various documents, however collectively they must demonstrate that the facility has documented procedures in place to identify, review, and monitor legal and other requirements to ensure compliance.
Interview Questions to Ask
- Staff responsible for environmental management are able to describe the facility’s processes to identify, monitor, and periodically verify all regulatory and other requirements for the facility’s significant environmental impacts.
- Key staff involved in processes are able to describe their role and responsibilities for ensuring compliance with all regulatory and other requirements.
Inspection – Things to Physically Look For
- Observations onsite confirm all significant sources of environmental impacts have been identified and applicable legal and other requirements are being complied with.
Partial Points:
Partial points will be awarded for facilities that have documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts, but you are currently not in compliance with one (1) or more legal and/or other requirements and they have a documented plan to remediate the non-compliance(s).
Answer
Answer
Answer
Answer Yes if: Your facility has provided training on environmental awareness and the facility’s environmental strategy to all employees.
Note: Different levels of training may be provided based on employees’ position and/or responsibilities, however training must have been provided to all employees to answer Yes to this question.
If you select Yes, you will be asked the following sub questions:
- If yes, how many employees were trained?
- If yes, how frequently do you train your employees?
- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
- Please upload documentation, if available.
Suggested Uploads:
- Documentation that demonstrates the facility has conducted training for all employees (e.g., Training plan, training records, training material used for environmental training, post-training evaluation procedures and/or records)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that environmental training has been to provided all employees.
Technical Guidance
It is important that all levels of employees are aware of the facility’s environmental programs and strategy and general environmental impacts and protection (e.g. environmental laws, energy and water conservation, waste and chemicals management, impacts of wastewater, air emissions, and climate change, etc.).
Facilities should have formal documented training processes to ensure awareness and knowledge is shared with all employees. An environmental training program can provide employees with information about the specific actions they can take to reduce the facility’s environmental impacts and help to promote a culture of environmental responsibility, leading to greater employee engagement and commitment to sustainability goals.
Employees may require different levels of trainings that are appropriate for their position or responsibilities. For example, general workers may only require awareness training on existing company environmental practices and goals, while management personnel may require more detailed training on environmental management systems or strategy as it relates to their responsibilities.
Having procedures to collect information to evaluate the effectiveness of training programs (e.g. trainee feedback questionnaires or test, observation or reviews of trainer performance, etc) will help facilities ensure the effectiveness of environmental trainings and knowledge retention.
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows the facility has provided environmental training for all employees. This may include:
- Training plan that identifies training schedule(s) and type of training for all levels of employees.
- Training attendance records
- Training material used for environmental training,
- Training evaluation procedures and/or records
Interview Questions to Ask:
- Staff responsible for the facility’s environmental training program can explain how trainings are provided and if applicable, how the effectiveness of training is evaluated.
- Employees who have received the trainings are aware of the content of the training and the facility’s environmental programs and their roles in supporting the program.
Inspection – Things to Physically Look For
- Supporting evidence of the facility’s environmental training program (e.g., awareness posters, informational postings related to the facility’s environmental programs and strategy, if available)
Partial Points: N/A
Answer
Answer
Answer
Answer
Answer
Answer Yes if: Your facility has a documented procedure that enables workers to report environmental incidents or issues and all employees have been trained on the procedures to report.
Note: If your facility has a general grievance/worker feedback procedure, but it does not specifically outline procedures to report on environmental incidents/issues, or employees have not been trained on the environmental reporting procedure you should select No for this question.
If you select Yes, you will be asked the following sub question:
- Please upload documentation.
Suggested Uploads:
- Documentation of procedures in place to enable workers to report environmental incidents or issues (e.g., reporting procedure, employee training, examples of reporting templates or previous reports submitted by employees, etc.)
What is the intent of the question?
The intent of this question is to demonstrate that facilities have established a proper channel for workers to report for environmental incidents or issues and that employees have been trained on the reporting procedure.
Technical Guidance
As part of an effective environmental management program, it should be every employees’ obligation to report suspected or actual violations of regulation or environmental incidents. Facilities should establish clear reporting channels and procedures to facilitate and encourage employees to report environmental incidents or issues. This is critical to prevent facilities from not reporting any violations and/or delaying the necessary actions to reduce environmental contamination.
Procedures should include:
- A clear description of the steps for reporting environmental incidents or issues based on the nature of the incident or issue to both internal and external parties (e.g., the facility’s environmental management, local environmental bureau)
- Identify the responsible contacts or departments (internally and externally) who the report should be submitted to.
- Include details on how reports will be managed or escalated by the facility’s environmental management team)
- Include guarantees that there will be no punished or retaliated against for reporting truthful information to law enforcement.
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows the facility has procedures in place to enable workers to report environmental incidents or issues. This may include:
- Environmental incident or issues reporting procedure.
- Employee training attendance records and/or training material.
- List of contacts (internally and externally) who incidents should be reported to.
- Examples of reporting templates or previous reports submitted by employees.
Interview Questions to Ask:
- Staff responsible for environmental management are able to describe the facility’s reporting procedures and how employees are trained on the procedures.
- Employees are aware of the procedures and how they can report environmental incidents or issues.
Inspection – Things to Physically Look For:
Onsite observations confirm procedures to report environmental incidents or issues are available to workers (e.g., posting of reporting procedures and/or contacts, etc.)
Partial Points: N/A
Answer
Answer Yes if: Your facility has a documented process and maintenance schedule covering all equipment used for production and facility operations that is being implemented.
Answer Partial Yes if: Your facility has a documented process and maintenance schedule for equipment used for production and facility operations, but it does not include all production and operations equipment and/or some equipment is not being maintained per the maintenance schedule.
If you select Yes or Partial Yes, you will be asked the following sub questions:
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- Facility equipment maintenance procedures and schedule
- Examples of equipment maintenance records/logs
What is the intent of the question?
The intent of this question is for facilities to demonstrate they have appropriate maintenance procedures that are being implemented for all production and operations equipment at the facility.
Technical Guidance
All equipment used for production and facility operations should be maintained regularly to ensure it is operating efficiently and as designed. Properly maintained equipment is crucial to minimize environmental impact (e.g., minimizing waste or air emissions due to inefficient machinery or leakage and excess resource consumption) and can help identify problematic equipment and opportunities to reduce waste and resource consumption (e.g., energy, compressed air, and water use).
Depending on the type of equipment, the frequency and scope of maintenance can vary. Regular maintenance should be scheduled based on available information for each piece of equipment (e.g., manufacturer’s recommendations, past breakdowns or leaks from equipment, operating conditions, etc.) and be performed with the goal to reduce the chances of equipment failure and identify potential problems before they result in breakdowns or leaks.
Key aspects of a good maintenance program should include procedures for:
- Appointing qualified staff to oversee, manage and implement the maintenance program (including any external contractors).
- Creating an inventory of all equipment at the facility (e.g., name, function, make, model, serial number, etc).
- Identifying the required and/or recommended maintenance activities for each piece of equipment (e.g., from manufacturers specifications, legally required inspection/testing or certification requirements, etc.)
- Defining the appropriate maintenance scope and schedule for each piece of equipment.
- Creating standardized documentation or utilizing technology/software to record and track maintenance for all equipment (e.g., maintenance checklists, maintenance records/logs, etc)
- Ensuring the appropriate resources are available for staff to implement the maintenance program. (e.g., budget, time, and proper tools/equipment).
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have a documented process and maintenance schedule covering all equipment used for production and facility operations that is being implemented
Documentation Required:
- Documentation that demonstrates the facility has a process and schedule for maintaining maintenance of all equipment used for production and facility operations. This may include:
- Facility equipment maintenance procedures and schedule that covers all facility equipment.
- Equipment maintenance records/logs that indicate equipment has been maintained per the maintenance schedule.
Interview Questions to Ask:
- Staff responsible for the facility’s maintenance program should be able to explain how the maintenance procedures and schedule were developed and how these are being implemented.
- Relevant staff (e.g., maintenance staff) should be aware of the established maintenance procedures and schedule and understand their responsibilities for implementation of the maintenance program.
Inspection – Things to Physically Look For:
- Observations onsite indicate that the facility is implementing the maintenance program as per the established procedures and schedules (e.g., equipment is in good operating order, equipment maintenance tags/records indicate maintenance is occurring per the schedule, etc.)
Partial Points:
Partial Points will be awarded for facilities that have a documented process and maintenance schedule for equipment used for production and facility operations, but it does not include all production and operations equipment, and/or some equipment is not being maintained per the maintenance schedule.
Answer
Answer
Answer Yes if: Your facility has confirmed there has been no soil/ groundwater contamination at your facility. This means that there have not been any spills or leaks of hazardous materials at the facility that resulted in soil and/or groundwater contamination.
Answer Partial Yes if: If there has been one (1) or more spill that caused contamination of soil and/or groundwater at the facility, but you have fully remediated, or the facility is in the process of remediating the contamination and has an established remediation plan that includes details of the specific actions, responsibilities, investment, and timeline for remediation activities.
Notes:
- If your facility currently has soil and/or groundwater contamination onsite and have not begun remediation, you should answer No to this question.
- Hazardous Material is defined as any material that could cause harm to public health and/or the environment because of its chemical, physical, or biological characteristics (e.g., it is flammable, explosive, toxic, radioactive, infectious, etc.). Hazardous material can be liquids, solids, gases, or sludge, and it could be a waste, resource or a raw material.
If you select Yes, you will be asked the following sub questions:
- Please describe how your facility prevented such contamination.
If you select Partial Yes, you will be asked the following sub question:
- Is your facility remediating and/or have you remediated the issue?
- If yes, please upload documentation (Photographs, Report, Action plan, Legal notice if any)
- If you cannot upload the documents, please briefly explain how you remediate the issue:
If you select No, you will be asked the following sub questions:
- Please describe the contamination in detail
- Please upload documentation if any (i.e., Photographs, Report, Legal notice)
Suggested Uploads:
- Documentation that demonstrates your facility has not caused soil and/or groundwater contamination at your facility site (e.g., soil and/or groundwater investigation reports, current environmental impact assessment, etc.).
- Where applicable, documentation of remediation activities to address any soil and/or groundwater contamination (e.g., records of spills response/clean-up activities or procedures, remediation action plans, post clean up investigations that show contamination soil and/or groundwater was remediated, etc.).
What is the intent of the question?
The intent of this question is for facilities to demonstrate that their operations have not resulted in contamination of soil and/or groundwater, or if contamination has occurred, that this has been remediated.
Technical Guidance
Soil or groundwater contamination refers to the presence of hazardous substances in the soil or groundwater at levels that can have negative impacts on human health and/or the surrounding environment.
Contamination can occur as a result of various activities associated with manufacturing operations including spills of hazardous materials, leaks from hazardous materials storage tanks or areas, improper waste disposal or storage. When hazardous substances enter the soil or groundwater, they can persist for years, potentially leach into nearby waterways which can pose health risks to humans and the environment. Having procedures to prevent and remediate contamination will help facilities reduce potential environmental impacts and compliance risks.
Additionally, facilities should have procedures to monitor risk of contamination through internal audits / walkthroughs to check for indications of soil/groundwater contamination from its operations.
If contamination is identified, the facility should establish appropriate action plans to remediate the contamination. This may include:
- Initial containment activities to prevent or reduce the spread of contamination.
- Soil/groundwater investigation to determine the extent and severity of the contamination.
- Specific actions required to remove and/or clean up contaminated soil and/or groundwater.
- Post remediation investigation to confirm the contamination was remediated.
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that can demonstrate that there has been no soil/ groundwater contamination at the facility. This means that there have not been any spills or leaks of hazardous materials at the facility that have resulted in soil and/or groundwater contamination.
Documentation Required:
- Documentation that demonstrates the facility has not caused soil and/or groundwater contamination at the facility site. This may include:
- Soil and/or groundwater investigation reports.
- Environmental impact assessment indicating that the facility’s operations did not contaminate groundwater / soil.
- Document procedures or records of internal audits, walkthroughs to monitor risks of contamination.
- Where applicable, documentation of remediation activities taken to remediate soil and/or groundwater contamination. This may include:
- Records of spills response/clean-up activities or procedures.
- Remediation action plan that includes details on the specific actions and timeline for remediation activities.
- Post clean up investigations/reports that show contamination soil and/or groundwater has been remediated.
Interview Questions to Ask:
- Staff responsible for environmental management at the facility are able to explain the facility’s procedures and action taken to confirm no soil and/or groundwater contamination has occurred and how this is monitored.
- Staff responsible for any soil/groundwater remediation are able to explain the actions taken by the facility to remediate the contamination.
Inspection – Things to Physically Look For:
- Onsite observations indicate that there is no contamination of soil and/or groundwater occurring (e.g., no observed spills or leaks of hazardous materials or direct discharge of wastewater to the environment, no evidence of improper waste disposal, etc.)
- Indication that any contamination has been appropriately remediated.
Partial Points:
- Partial Point will be awarded if there has been one (1) or more spill that caused contamination of soil and/or groundwater at the facility, and there is supporting evidence that the contamination has been have fully remediated, or the facility is in the process of remediating the contamination and has an established remediation plan that includes details on the specific actions, responsibilities, investment, and timeline for remediation activities.
Answer Yes if: Your facility tracks and reports quantitative metrics data in the Higg FEM AND has a data quality management system for quantitative metrics that covers all applicable environmental data at the facility (e.g., energy and water use data, waste generation, etc.) that is tracked AND the system includes all of the following elements:
- Documented Roles and Responsibilities
- Centralized Data Collection and Management Procedures
- Capacity building and training of staff on environmental data quality principles
- Internal Quality Assurance (QA) Procedures
Answer Partial Yes if: Your facility tracks and reports quantitative metrics data in the Higg FEM AND has a data quality management system for quantitative metrics that covers all applicable environmental data at the facility (e.g., energy and water use data, waste generation, etc.) that is tracked, however the system includes at least one, but not all of the elements listed above OR your data quality management system has all of the elements listed above, however it is not applied to all quantitative metrics data your facility reports.
Answer No if: Your facility tracks and reports quantitative metrics data in the Higg FEM, but does not have a data quality management system that includes any of the elements above OR if your facility is not able to report any quantitative metrics data in the Higg FEM.
Note: Quantitative Metrics are quantitative (numerical) values input in the Higg FEM (e.g., production volume, energy and water use quantities, wastewater discharge quantities, waste generation quantities, baseline and improvement quantities, etc.).
If you select Yes or Partial Yes, you will be asked the following sub question(s):
- If Yes, which of the following elements are included in your Data Quality Management System for Quantitative Metrics?
- Documented Roles and Responsibilities
- Centralized Data Collection and Management Procedures
- Note: Centralized data collection refers to any form of electronic data management program used to record and store data (e.g., electronic spreadsheets, other data management software)
- Capacity building and training of staff on environmental data quality principles
- Internal QA Procedures
Suggested Uploads:
Documentation that demonstrates the facility has an established data quality management system that is applied to environmental data (e.g. defined job responsibilities, data collection and recording procedures, training material and/or records for relevant staff, internal data quality auditing procedures and/or reports).
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they have an effective data quality management system in place that is applied to all environmental data reported in the Higg FEM.
Technical Guidance:
Accurately tracking and reporting environmental data provides facilities and stakeholders with detailed insight into opportunities for improvement. If data is not accurate, this limits the ability to understand the facility’s environmental footprint and identify the specific actions that will help reduce environmental impacts and drive efficiencies.
When establishing an effective data quality management system facilities should consider the following key elements:
- Defined responsibilities with clear accountability for collecting, monitoring, and ensuring the quality of environmental data quality (e.g. environmental data quality manager and other support staff).
- Note: A data quality team often requires the involvement of several departments and staff to coordinate data collection and analysis (e.g., maintenance, accounting, operations teams, engineering)
- Centralized Data Collection and Management Procedures that address how data is collected and input into the centralized database. This should clearly define:
- What data is available (e.g. invoices, meters, etc.)
- Who is responsible for data collection and recording.
- The frequency of data collection/recording for all activity data.
- Capacity building and training program for relevant staff on environmental data quality principles and the facility’s data quality management system procedures.
- Internal QA Procedures that include procedures review and audit data on a regular basis. This can include
- Double checking sources data (invoices, meter logs, etc) with data input into data tracking tools.
- Comparison of current data with historical data and trends.
- Review of any unit conversions or automated calculations in tracking tools.
Resources:
- Chapter 7 of the GHG Protocol – A Corporate Accounting and Reporting Standard provides detailed information and principles on data quality management that can be applied to all types of environmental data – https://ghgprotocol.org/
How This Will Be Verified:
Full Points
Full Points will be awarded if your facility tracks and reports quantitative metrics data in the Higg FEM AND has a data quality management system for quantitative metrics that covers all applicable environmental data at the facility (e.g., energy and water use data, waste generation, etc.) that is tracked AND the system includes all of the following elements:
- Documented Roles and Responsibilities
- Centralized Data Collection and Management Procedures
- Capacity building and training of staff on environmental data quality principles
- Internal Quality Assurance (QA) Procedures
Documentation Required:
- Documentation that demonstrates the facility has an established data quality management system that is applied to environmental data collected at the facility. This may include:
- Defined job responsibilities
- Data collection and recording procedures
- Training material and records for relevant staff
- Internal data quality assurance/auditing procedures or reports.
Interview Questions to Ask:
- Staff responsible for managing environmental data are able to explain the following:
- The procedures in place for tracking and recording environmental data.
- How data quality is maintained.
Inspection – Things to Physically Look For:
- Observations indicate that the facility’s environmental data quality system is being implemented for all applicable environmental data reported in the Higg FEM.
Partial Points:
Partial Points will be awarded if your facility tracks and reports quantitative metrics data in the Higg FEM AND has a data quality management system for quantitative metrics that covers all applicable environmental data at the facility (e.g., energy and water use data, waste generation, etc.) that is tracked, however the system includes at least one, but not all of the elements listed above OR your data quality management system has all of the elements listed above, however it is not applied to all quantitative metrics your facility reports.
EMS – Level 2
Higg FEM Level Progression
If your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:
Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?
If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.
If you Answer No: Level 2 and 3 questions will not be available in this section.
Notes:
- If your facility did not achieve Level 1 in this section, answering Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
- It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.
- Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3.
Answer
Answer
Answer
Answer
Answer Yes if: Your facility has conducted a review of your environmental management system with the facility’s management team(s) in the last calendar year.
Note: The review must have been conducted in the Higg FEM reporting year (e.g., for FEM 2023, the meetings must have been conducted in the 2023 calendar year).
If you select Yes, you will be asked the following sub questions:
- Please upload documentation, if available
- If you cannot upload the documents, please describe here:
Suggested Uploads:
- Records of environmental management system review(s) conducted during the Higg FEM reporting year.
What is the intent of the question?
The intent of this question is for factories to demonstrate that their environmental management system is reviewed on an annual basis with facility management team(s).
Technical Guidance
Conducting a management review of environmental management systems and programs is an important part of the plan, do, check, and act (PDCA) management system model to review performance and create action plans to drive improvement. Having a defined schedule for regular management meetings to discuss performance is recommended (e.g., on quarterly basis). At least one full management review is recommended annually. The meeting should review environmental information such as legal compliance, environmental performance, status of objectives and targets, status of preventive & corrective actions (including those from internal/external audits, incidents, accidents, emergency drills etc, recommendations for improvements, etc.)
Recognized environmental management system certification schemes (such as ISO 14001) include key objectives and processes for management systems reviews. Key areas that should be covered in a successful management review include:
- Results of internal audits, legal compliance, and other requirements to which the organization subscribes.
- Communication from external parties
- Environmental performance
- Progress of objective and targets
- Progress of corrective actions
- Follow-up actions from previous management review
- Changing circumstances including the update of legal requirements
- Recommendations for improvement
Resources:
- ISO 14001:2015 Environmental management systems — Requirements with guidance for use https://www.iso.org/standard/60857.html
- EU Eco-Management and Audit Scheme (EMAS) https://green-business.ec.europa.eu/eco-management-and-audit-scheme-emas_en
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates the facility has conducted a management review of the facility’s environmental management system in the FEM reporting year. This may include:
- EMS management review meeting plan/agenda
- Meeting minutes and/or attendance records
- Meeting outcomes (e.g., action plan updated environmental strategy, objectives, or targets, etc.)
Interview Questions to Ask:
- Staff responsible for the facility’s environmental management system should be able to explain the facility’s procedures for management review of the environmental management system and programs.
- Facility management should be able to explain how they participate in the management reviews.
Inspection – Things to Physically Look For:
- Where applicable, onsite observations indicate that management reviews are conducted of the facility’s environmental management systems (e.g., posted meeting minutes or outcomes of management review meetings)
Partial Points: N/A
Answer
Answer
Answer Yes if: Your facility is meeting all of the criteria below:
- Your facility has evaluated and defined the technical competencies and qualifications required to manage your facility’s environmental programs.
- Your current staff responsible for managing environmental programs meets the defined qualifications.
- Competency needs are evaluated on an annual basis to evaluate staff performance and competency and to identify needs for further professional development (e.g., obtaining additional certification or accreditation, attending professional development trainings, etc).
Answer Partial Yes if: Your facility has evaluated and defined the technical competencies and qualifications required for staff member responsible for managing your facility’s environmental programs, however your current staff do not meet the defined qualifications and/or competency needs are not evaluated on an annual basis to determine whether staff are qualified or require further professional development.
If you select Yes or Partial Yes, you will be asked the following sub questions:
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- Documentation that demonstrates the facility has processes in place to ensure environmental staff have the required technical competencies/qualifications (e.g., list of environmental staff/roles with the required competencies or qualifications, job descriptions that include competencies for environmental management, competency/qualifications need assessment, copies of staff’s certifications or accreditations, etc.)
- Documentation that demonstrates competencies and professional development needs are reviewed on an annual basis (e.g., annual competency/qualification needs assessment, professional development plan for environmental staff, etc)
What is the intent of the question?
The intention of this question is for facilities to demonstrate that processes are in place to ensure staff responsible for managing environmental matters have appropriate technical competencies and qualifications to effectively manage the facility’s environmental programs and that this is reviewed on an annual basis.
Technical Guidance:
Managing environmental programs at a facility requires an in depth understanding of both technical environmental subject matter as well as how to implement an effective environmental management system. One of the major barriers to progress on environmental performance and sustainability is the lack of technical expertise. Having staff with strong technical expertise in relevant impact areas is crucial to a facility’s environmental management program.
A team with appropriate qualifications and knowledge, helps facilities better understand environmental risks and impacts, and helps to identify and implement appropriate measures to mitigate those risks and make improvements. Also, it helps ensure compliance with environmental regulations and other requirements, which are constantly evolving and becoming more complex.
Facilities should have a process in place to evaluate and define the specific experience and qualification requirements for environmental team members. This should include:
- Educational requirements (e.g., Tertiary degree in environmental related field)
- Certification or accreditation requirements (e.g., legally required environmental certifications, Certified Environmental Professional (CEP), ISO 14001 Auditor certification, etc.)
- Required training(s) from reputable training providers on specific environmental subject matter (e.g., Energy and GHG management, wastewater, or chemicals management, legally required trainings, etc)
It is also important for facilities to ensure that competency needs for environmental staff are regularly evaluated and that opportunities are available for environmental management staff to participate in professional development activities to enhance their knowledge on environmental management and technical subject matter such as attending external trainings, obtaining additional environmental certification or accreditation, etc.
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that are meeting all the criteria below:
- The facility has evaluated and defined the technical competencies and qualifications required to manage environmental programs.
- Current staff responsible for managing environmental programs meets the defined qualifications.
- Competency needs are evaluated on an annual basis to evaluate staff performance and competency and to identify needs for further professional development.
Documentation Required:
- Documentation that shows the facility has processes in place to ensure environmental management staff have the required technical competencies/qualifications. This may include:
- A list of environmental staff/roles with the required competencies or qualifications for each role.
- Job descriptions that include competencies for environmental management.
- Competency/qualifications needs assessment.
- Copies of certifications or accreditations for environmental management staff.
- Documentation that demonstrates competencies and professional development needs are reviewed on an annual basis. This may include:
- Annual competency/qualification needs assessment.
- Professional development plan for environmental staff.
- Meeting records of performance and/or competency evaluations.
Interview Questions to Ask:
- Staff responsible for recruiting environmental management staff are aware of the competency and qualification requirements for environmental staff and can explain how the facility ensures qualified staff are recruited for environmental management roles.
- Relevant environmental staff can demonstrate their knowledge and expertise related to the areas of environmental management they oversee.
- Relevant staff can explain the facility’s procedures for reviewing competency/qualification requirements and professional development needs for environmental management staff.
Inspection – Things to Physically Look For:
- Onsite observations indicate that environmental programs are being managed by staff with appropriate technical competency and qualifications (e.g., Certifications or trainings provided are for the individuals responsible for environmental management, environmental management staff’s ability to demonstrate technical understanding on environmental subject matter throughout the verification, etc.)
Partial Points:
Partial points will be awarded for facilities that have evaluated and defined the technical competencies and qualifications required for staff member responsible for managing environmental programs, however current staff do not meet the defined qualifications and/or competency needs are not evaluated on an annual basis to determine whether staff are qualified or require further professional development.
Answer
Answer
Answer Yes if: Your facility has a documented program for communicating awareness on your facility’s environmental impacts and performance to all employees and this is communicated to all employees on an annual or more frequent basis.
Answer Partial Yes if: Your facility has a documented program for communicating awareness on your facility’s environmental impacts and performance, but this has not been communicated to all employees or your facility is in the process of developing a communication program.
Note: This communication program must be in addition to basic environmental training for staff on their roles and responsibilities covered in level 1 and specifically include awareness on the facility’s environmental impacts and performance (e.g., performance on environmental KPIs and/or progress on the facility’s environmental strategy)
If you select Yes, you will be asked the following sub questions:
- Please upload documentation, if available
- If you cannot upload the documents, please describe here:
Suggested Uploads:
- Documentation that shows your facility has a communication plan in place that focuses on providing awareness on the facility’s environmental impacts and performance, and that communication was provided to all employees (e.g., Environmental performance communication plan and schedule, communication materials such as presentations, bulletins, newsletters, meeting agendas/minutes, etc)
What is the intent of the question?
The intent of this question is for facilities to have a formal program to communicate environmental performance and strategy to inform and motivate employees to support the facility’s environmental strategy.
Technical Guidance:
Clearly communicating a facility’s environmental management programs and performance to its workforce is a key to its success. The more involved employees are, the more committed they will be which can increase the effectiveness of environmental programs and performance.
Communicating environmental impacts and performance to employees can be done in a number of ways including training/presentations, meetings, bulletin boards, newsletters, posters, or other established communication channels at the facility.
Regardless of the mode(s) of communications used, a communication plan and procedures should be established to ensure that information is communicated in a clear and consistent way that provides employees with key information on the facility’s environmental programs, performance, and strategy. Some key areas to include in employee communications include:
- Information on the environmental aspects and impacts of the facility
- Information on the facility’s environmental strategy and updates on the facility’s progress on environmental objective and targets
- Information on any key performance indicators (KPIs) or metrics used to monitor the facility’s environmental performance.
- Information on how employees can participate in environmental programs and the benefits of doing so.
- Information on how employees can communicate suggestions for environmental improvements.
How This Will Be Verified:
Full Points:
Full Points will be awarded for facilities that have a documented program for communicating awareness of environmental impacts and performance to all employees and this is communicated to all employees on an annual or more frequent basis.
Documentation Required
- Documentation that shows the facility has an established communication program and that communication to all employees occurs on an annual basis or more frequent. This may include:
- Environmental performance communication plan and schedule
- Communication materials such as presentations, bulletins, newsletters, meeting agendas/minutes.
- Records that demonstrate information on environmental impacts and performance had been provided to workers where applicable (e.g., meeting attendance records, past bulletins, or newsletters, etc.).
Interview Questions to Ask
- Staff responsible for the communication program can describe what information is communicated with employees and how it is communicated.
- Employees can demonstrate awareness of the facility’s environmental impacts, performance, strategy and KPIs.
Inspection – Things to Physically Look For
- Observations indicate the communication program has been implemented per the documented and reported communication procedures (e.g., awareness posters or bulletins, visible postings of the facility’s environmental performance and strategy, etc.)
Partial Points:
- Partial points will be awarded for facilities that have a documented program for communicating awareness on your facility’s environmental impacts and performance, but this has not been communicated to all employees or your facility is in the process of developing a communication program.
EMS – Level 3
Answer
Answer
Answer Yes if: Your facility engages all subcontractors to improve environmental performance using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and can demonstrate that improvements have been made in subcontractor environmental performance.
Answer Partial Yes if: Your facility engages with at least one (1), but not all subcontractors to improve environmental performance using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and has procedures to monitor and track subcontractor performance, but cannot demonstrate that improvements have been made in subcontractor environmental performance.
Answer Not Applicable if: Your facility does not use any subcontractors.
Notes:
- The scope of subcontractors for this question refers to subcontractors used for production (e.g., a separate business entity used to perform a specific process or manufacturing step to produce a final product such as garment dyeing, embroidery, and screen-printing tasks, etc.)
- If the engagement only requires subcontractors to complete an assessment, but there is no follow-up monitoring or reporting of improvements at the subcontractor required, you should answer No to this question. (e.g., if the subcontractor is only required to share their Higg FEM module and your facility does not follow-up to provide support or require and track improvements)
If you select Yes or Partial Yes, you will be asked the following sub questions:
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here:
Suggested Uploads:
- Documentation that demonstrates your facility has engaged with subcontractors using the Higg FEM or other environmental assessment scheme (e.g., list of subcontractors, evidence of FEM module sharing, other environmental assessment reports)
- Documentation that shows this engagement has resulted in environmental performance improvements at the subcontractor (e.g., records of the facility’s monitoring or tracking of subcontractor improvements plans, corrective action support or requests from the facility, completed improvement actions plans from subcontractors, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they leverage the Higg FEM or other environmental assessment to work with subcontractors to evaluate their performance, monitor impacts, and make improvements.
Technical Guidance:
The environmental footprint and impacts of the products you produce includes your subcontractors’ activities. Engaging with subcontractors using an established environmental assessment scheme will help to understand environmental performance at subcontractor facilities and identify areas where your company can support and drive improvements.
Subcontractor engagement programs should include procedures for requiring subcontractors to perform assessment of current environmental practices and report improvement plans and/or actions to demonstrate improvements. Facilities should also have established procedures to monitor and track subcontractor improvements over time.
Expectations and requirements for subcontractors’ environmental programs can also be included in the terms and conditions of contractual agreements to ensure the subcontractors clearly understand and are held accountable to these expectations.
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have engaged with all subcontractors using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and can demonstrate that improvements have been made in subcontractor environmental performance.
Documentation Required:
- Documentation that shows your facility has engaged with subcontractors using the Higg FEM or other environmental assessment scheme. This may include:
- Subcontractor engagement procedures or business agreements/contracts with environmental performance terms.
- List of all subcontractors that your facility conducts business with.
- Evidence of FEM module sharing or other environmental assessment reports.
- Other relevant communications with subcontractors related to engagement on environmental performance.
- If applicable, documentation that shows environmental performance improvements at the subcontractor. This may include:
- Records of the facility’s monitoring or tracking of subcontractor improvements plans.
- Completed improvement actions plans from subcontractors.
- Other relevant communications with subcontractors related to environmental improvements.
Interview Questions to Ask:
- Staff responsible for managing the subcontractor engagement program are able to describe:
- How the facility engages with subcontractors.
- The facility’s procedures for how subcontractor performance and improvement are monitored.
- Staff responsible for managing the subcontractor engagement program are able to describe:
- How they facility uses subcontractor Higg FEM or other environmental assessment results to drive environmental improvements.
Inspection – Things to Physically Look For:
- Observations are consistent with the reported subcontractor engagement program (e.g., evidence of subcontracted processes are consistent with the reported subcontractors used by the facility, etc)
Partial Points:
Partial points will be awarded for facilities that have engaged with at least one (1), but not all subcontractors using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and have procedures to monitor and track subcontractor performance, but cannot demonstrate that improvements have been made in subcontractor environmental performance.
Answer
Answer
Answer Yes if: Your facility engages with one (1) or more upstream suppliers to improve environmental performance using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc.) and can demonstrate that improvements have been made in upstream supplier environmental performance.
Answer Partial Yes if: Your facility engages with one (1) or more upstream suppliers using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc.) and has procedures to monitors and track performance, but cannot demonstrate that improvements have been made in upstream supplier environmental performance.
Note: If the engagement only requires upstream suppliers to complete an assessment, but there is no follow-up monitoring or reporting of improvements required, you should answer No to this question. (e.g., if the upstream supplier is only required to share their Higg FEM module and your facility does not follow-up to provide support or require and track improvements)
If you select Yes or Partial Yes, you will be asked the following sub questions to provide details on your upstream supplier engagement:
- Which types of suppliers are assessed/engaged?
- Chemical suppliers
- Raw material suppliers (i.e., suppliers of raw materials other than chemicals)
- Component suppliers (i.e., suppliers of premade/assembled components such as zippers, buttons, etc)
- Other suppliers
- For each, describe the engagement activities and the resulting environmental benefits.
- Please upload documentation, if available
Suggested Uploads:
- Documentation that demonstrates your facility has engaged with upstream suppliers using the Higg FEM or other environmental assessment scheme (e.g., list of upstream suppliers, evidence of FEM module sharing, other environmental assessment reports)
- Documentation that shows this engagement has resulted in environmental performance improvements at the upstream supplier (e.g., records of the facility’s monitoring or tracking of upstream supplier improvements plans, corrective action support or requests from the facility, completed improvement actions plans from upstream supplier, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they leverage the Higg FEM or other environmental assessment to work with upstream suppliers to evaluate their performance, monitor impacts, and make improvements.
Technical Guidance:
The environmental footprint and impacts of the products you produce includes your upstream suppliers’ activities. Engaging with upstream suppliers using an established environmental assessment scheme will help to understand environmental performance at upstream supplier facilities and identify areas where your company can support and drive improvements.
Upstream supplier engagement programs should include procedures for requiring upstream suppliers to perform assessment of current environmental practices and report improvement plans and/or actions to demonstrate improvements. Facilities should also have established procedures to monitor and track upstream supplier improvements over time.
Expectations and requirements for s upstream suppliers’ environmental programs can also be included in the terms and conditions of contractual agreements to ensure the upstream suppliers clearly understand and are held accountable to these expectations.
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have engaged with one (1) or more upstream suppliers using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and can demonstrate that improvements have been made in upstream supplier environmental performance.
Documentation Required:
- Documentation that shows your facility has engaged with s upstream suppliers using the Higg FEM or other environmental assessment scheme. This may include:
- Upstream supplier engagement procedures or business agreements/contracts with environmental performance terms.
- List of all upstream suppliers that your facility conducts business with.
- Evidence of FEM module sharing or other environmental assessment reports.
- Other relevant communications with upstream suppliers related to engagement on environmental performance.
- If applicable, documentation that shows environmental performance improvements at the upstream supplier. This may include:
- Records of the facility’s monitoring or tracking of upstream supplier improvements plans.
- Completed improvement actions plans from upstream supplier.
- Other relevant communications with upstream suppliers related to environmental improvements.
Interview Questions to Ask:
- Staff responsible for managing the upstream supplier engagement program are able to describe:
- How the facility engages with upstream suppliers.
- The facility’s procedures for how upstream supplier performance and improvement are monitored.
- Staff responsible for managing the upstream supplier engagement program are able to describe:
- How the facility uses upstream suppliers’ Higg FEM or other environmental assessment results to drive environmental improvements.
Inspection – Things to Physically Look For:
- Observations are consistent with the reported upstream supplier engagement program (e.g., evidence of supplied chemicals, raw materials, and/or components are consistent with the reported upstream suppliers used by the facility, etc.)
Partial Points:
Partial points will be awarded for facilities that have engaged with one (1) or more upstream suppliers using the Higg Index or other related environmental assessment scheme (e.g., ISO14001, Amfori BEPI, etc) and have procedures to monitor and track upstream supplier performance, but cannot demonstrate that improvements have been made in upstream supplier environmental performance.
Answer
Answer
Answer
Answer
Answer Yes if: Your facility has engaged with local stakeholders in your facility’s local community and have contributed and/or participated in one (1) or more projects, worked with local stakeholder, business, or government agency working group(s) on environmental management improvements in the Higg FEM reporting year and have supporting documentation to demonstrate this engagement.
Note: If the facility is part of a manufacturing group and the engagement is initiated and/or coordinated by the manufacturing group, facilities can answer Yes, if the facility actively contributes to the engagement by providing resources (e.g. staff participation or financial support)
If you select Yes, you will be asked to select the ways in which your facility engages in environmental improvement and provide additional details for each type of engagement using the options listed below:
- We support (financially or otherwise) conservation or improvement projects for 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
Suggested Uploads:
- Documentation that demonstrates how your facility has contributed or participated in activities focused on environmental improvement in your local community in the Higg FEM reporting year (e.g., lists of activities and stakeholders with dates of engagement, pictures, articles or press releases; list of organizations/initiatives your facility support, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are actively engaging with local businesses, organizations, NGOs, and/or community groups to contribute and/or participate in initiatives to make environmental improvements in the communities where they operate.
Technical Guidance:
Engaging with local community stakeholders is important because your facility has a direct impact on the local environment your facility operates in and working collaboratively with local businesses and organizations (e.g. government agency, NGOs, community environmental groups) can create a shared focus and resources to make environmental improvement in the community.
Facilities can engage with the local community in a number of ways. A list of some examples of engagement activities are provided below:
- Support conservation or improvement projects for environmental issues. For example:
- Organize/support local waste or river clean-ups for the community
- Organize/support wetland preservation projects
- Organize local fundraisers for environmental non-profits or community groups.
- Organize/support educational events for children to start environmental stewardship.
- Work with other similar businesses to share best practice for environmental management. For example:
- Establish collaborative working groups with local manufacturers to share best practices for environmental management and/or protection.
- Work within a group of other local stakeholders including government and communities, to understand and address local environmental issues. For example:
- Provide waste disposal opportunities such waste collection facilities to the community to support the proper disposal of household hazardous waste or electronic waste.
- Engage directly with local or national governance bodies on environmental regulation or management issues
- Facilitate regular meetings with local or national government agencies to review and support policy and regulatory developments to protect the environment.
- Work together in a group with other local stakeholders, to engage with local or national governance bodies on environmental regulation or management issues. For example:
- Attend or facilitate regular meetings with other manufacturing stakeholder groups and local or national government agencies to review and support policy and regulatory developments to protect the environment
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows the facility contributed or participated in activities focused on environmental improvement in the local community in the Higg FEM reporting year. This may include:
- List of engagement activities and stakeholders with dates of engagement.
- Evidence of funding or donations to local charities or environmental groups.
- Records of participation in local environmental initiatives (e.g., newspaper articles, pamphlets, or photo evidence of local community involvement)
- Records of environmental policy collaboration with local government agencies.
- Other relevant documentation of local stakeholder engagement and/or environmental improvements.
Interview Questions to Ask:
- Staff responsible for management external stakeholder engagement are able to explain how and who they engage with on environmental improvement in the community.
Inspection – Things to Physically Look For:
- Where applicable, observations onsite are consistent with the reported engagement activities (e.g., community waste disposal facilities onsite, evidence posted in the facility such as event photos, newspaper articles showing the facility’s engagement, etc.)
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