Air Emissions 2021

General Introduction

We have all seen smog clouds over cities and know that pollution is unhealthy for humans and the environment. This visible smog is one result of air emissions from your facility, but Industrial processes and operations also emit other invisible pollutants into the air that impact human health and contribute to climate change.

Air emissions are commonly generated from:

  • Facility operations: boilers, generators, and cooling systems (typically emit dust/particulates (PM10, PM2.5), various oxides of nitrogen (“NOx”), various oxides of Sulphur (“SOx”), ozone depleting substances (“ODS”) and other toxic air pollutants).
  • Production processes: production line equipment and manufacturing processes (typically emit volatile organic compounds (“VOCs”), ozone depleting substances (“ODS”), dust/particulates (PM10, PM2.5), and other toxic air pollutants).

IMPORTANT NOTE: You will be asked to select which air-emitting operations or processes you have on-site below. These selections will direct you to the questions that are most applicable for your facility. If you don’t have any facility air emissions from operations or production, you will not need to complete this section.

The Higg Air Emissions section requires you to:

  • Track quantity of emissions from facility operations and refrigeration, if applicable.
  • IMPORTANT NOTE: 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 so please try to accurately report refrigerant tracking.
  • Track quantity of emissions from production processes, if applicable.
  • List control devices / abatement processes and monitoring frequency for operating and refrigeration
  • List control devices / abatement processes and monitoring frequency for production
  • 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.

REMEMBER: Most fugitive releases of air pollution from refrigerants are due to breaks or leaks in equipment. The equipment maintenance question you were asked in the Environmental Management System section is relevant to this section as preventative maintenance is one of the best ways to prevent fugitive emissions.

Air Emissions Introduction

Facility air emissions are commonly generated from:

  • Your production processes: production line equipment and manufacturing processes
  • Your facility operations: boilers, generators, and cooling systems

 

Types of emissions include:

  • Point Source Emissions – air flow which is controlled in some way and released into the atmosphere from a single source such as stack. These emissions can be facilities related, such as emissions from boilers, or process related, such as exhaust systems for volatile chemical use.
  • Non-Point Source or Fugitive Emissions – for the Higg FEM, these sources of air emissions are those that are released into the general indoor or outdoor environment. These types of emissions are typically process related such as screen printing, spot cleaning, dyeing, etc.). 

Anyone of the emissions sources may have several discharge points at a single facility. For example, a facility may have multiple boilers or multiple point-source process emissions stacks.

These are the common pollutants released into the air by these activities:

  • Acid fumes
  • dust/particulates (PM10, PM2.5) – typically associated with fuel combustion, yarn spinning, synthetic fiber manufacturing, casting
  • various oxides of nitrogen (“NOx”) – typically associated with fuel combustion
  • various oxides of Sulphur (“SOx”) – typically associated with fuel combustion
  • volatile organic compounds (“VOCs”) – typically associated with fabric finishes, solvents, adhesives, fabric printing, tenterframes, degreasing operations
  • ozone depleting substances (“ODS”) – commonly found in refrigerants, many apparel spot cleaners, and some adhesives and solvents
  • hazardous or toxic air pollutants – typically associated with fuel combustion, solvents, adhesives, and some apparel finishes, metal plating
  • Regulated cotton dust emission from spinning, slashing, and weaving
  • Fumes: Painting and plastic injection molding

For a given source of emissions (e.g. boiler operations, multiple production lines or processes), there may be several emissions or discharge points. Your factory’s emissions points are your greatest opportunity for controlling the air pollutants released by your factory. Here are the most common discharge points for air emissions:

  • Stacks, chimneys, or vents (from production equipment or dorm services, such as a kitchen)
  • Open tanks
  • Handling or moving dusty materials
  • Solvent applications

Managing air emissions requires a different approach than managing energy, water, and waste. Air emissions are regulated to a set level, while energy, water, and waste can be continuously improved.

Your factory’s air performance really depends on the equipment you have. If you have older or poorly maintained equipment, you have a greater risk of air emissions. The best thing you can do to ensure good air emissions management is to upgrade to modern equipment and have a strict process for maintaining and monitoring existing equipment.

If CFCs and HCFCs (ozone depleting substances) are used on-site, solutions to phase out these gases should be considered. One solution is to use chemicals with low-GWP such as HFO’s in the applications of refrigerants, aerosol propellants and foam blowing agents. Please refer to the following list of refrigerants with reference numbers to determine which of your refrigerants are important to track and phase out: https://www.ashrae.org/standards-research–technology/standards–guidelines/standards-activities/ashrae-refrigerant-designations.

How will Higg assist you in improvement?

To take action on air emissions, there are several important things for you to have in place:

  1. You must know your local rules/permit requirements, know how the monitoring/enforcement process works, and have a process in place to demonstrate compliance (Higg FEM Permits section and EMS section)
  2. You must know your factory’s sources of air emissions (Higg FEM Applicability Test)
  3. You must track the air pollutants that your factory emits (Higg FEM Level 1)
  4. You must install control devices and/or upgrade to modern equipment (e.g., modern boiler) to ensure compliance/standard is met or exceeded (Higg FEM Level 1)

Air emissions are often dependent on your specific technologies and machines; therefore, it is important to maintain and upgrade equipment. There is not yet a standard to guide you on which technologies are associated with which reduced emissions, but Higg FEM questions prepare you to take the most direct actions to manage your emissions. Knowing how to maintain equipment is a job best suited for a trained technical expert on-site.

Abatement technologies could be:

  • Absorption
  • Activated carbon filter
  • Cyclone
  • Dust bag filter
  • Electrostatic precipitator
  • Scrubber
  • Selective catalytic reaction
  • Selective non-catalytic reaction

GHG emissions are not limited to energy use and fuel consumption, but also result from emissions as a result of production processes. The Air section of the Facility Environmental Module measures the GHG emissions that are not linked to fuel combustion. If your factory emits GHG gases from non-combustion sources such as HFCs (e.g. leakage of refrigerants and release of HFs in aerosol propellants and foam blowing agents) and control devices for production emissions, Higg Index will help you calculate GHG emissions as part of the GHG footprint.

Tracking and Reporting Air Emissions in Higg FEM

Accurately tracking and reporting air emissions data over time 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 air emissions and identify the specific actions that will help reduce environmental impacts.

When establishing an air emissions tracking and reporting program, the following principles should be applied:

  • Completeness – The tracking and reporting program should include all relevant sources (as listed in the FEM).
  • Accuracy – Ensure that the data input into the air emissions tracking program is accurate and is derived from credible sources (e.g. emissions testing or continuous monitoring systems that are based on established scientific measurement principles or engineering estimates, etc.)
  • Consistency – Use consistent methodologies to track air emissions data that allows for comparisons of emissions over time. If there are any changes in the tracking methods, sources, or other operations that impact air emissions data, this should be documented.
  • Transparency – All data sources (e.g., testing reports), assumptions used (e.g., estimation techniques), and calculation methodologies should be disclosed in data inventories and be readily verifiable via documented records and supporting evidence.
  • Data Quality Management – Quality assurance activities (internal or external) should be defined and performed on air emissions data as well as the processes used to collect and track data to ensure reported data is accurate.

The above principles are adapted from The Greenhouse Gas Protocol – Chapter 1: GHG Accounting and Reporting Principles.

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. Air emissions can be from materials processing equipment AND/OR boilers that generate steam for operations.

 

You will first be asked to select which operations or processes are present in your factory. These selections will direct you to the Higg questions that are most applicable for your facility

  • If you have any air-emitting operations (e.g., boiler), 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 Level 1
  • If you don’t have any facility operation or production air emissions, you do not need to complete this section.

1. Does your facility contain any of the following operations equipment?

  •  Boiler
    • If selected, tell us size:
      • Small: less than 50 MW
      • Medium: 50 MW – 300 MW
      • Large: more than 300 MW
    • Generators
    • Combustion Engines (e.g. gasoline powered pumps)
    • Industrial Ovens (for heating/drying/curing)
    • Combustion Heating (Furnace) and ventilation
    • Refrigerant containing device (other than air conditioning system)
    • Air conditioning (Cooling)
    • Other sources of known air emissions from facility operations
    • Other sources of volatile organic compounds (VOCs)

2. Does your facility conduct any of the following processes or use any of the following substances?

  • Yarn spinning or synthetic fiber manufacturing
  • Finishes (any mechanical or chemical process that occurs after dying to affect the look, performance, or feel of the product)
  • Solvents
  • Adhesives/cementing
  • Printing
  • Dyeing
  • Tenterframes or other heating processes
  • Spot cleaners (*Spot cleaners are chemicals used to remove contaminated spots from final products such as garments, bed covers, shoes etc. In many cases, acetone-based chemicals are used as spot cleaners. Spot cleaning activity may be done on line during production process, or a facility may have a dedicated room for spot cleaning.)
  • Sprayed chemicals or paints
  • Other sources of ozone depleting substances (ODSs)

3. Does your facility monitor air emissions?

Air Emission – Level 1

Questions

Select all sources of air emissions relevant to your facility’s operations

Please enter data for all air emissions. Please select all pollutants that may be associated with the same emission source. This question excludes emissions from production processes.

  • Source
  • Are there emissions from this source?
  • Do you track emissions from this source?
  • What equipment is this source linked to?
  • What pollutants are found in this source?
  • Are pollutants regulated by a government agency?
  • If the pollutant is regulated by a permit, is it in compliance with the permit?
  • If your facility is out of compliance, update the action plan for the substance detected
  • If you cannot upload a copy, please describe the action plan
  • If applicable, upload emissions test report(s).
  • Additional comments

Note: In the future version, Higg FEM will require detailed tracking and reporting of emissions data and the below technical guidance and verification requirements are provided for reference.

What is the intent of the question?

The intent of this question is to have facilities report air emission from on-site operations. This question should drive you to inventory all possible sources of emissions to air from operations on-site.

Technical Guidance

Air emissions are measured and regulated in different ways, which are summarized below. When evaluating whether your emissions are in compliance, the following types of standards may need to be considered:

Air quality standards: These are the quality guidelines, often associated with human health within an airshed. Good examples are the U.S. National Ambient Air Quality Standards (https://www.epa.gov/criteria-air-pollutants/naaqs-table), the Chinese Ambient Air Quality Standards (GB 3095-2012), and the World Health Organization air quality guidelines (https://www.who.int/airpollution/guidelines/en/ ). Facilities should not have emissions that result in pollutant concentrations that reach or exceed relevant ambient quality guidelines or contribute a significant portion to the attainment of relevant ambient air quality guidelines. That can only be determined by estimating through qualitative or quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models to assess potential ground level concentrations. Some countries utilize ground level concentration measurements for regulatory assessment (permitting).

Emission standards (concentration): Air pollution limits are sometimes concentration limits (e.g. ppm, mg/m3). Regulatory authorities may set maximum emissions concentrations based upon overall goals to reduce air pollution. For example, for automobiles, governments may regulate concentration limits measured at the exhaust. The same is true for most small combustion facilities (e.g. boiler), which have emissions standards in concentrations (e.g. gas boiler is limited to NOx concentration of 320 ppm measured in stack). Permits for these small facilities may also be based on concentrations measured in the stack. These are not quantities, but may be useful in calculations or estimations of quantity, especially when flow rates are known.

Emissions standards (quantity): Air pollution limits may also be measured by the actual quantity of emissions from a source. Some regulatory authorities limit the annual quantity of emissions from a whole facility, however, others apply to point source emissions that are specifically defined or identified by regulation or other requirements. Quantity is the total quantity of emissions that ultimately have the impact on the environment.

Regulatory requirements for monitoring of emissions varies depending on local regulatory requirements. Data about emissions and ambient air quality generated through your monitoring program should be representative of the emissions discharged by the facility and process over time. For example, data should account for time-dependent variations in the manufacturing process such as batch process manufacturing and seasonal process variations. Emissions from highly variable processes may need to be sampled more frequently or through composite methods. Emissions monitoring frequency and duration may also range from continuous for some combustion process operating parameters or inputs (e.g. the quality of fuel) to less frequent, monthly, quarterly or yearly stack tests. Annual quantities of emissions from variable sources may also need to be determined using engineering estimates or modelling based on the process inputs (e.g. the amount and types of chemicals used in the process).

Creating an Air Emissions Inventory:

An air inventory is needed for the facility to track and manage emissions and their sources. To prepare a facilities inventory, emissions from all ancillary activities and equipment should be included. Regular review should be carried out to make sure the inventory is up-to-date. This inventory should include emissions sources regulated by permit as well as those not currently regulated.

The following elements are suggested to be included in the inventory (source: GSCP):

  • Pollutants known or likely to be present
  • Quantity of each pollutant emitted
  • Emissions/discharge points
  • Control devices and their operating parameters
  • Frequency of monitoring
  • Compliance with legal regulations

An example inventory can be downloaded here: https://www.sumerra.com/wp-content/uploads/Air-Emissions-Inventory.xlsx

Emission testing (concentration): Emissions testing is sometimes regulated by concentration, which requires certain test locations to fall below a given emissions per time. Testing shall be done during representative operating scenarios, and non-standard testing or calculations can be considered separately.  Each test method and/or equipment used to determine emissions likely has a minimum time and/or repeat test requirement, and these statistical variations shall be considered. 

Emissions testing may be used to calculate the quantity of emissions through continuous monitoring, or through discrete testing during representative operating scenarios and extrapolating over the course of one-year or standard operation through calculations.  Each test method and/or equipment used to determine emissions likely has a minimum time and/or repeat test requirement, and these statistical variations shall be considered. 

Emissions estimation (quantity): For each source of emissions, a quantity for each relevant pollutant should be calculated. Facilities can estimate their emissions quantities using one of the emission estimation techniques available.

Multiple discharge points from a type of emissions source (e.g. boilers or multiple solvent application processes) can be considered a single emissions source for the purposes of reporting, or may be separated by each location. The appropriate methodology should be applied by qualified individuals such as a process or environmental engineer.

Reporting Air Emissions from Operations in the FEM:

Before reporting air emissions data in the FEM from facility operations sources, data quality checks should be performed to ensure that the data AND the processes used to calculate, and track emissions data are effective at producing accurate air emissions data.

Note: The methodology used to determine emissions from each source should be selected and applied by qualified individuals such as a process or environmental engineer.

  • For each source, pollutant emission quantities should be calculated. This can be done using emissions testing data and/or engineering estimates.
  • If the source is not regulated by a permit or not in compliance with its required permit, the emission data from the source should be included in the Question 1 data table.
  • List the equipment that the emissions are linked to. Note: If there is more than one source, list all sources (e.g., Boiler 1 and Boiler 2)
  • Select the pollutants that are not regulated by a permit or are out of compliance from the dropdown list. Note: If other is selected, please provide a description in the “Additional Comments” field.
  • List the quantity of pollutants emitted from the source(s). The quantities of each pollutant should be added together and entered in the Higg FEM.. Multiple discharge points from a type of emission source (e.g. boilers, generators, etc.) can be considered a single emissions source for the purposes of reporting in the FEM.
    • Note: If the emission quantity is listed as a concentration (e.g. PPM or mg/m3), exhaust flow data for the source(s) should be entered in the table.
  • If applicable, report the testing method or equipment used to test the source (e.g. USEPA method 5 for Particulate Matter or Real-Time Continuous Emission Monitoring System for NOx, etc.)

Add notes in the “Additional Comments” field to describe any data assumptions, estimation methodology, or other relevant comments on the quantities of pollutants emitted for the source(s).

How This Will Be Verified:

When verifying a facility’s air emissions data, Verifiers must review all aspects of the facility’s emissions tracking and reporting program that could produce inaccuracies including:

  • Emissions data sources (e.g., testing reports, emissions modelling or other engineering estimates); and
  • The process and tools used to aggregate the data (e.g. spreadsheet calculations, unit conversions, etc.)

If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.

Full Points

Documentation Required:

  • An inventory of emissions to air for ALL sources related to facility operations.
  • Emission testing/monitoring reports. Testing data compiled in a spreadsheet (e.g. Excel) is ok as long as the testing reports are available for review as well as the data matches the reported information to all questions answered.
  • Emission estimation methodology/calculations documented where applicable.
  • Information entered into Higg for each emission source can be verified with appropriate evidence such as equipment sources and quantity of emissions.

Interview Questions to Ask:

  • Management is able to explain the list of sources for emissions to air and how they inventory each source including the methodology for any emissions estimates.

Inspection – Things to Physically Look For:

  • Onsite evaluation of air emission sources listed.
  • Ensure all applicable equipment is listed on sources list.

Partial Points

Documentation Required:

  • Compliance issue documentation from permitting office shows that the issue(s) is less than three months old.
  • An action plan is completed for any emissions source found out of compliance.

Interview Questions to Ask:

  • Management can explain the source of non-compliance and their plans for coming back into compliance.

Inspection – Things to Physically Look For:

  • Any improvements made, or work done to address any non-compliances. Please take pictures.

Select all sources of air emissions that result from production processes

  • Processes Selected
  • Are there emissions from this source?
  • Emissions source title
  • Do you track emissions from this source?
  • What pollutants are found in this source?
  • Are pollutants regulated by a government agency?
  • If the pollutant is regulated by a permit, is it in compliance with the permit?
  • If your facility is out of compliance, update the action plan for the substance detected
  • If you cannot upload a copy, please describe the action plan
  • If applicable, upload emissions test report(s).
  • Additional comments

This question tracks the presence of indoor air quality emissions from production processes. This includes fugitive sources from production processes (sources without a chimney that emit into the building outside through windows, doors, etc.).

Note: In the future version, Higg FEM will require detailed tracking and reporting of emissions data and the below technical guidance and verification requirements are provided for reference.

What is the intent of the question?

The intention of this question is for your facility to know the sources of process air emissions to put necessary action and abatement in place to monitor and control them.

Technical Guidance:

All process emissions should be tracked, regardless of if they are captured and discharged in a stack/chimney. These may include non-point sources such as drying rooms, or fugitive emissions such as outdoor dust.

The following elements are suggested to be included in the inventory (GSCP):

  • The pollutants known or likely to be present
  • The estimated quantity emitted
  • Emissions/discharge points or locations, if applicable
  • Any control devices, if applicable
  • Monitoring conducted
  • Compliance with legal regulations, if applicable

Non-point source emissions may require a different methodology to determine the amount of pollutants emitted. Note that specific regulatory calculation or reporting methodology may be applicable for fugitive sources.  Additional explanation and examples of how air emission can be determined are listed below:

  1. Inventory-based (Potential to Emit, PTE)
    • A Potential To Emit looks at inventories for all air emissions including energy generation and process chemistry to establish the maximum amount that could be emitted from that facility. For example, if 1 ton of IPA was purchased, 1 ton of IPA could potentially be emitted to the air.  This is generally a very conservative assumption and gives the maximum potential of emissions from a site.
    • To provide a conservative estimate when calculating or reporting air emissions quantities, it is often estimated that 100% of the volatile pollutants will be emitted to the environment. If a percent composition range is provided (i.e. on and SDS) the upper part of the range can be used
  2. Inventory-based (Potential to Emit + Mass Balance and/or Abatement)
    • Once a PTE analysis is completed, mass balance and/or abatement assumptions may be added. For example, if 1 Ton of IPA was purchased, yet 0.25 tons went to solvent recovery, we could assume a maximum of 0.75 tons would be emitted to air.  However, if a thermal oxidizer was used to abate the 0.75 tons at a 90% efficiency, we would calculate that only 0.075 tons would be emitted to air.  This same technique can be applied for many different uses of mass balance including re-use, wastewater, and other waste types.
  3. Emissions Factor-based (Factory or Offsite Testing)
    • Emissions factors represent standard rates of emissions given a certain process. For example, a process using a recipe of 1kg of chemical may be tested to show that only 0.05kg is released to air each time that recipe is run.  If that’s the case, then for every 1kg of chemical used on that process step and on that specific tool, 0.05kg can be multiplied to get the total emissions.  These types of testing may be done onsite or offsite by a 3rd  Please note that the general recipe and tool must be the same or similar enough to generate the same emissions for this factor to be used.  Sometimes, for a given facility, hundreds or even thousands of emissions factors are needed to represent their operations.  All testing and documentation must be available to utilize this method.  Where recipes and tool designs do not change frequently, or when similar recipes are used over a long time, this may be a very cost effective way to estimate emissions to prevent repetitive emissions testing.

The chosen emission estimation method must be applicable to the source type (e.g. for intermittent activities or high change over with different chemistries the quantity could be estimated based on consumption of solvents annually for that process).

Mass Balance Example: Emissions may be estimated based on the chemical composition of materials used (i.e. percentage of VOC content or individual pollutant) and how much of the chemical is used annually (i.e. liters/year).

As an example, A total of 100 L of acetone is used for spot cleaning on an annual basis. The density of acetone is 784 kg/m3.  If we assume 50% is collected as waste and 50% is emitted to the environment, we could calculate that 50 L X (784 kg/m3/1000 L/m3) = 39.2 kg of acetone is emitted to air annually.

Another example: If the VOC content in a chemical was 5g/L and the facility used 1,000L annually, yet abatement was applied at 90% efficiency, the annual emissions would be 5,000g*(10%) = 500g emitted.

In some cases, emissions factors can be used. For example, if known quantities of a nitrogen containing chemical are mixed with another non-nitrogen containing chemical and tests detect nitrogen oxide emissions, an emissions factor may be used if the recipe is repeated without change. If 1kg of the original chemical always causes 0.3kg of NOx, then the emissions factory for NOx in this recipe is 0.3.  These calculations may be complex, so please utilize chemical and environmental expertise if this method is chosen.

References:

National Pollutant Inventory (NPI) Emission Estimation Techniques Manual for Textile and Clothing Industry (http://www.npi.gov.au/system/files/resources/1889355c-bdcc-f7d4-853f-203ddf3652bd/files/ftextile.pdf

US EPA Compilation of Air Pollutant Emissions Factors (AP-42): https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors

All of the examples above are basic examples demonstrating the principles of estimating emissions. The appropriate methodology should be applied by qualified individuals such as a process or environmental engineer.

Reporting Air Emissions from Production in the FEM:

Before reporting air emissions data in the FEM from production sources, data quality checks should be performed to ensure that the data AND the processes used to calculate, and track emissions data are effective at producing accurate air emissions data. The guidance provided on reporting emissions in Question 1 above should also be used for reporting emissions from production sources in this question.

Note: The methodology used to determine emissions from each source should be selected and applied by qualified individuals such as a process or environmental engineer.

How This Will Be Verified:

When verifying a facility’s air emissions data, Verifiers must review all aspects of the facility’s emissions tracking and reporting program that could produce inaccuracies including:

  • Emissions data sources (e.g., testing reports, emissions modelling or other engineering estimates); and
  • The process and tools used to aggregate the data (e.g. spreadsheet calculations, unit conversions, etc.)

If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.

Yes

Full Points

Documentation Required:

  • An inventory of emissions to air for ALL sources of emissions from production processes.
  • Emission testing/monitoring reports. Testing data compiled in a spreadsheet (e.g. Excel) is ok as long as the testing reports are available for review as well and the data matches the reported information to all questions answered.
  • Emission estimation methodology/calculations documented where applicable.
  • Information entered into Higg for each emission source can be verified with appropriate evidence such as equipment sources and quantity of emissions.

 Interview Questions to Ask:

  • Management is able to explain the list of sources for emissions to air and how they inventory each source

Inspection – Things to Physically Look For:

  • Onsite evaluation of air emission sources matches what is listed
  • Ensure all applicable equipment is listed on sources list
  • Supporting documentation for test results for all sources of emissions (equipment) for those regulated by a governmental/ accredited agency

Partial Points

Documentation Required:

  • Compliance issue documentation from permitting office shows that the issue(s) is less than three months old.
  • An action plan is completed for any emissions source found out of compliance.

Interview Questions to Ask:

  • Management can explain the source of non-compliance and their plans for coming back into compliance.

Inspection – Things to Physically Look For:

  • Any improvements made, or work done to address any non-compliances. Please take pictures.

Do you track refrigerant use/emissions?

If yes, select all refrigerants added to existing equipment

  • Refrigerant
  • Quantity of refrigerant added to existing equipment in this reporting year
  • Unit of measure
  • What method was used to track emissions from this source?
  • What is your plan for fixing this leak?

This question will contribute to your GHG-emissions calculation so it’s important for you to enter accurate data about leak quantities. Please note that your GHG result is intended to provide directional insight into your opportunities to improve, but is not a formal GHG calculation to be used for public reporting.

Having to add refrigerants to existing equipment indicates the system has a leak. If CFC-based refrigerants are maintained in the building, you must reduce annual leakage to 5% or less and reduce the total leakage over the remaining life of the equipment to less than 30% of its refrigerant charge.

ONLY answer NO if you did not add additional refrigerants to any existing equipment in the reporting year. Full Point will be granted.

If you do not know whether refrigerants were added to any existing equipment in the reporting year, you should answer Unknown.

If you know that refrigerants were added, however you do not know the quantity, You should select Yes to the question “Did your facility add additional refrigerants to any existing equipment in the reporting year?”, and select No to the Question “Do you track refrigerant use/emissions?”

What is the intent of the question?

The intent is for you to enter quantitative data that shows how much refrigerant(s) your facility emitted in the reporting year. This question also helps you identify what refrigerants are being used, where they are being used in your factory, and how much is potentially being emitted to the atmosphere.

Technical Guidance:

Refrigerants are ozone depleting substances that can be harmful contributors to GHG emissions and climate change due to the relatively high global warming potentials (GWPs) common refrigerants have. Refrigerants are often emitted through equipment leaks, servicing and disposal.

Although most modern equipment is designed to minimize leaks, it is important to identify leaks if they do occur.  Leaks are typically identified by having to add additional refrigerant to equipment.  It is also important to have an action plan to fix the leaks and/or upgrade equipment to eliminate refrigerant leakage.

If refrigerants are used on-site, solutions to phase out these gases should be considered. One other solution is to use refrigerants with lower global warming potentials (GWP) such as HFO’s in the applications of refrigerants, aerosol propellants and foam blowing agents. Please refer to the following list of refrigerants with reference numbers to determine which of your refrigerants are important to track and phase out: https://www.ashrae.org/standards-research–technology/standards–guidelines/standards-activities/ashrae-refrigerant-designations.

CFCs and HCFCs are being phased out under an international agreement called the Montreal Protocol, in favor of HFCs which are potent greenhouse gases with high GWPs, and they are released into the atmosphere during manufacturing processes and through leaks, servicing, and disposal of equipment in which they are used. Newly developed Hydrofluoroolefins (HFOs) are a subset of HFCs and are characterized by short atmospheric lifetimes and low GWPs. HFOs are currently being introduced as refrigerants, aerosol propellants and foam blowing agents.

For more information on phasing out Ozone Depleting Substances: https://www.epa.gov/ods-phaseout

  • Substances NOT in scope include:
    • The production and consumption of mineral products such as cement, the production of metals such as iron and steel, and the production of chemicals. (CO2)
    • The production of adipic acid, which is used to make fibers, like nylon, and other synthetic products. (N2O)
    • Production, processing, storage, transmission, and distribution of natural gas and crude oil; and extraction of coal. (CH4)
    • Industrial livestock operations, landfills, and anaerobic treatment of wastewater. (CH4)
    • Agricultural soil management, production and application of synthetic fertilizers, and livestock manure management. (N2O)
    • Forestry Practices and Land Use. (CO2)
    • Perfluorocarbons are compounds produced as a byproduct of various industrial processes associated with aluminium production and the manufacturing of semiconductors. (PFC)
    • HFC-23 is produced as a byproduct of HCFC-22 production. (HFC)
    • Sulfur hexafluoride (SF6) is used in magnesium processing and semiconductor manufacturing, as well as a tracer gas for leak detection, and is used in electrical transmission equipment including circuit breakers.

For additional resources please visit:

Tracking Refrigerant Use:

Identifying and tracking refrigerant use is the first step in managing refrigerants use onsite. When establishing your tracking and reporting program, start by doing the following:

  • Map out all facility equipment (production and operational equipment) to identify equipment that contain refrigerants.
    • This should include identifying the specific refrigerant type that is used in the equipment (e.g. R-22).
  • Establish procedures determine how much refrigerant is released (e.g. through leaks, disposal, etc) from each piece of equipment.
    • In general, the amount of refrigerant released is equal to the amount of Refrigerant that is added to the equipment (see Calculating Leak Rate below)
    • Refrigerant purchase invoices, or service records may also be helpful in determining quantities released.
    • If estimation techniques are used, the calculation methodology should be clearly defined and be supported by verifiable data.
  • Record tracking data (e.g. monthly, annual leakage or top-up records) in a format that is easy to review [e.g. spreadsheet (e.g. Microsoft Excel) or similar data analytics program that allows export of data in a human readable format (e.g. Excel, csv)] and maintain relevant supporting evidence for review during verification.

Calculating a Leakage Rate

When determining the quantity of refrigerants emitted from a piece of equipment, it is generally considered that the amount of refrigerant emitted is equal to the amount that was added to the equipment after a period of time to return the equipment back to a full charge.

  • For example, if you recharge the refrigerant in a Chiller unit to a full charge, then after one year of operation you need to add 0.5kg to fully recharge the unit, then is it assumed that the 0.5kg was emitted due to leaks or servicing throughout the year.

When tracking refrigerant emissions, a facility can directly measure and record the amount of refrigerant added to a piece of equipment in the reporting year or a leakage rate can be determined used to estimate emissions.

The leakage rate is typically expressed as the percentage of a full charge that would be lost in a 12-month period. The example below is one way to calculate a leak rate.

  1. Take the kilograms (kg) of refrigerant you added to recharge the system to a full charge and divide it by the kg of refrigerant in the normal full charge for the system.
  2. Determine the number of days that have passed between charges (e.g. how many days between the last time refrigerant was added and this time refrigerant was added), then divide by 365 (the number of days in a year).
  3. Take the kg of refrigerant determined in step 1 and divide it by the number of days determined in step 2.
  4. Lastly, multiply by 100% (to determine a percentage).

For example:

Chiller #1

  • Refrigerant Added = 1kg
  • Full charge = 5kg
  • Days between charges = 275

Leakage rate = (1kg ÷ 5kg) ÷ (275 ÷ 365) x 100% = 26.5%

 

Therefore, this Chiller unit loses/emits 1.33kg (26.5% of a full charge) of refrigerant in a year.

Note:  Leakage rates may also be used to determine when equipment may need additional service or replacement.

Reporting Refrigerant Data in the FEM:

Before reporting refrigerant data in the FEM, data quality checks should be performed to ensure that the data AND the processes used to collect and record the data are effective at producing accurate energy data.

Do:

  • Review source data (e.g. equipment maintenance records, servicing logs, refrigerant purchase invoices, etc.) against aggregated totals to ensure it is accurate.
  • Ensure the most recent and updated versions of data tracking spreadsheets are being used and that all automated calculations/formulas are correct.
  • Ensure the proper units are reported and verify any unit conversions from source data to reported data.
  • Review any assumption or estimation methodology/calculations to ensure accuracy.
  • Report the proper tracking method in the FEM (e.g. measured, leakage rate, estimate)

Do Not:

  • Report data that is not accurate (e.g. the data source is unknown or has not been verified).
  • Report estimated data if it is not supported by verifiable and reasonably accurate estimation methodology and data (e.g. leakage rate or other engineering calculations).

How This Will Be Verified:

When verifying a facility’s refrigerant data, Verifiers must review all aspects of the facility’s tracking program that could produce inaccuracies including:

  • The initial data collection processes and data sources (e.g., equipment maintenance records, servicing logs, refrigerant purchase invoices, etc.); and
  • The process and tools used to aggregate the data (e.g. spreadsheet calculations, leakage rate calculations, etc.)

If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.

Full Points

Documentation Required:

  • All refrigerant equipment has a log of equipment servicing including refrigerant replacement that is kept up to date
  • These records must show that no refrigerants were added in 2021

Interview Questions to Ask:

  • Can the employee(s) responsible for maintaining the refrigeration equipment describe the process and frequency with which they evaluate the equipment for leaks?

Inspection – Things to Physically Look For:

  • Well-kept records of equipment maintenance
  • Potential refrigerant leaks

Partial Points

Documentation Required:

  • All refrigerant equipment has a log of equipment servicing including refrigerant replacement that is kept up to date
  • Equipment logs show the date, specific type and amount of refrigeration added
  • The source of the leak(s) was identified
  • An action plan and responsible employee are in place to make sure the leak gets repaired rapidly

Interview Questions to Ask:

  • Can the employee(s) responsible for maintaining the refrigeration equipment describe the process and frequency with which they evaluate the equipment for leaks?
  • Can the employee responsible for fixing any leaks describe what work he/she is doing to resolve the issue(s)?

Inspection – Things to Physically Look For:

  • Well-kept records of equipment maintenance
  • Any evidence that leaks are being addressed by staff responsible for maintaining the equipment
  • Source
  • Do you have control devices/abatement process for this source?
  • What control device, abatement process, or safety equipment was used for this source of air emissions?
  • What was the frequency of monitoring?

Suggested Upload: Emission testing records from control devices or abatement processes.

Answer Yes only if you have control device(s) installed and in operation for all sources of emissions from operations.

Answer Partial Yes if you have control device(s) installed and in operation for some sources of emissions from operations. This question does not include controls for indoor air quality emissions from production processes.

Definition of Point Source Emissions – air flow which is controlled in some way and released into the atmosphere from a single source such as stack.  These emissions can be facilities related, such as emissions from boilers, or process related, such as exhaust systems for volatile chemical use.

What is the intent of the question?

The intent of this question is to understand if the facility has effective controls in place to manage and limit its emissions to air from all point sources.

Air pollution control or abatement devices are the techniques used to reduce or eliminate the operational emission into the atmosphere of substances that can harm the environment or human health. Abatement process can range from a simple process or a sophisticated device and control equipment depending on the source of air emission and necessity. If facility meets the required standard for air emission, it is most likely that an abatement process is already in place or the control device is already part of the existing equipment. Example of the devices include dust collection and extract units (DCE), scrubbers and incinerator.

Technical Guidance:

This question primarily applies to point source/stack emissions. For example, this may include boilers from facilities, or other stacks from process exhausts. Controls on these emissions may include dust collectors, scrubbers, incinerators, etc.

Monitoring and maintenance of control and abatement devices should be included in your factory’s preventative maintenance program and in the checklists for ongoing visual inspections so that any problems can be identified promptly.

The effectiveness and efficiency of your control devices is typically evidenced through monitoring/testing data. Therefore in the case that no regular monitoring is conducted, facilities should answer No to this question.

Scoring: Full Point will be given based on the extent that the facility has abatement processes or controls processes (when technically applicable) for all identified or potential point source/stack emissions to air that result in lesser quantities of emissions that would otherwise be found if no controls were in place. This obviously requires confirmation and therefore monitoring/testing data as noted above.

How This Will Be Verified:

Yes

Documentation Required:

  • Schematics, descriptions or procedures for control devices or abatement processes
  • Records of calibration and maintenance for control devices listed

Interview Questions to Ask:

  • Management and responsible employees are able to describe the control devices or abatement processes are in place at the facility and how they reduce emissions

Inspection – Things to Physically Look For:

  • Review the list of the control devices in the facility are in fact where they should be and are in operation and good working condition (per regular maintenance and observation by responsible staff) for all sources of emissions from operations

Partial Yes

  • Same as “yes” but control devices installed for some but not all sources of emissions from operations.

Reference: This question can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Air Quality – Manufacturing Key Performance Indicator asks respondents if annual air emissions are tracked and reported by final manufacturing facilities. The facility data can be aggregated by brands to answer TSC’s question.

  • Source
  • Do you have control devices/abatement process for this source?
  • What control device, abatement process, or safety equipment was used for this source of air emissions?
  • What was the frequency of monitoring?

Suggested Upload: Emission testing records from control devices or abatement processes.

Answer Yes only if you have control devices installed and in operation for all sources of emissions from production processes.

Answer Partial Yes if you have control devices installed and in operation for some sources of emissions from production processes.

Definition of Non-Point Source or Fugitive Emissions – for the Higg FEM, these sources of air emissions are those that are released into the general indoor or outdoor environment.  These types of emissions are typically process related such as screen printing, spot cleaning, dyeing, etc.). 

What is the intent of the question?

The intent of this question is to understand if the facility has effective controls in place to manage and limit its emissions from non-point or fugitive sources of air emissions.

Air pollution control or abatement devices are the techniques used to reduce or eliminate the emission into the atmosphere of substances that can harm the environment or human health. Abatement process can range from a simple process or a sophisticated device and control equipment depending on the source of air emission and necessity. For example, this may include exhaust which is treated for VOC from a drying room.

Technical Guidance:

This question primarily applies to any non-point sources that generate emissions, and may impact both indoor air quality and the environment. Some examples of production processes that produce emissions include:

  • Digital printing units which are producing their own colorants / inks by dissolving the solid colorants (acid, reactive and disperse dyes usually) using solvent systems which includes, glycols, dioxanes among others in house.
  • Coating / lamination units which use solvents
  • Embroidery yarn dyeing units which typically use viscose filament yarn using vat dyes in powder form
  • Footwear assembly units which use spraying systems to color the soles
  • Leather coating / spraying units which use liquid dispensing chambers
  • Transfer printing units which use solvents
  • Dry cleaning processes using halogenated solvents
  • Potassium permanganate (PP) spraying units
  • Molding units which use lamination or fusing processes etc.
  • Curing the fabric/ apparel after dyeing
  • Other solvent or adhesive applications (e.g. gluing or priming)

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

Monitoring and maintenance of control and abatement devices shall be included in your factory’s preventative maintenance program and also in the checklists for ongoing visual inspections and other required testing so that any problems could be identified promptly.

Scoring: Full Point will be given based on the extent that the facility has abatement processes or controls (when technically applicable) for all identified or potential fugitive emissions to air that result in lesser quantities of emissions that would otherwise be found if no controls were in place.

How This Will Be Verified:

Yes

Documentation Required:

  • Schematics, descriptions or procedures for control devices or abatement processes
  • Records of calibration and maintenance for control devices listed

Interview Questions to Ask:

  • Management and responsible employees are able to describe the control devices or abatement processes are in place at the facility and how they reduce emissions

Inspection – Things to Physically Look For:

  • Review the list of the control devices in the facility are in fact where they should be and are in operation and good working condition (per regular maintenance and observation by responsible staff) for all sources of emissions from production processes.

Partial Yes

  • Same as “yes” but control devices installed for some but not all sources of emissions from production processes.

Air Emission – Level 2

Questions
  • If yes, specify the level.

Upload emissions testing results for PM, SO2, and NOx

Higg FEM encourages air emissions performance that goes beyond compliance. However, there is not currently an air standard that exists for the apparel, footwear, and textiles industry. If an industry air standard becomes available, we will update the tools accordingly.

What is the intent of the question?

The intent of this question is to demonstrate whether your facility has improved air emissions from combustion devices beyond compliance.

Technical guidance:

Meeting an Air Standard: Air emissions are typically managed to a specified limit as set by local regulations. However in sustainability, it is important to improve beyond compliance to the most aspirational level of air performance possible. Currently, there is no existing air standard for the industry, so The Higg FEM Air section leverages a collaboratively-developed set of limits that are aligned with the best available air pollutant guidance.

The Higg FEM Air section encourages you to reduce pollutant limits as far as possible by setting three levels of limits for combustion devices (e.g., boilers and generator) emitting Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate Matter (PM). These limits were identified by leveraging IFC’s Small Combustion Facilities Emissions Guidelines and standards from Sri Lanka, Belgium, Australia, Germany (more than 50 MW), Japan, and India. SAC or another industry organization will refine these limits over time or replace with another standard if such a standard emerges for the apparel industry.

You can assess different opportunities in reducing emissions at source against these levels of emission limits. Examples include boiler retrofit to use cleaner fuel, improving control device to reduce emissions, etc.

Draft Air Standard for Boilers and Generators (Unit of measure: mg/Nm3):

Small (less than 50 MW) 

Level 1

Foundational

Level 2

Strategic

Level 3

Aspirational

PM15010050
SO220001000400
NOx650300200
Medium (50 MW – 300 MW) Level 1Level 2Level 3
PM1508050
SO215001000200
NOx600300150
Large (greater than 300 MW) Level 1Level 2Level 3
PM1005030
SO2850600150
NOx510200150

 

How This Will Be Verified:

Yes

Documentation Required:

  • Emission testing results which show facility has gone beyond permit requirements to achieve a higher level of air performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx), and Particulate Matter (PM).
  • A plan in place or project description of what was done to achieve it. This should include a list of equipment and/or process changes along with records for the change in emissions resulting from improvements made.

Interview Questions to Ask:

  • Management is able to explain the actions resulting in the facility going above and beyond permit requirements

Inspection – Things to Physically Look For:

  • Reference items listed in plan including equipment or processes used for achieving higher level of air performance.

Air Emission – Level 3

Questions

Upload: Documentation of plans/process for equipment upgrades or documentation of recent upgrades

Select Yes if you have a documented plan to upgrade machinery or if all machinery has been upgraded to the most modern version as this is one of the best ways to control pollutants and minimize air emissions.

What is the intent of the question?

The intent is for a facility to be able to share or demonstrate advanced practices to control air pollutants.

Modernizing equipment is an effective way to reduce or eliminate air emissions and indoor air quality issues. Feasibility studies are helpful to identify and assess the possibility to upgrade equipment (e.g. replacing equipment, modifying existing equipment, further optimizing abatement equipment, etc.) to reduce emissions (GSCP).

Technical Guidance:

Antiquated or ineffectively operating equipment often does not utilize the best available technology (BAT) or best available control technology (BACT) for air emissions controls. Therefore, current equipment may result in greater air emissions than newer, more modern, equipment. Modernizing machinery means retrofitting existing machinery with newer technologies or purchasing new equipment with more advanced technologies for controlling air emissions.

One example of modernizing machinery is to upgrade refrigeration and/or air conditioning systems so that they may use refrigerants with lower GWP or substituting ODS with more environmental friendly refrigerants.

Another example is the procurement of a new boiler or generator powered by cleaner fuels and thus results in less air emissions.

How This Will Be Verified:

Yes

Documentation Required:

  • Documentation of plans/process for equipment upgrades or documentation of recent upgrades
  • List of recent equipment upgrades (if applicable)

Interview Questions to Ask:

  • Management is able to describe plan/process for equipment upgrades or documentation of recent upgrades.

Inspection – Things to Physically Look For:

Verify equipment upgrades in facility against plan in place

X