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 requires you to:
- Identify staff responsible for coordinating environmental management activities and ensure technical competence
- Identify significant environmental impacts associated with current operations
- Set a long-term environmental management strategy
- Develop a system to ensure compliance with all laws, regulations, standards, codes and other legislative and regulatory requirements
- Continuously maintain all factory equipment
- Engage facility leadership and workers on environmental strategy and performance
- Engage with subcontractors and upstream suppliers on environmental performance using the Higg Index
- Engage with local stakeholders on environmental performance improvements
EMS – Level 1
Questions
If yes, please answer the following questions for each:
- Name
- Job Title
- Time spent on environmental management:
- Select environmental topic (select all that apply):
- Energy
- Water
- Wastewater
- Air Emissions
- Waste
- Chemical Management
- Description (description of employee’s roles and responsibilities)
Upload: Environmental management team organization chart
Answer Yes if you have any full-time, half-time, part-time, seasonal or contract employees working on environmental management in your facility.
You can provide details on up to six employees. If you wish to provide details on more than six employees, please upload these details in a document.
What is the intent of the question?
This question is intended to confirm who in your facility is/are responsible for managing environmental impact areas.
The first step to demonstrate that environmental improvement is a core focus in your business strategy is to have dedicated staff responsible for managing environmental impacts.
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 system documents to oversee or coordinate. An environmental management team organizational chart and clear job descriptions could help to keep the members accountable to their roles.
If one person has multiple responsibilities, you have the option to indicate multiple responsibilities within the environmental topics and description section.
How This Will Be Verified:
Yes
- Documentation Required:
- Environmental Management Team organization chart and job descriptions records
- Supporting documentation:
- Employee Name(s)
- Job Title(s)
- Time Spent on each area (General environmental management, Energy, Water, Wastewater, Air, Waste, etc.)
- Performance and project plans for various environmental initiatives
- Interview Questions to Ask:
- Management can clearly articulate the roles and responsibilities of those responsible for coordinating environmental management activities
- Key Employees responsible for coordinating environmental management activities can demonstrate that they understand and are able to explain their roles
- Inspection – Things to Physically Look For:
- Evidence to support that the Environmental Management Team is appropriately staffed and capable for the facility operations and size.
- How many personnel are part the environmental team?
- Are there enough environmental personnel part of the team to handle the breadth and depth of environmental impacts created by the facility?
- Can they demonstrate reductions in environmental impact as a result of the programs they have implemented?
Link
Select all topics covered by this strategy:
- Energy
- Water
- Wastewater
- Air
- Waste
- Chemical Management
Upload Environmental Management Strategy
Answer Yes if you have a documented environmental strategy in place that sets forth environmental priorities, goals, and actions for 3+ years. A good environmental strategy should:
- address your facility’s significant environmental impacts and compliance obligations as prioritized in your environmental impact assessment;
- be supported by facility leadership;
- be communicated to all employees. To ensure environmental objectives are carried out, your strategy should include plans for achievement that detail: what will be done, what resources will be required, who will be responsible, when it will be completed, and how results will be evaluated (reference: ISO 14001).
- If you have an environmental strategy that aligns with requirements in ISO 14001 and plans for 3+ years into the future, you may answer Yes to this question.
What is the intent of the question?
This question is intended to drive your facility to go through a strategy development process to confirm long-term goals for environmental improvements and investments. Holistic environmental management needs leadership support to work. Having a long-term sustainability strategy built into your business is an important sign of a mature management approach.
A documented environmental policy and/or strategy can be used by 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. It requires and proposes continual improvement of environmental performance.
One option for facilities to build a holistic environmental management system pairs the environmental policy and/or strategy with consistent completion and continuous improvement of the Higg FEM.
A facility is advised to follow an internationally recognized EMS standard, for example ISO 14001. Refer to the following guidance on how to create an environmental management system and strategy:
- ISO 14001 Environmental management systems — Requirements with guidance for use: https://www.iso.org/iso-14001-environmental-management.html
- This support site contains examples and templates for setting EMS policies and strategies: http://www.epd.gov.hk/epd/misc/env_management_sme/eng/um_main1.htm
Technical Guidance:
In order to set up meaningful and effective EMS system, a facility has to first carry out an environmental impact assessment (EMS Question 3) to identify the most significant environmental impacts at the facility. Then formal documentation and clear environmental policy can be created that describes the site’s activities, products, and services including a commitment to continual improvement and prevention of pollution. Once there is a clear understanding of the key environmental impacts to focus on, 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+ years). Both policy and strategy should be reviewed regularly by facility management.
In addition, relevant staff should be trained to implement and maintain the EMS including environmental policies and procedures and address potential consequences of departure from procedures.
How This Will Be Verified:
Yes
- Documentation Required:
- The company’s environmental strategy is signed off by factory management and there is a long-term strategy that extends 3+ years into the future
- The company environmental strategy should provide a direction and a plan of actions designed to achieve goals within a defined timeline. The strategy document should be well written and endorsed by the company management or authorized committee to guide planning, decision making and activities that impact on the environmental improvement and target achievement. Including items such as; consumption reduction, emission reduction, cost saving target, or changing staff practice to reduce water consumption, waste reduction and resource conservation, etc.
- Interview Questions to Ask:
- Management is able to explain the long-term strategy in place
- Key employees involved with implementing the long-term strategy is able to explain their role
- Inspection – Things to Physically Look For:
- Evidence that the long-term strategy is in place and working, such as:
- Compliance with environmental regulations
- Regular and frequent tracking of all environmental impacts
- Action plans and/or capital improvement plans for improving equipment or process efficiency
- Reduction targets and reductions for key environmental impacts (e.g. energy, water, waste)
- The use of renewable energy
- Community service projects including tree planting, etc.
Other References:
- These questions can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Air Quality – Manufacturing, Greenhouse Gas Emissions Intensity – Manufacturing, Greenhouse Gas Emissions – Supply Chain, Water Use – Supply Chain, and Wastewater Generation – Supply Chain Key Performance Indicators cover reductions in environmental impacts in product production. These TSC KPIs can be used to answer EMS questions 1.2 and 2.2 environmental impact management and reduction associated with products produced at the facility.
- ISO 140001 Standard: https://www.iso.org/iso-14001-environmental-management.html
Link
Answer Yes only if you have an environmental impact assessment that shows significant environmental impacts from current factory operations.
What is the intent of the question?
The intent of this question is to demonstrate the value of conducting a holistic assessment of the greatest environmental risks to your facility’s operations. Knowing your facility’s greatest risks will help you prioritize improvement actions in the forthcoming sections of this module.
An environmental impact assessment is used to identify and characterize potential and actual adverse risks to the environment from the presence and operations of your facility.
The environmental impact assessment is comprised of numerous impact areas, including wastewater, extraction of water, other sources of incoming water, solid and liquid waste, stationary and fugitive emissions, storage of gases and liquids, noise and vibrations. The results will enable facility management to identify the source, magnitude and urgency of specific risks related to the location and operation of the facility.
This information will support the creation of necessary risk mitigation and elimination strategies to minimize harm to the environment. The environmental impact assessment is an iterative process that will continuously evaluate any new risks associated with the location and/or operations of the facility.
Technical Guidance:
A facility should check laws and regulations to determine whether their local government has rules governing the process of evaluating likely environmental impacts of the facility’s operation (i.e. Environmental Impact Assessment) that should be followed. If there are no local regulations, an impact assessment can be conducted following an internationally recognized EMS framework, such as
- International Finance Corporation IFC Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts [January 1, 2012]: https://www.ifc.org/wps/wcm/connect/8804e6fb-bd51-4822-92cf-3dfd8221be28/PS1_English_2012.pdf?MOD=AJPERES&CVID=jiVQIfe
- World Bank Environmental, Health and Safety General Guidelines [April 30, 2007]: https://www.ifc.org/wps/wcm/connect/29f5137d-6e17-4660-b1f9-02bf561935e5/Final%2B-%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES&CVID=jOWim3p
- ISO 14001:2015, clause 6.1.2 identifies the requirements for assessing environmental aspects, impacts and their significance. Certification to ISO 14001:2015 is an acceptable means for demonstrating conformance with this requirement.
- Environmental permit application and permit requiring controls based on the impacts described in the application together are also an acceptable means of demonstrating conformance with this requirement. A summary of environmental impacts and their significance derived from the permit application and the permit shall be acceptable. If permit is not renewed at a frequency stipulated by regulation, then the impacts should be assessed every three years against any changes in the operation as a general good practice.
These standards and guidelines can be used by facilities to evaluate environmental risks and impacts at the facility level.
How This Will Be Verified:
Yes
The environmental impact assessment must be available, comprehensive of all environmental impacts, and completed in accordance with any applicable standards, rules, or regulations.
- Documentation Required:
- Environmental impact analysis and aspect evaluation and/or latest local government environmental assessment report
- Interview Questions to Ask:
- Can factory management demonstrate awareness and understanding of the significant aspects and impacts associated with the employment site?
- Can factory management demonstrate knowledge of laws and regulations concerning environmental management?
- Inspection – Things to Physically Look For:
- All environmental aspects associated within the factory’s control or influence are included in the report
- All environmental impacts covered by local regulation must be included as well
- The assessment must include an analysis of the significance/importance of the different environmental impacts. The process for evaluating the significance of environmental impacts must be done periodically in order that the document be reproducible for comparing results.
Link
Upload: a) List of required permits needed for your facility to operate and calendar of permit activities; b) Documentation of programs or systems in place to review and monitor environmental permit status, renewals, and ensure you are meeting the legal requirement.
Answer Yes if you have a program or process to monitor compliance with environmental permits and rules.
What is the intent of the question?
The intent of this question is to ensure the facility has the ability to take action and manage a process (or standard operating procedure) maintaining compliance with environmental permits.
Staying in compliance with regulations is a fundamental business practice. Facility must ensure basic compliance is met before moving on to performance improvements and reductions.
Permits have legal requirements that must be met as well as expiration of the permits. Response to this question will explain how your standard management practices are followed by the facility to maintain the validity of the permits legally including expiration.
Technical Guidance:
At a minimum it is advised to create a regularly updated document that tracks your environmental permit review and update approach on a set schedule. The content of the tracking document can include environmental impact areas, permit name, permit status, permit number, valid period, requirements, key responsible person for ensuring compliance, etc. You may also go further and create a detailed standard operating procedure to monitor compliance of all the permit requirements.
Here is an example template for tracking permits: https://howtohigg.org/resources/resources-library/#templates
How This Will Be Verified:
Yes
- Documentation Required:
- Local environmental permit requirement for the facility’s corresponding country or locality
- List of required permits needed for facility to operate
- Permits listed in the Permits section on Site Info
- Documentation of the program or system in place to review and monitor environmental permit status and renewal and ensure you are meeting the legal requirement
- Elements include:
- Internal review mechanism
- Responsible staff/party
- Environmental permits renewal process
- Timeframe to renew the permits to ensure compliance
- Action plan if the environmental permits expire
- Interview Questions to Ask:
- Management is able to explain the process and calendar for ensuring permits are meeting the legal requirements
- Key employees involved in the process are able to explain their role and responsibilities for contributing to the success of the program in place for ensuring the permits are meeting the legal requirements
- Inspection – Things to Physically Look For:
- Permits in good standing for all permits listed to operate facility
Link
Select all topics covered by the system:
- Energy
- Water
- Wastewater
- Air
- Waste
- Chemicals
Are the findings used to set an improvement plan that is regularly reviewed?
Upload: Documentation of your system to identify, monitor, and periodically verify all laws, regulations, standards, codes, and other legislative and regulatory requirements for your significant environmental impacts
Answer Yes only if you have a system to monitor requirements.
What is the intent of the question?
The intent of this question is to evaluate if your management has a process (or standard operating procedure) that insures the facility is taking action from laws, regulations, standards, codes and other legislative and regulatory requirements for your significant environmental impacts outside of legal permits. (This is not inclusive of legal permits. See Question #4).
In many cases, facilities may have a valid permit but they are actually not complying with all local environmental requirements or don’t have a program to identify which laws are applicable to the factory. Examples: 1) facility has valid permit but they don’t know which regulations they should check against for legally restricted chemicals; 2) Water recycling/ energy efficient machineries are required by the local government but there is no specified timeline for facility to complete or no specified legal consequence on the environmental permit if they don’t change the machines.
Facilities are also required to monitor and verify industry requirements. An example might be a facility in China required to disclose on the IPE program.
Your manufacturing organization may monitor and verify regulations at the parent company level or at the facility level. The response will identify your management practices that maintain business continuity.
Technical Guidance:
Setting up a process for identifying, monitoring and verifying environmental compliance should be part of your formal environmental management system. The process has to be documented (for example, through a standard operating procedure), maintained and executed by qualified personnel that have a good understanding of environmental regulations. Periodic review and updates of environmental regulations have to be conducted and documented.
Here is an example template for tracking local regulations: https://howtohigg.org/resources/resources-library/#templates
How This Will Be Verified:
Yes
- Documentation Required
- Documentation of the facility’s system to identify, monitor, and periodically verify all laws, regulations, standards, codes, and other legislative and regulatory requirements for the facility’s significant environmental impacts. Facility should follow the most stringent of national level, provincial level, or industrial requirements.
- System should include the following elements:
- Scope of regulatory requirement to be monitored
- Responsible staff/party
- Internal review & tracking mechanism
- When does this occur?
- How often does it occur?
- What is the process to update the content?
- Who reviews and approves the content?
- Action plan for any non-compliance?
- Examples of standards and codes:
- Use of chemicals in the work of safety conventions
- Regulations on the management of ozone depleting substances
- Cleaner Production Promotion National Law
- Energy management standard
- Energy saving technology standard
- Energy saving facility and their assessment standard
- Interview Questions to Ask
- Management is able to describe the system used in the facility to identify, monitor, and periodically verify all laws, regulations, standards, codes, and other legislative and regulatory requirements for your significant environmental impacts
- Key Employees who are part of the system should be able to clearly explain their role in ensuring all regulatory requirements are met
- Inspection – Things to Physically Look For
Evidence to support there is a system in place that is being used in the facility to identify, monitor, and periodically verify all laws, regulations, standards, codes, and other legislative and regulatory requirements for your significant environmental impacts
Link
Suggested uploads: Documentation of procedures in place to enable workers to report environmental emergencies/violations
Answer Yes if you have a documented procedure that enables workers to report environmental emergencies/violations.
What is the intent of the question?
The intent is to ensure workers have a proper channel to report for environmental emergencies/ violations.
This is critical to prevent facilities from covering up any violations and/or delaying the necessary corrective actions to reduce environmental contamination.
Technical Guidance:
It is every worker’s obligation to report suspected or actual violations of regulation. The facility needs to set up and document a procedure which allow workers to report environmental emergencies/ violations. The document should clearly mention the steps and responsible contacts the workers can report to. The facility should also make a statement to guarantee there will be no workers punished or retaliated against for reporting truthful information to a law enforcement.
How This Will Be Verified:
Yes
- Documentation Required
- Documentation of procedures for workers to report environmental emergencies/violations
- Interview Questions to Ask:
- Are workers aware of the procedures to report environmental emergencies/ violations?
- Is management held accountable for ensuring that there are no negative consequences towards employees who report grievances?
- Inspection – Things to Physically Look For
- Documented procedures or policy of reporting environmental emergencies/violations are accessible by workers.
Link
Upload: Maintenance schedule
Answer Yes if you maintain all equipment since this is important for managing emissions to air, energy efficiency, water efficiency, and other environmental impacts.
What is the intent of the question?
The intent is for your facility to have appropriate maintenance procedures for managing emissions to air, energy efficiency, water efficiency etc. Maintenance can help your facility ensure compliance, reduce waste due to inefficient machinery or leakage, and identify savings opportunities.
Technical Guidance:
All equipment for production and operation should be maintained regularly in order to ensure compliance and reduce environmental impact. Depending on the types of equipment, the frequency and scope of maintenance of equipment will vary. Appropriate maintenance of equipment can be ensured through the following steps:
- Appoint at least one facility engineer or technician to be responsible for managing equipment maintenance.
- Define maintenance scope and schedule for all equipment.
- Establish a regular process to maintain all production and operational equipment.
- Compile and keep maintenance logs.
How This Will Be Verified:
Yes
- Documentation Required
- Equipment maintenance schedule
- Equipment maintenance log
- Equipment maintenance procedures, including the following:
- A list of all equipment used for production and measurement
- Date Checked
- Performance Status
- Problems Identified
- Action required
- Action Complete Date
- Name of personnel and Signature
- Due date for next check
- Interview Questions to Ask:
- Who is responsible for executing the equipment maintenance procedures?
- How often are the procedures updated?
- Inspection – Things to Physically Look For
- Verifiers should spot check the equipment seen on the facility work floor and reference the equipment list to ensure equipment is listed and relevant maintenance logs are available.
Link
EMS – Level 2
Questions
Suggested upload: Records from last annual management strategy review
Answer Yes only if you have evidence of management reviews conducted in 2022.
What is the intent of the question?
The intent of this question is to drive management to communicate environmental management strategy and/or opportunities to present environmental progress to facility management team each year.
Holistic environmental management needs leadership support to work – having a long-term sustainability strategy built into your business is an important sign of a mature management approach.
Technical Guidance:
Conducting management review of environmental management systems should be an ongoing process with a focus on driving improvement. Having a set schedule for regular management meeting (such as on quarterly basis) is recommended. At least one full management review is recommended annually. The meeting should review information such as results of verification and legal compliance, environmental performance, status of objective and targets, status of preventive & corrective actions, recommendations for improvements, etc.
ISO 14001 has detailed objectives and processes for management review. There are eight different inputs that are required for successful management review:
- 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
Further guidance and tips on conducting management review: https://advisera.com/14001academy/blog/2014/07/30/can-ems-management-review-useful/
https://www.deq.virginia.gov/Portals/0/DEQ/AboutUs/EMS/EMS01%20DEQ%20EMS%20Manual.pdf
Click here for a sample implementation plan for a small/medium size mill
How This Will Be Verified:
Yes
- Documentation Required
- Site EMS management review meeting plan
- Site EMS management review meeting agenda
- Meeting memo, action plan & timeline
- Meeting attendance record
- Interview Questions to Ask
- Management should be able to clearly articulate, in detail, the current long-term sustainability strategy
- Inspection – Things to Physically Look For
- Training materials for most recent training conducted in the last year
- Training sheets for employees in attendance
Link
Upload: a) List of individuals that are responsible for environmental related issues; b) Procedure to cross reference the individuals listed have the technical competence required to do their job
Answer Yes if you can explain how you ensure environmental employees: a) have technical competence, b) are provided with trainings or certifications as needed, and c) are evaluated for competence on an annual basis.
Answer Partial Yes if you can demonstrate employee competence but do not yet have a process for annual performance review
What is the intent of the question?
The intention is to demonstrate value in technical training for staff and/or hire staff with technical backgrounds (university degrees, prior work experience, training program certificates) to manage your facility’s environmental impacts.
One of the major barriers to progress on sustainability is the lack of technical expertise. Having staff with strong technical expertise in relevant impact areas is what sets apart leaders and beginners in sustainability work.
For example, in order to improve energy and water use on-site, there should be someone who knows what machinery/technologies you use and how much energy/water they use. You need to have someone on-site who can walk through the factory and know how to spot leaks or other inefficiencies.
Technical Guidance:
Hiring someone with a background in engineering or another technical areas is valuable to effectively manage environmental impacts at a facility. If hiring a technical expert is not an option, investing in technical training for existing employees (e.g. Certificate in ANSI/ ISO 14001: Standard), demonstrating how technical expertise has been cultivated over-time (e.g. staff spent multiple years in the same role with demonstrated environmental improvements), or hiring a consultant/advisor with technical expertise are other solutions.
External trainings for staff to become internal EMS auditors can be offered (e.g. attending internal EMS auditor training courses certified by a reputable professional organization such as the Institute of Environmental Management & Assessment (IEMA), International Registration of Certified Auditors (IRCA), etc.)
How This Will Be Verified:
Yes
- Documentation Required:
- List of individuals that are responsible for environmental related issues
- Environmental management team organization chart
- Roles & responsibilities, and their background & qualification in corresponding area
- Certificates proving their professional qualifications
- Training records showing the person in charge has received training from time to time to update his/her knowledge in environmental management field
- Interview Questions to Ask:
- Management is able to explain how they ensure they have individuals with technical competence required to do their job effectively
- Responsible staff can demonstrate their knowledge and expertise related to the areas of environmental management they oversee
- Management provides training and development opportunities for staff responsible for environmental management
- Inspection – Things to Physically Look For:
- Certifications or trainings provided to the individuals listed who are responsible for environmental related issues
- Annual review of employee’s job performance to ensure they are meeting the technical competence needed to do their job
- Staff’s abilities to communicate their responsibilities and progress against their goals throughout the site visit
Partial Yes
- Documentation Required:
- List of individuals that are responsible for environmental related issues
- Job descriptions for the list of individuals that are responsible for environmental related issues
- Development plans for staff to ensure they have the appropriate level of technical knowledge and resources to successfully manage their areas of responsibility
- Interview Questions to Ask:
- Management is able to explain how they ensure they have individuals responsible for environmental related issues also have the technical competence required to do their job.
- Inspection – Things to Physically Look For:
- Certifications or trainings provided to the individuals listed who are responsible for environmental related issues
Link
EMS – Level 3
Questions
Upload: Plan for promoting awareness of the environmental strategy to workers.
Answer Yes if you can demonstrate how your environmental strategies have been communicated to workers.
Answer Partial Yes if you are in the process of developing a communication plan
What is the intent of the question?
The intent is for facility management to communicate your environmental strategy and action plan to the facility’s workers through trainings, newsletters, posters, or other mechanisms.
Workers play a major role in how much energy and water is used, how much waste is generated, how chemicals are managed, and can also help identify improvements for air and wastewater impacts. By communicating your plans to improve your environmental footprint, you help motivate and mobilize your workforce to support you in these improvements.
Technical Guidance:
As a first step a facility should set up an internal communication plan which identifies different ways of communicating the facility’s environmental strategy.
An example of communications includes posters in a visible place that communicate preferred behaviors or strategies (e.g., How to conserve energy and water in dorms/kitchens/toilets, or appropriate waste disposal procedures such as what can be recycled).
More advanced examples of such communication include having formal meetings, reviews and training sessions to inform employees of progress against key performance indicators (KPI’s) defined by the environmental policy/strategy. For example, some companies have expanded this education to provide incentives for workers that suggest process improvements that make the facility more efficient.
How This Will Be Verified:
Yes
- Documentation Required
- Plans for promoting awareness of the environmental strategy to workers that includes the schedule and frequency of communications as well as the content to be delivered, attendance records, and employee evaluations on the success of the program.
- Communications tactics may include: slogan, posters, newsletters, games & competitions, awards, team/division ambassadors, training, best practice sharing, broadcast announcement, etc.
- Interview Questions to Ask
- Management is able to explain how they promote awareness of the environmental strategy to workers at different levels in the organization.
- Inspection – Things to Physically Look For
- Evidences to support management in promoting awareness of the environmental strategy, which may include posters in a visible place, training materials provided to workers, formal meeting minutes and sign in sheets, evaluation reports, etc.
- Employees can demonstrate their awareness of all or components of the environmental strategy
Partial Yes
- Documentation Required:
- A plan for promoting awareness of the environmental strategy to workers exists and implementation will begin this year
- Interview Questions to Ask:
- Management can articulate the plans and can confirm how and when implementation will commence
- Inspection – Things to Physically Look For:
- Training dates, examples of educational collateral, designated employee trainers, etc.
Link
Upload: List of all subcontractors with proof of Higg Index engagement: e.g., show Higg.org Module shared or other documentation of their Module results such as an emailed export of results.
Answer Yes if you engaged any subcontractors in environmental assessment using the Higg Index.
Answer Partial Yes if you have a plan to engage subcontractors using the Higg Index
Answer “Not Applicable” if you do not have subcontractors
The scope of subcontractors for this question only includes subcontractors used for production.
A subcontractor is usually an entity hired by a manufacturer to complete specific tasks which are also considered special tasks or manufacturing process steps. Manufacturers hire subcontractors because they do not have the expertise or resources in-house, and they need the services from subcontractors to complete a portion of the manufacturing process or certain pieces of work to produce finished goods. For example, cut and sew garment manufacturers may need to hire subcontractors for processes, such as, garment dyeing, embroidery and screen-printing tasks.
Subcontractors may or may not have direct ownership connection to the manufacturer. Finished goods facilities that perform the complete manufacturing process, even when they are not privately owned by the manufacturer/ the manufacturer’s mother company, should not be considered or termed as a subcontractor in the Higg FEM context.
What is the intent of the question?
The intent is to leverage the Higg FEM and communicate why environmental performance matters to your business with subcontractors, and work with them to evaluate their own performance, monitor impacts, and improve.
The environmental footprint of the products you produce includes your subcontractors’ impacts. For example, if you subcontract the final washing step of denim production, it is important that your subcontractor is aware of their water risks and is engaged in reducing water use. Or if you make fabric and you subcontract a screen-printing process, it is important that your subcontractor be engaged in Restricted Substance List compliance.
This is a more advanced practice that environmental leaders should be working on. It’s important to start with Level 1 practices to ensure you have your own environmental strategy and action plan, before extending your efforts to your subcontractors.
Technical Guidance:
Ways to engage subcontractors involves leveraging the Higg Index to educate, evaluate performance and identify improvement opportunities. You can invite your subcontractors to complete the Higg FEM and share their results with you. Any engagement and partnership should be continuous so that improvement is monitored and managed over time. Tracking relevant documentation, such as training materials, signed environmental commitment documents, site evaluation reports is recommended.
How This Will Be Verified:
Yes
- Documentation Required:
- List of all subcontractors that your facility conducts business with along with which ones have posted Higg FEM modules
- Obtain a list from the accounting department and cross reference all subcontractors are listed
- Proof of Higg Index engagement: e.g., show Higg.org connections and shared modules or other documentation of subcontractor module results such as an emailed export of results.
- The facility should demonstrate a subcontractor evaluation system and monitoring plan which should include items such as:
- an EMS training for subcontractors to ensure they understand your facility’s requirements and any targets they have to achieve
- an annual training plan
- training materials
- training records, such as an attendance list
- Interview Questions to Ask:
- Management is able to demonstrate the extent to which their sub-contractors are using Higg
- Management can articulate how they are using suppliers’ Higg results to drive environmental improvements up the value chain
- Inspection – Things to Physically Look For:
- Relevant documentation about subcontractor engagement (e.g. agreements, communication documents with subcontractors, Higg Index results for suppliers)
Partial Yes
- Documentation Required:
- List of all subcontractors facility conducts business with and which ones they engage with or plan to engage with using Higg
- Engagement with subcontractors is in progress or there is a plan in place to engage with them, but no or limited Higg completion or sharing has occurred: e.g., emailed invitations to register, emailed invitation to participate with description of Higg
- Interview Questions to Ask:
- Management is able to explain why and how they plan to engage with their subcontractors on their environmental performance using Higg
- Inspection – Things to Physically Look For:
- Evidence that a plan is in progress and dates have been set for subcontractor engagement to occur
Not Applicable
- Documentation Required:
- Proof that subcontracts are not used for production activities
Link
Select the ways in which your facility engages in environmental improvement:
- 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 Upload: a) Evidence of environmental improvement in your local context (e.g., community, river basin, etc.); b) List of local stakeholders and dates of engagement; c) Pictures, articles or press releases; List of organizations/initiatives you support.
Answer Yes if you have engaged in your local context (e.g., your community, your river basin, your region) and can show improvements and lists of stakeholders that you worked with.
What is the intent of the question?
The intent is to build engagement with people, businesses, and organizations in the community around your facility on environmental practices and improvement.
This practice is important because your facility has a direct impact on the local environment your facility is located in. It is beneficial for your facility to engage with local entities that may include government, NGOs, community members, and environmental impacts in order to more deeply integrate environmental improvement into your local context.
Technical Guidance:
One important way to engage in the community is to partner with local regulatory agencies or centralized wastewater treatment plants to improve environmental performance and investments. For example:
- Organize local trash clean-ups or provide incentives to local families who properly dispose of electronic waste.
- Organize local fundraisers for environmental non-profits.
- Organize educational events for children to start environmental stewardship
References: Answer options adapted from the World Wildlife Federation’s water projects questionnaire.
How This Will Be Verified:
Yes
- Documentation Required:
- Evidence of environmental improvement in their local context (e.g., community, river basin, etc.) such as donations to local charities; participation in local environmental initiatives; community service outcomes; newspaper articles, pamphlets, or photo evidence of local community involvement; outcomes of environmental policy work; etc.
- List of local stakeholders and dates of engagement
- Interview Questions to Ask:
- Management is able to explain how they engage in environmental improvement in their local context
- Inspection – Things to Physically Look For:
- Supporting documentation of engagement with local community:
- Event photos, or videos
- Charitable contributions
- Newspaper articles
Link
If yes, which type of suppliers?:
- Chemical suppliers
- Raw material suppliers
- Other suppliers, please describe
Suggested Uploads: List of upstream suppliers with proof of Higg Index engagement: e.g., show Higg.org Module shared or other documentation of their Module results such as an emailed export of results.
Answer Yes if you engaged any upstream suppliers in environmental assessment using the Higg Index.
Answer Partial Yes if you have a plan to engage upstream suppliers using the Higg Index.
Upstream suppliers are usually an entity providing raw materials to manufacturers that ultimately process the materials. For example, fabric mills, zipper and buttons manufactories are common upstream suppliers for a cut-sew garment factory.
What is the intent of the question?
The intent is to communicate why environmental performance matters to upstream suppliers, and work with them to evaluate their performance, monitor impacts, and improve using the Higg Index.
The environmental footprint of the products you produce includes your suppliers’ impacts. For example, you want to make sure you are purchasing chemicals from a chemicals supplier that gives you all the information you need to confirm proper usage and storage of a chemical. Or you may choose to work with a chemicals supplier that delivers chemicals in tanks instead of drums to reduce waste. Or if you assemble footwear, you may choose to work with component suppliers that understand their own environmental impacts and are taking steps to improve. Or if you make textiles, you want to source from a fabric mill that has an effective wastewater treatment system and doesn’t pollute local waterways while dyeing your product’s fabric.
An easy way to answer “yes” to this question would be to invite your suppliers to complete the Higg FEM and share their results with you.
This is a more advanced practice that environmental leaders should be working on. It’s important to start with Level 1 practices to ensure you have your own environmental strategy and action plan, before extending your efforts to your suppliers.
Technical Guidance:
Ways to engage upstream suppliers involves leveraging the Higg FEM to educate, evaluate performance and identify improvement opportunities. Any engagement and partnership should be continuous so that improvement is monitored and managed over time. Tracking relevant documentation, such as training materials, signed environmental commitment documents, site evaluation reports is recommended. See “How this will be verified” for documentation required.
Tracking a suppliers’ environmental performance, a schedule to regularly monitor performance is recommended. Documentation review and factory site visits are recommended. The Higg FEM can be used as a tool to monitor upstream suppliers.
How This Will Be Verified:
Yes
- Documentation Required:
- List of ALL upstream suppliers facility conducts business with
- Proof of Higg Index engagement: e.g., emailed registration invitations, communications/requests for completion, Higg.org Module share, documentation of their Module results.
- Communications with upstream suppliers and their feedback on the use of the Higg Index
- Interview Questions to Ask:
- Management is able to provide a description of scope of which upstream supplier are engaged
- Review the monitoring process of upstream suppliers using the Higg Index
- Inspection – Things to Physically Look For:
- Relevant documentation about upstream supplier engagement (e.g. Contract, agreement, communication documents with upstream suppliers)
Partial Yes
- Documentation Required:
- List of ALL upstream suppliers facility conducts business with
- Plan in place to engage with suppliers on Higg Index for upcoming adoption cycle
- Interview Questions to Ask:
- Management is able to explain how they plan to engage with their upstream suppliers on their environmental performance
- Inspection – Things to Physically Look For:
- Evidence that a plan is in progress and dates have been set for upstream suppliers engagement to occur.
Other References:
- This question can be used to inform responses to The Sustainability Consortium’s Home and Apparel Textiles Toolkit. The Greenhouse Gas Emissions – Supply Chain, Water Use – Supply Chain, Wastewater Generation – Supply Chain Key Performance Indicators address environmental impacts from upstream suppliers. The facility data can be aggregated by brands to determine environmental impact management and reduction associated with the final product.