General Introduction
Air emissions from industrial processes and manufacturing operations have the potential to emit pollutants into the air that impact the environment, human health and contribute to climate change. As governments and industry stakeholders continue to focus on reducing environmental impacts, more stringent requirements and regulations may be imposed. By proactively managing and working to reduce impacts of your facility’s air emissions, you can reduce your exposure to regulatory risks or new requirements from business partners. In general, the Higg FEM Air Emissions section encourages you to:- Identify and understand the types of emission sources and pollutants that are emitted from your facility.
- Understand and comply with all applicable legal requirements relating to air emissions including all permitting, reporting, and testing requirements.
- Track and report emissions of key pollutants associated with facility operations and production.
- Evaluate, plan for, and adopt best available technologies (BAT) including materials, processes, and equipment to minimize emissions to air.
Air Emissions At Your Facility
Pollutants are typically emitting from the one of the following types of emission sources:
- Point Source: air flow which is actively controlled and directed (e.g., by fan and exhaust ducting) into the atmosphere from a single stationary fixed source such as stack or vent. Examples include boiler exhaust stack, the exhaust stack of a local ventilation system used to capture emissions from processes that emit volatile organic compounds (VOCs).
- Fugitive Emissions Source: for the Higg FEM, fugitive emission sources are those that are passively released into the outdoor environment and are not actively directed through a single exhaust point (e.g., stack or vent). Examples include screen printing, spot cleaning or dyeing areas with only general ventilation (e.g. passive sidewall ventilation or windows).
- Mobile Emissions Source: for the Higg FEM, mobile emission sources are those that are non-stationary sources of emission. Examples include powered motor vehicles (e.g., forklifts, trucks, passenger vehicles), heavy machinery (e.g., mobile cranes or lifts), small engines (e.g., landscaping equipment).
The Higg FEM also further categorizes emissions based on the nature of the emission source as follows:
- Emission from Facility Operations: for the Higg FEM, these include emissions from sources that support facility operations and are not the direct result of production processes. Emissions from facility operations are typically emitted through point source or mobile emissions sources. Examples include boilers, generators, heating and cooling systems (e.g., combustion heating, refrigerant-containing cooling equipment), and combustion engines.
Emissions from Production: for the Higg FEM, these include emissions from sources that are related to production processes. Emissions from production are typically emitted through point sources or as fugitive emissions. Examples include production processes that use chemicals (e.g., solvents, adhesives, printing, dyeing) processes that emit dust/particulates, products of combustion, or other hazardous or toxic air pollutants.
Reportable Pollutants in the FEM
The Higg FEM requires that facilities track and report emission data for refrigerants used onsite and several key pollutants listed below. Additional details on reporting pollutant quantities in the FEM are provided in the relevant questions.
| Pollutants Emitted from Operations | Pollutants Emitted from Production Processes |
| Particulate Matter Nitrogen Oxides (NOx) Sulfur Oxides (SOx) Carbon Monoxide (CO) Volatile Organic Compounds (VOC) or Total Organic Carbon (TOC) Hazardous or Toxic Air Pollutants (HAP/TAP) Ammonia (NH3) Ozone (O3) Ozone Depleting Substances (ODS) Carbon disulfide (CS2) Hydrogen sulfide (H2S) |
Volatile Organic Compounds (VOC)
VOC are defined as organic chemical compounds that under normal conditions are gaseous or can vaporise and enter the atmosphere. The general criteria for determining whether a pollutant is considered a VOC is provided below:
- It contains carbon.
- Vapor Pressure is > or = 0.01 kPa (~0.075 mmHg) at 20C
- Boiling point is < or = 250C at standard pressure of 101.3 kPa
Hazardous or Toxic Air Pollutants (HAP/TAP)
Are defined as compounds that are known or suspected to cause significant harmful impacts to human health or the environment.
Country-specific regulation may define which air pollutants are designated as HAPs/TAPs within a specific jurisdiction. Where country-specific definitions or regulations do not define HAPs/TAPs, recognized lists from other jurisdictions may be referenced when determining if pollutants from facility operations should be included in the reported quantity for HAPs/TAPs. For example, information on HAPs from the US EPA can be found here https://www.epa.gov/haps. A current list of HAPs (as defined by the US EPA can be found here: https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications
Best Available Technology (BAT)
In the FEM, the concept of Best Available Technology (BAT) is defined as the most effective and advanced technology including materials, processes, and equipment that is currently available that will result in reduction of pollutants emitted and minimizing impacts to the environment. This is further defined as follows:
- Best in relation to technology means the most effective method in achieving a high level of protection of the environment.
- Available means technology that is developed on a scale that allows for economically and technically viable implementation taking into consideration the costs and benefit and that the technology reasonably accessible to the business carrying on the activity regardless of whether the technology is developed or widely implemented locally.
- Technology refers to materials, processes, and equipment, and the way it is designed, built, maintained, operated.
The adoption of BAT often depends on the specific operations, emission source and pollutant characteristics at a facility. For example:
- In some cases, the most effective current solution for reducing particulate emission may be an Electrostatic precipitator (ESP) and in other cases a form of wet scrubbing or cyclone filtration may be more effective.
- In some cases, the most effective current solution for reducing emission of organic compounds (e.g., formaldehyde) may be substitution for an alternative chemical input or the use of a control technology such as thermal oxidation.
The adoption of BAT often requires actions such as process/equipment modifications, the installation of control equipment, research into alternative raw material/chemical inputs that requires planning and evaluation of available solutions and capital allocation. Facilities should have processes in place to stay up to date with emerging technologies and regularly review these to determine viable options for both new and existing emission sources to determine the most effective means to reduce the emissions to the air. These evaluations should be included in the long-term planning to reduce emissions.
Evaluation of BAT must be conducted by qualified professionals such as process or environmental engineers who understand the facility’s emissions and pollutant characteristics (e.g., pollutant loading, emission source operational parameters such as temperature and moisture content, etc) and the design and operational characteristics of any controls or alternative technologies being evaluated in order to determine potential air emission reductions through engineering estimates or other air emission calculation methodology.
Note: In some countries, requirements to adopt BAT or procedures to determine BAT may be defined by local regulations or directives, which should be complied with, however facilities should strive to conduct a detailed evaluation of all available technologies to reduce environmental impacts to the lowest achievable level.
Air Emissions Data Quality
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 emission sources.
- Accuracy – Ensure that the data input into the air emissions tracking program is accurate and is derived from credible sources (e.g., emissions testing/monitoring or emissions calculations are based on established scientific measurement principles or established emissions estimation methodologies, 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.
Applicability Questions
To determine which questions you will need to complete in the Air Emissions section, you will need to complete the applicability questions listed below. You will be asked to select which air-emitting equipment, processes, and potential pollutants you have on-site. Your selections will direct you to complete 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 answer any additional questions in this section.
Notes:
- If you have air emissions from facility operations (e.g., boilers, generators), you will answer relevant questions about emissions to air from facility operations sources.
- If you have air emissions from production processes (e.g., solvents or adhesives), you will answer relevant questions about emissions to air from production sources.
1. Does your facility contain any of the following operations equipment?
- Boiler
- Generators
- Combustion Engines (e.g., gasoline powered pumps)
- Industrial Ovens (for heating/drying/curing)
- Heating and Ventilation (Combustion Heating (Furnace))
- 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 (i.e. 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 onsite during production processes, or a facility may have a dedicated room for spot cleaning.)
- Sprayed chemicals or paints
- Other sources of ozone depleting substances (ODSs)
- Other sources of particulate matter (PM)
- Other sources of volatile organic compounds (VOCs)
- Hazardous or Toxic Air Pollutants (HAPs/ TAPs)
3. Does your facility produce Man-made Cellulose Fibre (MMCF)?
- Yes should be selected only if your facility manufactures MMCF. Facilities that use MMCF to make final products should select No.
Air Emissions – Level 1
Air Emissions – Level 2
Higg FEM Level Progression
If your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:
Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?
If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.
If you Answer No: Level 2 and 3 questions will not be available in this section.
Notes:
- If your facility did not achieve Level 1 in this section, answering Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
- It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.
- Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3