Summary of Updates to the Higg FEM 4.0 (For FEM 2023)
This summary of updates is to provide a detailed level of content changes from Higg FEM 2022 (FEM 3.0) to Higg FEM 2023 (FEM 4.0) in each Higg FEM section.
The entire How-to-Higg FEM Guide has been reviewed and updated in each question to provide as much clarity as possible for all stakeholders to understand the intent and expectations.
Facility Site Info
- Revamp the Facility Profile question structure
- Standardize Unit of Measure on Annual Volume based on Facility Type
- Provide additional Unit of Measure on Annual Volume as an Optional field
| Question 4 | NEW Question “Does your facility operate within an industry zone/park?” |
| Question 5 | Updated Question text to clarify the pre-treatment refers to incoming water pre-treatment Added a new secondary question “How many employees are engaged in the operation and regular maintenance of the water treatment processes?” |
| Question 7 | NEW Question “Has your facility undergone any Environmental Assessment /Audit within the reporting year? ( in addition to a Higg vFEM)” |
| Question 8 | NEW Question “Is this facility’s GHG emissions included in a broader corporate disclosure?” |
Permits
- Added Reasons as a selection option to provide clarity on why Operating license and and/or other required environmental permits are invalid
- Revamped the environmental permits selection to include broader environmental aspect and potential facility operation
EMS
- Questions have been moved around in sequence and in between Levels to provide a better structure on management system questions.
| Question 6 | Updated question text to clarify the intent of the question is to understand environmental permits in addition to the legally required permits |
| Question 7 | NEW Question ”Does your facility provide training to employees on environmental awareness and company environmental management strategy?” |
| Question 8 | Updated question text to clarify the intent of the question is to enable employees to report on environmental incidents. |
| Question 10 | NEW Question “Can you please confirm there is no soil and/or groundwater contamination in your facility?” |
| Question 13 | Updated question text to clarify the intent of the question is to build awareness of your environmental impacts and performance. Move from being Level 3 question to being Level 2 question |
| Question 14 | Updated question text to clarify the intent of the question |
| Question 15 | Updated question text to clarify the intent of the question |
Energy
- Revamp the Energy questions to collect necessary data to calculate Scope 1 and Scope 2 carbon emissions of a facility
- Split the energy source between Domestic/Industrial use vs. energy source for company owned and controlled vehicles
- Ability to report energy consumption between Domestic use and Industrial use
- Categorize energy source into Purchased Energy, Renewable Energy, Non-Renewable Energy and Biomass
| Question 4 | NEW Unscored Question “Does your facility purchase Carbon Offsets?” |
| Question 7 | NEW Question “Does your facility identify and track separately energy use in domestic vs. production?” |
| Question 8 | NEW Question “Does your facility track energy/fuel use from each energy/fuel source of company owned and controlled vehicles that your facility utilizes?” |
| Question 14 | Updated question text to clarify the intent of the question |
| Question 16 | NEW Question “Has an energy audit been conducted at your facility within the last 5 years?” |
| Question 17 | NEW Question “Does your facility have a plan to phase-out Coal?” |
| Question 19 | NEW Question “Has your facility reduced your facilities overall Scope 1 and Scope 2 GHG emission compared with its baseline in the reporting year?” |
| Question 20 | Updated from an Unscored to Scored question |
| Question 21 | Updated from an Unscored to Scored question |
| Question 22 | NEW Question “Does your facility have a plan to phase-out any fossil fuel, other than Coal?” |
| Question 23 | NEW Question “Has your facility successfully replaced any fossil fuel(s) with renewable energy?” |
Water
- Added new applicability questions to understand how a facility is using water and whether or not a facility can track water consumption based on each facility type. NEW Applicability question:
- Is your facility using water for production use?
- Is your facility able to separately report water consumption by each facility type?
- Ability to report water consumption between Domestic use and Industrial use
- Categorize water source into Blue Water and Grey Water
| Question 4 | NEW Unscored Question “Does the water consumption you track and report include the rejected water quantity from pre-treatment?” |
| Question 5 | NEW Question “Are you able to identify and track domestic and production water use separately?” |
| Question 6 | NEW Question “Are there any Legally Mandated Groundwater Abstraction Restrictions in your country?” |
| Question 7 | NEW Question “Does your facility have a process to monitor the water supply network in your facility for leaks?” |
| Question 9 | NEW Unscored Question “Are you able to set a baseline separately for water use in domestic vs. production?” |
| Question 13 | Move from being Level 3 question to being Level 2 question |
| Question 14 | Updated Questions intent to emphasize on reducing blue water except rainwater Question text “Has your facility set targets for reducing blue water use from any source, except rainwater?” |
| Question 15 | NEW Question “Has your facility set targets for increasing grey water use from any source?” |
| Question 16 | NEW Question “Does your facility set targets to improve the rainwater harvesting capacity at your facility?” |
| Question 18 | Updated Questions intent to emphasize on reducing blue water Question text “Has your facility reduced blue water use for any sources, compared with your baseline?” |
| Question 19 | NEW Question “Has your facility increased grey water use for any sources, compared with your baseline?” |
| Question 20 | NEW Question “Does your facility have a plan to reduce your absolute bluewater use?” |
| Question 21 | NEW Question “Have you eliminated (reduced more than 90%) the use of groundwater for your production processes?” |
| Question 22 | NEW Question “Can your facility demonstrate you have reduced your overall absolute bluewater use?” |
| Question 23 | NEW Question “Does your facility report or disclose water risk and consumption to an external reporting standard, i.e. GRI / CDP?” |
| Question 24 | NEW Question “Can your facility demonstrate positive impact onto the water catchment/basin area or water source in your community?” |
| Question 25 | NEW Question “Does your facility implement any “leading technology” practices to significantly reduce water use in the manufacturing process?” |
| Question 26 | NEW Unscored Question “Has your facility set a Science-Based Target on Water?” |
Wastewater
- Added Questions set in alignment with ZDHC Wastewater Sludge Guideline
- Expanded testing result questions of ZDHC WAstewater Guidelines into multiple primary questions to allow better analytics capabilities
- Separated questions about reuse wastewater and recycle wastewater to reflect its difference
| Question 2 | NEW Unscored Question “Does your facility monitor the BOD5 Level of your wastewater?” |
| Question 3 | Updated Question to emphasize the intent of the question. Question text “Does your facility have a mechanism to prevent stormwater from being contaminated before it is discharged into the environment?” |
| Question 4 | Move the original secondary question to primary question to emphasize the important of maintaining current contract / permit and manage offsite wastewater treatment plant. Question text “Does your facility maintain a copy of the current contract, permit, agreement or invoices regarding wastewater discharge regulatory compliance requirements for your facility to the offsite wastewater treatment plant?” |
| Question 5 | NEW Question “Does your facility have a mechanism or process to monitor whether your wastewater treatment plant is functioning as per the design parameters (Volume, Flow Rate, Input /Output Quality)?” |
| Question 7 | Updated Question text to emphasize the intent of the question. Question text “Can you please confirm that, wastewater generated by the facility is not discharged to the environment through leaking and/or bypassing?” |
| Question 8 | NEW Unscored Question “How many separate and distinct sources of wastewater sludge are managed and disposed of?” |
| Question 9 | NEW QUestion “Does your facility track its industrial wastewater sludge generated in the reporting year?” |
| Question 10 | NEW Question “Does your facility track its domestic wastewater sludge generated in the reporting year?” |
| Question 11 | NEW Question “Does your facility have well-marked, designated wastewater sludge storage areas?” |
| Question 12 | Updated Choice of Pathway of disposing industrial wastewater sludge |
| Question 13 | NEW Question “Does your facility maintain manifests or similar documentation of the handling, transportation, processing, and disposal of sludge, accounting for all industrial wastewater sludge generated at the facility?” |
| Question 14 | Move the original secondary question to the primary question to emphasize the importance of providing training to relevant employees. Question text “Does your facility provide training to all employees whose work involves wastewater sludge handling (such as maintenance and custodial staff)?” |
| Question 15 | Updated Choice of Pathway of disposing domestic wastewater sludge |
| Question 16 | Revamp the Septic question to emphasize the relevancy Question text “Does your facility manage the residue of the Septic System?” |
| Question 17 | NEW Unscored Question “Have you tested your wastewater against the legal requirements that apply to your facility?” |
| Question 18 | Move from being Level 2 question to being Level 1 question, Unscored ; while also opportunity to score the same question in Level 2 Question text “Are you reporting against any wastewater standard (additional to the legal requirement)?” |
| Question 20 | Move the original secondary question to the primary question to allow future analytic capability. Question text “Are you in compliance/conformance with the reported wastewater standard?” |
| Question 21 | NEW Question “If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and meet foundational level conventional parameters and Anion in the reporting year? (Take the last test of the reporting year)” |
| Question 22 | NEW Question “If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and meet foundational level heavy metal limits in the reporting year? (Take the last test of the reporting year)” |
| Question 23 | NEW Question “If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and detect any MRSL parameters in the reporting year? (Take the last test of the reporting year)” |
| Question 24 | NEW Question “If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and get conformance against microfiber parameters in the reporting year?” *Available from FEM 2025 onwards, inline with the release of the ZDHC guideline |
| Question 25 | NEW Question “Does your facility track wastewater sludge by each source which includes all sludge generated onsite and its disposition in your sludge inventory?” |
| Question 26 | NEW Question “Does your facility maintain manifests or similar documentation of the handling, transportation, processing, and disposal of sludge, accounting for all domestic sludge generated at the facility?” |
| Question 27 | Move the original secondary question to the primary question. Move this question from Level 1 to Level 2. Changed to be an Unscored Question. Question text “Do you have a plan to upgrade your septic tank to a more modern wastewater treatment approach?” |
| Question 29 | NEW Question “Does your facility engage/collaborate with your off-site wastewater treatment plant to improve their wastewater treatment and/or engage in recycling?” |
| Question 30 | Updated Question text “Does your facility reuse process wastewater as process water?” |
| Question 31 | Updated Question text “Does your facility recycle industrial wastewater for production processes?” |
| Question 32 | Updated Question text “Does your facility recycle domestic wastewater for domestic use (i.e. landscape irrigation, toilets)? (only apply to Domestic wastewater onsite only)” |
Air Emissions
- Revamp the entire section to reflect many applicability questions and question relevancy.
- Added new applicability questions to understand whether or not the facility is producing Man-made Cellulose Fibre (MMCF). NEW Applicability question:
- Does your facility produce Man-made Cellulose Fibre (MMCF)?
- Added Questions set in alignment with ZDHC Air Emission Position Paper / Guideline, ZDHC MMCF Guideline
- Updated Questions related to refrigerants to allow proper carbon emissions calculation.
| Question 1 | NEW Question “Has your facility created an inventory of all point source air emission sources at your facility?” |
| Question 2 | NEW Question “Has your facility created an inventory of all mobile and fugitive air emission sources at your facility?” |
| Question 3 | NEW Question “Is your facility in compliance with all applicable legal requirements relating to air emissions including all permitting, reporting and testing requirements?” |
| Question 4 | NEW Question “Do you know what refrigerant(s) your facility uses?” |
| Question 5 | NEW Question “Does your facility have preventative maintenance procedures in place to avoid refrigerant leakage from your equipment?” |
| Question 7 | NEW Question “Are you monitoring or reporting against any industry guidelines or tools for air emissions (additional to the legal requirement)?” Unscored in Level 1, but Scored in Level 2 |
| Question 8 | NEW Question “Does your facility track the total annual emissions quantities of key pollutants from all point source emissions from facility operations?” |
| Question 9 | NEW Question “Does your facility track the total annual emissions quantities of key pollutants from all emissions from production?” |
| Question 10 | NEW Question “Has your facility established an implementation plan to reduce air emissions from facility operations?” |
| Question 11 | NEW Question “Has your facility established an implementation plan to reduce air emissions from production processes?” |
| Question 13 | NEW Question “Are you meeting / conforming to the requirements of the industry guideline(s) on air emissions?” |
| Question 14 | NEW Question “Do you have a plan to or have you already replaced your current refrigerant with low ODP / low GWP refrigerant gasses that goes beyond current legal requirements?” |
| Question 15 | NEW Question “Does the facility have business policies or procedures in effect that ensure that all Best Available Technologies (BAT) for air emissions reductions are considered in the long-term environmental plans of the facility?” |
| Question 16 | NEW Question “Has your facility made progress on your implementation plan to reduce air emissions from facility operations in the reporting year?” |
| Question 17 | NEW Question “Has your facility made progress on your implementation plan to reduce air emissions from production processes in the reporting year?” |
| Question 18 | NEW Question “Has your facility replaced any refrigerant with low ODP / low GWP refrigerant gasses that goes beyond current legal requirements?” |
| Question 19 | Updated Question to clarify the intent of the question Question text “Have you utilized the best available technology (BAT) for the major air emissions from your facility?” |
Waste
- Separated Questions set between Non-Hazardous Waste and Hazardous Waste for applicability pathway
- Categorize waste disposal method into Preferred Options, Less Preferred Options and Least Preferred Options
- Added Questions associated with each category of waste disposal method
| Question 1 | Refined the list of non-hazardous waste streams in answer options |
| Question 2 | Move the original secondary question to the primary question. |
| Question 5 | Refined the list of hazardous waste streams in answer options |
| Question 10 | Added two new hazardous waste storage area requirements |
| Question 11 | Added one new non-hazardous waste storage area requirement |
| Question 12 | Updated Questions to include forbidding intentional release of waste into soil and/or water. Question text “Does your facility forbid all irresponsible waste disposal actions including open burning, open dumping, burying waste and intentional release into soil and/or water?” |
| Question 13 | NEW Question “Does your facility provide awareness training to employees regarding segregation of waste?” |
| Question 17 | NEW Question “Which waste disposal methods are used for your facility’s wastes (Select all that apply)” |
| Question 21 | Updated question to provide example on proper improvement behavior |
| Question 22 | Updated answer option with a list of expected practices and checkboxes |
| Question 23 | NEW Question “Does your facility have an implementation plan to switch to a more preferred waste disposal method?” |
| Question 28 | NEW Question “Does your facility validate the final disposal and treatment of all non-hazardous wastes?” |
| Question 29 | Updated Question to clarify the intent of the question Question text “Has your facility disposed of waste through Preferred disposal methods?” |
| Question 30 | NEW Question “Do you or are you willing to work on circular economy systems?” |
Chemicals
- Added new applicability questions to understand how a facility uses chemicals and to properly determine applicability pathways. NEW Applicability question:
- Does your facility use commodity chemicals?
- Does your facility implement an MRSL?
- Facilities will answer the applicable questions based on their facility operations and how they use Chemicals in their facility. Questions are being tag as Use Chemicals in Production, Use Chemicals in Facility Operations, USe Chemicals in Tooling/Equipment, Only Use Spot Cleaner, and Facility that either do not use chemicals onsite or Use Minimal Chemicals)
- Added Questions set in alignment with ZDHC CMS Technical Industry Guide (TIG)
- Separated questions between RSL and MRSL to allow applicability to work
- Separated questions between a main designated chemical storage area and sub-storage areas
| Question 1 | NEW Question “Does your facility have a written Chemical Management System (CMS) policy?” |
| Question 2 | NEW Question “Have you assigned the responsibility of implementing and maintaining the Chemical Management System (CMS) to a team/staff member?” |
| Question 3 | NEW Question “Does your facility have a chemical purchasing policy?” |
| Question 5 | Move the original secondary question to the primary question to clarify the importance of maintaining relevant data in Chemical Inventory List (CIL) |
| Question 7 | Added secondary question on evaluating employees after the training |
| Question 8 | Added secondary question on evaluating employees after the training |
| Question 15 | NEW Question “Does your facility have well marked sub-storage areas?” |
| Question 19 | NEW Question “Does your facility engage contractor(s) or subcontractor(s) on MRSL / RSL?” |
| Question 20 | NEW Question “Does your facility engage upstream supplier(s) on MRSL / RSL?” |
| Question 21 | NEW Question “Does your facility have the following capabilities and authority in your Chemical Management System (CMS) team?” |
| Question 23 | Move this question from Level 3 to Level 2. |
| Question 25 | NEW Question “Have you adopted and implemented the ZDHC Roadmap to Zero (or the Supplier to Zero) programme on sustainable chemical management and its impact areas or other chemical management related industry programs?” |
| Question 26 | NEW Question “Do you have a transparency policy or procedure in which you share information regarding chemical products, chemical waste, and wastewater with stakeholders (For example: with ZDHC, chemical formulators, brands/retailers, authorities, NGOs)?” |
Higg FEM Glossary
- Added the definition of each Material processes
- Reviewed and Update FEM Glossary where necessary to reflect the question content expectation
Appendix A: FEM Foundations
- New sets of Questions are identified in FEM Foundations.
- Guidance for specific FEM Foundations Questions are added.