Facility Site Information & Permits 2023

General Introduction

The Site Information & Permits section of the FEM requires you to complete questions and provide detailed information relating to your facility’s location, size, and operations. Your responses to these questions will be used to categorize your facility for comparative analytics. You will also be asked for information on your facility’s permits on this page. The intent of this is to determine your compliance status with relevant environmental permits. Please provide information on any rules or regulations your facility is required to follow such as permits, authorizations, licenses, registrations, certificates, or other compliance documentation your facility is required to follow. Examples of non-permit requirements to include are annual required government reports and required registration of specific chemicals. Note: The Site Information & Permits section of the FEM should be completed first before moving on to any other sections of the module.

Facility Scope

The FEM is a facility level assessment that is designed to be completed by a single business entity or manufacturing unit. It is understood that there may be complexities in defining this globally therefore, the following definitions and exceptions apply when determining the facility scope for the completion of a single FEM.
  • The FEM shall cover the entire facility which is defined as all onsite business activities of a legal business entity as defined by the scope of the applicable business license/operating permit in the facility’s country of operation. This includes all owned and operated onsite processes, equipment, and areas (e.g., facilities cannot exclude specific operations or facility areas from the FEM).
  • One (1) Higg FEM is required for each legal business entity as defined by the applicable business license/operating permit except in the following circumstance:
    • Where multiple manufacturing units (facilities) are located at the same premises with different business licenses, however the facilities are fully owned and operated by a single legal business entity, one (1) FEM can be completed.
      • Note: If the separate facilities are not legally owned/operated by a single parent business entity with a valid operating license, which includes ownership of all facilities, separate FEMs must be completed for each facility.
    • Where a material or component supplier of the facility with a separate business license is located at the same premises and supplies 100% of its materials/services to the facility, its operations can be included in the facility’s FEM.
      • Note: If the material or component supplier provides materials or services to other facilities, it must not be included in the facility’s FEM scope and would require a separate FEM.
    • Facilities located at two separate physical locations (i.e., different legal addresses) must complete one (1) FEM per location regardless of ownership (e.g., if two facilities are located at different physical locations, but their operations are covered under one (1) parent business license, separate FEMs are still required.)

Scoring

The Site Information and Permits section of the FEM is NOT SCORED. This means that you do not get points for being in compliance with basic legal requirements. However, the following scenarios will result in a score of ZERO for the entire FEM as these are considered basic compliance practices that must be met to achieve a FEM score.
  • If your facility does not have a valid operating license. (i.e., if you answer “No” to the question “Does your factory site have a valid operating license?”).
  • If your facility does not have a required environmental permit. (i.e., if you answer, “Not Available” to the question “What is your status for this permit?” for any required environmental permits).
    • Note: If the permit status is “Not available due to authorization in progress” or “Available but Invalid” the FEM may be scored based on the condition below.
  • If your facility is no longer able to meet the requirement of obtaining a required permit (i.e., if you answer, “Facility is no longer able to meet the requirement of obtaining the required permit” to the question “Please specify the reason why this permit is invalid?”).

Site Information

Facility Profile Questions Pathway (by Facility Type) The Site Information section contains questions on facility type, product and material categories, facility processes and industry sector. Your facility’s responses to these questions will lead you through a series of predefined selections where you can select the applicable responses. Note: It is possible for multiple profile pathways to apply if more than one facility type is selected. This means that the facility would need to input information about the product and material category, and facility processes for each selected facility type.
  • For example, a vertical integrated facility will select two facility types (“Finished Product Assembler” and “Material Production (Raw and intermediate materials are transformed into their final state before assembly)”) and will need to provide information on the products, materials and processes for each facility type.

Facilities will select the country or region that the facility is located in.

Facilities will first select their facility type(s) from the list of options below. Based on the selected facility type(s) and then additional questions on applicable product categories, materials used, facility processes, and industry sector will apply. Note: If applicable, more than one facility type should be selected, for example:
  • If you are a vertically integrated facility with cut and sew operations as well as wet processing (e.g., dyeing) you would select both “Final Product Assembler” and “Finished Product Processing (Product Printing, Product Painting, Product Dyeing, Product Laundering and Product Finishing, Embroidery & Embellishments)”. OR
If you are a hardgoods facility that assembles final product and manufactures hard components on site, you would select both “Final Product Assembler” and “Component / Sub-Assembly Manufacturing (including Packaging)”  
Facility Type Option Examples 
Finished Product Assembler Finished goods production/ final product assembly.
Finished Product Processing (Product Printing, Product Painting, Product Dyeing, Product Laundering and Product Finishing, Embroidery & Embellishments) Printing and dyeing of materials, including wet processing, and laundering
Component / Sub-Assembly Manufacturing (including Packaging) Label, zipper, snap, button, elastic buggie, cardboard
Material Production (Raw and intermediate materials are transformed into their final state before assembly) Fabric dye-house, fabric manufacturer, yarn dyeing, PCB manufacturer, Hardgoods: Metal pieces, wooden laminates, metal plating
Raw Material Processing (Raw Materials are processed into intermediate material products) Yarn spinning Hardgoods: foundry, metal processing, plastic injection
Raw Material Collection & Bulk Refining (Materials are collected/extracted/farmed and refined to bulk commodity state) Cotton farming and ginning, processing of bottles, fabric scrap, etc. into new recycled materials, forestry, mining, crude oil refinery

This question will be only applicable to facilities that selected the following as their facility type(s):

  • Finished Product Assembler, and/or 
  • Finished Product Processing (Product Printing, Product Painting, Product Dyeing, Product Laundering and Product Finishing, Embroidery & Embellishments)

Facilities will select all of the applicable product categories from the list below. 

Note: For each selected product category, a detailed product list will be available for the facility to select which specific products they manufacture for each selected product category.

  • Apparel
  • Footwear
  • Home Textiles (includes bed linens, tablecloths, towels, cloth napkins, and similar products)
  • Accessories (includes handbags, jewellery, belts, and similar products)
  • Home Furnishings
  • Electronics
  • Toys
  • Outdoor Sporting Goods – Soft goods (includes tents, backpacks, luggage, harnesses, slings etc. with a textile component)
  • Outdoor Sporting Goods – Hard Goods (includes bikes, coolers, climbing gear, watercraft, and other equipment made of metal, plastic, or wood)

Facilities will select all the applicable type(s) of material categories from the list below based on their facility type. 

Note: For specific facility types, a detailed list of materials will be available for the facility to select which materials they use for each selected material category.

  • Barriers
  • Foams
  • Insulation Materials
  • Leather
  • Metals
  • Plastics
  • Rubbers
  • Synthetic Leathers
  • Textiles
  • Wood-Biomass Based
  • MMCF
  • Electronic related material
  • Packaging related material
  • Fiber (natural and man-made)
  • Chemicals
  • Metals
  • Other

Facility Processes

Facilities will select all the applicable processes from the available lists based on their facility type. Note: The list of specific facility processes that can be selected will be predefined for each facility based on their selected facility type, products type (if applicable), and materials used.

Facilities will select all the applicable industry sectors from the list below. 

Notes:

  • Industry sector refers to the industry which the facility makes products or materials for.
  • Packaging manufacturers that supply packaging materials should select “Other” as their facility type.
    • Apparel
    • Footwear
    • Home Textiles (includes bed linens, tablecloths, towels, cloth napkins, and similar products)
    • Accessories (includes handbags, jewellery, belts, and similar products)
    • Home Furnishings (Non-Textile)
    • Electronics
    • Toys
    • Outdoor Sporting Goods – Soft goods (includes tents, backpacks, luggage, harnesses, slings etc. with a textile component)
    • Outdoor Sporting Goods – Hard Goods (includes bikes, coolers, climbing gear, watercraft, and other equipment made of metal, plastic, or wood)
    • Other

Enter a total number (not a range) of days that the facility operated in the reporting year. Operating days are considered days when production and/or production related activities (e.g. product/raw material loading/shipment) were conducted at the facility.  Any operating day where the number of hours in operation OR the number of workers is less than 50%, then count the day as 0.5 day. Where the number of hours in operation OR the number of workers is greater than 50%, then count the day as 1 day.

For Higg FEM Verification, it is recommended that summaries of operating data be available 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 any relevant supporting evidence be readily available for review.

Enter the average number (not a range) of full-time and temporary employees that worked at the facility in this reporting year.  The calculation guidance below applies for both full-time and temporary employees.

How To Track Facility Data:

Facilities should establish a process to track the number of workers in each pay period (e.g. weekly, bi-weekly, monthly). The average number of employees (full-time or temporary) can then be determined using the following guidance:

  • Add the total number of employees your facility paid in all pay periods during the year.
  • Count the number of pay periods your facility had during the year. 
  • Divide the number of employees by the number of pay periods.
  • Round the answer to the next highest whole number to get the annual average number of employees 

For example:

  • Pay period 1: 520 employees
  • Pay period 2: 525 employees
  • Pay period 3: 545 employees
  • Average number of employees: 530 [(520+525+545)/3]

Note: The same calculation methodology should be applied for full-time and temporary employees.

For Higg FEM Verification, it is recommended that summaries of this data be available 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 any relevant supporting evidence be readily available for review.

How This Will Be Verified:

Documentation Required: 

  • Payroll/accounting records that show the number of each worker category (full-time and temporary) in each pay period.
  • Payroll/accounting records that show the number of pay periods in the reporting year.

Facilities will be required to complete a table to provide the following information on their annual production volume in the FEM reporting year for each applicable facility type:

  • Facility Type (This will be pre-populated based on the selected facility types)
  • Annual Quantity
  • Unit of Measure (This will be pre-populated based on the selected facility types)
  • Annual Quantity (Additional Option)
  • Unit of Measure (Additional Option)

Note: The additional options for reporting annual quantity and unit of measure are provided to allow for reporting of annual production in different units from a predefined list of units of measure for each facility type.

Reporting Production Volume in the FEM

Facilities should report the total amount of product shipped/sold in the FEM reporting year.

Note: Total amount of product shipped/sold should not include the total amount of rejects in the last calendar year.

Why does the FEM use shipped/ sold quantity instead of annual production output?

The main rationale is to create a consistent production metric that all facilities are able to track and the data are more comparable for industry benchmarking at the end. Besides, using shipped/ sold amount as the metric is to discourage excessive or unnecessary production including leftovers, semi-products, samples and rejects which are also an environmental concern.

We understand that some products may have to be shipped / sold after the calendar year that they are actually manufactured. The limitation of using shipped/ sold quantity is – the reported energy, water and waste amounts are not covering the products being made in the same calendar year but shipped in the following year, instead they would cover some products which are shipped in the same year but actually being produced in the previous year. By considering this as a usual practice in the factory every year, the impact to the total shipped/ sold quantity should be relatively limited. However, if there is any exceptional case that may cause a significant impact on the environmental performance of the facility (e.g. demonstrate improved energy / water consumption), we encourage the factories to communicate to relative stakeholders to explain their situation if needed.

Reporting Standard Allowed Minutes in the FEM

For some facility types, additional production volume reporting options allow facilities to report in Standard Allowed Minute (SAM) which is a metric that provides an indicator of the time allowed to produce a product by workers including general allowances (e.g., efficiency, machine, personal, fatigue allowances, etc.). The guidance below provides an overview and examples how SAM can be determined.

Different products utilize different amounts of time and resources during production which will in turn influence resource consumption (i.e., energy, water used, etc.). SAM can be used as a production metric to relate resources consumption and the environmental impact to different types of products or be added together and used as a metric to normalize resource consumption and environmental impacts for production over a period of time (e.g., a calendar year). It should be noted that the SAM will vary by the type of product (e.g. shorts versus a jacket).

Year on year, tracking of SAM against energy, water and other parameters can allow facilities to review the efficiency of resource consumption and help inform performance improvement.

When reporting production volume in SAM, the user must report the TOTAL SUM of SAM for the reporting year and not the INDIVIDUAL SAM for each product type that is manufactured in your facility.

Once individual SAM values are known for a specific product, the product SAM can be multiplied by the number of products shipped / sold. This is done across all product types / categories and the total is calculated to arrive at the TOTAL SAM. This total is reported as the “Annual Quantity”.

Example for Apparel facility:

Product typeProcessesSAM per pieceNumber of products shipped/ sold in reporting yearTotal SAM per product type
Polo shirt

Cutting

Sewing

Packaging

15100,00015 x 100,000= 1,500,000
 
V-neck shirt

Cutting

Sewing

Packaging

12500,00012 x 500,000 = 6,000,000
Total SAM7,500,000

 

Example for Hardgoods facility:

Product typeProcessesSAM per pieceNumber of products shipped/ sold in reporting yearTotal SAM per product type
Rucksack

Cutting

Gluing

Sewing

Assembly

Packaging

4520,00045 x 20,000= 900,000
 
Tent

Cutting

Gluing

Sewing

Assembly

Packaging

6030,00060 x 30,000= 1,800,000
Camping table

Cutting

Assembly

Packaging

15010,000150 x 10,000 = 1,500,000
Total SAM4,200,000

 

There are different approaches to calculating SAM, however if a consistent methodology is used across all products, this will produce comparable data that can be compared year over year.   Below are some resources that look at the different methods of determining SAM (which is often used interchangeably with Standard Minute Value or SMV):

How To Track Facility Data:

Facilities should establish a process to track the amount of product shipped/sold in the last calendar year. For FEM Verification, it is recommended that summaries of this data (e.g., daily, weekly, monthly records) be tracked 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 any relevant supporting evidence be readily available for review during Verification.

How This Will Be Verified:

Documentation Required

  • Production, sales, product shipment records that show the quantity of products shipped/sold in the reporting year.

Answer Yes if: Your facility is located inside a designated industry zone/park. 

Answer Yes if: Your facility performs onsite pre-treatment of incoming water and/or your facility performs onsite treatment of wastewater.

If you answer Yes to this question, you will be asked to select the type of pre-treatment and/or wastewater treatment that your facility performs onsite from the list of treatment options below and complete the following sub questions:

Note: After selecting the applicable treatment options, facilities will also need to select the specific treatment methods/technologies used from a predefined list for each treatment option. 

  • Select the type of treatment.
    • Incoming Water Pre-Treatment
    • Primary Treatment
    • Secondary Treatment
    • Tertiary Treatment
    • Advanced treatment / Zero Liquid Discharge (ZLD) / Salt recovery
    • Sludge Treatment
  • How many employees are engaged in the operation and regular maintenance of the water treatment processes?
  • Please upload your facility’s water treatment process flow and hydraulic diagrams, if you have one.

Suggested Uploads: Facility’s water treatment process flow and/or hydraulic diagrams.

How This Will Be Verified:

Documentation Required 

  • Facility’s water treatment flow chart and hydraulic diagrams

Inspection – Things to Physically Look For: 

  • Observations onsite are consistent with the facility’s reported water/wastewater treatment processes.

Answer Yes if: Your facility participated in industry programs related to sustainability and/or have valid sustainability related certificates during the FEM reporting year.

Note: Brand or customer-specific auditing schemes that include environmental aspects should not be reported in this question as the focus is on broader industry sustainability programs or initiatives such as those listed in the Higg FEM.

If you answer Yes to this question, you will be asked to select the program and provide the following information on your facility’s participation in the program, if applicable:

  • How long have you been in this program?
  • Enrollment/Validity Period.
  • Start Date (Month/Year)
  • Enrollment/Validity Period.
  • End Date (Month/Year), if applicable. (Optional Field. Leave blank if there is no end date)
  • What rating/status did you receive?
  • If available, please enter a direct link you can provide to view the status of this program or certificate.
  • If a direct link is not available, please upload a copy of the program enrollment status or certificate.
  • Provide any additional notes.

Suggested Uploads:

  • Documentation of ALL programs the facility has participated or enrolled in, which includes the name of the program, any certification or declaration of enrolling the program.
  • Result of the industry program (e.g., certification), if applicable.

Technical Guidance:

Industry Programs enable facilities to build robust programs and practices that can improve overall sustainability or specific impact areas.  There are a wide range of industry programs related to Environmental Sustainability that are focused on supporting facilities in identifying environmental impacts and providing solutions or standards of practice that can help mitigate impacts to the environment (e.g., Apparel Impact Institute’s Clean by Design, Textile Exchange’s Global Recycled Standard (GRS), ZDHC CleanChain, bluesign System Partner, etc.)

Facilities can select programs from the list in the FEM or select Other to add programs that are not listed.

Note: Facilities can also use the listed programs to identify industry programs or initiatives that can be considered for adoption. The table below provides links to many of the available industry programs or initiatives.

Name of Industry Programs or Certification SchemeReference Link 
Alliance for Water Stewardship Standardhttps://a4ws.org/
Apparel Impact Institute Clean by Design (CbD)https://apparelimpact.org/clean-by-design-energy-water-efficiency-for-stage-1-tier-2/
Apparel Impact Institute Clean by Design +https://apparelimpact.org/clean-by-design-energy-water-efficiency-for-stage-2-tier-2-program/
Apparel Impact Institute Clean by Design Tier 1https://apparelimpact.org/clean-by-design-for-tier-1-energy-efficiency-stage-1-tier-1-program-cbd-s1t1/
Apparel Impact Institute Clean by Design Chemistry & Wastewaterhttps://apparelimpact.org/chemistryandwastewaterprogram/
Apparel Impact Institute Carbon Leadership Programhttps://apparelimpact.org/apparel-impact-institute-carbon-leadership-project/
Apparel Impact Institute Renewable Energy Pilothttps://apparelimpact.org/apparel-impact-institute-carbon-leadership-project/
Apparel Impact Institute Coal Phase Outhttps://apparelimpact.org/apparel-impact-institute-carbon-leadership-project/
Business Environmental Performance Initiative (BEPI)https://www.amfori.org/content/amfori-bepi
bluesign System Partnerhttps://www.bluesign.com/en
BREEAMhttps://bregroup.com/products/breeam/
BVE3 (Environmental Emission Evaluator)https://e3.bvonesource.com/cd/cpdHome
Country specific Green Building Certification 
Cradle to Cradle Certifiedhttps://www.c2ccertified.org/get-certified/product-certification
Eco-management and Audit Scheme (EMAS)https://ec.europa.eu/environment/emas/index_en.htm
Fair Wear Foundationhttps://www.fairwear.org/
Fashion for Goodhttps://fashionforgood.com/
Forest Stewardship Council (FSC) Certificatehttps://fsc.org/en
GOTShttps://global-standard.org/
Initiative for Compliance and Sustainability (ICS)https://ics-asso.org/
ICTI Ethical Toy Program (IETP) (Environmental Assessment)https://www.ethicaltoyprogram.org/en/our-program/environmental-assessment/
IDH Race to the Tophttps://www.idhsustainabletrade.com/
IFC PaCThttps://www.textilepact.net/
IPEhttps://wwwen.ipe.org.cn/
ISO 14001https://www.iso.org/iso-14001-environmental-management.html
ISO 45001 (previously known as OHSAS 18001)https://www.iso.org/standard/63787.html
ISO 50001https://www.iso.org/iso-50001-energy-management.html
ITC Resource Efficiency and Circular Productionhttps://www.sustainabilitygateway.org/; https://learning.intracen.org/course/info.php?id=1918
Leather Working Group Standardhttps://www.leatherworkinggroup.com/
LEEDhttps://www.usgbc.org/leed
OEKO-TEX Made in Greenhttps://www.oeko-tex.com/en/our-standards/made-in-green-by-oeko-tex
OEKO-TEX STePhttps://www.oeko-tex.com/en/apply-here/step-by-oeko-tex
Responsible Business Alliance Validated Assessment Program (VAP) (previously known as EICC)https://www.responsiblebusiness.org/vap/about-vap/
Roundtable on Sustainable Palm Oil (RSPO) certificationhttps://rspo.org/certification
Science-Based Target Initiativehttps://sciencebasedtargets.org/
Textile Exchange Global Recycled Standardhttps://textileexchange.org/standards/recycled-claim-standard-global-recycled-standard/
Textile Exchange Organic Content Standardhttps://textileexchange.org/standards/organic-content-standard/
Textile Exchange Recycled Content Standardhttps://textileexchange.org/standards/recycled-claim-standard-global-recycled-standard/
Textile Exchange RDS – Responsible Down Standardhttps://textileexchange.org/standards/responsible-down/
Textile Exchange RWS – Responsible Wool standardhttps://textileexchange.org/standards/responsible-wool/
ZDHC Gateway- Chemical Module (with InCheck Solution)https://www.zdhc-gateway.com/
ZDHC Supplier to Zero (with certificate)https://www.implementation-hub.org/supplier-to-zero
ZDHCGateway – Wastewater module(with ZDHC ClearStream)https://www.zdhc-gateway.com/modules/wastewater-module
Other 

How This Will Be Verified:

Documentation Required:

  • Documentation of ALL programs the facility has participated or enrolled in, which includes the name of the program, any certification or declaration of enrolling the program.
  • Result of the industry program (e.g., certification), if applicable.

Interview Questions to Ask:

  • Facility staff responsible for managing or implementing the program are knowledgeable on the program’s requirements or initiatives and what is required to meet or maintain the program requirements (e.g., certification maintenance)

Inspection – Things to Physically Look For:

  • Facility practices and onsite observations align with the reported program requirements or initiatives.

Answer Yes if: Your facility underwent one (1) or more environmental assessments or audits other than the Higg FEM in the FEM reporting year.

If you answer Yes to this question, you will be asked to complete the following sub question(s):

  •  Please indicate how many assessments/audits the facility has undergone?
  • Please indicate how many auditor person days in total these assessments/audits consisted of?
    • Notes: 
      • One person day is considered one day for one auditor (e.g., if there were 2 auditors for 1 day, the total for this audit would be 2 person days)
      • If the audit was combined with other aspects (e.g., social compliance) please indicate the number of person days spent on the environmental portion of the assessment/audit (e.g., 0.5 if a half day was used to cover the environmental portion of the assessment)
  • Please list out the types of individual Assessment /Audits that have been indicated.
    • Note: Facilities can indicate the name and/or type of the assessment as well as other relevant details (e.g. 2nd or 3rd party audit/assessment etc.)

Answer

Answer Yes if: Your facility’s GHG emissions are included in a broader corporate GHG report/disclosure.

Note: In this question a “broader corporate disclosure” refers to GHG reporting/disclosure that was performed by the facility or a business entity other than the facility (e.g., parent, or manufacturing group corporate headquarters, etc.) that includes the facility’s GHG emissions data in the overall GHG reporting/disclosure.

If you answer Yes to this question, you will be asked to select the program and provide the following information on your facility’s participation in the program:

  • What reporting platform is used?
    • CDP 
    • Corporate website or Sustainability report
    • Other
      • If other, please describe.

Suggested Uploads:

  • If available a copy of the corporate disclosure report (or link to reporting platform where the GHG report can be viewed. 

How This Will Be Verified:

Documentation Required: 

    • Documentation  that demonstrates the facility’s GHG emissions are included in a broader corporate GHG report/disclosure. 
  • A copy of the corporate disclosure report (or link to a reporting platform where the GHG report can be viewed, if applicable).

Interview Questions to Ask: 

  • Facility staff responsible supporting the corporate reporting/disclosure can describe how the facility’s GHG emissions data was provided and involved in the corporate reporting/disclosure.

Permits

Answer Yes if: Your facility has a current and valid operating license or if an operating license is not required by local law.

Answer No if: Your facility’s operating license is expired even if your facility is in the process of updating your operating license. 

Note: If you answer “No” this question you will score ZERO points for the entire FEM. This is because a valid and current operating license is required to score points in the Facility Environmental Module.

Suggested Uploads:

  • A copy of the valid operating license. 
  • If applicable, evidence that demonstrates an operating license is not required by local law.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have the required legal authorization (e.g., license) to operate as a business.

How This Will Be Verified:

Documentation Required: 

  • Copy of current and valid business license, if applicable and any other relevant licenses

Interview Questions to Ask: 

  • Who in the facility is responsible for ensuring the business license is kept up to date?
  • What is the procedure for updating the business license, when required?

Inspection – Things to Physically Look For: 

  • Name on Business License matches the business name of the facility.
  • Validity of the License that indicates it is not expired, if applicable.

Answer Yes if: Your facility received a government-issued environmental violation in the FEM reporting year.

If you answer Yes to this question, you will be asked the following sub question:

  • Please describe the violation and your site’s action plan to improve.

Suggested Uploads:

  • Copy of the government issues violation notice
  • If applicable, the facility’s defined action plan to correct the violation.

What is the intent of the question?

The intent of this question is for facilities to disclose any government-issued environmental violation received in the reporting year and if applicable, provide information on their plans to correct the violation. 

How This Will Be Verified:

Documentation Required:

  • Copy of government-issued violation notice.
  • If applicable, the facility’s action plan to correct the violation.

Interview Questions to Ask: 

  • Staff responsible for environmental management can explain why the violation was received and the facility’s plans to correct the violation and prevent it from occurring in the future.

Inspection – Things to Physically Look For: 

  • Observations of the noted issues listed on the violation, or any actions completed to correct the violation.
  • Online search of available government database(s)/records to identify any violations.

Note: This question is only applicable to facilities located in China.

Answer Yes if: Your facility currently has any records on the IPE database.

If you answer Yes to this question, you will be asked the following sub questions:

    • If yes, what violation is it? (Select all that apply)
      • Wastewater
      • Air
      • Waste
      • Other
        • If other, please describe.
    • If yes, has your facility registered on the IPE database?
  • If yes, has your facility supplied enterprise feedback to the database and/or taken steps to remove the record(s) from the database? 

Suggested Uploads:

  • A copy of the IPE database record.
  • If applicable, documents of the facility’s action and/or enterprise feedback to the database to remove the record.

What is the intent of the question?

The intent of this question is for facilities to disclose any records on the IPE database if applicable, and provide information on actions taken to have the record removed from the database. 

Technical Guidance:

The following reference links are provided to assist users in accessing the IPE website, records, and additional information on using the IPE platform.

If your facility is new to the IPE, it is recommended that you visit these informational pages to learn more:

Viewing records database on IPE website and guidance on record removal:

Note: If your site has a violation record and would like to supply enterprise feedback to IPE and/or take steps to remove the record from the database, please contact ipe@ipe.org.cn

How This Will Be Verified:

Documentation Required:

  • A copy of the IPE database record.
  • If applicable, documents of the facility’s action and/or enterprise feedback to the database to remove the record.

Interview Questions to Ask: 

  • Staff responsible for environmental management can explain why the IPE record(s) were created and the facility’s plans or actions taken to have the record removed.

Inspection – Things to Physically Look For: 

  • Observations of the noted issues listed in the IPE record, or any actions completed to have the record removed.

Answer

For this question, facilities will be asked to complete a table to provide the following information on all applicable environmental permits.

  • Type of Permit (This list will be pre-populated with a list of environmental aspects which may require permits)
  • Is a permit required?
    • If yes, what is your status for this permit?
      • If “Not available” is selected, please describe, or provide additional details.
    • Name of the regulatory agency issuing the permit
    • Is there an expiration date?
    • Please enter expiration date (Month / Year)
    • Please specify the reason why this permit is invalid.
      • Required if “Available but Invalid” or “Not available due to authorization in progress” is selected for permit status. 
    • If “Available and valid” is selected, Do you have any outstanding legal notice documenting a non-compliance issue?
      • If yes, please describe.
    • Please upload a copy of your permit.
  • Provide any additional notes.

Note: 

The following Guidance should be used to answer the question “Is a Permit Required?”: 

  • Yes : Means, the facility has that environmental impact and a permit is required within that country or jurisdiction
  • No : Means, the facility has that environmental impact,but a permit is not required within that country or jurisdiction
  • Not Applicable : Means, the facility does not have that environmental impact as such there is no requirement to obtain a permit
  • Unknown : Means, the facility has that environmental impact but does not know whether a permit is required within that country or jurisdiction

Note: The following scenarios will result a score of ZERO for the entire FEM as these are considered basic compliance practices that must be met to achieve a FEM score:

  • If your facility does not have a required environmental permit. (i.e., if you answer, “Not Available” to the question “What is your status for this permit?” for any required environmental permits).
    • Note: If the permit status is “Not available due to authorization in progress” or “Available but Invalid” the FEM may be scored based on the condition below.
  • If your facility is no longer able to meet the requirement of obtaining a required permit (i.e., if you answer, “Facility is no longer able to meet the requirement of obtaining the required permit” to the question “Please specify the reason why this permit is invalid?”).

Suggested Uploads:

  • Copies of all up-to-date environmental permits/registrations which are applicable to the facility. 
  • If applicable, supporting evidence of applications for renewal for any expired permits.

Note: that licenses/permits for hazardous waste contractors will be requested in the Waste section

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have obtained all applicable legally required environmental permits. 

Technical Guidance:

Maintenance of all legally required environmental permits is a foundational compliance requirement. Please provide information on any rules or regulations your facility is required to follow such as permits, authorizations, licenses, registrations, certificates, or other compliance documentation your facility is required to follow for the following aspects:

  • Water use
  • Wastewater discharge (Direct/Onsite)
  • Wastewater discharge (Indirect/Offsite)
  • Wastewater treatment (Direct/Onsite)
  • Wastewater treatment (Indirect/Offsite)
  • Chemical use and management
  • Air emissions for supply unit (point source)
  • Air emissions for process (Fugitive source)
  • Solid waste discharge
  • Integrated Environmental permits (e.g., general environmental discharge permit)
  • Other environmental permits
    • Examples of other environmental permits may include:
  • Onsite waste generation, management or storage.
  • Required registration/permits for specific chemicals used. For example: Potassium Permanganate is controlled for purchasing and registration with the police office is required in some jurisdictions. This is not a permit, but registration required by law – therefore it must be included here.

How This Will Be Verified:

Documentation Required: 

    • Copies of all up-to-date environmental permits/registrations which are applicable to the facility as at the date/year when the verification takes place, as well as any applicable permits/registrations for the reporting year.
  • If applicable, supporting evidence of applications for renewal for any expired permits.

Interview Questions to Ask: 

  • Staff members responsible for environmental compliance and permitting can describe the facility’s procedures to ensure all required permits have been obtained and are being maintained and/or updated as required.

Inspection – Things to Physically Look For: 

  • Name and address on permits match the facility’s business name.
  • Observations indicate that the facility is operating in compliance with any permit requirements.