General Introduction
Wastewater can be a significant contributor to pollution and contamination of surrounding natural systems and communities if not managed, treated, and/or disposed of appropriately. The operational, environmental, and financial impacts of wastewater are key issues for facility operations. Driving efficient water use and reducing the amount of contaminants discharged to the environment from facility operations is an important area of focus for all factories.
In general, the Higg FEM wastewater section encourages you to:
- Identify and characterize wastewater sources at your facility (e.g., domestic, and industrial wastewater).
- Track the quantity of wastewater generated and discharged from your facility.
- If applicable, ensure that wastewater discharges adhere to all legal requirements for onsite or offsite treatment.
- Ensure that onsite wastewater treatment systems are designed and operated appropriately, and contingency plans are in place in case of treatment system failures.
- Identify, characterize, and track sludge generated onsite and ensure it is disposed of properly.
- Align with progressive industry wastewater standards that focus on eliminating or minimizing the discharge of hazardous chemicals.
- Implement leading practices and technology to improve wastewater treatment and increase reuse/recycling of wastewater.
Additional details on the intent and criteria for each Higg FEM Wastewater question is provided in the guidance below along with useful technical guidance and resources to support your facility with the management wastewater.
ZDHC Partnership and Resources
One of Cascale’s partner organizations, the ZDHC group, has developed a variety of wastewater related standards and resources for wastewater management and discharge that are referenced throughout the Higg FEM Guidance. For more information on the ZDHC, its initiatives, and resources, we encourage you to visit the links throughout this guidance and/or visit their website here: https://www.roadmaptozero.com/?locale=en.
One of the foundational aspects of the ZDHC’s Roadmap to Zero Programme is the ZDHC Wastewater Guidelines which is a living document that sets a single, globally unified expectation across the textile, leather and footwear industry supply chain for industrial wastewater and sludge. They define the guidelines for wastewater discharge, sludge quality and disposal pathways. The ZDHC Wastewater Guidelines and other relevant supporting guidelines and references can be found here: https://www.roadmaptozero.com/output#guidelines.
Guidance for Hardgoods facilities: Whilst the ZDHC Wastewater Guidelines are not directly applicable to hardgoods manufacturers, they are encouraged to align with the guidelines where appropriate and/or adopt equivalent industry best practices.
Wastewater at Your Facility
Wastewater can be generated from a variety of sources. In the Higg FEM, wastewater is categorized as follows:
- Domestic Wastewater: Wastewater originating from domestic/sanitary usage such as toilets, bathing, personal laundry and kitchens.
- Industrial Wastewater: Water that has been used for manufacturing processes and no longer meets the quality standard for beneficial use (e.g., wastewater from production, lubrication, cooling, maintenance, cleaning of production machines, etc.)
- Stormwater: Water that originates from precipitation (e.g., rainwater) that accumulates on and runs off roofs, hard standing surfaces, car parks, etc. (sometimes referred to as surface water run‐off)
The table below provides examples of common wastewater sources that are characterized as either domestic or industrial wastewater in the FEM.
| Domestic Wastewater | Industrial Wastewater |
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|
Note: It is expected that facilities comply with all applicable legal requirements related to the classification and discharge of domestic and industrial wastewater.
Wastewater Treatment
The most appropriate or effective options to treat wastewater will depend on a number of factors, including, the composition and volume of the wastewater, applicable legal requirement, available external infrastructure (e.g., offsite treatment facilities). In the Higg FEM, a facility’s wastewater treatment is categorized as one of the following:
- On-site Wastewater Treatment Only: This is treatment that is performed onsite at a facility in a wastewater treatment plant used managed/operated by the facility. After on-site treatment, the wastewater is discharged to the environment.
- Zero-Liquid Discharge (ZLD): ZLD is a type of onsite treatment that is designed so no water leaves a facility in liquid form. At a facility with on-site ZLD treatment system, almost all wastewater is treated and recovered such that the only water discharged from the facility exists by evaporation or as moisture in the sludge from treatment plant operations. A facility is not considered to have a ZLD treatment system if there is any industrial liquid discharge (Source: ZDHC Knowledgebase – Glossary: https://knowledge-base.roadmaptozero.com/hc/en-gb/sections/360002796277-Glossary).
- On-site Wastewater Treatment + Offsite Treatment: This is treatment that is initially performed onsite at a facility then discharged to an offsite 3rd party treatment plant for additional treatment (also referred to as partial onsite treatment).
- Off-site Wastewater Treatment Only: This is treatment that is performed offsite by a 3rd party wastewater treatment service provider that may be government or privately owned/operated. With offsite treatment, the facility’s untreated wastewater is discharged directly to the off-site treatment facility.
- Septic System: Septic systems are underground wastewater treatment structures that use a combination of natural/primary processes to treat wastewater. The process typically involves solids settling within the septic tank and ends with wastewater being discharged to the soil via a drainfield.
Applicability Questions
To determine which questions you will need to complete in the wastewater section, you will need to complete the applicability questions listed below.
After completing the applicability questions, facilities will be classified based on the factors below and answer applicable questions relevant to their wastewater type and treatment location(s):
- The type of wastewater generated (i.e., domestic, industrial, or both); and
- The type and location of wastewater treatment for domestic, industrial, and/or combined treatment of both). Wastewater treatment location include:
- Treated onsite only.
- Treated onsite with Zero Liquid Discharge (ZLD) system.
- Treated offsite only.
- Treated onsite and then discharged to Offsite treatment centre for further treatment.
- Sent to a Septic system onsite (applies to domestic wastewater only)
- Sent to an enclosed Septic Tank and then discharged to Offsite for further treatment (applies to domestic wastewater only)
- Grey Water Treated Onsite only and direct discharged to environment after treatment , Black Water Sent to a Septic system onsite
- Note: Black water is defined in the FEM as wastewater from toilets which can contain pathogens, feces, urine, and other sanitary waste from flushed toilets.
- Not Treated
1. Does your facility generate industrial wastewater?
- Yes
- No
Note: For the definition of industrial wastewater refer to the Introduction section of the Guidance.
2. Does your facility have Zero Liquid Discharge?
- Yes
- No
Note: For the definition of Zero Liquid Discharge (ZLD) refer to the Introduction section of the Guidance.
3. Do you treat industrial and domestic wastewater together?
- Yes
- No
4. Where is your industrial/domestic/combined wastewater treated?
- Treated Onsite Only and directly discharged to the environment after treatment.
- Treated Offsite Only.
- Treated Onsite and then discharge to Offsite for further treatment.
- Sent to a Septic system onsite (applies to domestic wastewater only)
- Sent to an enclosed Septic Tank and then discharged to Offsite for further treatment (applies to domestic wastewater only)
- Zero Liquid Discharge
- Not Treated
Wastewater – Level 1
Answer Yes If: Your facility tracked the volume of wastewater discharged from all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
Answer Partial Yes If: Your facility tracked the volume of wastewater discharged from one (1) or more, but not all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
If you answer Yes or Partial Yes to this question, you will be asked to complete a table with the following questions to provide details on your facility’s wastewater discharge for each applicable wastewater type.
- Does your facility track its wastewater volume for this wastewater type?
- What was the total quantity of wastewater discharged from your facility during this reporting year? (in cubic meters – m3)
- Which method was used to track wastewater volume?
- Note: If your facility does not track wastewater via metering or metered invoices and calculates your annual wastewater discharge volume using an estimation methodology, then you must select “Estimates” for this question.
- What was the frequency of measurement?
- How many wastewater discharge points do you have?
- Have you labelled all wastewater discharge points?
- Do you monitor all identified wastewater discharge points?
- What was the final discharge point for your facility’s wastewater?
- Note: This should be where the wastewater is discharged to after it leaves the facility.
- Provide any additional comments.
- Please upload documentation.
Suggested Uploads:
- Documentation that demonstrates the facility tracked the volume of wastewater discharged from applicable sources. (e.g., tracking records for wastewater discharge, metering records/logs, wastewater treatment invoices, etc.)
Note: Uploading of all metering records/logs or bills is not required, however they should be available for review at the time of verification.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are tracking the volume of wastewater discharged from the facility.
Technical Guidance:
Wastewater tracking allows visibility into daily operations and which operations impact wastewater volume. Knowing your wastewater volume is also linked to potential environmental impact and operational costs.
Wastewater tracking should include all wastewater generated from all manufacturing and/or commercial activities at the facility (domestic and industrial). Tracking should also include wastewater that is reused/recycled at the facility.
When establishing your water tracking and reporting program, start by doing the following:
- Mapping out facility areas and processes to identify where wastewater is generated and discharged.
- Establish procedures to collect and track wastewater data:
- Install on-site meters or use metered invoices from off-site treatment facilities.
- If estimation techniques are used to determine the amount of wastewater generated, the calculation methodology should be clearly defined and be supported by verifiable data.
- Record tracking data (e.g., daily, weekly, monthly records) in a format that is easy to review (e.g., Microsoft Excel or similar data analytics program that allows export of data in a human readable format) and maintain relevant supporting evidence for review during verification.
Tracking Wastewater Volume
The most accurate way to track wastewater volume is using a metering system. Mechanical meters and ultrasonic meters are widely used to track wastewater volume. Facilities should install meters at all wastewater discharge points before wastewater is discharged to the environment. If the facility has its own effluent treatment plant (ETP), the meter should be installed at the outlet of the wastewater treatment facility. Facilities should collect data from the meters regularly in order to track accurate wastewater discharge volumes. This method applies to both domestic and industrial wastewater.
If a facility does not have meters to track its wastewater discharge volume, an estimation method can be used which may include any of the following estimation techniques listed below.
Note: If your facility does not track wastewater via outlet metering or metered invoices and calculates your annual wastewater discharge volume using an estimation methodology, then you must select “Estimates” for the question “Which method was used to track wastewater volume?”
- If the facility has accurate data (meters or invoices) on incoming water volume for production process and domestic use, the facility may estimate wastewater discharge volume using the incoming water volume. The facility may need to account for water use or loss for things like cooling tower evaporation loss or irrigation when estimating wastewater volume.
- Use of any official environmental reports that contain data on wastewater discharge volume (e.g., Environmental Impact Assessment reports, Environmental permit applications, Government’s compliance report or offsite wastewater treatment invoices).
- Note: In some cases, wastewater treatment invoices from offsite wastewater treatment facilities may not provide the treated wastewater volume. Instead, the invoice would indicate the total treatment fee (e.g., 100 USD) with unit treatment cost ($1 USD/m3). In this case, a facility may need to manually calculate and record wastewater volume with the total treatment fee and unit cost (e.g., total treatment fee ÷ unit treatment cost = wastewater volume).
- If the facility has no documentation which indicates the amount of incoming water, then they can estimate industrial wastewater volume based on different production processes and equipment specific consumption.
- For example, in a dyeing mill, the dyeing recipe may have water needed for each dyeing batch, or the dyeing machine may also have specifications on how much water is required for each batch. Facility would need to collect the production volume of each dyeing recipe and production volume of each dyeing machine. Then the facility would be able to manually calculate using production water use of each recipe per machine and water needed of each recipe/machine, multiply by respective production volume. Lastly, sum up all production water use. This estimated production water volume could be considered as the estimated amount of industrial wastewater discharged. Facilities may also need to account for any loss due to evaporation during production processes.
A tool available to help calculate water use from different sources can be found here: http://waterplanner.gemi.org/calc-waterbalance.asp.
Domestic Wastewater Tracking (including Septic Systems):
Tracking the flow rate and discharge volume of domestic wastewater with on-site meters is not a common practice but it is highly encouraged to accurately track the volume and quantity of domestic wastewater discharged.
If domestic wastewater discharge metering data or actual discharge data is not available, the facility could consider estimating wastewater discharge based on the site’s total water use, the estimated amount used for domestic purposes and then minus an estimated amount due to losses (e.g., evaporation).
- For example, a site with domestic only wastewater who used 150m3 of municipal water per month estimates that 10% of the water is lost due to evaporation and leaks would report 135m3 of wastewater discharged (150m3 – 10%).
Water use in a facility can also be estimated by the number of persons, number and types of facilities, taps, toilets, shower, irrigation etc. based on any available local/regional data or manufacturer’s specifications (e.g., rated litres per flush for toilet fixtures).
Note: If an estimation technique is used, this should be fully documented, applied consistently and based on reasonable estimation factors that are derived from relevant sources (e.g., manufacturer’s specifications, regional data on sewerage volume per person/day, etc.)
Reporting wastewater data in the FEM:
Before reporting wastewater data in the FEM, data quality checks should be performed to ensure that the data AND the processes used to collect and record the data are effective at producing accurate data.
Do:
- Review source data (e.g., meter logs, invoices, etc) against aggregated totals to ensure it is accurate.
- Compare the current year with historical data. Any significant changes (e.g., an increase or decrease of over 10%) should be attributable to known changes. If not, further investigation may be warranted.
- Ensure the most recent and updated versions of data tracking spreadsheets are being used and that all automated calculations/formulas are correct.
- Ensure the proper units are reported and verify any unit conversions from source data to reported data. Note: The FEM requires that wastewater data be entered in cubic meters (m3).
- Report the data source (e.g., meters, invoice, estimates) and frequency of measurement (e.g., daily, monthly, etc).
- Report the final discharge point (e.g., Offsite Wastewater Treatment Plant). Note: This should be where the wastewater is discharged to after it leaves the facility.
- Review any assumption or estimation methodology/calculations to ensure accuracy.
- Add notes in the “Provide any additional comments” field to describe any data assumptions, estimation methodology, or other relevant comments on the reported quantity.
Do Not:
- Report data that is not accurate (e.g., the data source is unknown or has not been verified).
- Report estimated data if it is not supported by verifiable and reasonably accurate estimation methodology and data (e.g., engineering calculations).
How This Will Be Verified:
When verifying a facility’s wastewater data, Verifiers must review all aspects of the facility’s wastewater tracking program that could produce inaccuracies including:
- The initial data collection processes and data sources (e.g., invoices, on-site meters, metering logs, etc.); and
- The process and tools used to aggregate the data (e.g., spreadsheet calculations, unit conversions, etc.)
If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.
Full Points:
Full points will be awarded for facilities that have tracked the volume of wastewater discharged from all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
Documentation Required:
- Documentation that demonstrates the facility tracked the volume of wastewater discharged from applicable sources. This may include:
- Wastewater discharge records (e.g., monthly bills and annual discharge records, metering records/logs, etc.)
- Note: Annual discharge records compiled in a spreadsheet (e.g., Excel) are ok as long as detailed discharge tracking data is available for review.
- Wastewater discharge records (e.g., monthly bills and annual discharge records, metering records/logs, etc.)
- Meter calibration records where applicable (e.g., as per manufacturer’s specifications).
- Estimation methodology documented where applicable.
- All wastewater sources at the facility are tracked in full. This means that all sources listed in the Level 1 table have complete answers in all columns that are accurate.
Interview Questions to Ask:
- Staff responsible for managing wastewater can explain the facility’s wastewater tracking program (e.g., how wastewater sources are identified, and discharge quantities are tracked).
- Key staff should understand:
- The procedures in place for tracking wastewater quantity.
- How data quality of the wastewater tracking program is maintained.
- Any estimation methodologies used to calculate annual wastewater discharge volume.
Inspection – Things to Physically Look For:
- All wastewater sources observed are properly identified and tracked.
- Appropriate equipment for wastewater measurement is present (e.g., meters) if applicable.
Partial Points:
- Partial points will be awarded for facilities that have tracked the volume of wastewater discharged from one (1) or more, but not all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
Answer
Answer Yes if: If your facility tests wastewater for Biochemical Oxygen Demand 5-days concentration (BOD5) and at least one test has been conducted in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- How does your facility monitor the BOD5 Level of your wastewater?
- Before Treatment only.
- After Treatment only.
- Before and After Treatment.
- All processes including sub process level.
- How many biological treatment subprocesses does your treatment plant(s) consist of?
- Note: This question only applies to facilities that monitor BOD5 in all processes and sub processes of wastewater treatment.
Based on where your facility monitors BOD5, you will be asked to complete a table with the following questions to provide details on your wastewater treatment processes/subprocesses and BOD5 monitoring practices:
| If BOD5 is Monitored Before and After Treatment | If BOD5 is Monitored in All Processes and Subprocesses |
| Wastewater Type (responses will be pre-populated based on wastewater sources) | Biological Treatment Sub Process (responses will be pre-populated based on number of sub processes reported) |
| Indicate whether each subprocess is Aerobic, Anaerobic or Facultative. | Wastewater Type |
| What is your BOD5 level prior to treatment? (mg/L) | Indicate whether each subprocess is Aerobic, Anaerobic or Facultative. |
| What is your BOD5 level after treatment? (mg/L) | What is your BOD5 level immediately prior to the biological treatment sub process? (mg/L) |
| How was the BOD5 value obtained? | What is your BOD5 level immediately after the biological treatment sub process? (mg/L) |
| How was the BOD5 value obtained? |
Suggested Uploads:
- Documentation that shows the facility monitors BOD5 in wastewater (e.g., sampling and analysis reports, onsite monitoring records/logs, sampling plan/schedule that shows BOD5 sampling practices).
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that the concentration of BOD5 in wastewater is being monitored. Note: In the FEM, BOD5 is used to calculate the biogenic GHG emissions from Wastewater Treatment.
Technical Guidance
Biochemical oxygen demand (BOD) is a characteristic of wastewater that represents the amount of oxygen required by bacteria and other microorganisms to remove waste organic matter from water under aerobic conditions (where oxygen is present) at a specified temperature. High levels of BOD can impact water quality by depleting the amount of dissolved oxygen to levels that are harmful to aquatic life. BOD is commonly reported as BOD5, which is the amount of oxygen consumed over a 5-day period of incubation during testing.
In most cases limits for the BOD concentration in discharged wastewater are regulated by local laws or other requirements (e.g., brand or industry standards). At minimum, facilities should ensure that processes are in place to monitor BOD and ensure compliance as required, however additional monitoring of BOD throughout a facility’s treatment processes (and sub processes) can provide valuable information on BOD loading into the treatment systems processes and the effectiveness of treatment.
It is also important to ensure that testing is performed in accordance with recognized testing methods that comply with any applicable legal requirements (e.g. ISO 5815-1, USEPA 405.1, SM 5210-B, HJ 505, IS 3025 (Part 44)).
Resources:
- ZDHC Wastewater Guidelines https://www.roadmaptozero.com/output#guidelines
- ZDHC Wastewater and Sludge Sampling and Analysis Plan https://www.roadmaptozero.com/output#Sampling
- ZDHC Wastewater Treatment Technologies https://www.roadmaptozero.com/output#Wastewater-Treatment-Technologies
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that demonstrates the facility has tested/monitored BOD5 in wastewater. This may include:
- Sampling and analysis reports or onsite monitoring records/logs from the FEM reporting year.
- Wastewater sampling procedures (e.g., sampling plan/schedule that shows BOD5 sampling practices).
Interview Questions to Ask:
- Staff responsible for wastewater management/treatment can explain how the facility monitors BOD5 in wastewater.
Inspection – Things to Physically Look For:
- Observations on site are consistent with the facility’s reported practices for monitoring BOD5 in wastewater (e.g., wastewater sampling locations, presence of onsite sampling and analysis equipment if applicable).
Answer
Answer
Answer
Answer
Answer Yes If: Your facility has a mechanism to ensure stormwater is not being contaminated before being discharged to the environment from the facility.
Note: For this question the term “mechanism” refers to procedures, practices and/or protections that are in place to prevent stormwater contamination.
Answer Not Applicable If: Your facility is located in a multi-storey building and stormwater runoff does not accumulate in the areas owned or controlled by your facility.
If you answer Yes to this question, you will be asked the following sub question(s):
- How do you prevent stormwater pollution at your facility?
- Please upload documentation, if available.
If you answer No to this question, you will be asked the following sub question(s):
- Can you please confirm that contaminated stormwater is not directly discharged into the environment?
- How do you manage contaminated stormwater if it occurs at your facility?
- Please upload documentation, if available
Suggested Uploads:
- Documentation that demonstrates the facility has mechanisms in place to prevent the contamination of stormwater (e.g., facility diagram showing stormwater flow/drainage network and storage, photos of any protection devices such as drain covers, berms, stormwater management or monitoring procedures, etc.)
What is the intent of the question?
The intent of this question is to ensure that mechanisms are in place to prevent the contamination of stormwater through appropriate stormwater collection and drainage and ensure that any contaminated stormwater is properly treated before being discharged to the environment.
Technical Guidance:
It is considered a good practice to separate stormwater collection and drainage systems from wastewater or other sources of potential contamination. This provides greater control over waste volume surges and pollutant loading on wastewater treatment systems as well as prevention of overflows that release sewage and/or untreated industrial wastewaters to the environment. Facilities should ensure that stormwater and industrial/domestic wastewater collection and drainage systems are separated throughout the facility, however facilities are expected to adhere to any applicable legal requirements related to stormwater management.
Good practices to prevent contamination of stormwater may include:
- Coding and labelling of all the stormwater and wastewater collection points, drains, and drainage systems to prevent unintended contamination.
- Develop a stormwater and wastewater drainage network map with the information of location, uses, code and responsible person.
- Post the drainage map in a location where it is accessible for most of the employees. Note: The facility’s wastewater collection and stormwater drainage system may be included on facility structural engineering/utility drawings.
- Ensuring there is sufficient collection and storage capacity for surges in stormwater (e.g., precipitation) to avoid overflow.
- Install and maintain protections (e.g., drain covers, berms) in areas where there is a risk of contamination.
- Ensure staff are aware of the facility’s stormwater protection and management practices.
- Ensure procedures are in place for the proper storage of hazardous materials and effective spills response procedures are in place to prevent contamination of stormwater drains.
- Regularly check (e.g., daily, monthly, etc) all stormwater and wastewater collection points and drainage systems to ensure there is no mixing or damage to the systems.
Note: If there are no mechanisms in place to prevent stormwater from being contaminated, procedures should be in place to ensure that if contamination occurs that the stormwater is collected and appropriately treated (to levels that comply with legal or other applicable requirements) before being discharged to the environment.
Resources:
Note: The resources below are provided for reference only and include links to external service provider websites. Cascale does not endorse the products or services offered or provided.
- Examples of stormwater protection equipment
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have mechanism(s) in place to prevent the contamination of stormwater.
Documentation Required:
- Documentation that demonstrates the facility has mechanisms in place to prevent the contamination of stormwater. This may include:
- Stormwater management procedures.
- Facility diagram showing stormwater flow/drainage network and storage.
- Stormwater drainage system inspection and maintenance records.
- If applicable, documentation that shows contaminated stormwater is treated before being discharged to the environment.
- If applicable, any required permit or discharge requirements related to stormwater or combined stormwater/wastewater discharge.
Interview Questions to Ask:
- Staff responsible for stormwater management can explain the facility’s procedures to prevent the contamination of stormwater and maintain the stormwater collection and drainage system at the facility.
- Staff responsible for inspection and maintenance of the stormwater collection and drainage system understand the facility’s procedures to prevent contamination and maintain the stormwater system.
Inspection – Things to Physically Look For:
- Observations indicate that appropriate infrastructure (e.g., collection, storage, and drainage systems) and protections are in place to prevent the contamination of stormwater.
- Observations do not indicate the presence of stormwater contamination (e.g., untreated wastewater flowing to stormwater drainage).
Partial Points:
- Partial points will be awarded to facilities that do not have mechanisms in place to prevent the contamination of stormwater but can demonstrate that an effective process is in place to manage and treat contaminated stormwater if needed.
Answer
Answer
Answer
Answer
Answer Yes If: Your facility has a current/valid copy of the current contract, permit, agreement, or invoices that demonstrate compliance with applicable requirements for wastewater discharge to the offsite wastewater treatment plant.
If you answer Yes to this question, you will be asked the following sub question(s):
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
- Please provide the name and contact information of the offsite wastewater treatment plant
- Name
- Address
- Ownership
Suggested Uploads:
- A copy of the permit, contract, agreements, invoices, or other supporting documentation (e.g., payment terms, wastewater quality standards, volume / flow rate thresholds, etc.) that demonstrates compliance with applicable requirements for discharge to an offsite wastewater treatment facility.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they maintain the required documentation to demonstrate compliance with applicable requirements for discharge to the offsite wastewater treatment plant.
Technical Guidance
It is important that facilities understand the requirements related to discharging wastewater to an offsite treatment plant. Requirements may be outlined in contractual agreements, permits relating to the quantity and quality of wastewater that can be discharged, or established fee structures for accepting wastewater discharges.
These requirements allow facilities to establish the required procedures, monitoring, and reporting practices to ensure wastewater discharged complies with applicable requirements and does not negatively impact the operations of the offsite treatment facility.
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates the facility is in compliance with applicable requirements for discharge to the offsite wastewater treatment facility. This may include:
- A current/valid copy of the permit, contract, agreements, invoices, or other supporting documentation (e.g., payment terms, wastewater quality standards, volume / flow rate thresholds, etc.).
Interview Questions to Ask:
- Staff responsible for wastewater management can explain any contractual or permit requirements related to wastewater discharge to the offsite plant and how the facility ensures compliance.
Inspection – Things to Physically Look For:
- Observations onsite indicate that the facility’s wastewater management and discharge practices align with the applicable requirements for discharge to the offsite treatment plant.
Partial Points: N/A
Answer
Answer
Answer
Answer Yes If: If your facility has established procedures to ensure your water treatment plant is operating as per the design parameters and the documented procedures or processes must cover all of the following aspects:
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
Answer Partial Yes If: If your facility has established procedures to ensure your water treatment plant is operating as per the design parameters and your documented procedures or processes, at minimum, cover the following aspects:
- Standard Operating Procedures
- Continuous monitoring
- Ongoing Maintenance
If you answer Yes or Partial Yes to this question, you will be asked the following sub question(s):
- If yes, which of the following activities do you have and are being conducted?
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
- What is the design capacity of your onsite wastewater treatment plant (m3/h)?
- What is the average volume of wastewater treated by your wastewater treatment plant per day (m3/day)?
- Do you monitor all process control parameters of your wastewater treatment plant as per the design parameters and operating procedures of the system?
- Select Yes If: Your facility monitors all of the control parameters as specified by the design parameters and operating procedures of your treatment system.
- Select Partial Yes If: Your facility monitors some, but not all of the control parameters as specified by the design parameters and operating procedures of your treatment system.
- If yes or partial yes, how frequently do you monitor them?
- Please upload documentation.
Suggested Uploads:
- Documentation that demonstrates the facility’s wastewater treatment plant is being operated as per the design parameters (e.g., treatment plant design specifications, drawings, or manufacturers operating specifications, wastewater treatment plant operating procedures, records of process monitoring, testing).
What is the intent of the question?
The intent of this question is for facilities to demonstrate that the wastewater treatment plant is being operated and maintained as per the design specification/parameters.
Technical Guidance:
Wastewater treatment systems are highly engineered systems that are specifically designed based on the wastewater characteristics they are intended to treat (e.g., the types and concentrations of pollutants, volume of wastewater, level of treatment required, etc). It is crucial that the wastewater treatment system is operated within its design specifications and operating parameters to ensure the effective treatment of wastewater.
Facilities should have established procedures to ensure that the system is operated, monitored, and maintained in accordance with the design specifications and manufacturer’s specifications for all system equipment and components (e.g., pumps and valves, flowmeters, motoring/sampling equipment, etc.)
It is also important that staff who operate and maintain the treatment system are appropriately trained to understand the operating/monitoring requirements, limitations, and troubleshooting of the system to ensure its continuous and effective operation.
Resources:
- ZDHC Wastewater Treatment System Operator Minimum Qualifications Guidelines https://www.roadmaptozero.com/output#Qualification
- ZDHC Wastewater Treatment Technologies https://www.roadmaptozero.com/output#Wastewater-Treatment-Technologies
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have established procedures to ensure the water treatment plant is operating as per the design parameters and the documented procedures or processes cover all of the following aspects:
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
Documentation Required:
- Documentation that demonstrates the facility’s wastewater treatment plant is being operated and maintained per the design parameters. This may include:
- Treatment plant design specifications, drawings, or manufacturers operating specifications
- The facility’s wastewater treatment plant operating procedures
- Process monitoring/testing records to ensure plant is operating within the designed operating parameters (e.g., flow rates, temperature, pH, suspended solids and/or heavy metals concentrations, etc)
- Training records for operators.
- Maintenance records that show equipment and components are maintained and calibrated per the design and manufacturer’s specifications.
Interview Questions to Ask:
- Staff responsible for wastewater management can explain the facility’s procedures for ensuring the wastewater treatment system is operated and maintained as per the design specifications and operating parameters.
- Operators and staff responsible treatment system maintenance understand the facility’s procedures as well as the design/operating parameters and troubleshooting/maintenance procedures.
Inspection – Things to Physically Look For:
- Observations indicate that the treatment system is being operated and maintained in accordance with the facility’s procedures and the systems design parameters (e.g., equipment is observed to be in good working order, proper process monitoring/testing activities are being conducted, etc.)
Partial Points:
- Partial points will be awarded for facilities that have established procedures to ensure the water treatment plant is operating as per the design parameters and the documented procedures or processes, at minimum, cover the following aspects:
- Standard Operating Procedures
- Continuous monitoring
- Ongoing Maintenance
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Answer Yes If: Your Facility has a back-up plan, process, and/or onsite and/or offsite facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility.
If you answer Yes to this question, you will be asked the following sub question(s):
- Does your facility have a process to contact appropriate government authorities or agencies as legally required in case of accidental discharge?
- Please upload documentation, if available
- If you cannot upload the documents, please describe here.
Note: If your facility is not legally required to notify relevant government authorities or agencies of any accidental discharge, you should select “Not Legally Required” for this question.
- Select all strategies included in your facility’s back-up plan for wastewater:
- Emergency Production Shutdown
- Note: This action must be backed up by additional emergency response actions or processes rather than stating simply that the facility will stop production.
- Holding Tank
- What is the size of your facility’s holding tank (in m3)?
- Availability of additional pumps, blowers, dosing pumps and critical equipment for the specific treatment plant, that are not used for day to day running of the plant.
- Discharge to Offsite Water Treatment Plant
- Note: Discharge of untreated wastewater that cannot be treated onsite due to an emergency must be directed authorized offsite wastewater treatment service provider (public or private) with prior consent.
- Other Backup Process
- If other, please describe.
- Emergency Production Shutdown
- Please upload your backup plan
- What is your facility’s wastewater treatment plant maximum holding capacity (in m3) if the treatment plant is shut down in an emergency?
- Does your facility provide training to all relevant employees regarding the backup plan?
- If yes, how many employees were trained?
- If yes, how frequently do you train your employees?
- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
- Please upload documentation.
Suggested Uploads:
- Documentation that shows emergency backup processes are in place that are sufficient to treat the average daily volume of wastewater discharged by the facility site (e.g., wastewater treatment flow diagram, documented back-up plan, back -up equipment inventory, agreement with offsite treatment plant to receive wastewater in an emergency, etc.).
What is the intent of the question?
The intent of this question is to confirm that facilities have a contingency plan in the event the treatment process fails to prevent untreated effluent from being discharged.
Technical Guidance:
It is crucial that facilities evaluate the risk of wastewater treatment system failures (e.g., failures in treatment processes or equipment, natural disasters, power outages). Facilities should establish a documented contingency plan to respond to potential emergencies. It is important to know the wastewater treatment systems handling capacity (per day) and compare this information with the quantity of wastewater generated to determine what actions or onsite facilities are required to effectively manage any treatment system failures.
It is also important that facilities ensure the relevant staff members and teams are trained and understand the facility’s back-up plan to ensure that emergency response actions are effective.
Some examples of actions that can be taken in the event of an emergency include, but are not limited to:
- Emergency shutdown of production or treatment system until the situation is rectified.
- Note: This action must be backed up by additional emergency response actions or processes rather than stating simply that the facility will stop production.
- Back-up holding tank capacity which temporarily stores the quantity of wastewater equal to one day’s production.
- Note: Holding tanks should not be considered as an exclusive backup measure.
- Maintaining a sufficient amount of back up equipment to ensure broken/damaged equipment can be timely replaced.
- Establish agreement and procedures for alternative offsite treatment with a licensed third-party wastewater treatment plant or service provider.
Resources:
Note: The resources provided below are for reference only and may contain reference to legal requirements that do not apply to your facility. It is expected that facilities comply with all applicable legal requirements related to wastewater emergency planning and procedures.
- New Hampshire Department of Environmental Services – Emergency Response Planning Guide Developed for Insertion into Wastewater Treatment Facility O&M Manuals https://www.des.nh.gov/sites/g/files/ehbemt341/files/documents/2020-01/ww-emergency-response-guide.pdf
- ICS Effluent Treatment Plant (ETP) – Emergency response plan Fact Sheet https://ics-asso.org/wp-content/uploads/2018/04/Chap-4_Wastewater_Effluent-treatment-plant-emergency-response-plan_factsheet.pdf
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have a back-up plan, process, and/or onsite and/or offsite facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility and have a process to notify relevant government authorities or agencies of any accidental discharge, if it is legally required.
Documentation Required:
- Documentation that shows emergency backup processes are in place that are sufficient to treat the average daily volume of wastewater discharged by the facility site. This may include:
- Wastewater treatment flow diagram showing additional emergency holding or treatment capacity if applicable.
- Documented back-up plan and/or procedures (e.g., emergency shutdown procedures).
- Back -up equipment inventory
- Agreement with an offsite treatment plant to receive wastewater in an emergency.
- List of emergency contacts/responsible parties (internal and external).
Interview Questions to Ask:
- Staff responsible for wastewater management can explain the facilities back-up plan and/or procedures to respond to any type of wastewater emergency.
- Responsible staff (treatment plant operators, maintenance staff) understand the facility’s emergency response procedures.
Inspection – Things to Physically Look For:
- Observations indicate the appropriate equipment and facilities are in place as per the facility’s back up plan.
Partial Points:
Partial points will be awarded for facilities that have a back-up plan, process, and/or onsite and/or facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility, but do not have a process to notify relevant government authorities or agencies of any accidental discharge, if it is legally required.
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Answer Yes If: Your facility has processes in place to ensure that untreated wastewater is not discharged to the environment from leaks or bypassing of the wastewater treatment system.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, please describe how you monitor.
- Please upload documentation.
Suggested Uploads:
- Documentation that shows no wastewater is discharged through leaks or bypassing the facility’s treatment system (e.g., wastewater flow/piping diagram, records of effluent volume monitoring against the volume of wastewater generated, leak inspection records)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that untreated wastewater is not being discharged to the environment from leaks or bypassing of the wastewater treatment system.
Technical Guidance
Ensuring that the facility’s wastewater collection and treatment system network (e.g., collection and transfer piping, and storage) is properly designed and capable of appropriately directing wastewater to treatment is crucial to ensure that no untreated wastewater is able to bypass treatment. It is also important to ensure that this network is inspected and maintained to prevent unintended discharge from leaks or overflow.
Factories should have an established process to monitor the volume of wastewater generated from production or other operations in relation to the volume of water that is treated and discharged. Any significant or unknown difference should be investigated to determine the cause.
Examples of actions that can be taken to prevent this include, but are not limited to:
- Review the facility’s wastewater collection and treatment system network (e.g., construction or utility drawings) to ensure all wastewater is being properly collected and directed to treatment.
- Identify and characterize all wastewater streams to ensure they are directed to treatment before being discharged to the environment.
- Install and maintain appropriately sized wastewater treatment systems that account for the expected volume of wastewater generated on site.
- Conduct regular inspections of wastewater piping systems and tanks to monitor for leaks.
- Prepare for emergencies and implement emergency response actions in case the on-site wastewater treatment plant exceeds its capacity or if it malfunctions.
How This Will Be Verified:
Full points:
Documentation Required:
- Documentation that demonstrates the facility has processes in place to ensure that untreated wastewater is not discharged to the environment from leaks or bypassing of the wastewater treatment system. This may include:
- Wastewater flow/piping diagram.
- Wastewater volume monitoring records that show the difference between volume of wastewater generated and discharged is acceptable.
- Records of inspections for of wastewater piping systems and tanks that the facility uses to monitor for leaks (e.g., inspection schedule, and completed checklists)
Interview Questions to Ask:
- Staff responsible for wastewater management can describe how the facility ensures that all wastewater is directed to appropriate treatment and the system is monitored for leaks.
- Staff responsible for inspecting and monitoring the system for leaks understand the facility’s inspection procedures and how to effectively identify leaks.
Inspection – Things to Physically Look For:
- Observations indicate that all wastewater is appropriately directed to treatment (e.g., no observed bypassing of wastewater collection or treatment) and the wastewater piping network and tanks are maintained in good condition (e.g., there are no observed leaks).
Partial Points: N/A
If you indicate that your facility has one (1) or more sources of sludge, you will be asked the following sub question(s):
- Please describe the source of each type of wastewater sludge generated at your facility.
- Do you know the % solids of your wastewater sludge you generated?
- What are the % solids of this wastewater sludge you have generated?
Notes:
- The % solids of sludge should be reported as the average % solids value for that sludge type if multiple samples were analysed.
- The formula for determining the % solids is:
- weight of dry sludge / weight of wet sludge x 100
- If you have not conducted % solids analysis in accordance with a recognized test method (e.g., EPA 160.3 or SM 2540G), you should answer No to the Question. Do you know the % solids of your wastewater sludge you generated?
Suggested Uploads:
- Documentation that shows your facility has identified all sources of sludge and conducted an analysis to determine the % solids of the sludge (e.g., a list/inventory of the types of sludge, internal or external sludge analysis results/reports).
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to identify the different sources of sludge generated at the facility and understand the % solids content of each sludge type.
Technical Guidance:
It is important for facilities to know the different sources (e.g., types) of sludge and the general composition of sludge to ensure the most effective treatment and disposal options are used. The compositions of can vary depending on the composition of wastewater and the processes used for its treatment. In general, sludge contains water, organic and inorganic materials, and solids.
A key basic sludge quality parameter that is important to understand is the % of dry solids content. The % solids indicate the moisture content or sludge after its generated at the facility and can impact the cost and type of disposal that is available. In general, reducing sludge moisture content (e.g., drying, dewatering) as much as possible can help reduce sludge volume and the associated transportation/disposal costs.
Resources:
- ZDHC Sludge Reference Document. Note: This guidance is not applicable for domestic only sludge. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
- ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that shows your facility has identified all sources of sludge and conducted an analysis to determine the % solids of the sludge. This may include:
- A list/inventory of the types of sludge.
- Internal or external sludge analysis results/reports.
- Supporting data and calculations to that shows the average % solids content for sludge (where multiple analyses have been performed).
Interview Questions to Ask:
- Staff responsible for wastewater and sludge management can explain how the facility identified its sludge sources and the methodology used for determining the % solids content of sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sources of sludge reported are consistent with sludge generation at the facility.
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Answer Yes if: Your facility tracked the annual quantity of industrial wastewater sludge generated at the facility in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, how much industrial wastewater sludge (in Metric Tons) did you generate in the reporting year?
- Note: If domestic sludge is combined with industrial sludge, it should be reported here.
Suggested Uploads
- Sludge quantity/disposal tracking records that show the quantity of sludge generated of in the reporting year (e.g., waste manifests, internal tracking records)
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate the annual quantity of industrial wastewater sludge was tracked in the reporting year.
Technical Guidance:
Tracking the quantity of sludge provides important information that can be used to identify opportunities to reduce sludge and quantify these reductions.
Procedures to track the annual quantity of sludge generated generally align with the practices used to track the quantity any waste stream and include the following:
- Determine what types of waste are generated.
- Determine where (location and processes) where sludge is being generated.
- Establish procedures to collect and track waste data:
- Examples include on-site scales, waste invoices/manifests.
- If estimation techniques are used to calculate the quantity of sludge, the methodology should be clearly defined and be supported by verifiable data.
- Record the data (e.g., daily, weekly, monthly sludge quantities) in a format that is easy to use and review such as Microsoft Excel or another data analytics program.
Estimating Sludge Quantity Data
In some cases, calculating annual sludge quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that include details on the calculation methodology and any data or assumptions used.
Note: If an estimation technique is used, the methodology should be applied consistently and based on reasonable estimation factors that are derived from relevant data (e.g., actual weights of a representative sample of the sludge).
An example of how waste quantity data can be estimated is provided below:
- A facility generates a specific quantity of sludge every time the filter press is unloaded. Weighing the sludge every time is not practical. Therefore, the average weight of each filter press load can be determined by weighing a representative sample of sludge from multiple loads and then multiplying this average weight by the number of filter press loads each week or month as shown below:
- Average weight of a load = 50kg (based on representative weights of loads from different days, months, production scenarios, etc.)
- Number of loads in 1 month = 45
- Total estimated sludge quantity for the month = 2,250kg (50kg x 45 loads)
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that supports the reported sludge quantity. This may include:
- Tracking records for annual sludge quantities (e.g., invoices from waste contractors, weighing records, etc.).
- Scale calibration records if applicable (e.g., as per manufacturer’s specifications)
- Documented estimation methodologies if applicable.
Interview Questions to Ask:
- Staff responsible for managing sludge and/or wastes can explain how sludge quantity is tracked.
- Key staff should understand:
- How data quality of the sludge tracking program is maintained.
- Any estimation methodologies used to calculate annual sludge quantity.
Inspection – Things to Physically Look For:
- Observations are consistent with the facility reported procedures to track and measure sludge quantity (e.g., appropriate equipment is available for sludge quantity measurement if applicable).
Answer
Answer Yes if: Your facility tracked the annual quantity of domestic wastewater sludge generated at the facility in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, how much domestic wastewater sludge (in Metric Tons) did you generate in the reporting year?
Suggested Uploads
- Sludge quantity/disposal tracking records that show the quantity of sludge generated of in the reporting year (e.g., waste manifests, internal tracking records)
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate the annual quantity of domestic wastewater sludge was tracked in the reporting year.
Technical Guidance:
Tracking the quantity of sludge provides important information that can be used to identify opportunities to reduce sludge and quantify these reductions.
Procedures to track the annual quantity of sludge generated generally align with the practices used to track the quantity any waste stream and include the following:
- Determine what types of waste are generated.
- Determine where (location and processes) where sludge is being generated.
- Establish procedures to collect and track waste data:
- Examples include on-site scales, waste invoices/manifests.
- If estimation techniques are used to calculate the quantity of sludge, the methodology should be clearly defined and be supported by verifiable data.
- Record the data (e.g., daily, weekly, monthly sludge quantities) in a format that is easy to use and review such as Microsoft Excel or another data analytics program.
Estimating Sludge Quantity Data
In some cases, calculating annual sludge quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that include details on the calculation methodology and any data or assumptions used.
Note: If an estimation technique is used, the methodology should be applied consistently and based on reasonable estimation factors that are derived from relevant data (e.g., actual weights of a representative sample of the sludge).
An example of how waste quantity data can be estimated is provided below:
- A facility generates a specific quantity of sludge every time the filter press is unloaded. Weighing the sludge every time is not practical. Therefore, the average weight of each filter press load can be determined by weighing a representative sample of sludge from multiple loads and then multiplying this average weight by the number of filter press loads each week or month as shown below:
- Average weight of a load = 50kg (based on representative weights of loads from different days, months, production scenarios, etc.)
- Number of loads in 1 month = 45
- Total estimated sludge quantity for the month = 2,250kg (50kg x 45 loads)
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that supports the reported sludge quantity. This may include:
- Tracking records for annual sludge quantities (e.g., invoices from waste contractors, weighing records, etc.).
- Scale calibration records if applicable (e.g., as per manufacturer’s specifications)
- Documented estimation methodologies if applicable.
Interview Questions to Ask:
- Staff responsible for managing sludge and/or wastes can explain how sludge quantity is tracked.
- Key staff should understand:
- How data quality of the sludge tracking program is maintained.
- Any estimation methodologies used to calculate annual sludge quantity.
Inspection – Things to Physically Look For:
- Observations are consistent with the facility reported procedures to track and measure sludge quantity (e.g., appropriate equipment is available for sludge quantity measurement if applicable).
Answer
Answer Yes if: Your facility has designated wastewater sludge storage areas.
If you answer Yes to this question, you will be asked a set of sub questions to indicate which of the following practices your facility has in place for sludge storage areas:
- Does your facility have the following practices in place in the wastewater sludge storage area?
- The surface of the wastewater sludge storage area prevents permeability into the ground and is inert in nature.
- The wastewater sludge storage area is protected from exposure to precipitation and stormwater runoff.
- The industrial and domestic wastewater sludge are kept and stored separately.
- If only Domestic wastewater sludge is generated, Not Applicable should be selected for this question.
- The industrial wastewater sludge storage area is protected from unauthorized employees.
Suggested Upload:
- Photos of sludge storage areas.
What is the intent of the question?
The intent of this question is to ensure that sludge is stored in a way that is safe for employees, the environment, and the local community.
Technical Guidance:
The proper storage of sludge is important to prevent unintended contamination of other wastes, the surrounding environment and to reduce exposure risks to employees. Facilities should have dedicated storage areas for sludge and implement appropriate controls practices based on the hazardous characteristics of the sludge such as those listed in the sub questions.
Information on the hazardous characteristics of sludge should be evaluated using analysis data from sludge samples or in the Safety Data Sheets (SDS) of the hazardous raw materials used in the processes that generate the sludge. For example, if heavy metals are used in any process chemistry, these contaminants will likely be present in sludge generated.
Sludge storage areas should also be inspected regularly to ensure good storage and housekeeping practices are continuously implemented.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Full Points:
Facilities will receive full points for having dedicated sludge storage areas, and have implemented all the applicable control measures listed in the sub question.
Documentation Required:
- Documentation to support the facilities procedures to ensure that sludge is stored appropriately. This may include:
- Procedures or work instructions for sludge/waste storage areas
- Hazardous waste area inspection records
Interview Questions to Ask:
- Staff responsible for sludge/waste management handling and storage understand risks associated with sludge stored and how to properly store sludge (e.g., which containers to use, required segregation, etc.)
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being stored in designated areas with appropriate controls.
Partial Points:
- Partial Points will be awarded to facilities that have dedicated sludge storage areas and have implemented some, but not all, the applicable control measures listed in the sub questions.
Answer
Answer Yes if: Your facility is disposing of industrial wastewater sludge in accordance with all legal requirements based on the hazardous characteristic of the sludge.
Note: This question refers to the final treatment/disposal method of the sludge. This can be onsite or offsite depending on the final treatment/disposal location.
If you answer Yes to this question, you will be asked the following sub question(s):
- Which disposal pathway(s) does your facility dispose of your industrial wastewater sludge?
- Hazardous Waste Treatment
- Open burning
- Note: The use of open burning of sludge is strongly discouraged unless specific regulatory approval is obtained and complied with.
- Onsite Incineration at ≥1000 °C
- Onsite Incineration at <1000 °C
- Offsite Incineration at ≥1000 °C
- Landfill with Significant Control Measures
- Building Products Processed at ≥1000 °C
- Landfill with Limited Control Measures
- Offsite Incineration and Building Products Processed at <1000 °C
- Landfills with No Control Measures
- Land Application
- E.g., Compost, fertilizer.
- Non-disclose method by authorized third party (final disposal method not disclosed)
- Please upload documentation.
Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Suggested Uploads:
- Documentation that demonstrates industrial wastewater sludge is being disposed of properly (sludge analysis/test showing hazardous properties, sludge disposal manifests, permit/license of waste vendor accepting and treating the sludge, evidence of the final treatment/disposal method being used, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that industrial wastewater sludge is being disposed of responsibly to minimize environmental impacts.
Technical Guidance:
The hazardous properties and proper disposal method of sludge depend on the specific hazardous properties of the sludge (e.g., the type and concentration of hazardous chemicals). Facilities should ensure that sludge is properly characterized (e.g., via laboratory testing) to identify its hazardous properties and any specific disposal requirements or limitations.
At minimum, sludge should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics as required.
As part of a facilities waste management program, it is important for facilities to understand how wastes (including sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for sludge.
If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
- ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates industrial wastewater sludge is being disposed of in accordance with all legal requirements based on the hazardous characteristic of the sludge. This may include:
- Sludge analysis/test showing hazardous properties.
- Sludge disposal manifests
- Where applicable, permit/license of waste vendor accepting and treating the sludge.
- Evidence of the final treatment/disposal method being used by the waste vendor.
- Legal approvals/permits for any onsite treatment/disposal of sludge if applicable.
Interview Questions to Ask:
- Staff responsible for wastewater/waste management understand the hazardous composition of the facility’s sludge and the final disposal method used to treat/dispose of the sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being collected and treated per the methods reported by the facility (e.g., onsite treatment/disposal conditions, sludge storage conditions, etc.)
Partial Points: N/A
Answer
Answer Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and all of the following conditions are met:
- Documentation has been obtained that accounts for all sludge disposals.
- The documentation contains all of the information noted below:
- Shipper (the facility generating the sludge).
- Mass or volume of the shipment.
- Transporter’s company name.
- Shipment/Receiving dates
- Name of the disposal or processing facility that the sludge was shipped to.
Answer Partial Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge, and documentation has been obtained for all sludge disposals; however
- The documentation does not contain one or more of the pieces of information noted below:
- Shipper (the facility generating the sludge).
- Mass or volume of the shipment.
- Transporter’s company name.
- Shipment/Receiving dates
- Name of the disposal or processing facility that the sludge was shipped to.
If you answer Yes or Partial Yes to this question, you will be asked the following sub question(s):
- Does your facility use authorized third party for legal disposal of Industrial wastewater sludge?
- Does your facility retain documentation of all wastewater sludge transportation and disposal/treatment companies?
- Note: This refers to the legally required amount of time that documentation must be retained, which may vary by jurisdiction. If there are no legal requirements documentation must be retained for at least two (2) years.
- Are all Industrial wastewater sludge transporters, treatment, and disposal facilities licensed and permitted?
- Please upload documentation.
Suggested Uploads:
- Samples of waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge.
- Copies of sludge handling/treatment/disposal vendor licenses and/or permits that show they are authorized to receive, process and dispose of the sludge.
Note: Uploading of all manifest or other documentation is not required, however they should be available for review at the time of verification.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that processes are in place to obtain and retain information related to the handling, transportation, processing, and disposal of industrial wastewater sludge and to ensure that any third-party waste vendors have the required legal approvals to receive, process and dispose of the facility’s sludge.
Technical Guidance:
To ensure proper accountability, facilities should have established processes in place to maintain documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge. Often the minimum requirements for generating and maintaining documentation related to waste disposal is governed by legal requirements (particularly for hazardous wastes) and all applicable requirements should be met by facilities.
In addition to any legal requirements, facilities should ensure that a waste manifest or a similar local transport document that contains the following information is obtained and maintained for each sludge shipment as a good practice. If needed this additional information can be requested from waste vendors:
- Shipper (the facility generating the sludge).
- Mass or volume of net shipment.
- Transporter’s company name.
- Shipment/Receiving dates
- Name of the disposal or processing facility that the sludge was shipped to.
Facilities should also ensure that any third-party waste vendors used have the required legal approvals to receive, process and dispose of the facility’s sludge. Facilities should ensure that part of the waste vendor approvals process include the verification of all legally required approvals (e.g., licenses and permits). It is considered a good practice (if not legally required) for facilities to request and maintain up-to-date and valid copies of vendor approvals onsite.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and all of the following conditions are met:
- Documentation has been obtained that accounts for all sludge disposals and contains all of the required information.
- Documentation is retained onsite for at least the legally minimum required length of time. If there are no legal requirements documentation must be retained for at least two (2) years.
- Any third-party waste vendors used have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.
Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.
Documentation Required:
- Documentation that shows the facility has obtained and maintains waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and that sludge is being received by authorized vendors. This may include:
- Waste manifests or other transport documentation.
- Waste vendor licenses and/or permits that show they are authorized to receive, process and dispose of the facility’s sludge.
Interview Questions to Ask:
- Staff responsible for managing wastes can explain the facilities procedures to obtain and maintain manifests and/or other transport information related to sludge disposal and how the facility ensures that waste vendors have the required approvals to collect, receive, or process the facility’s sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being collected and treated per the process reported by the facility (e.g., sludge disposal records, sludge storage conditions, presence of waste contractors onsite during verification, etc.)
Partial Points:
Partial points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge, and documentation has been obtained for all sludge disposals, however:
- Documentation does not include the required information; and/or
- Documentation is not retained onsite for at least the legally minimum required length of time or if there are no legal requirements, documentation has not been retained for two (2) years; and/or
- Any third-party waste vendors used do not have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.
Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.
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Answer Yes if: Your facility provides training to all employees who handle wastewater sludge and the training covers safe handling, storage, and disposal of sludge.
If you answer Yes to this question, you will be asked the following sub question(s):
- How many employees were trained?
- How frequently do you train your employees?
- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
- Please upload documentation.
Suggested Upload:
- Records of sludge handling training or general waste handling training if sludge is included in this.
- Copies of training material used.
- Employee training plans or procedures that demonstrate training is provided to all employees who handle sludge.
What is the intent of the question?
The intent of this question is to ensure facilities have procedures in place to train all employees who handle wastewater sludge on practices to minimize environmental and health risks associated with sludge.
Technical Guidance:
Wastewater sludge can pose significant risks to the environment and human health. Employees who handle sludge on-site should understand these risks and know how to safely, handle, store, and dispose of sludge to minimize environmental and health and safety impacts.
Additionally, having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of trainings and knowledge retention.
Resources:
- ZDHC Wastewater Treatment System Operator Qualification Training Course – I : Basic Physical/Chemical Treatment https://academy.roadmaptozero.com/courses/group/3#category-18
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates that all employees who handle sludge are trained on safe handling, storage, and disposal of sludge. This may include:
- Records of sludge or general waste training if sludge handling is included in this.
- Training material used.
- Employee training plans or procedures that demonstrate sludge handling training is provided to all employees who handle sludge.
Interview Questions to Ask:
- Staff responsible for sludge/waste management can explain the facility’s sludge handling procedures and how all relevant employees are trained.
- Relevant employees understand the facility’s sludge handling procedures and have received training.
Inspection – Things to Physically Look For:
- On-site observations indicate that sludge is being handled in accordance with the facility’s waste handling procedures.
Partial Points: N/A
Answer
Answer
Answer
Answer
Answer Yes if: Your facility is disposing of domestic wastewater sludge in accordance with all legal requirements based on the hazardous characteristic of the sludge.
Note: This question refers to the final treatment/disposal method of the sludge. This can be onsite or offsite depending on the final treatment/disposal location.
If you answer Yes to this question, you will be asked the following sub question(s):
- Which disposal pathway(s) does your facility dispose of your domestic wastewater sludge?
- Hazardous Waste Treatment
- Open burning
- Note: The use of open burning of sludge is strongly discouraged unless specific regulatory approval is obtained and complied with.
- Onsite Incineration at ≥1000 °C
- Onsite Incineration at <1000 °C
- Offsite Incineration at ≥1000 °C
- Landfill with Significant Control Measures
- Building Products Processed at ≥1000 °C
- Landfill with Limited Control Measures
- Offsite Incineration and Building Products Processed at <1000 °C
- Landfills with No Control Measures
- Land Application
- E.g., Compost, fertilizer.
- Non-disclose method by authorized third party (final disposal method not disclosed)
- Please upload documentation.
Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Suggested Uploads:
- Documentation that demonstrates domestic wastewater sludge is being disposed of properly (sludge analysis/test showing hazardous properties, sludge disposal manifests, permit/license of waste vendor accepting and treating the sludge, evidence of the final treatment/disposal method being used, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that domestic wastewater sludge is being disposed of responsibly to minimize environmental impacts.
Technical Guidance:
The hazardous properties and proper disposal method of sludge depend on the specific hazardous properties of the sludge (e.g., the type and concentration of hazardous chemicals). Facilities should ensure that sludge is properly characterized (e.g., via laboratory testing) to identify its hazardous properties and any specific disposal requirements or limitations.
At minimum, sludge should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics as required.
As part of a facilities waste management program, it is important for facilities to understand how wastes (including sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for sludge.
If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.
Resources:
- ZDHC Sludge Reference Document. Note: This guidance is not applicable for domestic only sludgehttps://downloads.roadmaptozero.com/output/Sludge-Reference-Document
- ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates domestic wastewater sludge is being disposed of properly. This may include:
- Sludge analysis/test showing hazardous properties.
- Sludge disposal manifests.
- Where applicable, permit/license of waste vendor accepting and treating the sludge.
- Evidence of the final treatment/disposal method being used by the waste vendor.
- Legal approvals/permits for any onsite treatment/disposal of sludge if applicable.
Interview Questions to Ask:
- Staff responsible for wastewater/waste management understand the hazardous composition of the facility’s sludge and the final disposal method used to treat/dispose of the sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being collected and treated per the methods reported by the facility (e.g., onsite treatment/disposal conditions, sludge storage conditions, etc.)
Partial Points: N/A
Answer
Answer Yes if: Your facility has procedures or processes to manage the residue (e.g., sludge) from your septic system in accordance with the design and operating specifications of the septic system.
If you answer Yes to this question, you will be asked the following sub question(s):
- Is your Septic System adequately designed for the septic wastewater volume generated at your facility?
- Please upload the Septic system design.
- If you cannot upload the design document, please describe here:
- How frequently does your facility unload your septic tank(s)?
- How did your facility dispose of the solids after unloading from your septic tank?
- Sent to Municipal plant for further treatment.
- Hazardous Waste Treatment
- Open burning
- Onsite Incineration at ≥1000 °C
- Onsite Incineration at <1000 °C
- Offsite Incineration at ≥1000 °C
- Landfill with Significant Control Measures
- Building Products Processed at ≥1000 °C
- Landfill with Limited Control Measures
- Offsite Incineration and Building Products Processed at <1000 °C
- Landfills with No Control Measures
- Land Application
- Non-disclose method by authorized third party (final disposal method not disclosed)
- Does your facility obtain shipment manifest / record for offloading septic waste?
- Please upload documentation if available.
Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Suggested Uploads:
- Documentation that shows how the facility manages residue (e.g., sludge) from the septic system (e.g., the septic system design drawings showing capacity, tracking records of volume of wastewater sent to the septic system, septic system cleaning schedule and records, records of sludge generation, collection and disposal manifests, records of the final treatment/disposal method being used by the waste vendor.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that wastes (e.g., sludge) from the septic system are being managed in accordance with the design and operating specifications of the septic system.
Technical Guidance:
Septic systems are engineered systems that are specifically designed based on the wastewater characteristics they are intended to treat (e.g., the volume of wastewater and pollutant loading). It is crucial septic systems are operated within their design specifications and operating parameters to ensure the effective treatment of wastewater.
Facilities should have established procedures to ensure that the system is operated, monitored, and maintained in accordance with the design specifications and manufacturer’s specifications for all system equipment and components (e.g., pumps, flowmeters, motoring/sampling, frequency for cleaning out sludge, etc.)
At minimum, residue (e.g., sludge) from the system should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics.
As part of a facilities waste management program, it is important for facilities to understand how wastes (including septic system sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for septic system sludge.
If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.
Resources:
- ZDHC Sludge Reference Document. Note: This guidance is not applicable for domestic only sludge https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that shows how the facility manages residue (e.g., sludge) from the septic system and how the system is being operated in accordance with its design capacity and operating specifications. This may include:
- The septic system design drawings showing capacity.
- Tracking records of volume of wastewater sent to the septic system (e.g., showing that the system is not being overloaded)
- Septic system cleaning schedule and records.
- Records of sludge generation, collection.
- Septic system waste manifests.
- Evidence of the final treatment/disposal method being used by the waste vendor.
Interview Questions to Ask:
- Staff responsible for managing wastewater and/or the septic system can explain how the facility ensures that it is being operated in accordance with the design capacity, how the system is maintained (e.g., cleaning frequency) and how wastes from the septic site are disposed of
Inspection – Things to Physically Look For:
- Observations indicate that the specific system is being operated and maintained properly (e.g., no standing water, damp spots or strong odours near the septic tank or drainfield)
Partial Points: N/A
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer Yes if: Your facility has conducted wastewater testing at the frequency required by local law and for all the legally required parameters.
Answer Not Applicable if: There are no applicable legal requirements for your facility to test its wastewater.
If you answer Yes to this question, you will be asked the following sub question(s):
- Do the results show compliance against the requirement?
- Please upload your test report(s) (Multiple reports as per legal testing frequency)
Note: The question “Do the results show compliance against the requirement?” Should be answered based on the guidance below:
- Answer Yes if: Testing results in all tests meet the legal requirements for all parameters.
- Answer Partial Yes if: Testing results show one parameter did not meet the legal requirements. If there are multiple test reports, there must be no more than one parameter exceedance in one (1) report.
- Answer No if: Testing results show one (1) or more parameters have not been met in multiple test reports, or more than one parameter have not been met in at least one report.
Suggested Uploads:
- Copies of wastewater testing report.
- Wastewater discharge permit or approvals that show the testing parameters and discharge limits that are applicable to the facility.
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that wastewater has been tested against applicable legal requirements.
Technical Guidance:
Testing wastewater in accordance with legal requirements is a fundamental practice to determine if the facility’s wastewater meets the applicable discharge limits. Facilities should ensure that all applicable testing requirements are understood and that procedures to test wastewater per the applicable legal requirements are implemented. This information should be used to monitor compliance and identify issues that require action to achieve and maintain compliance (if non-compliance is detected).
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Wastewater testing results showing results of testing against all legally required parameters.
- Wastewater discharge permit or approvals that show the testing parameters and discharge limits that are applicable to the facility.
Interview Questions to Ask:
- Staff responsible for wastewater management and legal compliance can explain how the facility’s wastewater testing covers all applicable legal requirements.
Inspection – Things to Physically Look For:
- Observations indicate that all wastewater is being tested in accordance with legal requirements (e.g., the facility has identified and tested all wastewater discharge points as per applicable legal requirements).
Answer
Answer
Answer Yes if: Your facility is testing wastewater and reporting results against a wastewater standard in addition to legally required testing.
Note: If your facility has only tested wastewater in accordance with legal requirements, you should answer No to this question.
Answer Not Applicable if: There are no applicable industry wastewater standards (in addition to legal testing requirements) that apply to your facility.
If you select Yes, you will be asked the following sub question(s):
- Please indicate which wastewater standard(s) you are reporting against:
- ZDHC Wastewater Guidelines (for Leather & Textile) (WWG)
- ZDHC MMCF Guidelines
- ZDHC Sludge Reference Document
- BSR
- bluesign Wastewater Standard
- Customer/Brand
- Other
- If other, please describe.
Suggested Uploads:
- Copies of wastewater testing results conducted in accordance with the applicable standard.
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that their wastewater is being tested against a wastewater standard in addition to any legally required testing.
Technical Guidance
The standards referred to in this question refer to industry standards, and the intention is to evaluate compliance beyond basic legal discharge requirements.
Industry standards and tools are developed to support facilities in the proper management and reduction of hazardous pollutants discharged in wastewater to the environment. These tools intend to provide consistent methodologies to identify, monitor and report discharge of hazardous pollutants. They also strive to support facilities in managing and reducing hazardous discharges by establishing progressive discharge limits that go beyond basic legal compliance.
Different standards or tools may have different requirements for monitoring and reporting of wastewater data (e.g., the type and frequency of reporting, types of pollutants that must be monitored/reported, or testing methodologies, etc.) When adopting an industry standard, facilities should review the guideline to determine the monitoring and reporting requirements that apply to their operations and put in place procedures to meet the required monitoring and reporting requirements.
Examples of industry guidance/tools for wastewater include:
- The ZDHC suite of guidelines which can be downloaded here: https://www.roadmaptozero.com/output
- ZDHC Wastewater Guidelines for Leather & Textile
- ZDHC Man-Made Cellulosic Fibres (MMCF) Guidelines
- ZDHC Sludge Reference Document
- bluesign® CRITERIA for production sites (and its Annexes) which can be downloaded here: https://www.bluesign.com/en/downloads
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the applicable standard(s) selected. This may include:
- Wastewater test report showing the parameters tracked by the facility.
- Note: Testing should be conducted in accordance with the applicable standard (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
- If applicable, internal procedures used to ensure the requirements of the standard are being met.
- Wastewater test report showing the parameters tracked by the facility.
Note: Required documentation may vary by standard being reported against. All wastewater reporting documentation required by the standard should be available for verification.
Interview Questions to Ask:
- Staff responsible for managing wastewater understand and can describe the monitoring and reporting requirements of the standard the facility is reporting against.
Inspection – Things to Physically Look For:
- The relevant wastewater sources observed at the facility are included in the facility’s monitoring/reporting procedures as required by the standard used to report wastewater data.
Wastewater – Level 2
Answer
Answer
Note: The response to this Level 2 question will be pre-populated based on the response to the wastewater standard question in Level 1. The Level 1 question is unscored, and scoring will be applied in Level 2 as follows:
- Full Points: will be awarded for a Yes response.
- No Points: will be awarded for a No response.
- Unscored: This question will be unscored if the response is Not Applicable.
How This Will Be Verified:
This question will be verified in accordance with the criteria set forth in the Level 1 question.
Note: This question will only be applicable to facilities that have a Yes response to the question: Are you reporting against any wastewater standard (additional to the legal requirement)?
In this question, you will be asked to complete a table with the following questions to provide details on your facility’s compliance/conformance status with the wastewater standard(s) your facility reports against.
- Reported Wastewater standard (this will be pre-populated with the applicable standard(s) the facility is reporting against).
- Frequency of Sampling
- Are you in compliance with this wastewater standard?
- If not, please provide additional information of why you are not compliant with this wastewater standard.
- Are your parameter results available on the standard’s platform?
- Please provide a direct link to the standard’s platform to access results.
- Please upload documentation to demonstrate you are compliant with the standard.
Note: The question “Are you in compliance with this wastewater standard?” Should be answered based on the guidance below:
- Answer Yes, all parameters are compliant if: Testing is conducted at the frequency required by the standard and the most recent testing results from the FEM reporting year meet the requirements of the standard for all parameters.
- Answer Partial Yes, at least one or more parameters are not compliant if: Testing is not conducted at the frequency required by the standards and/or the most recent testing results from the FEM reporting year show one (1) or more parameters did not meet the requirements of the standard.
- Answer No, I did not test, or all parameters are not compliant if: Testing was not conducted in the FEM reporting year, or all parameters did not meet the requirements of the standard.
Suggested Uploads
- Copies of wastewater testing results and data reporting that demonstrates the facility is meeting the requirements of the standard.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are meeting all of the requirements of the wastewater standard that goes beyond basic legal compliance monitoring and reporting.
Technical Guidance:
Different standards or tools may have different requirements for monitoring and reporting of wastewater data (e.g., the type and frequency of reporting, types of pollutants that must be monitored/reported, or testing methodologies, etc.) When adopting an industry standard, facilities should review the guideline to determine the monitoring and reporting requirements that apply to their operations and put in place procedures to meet the required monitoring and reporting requirements.
Supporting documentation that shows the facility is meeting these requirements such as wastewater monitoring data, testing results, etc. should be maintained.
Examples of industry guidance/tools for wastewater include:
- The ZDHC suite of guidelines which can be downloaded here: https://www.roadmaptozero.com/output
- ZDHC Wastewater Guidelines for Leather & Textile
- ZDHC Man-Made Cellulosic Fibres (MMCF) Guidelines
- ZDHC Sludge Reference Document
- bluesign® CRITERIA for production sites (and its Annexes) which can be downloaded here: https://www.bluesign.com/en/downloads
How This Will Be Verified:
Full Points:
Full points will be awarded if testing is conducted at the frequency required by the standard and testing results of all the most recent testing results from the FEM reporting year meet the requirements of the standard for all parameters.
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the applicable standard(s) selected. This may include:
- Wastewater test report showing the parameters tracked by the facility.
- Note: Testing should be conducted in accordance with the applicable standard (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
- External links to the facility’s wastewater data on the standard’s platform
- If applicable, internal procedures used to ensure the requirements of the standard are being met.
- If applicable supporting documentation of investigations to identify the cause of any non-conformances.
- Wastewater test report showing the parameters tracked by the facility.
Note: Required documentation may vary by standard being reported against. All wastewater reporting documentation required by the standard to demonstrate compliance should be available for verification.
Interview Questions to Ask:
- Staff responsible for managing wastewater understand and can describe the monitoring and reporting requirements of the standard the facility is reporting against.
Inspection – Things to Physically Look For:
- The relevant wastewater sources observed at the facility are included in the facility’s monitoring/reporting procedures as required by the standard used to report wastewater data.
Partial Points:
Partial points will be awarded if testing is not conducted at the frequency required by the standards and/or the most recent testing results from the FEM reporting year show one (1) or more parameters did not meet the requirements of the standard.
Answer
Note: This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.
Answer Yes, I tested and meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show all conventional parameters and Anions met the foundational level of the standard.
Answer Partial Yes, I have tested and did not meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more conventional parameters or anions did not meet the foundational level of the standard.
Answer Not Applicable if: Conventional parameters and anions are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.
If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC conventional parameters and anions :
- Did this parameter exceed the foundational limit?
- Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
- Quantity Detected
- Unit of measure
- What is the limit quantity?
- Unit of measure
- How long have you had this problem?
- Upload your action plan for the substance detected.
- If you don’t have a document to upload, describe your plan.
Technical Guidance:
For detailed information on the ZDHC wastewater guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output
How This Will Be Verified:
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
- Wastewater test report showing the parameters tracked by the facility.
- Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
- External links to the facility’s wastewater data on the standard’s platform
- If applicable, supporting documentation of planned actions to address any non-conformances.
- Wastewater test report showing the parameters tracked by the facility.
Interview Questions to Ask:
- Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC Wastewater Guidelines.
Inspection – Things to Physically Look For:
- The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.
Answer
Answer
Note: This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.
Answer Yes, I tested and meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show all heavy metals met the foundational level of the standard.
Answer Partial Yes, I have tested and did not meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more heavy metals did not meet the foundational level of the standard.
Answer Not Applicable if: Heavy metals are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.
If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC heavy metals parameters :
- Did this parameter exceed the foundational limit?
- Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
- Quantity Detected
- Unit of measure
- What is the limit quantity?
- Unit of measure
- How long have you had this problem?
- Upload your action plan for the substance detected.
- If you don’t have a document to upload, describe your plan.
Technical Guidance:
For detailed information on the ZDHC Wastewater Guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output
How This Will Be Verified:
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
- Wastewater test report showing the parameters tracked by the facility.
- Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
- External links to the facility’s wastewater data on the standard’s platform
- If applicable, supporting documentation of planned actions to address any non-conformances.
- Wastewater test report showing the parameters tracked by the facility.
Interview Questions to Ask:
- Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC Wastewater Guidelines.
Inspection – Things to Physically Look For:
- The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.
Answer
Note: This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.
Answer Yes, I tested and meet parameter limits if: The most recent ZDHC testing results from the FEM reporting year show no MRSL parameters were detected including raw wastewater samples.
Answer Partial Yes, I have tested and did not meet all parameter limits if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more MRSL parameters was detected including raw wastewater samples.
Answer Not Applicable if: MRSL parameters are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.
Note: No detection means that the parameter was not detected above the specified reporting limit listed in the ZDHC Wastewater Guideline.
If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC MRSL parameters :
- Was a chemical in this MRSL Parameter Category Detected?
- Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
- Quantity Detected
- Unit of measure
- What is the limit quantity?
- Unit of measure
- How long have you had this problem?
- Upload your action plan for the substance detected.
- If you don’t have a document to upload, describe your plan.
Technical Guidance:
For detailed information on the ZDHC Wastewater Guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output
How This Will Be Verified:
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
- Wastewater test report showing the parameters tracked by the facility.
- Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
- External links to the facility’s wastewater data on the standard’s platform
- If applicable, supporting documentation of planned actions to address any non-conformances.
- Wastewater test report showing the parameters tracked by the facility.
Interview Questions to Ask:
- Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC wastewater guidelines.
Inspection – Things to Physically Look For:
- The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.
Answer
Answer
Answer Yes if: Your facility tracks wastewater sludge and the disposal method for at least one (1) source of sludge generated at the facility.
If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your wastewater sludge generated by each source during this reporting year.
- Source of Wastewater Sludge (This will be pre-populated based on the facility’s reported sources of sludge)
- How is this wastewater sludge generated classified for this source?
- Domestic
- Industrial
- Combined Domestic and Industrial
- Does your facility track how much wastewater sludge it generates from this source in the reporting year?
- How much wastewater sludge (in Metric Ton) do you generate from this source in the reporting year (after any drying process is conducted, if any)?
- How does your facility dispose of this wastewater sludge?
- How does your facility dispose of ash generated from onsite incineration? (Applies if onsite incineration is selected)
- If Other, please describe your disposal pathway.
- Did you test the wastewater sludge of this source?
- Were MRSLs detected in the sludge?
- If MRSLs is detected, please select which one (Select all that apply)
- Were Heavy Metal (Total Metal) and conventional parameters tested?
- If Heavy Metal (Total Metal) and conventional parameters were above allowable limits, please select which one (Select all that apply)
- Were MRSLs detected in the sludge?
- Provide any additional comments.
- Please upload documentation.
Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Suggested Uploads:
- Documentation that demonstrates wastewater sludge quantity, composition, and disposal method(s) are being tracked (e.g., sludge inventory/tracking, sludge analysis/test showing hazardous properties, sludge disposal manifests, evidence of the final treatment/disposal method being used, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that wastewater sludge generated at the facility is being tracked (e.g., sludge quantity, composition, and disposal method).
Technical Guidance:
It is important for facilities to know and track the different sources (e.g., types) of sludge and the general composition of sludge to ensure the most effective treatment and disposal options are used. Tracking the properties and volume of sludge generated at the facility can also provide insight into the effectiveness of wastewater treatment processes, the presence of undesired chemicals (e.g., MRSL compounds) as well as disposal costs.
The hazardous properties and proper disposal method of sludge depend on the specific hazardous properties of the sludge (e.g., the type and concentration of hazardous chemicals). Facilities should ensure that sludge is properly characterized (e.g., via laboratory testing) to identify its hazardous properties and any specific disposal requirements or limitations.
At minimum, sludge should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics.
Additionally, as part of a facilities waste management program, it is important for facilities to understand how wastes (including sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for sludge.
If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
- ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates wastewater sludge is being tracked. This may include:
- Sludge inventory showing the quantity, composition, and disposal method(s) for sludge generated at the facility.
- Sludge analysis/test showing hazardous properties.
- Sludge disposal manifests
- Evidence of the final treatment/disposal method being used onsite or by the waste vendor.
Interview Questions to Ask:
- Staff responsible for wastewater/waste management can explain how sludge is tracked at the facility including tracking of sludge volume, composition, and the final disposal method used to treat/dispose of sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being tracked in accordance with the facility’s reported procedures for tracking sludge.
Partial Points: N/A
Answer
Answer Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and all of the following conditions are met:
- Documentation has been obtained that accounts for all sludge disposals.
- The documentation contains all of the information noted below:
- Shipper (the facility generating the sludge).
- Mass or volume of the shipment.
- Transporter name.
- Shipment/Receiving dates.
- Name of the disposal or processing facility that the sludge was shipped to.
Answer Partial Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge, and documentation is available, however:
- The documentation has not been obtained for all sludge disposals; and/or
- The documentation does not contain all of the information noted below:
- Shipper (the facility generating the sludge).
- Mass or volume of the shipment.
- Transporter name.
- Shipment/Receiving dates.
- Name of the disposal or processing facility that the sludge was shipped to.
If you answer Yes or Partial Yes to this question, you will be asked the following sub question(s):
- Does your facility use authorized third party for legal disposal of domestic wastewater sludge?
- Does your facility retain documentation of all wastewater sludge transportation and disposal/treatment companies?
- Note: This refers to the legally required amount of time that documentation must be retained, which may vary by jurisdiction. If there are no legal requirements, documentation must be retained for at least two (2) years.
- Are all domestic wastewater sludge transporters, treatment, and disposal facilities licensed and permitted?
- Please upload documentation.
Suggested Uploads:
- Samples of waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge.
- Copies of sludge handling/treatment/disposal vendor licenses and/or permits that show they are authorized to receive, process and dispose of the sludge.
Note: Uploading of all manifest or other documentation is not required, however they should be available for review at the time of verification.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that processes are in place to obtain and retain information related to the handling, transportation, processing, and disposal of domestic wastewater sludge and to ensure that any third-party waste vendors have the required legal approvals to receive, process and dispose of the facility’s sludge.
Technical Guidance:
To ensure proper accountability, facilities should have established processes in place to maintain documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge. Often the minimum requirements for generating and maintaining documentation related to waste disposal are governed by legal requirements and all applicable requirements should be met by facilities.
In addition to any legal requirements, facilities should ensure that a waste manifest or a similar local transport document that contains the following information is obtained and maintained for each sludge shipment as a good practice. If needed this additional information can be requested from waste vendors:
- Shipper (the facility generating the sludge).
- Mass or volume of net shipment.
- Transporter name.
- Driver’s name/signature.
- Name of the disposal or processing facility that the sludge was shipped to.
- Name/signature of personnel at the disposal or processing facility certifying acceptance of the sludge.
Facilities should also ensure that any third-party waste vendors used have the required legal approvals to receive, process and dispose of the facility’s sludge. Facilities should ensure that part of the waste vendor approvals process include the verification of all legally required approvals (e.g., licenses and permits). It is considered a good practice (if not legally required) for facilities to request and maintain up-to-date and valid copies of vendor approvals onsite.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and all of the following conditions are met:
- Documentation has been obtained that accounts for all sludge disposals and contains all of the required information.
- Documentation is retained onsite for at least the legally minimum required length of time.If there are no legal requirements, documentation must be retained for at least two (2) years.
- Any third-party waste vendors used have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.
Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.
Documentation Required:
- Documentation that shows the facility has obtained and maintains waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and that sludge is being received by authorized vendors. This may include:
- Waste manifests or other transport documentation.
- Waste vendor licenses and/or permits that show they are authorized to receive, process and dispose of the facility’s sludge.
Interview Questions to Ask:
- Staff responsible for managing wastes can explain the facilities procedures to obtain and maintain manifests and/or other transport information related to sludge disposal and how the facility ensures that waste vendors have the required approvals to collect, receive, or process the facility’s sludge.
Inspection – Things to Physically Look For:
- Observations indicate that sludge is being collected and treated per the process reported by the facility (e.g., sludge disposal records, sludge storage conditions, presence of waste contractors onsite during verification, etc.)
Partial Points:
Partial points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge, and documentation is available, however one (1) or more of the following conditions exist:
- Documentation has been obtained but does not account for all sludge disposals or does not include the required information; and/or
- Documentation is not retained onsite for at least the legally minimum required length of time .If there are no legal requirements, documentation has not been retained for two (2) years; and/or
- Any third-party waste vendors used do not have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.
Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.
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Answer Yes if: Your facility has a documented plan with a defined timeline to upgrade your septic system to a more advanced treatment system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, when do you plan on having the upgrade completed?
- If yes, please upload documentation.
If you answer No to this question, you will be asked the following sub question(s):
- If no, please describe why you do not plan to upgrade your septic tank?
Suggested Uploads:
- Documentation that supports the facility’s plans to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility (e.g., records of purchase of wastewater treatment system, contract for planned construction of new treatment facility or removal of septic system, agreement with offsite wastewater treatment facility to begin receiving the facility’s wastewater, etc.)
This question is not scored in the 2023 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that there is an established plan in place to upgrade the septic system to a more advanced treatment system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility.
Technical Guidance:
Septic systems provide a basic level of treatment for wastewater that are often not capable of providing a sufficient level of treatment before discharging wastewater directly to the environment. Additionally, in most cases it is not practical to effectively monitor effluent from the septic system to ensure that potential environmental impacts are being minimized. Effluent from septic systems can often contain levels of pathogens (e.g., E. coli), chemicals, and nutrients (e.g., nitrogen and phosphorus) that can contaminate groundwater or nearby surface water.
Upgrading a septic system to a more advanced type of treatment system (e.g., primary, secondary, and tertiary treatment) can reduce the risk of adverse impacts to the environment and allow facilities to ensure wastewater is appropriately treated before being discharged.
An alternative solution to a septic system upgrade could also include discontinuing the use of the septic system and directing wastewater to an authorized offsite wastewater treatment facility for treatment.
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that demonstrates the facility has an established plan to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility. This may include:
- Records of purchase of new wastewater treatment system.
- Contract for planned construction of new treatment facility or removal of septic system.
- Agreement with offsite wastewater treatment facility to begin receiving the facility’s wastewater.
- Documented timelines for project completion if available.
Interview Questions to Ask:
- Staff responsible wastewater management can explain the facility’s plans to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility.
Inspection – Things to Physically Look For:
- If applicable, observations are consistent with the facility’s reported plans (e.g., observed onsite construction activities or preparations for system upgrades)
Answer
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Answer Yes if: Your facility obtained wastewater results from the offsite wastewater treatment plant in the Higg FEM reporting year or your facility has formally requested the offsite wastewater treatment plant to provide these results, or the wastewater treatment plant posts their effluent testing data online and the facility has access to this.
Notes:
- Formally requested means that the facility has contacted the wastewater treatment plant or operator (via email, letter, or other means of communication) to request wastewater quality test results.
- If results have formally been requested and the facility has documentation of this request and results are not provided, and there is supporting evidence of the refusal, Yes can be selected for this question.
If you answer Yes to this question, you will be asked the following sub question(s):
- How / What action did you take to make the request?
- Request Permit / compliance status of offsite Wastewater treatment plant.
- Research online record.
- Send official request to offsite Wastewater treatment plant.
- Other
- If Other, please describe.
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
Suggested Uploads:
- Offsite wastewater treatment plant quality test records for the FEM reporting year (if provided).
- Documentation of your request to the offsite wastewater treatment plant for wastewater quality records in the FEM reporting year.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are proactively seeking to verify that wastewater from the offsite treatment plant is compliant with applicable legal and understand any potential impacts the facility’s wastewater may have on the offsite treatment plants operations.
Technical Guidance:
The objective of requesting wastewater quality test results from the offsite treatment plant is for a facility to proactively verify that treated wastewater effluent discharged from the offsite facility to the environment is compliant.
Although facilities do not have operational control over the third-party treatment provider, it is important to be aware of any non-compliances and to what extent the facility may be contributing to non-compliances. This information is useful to help understand your situation and identify risk factors and/or opportunities for improvement.
It is recommended that facilities establish procedures to obtain (when possible), verify, and track this data on a regular basis (e.g., monthly, quarterly, etc) to monitor compliance as part of their environmental management program.
How This Will Be Verified:
Full Points:
Documentation Required:
- Offsite wastewater treatment plant quality test records for the FEM reporting year (if provided).
- Documentation of your request to the offsite wastewater treatment plant for wastewater quality records in the FEM reporting year.
Interview Questions to Ask:
- Staff responsible for wastewater management at the facility can explain how wastewater treatment plant quality test records are obtained and/or requested from the offsite treatment plant.
Inspection – Things to Physically Look For:
- Observations indicate that the wastewater test results or requests made are for the offsite treatment plant used by the facility.
Partial Points: N/A
Wastewater – Level 3
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Answer Yes if: Your facility proactively engages/collaborates with your offsite wastewater treatment provider to improve their wastewater treatment and/or increase wastewater recycling.
If you answer Yes to this question, you will be asked the following sub question(s):
- Please describe your engagement/collaboration activity.
Suggested Uploads:
- Documentation that demonstrates how your facility has engaged with the offsite wastewater treatment plant in the Higg FEM reporting year (e.g., lists of activities and with dates of engagement, meeting records, completed audits or surveys etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are actively engaging with their offsite wastewater treatment plant to improve treatment and increase wastewater recycling.
Technical Guidance:
Engaging with your offsite wastewater treatment plant is important because your facility often has a direct impact on their operations and working collaboratively with them as well as other relevant stakeholders can create a shared focus and dedicate resources to making improvements.
Examples of engagement can include, but are not limited to:
- Audits or surveys of treatment plant operations with the objective of identifying and providing feedback on opportunities for improvement.
- Regularly scheduled (e.g., annual) collaborative meetings with wastewater treatment provider and other relevant stakeholders to evaluate and plan for improvements (e.g., evaluate the feasibility of new or best available technologies for wastewater treatment and/or recycling, development of improvement plans or road map).
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates how your facility has engaged with the offsite wastewater treatment plant in the Higg FEM reporting year. This may include:
- List of engagement activities and stakeholders with dates of engagement.
- Records of collaborative meetings to evaluate and plan for improvements.
- Completed audits or surveys of offsite treatment plant operations.
- Other relevant documentation of engagement and/or improvements resulting from engagement with the offsite treatment plant.
Interview Questions to Ask:
- Staff responsible for managing/participating in the engagement can explain how and who they engage with on improvements for wastewater treatment and/or recycling.
Inspection – Things to Physically Look For:
- Where applicable, observations onsite are consistent with the reported engagement activities.
Partial Points: N/A
Answer
Answer Yes if: Your facility reuses process wastewater as process water and tracks the quantity of water reused.
Note: Process wastewater reuse is defined as the act of taking wastewater discharged from one process from which it no longer has beneficial use and using it in other processes without treatment. This does not include water cycled in operations such as cooling towers and non-contact heat exchange operations or water that is reused for domestic uses such as landscape irrigation.
If you answer Yes to this question, you will be asked the following sub question(s):
- How much (in m3) of process wastewater was reused back into your production processes?
- Note: The annual quantity of process water reused in the FEM reporting year should be input here.
- Enter the percentage of process wastewater reused back into your production processes.
- Note: The annual percentage of process water reused in the FEM reporting year should be input here. This is calculated as follows:
- % of water reused = Total Annual Water Reused (m3) / Total Annual Production Water (m3) x 100%
- If production and domestic water use cannot be separated, the total annual water use should be used.
- Note: The annual percentage of process water reused in the FEM reporting year should be input here. This is calculated as follows:
- Please briefly describe how the reuse process is conducted within your facility.
- Please upload documentation.
Suggested Uploads:
- Tracking records of the quantity of process water reuse (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water reuse system design drawings or water flow diagrams that show where and how process water is reused.
What is the intent of the question?
The intent of this question is to incentivise the use of innovative technology or solutions to reuse process wastewater to reduce the facility’s water use footprint.
Technical Guidance:
Water reuse is an effective solution to reduce overall water use. This utilizes wastewater from a process as the water source for another process without the need for treatment. The quality of this wastewater and requirements for reuse are key factors that will dictate if and where the process wastewater can be reused.
Facilities should evaluate the process wastewater from all processes to determine if it is suitable for reuse and what will be needed to reuse the wastewater (e.g., retrofits to the water collection and supply network).
Facilities should also establish procedures to track the volume of water reused so this can be monitored and used to demonstrate reductions in the facility’s water use footprint. Direct Measurement (e.g., with meters) is the preferred tracking method, however in some cases the volume of water reused may need to be calculated using an established estimation methodology. Any estimation methodology should be established or evaluated by a qualified individual (e.g., an environmental or process engineer) to ensure that the methodology is as accurate as possible and representative of facility operating conditions.
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that reuse process wastewater as process water and track the quantity of water reused. Points are not allocated based on the percentage reused.
Documentation Required:
- Tracking records of the quantity of process water reuse (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water reuse system design drawings or water flow diagrams that show where and how process water is reused.
- Documented calculation/estimation methodology if applicable.
Interview Questions to Ask:
- Staff responsible for water/wastewater management can describe how process wastewater is reused as process water, how this is tracked and how the accuracy of the water reuse data is ensured.
Inspection – Things to Physically Look For:
- Observations indicate that the reported process water is being reused as process water (e.g., observe the equipment/water source network facilities in place to facilitate the water reuse).
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Answer Yes if: Your facility recycles industrial wastewater for production processes and tracks the quantity of water recycled.
Note: Recycled industrial wastewater is defined as process wastewater that has been treated using physical, chemical, and/or any additional treatment processes to meet a quality which allows the water to be used again in a production process. For example, wastewater that has gone through a membrane filtration process and used back in the industrial operations is considered recycled water. This does not include water cycled in operations such as cooling towers and non-contact heat exchange operations or water that is recycled and used for domestic uses such as landscape irrigation.
If you select Yes, you will be asked the following sub question(s):
- How much (in m3) of treated industrial wastewater was recycled back into your production processes?
- Note: The annual quantity of recycled industrial wastewater in the FEM reporting year should be input here.
- Enter the percentage of treated industrial wastewater that was recycled back into your production processes.
- Note: The annual percentage of industrial wastewater recycled in the FEM reporting year should be input here. This is calculated as follows:
- % Recycle Rate = Recycled used / (Recycle used + Wastewater Discharge) x 100%
- If production and domestic water use cannot be separated, the total annual water use should be used.
- Note: The annual percentage of industrial wastewater recycled in the FEM reporting year should be input here. This is calculated as follows:
- Please briefly describe how the recycling process is conducted within your facility.
- Please upload documentation.
Suggested Uploads:
- Tracking records of the quantity of industrial wastewater recycled (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water recycling system design drawings or water flow diagrams that show where and how industrial wastewater is recycled and used.
What is the intent of the question?
The intent of this question is to incentivise the use of innovative technology or solutions to recycle industrial wastewater back into production processes to reduce the facility’s water use footprint.
Technical Guidance:
Water recycling is an effective solution to reduce overall water use. If industrial wastewater does not meet the quality requirements to be reused in production processes, it can be treated (either chemically or biologically) to meet the required quality specifications and be recycled. The quality of the wastewater, and level of treatment that can be achieved are key factors that will dictate if and where the wastewater can be recycled for use again in the facility.
Facilities should evaluate the quality of industrial wastewater and treatment capabilities to determine if it is suitable to be recycled and used again and what will be needed to reuse the wastewater (e.g., retrofits to the water treatment system or collection and supply network).
Facilities should also establish procedures to track the volume of water recycled so this can be monitored and used to demonstrate reductions in the facility’s water use footprint. Direct Measurement (e.g., with meters) is the preferred tracking method, however in some cases the volume of water recycled may need to be calculated using an established estimation methodology. Any estimation methodology should be established or evaluated by a qualified individual (e.g., an environmental or process engineer) to ensure that the methodology is as accurate as possible and representative of facility operating conditions.
How This Will Be Verified:
Full Points:
Full points will be awarded if the facility recycled 50% or more of its industrial wastewater back into production processes in the FEM reporting year.
Documentation Required:
- Tracking records of the quantity of industrial wastewater recycled (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water recycling system design drawings or water flow diagrams that show where and how industrial wastewater is recycled and used in production processes.
- Documented calculation/estimation methodology if applicable.
Interview Questions to Ask:
- Staff responsible for water/wastewater management can describe how industrial wastewater is recycled and used in production processes, how this is tracked and how the accuracy of the water recycling data is ensured.
Inspection – Things to Physically Look For:
- Observations indicate that the reported industrial wastewater is being recycled back into production processes (e.g., observe the equipment/water source network facilities in place to facilitate the water recycling and reuse).
Partial Points:
- Partial points will be awarded if the facility recycled 20% to 49% of its industrial wastewater back into production processes in the FEM reporting year. No points are awarded if less than 20% of industrial wastewater is being recycled.
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Answer Yes if: Your facility recycles domestic wastewater for domestic use and tracks the quantity of water recycled.
Answer Not Applicable if: Your facility is not permitted by law to reuse domestic wastewater as domestic water.
Note: Recycled domestic wastewater is defined as domestic wastewater that has been treated using physical, chemical, and/or any additional treatment processes to meet a quality which allows the water to be used again for domestic uses such as landscape irrigation, toilets.
If you select Yes, you will be asked the following sub question(s):
- How much (in m3) of treated domestic wastewater was recycled back as domestic water?
- Note: The annual quantity of recycled domestic wastewater in the FEM reporting year should be input here.
- Enter the percentage of wastewater treated and recycled back as domestic water
- Note: The annual percentage of domestic wastewater recycled in the FEM reporting year should be input here. This is calculated as follows:
- % of water recycled = Total Annual Domestic Water Recycled (m3) / Total Annual Domestic Water (m3) x 100%
- Note: The annual percentage of domestic wastewater recycled in the FEM reporting year should be input here. This is calculated as follows:
- Please briefly describe how the recycling process is conducted within your facility.
- Please upload documentation.
Suggested Uploads:
- Tracking records of the quantity of domestic wastewater recycled (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water recycling system design drawings or water flow diagrams that show where and how domestic wastewater is recycled and used.
What is the intent of the question?
The intent of this question is to incentivise the use of innovative technology or solutions to recycled domestic wastewater for domestic use to reduce the facility’s water use footprint.
Technical Guidance:
Water recycling is an effective solution to reduce overall water use. Domestic wastewater can be treated (either chemically or biologically) to meet the required quality specifications and be recycled to use again for domestic use. The level of treatment that can be achieved and any applicable legal requirements for reuse of domestic water for land applications are key factors that will dictate if and where the wastewater can be recycled for use again.
Facilities should evaluate the quality of domestic wastewater and treatment capabilities to determine if it is suitable to be recycled and used again and what will be needed to reuse the wastewater (e.g., retrofits to the water treatment system or collection and supply network).
Facilities should also establish procedures to track the volume of water recycled so this can be monitored and used to demonstrate reductions in the facility’s water use footprint. Direct Measurement (e.g., with meters) is the preferred tracking method, however in some cases the volume of water recycled may need to be calculated using an established estimation methodology. Any estimation methodology should be established or evaluated by a qualified individual (e.g., an environmental or process engineer) to ensure that the methodology is as accurate as possible and representative of facility operating conditions.
How This Will Be Verified:
Full Points:
Documentation Required:
- Tracking records of the quantity of domestic wastewater (e.g., meter logs, data tracking worksheets/charts, calculations).
- Water recycling system design drawings or water flow diagrams that show where and how domestic wastewater is recycled and used for domestic purposes.
- Documented calculation/estimation methodology if applicable.
Interview Questions to Ask:
- Staff responsible for water/wastewater management can describe how domestic wastewater is recycled and used for domestic purposes, how this is tracked and how the accuracy of the water recycling data is ensured.
Inspection – Things to Physically Look For:
- Observations indicate that the reported domestic wastewater is being recycled and used again for domestic use (e.g., observe the equipment/water source network facilities in place to facilitate the water recycling and reuse).
Partial Points: N/A
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