Hazardous Waste Determination

Outline of the six steps

EPA recommends that you follow a six step process to determine whether a waste is hazardous.  The steps are listed below, expressed as a series of questions:

You can find more information on our web, so please take a look.

• Is it "solid waste"?  (Does it meet the regulatory definition of a "solid waste"?)
• Is it excluded?  (Does it fall under a regulatory exemption?)
• Is it listed?  (Is it included in a specific list of wastes?)
• Is it characteristic?  (Does it have a specific set of properties?)
• Is it a mixture?  (Even if not itself hazardous, is it mixed with hazardous wastes?)
• Is it derived from a hazardous waste?

The steps are discussed in some detail in the following sections, with an emphasis on issues that would typically arise in healthcare facilities.  Because the issues can get complicated, the sections also provide links to more detailed information.

Is it "solid waste"?

The first step in determining if a material is a hazardous waste is to determine whether it is classified as a "solid waste".  The rules specify that a material cannot be a hazardous waste unless it is first determined to be a solid waste.

"Solid" for RCRA purposes doesn't mean what it means to you and me.  The regulatory usage of the term "solid" in this context is closer to the sense of the word "contained".

RCRA states:

“The term “solid waste” means any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material including solid, liquid, semisolid or contained gaseous material…”  (US Code, Title 42, paragraph , emphasis added)

So even gaseous material can, in some circumstances, qualify as a "solid waste".

Most materials of concern in healthcare facilities will fall under the "other discarded material" category in the RCRA definition.  So how can you recognize when material has been "discarded"?  According to EPA usage, there are three types of "discarded" material:

1. Abandoned
2. Recycled
3. Inherently waste-like

Abandoned: In simplest terms, a material is considered "abandoned" if you plan to get rid of it. It clearly applies to material you have already disposed of, or that you have incinerated. It also applies to material that is being accumulated, stored and treated for eventual disposal.

It's not hard to imagine situations in which a facility and an inspector might have a difference of opinion about whether some stored material is or is not a waste.  Here are some of the questions the inspector might ask:

1. Does the facility have a use for the material?
2. Does the facility treat the material as if it was a valuable commodity?
3. Does the facility plan to give it to someone else that has a use for it?

For example, suppose the inspector comes across a 55 gallon drum of solvent in the basement that is rusted, corroded and sitting in a pool of water. Even if the solvent is a valuable commodity, the facility is not ‘treating’ it as such.  They are treating it as waste. The inspector would be likely to consider it abandoned.

Recycled:  Specific types of recycled materials are considered ‘discarded’ and are therefore solid waste.

A material is normally considered to be discarded if it is:

• used in a manner constituting disposal
• burned for energy recovery
• reclaimed
• accumulated speculatively

"Speculative accumulation" refers to all those piles of material that you fully intend to recycle, but haven't quite gotten around to.  EPA will generally consider that your material is being "accumulated speculatively" if you cannot demonstrate a viable market for it, or if you have not recycled at least 75% of it in a given calendar year.

A material is also considered discarded if it is accumulated, stored or treated before recycling.

Please note that some materials that are reclaimed are not considered solid wastes under RCRA, even if they exhibit a characteristic of hazardous waste (like ignitability or corrosivity --  see below).  These include:

• commercial chemical products
• sludges
• by-products

Similarly, commercial chemical products that are speculatively accumulated are also not solid wastes under RCRA.

Inherently waste-like:  Certain materials pose such a significant threat to human health that they are deemed "inherently waste-like" and are always considered solid wastes.  A standard example is any material containing dioxins -- that is in fact the only example so far.

In case of dispute:  It can sometimes happen that an inspector will consider that a particular material has been "discarded", and the facility will not agree.  In such a case, the facility will have to submit appropriate documentation to the inspector.  For example, if you are claiming that the material is a valuable commodity or has another use, you will need to show that you have a market for it, or that someone is actually taking and using it beneficially, etc.

Is it excluded?

The next step is to determine if the waste qualifies for an exclusion from RCRA regulation.  There are three main avenues:

• solid waste exclusion
• solid waste variance
• hazardous waste exclusion
• recycling

Solid waste exclusion:  There are some materials that are specifically excluded from the definition of "solid waste".  You can find a full listing in 40 CFR 261.4(a), but most cases are not likely to be relevant to healthcare facilities.  Examples include solid or dissolved material in domestic sewage, certain nuclear materials (already covered under the Atomic Energy Act), and a long list of materials from industrial and agricultural processes.

Regarding the case of domestic sewage, please be aware that this exclusion does not give you an opportunity to throw questionable waste down the drain and then claim that it's excluded under 40 CFR 261.4.  The purpose of that exclusion is to allow facilities like municipal sewage treatment plants (known as "publicly owned treatment works", or POTWs) to deal with their waste streams without having to comply with RCRA requirements that would be inappropriate for them.  Healthcare facilities must have a written agreement from their POTW to accept any waste that might qualify. 

Solid waste variance:  Another possible way to keep a particular material from being regulated under RCRA is to apply for a solid waste variance.   This option applies to:

• Materials accumulated speculatively without sufficient amounts recycled
• Materials reclaimed and reused within original process
• Materials incompletely reclaimed

In order to use these variances, you will have to submit documentation demonstrating your case. If your state is authorized to administer the variance program, send the documentation to the director of your state agency.  Otherwise, send it to the EPA Regional Administrator.  You can find the rules governing solid waste variances in 40 CFR, sections 40 CFR 260.30, 40 CFR 260.31 and 40 CFR 260.33.

Hazardous waste exclusion:  Even if a material is indeed a solid waste, and even if it does not qualify for a solid waste variance, the regulations provide yet another possibility for exclusion.  The solid waste might be excluded from being considered a "hazardous waste" if it falls under any of the exemptions listed in the next subsection of the Code, 40 CFR 261.4(b).

Most of the hazardous waste exclusions listed in that subsection are not relevant to healthcare facilities, but here are three possibilities that may apply to you:

1. Household waste (see 261.4(b)(1))
   • Waste from university dormitories, military housing, and any residents’s housing that you may have at your facility will fall under this exclusion. 
   • However, note that only wastes normally found in a household would fall under this exclusion.
   • Note: if your facility hosts a mercury thermometer swap for the community, this would be household waste and would qualify for the exclusion, as long as that waste is kept separate from other hospital waste.
2. Used Freon (see 261.4(b), paragraphs (11) and (12))
3. Samples of solid waste collected for the purpose of testing and treatability studies (see 261.4(d),(e), and (f))

Is it listed?

The RCRA regulations include four lists of materials, designated with the letters F, K, P, and U.  (The origin of the letter designations is obscure.)  If the waste you are screening appears on the any of the lists, your task is done -- it's hazardous.

What distinguishes the lists?

The F- and K-lists cover process wastes -- wastes generated from processes carried out in your facility.  The P- and U-lists cover unused commercial chemicals that are being discarded for various reasons;  for example, they may be off-specification or expired,  they may have been spilled and cleaned up, or they may be residues left in containers.

The distinction between the two process waste lists (F and K) lies in their specificity.  The K-list deals with very specific processes that are typically carried out by one manufacturing sector only, such as organic chemical manufacturing or petroleum refining.  The F-list covers general processes that might occur in a range of sectors, such as solvent use, metal finishing processes, and wood preserving.

The unused chemicals lists (P and U) differ in their degree of risk. P-listed wastes are "acutely toxic", meaning that they can cause death or irreversible illness at low doses. U-listed wastes are "toxic": they are still regarded as hazardous, but some of the more stringent regulations that apply to the P-list do not apply to U-listed wastes. It should be noted that the drug is only listed if its sole active ingredient is listed on the P or U list.

The P- and U-lists do not apply to manufactured articles that contain a P- or U-listed waste (e.g. mercury thermometers) or to products that contain more than one active ingredient.   Such wastes might still be hazardous, but their hazard classification would fall under a different category (most likely the toxicity characteristic discussed in the next section).

K-list

Healthcare facilities do not carry out manufacturing processes, and would not typically generate any K-listed materials.

F-list

The first five F-listed categories, F001 - F005, cover a range of solvents used in a variety of applications.  A healthcare facility might generate F-listed solvents such as acetone, methanol, toluene, xylene, and methylene chloride from departments such as:

• pathology laboratory
• histology laboratory (xylene)
• pharmacy
• morgue
• maintenance shops (degreasers)

The rest of the F-list is not likely to apply to healthcare facilities.

P-list

If you are interested in reducing the hazardous waste generated in your facility, eliminating or finding substitutes for P-listed chemicals is a good place to start.  A small quantity -- one kilogram -- of a P-listed waste can cause a facility to be classified as a "large quantity generator," and to have to comply with more stringent rules as a consequence.

The P-list includes about 239 different "acutely toxic" substances, listed under about 135 different waste codes.  (Some codes cover several substances.)  HERC has identified 15 of these that you might expect to find in a healthcare facility.  They are listed below, along with their waste codes and typical uses associated with each.  The CAS numbers for these compounds can be found in the official list at 40 CFR 216.33.

Please note that our short list is not meant to be exhaustive, and also that states may impose restrictions that apply to wastes beyond those listed in the federal list.

P-listed chemicals commonly found in healthcare facilities Material Code Use Arsenic Trioxide P012 antineoplastic Cyanide Salts P030 laboratory Nicotine P075 smoking cessation, nicotine patches, etc. Potassium Silver Cyanide P099 bactericide Warfarin >0.3% P001 blood thinner Physotigmine Salicylate P188 glaucoma

U-list

The U-list includes about 472 distinct materials, listed under about 247 different waste codes.  (As with the P-list, the same code can refer to several different materials.)  HERC has identified 66 of them that you might expect to find in a healthcare setting, and has listed them, along with their waste codes and typical uses, below.    The CAS numbers for these compounds can be found in the official list at 40 CFR 216.33.

Our list is not meant to be exhaustive.  States may impose restrictions that apply to wastes beyond those listed in the federal list.

U-listed chemicals commonly found in healthcare facilities Material Code Use Mitomycin C U010 antineoplastic Chloral hydrate (CIV) U034 seditive Cyclophosphamide U058 antineoplastic Daunomycin U059 antineoplastic Lindane U129 lice, scables Melphalan U150 antineoplastic Selenium sulfide U205 anti-fungal, dandruff Streptoztocin U206 antineoplastic Benzidine dichloride U243 pathology laboratory

Chemotherapy agents

Some chemicals used to treat cancer patients during chemotherapy fall on either the U or P lists.  These agents are often referred to by their brand names rather than the chemical designations appearing on the lists. 

Is it characteristic?

Designating hazardous materials by listing them explicitly is fine as far as it goes, but that strategy will never go far enough.  There are many more materials used in commerce than could ever be covered in a manageable set of lists.  Furthermore, some mixtures of materials can be just as hazardous as single materials, while others can be relatively benign.  Given the astronomical number of possible combinations of materials, listing is not a practical way to account for mixtures.

To cope with these possibilities, RCRA provides another set of criteria for classifying a waste as hazardous.  Whatever its composition, a waste is considered hazardous by RCRA if it exhibits any of four characteristics:

• ignitability (D001)
• corrosivity (D002)
• reactivity (D003)
• toxicity (D0xx, where xx represents two digits from 04 through 43, and denotes a specific toxic chemical)

They are discussed in greater detail below.

Note:  Even if a waste has been determined to be a listed waste, it should also be evaluated to see if it also qualifies as a characteristic waste.  Additional rules may apply to it in some cases.

Ignitability

Ignitable wastes pose hazards because they either catch fire readily themselves, or (in the case of strong oxidizers) promote fires.

A waste is considered "ignitable" under RCRA if it is:

• a liquid with flash point under 140oF, or
• a non-liquid, but susceptible to vigorous burning by friction, water absorption, or spontaneous chemical change, or
• a flammable compressed gas, or
• a strong oxidizer

(The "flash point" of a liquid is the temperature at which the vapor above a pool of liquid will catch fire under a standard set of conditions.)

Ignitable wastes commonly found in hospitals include:

• rubbing alcohol (if the alcohol concentration exceeds 24%)
  • certain mouthwashes including Listerine' fall into this category
• paregoric
• methanol
• silver nitrate
• certain topical preparations, such as
  • Cleocin T topical solution
  • Erythromycin topical solution
  • Retin A gel
  • collodion based preparations
• certain injectable materials

The regulations covering the ignitability characteristic can be found in Title 40 of the Code of Federal Regulations, Part 261, Section 21 (40 CFR 261.21).

Corrosivity

Corrosive wastes include liquids with pH less than 2 or greater than 12.5, or that corrode steel faster than a quarter-inch per year at 55oC.

Examples of corrosive wastes occurring in hospitals include concentrated solutions of acetic acid or sodium hydroxide (lye).

The regulations covering the corrosivity characteristic can be found in Title 40 of the Code of Federal Regulations, Part 261, Section 22 (40 CFR 261.22).

Reactivity

Reactive wastes include:

• materials that generate toxic gases in contact with water
• wastes that contain cyanide or sulfide and can release toxic gases in contact with strong acids or bases
• explosive materials, or materials that are explosive when heated

Reactive wastes that may be found in hospitals include:

• lithium-sulfur batteries
• dry picric acid
  • explosive when dry -- should be handled with extreme care
  • may be found in histology laboratories
  • a component of the tissue preservative Bouin's Solution
• nitroglycerin formulations (see the HERC Pharmaceuticals page for more information on nitroglycerin)
• ethylene oxide

Toxicity

The RCRA sense of toxicity is somewhat indirect.  The concern is not so much with the toxic properties of the wastes themselves as with the extent to which toxic materials can leach out of the wastes if they are exposed to water in the environment.

To measure this potential, the rules specify a test called the Toxic Characteristic Leaching Procedure, or TCLP (EPA Method ).  The test is designed to give some indication of how readily various materials would tend to leach into groundwater if the waste were placed in a landfill.  One form of the test involves subjecting the waste to a mild acetic acid solution (about the strength of household vinegar) at room temperature for 18 hours.  The solution is then tested for the presence of any of the so-called "D-listed" chemicals.  For each of the chemicals, the RCRA rules specify a threshold level (concentration).  If any of the chemicals is present in the solution at a concentration above its threshold level, the waste is considered a toxic hazardous waste.

This link will take you to the most recent available version of the complete D-list.

Examples of hospital wastes that are considered by RCRA to have the toxicity characteristic include:

• mercury
• mercury compounds, such as thimerosal, used as a preservative in vaccines
• phenylmercuric acetate
• arsenic compounds
• barium compounds
• certain compounds containing other metals, including
  • chromium
  • cadmium
  • selenium
  • silver
• chloroform
• m-cresol
• Lindane

Is it a mixture?

If a hazardous waste and a non-hazardous waste are mixed, the resulting mixture may inherit the hazardous classification.  The rules are different for listed and characteristic wastes.

• Mixing in any amount of a listed waste will cause the mixture to be considered hazardous.
• Mixing in a characteristic waste will cause the mixture to become hazardous only if the mixture itself exhibits the characteristic.

There are various exceptions and exemptions -- see, for example, the RCRA Orientation Manual listed in the More Resources section for additional information and references.

Is it derived from a hazardous waste?

Similar rules apply to wastes that are derived from listed or characteristic hazardous wastes as residues from waste treatment processes.  Since most healthcare facilities are not hazardous waste Treatment, Storage, and Disposal (TSD) sites (and thus should be sending all hazardous wastes to a licensed TSD facility), this consideration is unlikely to apply to them.

More resources

Related EPA Policy Memos

• Scope of Hazardous Waste Listing for P046 - Phentermine. Feb. 17, memorandum from EPA's Materials Recovery and Waste Management Division.
• Regulatory Status of Antineoplastic Drug Wastes. This letter is in response to a request for clarification of the status of certain antineoplastic drug wastes. The request was for an interpretation of 40 CFR 261.33, with respect to excess antineoplastic drug formulations which are not needed and thus are discarded. (4/25/).
• Definition of Solid Waste and Reclamation. A distributor of a U-listed commercial chemical product finds that the product is no longer saleable. (8/)
• MERCURY THERMOMETERS RECLAIMED OFF SPEC AND BROKEN.' This is in response to a letter dated March concerning the regulatory status of off-spec and broken mercury thermometers that are reclaimed under the Resource Conservation and Recovery Act hazardous waste rules. 4/2/.
• WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS MERCURY.' This letter is in response to a conversation and letter, both dealing with waste listings for commercial chemical products (mercury thermometers). (11/2/)
• P AND U LISTED WASTES. This letter is in response to a letter, in which someone asked for clarification of Resource Conservation and Recovery Act (RCRA) regulations as they pertain to "U" and "P" listed wastes. (4/21/)

The definition of "solid waste" appearing above can be found in the US Code.  A different definition appears in the Code of Federal Regulations 40 CFR 261.2.   The US Code contains the text of laws passed by Congress, while the Code of Federal Regulations contains the text of rules written by executive agencies. The former is the definition most frequently cited by EPA.

General Introduction

Waste from industrial processes and manufacturing operations have the potential to impact the environment, human health, and local ecosystem.

As governments and industry stakeholders continue to focus on reducing waste and promoting more sustainable manufacturing practices, more stringent requirements and regulations may be imposed.  New materials and technologies are also being developed to reduce and recapture waste and work towards a circular economy that is more sustainable. By proactively managing and working to minimize waste generated from your facility, you can reduce impacts on the environment, exposure to regulatory risks or new requirements from business partners and contribute to a more sustainable future.

In general, the Higg FEM Waste section encourages you to:

• Identify and understand the types of wastes that are generated at your facility.

• Ensure all wastes are appropriately managed onsite (e.g., storage and disposal)
• Understand how your wastes are treated/disposed of after leaving your facility.
• Track and report the quantity of wastes generated at your facility.
• Evaluate, plan for, and adopt solutions to reduce waste through better manufacturing practices, recycling/reuse, and preferred waste treatment solutions.
• Implement leading practices to divert wastes from landfill and into the circular economy.

Additional details on the intent and criteria for each Higg FEM waste question is provided in the guidance below along with useful technical guidance and resources to support your facility in the management and reduction of waste.

Waste At Your Facility

Waste is any material or substance that has no further use and is discarded from a facility which can pollute or contaminate the environment and surrounding communities. In the FEM, wastes are categorized as follows:

• Non-hazardous Waste:  is any waste that causes no harm to human or environmental health. Non-hazardous waste usually includes both non-hazardous production waste as well as domestic waste. Examples of non-hazardous waste include:
  • Non-hazardous production waste such as textile, leather, plastic, paper, metal, or packaging waste, etc.
  • Domestic waste such as food waste and sanitary wastes including household waste from the office and/or dormitory areas (e.g., toilet paper, yard/garden waste, glass, and food packaging), etc.

• Hazardous Waste: is any waste that could cause harm to public health and/or the environment because of its chemical, physical, or biological characteristics (e.g., it is flammable, explosive, toxic, radioactive, or infectious). Hazardous wastes can be liquids, solids, or gases. Examples of hazardous waste include:
  • Hazardous production waste such as used chemicals, chemical containers/drums, waste oils, contaminated materials (e.g. materials that contain other substances that are hazardous waste such as rags containing solvents), etc.
  • Waste from facility operations such as wastewater treatment sludge if hazardous, fly ash, fluorescent light bulbs, electronic waste, batteries, etc.

Note: For all companies manufacturing or distributing in or to the European Union, the WEEE (Waste from Electrical and Electronic Equipment) directive is an important directive to follow.  The WEEE directive governs the reduction and separation of electronic waste.

Reportable Wastes in the FEM

The Higg FEM requires that facilities track and report waste generation data for several specific waste categories listed below. Additional details on reporting waste quantities in the FEM are provided in the relevant questions.

Non-hazardous Wastes Hazardous Wastes

• Textile Waste
• Leather Waste
• Rubber Waste
• Metal (broken needles, metal swarf, etc.)
• Plastic
• Paper
• Cans
• Wood
• Food Waste
• Glass
• Cartons
• Foams (EVA, etc.)
• Pre-Water treatment sludge (Non-Hazardous)
• General or unspecified waste
• Slag (Non-Hazardous)
• Other

• Empty chemical drums and containers (without proper cleaning)
• Film and Printing Frame
• Pre-water treatment sludge (Hazardous)
• Expired/unused/used chemicals (waste oil, solvents, reactants, etc.)
• Compressed gas cylinders (refrigerants, etc.)
• Contaminated materials
• Batteries
• Fluorescent light bulb
• Ink cartridges
• Waste oil and grease (from cooking)
• Waste oil and grease (from production, maintenance, etc. – not cooking)
• Metal sludge
• Empty containers (cleaning, sanitizing, pesticides, etc.)
• Electronic Waste
• Coal combustion residuals (fly ash and bottom ash/coal slag)
• Slag (Hazardous)
• Other

Note: The legal classification of hazardous waste may differ from one country or jurisdiction to another. Facilities should, at minimum, follow local regulatory requirements and definitions for classifying wastes as hazardous or non-hazardous. If legal requirements do not exist, it is recommended that facilities use industry guidelines or internationally recognized definitions of hazards wastes (such as those listed in the Basel Convention http://www.basel.int/TheConvention/Overview/TextoftheConvention/tabid//Default.asp). Additionally, where industry guidelines are more stringent than local requirements, it is recommended that facilities follow industry guidelines.

Waste to be Excluded from the Higg FEM Reporting Scope:

The following waste materials should not be reported in the FEM, as these types of waste are not generated from a “business as usual” situation:

• Medical waste
• Major construction and demolition projects waste
• Waste from natural disasters such as flood, fire, tornado, hurricane.

Waste Disposal Methods in the Higg FEM

The Higg FEM requires facilities to indicate how their wastes are currently being disposed of and plans or targets for improving waste disposal methods. The FEM includes several predefined waste disposal methods that can be selected. The table below provides a description of the available waste disposal method options in the FEM. These are categorized into Preferred, Less Preferred and Least Preferred options based on their associated environmental impacts.

Waste Disposal Method Description Preferred Options (Material Recovery) Reuse Pre or post-consumer wastes are reused to make new or second hand products without modification or additional manufacturing steps before using the waste. Recycle (including Upcycle) Pre or post-consumer wastes are reprocessed to produce new items of equal (or better) quality (e.g., textile to textile recycling or processing plastic bottles into fabric). Downcycle Pre or post-consumer wastes are recycled and processed to produce material or products of lesser economic value (e.g., recycled textiles used for rags, carpet padding, or sound insulation products). Less Preferred Options (Energy Recovery or Non-valorized Disposal) Incineration with energy recovery for Non-Recyclables only Energy recovery from the process of incinerating non-recyclable waste.
Note: Recycling infrastructure and capabilities may differ among regions and countries. Energy Recovery – Residual Management (e.g., Physical / Chemical / Biological Treatment) Energy Recovery as a form of residual management, ie. Sludge Treatment that leads to Biogas Generation, heat generation from biological treatment (composting), energy generation from any such activity that does not include “Incineration” Onsite incineration without energy recovery for Non-Recyclables Incineration of non-recyclable wastes onsite at the facility that does not recover energy from the incineration process. Offsite incineration without energy recovery for Non-Recyclables Incineration of non-recyclable wastes offsite at a third-party facility that does not recover energy from the incineration process. Non-valorized disposal – Other Treatment Any disposal method that does not recover usable materials or attributes of the waste such as converting them into more useful by products like raw materials, fuels, or other sources of energy. Non-valorized disposal – Responsibly Managed Landfills (for waste that cannot be managed in any of the options under Preferred options or Less Preferred Options)

In the Higg FEM, responsibly managed landfills aligns with the ZDHC Disposal Pathways definitions for landfills with significant control measures as defined in the ZDHC Sludge Management Document Version 1.0. available here: https://www.roadmaptozero.com/output, and as described below: Landfills with Significant Control Measures are landfills that control both leachate and gas produced from the materials placed in the landfill and are engineered to store waste in a manner that is safe to the surrounding environment. For purposes of the WW Guideline, significant control measures are defined as:

• Lined landfill such that the permeability of no more than 1 x 10-7 cm/sec is achieved. This is most often achieved using a synthetic composite liner on top of a packed natural clay liner but can also be achieved through two synthetic liners.
• Leachate is collected above the liner and removed for proper treatment and disposal. Leak detection and collection is implemented beneath the primary liner and above the secondary liner.
• Gas produced from aerobic and anaerobic decomposition is collected and safely used or disposed of. This gas is primarily carbon dioxide or methane but can include sulphurous compounds. Depending on the content of the gas, carbon dioxide can be vented directly to the atmosphere or collected, filtered, and used beneficially.
• Monitoring and documentation are maintained for the life of the landfill.

Landfills with Limited Control Measures are landfill types that do not meet the description requirements specified in the Landfill with Significant Control Measures section. The permeability, leachate and gas control, and documentation are generally less restrictive. Leachate control may be non-existent or consist of simple collection and drain to local sewer lines. Gases may be vented versus stored, treated and used. Monitoring requirements for these types of landfills are less stringent – requiring less frequent sampling, inspections, and records for a shorter time depending on the local laws and regulations.

Least Preferred Options Energy Recovery (e.g., Incineration with energy recovery for Recyclables) Energy recovery from the process of incinerating of recyclable waste.
Note: Material recovery is the preferred method for recyclable wastes.
Note: Recycling infrastructure and capabilities may differ among regions and countries. Landfill/Dumping with No Control Measures In the Higg FEM, landfill/dumping with no controls aligns with the ZDHC Disposal Pathways definitions for landfills with limited or no control measures as defined in the ZDHC Sludge Management Document Version 1.0. available here: https://www.roadmaptozero.com/output, and as described below: Landfills with Limited Control Measures are landfill types that do not meet the description requirements specified in the Landfill with Significant Control Measures section. The permeability, leachate and gas control, and documentation are generally less restrictive. Leachate control may be non-existent or consist of simple collection and drain to local sewer lines. Gases may be vented versus stored, treated and used. Monitoring requirements for these types of landfills are less stringent – requiring less frequent sampling, inspections, and records for a shorter time depending on the local laws and regulations. Landfills with No Control Measures are landfills constructed with no control measures. Any landfill that has not been designed to contain waste, limit percolation, or control leachates from exposure or entering the environment is considered a landfill with no control measure. This includes dump piles and holes with no lining or packing to limit waste exposure to the ground and/or groundwater. There may be few or no monitoring requirements for these types of landfills. In many cases, these types of landfills are constructed by simply digging a hole and then filling the hole with waste, or it may consist of filling a naturally occurring depression with waste. Onsite Incineration without energy recovery for Recyclables Incineration of recyclable wastes onsite at the facility that does not recover energy from the incineration process. Offsite incineration without energy recovery for Recyclables Incineration of recyclable wastes offsite at a third-party facility that does not recover energy from the incineration process. Other Any other waste disposal method that does not fit the description of the above noted methods.
Note: A detailed description of the other methods should be provided.

Waste Data Quality

Accurately tracking and reporting waste data over time provides facilities and stakeholders with detailed insight into opportunities for improvement. If data is not accurate, this limits the ability to understand a facility’s wastes and identify the specific actions that will help reduce environmental impacts and drive efficiencies.

When establishing a waste tracking and reporting program, the following principles should be applied:

• Completeness – The tracking and reporting program should include all relevant sources (as listed in the FEM). Sources should not be excluded from data tracking and reporting should be based on materiality (e.g., small quantity exceptions).
• Accuracy – Ensure that the data input into the waste tracking program is accurate and is derived from credible sources (e.g., calibrated scales, invoices, established scientific measurement principles or engineering estimates, etc.).
• Consistency – Use consistent methodologies to track waste data that allows for comparisons of waste quantities over time. If there are any changes in the tracking methods, waste sources, or other operations that impact waste data, this should be documented.
• Transparency – All data sources (e.g., invoices, weighing records, etc.), assumptions used (e.g., estimation techniques), and calculation methodologies should be disclosed in data inventories and be readily verifiable via documented records and supporting evidence.
• Data Quality Management – Quality assurance activities (internal or external data quality checks) should be defined and performed on waste data as well as the processes used to collect and track data to ensure reported data is accurate.

• Answer Yes if: You track the quantity of all waste streams generated at your facility.
• Answer Partial Yes if: You track the quantity of at least one (1) non-hazardous waste stream generated at your facility.

Note: If your facility does not track any of its waste streams, the answer to both questions above should be No.

If you answer Yes or Partial Yes to the questions above, you will need to complete a table with the following questions to provide details on your annual non-hazardous waste generation for each waste type during the reporting year:

• Do you track this waste stream?
• Description of waste steam
• What quantity of this waste stream did you generate during the reporting year?
• Unit of Measure
• Which method was used to track this waste stream?
• How was this waste disposed of?
  • Note: If the waste stream is disposed of using more than one method, please select the method that represents how the majority of the waste stream is disposed of and provide comments in the sub questions below.
• Describe your waste management and disposal processes for this waste stream.

Suggested Uploads

• A waste inventory of all non-hazardous waste streams generated at the facility.
• Waste quantity/disposal tracking records that show the quantity of wastes disposed of in the reporting year (e.g., waste manifests, internal tracking records)
• Documentation that shows the final disposal method for each waste (e.g., contracts with waste disposal carriers or facilities)

What is the intent of the question?

The intent is to ensure facilities are aware of all non-hazardous waste types (both production and domestic waste) produced at the facility and track the quantity and disposal methods of each waste type.

Technical Guidance:

Identifying all of the facility’s waste streams and tracking waste quantities, provides facilities important information that can be used to identify opportunities to reduce waste and quantify these reductions.

Note: This guidance also generally applies to hazardous waste management covered in the Higg FEM questions related to hazardous waste.

Creating a Waste Inventory:

Developing a waste inventory is an important first step in waste management. When establishing your waste tracking and reporting program, start by doing the following:

• Determine what types of waste are generated.
• Determine where (location and processes) waste is being generated.
• Establish procedures to collect and track waste data:

• Examples include on-site scales, waste invoices/manifests, receipts for waste materials that are sold, etc.
• If estimation techniques are used to calculate the amount of waste, the methodology should be clearly defined and be supported by verifiable data.

• Record data (e.g., daily, weekly, monthly waste quantities) in a format that is easy to use and review such as Microsoft Excel

Note: Waste materials that are not generated from a “business as usual” situation should not be reported in the FEM. Examples include:

• Medical waste
• Major construction and demolition projects waste
• Waste from natural disasters such as flood, fire, tornado, hurricane.

Selecting Waste Disposal Method

The table provided in the Introduction section provides a description of the waste disposal method options that can be selected in the FEM.

Estimating Waste Quantity Data

In some cases, calculating annual waste quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that includes details on the following:

• The calculation methodology and any data or assumptions used.
• Any production volume or facility operating data used in the calculations.
• Description of any updates or changes to the calculation methodology

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 waste).

An example of how waste quantity data can be estimated is provided below:

• A facility generates waste in barrels which are sealed when full and sent weekly for disposal. Weighing every barrel may not be possible. Therefore, the average weight of a full barrel can be determined by weighing a representative sample of barrels and then multiplying this average weight by the number of barrels disposed each week or month as shown below:
  • Average weight of a barrel = 25kg (based on representative weights of barrels from different days, months, production scenarios, etc.)
  • Number of barrels disposed of in 1 month = 65
  • Total waste for this source in 1 month = 1,625kg (25kg x 65 barrels)

• Similarly, the same methodology above could be used to estimate food or sanitary waste from a canteen or dormitory by collecting representative weight measurements of the average bag or bin and then multiplying the average weight by the number of bags or bins disposed of per month.

Reporting Waste Data in the FEM

Do:

• Review source data (e.g., weighing records, invoices/manifests, etc) against aggregated totals.
• 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.
• 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.
• Review any assumption or estimation methodology/calculations to ensure accuracy.
• Verify how waste is disposed and ensure reported the disposal method (e.g., landfill, recycle, incineration) is accurate.
• Ensure waste vendors have the appropriate licenses to handle each waste type.

Do Not:

• Report data that is not accurate or if data is unknown or has not been verified.
• Report estimated data that 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 waste data, Verifiers must review all aspects of the facility’s waste tracking program that could produce inaccuracies including:

• The initial data collection processes and data sources (e.g., weighing records, manifest/invoices/receipts, etc.)
• 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:

Facilities will receive full points for completely tracking all non-hazardous waste streams generated at the facility including the quantity and the disposal method of each waste stream.

Documentation Required:

• List of all non-hazardous waste produced by the facility, including but not limited to:
  • Production Waste
  • Packaging waste
  • Domestic Waste
• Documentation that supports the reported waste quantity and final disposal destination which may include:
  • Tacking records for all non-hazardous waste quantities (e.g., invoices from waste contractors, weighing records, etc.).
  • Contracts or agreements with waste disposal carriers or facilities that indicate how waste is treated.
  • 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 wastes are able to explain the information in the waste inventory, how waste sources are identified, and waste quantities are tracked.
• Key staff should understand:
  • The procedures in place for tracking non-hazardous waste, including tracking the waste collection process, quantity measurement and type of disposal.
  • How data quality of the waste data tracking program is maintained.
  • Any estimation methodologies used to calculate annual waste quantities.

Inspection – Things to Physically Look For:

• All non-hazardous waste streams observed are properly identified and tracked.
• Appropriate equipment for waste quantity measurement if applicable.
• Collection site(s) for waste disposal.

Partial Points:

• Partial Points will be awarded if at least one (1) non-hazardous waste source is tracked in full (e.g., quantity is accurately measured, and final disposal method is known) and there is evidence to support these responses.

• Answer Yes, if you track the quantity of all hazardous waste streams generated at your facility.
• Answer Partial Yes, if you track the quantity of at least one (1) hazardous waste stream generated at your facility.

Note: If your facility does not track any of its hazardous waste streams, the answer to both questions above should be No.

If you answer Yes or Partial Yes to the questions above, you will need to complete a table with the following questions to provide details on your annual hazardous waste generation during the reporting year:

• Do you track this waste stream?
• Description of waste steam
• What quantity of this waste stream did you generate during the reporting year?
• Unit of Measure
• Which method was used to track this waste stream?
• How was this waste disposed of?
• Is this hazardous waste transporter, treatment, and disposal facility licensed and permitted?
• Upload a copy of the permit.
• Describe your waste management and disposal processes for this waste stream.

Suggested Uploads

• A waste inventory of all -hazardous waste streams generated at the facility.
• Waste quantity/disposal tracking records that show the quantity of wastes disposed of in the reporting year (e.g., waste manifests, internal tracking records)
• Documentation that shows the final disposal method for each waste (e.g., contracts with waste disposal carriers or facilities)

What is the intent of the question?

The intent is to ensure facilities are aware of all hazardous waste types produced at the facility and track the quantity and disposal methods of each waste type.

Technical Guidance:  

Identifying all of the facility’s hazardous waste streams and tracking waste quantities, provides facilities important information to ensure compliance with applicable regulations and information that can be used to identify opportunities to reduce waste and quantify these reductions.

Note: The legal classification of hazardous waste may differ from one country or jurisdiction to another. Facilities should, at minimum, follow local regulatory requirements and definitions for classifying wastes as hazardous or non-hazardous.

Reporting Hazardous Waste Data in the FEM

The guidance provided in the Technical Guidance section of Question 1 for non-hazardous wastes should be applied to hazardous waste tracking and reporting.

Estimating Waste Quantity Data

In most cases, local laws require the detailed tracking and reporting of hazardous waste quantities, however in some cases, calculating annual waste quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that includes details on the following:

• The calculation methodology and any data or assumptions used.
• Any production volume or facility operating data used in the calculations.
• Description of any updates or changes to the calculation methodology

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 waste).

An example of how waste quantity data can be estimated is provided below:

• A facility disposes of empty chemical drums or full drums (containing liquid hazardous waste) Weighing every drum may not be possible. Therefore, the average weight of an empty or full drum can be determined by weighing a representative sample of drums and then multiplying this average weight by the number of drum disposed each week or month as shown below:
  • Average weight of a drum = 20kg (based on representative weights of drums from different days, months, production scenarios, etc.)
  • Number of drums disposed of in 1 month = 10
  • Total waste for this source in 1 month = 200kg (20kg x 10 drums)

• Similarity, the same methodology above could be used to estimate other hazardous waste quantities such as printing screens or fluorescent light bulbs.

Selecting Waste Disposal Method

The table provided in the Introduction section provides a description of the waste disposal method options that can be selected in the FEM.

How This Will Be Verified:

When verifying a facility’s waste data, Verifiers must review all aspects of the facility’s waste tracking program including:

• The data collection processes and data sources (e.g., weighing records, manifest/invoices/receipts, etc.)
• 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:

Facilities will receive full points for completely tracking all hazardous waste streams generated at the facility including the quantity and the disposal method of each waste stream, and the waste is being transported and disposed of by licensed vendors.

Documentation Required:

• List of all hazardous waste produced by the facility, including but not limited to:
  • Production Waste
  • Facility Operations waste
• Documentation that supports the reported waste quantity and final disposal destination which may include:
  • Tracking records for all hazardous waste quantities (e.g., hazardous waste manifests, invoices from waste contractors, weighing records, etc.).
  • Permits for hazardous waste handling if applicable.
  • Contracts or agreements with waste disposal carriers or facilities that indicate how waste is treated.
  • 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 hazardous wastes are able to explain the information in the waste inventory, how waste sources are identified, and waste quantities are tracked.
• Key staff should understand:
  • The procedures in place for tracking hazardous waste, including tracking the waste collection process, quantity measurement and type of disposal.
  • How data quality of the waste data tracking program is maintained.
  • Any estimation methodologies used to calculate annual waste quantities.

Inspection – Things to Physically Look For:

• All hazardous waste streams observed are properly identified and tracked.
• Appropriate equipment for waste quantity measurement if applicable.
• Collection site(s) for waste disposal.

Partial Points:

• Partial Points will be awarded if at least one (1) hazardous waste source is tracked in full (e.g., quantity is accurately measured, and final disposal method is known) and there is evidence to support these responses.

Answer Yes if:  Your facility has designated hazardous waste storage areas and hazardous wastes are stored in appropriate containers.

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 hazardous waste storage areas and containers:

Hazardous waste storage areas:

• The hazardous waste storage area is ventilated, dry and protected from the weather and fire risk.
• The hazardous waste storage area is protected from unauthorized employees Eating, smoking and drinking are not permitted in these areas.
• The hazardous waste storage area is clearly marked.
• Where liquid wastes are stored, the floor is solid and non-porous, containers have lids, there are no water drains that the liquid could spill into, and there is no evidence of spilled liquid.
• Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting.
• Incompatible waste must be segregated.
• Spill response equipment including necessary personal protective equipment (PPE) must be located near storage areas including accessible emergency eyewash and/or shower stations.
• Employees must use appropriate personal protective equipment (PPE) when in these areas.
• Adequate aisle space must be maintained between containers.
• Instructions for safe handling of hazardous waste and other appropriate signage should be displayed.

Hazardous waste storage containers:

• Storage containers are in good condition, appropriate for their contents, closed and clearly labelled with their contents.
• Containers must have lids.
• Containers must be secured to prevent falling and safely stacked.

Suggested Upload: 

• Photos of hazardous waste storage areas and containers

What is the intent of the question?

The intent of this question is to ensure that hazardous waste is stored in a way that is safe for employees, the environment, and the local community.

Technical Guidance:

The proper storage of hazardous wastes 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 hazardous waste storage and implement appropriate controls practices based on the hazardous characteristics of the waste such as those listed in the sub questions.

Information on the hazardous characteristics of waste can sometimes be found in Safety Data Sheets (SDS) of the hazardous raw materials used in the processes that generate the waste. For example, if flammable cleaning solvents are used, any waste that is contaminated with these solvents will likely have the same hazardous characteristics as the solvent (i.e., the raw material used).

Facilities should refer to material SDS for important information on the storage and handling requirements and any chemical incompatibilities which can be found in Sections 8 and 10, respectively on a GHS compliant SDS. Other important information such as measures to take in the event of fire, accidental release/spill, or employee exposure can also be found on the materials SDS.

Hazardous waste storage areas should also be inspected regularly to ensure good storage and housekeeping practices are continuously implemented.

How This Will Be Verified:

Full Points:

Facilities will receive full points for having dedicated hazardous waste storage areas and implemented all the control measures listed in the sub question.

Documentation Required: 

• Documentation to support the facilities procedures to ensure that hazardous wastes are stored appropriately. This may include:
  • Procedures or work instructions for hazardous waste storage areas
  • Safety Data Sheets, if relevant to the waste material(s).
  • Hazardous waste area inspection records

Interview Questions to Ask: 

• Staff responsible for hazardous waste management handling and storage understand risks associated with the materials stored in the waste storage areas and how to properly store waste materials (which containers to use, chemical segregation, etc.)

Inspection – Things to Physically Look For: 

• On-site observations indicate that wastes are being stored in designated areas with appropriate controls.

Partial Points:

• Partial Points will be awarded to facilities that have dedicated hazardous waste storage areas and have implemented some, but not all, the control measures listed in the sub questions.

Answer Yes if:  Your facility has designated waste storage areas and wastes are stored in appropriate containers.

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 non-hazardous waste storage areas and containers:

Non-hazardous waste storage areas:

• The non-hazardous waste storage area is ventilated, dry and protected from the weather and fire risk, and must be stored on impervious surfaces.
• The non-hazardous waste storage area is clearly marked.
• Flammable substances are kept away from sources of heat or ignition, including the use of grounding and explosion-proof lighting.
• Waste must be segregated by type.
• Employees must use appropriate personal protective equipment (PPE) when in these areas.

Non-Hazardous waste storage containers:

• Storage containers are in good condition, appropriate for their contents, closed and clearly labelled with their contents.
• Containers must be secured to prevent falling and safely stacked.

Suggested Upload: 

• Photos of non-hazardous waste storage areas and containers

What is the intent of the question?

The intent of this question is to ensure that non-hazardous waste is stored in a way that is safe for employees, the environment, and the local community.

Technical Guidance:

The proper storage of hazardous wastes is important to prevent unintended contamination of other wastes, the surrounding environment and to reduce exposure risks to employees as well as the risks of fires.  Facilities should have dedicated storage areas for non-hazardous waste storage and implement appropriate control practices based on the characteristics of the waste such as those listed in the sub questions.

Non-hazardous waste storage areas should also be inspected regularly to ensure good storage and housekeeping practices are continuously implemented.

How This Will Be Verified:

Full Points:

Facilities will receive full points for having dedicated non-hazardous waste storage areas and implementing all the control measures listed in the sub question.

Documentation Required: 

• Documentation to support the facilities procedures to ensure that non-hazardous wastes are stored appropriately. This may include:
  • Procedures or work instructions for non-hazardous waste storage areas
  • Non-hazardous waste area inspection records

Interview Questions to Ask: 

• Staff responsible for non-hazardous waste management handling and storage understand risks associated with the materials stored in the waste storage areas and how to properly store waste materials (which containers to use, waste segregation, etc.)

Inspection – Things to Physically Look For: 

• On-site observations indicate that wastes are being stored in designated areas with appropriate controls.

Partial Points:

• Partial Points will be awarded to facilities that have dedicated waste storage areas and have implemented some, but not all, the control measures listed in the sub questions.

Answer Yes if:  Your facility provides awareness training to all employees on waste segregation.

Answer Partial Yes if:  Your facility provides awareness training to employees on waste segregation and this training has been provided to 50% or more, but not all employees.

Suggested Upload: 

• Records of waste segregation training.
• Copies of waste segregation training material used.
• Employee training plans or procedures that demonstrate waste segregation training is provided to all employees.

What is the intent of the question?

The intent of this question is to ensure training is provided to employees on proper waste segregation practices at the facility.

Technical Guidance:

Separating wastes into different waste streams (i.e., waste segregation) allows facilities to understand and quantify the amount of each waste type that facilities produce. This also helps identify opportunities to reduce waste and increase recycling rates which can lower waste disposal costs.

To ensure that wastes are effectively segregated it is important that all employees are trained and understand how to properly separate wastes in the workplace. In addition to providing training, it is equally as important to have the proper waste disposal facilities in place such as

colour-coding of bins and having clear and consistent signage throughout the facility to make it easy for staff to dispose of waste appropriately.

How This Will Be Verified:

Full Points:

Full Points will be awarded to facilities that provide awareness training to all employees on waste segregation.

Documentation Required:

• Documentation that demonstrates that employees are trained on waste segregation at the facility. This may include:
  • Records of waste segregation training
  • Copies of waste segregation training material used.
  • Employee training plans or procedures that demonstrate waste segregation training is provided to employees.

Interview Questions to Ask:

• Staff responsible for waste management and handling can explain the facility’s waste segregation program and how employees are trained.
• Employees throughout the facility understand the facility’s waste segregation program and have received training.

Inspection – Things to Physically Look For:

• On-site observations indicate that wastes are being separated in accordance with the facility’s waste segregation program.

Partial Points:

• Partial points will be awarded to facilities that provide awareness training to 50% or more, but not all employees on waste segregation

Answer Yes if:  Your facility provides training to all employees who handle hazardous waste and the training covers proper handling, storage and disposal, waste minimization, and the use of personal protective equipment (PPE).

Answer Partial Yes if: Your facility provides training to all employees who handle hazardous waste, but the training does not cover all of the topics listed above.

If you answer Yes or Partial Yes to this question, you will be asked the following sub questions on your training program:

• Select all topics included in your training:
  • Proper handling
  • Storage and disposal techniques and procedures
  • Specific operational procedures for waste minimization
  • Use of personal protective equipment
  • Other
• 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 hazardous waste training.
• Copies of training material used.
• Employee training plans or procedures that demonstrate hazardous training is provided to all employees who handle hazardous wastes.

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 hazardous waste on practices to minimize environmental and health risks associated with hazardous waste.

Technical Guidance:

Hazardous waste can pose significant risks to the environment and human health. Employees who handle hazardous wastes on-site should understand these risks and know how to effectively minimize, handle, and dispose of hazardous wastes. Employees should also understand how to properly protect themselves when there is risk of exposure (e.g., through the use of appropriate PPE).

How This Will Be Verified:

Full Points:

Documentation Required:

• Documentation that demonstrates that all employees who handle hazardous waste are trained on proper handling, storage and disposal, waste minimization, and the use of personal protective equipment (PPE). This may include:
  • Records of hazardous waste training.
  • Copies of training material used.
  • Employee training plans or procedures that demonstrate hazardous training is provided to all employees who handle hazardous wastes.
  • List of PPE required for handling of hazardous wastes generated at the facility.

Interview Questions to Ask:

• Staff responsible for hazardous waste management can explain the facility’s hazardous waste handling procedures and how all relevant employees are trained.
• Relevant employees understand the facility’s hazardous waste handling procedures and have received training.

Inspection – Things to Physically Look For:

• On-site observations indicate that hazardous wastes are being handled in accordance with the facility’s hazardous waste handling procedures.
• Appropriate PPE is available and being used by employees.

Partial Points:

• Partial Points will be awarded to facilities that provide training to all employees who handle hazardous waste, but the training does not cover all of the topics listed above.

Higg FEM Level ProgressionIf your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:

Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?

If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.

If you Answer No: Level 2 and 3 questions will not be available in this section.

Notes:

• If your facility did not achieve Level 1 in this section, answering  Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
• It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.

Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3

Answer Yes if:  Your Facility has set a baseline for one (1) or more of your non-hazardous waste streams.

If you answer Yes to this question, you will be asked to complete a series of tables to provide details on your non-hazardous waste baselines for each applicable waste stream (All applicable waste streams selected in the applicability questions will be pre-populated in the table):

• Complete the following questions to provide details on your non-hazardous waste baseline during this reporting year.
  • Have you set a baseline for this non-hazardous waste stream?
  • Is this a normalized or absolute baseline?

For all wastes streams that have baselines, you will be asked to complete a table with the following questions based on whether the baseline is absolute or normalized:

Note: From FEM onwards, in the above table, baseline data can be auto populated or manually entered in the following ways:

• New FEM Users: Required to manually input baseline.
• Existing FEM Users without a baseline: Facility can choose to:
  • Enter the baseline manually OR
  • Have the FEM auto populate a baseline based on the data from the previous year’s FEM.
• Existing FEM Users with an existing baseline: Baseline will auto populate based on the data from the previous year’s FEM.

Suggested Uploads:

• Documentation that supports how the baseline was established for each waste stream (e.g., waste quantity tracking and production data from the baseline year, supporting calculations or assumptions used to determine the baseline).

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established baselines for non-hazardous wastes generated at the facility so that future reduction efforts can be quantified.

Technical Guidance:

A “baseline” is a starting point or benchmark that a facility can use to compare changes over time and quantify any reduction efforts.

Baselines can be absolute or normalized. For example:

• Absolute: The total amount of waste produced over a period of time (for example, 1,500 tons per year)

• Normalized: The amount of waste produced while making a unit of product (for example, 0.15 kg per pair of shoes produced or the amount of food waste per worker).

Note: It is recommended to use the ‘Normalized’ method to account for operational fluctuations. Normalized baselines provide more accurate and useful comparisons over time.

When establishing a baseline, be sure to do the following:

• Confirm the waste source data is stable, and sufficient to be used to determine a baseline. In the Higg FEM, a baseline should generally comprise of a full calendar year’s data.

• Note: If your factory has undergone major structural or operational changes such as acquisitions, new buildings or production areas, or significant changes in production, equipment or materials used, the baseline should be reviewed and revised, if needed, after the changes have been completed.

• Determine if the baseline is Absolute or Normalized (normalized baselines are preferred).

• Verify the source data and normalizing metric data is accurate.

• Waste quantities and production volume data from previous Higg FEM verifications, internal or external audits conducted by qualified personnel are acceptable sources of data verification.

• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen normalizing metric 1,500,000 kg per 1,000,000 pieces = 1.5kg/piece)

• Note: For waste sources that is not related to production, other normalizing metrics should be used where appropriate (e.g., food or other domestic wastes can be normalized per meal served or per worker)

• • Hardgoods guidance: For hardgoods production, normalizing metrics per product piece, or per kg of product may be relevant.

Note: If the baseline is used to evaluate performance against a target, the baseline should remain unchanged.

Reporting baseline data in the Higg FEM:

Do:

• Review source data and raw normalizing metric data (manifests/invoices, weighing records, production quantity, etc.) against aggregated totals to ensure they are accurate.
• Select the appropriate baseline type in the FEM – Absolute or Normalized.
• Ensure the proper units are reported and verify any unit conversions from source data to reported data (e.g., converting kg to tons).
• Enter the baseline year. This is the year the baseline data represents.
• Provide sufficient details on how the baseline was calculated (e.g., waste quantity is normalized per meter of fabric produced or per kg of product).
• Only select ‘Yes’ to the question “Was the baseline verified?” if the baseline data was fully verified in a previous Higg FEM verification or by an internal or external audit conducted by qualified personnel.

Do Not:

• Report inaccurate data (including if the data has not been verified).
• Report a baseline that is based on insufficient data (e.g., not a full year’s data).
• Report an estimated baseline if it is not supported by verifiable and accurate estimation methodology and data.

How This Will Be Verified:

When verifying a facility’s baselines, Verifiers must review:

• Source data (e.g., manifests, invoices, weighing records, production quantities, etc.) and aggregated data totals for the baseline year.
• Records of baseline data verification where available (e.g., previous Higg Verification, data quality review, internal or external audits, 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 if the facility has established baselines for all non-hazardous waste streams.

Documentation Required:

• Documentation that supports how the baseline was established for each waste stream. This may include:
  • Waste quantity tracking and production data from the baseline year
  • Supporting calculations methodologies or assumptions used to determine the baseline.

• Supporting evidence to demonstrate how baseline data was validated (e.g., verified Higg FEM data for the baseline year, external or internal data validation process or report).

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the baselines were determined including any normalizing metrics used or any assumption made in the calculation methodology.
• Relevant staff are able to describe the facility’s process to validate the accuracy of baseline data.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are consistent with the facility’s reported methods for determining baselines (e.g., weighing of wastes if applicable, waste segregation, etc.)
• Observations on-site do not indicate that there have been significant changes at the facility that could impact the appropriateness of the baseline (e.g., new production areas, changes to products, new buildings, etc.)

Partial Points:

• Partial points will be awarded if the facility has established baselines for one (1) or more non-hazardous waste stream.

Answer Yes if:  Your Facility has set a baseline for one (1) or more of your hazardous waste streams.

If you answer Yes to this question, you will be asked to complete a series of tables to provide details on your hazardous waste baselines for each applicable waste stream (All applicable waste streams selected in the applicability questions will be pre-populated in the table):

• Complete the following questions to provide details on your hazardous waste baseline during this reporting year.
  • Have you set a baseline for this hazardous waste stream?
  • Is this a normalized or absolute baseline?

For all wastes streams that have baselines, you will be asked to complete a table with the following questions based on whether the baseline is absolute or normalized:

Note: From FEM onwards, in the above table, baseline data can be auto populated or manually entered in the following ways:

• New FEM Users: Required to manually input baseline.
• Existing FEM Users without a baseline: Facility can choose to:
  • Enter the baseline manually OR
  • Have the FEM auto populate a baseline based on the data from the previous year’s FEM.
• Existing FEM Users with an existing baseline: Baseline will auto populate based on the data from the previous year’s FEM.

Suggested Uploads:

• Documentation that supports how the baseline was established for each waste stream (e.g., waste quantity tracking and production data from the baseline year, supporting calculations or assumptions used to determine the baseline).

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established baselines for hazardous wastes generated at the facility so that future reduction efforts can be quantified.

Technical Guidance:

A “baseline” is a starting point or benchmark that a facility can use to compare changes over time and quantify any reduction efforts.

Baselines can be absolute or normalized. For example:

• Absolute: The total amount of waste produced over a period of time (for example, 1,500 tons per year)

• Normalized: The amount of waste produced while making a unit of product (for example, 0.15 kg per pair of shoes produced).

Note: It is recommended to use the ‘Normalized’ method to account for operational fluctuations. Normalized baselines provide more accurate and useful comparisons over time.

When establishing a baseline, be sure to do the following:

• Confirm the waste source data is stable, and sufficient to be used to determine a baseline. In the Higg FEM, a baseline should generally comprise of a full calendar year’s data.

• Note: If your factory has undergone major structural or operational changes such as acquisitions, new buildings or production areas, or significant changes in production, equipment or materials used, the baseline should be reviewed and revised, if needed, after the changes have been completed.

• Determine if the baseline is Absolute or Normalized (normalized baselines are preferred).

• Verify the source data and normalizing metric data is accurate.

• Waste quantities and production volume data from previous Higg FEM verifications, internal or external audits conducted by qualified personnel are acceptable sources of data verification.

• Apply the appropriate baseline metric (i.e., per year for absolute OR divide by the chosen normalizing metric 1,500,000 kg per 1,000,000 pieces = 1.5kg/piece)

• Note: For waste sources that are not related to production, other normalizing metrics should be used where appropriate.

Note: If the baseline is used to evaluate performance against a target, the baseline should remain unchanged.

Reporting baseline data in the Higg FEM:

Do:

• Review source data and raw normalizing metric data (manifests/invoices, weighing records, production quantity, etc.) against aggregated totals to ensure they are accurate.
• Select the appropriate baseline type in the FEM – Absolute or Normalized.
• Ensure the proper units are reported and verify any unit conversions from source data to reported data (e.g., converting kg to tons).
• Enter the baseline year. This is the year the baseline data represents.
• Provide sufficient details on how the baseline was calculated (e.g., waste quantity is normalized per meter of fabric produced or per kg of product).
• Only select ‘Yes’ to the question “Was the baseline verified?” if the baseline data was fully verified in a previous Higg FEM verification or by an internal or external audit conducted by qualified personnel.

Do Not:

• Report inaccurate data (including if the data has not been verified).
• Report a baseline that is based on insufficient data (e.g., not a full year’s data).
• Report an estimated baseline if it is not supported by verifiable and accurate estimation methodology and data.

How This Will Be Verified:

When verifying a facility’s baselines, Verifiers must review:

• Source data (e.g., manifests, invoices, weighing records, production quantities, etc.) and aggregated data totals for the baseline year.
• Records of baseline data verification where available (e.g., previous Higg Verification, data quality review, internal or external audits, 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.

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Full Points:

Full Points will be awarded if the facility has established baselines for all hazardous waste streams.

Documentation Required:

• Documentation that supports how the baseline was established for each waste stream. This may include:
  • Waste quantity tracking and production data from the baseline year.
  • Supporting calculations methodologies or assumptions used to determine the baseline.

• Supporting evidence to demonstrate how baseline data was validated (e.g., verified Higg FEM data for the baseline year, external or internal data validation process or report).

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the baselines were determined including any normalizing metrics used or any assumption made in the calculation methodology.
• Relevant staff are able to describe the facility’s process to validate the accuracy of baseline data.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are consistent with the facility’s reported methods for determining baselines (e.g., weighing of wastes if applicable, waste segregation, etc.)
• Observations on-site do not indicate that there have been significant changes at the facility that could impact the appropriateness of the baseline (e.g., new production areas, changes to products, new buildings, etc.)

Partial Points:

• Partial points will be awarded if the facility has established baselines for one (1) or more hazardous waste stream.

Answer Yes if:  Your Facility has set a baseline for one (1) or more of your waste disposal methods.

If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your waste disposal method baselines for each applicable method:

• Have you set a baseline for this method?
• What is the baseline quantity?
• Unit of Measure.
• Enter baseline year.
• How was your baseline calculated?
• Was the baseline verified?
• Provide any additional comments.

Note: From FEM onwards, in the above table, baseline data can be auto populated or manually entered in the following ways:

• New FEM Users: Required to manually input baseline.
• Existing FEM Users without a baseline: Facility can choose to:
  • Enter the baseline manually OR
  • Have the FEM auto populate a baseline based on the data from the previous year’s FEM.
• Existing FEM Users with an existing baseline: Baseline will auto populate based on the data from the previous year’s FEM.

Suggested Uploads:

• Documentation that supports how the baseline was established for each waste disposal method (e.g., waste disposal and quantity tracking data from the baseline year, supporting calculations or assumptions used to determine the baseline).

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established baselines for waste disposal methods for facility wastes so that future improvement efforts can be quantified.

Technical Guidance:

A “baseline” is a starting point or benchmark that a facility can use to compare changes over time and quantify any improvement efforts. Waste disposal method baselines are different from the waste source baselines. Disposal methods baselines focus on the percentage of total facility wastes being disposed of by a specific method (e.g., 60% of all waste generated at the facility is disposed of by landfill with significant controls or 40% sent for recycling).

When establishing a baseline, be sure to do the following:

• Confirm the waste disposal method data is stable, and sufficient to be used to determine a baseline. In the Higg FEM, a baseline should generally comprise of a full calendar year’s data.

• Note: If your factory has undergone major structural or operational changes such as acquisitions, new buildings or production areas, or significant changes in production, equipment or materials used, the baseline should be reviewed and revised, if needed, after the changes have been completed.

• Calculate the total amount of waste generated at the facility (from all sources) including hazardous and non-hazardous sources.
• Calculate the total amount of wastes being disposed of using a particular disposal method (e.g., landfill, recycling, incineration)
• Divide the total amount of waste disposed of using the same method by the total amount of waste generated. For example:
  • Total waste generated from all sources: 460,555 kg per year.
  • Baseline quantity of waste recycled: 255,000kg/year.
  • Baseline percentage of recycled waste: 55.3% (255,000kg/460,555kg)
• Verify the baseline data accuracy.
  • Waste disposal method data from previous Higg FEM verifications, internal or external audits conducted by qualified personnel are acceptable sources of data verification.

Note: If the baseline is used to evaluate performance against a target, the baseline should remain unchanged.

Reporting baseline data in the Higg FEM:

Do:

• Review source data (manifests/invoices, weighing or disposal records, etc.) against aggregated totals to ensure they are accurate.
• Ensure the proper units are reported and verify any unit conversions from source data to reported data (e.g., converting kg to tons).
• Enter the baseline year. This is the year the baseline data represents.
• Provide sufficient details on how the baseline was calculated.
• Only select ‘Yes’ to the question “Was the baseline verified?” if the baseline data was fully verified in a previous Higg FEM verification or by an internal or external audit conducted by qualified personnel.

Do Not:

• Report inaccurate data (including if the data has not been verified).
• Report a baseline that is based on insufficient data (e.g., not a full year’s data).
• Report an estimated baseline if it is not supported by verifiable and accurate estimation methodology and data.

How This Will Be Verified:

When verifying a facility’s baselines, Verifiers must review:

• Source data (e.g., manifests, invoices, weighing or disposal records, etc.) and aggregated data totals for the baseline year.
• Records of baseline data verification where available (e.g., previous Higg Verification, data quality review, internal or external audits, 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 if the facility has established baselines for one (1) or more waste disposal methods.

Documentation Required:

• Documentation that supports how the baseline was established for each waste disposal method. This may include:
  • Waste quantity tracking and total quantities of waste for each disposal method from the baseline year.
  • Supporting calculations methodologies or assumptions used to determine the baseline.

• Supporting evidence to demonstrate how baseline data was validated (e.g., verified Higg FEM data for the baseline year, external or internal data validation process or report).

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the baselines were determined including any assumption made in the calculation methodology.
• Relevant staff are able to describe the facility’s process to validate the accuracy of baseline data.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are consistent with the facility’s reported methods for determining baselines (e.g., weighing of wastes if applicable, waste segregation, etc.)
• Observations on-site do not indicate that there have been significant changes at the facility that could impact the appropriateness of the baseline (e.g., new production areas, changes to products, new buildings, etc.)

Partial Points: N/A

Answer Yes if:  Your Facility has set a target to reduce waste generation for one (1) or more of your non-hazardous waste streams.

Note: If your facility has not conducted a formal evaluation of waste reduction opportunities and calculated how much waste can be reduced to support your target, you should select No for this question.

If you answer Yes to this question, you will be asked to complete a series of tables with the following questions to provide details on your non-hazardous waste targets for each applicable waste stream:

• Does your facility set formal targets to reduce non-hazardous waste generation?
  • Have you set a target for this non-hazardous waste?
  • Is this a normalized or absolute target?

For all wastes streams that have targets, you will be asked to complete a table with the following questions based on whether the target is absolute or normalized:

Suggested Uploads:

• Documentation that supports how the target was established and demonstrates the target is based on a formal evaluation of improvement opportunities (e.g., calculations, waste quantity data and baselines, new/proposed equipment specifications or work practices, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established formal targets to reduce non-hazardous wastes generated at the facility.

Technical Guidance:

Targets can use absolute or normalized metrics to drive quantifiable improvements by a set date compared to the baseline. For Higg FEM, reduction targets may be normalized to the production volume unit or another appropriate operational metric. A normalized target shows you when progress is real, rather than being a result of business changes such as reductions in production. An example of a normalized target is kilograms (kg) of a waste generated for the production of one unit of sellable product (kg/unit).

When establishing formal improvement targets, be sure to do the following:

• Base the target on a formal evaluation of improvement opportunities and actions (e.g., change of raw materials/packaging, process modifications or equipment replacement) to calculate the amount of waste that can be reduced.
  • For example: Setting a target based on an evaluation of the purchase of laser cutting machines that is expected to reduce fabric or metal waste by 15% per meter of fabric or metal that was calculated based on a formal review of equipment specifications and planned operations.
• Define the exact target quantity, expressed as a percent (e.g., reduce normalized fabric waste per piece by 5%). This must be based on a formal evaluation as noted above.
• Determine if the target will be Absolute or Normalized to a production or operating metric.
• Define the start date (i.e., “baseline”) of the target.
• Define the end date of the target, meaning the intended completion date of the required improvements.
• Define the appropriate measurement units.
• Establish procedures to review the target. This review should include an evaluation of the actions taken and progress on reaching the defined target. Quarterly reviews are recommended.
• Ensure the target is relevant to reducing the site’s waste (e.g., focuses on the most significant waste sources at the site)

Reporting Targets in the Higg FEM:

Do:

• Review the target to ensure all aspects noted above are covered and that the information is accurate.
• Enter the targeted reduction as a percentage. Make sure to enter a negative percentage for a reduction target (e.g., -5 for a 5% reduction)
• Provide sufficient details on how the target will be met in the “Describe the measures planned to achieve this target:” field (e.g., Achieve a 3% reduction in normalized cardboard waste generated by switching to reusable cartons for raw material deliveries).

Do Not:

• Report a target that is not accurate (e.g., the data source is unknown or has not been verified)
• Report a target that is based on insufficient data. (e.g., a reduction target that is not based on a formal evaluation of options such as process/equipment modifications or change of materials used to meet the stated target OR actions to meet the target have not been defined.)
• Report an estimated target if it is not supported by verifiable and accurate estimation methodology and data (e.g., engineering calculations).

How This Will Be Verified:

When verifying a facility’s targets, Verifiers must review:

• All supporting evidence (e.g., calculations, waste quantity data and baselines, new/proposed equipment specifications, etc) to verify target is based on a formal evaluation of improvement opportunities.
• Facility operations in relation to its waste sources to ensure targets and opportunities evaluated are relevant to the site’s wastes.

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 if the facility has established targets for all waste streams and the targets cover greater than 90% (by total waste quantity) of all non-hazardous wastes generated at the facility.

Documentation Required:

• Documentation that supports how the target was established for each waste stream and is based on a formal evaluation of reduction opportunities. This may include:
  • Waste quantity tracking and production data.
  • Documented evaluations of new/proposed equipment specifications, modifications to production processes or work practices that will result in waste reduction.
  • Supporting calculations methodologies or assumptions used to determine the target.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the targets were determined including any calculations or assumptions made in the target setting methodology.
• Relevant staff are able to describe the facility’s proposed actions to achieve the target and how progress is monitored and tracked.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are appropriate in relation to the established targets (e.g., tracking of waste quantity if applicable, waste segregation, etc.)

Partial Points:

• Partial points will be awarded if the facility has established targets for one (1) or more waste streams and the targets cover 50% to 89% (by total waste quantity) of all non-hazardous wastes generated at the facility.

Answer Yes if:  Your Facility has set a target to reduce hazardous waste generation for one (1) or more of your hazardous waste streams.

Note: If your facility has not conducted a formal evaluation of waste reduction opportunities and calculated how much waste can be reduced to support your target, you should select No for this question.

If you answer Yes to this question, you will be asked to complete a series of tables with the following questions to provide details on your hazardous waste targets for each applicable waste stream:

• Does your facility set formal targets to reduce hazardous waste generation?
  • Have you set a target for this hazardous waste?
  • Is this a normalized or absolute target?

For all wastes streams that have targets, you will be asked to complete a table with the following questions based on whether the target is absolute or normalized:

Suggested Uploads:

• Documentation that supports how the target was established and demonstrates the target is based on a formal evaluation of improvement opportunities (e.g., calculations, waste quantity data and baselines, new/proposed equipment specifications or work practices, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established formal targets to reduce hazardous wastes generated at the facility.

Technical Guidance:

Targets can use absolute or normalized metrics to drive quantifiable improvements by a set date compared to the baseline. For Higg FEM, reduction targets may be normalized to the production volume unit or another appropriate operational metric. A normalized target shows you when progress is real, rather than being a result of business changes such as reductions in production. An example of a normalized target is kilograms (kg) of a waste generated for the production of one unit of sellable product (kg/unit).

When establishing formal improvement targets, be sure to do the following:

• Base the target on a formal evaluation of improvement opportunities and actions (e.g., process modifications or equipment replacement) to calculate the amount of waste that can be reduced.
  • For example: Setting a target based on an evaluation of the purchase of automated printing machines that is expected to reduce chemical waste by 15% per unit of production that was calculated based on a formal review of equipment specifications and planned operations. OR
  • Setting a target based on an evaluation of the substitution with water-based solvents to reduce solvent usage and thereby hazardous waste generation by 10%; calculated based on a formal review of equipment specifications and planned operations.
• Define the exact target quantity, expressed as a percent (e.g., reduce normalized chemical waste per piece by 5%). This must be based on a formal evaluation as noted above.
• Determine if the target will be Absolute or Normalized to a production or operating metric.
• Define the start date (i.e., “baseline”) of the target.
• Define the end date of the target, meaning the intended completion date of the required improvements.
• Define the appropriate measurement units.
• Establish procedures to review the target. This review should include an evaluation of the actions taken and progress on reaching the defined target. Quarterly reviews are recommended.
• Ensure the target is relevant to reducing the site’s waste (e.g., focuses on the most significant waste sources at the site)

Reporting Targets in the Higg FEM:

Do:

• Review the target to ensure all aspects noted above are covered and that the information is accurate.
• Enter the targeted reduction as a percentage. Make sure to enter a negative percentage for a reduction target (e.g., -5 for a 5% reduction)
• Provide sufficient details on how the target will be met in the “Describe the measures planned to achieve this target:” field (e.g., Achieve a 10% reduction in normalized chemical waste generated by switching laser finishing for denim instead of potassium permanganate spray).

Do Not:

• Report a target that is not accurate (e.g., the data source is unknown or has not been verified)
• Report a target that is based on insufficient data. (e.g., a reduction target that is not based on a formal evaluation of options such as process/equipment modifications or change of materials used to meet the stated target OR actions to meet the target have not been defined.)
• Report an estimated target if it is not supported by verifiable and accurate estimation methodology and data (e.g., engineering calculations).

How This Will Be Verified:

When verifying a facility’s targets, Verifiers must review:

• All supporting evidence (e.g., calculations, waste quantity data and baselines, new/proposed equipment specifications, etc) to verify target is based on a formal evaluation of improvement opportunities.
• Facility operations in relation to its waste sources to ensure targets and opportunities evaluated are relevant to the site’s wastes.

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 if the facility has established targets that cover greater than 90% (by total waste quantity) of all hazardous wastes generated at the facility.

Documentation Required:

• Documentation that supports how the target was established for each waste stream and is based on a formal evaluation of reduction opportunities. This may include:
  • Waste quantity tracking and production data.
  • Documented evaluations of new/proposed equipment specifications, modifications to production processes or work practices that will result in waste reduction.
  • Supporting calculations methodologies or assumptions used to determine the target.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the targets were determined including any calculations or assumptions made in the target setting methodology.
• Relevant staff are able to describe the facility’s proposed actions to achieve the target and how progress is monitored and tracked.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are appropriate in relation to the established targets (e.g., tracking of waste quantity if applicable, waste segregation, etc.)

Partial Points:

• Partial points will be awarded if the facility has established targets that cover 50% to 89% (by total waste quantity) of all hazardous wastes generated at the facility.

Answer Yes if:  If your Facility has set a formal target to improve the waste disposal methods used by your facility.

Answer Not Applicable if: Your facility disposes of all wastes using the preferred methods of waste disposal. These are: reuse, recycle (including upcycle) or downcycle.

Note: If your facility has not conducted a formal evaluation of waste disposal improvement opportunities to support your target, you should select No for this question.

If you answer Yes to this question, you will be asked to complete a series of tables with the following questions to provide details on your waste disposal method targets:

• Have you set a target to switch from this waste disposal method?
• Which waste disposal method under Preferred or Less Preferred options your facility will switch to?
• What is your target for change (in %) in improving this disposal method? (Enter negative for reduction target ; Enter positive for increasing target)
• Enter the target year.
• Describe the measures planned to achieve this target:
• Provide any additional comments.

Suggested Uploads:

• Documentation that supports how the target was established and demonstrates the target is based on a formal evaluation of improvement opportunities (e.g., review of local waste disposal options, waste quantity data and baselines, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established formal targets to improve the waste disposal method for wastes generated at the facility.

Technical Guidance:

Minimizing the environmental impact of waste can be achieved by using a disposal method results in less environmental impact. Examples of improvements to disposal methods can include:

• Increasing the quantity of waste sent to external recycling contractors and biological treatment (e.g., non-hazardous production waste recycling and food waste biological treatment) to divert waste from landfill or incineration without energy recovery.
• Switching to a disposal/treatment method that recovers usable aspects of the waste (e.g., using incineration with energy recovery as opposed to landfilling)

Note: Improving waste disposal methods will often require collaboration with waste treatment vendors to evaluate which preferred disposal methods are available.

When evaluating opportunities to improve waste disposal or treatment methods the list of Preferred and Less Preferred methods listed in the Introduction section of this guidance can be referenced to evaluate which options are likely to reduce environmental impacts.

When establishing formal improvement targets, be sure to do the following:

• Base the target on a formal evaluation of improvement opportunities and actions (e.g., a review of the available disposal alternatives with waste treatment vendors) to calculate the amount and types of wastes that can be treated by the preferred method.
  • For example: Setting a target based on an evaluation of sending all fabric and plastic packaging to a recycling vendor as opposed to sending it to landfill is expected to result in a 25% increase in waste sent for recycling. OR
  • Setting a target to send metal sludge to recycling as opposed to landfill, resulting in a 10% increase in waste sent for recycling.
  • Note: It should be confirmed that the vendor is able to recycle the materials and has applicable technology and operating permits to do so.
• Define the exact target quantity, expressed as a percent (e.g., Increase waste treated by incineration with energy recovery by 15%). This must be based on a formal evaluation as noted above.
• Define the start date (i.e., “baseline”) of the target.
• Define the end date of the target, meaning the intended completion date of the required improvements.
• Establish procedures to review the target. This review should include an evaluation of the actions taken and progress on reaching the defined target. Quarterly reviews are recommended.
• Ensure the target is relevant to improving the facility’s waste disposal methods (e.g., new disposal methods result in less environmental impact)

Reporting Targets in the Higg FEM:

Do:

• Review the target to ensure all aspects noted above are covered and that the information is accurate.
• Enter the targeted reduction as a percentage. Make sure to enter a negative percentage for a reduction target (e.g. -5 for a 5% decrease in disposal method), and a positive percentage for an increased target (e.g. 5 for a 5% increase in disposal method)
• Provide sufficient details on how the target will be met in the “Describe the measures planned to achieve this target:” field (e.g. Achieve a 10% increase in waste being recycled by sending fabric scrap to a verified fibre recycling vendor).

Do Not:

• Report a target that is not accurate (e.g., the data source is unknown or has not been verified)
• Report a target that is based on insufficient data. (e.g., a reduction target that is not based on a formal evaluation of options such as new waste treatment vendors OR actions to meet the target have not been defined.)
• Report an estimated target if it is not supported by verifiable and accurate estimation methodology and data (e.g., engineering calculations).

How This Will Be Verified:

When verifying a facility’s targets, Verifiers must review:

• All supporting evidence (e.g., calculations, waste quantity data and baselines, new/proposed waste treatment methods, etc) to verify the target is based on a formal evaluation of improvement opportunities.
• Facility operations in relation to its waste disposal to ensure targets and opportunities evaluated are relevant to the site’s wastes.

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 if the facility has established targets to improve one (1) or more of its waste disposal methods.

If the criteria for Not Applicable is met, meaning the facility disposes of all wastes using preferred disposal methods, full points will be awarded for this question.

Documentation Required:

• Documentation that supports how the target was established for each waste disposal method and is based on a formal evaluation of improvement opportunities. This may include:
  • Waste quantity tracking and production data.
  • Documented evaluations of new/proposed waste treatment methods (e.g. waste vendor capacity evaluations).
  • Supporting calculations methodologies or assumptions used to determine the target.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the targets were determined including any calculations or assumptions made in the target setting methodology.
• Relevant staff are able to describe the facility’s proposed actions to achieve the target and how progress is monitored and tracked.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are appropriate in relation to the established targets (e.g., tracking of waste quantity if applicable, waste segregation, etc.)

Partial Points: N/A

Answer Yes if:  Your facility has a current documented plan and are working on all defined actions in the plan to switch one of the Preferred or Less Preferred waste disposal methods listed in the Higg FEM.

Answer Partial Yes if: Your facility has a documented plan in place with defined actions and has started work on at least one (1), but not all of the listed actions in the plan.

Answer Not Applicable if: Your facility disposes of all wastes using the preferred methods of waste disposal.

Note: If your facility has not conducted a formal evaluation of waste disposal improvement opportunities to support your plan, you should select No for this question.

If you answer Yes or Partial Yes to this question, you will be asked to upload a copy of your plan.

Suggested Uploads:

• Documentation that supports how the plan was established and demonstrates the plan is based on a formal evaluation of improvement opportunities (e.g., review of local waste disposal options, waste quantity data and baselines, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have established formal plans to improve the waste disposal method for wastes generated at the facility.

Technical Guidance

Creating an implementation plan includes the process of reviewing and evaluating available options to switch to a more preferred method of waste disposal. The key steps of creating an implementation plan should include the following:

• Identify available options for switching waste disposal methods through engaging with waste service providers or other parties that may be able to utilize waste generated at the facility (e.g., recyclers, other industry that could utilize waste materials)
• Evaluate available options to determine the most suitable options (e.g., feasibility studies, cost benefit analyses)
• Approve funds/budget for chosen options.
• Create a timeline and define the actions needed to switch the waste disposal method (e.g., additional segregation or onsite waste processes measures)

Resources:

A link to an implementation plan template that can be used is provided below:

• Implementation plan template: https://howtohigg.org/resources/resources-library/#templates

How This Will Be Verified:

Full Points:

Full Points will be awarded if the facility has an implementation and has started work on all the action items listed in the plan.

Documentation Required:

• An implementation plan that includes details of the specific actions the facility plans to take to switch to a preferred disposal method. This may include:
  • Documentation of the calculated waste volume that will be switched to the preferred disposal method.
  • Supporting documentation that confirms the waste will be disposed of or treated with a preferred treatment method (e.g., evaluation report or proposal/agreement with third party who will accept and treat or utilize the waste, if available).
  • Implementation timelines (i.e., the planned start and completion dates for actions listed in the plan).

Note: If the facility has completed all actions in the plan prior to reporting year and does not have an implementation plan switching to a preferred waste disposal method in the reporting year and beyond, a No response should be selected (i.e., points are not awarded for historical plans that were implemented prior to the reporting year).

Interview Questions to Ask:

• Staff responsible for the implementation plan can explain the facility’s process for evaluating waste disposal opportunities and the facility’s implementation plan to switch to a preferred waste disposal method.

Inspection – Things to Physically Look For:

• The actions listed in the implementation plans directly relate to the observed waste sources at the facility.

Partial Points: 

• Partial Points will be awarded if the facility has an implementation plan that meets the above requirements and has started work on at least one (1), but not all of the listed actions in the plan.

Answer Yes if:  Your Facility has reduced non-hazardous waste generation for one (1) or more of your non-hazardous waste streams compared with your baseline.

Note: Reductions in waste quantity generated due to reductions in production volume should not be considered reductions in waste generation as time as this will not result in sustainable improvements.

If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your non-hazardous waste reductions for each applicable waste stream:

• This is your reported baseline quantity.
• This is your reported unit of measure.
• This is your reported baseline year.
• Note: The above data will be auto-populated in the table based on your reported baseline data.
• Has your facility reduced waste generation for this stream compared with its baseline?
• What is your achievement for change (in %) in non-hazardous waste reduction from this stream compared to its baseline? (Enter negative for reduction %)
• Describe the strategies used to achieve this improvement.

Suggested Uploads:

• Documentation that supports a reduction in waste generation was achieved and that the reduction was related to specific actions taken by the facility to reduce waste (e.g., waste quantity data and baselines, evidence of process modifications, new equipment or work practices that resulted in waste reduction).

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have reduced the quantity of non-hazardous waste generated.

Technical Guidance:

Waste reductions can be absolute or normalized. However, it is recommended that you show normalized reductions (e.g., kg of waste per product was reduced by 50%). This is because normalized metrics data often provides a better indication of actual reductions whereas absolute improvements can be impacted by factors beyond the facility’s control such as reductions related to business changes or reduced production.

When evaluating your waste reductions, be sure to do the following:

• Review the waste data to ensure the data and any automated calculations are accurate.
• Review the actions taken to make improvements and determine if they have resulted in measurable improvements by comparing the data with historical waste data to determine the improvement quantity. Note: Historical data accuracy should also be verified.
  • For example: The installation of 5 laser cutting machines produced a reduction of 0.02kg of fabric waste per unit made, which is an 8% reduction from the baseline waste data, OR
  • The installation of a CAD system that reduced the metal waste by 5% compared to the baseline data.

Reporting Improvements in the Higg FEM:

Do:

• Review the improvement data to ensure all aspects noted above are covered and that the information is accurate.
• Input the percent (%) change in the waste quantity from the baseline year. (e.g., -5 for a 5% reduction)
• Provide sufficient details in the “Describe the strategies used to achieve this improvement:” field (e.g., Normalized waste generation was reduced by switching to reusable packaging containers for raw materials).

Do Not:

• Report improvements that are not accurate (e.g., the data source is unknown or has not been verified)
• Report an improvement that is absolute and relates to a decrease in production or reduced facility operations. This is why data normalization is important.
• Report an improvement that is based on insufficient data. (e.g., an overall reduction was achieved but this was not related to measurable or defined actions taken to achieve the reduction). This is particularly important when the improvements are marginal (e.g., less than 1-2%) and possibly attributable to measurement/ tracking errors and/or operational variability.

How This Will Be Verified:

When verifying a facility’s improvements, Verifiers must review:

• All supporting evidence (e.g., waste quantity data and baselines, etc.) to verify the reported improvement quantity is accurate and attributable to measurable actions taken to reduce waste.
• The implemented changes or actions taken to achieve the improvements.

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 if the facility has achieved reductions from the baseline quantity and achieved year over year reductions for all waste streams.

Note: Points are automatically calculated in the Higg FEM and awarded for a reduction of any amount (i.e., scoring is not based on the amount of the reduction achieved).

Documentation Required:

• Documentation that demonstrates reductions were achieved for each applicable waste stream and result from specific actions taken by the facility to reduce waste. This may include:
  • Waste tracking reports and quantity records showing reductions of waste generated.
  • Documented evidence of facility actions to reduce waste (e.g., evidence of process modifications, new equipment or work practices that resulted in waste reduction).
  • Supporting calculations methodologies or assumptions used to determine the reduction.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how reductions were achieved including any calculations or assumptions made determining the reductions.

Inspection – Things to Physically Look For:

• Onsite observations that indicate the facility has implemented the noted actions to reduce waste (e.g., process modifications, new equipment or work practices).

Partial Points: 

Partial Points will be awarded if the facility has achieved reductions from the baseline quantity or achieved year over year reductions for one (1) or more waste streams.

Answer Yes if:  Your Facility has reduced hazardous waste generation for one (1) or more of your hazardous waste streams compared with your baseline.

Note: Reductions in waste quantity generated due to reductions in production volume should not be considered reductions in waste generation as time as this will not result in sustainable improvements.

If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your hazardous waste reductions for each applicable waste stream:

• This is your reported baseline quantity.
• This is your reported unit of measure.
• This is your reported baseline year.
• Note: The above data will be auto-populated in the table based on your reported baseline data.
• Has your facility reduced waste generation for this stream compared with its baseline?
• What is your achievement for change (in %) in hazardous waste reduction from this stream compared to its baseline? (Enter negative for reduction %)
• Describe the strategies used to achieve this improvement.

Suggested Uploads:

• Documentation that supports a reduction in waste generation was achieved and that the reduction was related to specific actions taken by the facility to reduce waste (e.g., waste quantity data and baselines, evidence of process modifications, new equipment or work practices that resulted in waste reduction).

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have reduced the quantity of hazardous waste generated.

Technical Guidance:

Waste reductions can be absolute or normalized. However, it is recommended that you show normalized reductions (e.g., kg of waste per product was reduced by 50%). This is because normalized metrics data often provides a better indication of actual reductions whereas absolute improvements can be impacted by factors beyond the facility’s control such as reductions related to business changes or reduced production.

When evaluating your waste reductions, be sure to do the following:

• Review the waste data to ensure the data and any automated calculations are accurate.
• Review the actions taken to make improvements and determine if they have resulted in measurable improvements by comparing the data with historical waste data to determine the improvement quantity. Note: Historical data accuracy should also be verified.
  • For example: The installation of automated printing machines reduced chemical waste by 15% per unit of production from the baseline waste data.

Reporting Improvements in the Higg FEM:

Do:

• Review the improvement data to ensure all aspects noted above are covered and that the information is accurate.
• Input the percent (%) change in the waste quantity from the baseline year. (e.g., -5 for a 5% reduction)
• Provide sufficient details in the “Describe the strategies used to achieve this improvement:” field (e.g., Normalized waste generation was reduced by switching to laser finishing for denim from potassium permanganate spraying).

Do Not:

• Report improvements that are not accurate (e.g., the data source is unknown or has not been verified)
• Report an improvement that is absolute and relates to a decrease in production or reduced facility operations. This is why data normalization is important.
• Report an improvement that is based on insufficient data. (e.g., an overall reduction was achieved but this was not related to measurable or defined actions taken to achieve the reduction). This is particularly important when the improvements are marginal (e.g., less than 1-2%) and possibly attributable to measurement/ tracking errors and/or operational variability.

How This Will Be Verified:

When verifying a facility’s improvements, Verifiers must review:

• All supporting evidence (e.g., waste quantity data and baselines, etc.) to verify the reported improvement quantity is accurate and attributable to measurable actions taken to reduce waste.
• The implemented changes or actions taken to achieve the improvements.

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 if the facility has achieved reductions from the baseline quantity and achieved year over year reductions for all waste streams.

Note: Points are automatically calculated in the Higg FEM and awarded for a reduction of any amount (i.e., scoring is not based on the amount of the reduction achieved).

Documentation Required:

• Documentation that demonstrates reductions were achieved for each applicable waste stream and result from specific actions taken by the facility to reduce waste. This may include:
  • Waste tracking reports and quantity records showing reductions of waste generated.
  • Documented evidence of facility actions to reduce waste (e.g., evidence of process modifications, new equipment or work practices that resulted in waste reduction).
  • Supporting calculations methodologies or assumptions used to determine the reduction.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how reductions were achieved including any calculations or assumptions made determining the reductions.

Inspection – Things to Physically Look For:

• Onsite observations that indicate the facility has implemented the noted actions to reduce waste (e.g., process modifications, new equipment or work practices).

Partial Points: 

Partial Points will be awarded if the facility has achieved reductions from the baseline quantity or achieved year over year reductions for one (1) or more waste streams.

Answer Yes if:  If your Facility has improved one (1) or more of the waste disposal methods used by your facility compared with your baseline.

Notes: 

• Improvements are defined as:
  • For Preferred Options – An increase in the amount/percentage compared to the baseline
  • For Less Preferred Options – An increase in the amount/percentage compared to the baseline if the original waste type was disposed of previously with a least preferred option or a reduction in the amount/percentage compared to the baseline if the original waste type was disposed of previously as a less preferred option.
  • For Least Preferred options – A reduction amount/percentage compared to the baseline
• Improvements in waste disposal methods due to reductions in production volume should not be considered reductions in waste generation as time as this will not result in sustainable improvements.

If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your waste disposal methods improvement for each applicable disposal method:

• This is your reported baseline quantity.
• This is your reported unit of measure.
• This is your reported baseline year.
• Note: The above data will be auto-populated in the table based on your reported baseline data.
• Has your facility improved (increased or reduced) this waste disposal method compared with its baseline?
• What is your achievement for change (in %) in improving this waste disposal method compared to its baseline? (Enter negative for reduction %; Enter positive for increased %)
• Describe the strategies used to achieve this improvement.

Suggested Uploads:

• Documentation that supports how improvements were achieved (e.g., waste quantity data and baselines for waste disposal methods, agreement with third party who will accept and treat or utilize the waste, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have improved the waste disposal method for wastes generated at the facility.

Technical Guidance:

Improvements in waste disposal methods can be demonstrated by diverting wastes to a preferred disposal/treatment method that results in less impacts to the environment. Examples of improvements in disposal methods can include:

• Increasing the quantity of waste sent to external recycling contractors and biological treatment (e.g., non-hazardous production waste recycling and food waste biological treatment) to divert waste from landfill or incineration without energy recovery.
• Switching to a disposal/treatment method that recovers usable aspects of the waste (e.g., using incineration with energy recovery as opposed to landfilling)

Waste Disposal Improvements in the Higg FEM:

The Higg FEM defines waste disposal improvements as the following based on the Preferred, Less Preferred, and Least Preferred methods listed in the Higg FEM:

• For Preferred Options – An increase in the amount/percentage compared to the baseline.
• For Less Preferred Options – An increase in the amount/percentage compared to the baseline if the original waste was disposed previously with a least preferred method or a reduction in the amount/percentage compared to the baseline if the original waste type was disposed of previously as a less preferred option.
• For Least Preferred options – A reduction in the amount/percentage compared to the baseline.

When evaluating your waste disposal improvements, be sure to do the following:

• Review the waste data to ensure the data and any automated calculations are accurate.
• Review the actions taken to make improvements and determine if they have resulted in measurable improvements by comparing the data with historical waste data to determine the improvement quantity. Note: Historical data accuracy should also be verified.
  • For example: By sourcing a new material recycling vendor using advanced technology, the facility was able to increase the amount of total waste recycled by 25%.

Reporting Improvements in the Higg FEM:

Do:

• Review the improvement data to ensure all aspects noted above are covered and that the information is accurate.
• Input the percent (%) change in the total waste quantity for the respective disposal method from the baseline year. (e.g., -5 for a 5% reduction or 5 for a 5% increase)
• Provide sufficient details in the “Describe the strategies used to achieve this improvement:” field (e.g., Both fabric and leather waste are now being sent to material recyclers instead of landfill).

Do Not:

• Report improvements that are not accurate (e.g., the data source is unknown or has not been verified)
• Report an improvement that is absolute and relates to a decrease in production or reduced facility operations. This is why data normalization is important.
• Report an improvement that is based on insufficient data. (e.g., an overall reduction was achieved but this was not related to measurable or defined actions taken to achieve the reduction). This is particularly important when the improvements are marginal (e.g., less than 1-2%) and possibly attributable to measurement/ tracking errors and/or operational variability.

How This Will Be Verified:

When verifying a facility’s improvements, Verifiers must review:

• All supporting evidence (e.g., waste quantity data and baselines, etc.) to verify the reported improvement quantity is accurate and attributable to measurable improvements in waste disposal methods.
• The implemented changes or actions taken to achieve the improvements.

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 if the facility has improved the amount/percentage of waste disposed of using a Preferred or Less Preferred Option.

Notes:

• Improvements are defined as:
  • For Preferred Options – An increase in the amount/percentage compared to the baseline
  • For Less Preferred Options – An increase in the amount/percentage compared to the baseline if the original waste type was disposed of previously with a least preferred option or a reduction in the amount/percentage compared to the baseline if the original waste type was disposed of previously as a less preferred option.
  • For Least Preferred options – A reduction amount/percentage compared to the baseline.
• No points will be awarded if there is a reported increase in any Least Preferred option.

Documentation Required:

• Documentation that supports the improvement for each waste disposal method and that they are based on a formal evaluation of improvement opportunities. This may include:
  • Waste quantity data and baselines tracking for waste disposal methods.,
  • Agreement with the third party who will accept and treat or utilize the waste using a more preferred method.
  • Supporting calculations methodologies or assumptions used to determine the improvement.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how improvements were achieved including any calculations or assumptions made determining the improvements.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are appropriate in relation to the reported improvements (e.g., tracking of waste quantity, waste segregation, etc.)

Partial Points: N/A

Answer Yes if:  Your facility works with your waste contractors to validate the final disposal and how all hazardous wastes are treated. This means a formal evaluation or assessment has been conducted within the last three (3) years to validate the disposal and treatment of all hazardous wastes.

Answer Partial Yes if:  Your Facility has established formal plans and procedures to work with your facility’s waste contractors to validate the final disposal and how all hazardous wastes are treated. However:

• No formal evaluations or assessments have been conducted; or
• Validations are greater than 3-year-old or do not cover all hazardous wastes disposed of by the facility.

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

• Upload a supporting documentation.
• Describe how you work with your facility’s waste contractors to ensure appropriate disposal during the waste treatment.

Suggested Uploads

• Documentation that demonstrates how the facility validates waste disposal and treatment with its waste contractors (e.g., documented procedures for validation reviews and assessments, completed validation assessment reports of waste contractors, etc.)

What is the intent of the question?

The intent is to ensure facilities are validating the final disposal and treatment of all hazardous waste.

Technical Guidance:

Hazardous waste poses serious risks to the environment when improperly treated and disposed of. Facilities should take steps to confirm that their waste contractors are properly transporting, storing, treating, and disposing of hazardous wastes from the facility.

Facilities should evaluate their waste contractor(s) during the contractor selection process and conduct regular assessments to ensure that contractors have obtained and are maintaining all required permits and legal authorizations, and that they are operating within legal compliance and with the terms of any contracts or agreements relating to waste disposal and treatment.  Ongoing assessments should be conducted at least once every 3 years.

When evaluating waste management contractors, facilities should review and evaluate:

• Waste contractor qualifications (e.g., business license, environment permits, reports) of the contractor.
• Waste contractor due diligence and legal environment performance (e.g., historic violations)
• Overall environmental performance

After approving and working with contractors, facilities should conduct regular assessments of waste contractor facilities and work practices to review and evaluate if:

• The contractor continues to operate in compliance with all permits and legal obligations.
• The transportation of wastes is traceable and secure (e.g., proper waste manifesting and appropriate vehicles).
• The contractor utilizes good work practices for the handling and storage of wastes at its facilities including:
  • Proper segregation of waste.
  • Proper labelling of waste and transportation vessels.
  • Storage on impermeable surfaces.
  • Proper security and fire/flood protection.
  • No illegal dumping or burning.
  • Human health and safety practices, such as providing personal protective equipment, training, and machine safety.
• Where possible, contractors use optimized waste disposal methods (such as recycling hazardous waste or incinerate hazardous waste with energy recovery) that reduce impacts to the environment.

How This Will Be Verified:

Full Points:

Full Points will be awarded if the facility has validated the treatment and final disposal of all hazardous wastes within the last 3 years.

Documentation Required:

• Documentation that demonstrates how the facility validates waste disposal and treatment with its waste contractors. This should include:

• Procedures to work with your facility’s waste contractors to validate the final disposal and how all hazardous wastes are treated.
• Records of validation reviews or assessments of contractors responsible for final disposal or treatment of all hazardous wastes.
  • Notes: Records must show that the validations occurred within the past 3 years.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the facility screens waste contractors and conducts regular reviews of contractors to validate treatment and final disposal of all hazardous wastes.

Inspection – Things to Physically Look For:

• Evidence that shows the facility has validated their waste contractor’s waste treatment facilities in the past 3 years.

Partial Points: 

• Partial Points will be awarded if the facility has established formal plans and procedures to work with your facility’s waste contractors to validate the final disposal and how all hazardous wastes are treated. However:
  • No formal evaluations or assessments have been conducted; or
  • Validations are greater than 3-year-old or do not cover all hazardous wastes disposed of by the facility.

Answer Yes if:  Your facility works with your waste contractors to validate the final disposal and how all non-hazardous waste are treated. This means a formal evaluation or assessment has been conducted within the last three (3) years to validate the disposal and treatment of all non-hazardous wastes.

Answer Partial Yes if:  Your Facility has established formal plans and procedures to work with your facility’s waste contractors to validate the final disposal and how all non-hazardous waste are treated. However:

• No formal evaluations or assessments have been conducted; or
• Validations are greater than 3-year-old or do not cover all non-hazardous wastes disposed of by the facility.

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

• Upload a supporting documentation.
• Describe how you work with your facility’s waste contractors to ensure appropriate disposal during the waste treatment.

Suggested Uploads

• Documentation that demonstrates how the facility validates waste disposal and treatment with its waste contractors (e.g., documented procedures for validation reviews and assessments, completed validation assessment reports of waste contractors, etc.)

What is the intent of the question?

The intent is to ensure facilities are validating the final disposal and treatment of all non-hazardous waste.

Technical Guidance:

Wastes that are not treated or disposed of properly can pose serious risks to the environment. Facilities should take steps to confirm that their waste contractors are properly transporting, storing, treating, and disposing of non-hazardous wastes from the facility.

Facilities should evaluate their waste contractor(s) during the contractor selection process and conduct regular assessments to ensure that contractors have obtained and are maintaining all required permits and legal authorizations, and that they are operating within legal compliance and with the terms of any contracts or agreements relating to waste disposal and treatment.  Ongoing assessments should be conducted at least once every 3 years.

When evaluating waste management contractors, facilities should review and evaluate:

• Waste contractor qualifications (e.g., business license, environment permits, reports) of the contractor.
• Waste contractor due diligence and legal environment performance (e.g., historic violations)
• Overall environmental performance

After approving and working with contractors, facilities should conduct regular assessments of waste contractor facilities and work practices to review and evaluate:

• The contractor continues to operate in compliance with all permits and legal obligations.
• The transportation of wastes is traceable and secure (e.g., proper waste manifesting and appropriate vehicles).
• The contractor utilizes good work practices for the handling and storage of wastes at its facilities including:
  • Proper segregation of waste.
  • Proper labelling of waste and transportation vessels.
  • Storage on impermeable surfaces.
  • Proper security and fire/flood protection.
  • No illegal dumping or burning.
  • Human health and safety practices, such as providing personal protective equipment, training, and machine safety.
• Where possible, contractors use optimized waste disposal methods (such as recycling waste or incinerate waste with energy recovery) that reduce impacts to the environment.

Resources:

• Examples of online waste sourcing and material procurement platforms
  • https://cyrkl.com/en
  • https://recykal.com/
  • https://reverseresources.net/
  • https://www.wastetrade.com/

How This Will Be Verified:

Full Points:

Full Points will be awarded if the facility has validated the treatment and final disposal of all non-hazardous wastes within the last 3 years.

Documentation Required:

• Documentation that demonstrates how the facility validates waste disposal and treatment with its waste contractors. This should include:
• Procedures to work with your facility’s waste contractors to validate the final disposal and how all non-hazardous wastes are treated.
• Records of validation reviews or assessments of contractors responsible for final disposal or treatment of all non-hazardous wastes.
• Notes: Records must show that the validations occurred within the past 3 years.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the facility screens waste contractors and conducts regular reviews of contractors to validate treatment and final disposal of all non-hazardous wastes.

Inspection – Things to Physically Look For:

• Evidence that shows the facility has validated their waste contractor’s waste treatment facilities in the past 3 years.

Partial Points: 

• Partial Points will be awarded if the facility has established formal plans and procedures to work with your facility’s waste contractors to validate the final disposal and how all non-hazardous wastes are treated. However:
• No formal evaluations or assessments have been conducted; or
• Validations are greater than 3-year-old or do not cover all non-hazardous wastes disposed of by the facility.

Answer Yes if:  Your facility uses one (1) or more of the Preferred disposal methods listed in the Higg FEM. These include Reuse, Recycle (including Upcycle), or Downcycle.

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

• Enter the total percentage of waste being disposed of through the Preferred disposal method.
  • This is calculated as follows: Total quantity of waste disposed of using Preferred Methods/Total waste quantity (of all wastes) x 100%
    • Note: Total quantities for the FEM reporting year must be used.
• Upload supporting documentation.
• Please describe how this is implemented.

Suggested Uploads:

• Documentation that demonstrates your facility’s waste is disposed of using one of the preferred methods listed in the Higg FEM (e.g., waste disposal records, contracts/agreements with waste contractors, waste contractor evaluation/assessment reports, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that waste is being disposed of using one of the preferred methods listed in the Higg FEM.

Technical Guidance:

Material recovery (i.e., reuse, recycle including upcycling, or downcycling) are preferred solutions for wastes as these methods create value from wastes and contribute to creating a circular economy that minimizes waste.

Facilities should strive to work with waste contractors, industry partners, local governments, and communities to identify preferred solutions for wastes that include reuse or recovery of waste materials that extends the materials lifespan as long as possible.

Resources:

• The Ellen MacArthur Foundation – https://ellenmacarthurfoundation.org/
• Zero Waste International Alliance – https://zwia.org/
• The Waste and Resources Action Programme (WRAP) https://wrap.org.uk/taking-action/textiles
• US EPASustainable Materials Management: Non-Hazardous Materials and Waste Management Hierarchy https://www.epa.gov/smm/sustainable-materials-management-non-hazardous-materials-and-waste-management-hierarchy
• Examples of online waste sourcing and material procurement platforms
  • https://cyrkl.com/en
  • https://recykal.com/
  • https://www.wastetrade.com/
  • https://reverseresources.net/

How This Will Be Verified:

Full Points:

Full Points will be awarded if the is using preferred disposal methods to dispose of 90% or more of its total waste.

Documentation Required:

• Documentation that demonstrates the facility’s waste is disposed of using one of the preferred methods listed in the Higg FEM. This may include:
  • Waste disposal records including quantities and final disposal methods.
  • Contracts/agreements with waste contractors,
  • Waste contractor evaluation/assessment reports that confirm final disposal methods.

Interview Questions to Ask:

• Staff responsible for waste management are able to describe how the facility’s waste is disposed of using preferred methods and how the total quantities are tracked.

Inspection – Things to Physically Look For:

• The observed waste management practices on-site are consistent with the facility’s reported waste disposal methods.

Partial Points: 

• Partial Points will be awarded if the is using preferred disposal methods to dispose of 25 to 89% of its total waste.

Do you or are you willing to engage in circular economy systems? (Ref ID: wstworkoncircular )

Your facility is currently engaging in or is willing to engage in circular economy initiatives.

If you answer Yes to this question, you will be asked to indicate if your facility is currently engaging or is willing to engage in the following ways:

• Participate Independently – on your own
• Engage with industry working groups
• Engage with customers
• Engage with other suppliers
• Other

If Other, please specify

Suggested Uploads:

• Documentation that demonstrates your facility is capturing and/or reintroducing waste materials that are being used as part of a circular economy system. (e.g., waste disposal or purchase records, contracts/agreements with receivers or suppliers of waste materials, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate they are, or are willing to, participate in a circular economy system. This will also assist potential partnerships based on interest indicated by the facility.

Technical Guidance:

A circular economy is a regenerative system in which resource input and waste is minimized by slowing, closing, and narrowing material loops; this can be achieved through long-lasting design, maintenance, repair, reuse, remanufacturing, refurbishing, recycling, and upcycling. This is in contrast to a linear economy which is a ‘take, make, dispose’ model of production.

In the Higg FEM, Circular systems is defined as a system that captures and reintroduces waste from and into the facility’s own operations or production or captures and reintroduces waste  into an external party’s operations or production. Some examples include:

• Textile waste that is recycled into a new material and then used for a new production run.
• Recycling plastic bottles to make fabric.
• Recovering coal ash from the boiler room to make bricks.
• Aluminium recycling to produce cans.

The four key aspects of a closed-loop supply chain are:

• Source Materials: Use recycled or renewable materials that are responsibly sourced.
• Make Efficiently: Design and manufacture products to minimize the use of materials.
• Product Lifespan: Design products to be durable, so they can have long lives.
• Contribute: Replenish market supply with waste material or product that can be recycled, reclaimed, or renewed at least equal to the amount used to make the product.
• Facilities should strive to conduct research and work with waste contractors, industry partners, local governments, and communities to identify creative solutions for wastes that include reuse or recovery of waste materials that extends the material’s lifespan indefinitely or as long as possible.

Resources:

• Several resources are provided below that include guidance or examples of initiative to create circular economy systems or zero waste solutions.
• Note: The resources and examples provided below are for informational purposes only and do not constitute an endorsement by Cascale. Facilities should ensure that any circular economy initiatives (e.g., the purchase or sale of wastes) is conducted in accordance with applicable regulations.
• Zero Waste International Alliance – Zero Waste Hierarchy of Highest and Best Use https://zwia.org/zwh/
• Close the Loop – A Guide Towards a Circular Fashion Industry  https://www.close-the-loop.be/en
• The Ellen MacArthur Foundation – https://ellenmacarthurfoundation.org/
• Examples of online waste sourcing and material procurement platforms
  • https://cyrkl.com/en
  • https://recykal.com/
  • https://reverseresources.net/
  • https://www.wastetrade.com/

How This Will Be Verified:

Note: This question is unscored.

Documentation Required:

• Documentation that demonstrates the facility is, is willing to, capturing and/or reintroducing waste materials as part of a circular economy system. This may include:
  • Waste material sale or purchase records
  • Contracts/agreements with receivers or suppliers of waste materials.
  • Production records that demonstrate waste materials were reintroduced to facility operations or manufacturing processes.
  • Company Sustainability Strategy or Environmental Policy that includes circular economy related commitments.

Interview Questions to Ask:

• Staff responsible for waste management or material procurement are able to describe how the facility operates in the circular economy or has an understanding of how the facility could participate.

Inspection – Things to Physically Look For:

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• The observed waste management practices on-site are consistent with the facility’s reported actions or intent for participating the circular economy (e.g., onsite capture and reintroduction of wastes)