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FEM 2025 - Wastewater Level 1 (Part 2)

  • Updated

Table of Contents

Wwsludge

Does your facility maintain manifests or similar documentation of the handling, transportation, processing, and disposal of sludge, accounting for all industrial wastewater sludge generated at the facility?   (Ref ID: wwsludge)

Answer Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and all of the following conditions are met:

  • Documentation has been obtained that accounts for all sludge disposals.
  • The documentation contains all of the information noted below:
    • Shipper (the facility generating the sludge).
    • Mass or volume of the shipment.
    • Transporter’s company name.
    • Shipment/Receiving dates
    • Name of the disposal or processing facility that the sludge was shipped to. 

Answer Partial Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge, and documentation has been obtained for all sludge disposals; however

  • The documentation does not contain one or more of the pieces of information noted below:
    • Shipper (the facility generating the sludge).
    • Mass or volume of the shipment.
    • Transporter’s company name.
    • Shipment/Receiving dates
    • Name of the disposal or processing facility that the sludge was shipped to.

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

  • Does your facility use authorized third party for legal disposal of Industrial wastewater sludge? 
  • Does your facility retain documentation of all wastewater sludge transportation and disposal/treatment companies?
    • Note: This refers to the legally required amount of time that documentation must be retained, which may vary by jurisdiction. If there are no legal requirements documentation must be retained for at least two (2) years.
  • Are all Industrial wastewater sludge transporters, treatment, and disposal facilities licensed and permitted?
  • Please upload documentation.

Suggested Uploads:

  • Samples of waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge.
  • Copies of sludge handling/treatment/disposal vendor licenses and/or permits that show they are authorized to receive, process and dispose of the sludge.

Note: Uploading of all manifest or other documentation is not required, however they should be available for review at the time of verification.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that processes are in place to obtain and retain information related to the handling, transportation, processing, and disposal of industrial wastewater sludge and to ensure that any third-party waste vendors have the required legal approvals to receive, process and dispose of the facility’s sludge.

Technical Guidance:

To ensure proper accountability, facilities should have established processes in place to maintain documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge. Often the minimum requirements for generating and maintaining documentation related to waste disposal is governed by legal requirements (particularly for hazardous wastes) and all applicable requirements should be met by facilities.

In addition to any legal requirements, facilities should ensure that a waste manifest or a similar local transport document that contains the following information is obtained and maintained for each sludge shipment as a good practice. If needed this additional information can be requested from waste vendors:

  • Shipper (the facility generating the sludge).
  • Mass or volume of net shipment.
  • Transporter’s company name.
  • Shipment/Receiving dates
  • Name of the disposal or processing facility that the sludge was shipped to.

Facilities should also ensure that any third-party waste vendors used have the required legal approvals to receive, process and dispose of the facility’s sludge. Facilities should ensure that part of the waste vendor approvals process include the verification of all legally required approvals (e.g., licenses and permits). It is considered a good practice (if not legally required) for facilities to request and maintain up-to-date and valid copies of vendor approvals onsite.

Resources:

Wwsludge Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and all of the following conditions are met:

  • Documentation has been obtained that accounts for all sludge disposals and contains all of the required information.
  • Documentation is retained onsite for at least the legally minimum required length of time. If there are no legal requirements documentation must be retained for at least two (2) years.
  • Any third-party waste vendors used have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.

Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.

Documentation Required:

  • Documentation that shows the facility has obtained and maintains waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge and that sludge is being received by authorized vendors. This may include:
    • Waste manifests or other transport documentation.
    • Waste vendor licenses and/or permits that show they are authorized to receive, process and dispose of the facility’s sludge.

Interview Questions to Ask:

  • Staff responsible for managing wastes can explain the facilities procedures to obtain and maintain manifests and/or other transport information related to sludge disposal and how the facility ensures that waste vendors have the required approvals to collect, receive, or process the facility’s sludge.  

Inspection - Things to Physically Look For: 

  • Observations indicate that sludge is being collected and treated per the process reported by the facility (e.g., sludge disposal records, sludge storage conditions, presence of waste contractors onsite during verification, etc.)

Partial Points:

Partial points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of industrial wastewater sludge, and documentation has been obtained for all sludge disposals, however:

  • Documentation does not include the required information; and/or
  • Documentation is not retained onsite for at least the legally minimum required length of time or if there are no legal requirements, documentation has not been retained for two (2) years; and/or
  • Any third-party waste vendors used do not have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.

Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.

Wwsludgetraining

Does your facility provide training to all employees whose work involves wastewater sludge handling (such as maintenance and custodial staff)? (Ref ID: wwsludgetraining)

Answer Yes if:  Your facility provides training to all employees who handle wastewater sludge and the training covers safe handling, storage, and disposal of sludge.

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

  • How many employees were trained?
  • How frequently do you train your employees?
  • Do you evaluate your employees after the training?
    • How do you evaluate the knowledge of your employees after the training?
  • Please upload documentation.

Suggested Upload: 

  • Records of sludge handling training or general waste handling training if sludge is included in this. 
  • Copies of training material used. 
  • Employee training plans or procedures that demonstrate training is provided to all employees who handle sludge. 

What is the intent of the question?

The intent of this question is to ensure facilities have procedures in place to train all employees who handle wastewater sludge on practices to minimize environmental and health risks associated with sludge. 

Technical Guidance:

Wastewater sludge can pose significant risks to the environment and human health. Employees who handle sludge on-site should understand these risks and know how to safely, handle, store, and dispose of sludge to minimize environmental and health and safety impacts. 

Additionally, having procedures to collect information to evaluate the effectiveness of training programs (e.g., trainee feedback questionnaires or test, observation, or reviews of trainer performance, etc) will help facilities ensure the effectiveness of trainings and knowledge retention.

Resources:

Wwsludgetraining Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required: 

  • Documentation that demonstrates that all employees who handle sludge are trained on safe handling, storage, and disposal of sludge. This may include:
    • Records of sludge or general waste training if sludge handling is included in this. 
    • Training material used. 
    • Employee training plans or procedures that demonstrate sludge handling training is provided to all employees who handle sludge. 

Interview Questions to Ask: 

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

Inspection - Things to Physically Look For: 

  • On-site observations indicate that sludge is being handled in accordance with the facility’s waste handling procedures.

Partial Points: N/A

Wwnhsludgedisposal

Is domestic wastewater sludge disposed of properly?   (Ref ID: wwnhsludgedisposal)

Answer Yes if: Your facility is disposing of domestic wastewater sludge in accordance with all legal requirements based on the hazardous characteristic of the sludge.

Note: This question refers to the final treatment/disposal method of the sludge. This can be onsite or offsite depending on the final treatment/disposal location.

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

  • Which disposal pathway(s) does your facility dispose of your domestic wastewater sludge?
    • Hazardous Waste Treatment
    • Open burning
      • Note: The use of open burning of sludge is strongly discouraged unless specific regulatory approval is obtained and complied with.
    • Onsite Incineration at ≥1000 °C
    • Onsite Incineration at <1000 °C
    • Offsite Incineration at ≥1000 °C 
    • Landfill with Significant Control Measures
    • Building Products Processed at ≥1000 °C
    • Landfill with Limited Control Measures
    • Offsite Incineration and Building Products Processed at <1000 °C
    • Landfills with No Control Measures
    • Land Application
      • E.g., Compost, fertilizer.
    • Non-disclose method by authorized third party (final disposal method not disclosed)
  • Please upload documentation.

Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document

Suggested Uploads:

  • Documentation that demonstrates domestic wastewater sludge is being disposed of properly (sludge analysis/test showing hazardous properties, sludge disposal manifests, permit/license of waste vendor accepting and treating the sludge, evidence of the final treatment/disposal method being used, etc.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that domestic wastewater sludge is being disposed of responsibly to minimize environmental impacts.

Technical Guidance:

The hazardous properties and proper disposal method of sludge depend on the specific hazardous properties of the sludge (e.g., the type and concentration of hazardous chemicals). Facilities should ensure that sludge is properly characterized (e.g., via laboratory testing) to identify its hazardous properties and any specific disposal requirements or limitations.

At minimum, sludge should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics as required.

As part of a facilities waste management program, it is important for facilities to understand how wastes (including sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for sludge. 

If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.

Resources:

Wwnhsludgedisposal Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Documentation that demonstrates domestic wastewater sludge is being disposed of properly. This may include:
    • Sludge analysis/test showing hazardous properties.
    • Sludge disposal manifests.
    • Where applicable, permit/license of waste vendor accepting and treating the sludge.
    • Evidence of the final treatment/disposal method being used by the waste vendor.
    • Legal approvals/permits for any onsite treatment/disposal of sludge if applicable.

Interview Questions to Ask:

  • Staff responsible for wastewater/waste management understand the hazardous composition of the facility’s sludge and the final disposal method used to treat/dispose of the sludge.

Inspection - Things to Physically Look For: 

  • Observations indicate that sludge is being collected and treated per the methods reported by the facility (e.g., onsite treatment/disposal conditions, sludge storage conditions, etc.)

Partial Points: N/A

Wwsepticwater

Does your facility manage the residue of the Septic System? (Ref ID wwsepticwater) 

Answer Yes if: Your facility has procedures or processes to manage the residue (e.g., sludge) from your septic system in accordance with the design and operating specifications of the septic system. 

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

  • Is your Septic System adequately designed for the septic wastewater volume generated at your facility? 
  • Please upload the Septic system design.
    • If you cannot upload the design document, please describe here:
  • How frequently does your facility unload your septic tank(s)?
  • How did your facility dispose of the solids after unloading from your septic tank?
    • Sent to Municipal plant for further treatment.
    • Hazardous Waste Treatment
    • Open burning
    • Onsite Incineration at ≥1000 °C
    • Onsite Incineration at <1000 °C
    • Offsite Incineration at ≥1000 °C
    • Landfill with Significant Control Measures
    • Building Products Processed at ≥1000 °C
    • Landfill with Limited Control Measures
    • Offsite Incineration and Building Products Processed at <1000 °C
    • Landfills with No Control Measures
    • Land Application
    • Non-disclose method by authorized third party (final disposal method not disclosed)
  • Does your facility obtain shipment manifest / record for offloading septic waste?
  • Please upload documentation if available.

Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document  

Suggested Uploads:

  • Documentation that shows how the facility manages residue (e.g., sludge) from the septic system (e.g., the septic system design drawings showing capacity, tracking records of volume of wastewater sent to the septic system, septic system cleaning schedule and records, records of sludge generation, collection and disposal manifests, records of the final treatment/disposal method being used by the waste vendor.)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that wastes (e.g., sludge) from the septic system are being managed in accordance with the design and operating specifications of the septic system.  

Technical Guidance:

Septic systems are engineered systems that are specifically designed based on the wastewater characteristics they are intended to treat (e.g., the volume of wastewater and pollutant loading). It is crucial septic systems are operated within  their  design specifications and operating parameters to ensure the effective treatment of wastewater. 

Facilities should have established procedures to ensure that the system is operated, monitored, and maintained in accordance with the design specifications and manufacturer’s specifications for all system equipment and components (e.g., pumps, flowmeters, motoring/sampling, frequency for cleaning out sludge, etc.)

At minimum, residue (e.g., sludge) from the system should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics.

As part of a facilities waste management program, it is important for facilities to understand how wastes (including septic system sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for septic system sludge. 

If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.

Resources:

Wwsepticwater Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Documentation that shows how the facility manages residue (e.g., sludge) from the septic system and how the system is being operated in accordance with its design capacity and operating specifications. This may include:
    • The septic system design drawings showing capacity.
    • Tracking records of volume of wastewater sent to the septic system (e.g., showing that the system is not being overloaded)
    • Septic system cleaning schedule and records.
    • Records of sludge generation, collection.
    • Septic system waste manifests. 
    • Evidence of the final treatment/disposal method being used by the waste vendor.

Interview Questions to Ask:

  • Staff responsible for managing wastewater and/or the septic system can explain how the facility ensures that it is being operated in accordance with the design capacity, how the system is maintained (e.g., cleaning frequency) and how wastes from the septic site are disposed of

Inspection - Things to Physically Look For: 

  • Observations indicate that the specific system is being operated and maintained properly (e.g., no standing water, damp spots or strong odours near the septic tank or drainfield)

Partial Points: N/A

Wwtestlegal

Have you tested your wastewater against the legal requirements that apply to your facility? (Ref ID: wwtestlegal)

Answer Yes if: Your facility has conducted wastewater testing at the frequency required by local law and for all the legally required parameters. 

Answer Not Applicable if: There are no applicable legal requirements for your facility to test its wastewater. 

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

  • Do the results show compliance against the requirement?
  • Please upload your test report(s) (Multiple reports as per legal testing frequency)

Note: The question “Do the results show compliance against the requirement?” Should be answered based on the guidance below:

  • Answer Yes if: Testing results in all tests meet the legal requirements for all parameters.
  • Answer Partial Yes if: Testing results show one parameter did not meet the legal requirements. If there are multiple test reports, there must be no more than one parameter exceedance in one (1) report.
  • Answer No if: Testing results show one (1) or more parameters have not been met in multiple test reports, or more than one parameter have not been met in at least one report.

Suggested Uploads:

  • Copies of wastewater testing report.
  • Wastewater discharge permit or approvals that show the testing parameters and discharge limits that are applicable to the facility.

This question is not scored in the 2025 Higg FEM reporting year. Scoring may be applied in future reporting years.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that wastewater has been tested against applicable legal requirements.

Technical Guidance:

Testing wastewater in accordance with legal requirements is a fundamental practice to determine if the facility’s wastewater meets the applicable discharge limits. Facilities should ensure that all applicable testing requirements are understood and that procedures to test wastewater per the applicable legal requirements are implemented.  This information should be used to monitor compliance and identify issues that require action to achieve and maintain compliance (if non-compliance is detected).

Wwtestlegal Verification And Scoring

How This Will Be Verified:

Note: This question is unscored.

Documentation Required:

  • Wastewater testing results showing results of testing against all legally required parameters.
  • Wastewater discharge permit or approvals that show the testing parameters and discharge limits that are applicable to the facility.

Interview Questions to Ask:

  • Staff responsible for wastewater management and legal compliance can explain how the facility’s wastewater testing covers all applicable legal requirements.  

Inspection - Things to Physically Look For: 

  • Observations indicate that all wastewater is being tested in accordance with legal requirements (e.g., the facility has identified and tested all wastewater discharge points as per applicable legal requirements).

Wwstandard

Are you reporting against any wastewater standard (additional to the legal requirement)? (Ref Id: wwstandard)

Answer Yes if: Your facility is testing wastewater and reporting results against a wastewater standard in addition to legally required testing.

Note: If your facility has only tested wastewater in accordance with legal requirements, you should answer No to this question.

Answer Not Applicable if: There are no applicable industry wastewater standards (in addition to legal testing requirements) that apply to your facility.

Note: If your facility only generates domestic wastewater and there are no industry standards applicable to domestic wastewater  (in addition to legal testing requirements) "Not Applicable" should be selected.

If you select Yes, you will be asked the following sub question(s):

  • Please indicate which wastewater standard(s) you are reporting against:
    • ZDHC Wastewater Guidelines (for Leather & Textile) (WWG)
    • ZDHC MMCF Guidelines
    • ZDHC Sludge Reference Document
    • BSR
    • bluesign Wastewater Standard
    • Customer/Brand
    • Other
      • If other, please describe.

Suggested Uploads:

  • Copies of wastewater testing results conducted in accordance with the applicable standard.

This question is not scored in the 2025 Higg FEM reporting year. Scoring may be applied in future reporting years.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that their wastewater is being tested against a wastewater standard in addition to any legally required testing.

Technical Guidance

The standards referred to in this question refer to industry standards, and the intention is to evaluate compliance beyond basic legal discharge requirements. 

Industry standards and tools are developed to support facilities in the proper management and reduction of hazardous pollutants discharged in wastewater to the environment. These tools intend to provide consistent methodologies to identify, monitor and report discharge of hazardous pollutants. They also strive to support facilities in managing and reducing hazardous discharges by establishing progressive discharge limits that go beyond basic legal compliance.  

Different standards or tools may have different requirements for monitoring and reporting of wastewater data (e.g., the type and frequency of reporting, types of pollutants that must be monitored/reported, or testing methodologies, etc.) When adopting an industry standard, facilities should review the guideline to determine the monitoring and reporting requirements that apply to their operations and put in place procedures to meet the required monitoring and reporting requirements. 

Examples of industry guidance/tools for wastewater include:

Wwstandard Verification And Scoring

How This Will Be Verified:

Note: This question is unscored. 

Documentation Required:

  • Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the applicable standard(s) selected. This may include:
    • Wastewater test report showing the parameters tracked by the facility. 
      • Note: Testing should be conducted in accordance with the applicable standard (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
    • If applicable, internal procedures used to ensure the requirements of the standard are being met.

Note: Required documentation may vary by standard being reported against. All wastewater reporting documentation required by the standard should be available for verification. 

Interview Questions to Ask:

  • Staff responsible for managing wastewater understand and can describe the monitoring and reporting requirements of the standard the facility is reporting against.

Inspection - Things to Physically Look For: 

  • The relevant wastewater sources observed at the facility are included in the facility’s monitoring/reporting procedures as required by the standard used to report wastewater data.

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