FEM 2025 - Waste Level 2 (Part 2)

Table of Contents

• Wstmanage
• Wstmanage Verification And Scoring
• Wstredimpplan
• Wstredimpplan Verification And Scoring
• Wstredimpnhsource
• Wstredimpnhsource Verification And Scoring
• Wstredimphprodsource
• Wstredimphprodsource Verification And Scoring
• Wstredimpdisp
• Wstredimpdisp Verification And Scoring
• Wsthazdispvalidate
• Wsthazdispvalidate Verification And Scoring

Wstmanage

Which of the following are you doing to manage your waste? (Select all that apply) (Ref ID: wstmanage )

• Waste mapping – understanding waste flows from different processes. Includes: textile waste, sludge, emissions, discharge, etc.
• Waste segregation – segregate waste materials so they are clean/controlled. For textile waste: separate into different material types, such as cotton / nylon / polyester / specific blend/ specific metal types/sludge or blends.
• Waste training – training specific team members to correctly segregate (textile or any other material) waste so it remains clean and retains value for recycling.
• Waste storing – store waste materials separately
• Waste labelling/bagging – label/bag separate waste materials
• Waste tracking & digitized reporting – to offer information/insights to waste solution providers and traceability.
• Waste matching to solution providers for recycling/upcycling/downcycling/service providers that can valorize the waste streams.
• Working with stakeholders, such as recyclers and product creators to create fully circular business models. Such as re-introducing (recycled) waste streams back into new products.

Suggested Uploads:

• Documentation that supports your facility is performing the action selected (e.g., waste maps, processes for handling wastes onsite and training workers, waste tracking, evaluation or collaborative assessments with waste solution providers etc.) 

What is the intent of the question?

The intent of this question is for facilities to indicate which practices are included in their waste management programs and processes.

Technical Guidance:

Adopting good practices, such as those listed in this question, for managing wastes will support your facility in accurately identifying and tracking waste streams to better understand waste generation as well as help with identifying opportunities to prevent or reduce wastes and evaluate preferred solutions for waste treatment or disposal.   

Wstmanage Verification And Scoring

Full Points:

Full Points will be awarded if the facility has implemented all of the listed practices.

Documentation Required: 

• Documentation that supports the action(s) selected by the facility. This may include:
  • Waste maps.
  • Processes for handling wastes and storage and training workers.
  • waste tracking records and digital/online platforms used to manage or find solutions for waste.
  • Evaluation or collaborative assessments with waste solution providers to identify alternative waste solutions that reduce impacts to the environment.

Interview Questions to Ask: 

• Staff responsible for waste management are able to describe how the facility implements the selected actions.

Inspection – Things to Physically Look For: 

• The observed waste management practices on-site are consistent with the facility’s selected actions. 

Partial Points: 

• Partial Points will be awarded if the facility has implemented one (1) or more of the listed practices.

Wstredimpplan

Does your facility have an implementation plan to switch to a more preferred waste disposal method? (Ref ID: wstredimpplan )

Answer Yes if:  Your facility has a current documented plan and has started work 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.cascale.org/resources-library/resources-library-fem-2023-and-prior-resources-archive/

Wstredimpplan Verification And Scoring

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.

Wstredimpnhsource

Has your facility reduced non-hazardous waste generation in the reporting year, compared with your baseline? (Ref ID: wstredimpnhsource )

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.

Wstredimpnhsource Verification And Scoring

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: N/A

Wstredimphprodsource

Has your facility reduced hazardous waste generation in the reporting year, compared with your baseline? (Ref ID: wstredimphprodsource)

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.

Wstredimphprodsource Verification And Scoring

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: N/A

Wstredimpdisp

Has your facility improved waste disposal methods for overall waste in the reporting year, compared with the baseline? (Ref ID: wstredimpdisp)

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.

Wstredimpdisp Verification And Scoring

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

Wsthazdispvalidate

Does your facility validate the final disposal and treatment of all hazardous wastes? (Ref ID: wsthazdispvalidate )

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. 

Wsthazdispvalidate Verification And Scoring

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.