Table of Contents
General
- If a facility does not treat water onsite, is it still expected to have an emergency plan if there’s an issue with the wastewater treatment?
- Can facilities registered in ZDHC Gateway use this data in the FEM module directly?
- Is employee training required if sludge is not hazardous?
Definitions
- If a facility’s industrial wastewater is reused by a third party, does it qualify as reusing that facility’s wastewater?
- Is ink sludge from the industrial preliminary treatment system classified as 'Pre-water treatment sludge'?
- Regarding the definition of reuse process wastewater, does it refer only to closed-loop systems with water as working fluid?
BOD Tests and ETP
- Does the BOD5 test need to be conducted for ETP and STP outlet water or only for STP?
- Are other BOD tests acceptable, or do facilities have to conduct BOD5 tests for wastewater?
- If the facility is using a common ETP owned by another facility of the factory group at the same shared site, should it be considered as onsite or offsite treatment?
- Will a facility receive a zero in the FEM if the facility is getting wastewater treated by an offsite ETP that is unwilling to share test reports/permits?
If a facility does not treat water onsite, is it still expected to have an emergency plan if there’s an issue with the wastewater treatment?
Yes, even if the wastewater is treated offsite, it is possible that there could be a spill of wastewater. For example, a pipe could break before the wastewater has left the facility and sent to the offsite treatment center. As such, it is important to have an emergency contingency plan.
Can facilities registered in ZDHC Gateway use this data in the FEM module directly?
There is no direct software integration between ZDHC gateway and the FEM module, where the data for facilities registered in ZDHC gateway can be directly imported into the FEM Module. However, you can use the data from the ZDHC Gateway for the FEM module. Facilities are required to input the details directly into the FEM.
The ZDHC programming is applicable to the Wastewater, Chemicals, and Air Emissions sections.
The ZDHC Gateway harnesses the power of transparency and collaboration to eliminate harmful substances from global value chains. It is the world’s largest database dedicated to enabling safer choices of chemical products for the textile, apparel and footwear industry.
Is employee training required if sludge is not hazardous?
The training regardless of whether sludge is hazardous or not should focus on the intent of the question:
"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".
Sludge needs to be taken out of the tanks, and it also needs to be dewatered, and transported from the ETP/STP to a storage location, even though the sludge is not treated, employees within the facility would have some level of interaction with it, as such they need to be trained on how to handle it.
If a facility’s industrial wastewater is reused by a third party, does it qualify as reusing that facility’s wastewater?
If the water is reused outside of the facility premises, it does not count towards recycling wastewater. The water is considered recycled at the facility where it is reused.
Is ink sludge from the industrial preliminary treatment system classified as 'Pre-water treatment sludge'?
Ink sludge is not classified as 'pre-water treatment sludge', it is categorized as wastewater treatment sludge.
Regarding the definition of reuse process wastewater, does it refer only to closed-loop systems with water as working fluid?
Reuse process wastewater refers to closed-loop systems with water as the working fluid. This includes boiler steam distribution for non-contact heat transfer, as well as chillers that use water as the thermal transfer medium. This process does not physically contaminate the water, but rather supports the transfer of thermal energy.
Does the BOD5 test need to be conducted for ETP and STP outlet water or only for STP?
Testing needs to be done or evaluated based on biological treatment, regardless of ETP or STP.
Both inlet, within process, and outlet BOD5 should be evaluated, as this will allow you to better calculate your GHG emissions from wastewater treatment.
Are other BOD tests acceptable, or do facilities have to conduct BOD5 tests for wastewater?
The How to Higg Guidance specifically requires testing for Biochemical Oxygen Demand 5-day concentration (BOD5). The intent of the question is for facilities to demonstrate that the concentration of BOD5 in wastewater is being monitored. Testing for BOD3 does not meet the requirements outlined in the guidance. If they did not conduct at least one test for BOD5 in wastewater, No should be selected.
If the facility is using a common ETP owned by another facility of the factory group at the same shared site, should it be considered as onsite or offsite treatment?
If the ETP is owned and operated by a separate business entity, the treatment would be considered off-site, as long as the licensing/permitting of the ETP reflects the distinction between the two legal business entities.
Will a facility receive a zero in the FEM if the facility is getting wastewater treated by an offsite ETP that is unwilling to share test reports/permits?
No, facilities will only receive a zero FEM score if they do not have required operating licenses or permits.
As long as the facility has a permit or agreement to dispose of wastewater to an external party, or the facility is not required to obtain a permit for Wastewater disposal as per the legal regulations of the facility’s country, it will not get a zero score for not having the disposal permit or disposal test reports from the offsite ETP.
However, it is recommended that the facility move to an offsite ETP that is willing to provide this documentation so that it can obtain higher scores in the Wastewater section.