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Air Emissions

We have all seen smog clouds over cities and know that pollution is unhealthy for humans and the environment. This visible smog is one result of air emissions from your facility, but Industrial processes and operations also emit other invisible pollutants into the air that impact human health and contribute to climate change.

 Air emissions are commonly generated from:

  • Facility operations: boilers, generators, and cooling systems (typically emit dust/particulates (PM10, PM2.5), various oxides of nitrogen (“NOx”), various oxides of Sulphur (“SOx”), ozone depleting substances (“ODS”) and other toxic air pollutants).
  • Production processes: production line equipment and manufacturing processes (typically emit volatile organic compounds (“VOCs”), ozone depleting substances (“ODS”), dust/particulates (PM10, PM2.5), and other toxic air pollutants). 

IMPORTANT NOTE: You will be asked to select which air-emitting operations or processes you have on-site below. These selections will direct you to the questions that are most applicable for your facility. If you don’t have any facility air emissions from operations or production, you will not need to complete this section. 

The Higg Air Emissions section requires you to:

  • Track quantity of emissions from facility operations and refrigeration, if applicable.
  • IMPORTANT NOTE: If you use refrigerants on-site you will be asked to specify which refrigerants are used. These refrigerants will factor into your GHG emission calculations so please try to accurately report refrigerant tracking.
  • Track quantity of emissions from production processes, if applicable.
  • List control devices / abatement processes and monitoring frequency for operating and refrigeration
  • List control devices / abatement processes and monitoring frequency for production
  • Specify achievements of advanced performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate Matter (PM).
  • Specify whether your facility has a process for modernizing equipment to improve air emissions.

REMEMBER: Most fugitive releases of air pollution from refrigerants are due to breaks or leaks in equipment. The equipment maintenance question you were asked in the Environmental Management System section is relevant to this section as preventative maintenance is one of the best ways to prevent fugitive emissions.

Air Emissions Introduction

Facility air emissions are commonly generated from:

  • Your production processes: production line equipment and manufacturing processes
  • Your facility operations: boilers, generators, and cooling systems

Types of emissions include:

  • Point Source or Stack Emissions - stationary identifiable sources of emissions that release pollutants into the atmosphere. Examples include emissions from boilers and other combustion facilities.
  • Mobile Emissions - emissions from equipment that moves from one location to another. Examples include motor vehicles and construction equipment. 
  • Non-Point or Fugitive Emissions - emissions which do not pass through a stack, chimney, vent, or other functionally-equivalent opening. Common sources of fugitive emissions include screen printing, foil printing, molding, etc.  Fugitive emissions could also be the result of construction activities that generate dust or other emissions. These types of emissions are seldom included in the permitting process. 

 Anyone of the emissions sources may have several emissions or discharge points at a single facility.  For example, a facility may have multiple boilers or multiple point-source process emissions stacks. 

These are the common pollutants released into the air by these activities:

  • dust/particulates (PM10, PM2.5) - typically associated with fuel combustion, yarn spinning, synthetic fiber manufacturing
  • various oxides of nitrogen (“NOx”) – typically associated with fuel combustion
  • various oxides of Sulphur (“SOx”) – typically associated with fuel combustion
  • volatile organic compounds (“VOCs”) - typically associated with fabric finishes, solvents, adhesives, fabric printing, tenterframes
  • ozone depleting substances (“ODS”) – commonly found in refrigerants, many apparel spot cleaners, and some adhesives and solvents
  • toxic air pollutants - typically associated with fuel combustion, solvents, adhesives, and some apparel finishes
  • water vapor/steam
  • Fugitive sources from production processes such as Screen printing, Foil Printing, Molding, others (sources without a chimney that emit into the building and from there outside through windows, doors, etc.)
  • Regulated cotton dust emission from spinning, slashing, and weaving

 For a given source of emissions (e.g. boiler operations, multiple production lines or processes), there may be several emissions or discharge points. Your factory’s emissions points are your greatest opportunity for controlling the air pollutants released by your factory. Here are the most common discharge points for air emissions:

  • Stacks, chimneys, or vents (from production equipment or dorm services, such as a kitchen)
  • Open tanks
  • Transport vehicles
  • Handling or moving dusty materials
  • Solvent applications

Managing air emissions requires a different approach than managing energy, water, and waste. Air emissions are regulated to a set level, while energy, water, and waste can be continuously improved. 

Your factory’s air performance really depends on the equipment you have. If you have older or poorly maintained equipment, you have a greater risk of air emissions. The best thing you can do to ensure good air emissions management is to upgrade to top-level, modern equipment and have a strict process for maintaining and monitoring existing equipment.

 If CFCs and HCFCs (ozone depleting substances) are used on-site, solutions to phase out these gases should be considered. One solution is to use chemicals with low-GWP such as HFO’s in the applications of refrigerants, aerosol propellants and foam blowing agents. Please refer to the following list of refrigerants with reference numbers to determine which of your refrigerants are important to track and phase out: https://www.ashrae.org/standards-research--technology/standards--guidelines/standards-activities/ashrae-refrigerant-designations.

How will Higg assist you in improvement?

To take action on air emissions, there are several important things for you to have in place:

  1. You must know your local rules/permit requirements, know how the monitoring/enforcement process works, and have a process in place to demonstrate compliance (Higg Permits and EMS section)
  2. You must know your factory’s sources of air emissions (Higg Applicability Test)
  3. You must track the air pollutants that your factory emits (Higg Level 1)
  4. You must install control devices and/or upgrade to modern equipment (e.g., modern boiler) to ensure compliance/standard is met or exceeded (Higg Level 1)

Since air emissions are so dependent on your specific technologies and machines, the best thing you can do now is to maintain and upgrade equipment. There is no perfectly automated system to guide you on which technologies are associated with which reduced emissions, but Higg questions prepare you to take the most direct actions to manage your own emissions. Knowing how to maintain equipment is a job best suited for a trained technical expert on-site.

 GHG emissions are not limited to energy use and fuel consumption, but also result from emissions as a result of production processes. The Air section of the Facility Environmental Module measures the GHG emissions that are not linked to fuel combustion. If your factory emits GHG gases from non-combustion sources such as HFCs (e.g. leakage of refrigerants and release of HFs in aerosol propellants and foam blowing agents) and control devices for production emissions, Higg Index will help you calculate GHG emissions as part of the GHG footprint.

 Applicability Test

To determine whether you need to complete the questions in the Air Emissions section, we must evaluate whether your factory has relevant sources of air emissions. Air emissions can be from materials processing equipment AND/OR boilers that generate steam for operations.

You will first be asked to select which operations or processes that emit air pollution are present in your factory. These selections will direct you to the Higg questions that are most applicable for your facility

  • If you have any air-emitting operations (e.g., boiler), you will answer questions about operating emissions in all levels.
  • If you have any air-emitting production processes (e.g., solvents or adhesives), you will answer questions about production emissions in Level 1
  • If you don’t have any facility operation or production air emissions, you will not need to complete this section.
  1. Please select whether your factory contains any of the following:
  • Boiler
    • If selected, tell us size:
      • Small: less than 50 MW
      • Medium: 50 MW - 300 MW
      • Large: more than 300 MW
    • Generators
    • Combustion Engines (e.g. gasoline powered pumps)
    • Industrial Ovens (for heating/drying/curing)
    • Combustion Heating (Furnace)
    • Air conditioning (Cooling)
    • Refrigerant containing device (other than air conditioning system)
    • Other sources of known air emissions from facility operations
  1. Does your facility conduct any of the following processes or use any of the following substances?
  • Yarn spinning or synthetic fiber manufacturing
  • Finishes (any mechanical or chemical process that occurs after dying to affect the look, performance, or feel of the product)
  • Solvents
  • Adhesives/cementing
  • Printing
  • Dyeing
  • Tenter frames or other heating process
  • Sprayed chemicals or paints
  • Spot cleaners
  • Other sources of known air emissions from production processes

 

Air Emissions - Level 1 

1. Select all sources of air emissions relevant to your facility's operations that are not regulated by a permit, or for which your facility is not in compliance with its permit

Since you demonstrated compliance with your air permit in the Permits section, please only enter data for emissions that are not tracked by a permit or that are not in compliance with a permit. This question excludes emissions from production processes.

What is the intent of the question?

The intent of this question is to determine if the facility is aware of all on site emissions to air. This question should drive you to inventory all possible sources of emissions to air from factory production to operations on-site.

Technical Guidance

Air emissions are measured and regulated in different ways. Which are summarized below:

Air quality standards: These are the quality guidelines and are the end goal of emissions standards. Good examples are the U.S. National Ambient Air Quality Standards (https://www.epa.gov/criteria-air-pollutants/naaqs-table), the Chinese Ambient Air Quality Standards (GB 3095-2012), or World Health Organization air quality guidelines (http://www.who.int/mediacentre/factsheets/fs313/en). Facilities should not have emissions that result in pollutant concentrations that reach or exceed relevant ambient quality guidelines or contribute a significant portion to the attainment of relevant ambient air quality guidelines. That can only be determined by estimating through qualitative or quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models to assess potential ground level concentrations. Some countries do utilize ground level concentration measurements for regulatory attainment (permitting). 


Emission standards (concentration): Sometimes permits are concentration limits (e.g. ppm, mg/m3). Regulatory authorities may limit emissions concentrations based on overall goals of reducing air pollution. A good example is automobiles. Governments generally regulate concentration limits measured at the exhaust.The same is true for most small combustion facilities (e.g. boiler), which have emissions standards in concentrations (e.g. gas boiler is limited to NOx concentration of 320 ppm measured in stack). Often, permits for these small facilities such as boilers are based on concentrations measured in the stack. These are not quantities, but may be useful in calculations or estimations of quantity.


Emissions standards (quantity): This is the most important and is the actual quantity of emissions from a source. Some regulatory authorities limit the annual quantity of emissions, however, this generally applies to point source emissions that are specifically defined or identified by regulation. Quantity is relevant as it is the total quantity of emissions that ultimately have the impact on the environment, though in many cases, limits or targets based on quality (e.g. concentration) can achieve the goal of limiting the quantity of emissions. The Higg FEM requires quantity of emissions to be entered and therefore it is necessary to calculate or estimate this value.

Regulatory requirements for monitoring of emissions varies depending on the regulatory scheme. Data on emissions and ambient air quality generated through your monitoring program should be representative of the emissions discharged by the process over time. Examples of time-dependent variations in the manufacturing process include batch process manufacturing and seasonal process variations. Emissions from highly variable processes may need to be sampled more frequently or through composite methods. Emissions monitoring frequency and duration may also range from continuous for some combustion process operating parameters or inputs (e.g. the quality of fuel) to less frequent, monthly, quarterly or yearly stack tests. Annual quantities of emissions from variable sources may also need to be determined using engineering estimates or modelling based on the process inputs (e.g. the amount and types of chemicals used in the process)

 An air inventory is needed for the facility to track and manage emissions and their sources. To prepare an inventory, emissions from all processes, ancillary activities and equipment should be included. Regular review should be carried out to make sure the inventory is up-to-date.  This inventory should include emissions sources regulated by permit as well as those not currently regulated (NOTE: this question only requires you to enter data into the Higg FEM for sources that are not regulated or for which you exceed the requirements of the permit, however, your inventory should include all emissions sources). 

 The following elements are suggested to be included in the inventory (source: GSCP):

  • The pollutants known or likely to be present
  • The quantity of each pollutant emitted
  • Emissions/discharge points
  • Any control devices
  • Frequency of monitoring
  • Compliance with legal regulations

 An example inventory can be downloaded here: https://www.sumerra.com/wp-content/uploads/Air-Emissions-Inventory.xlsx

 For each source of stack emissions, a quantity should be calculated.  Facilities can estimate their emissions quantities using one of the emission estimation techniques available.  A good reference for this is National Pollutant Inventory (NPI) Emission Estimation Techniques Manual for Textile and Clothing Industry (http://www.npi.gov.au/system/files/resources/1889355c-bdcc-f7d4-853f-203ddf3652bd/files/ftextile.pdf). The quantities for each pollutant source can be summed together and entered in the Higg FEM. Multiple discharge points from a type of emissions source (e.g. boilers or multiple solvent application processes) can be considered a single emissions source for the purposes of reporting. The appropriate methodology should be applied by qualified individuals such as a process or environmental engineer.

How this will be verified:

Full Points

  • Documentation required
    • A list of inventory of emissions to air for ALL sources
    • Information entered into Higg for each emission source can be verified with appropriate evidence such as equipment sources and quantity
  • Interview questions to ask
    • Management is able to explain the list of sources for emissions to air and how they inventory each source
  • Inspection - things to physically look for
    • Onsite evaluation of air emission sources listed
    • Ensure all applicable equipment is listed on sources list

Partial Points

  • Documentation required
    • Compliance issue documentation from permitting office shows that the issue(s) is less than three months old
    • An action plan is completed for any emissions source found out of compliance
  • Interview questions to ask
    • Management can explain the source of non-compliance and their plans for coming back into compliance
  • Inspection - things to physically look for
    • Any improvements made, or work done to address any non-compliances. Please take pictures. 

2. Select all sources of air emissions that result from production processes

  • Source
  • What pollutants are known or likely to be present?
  • What pollutants are known or likely to be present?
  • What quantity of air emissions were emitted by this source in the last calendar year?
  • What method was used to track emissions from this source?

This question tracks the presence of indoor air quality emissions from production processes. This includes fugitive sources from production processes (sources without a chimney that emit into the building outside through windows, doors, etc.).

Permit compliance does not apply to this question, as indoor air quality emissions are infrequently regulated. 

What is the intent of the question?

The intention of this question is for your facility to know the sources of indoor air quality contaminants and put action and abatement in place to monitor and control them.

Technical Guidance:

You should also include, or create a separate inventory for, emissions generated by production processes that are not captured and discharged in a stack/chimney. These are generally considered fugitive emissions as they are not captured in a stack/chimney for discharge to the outdoors.  This may also include emissions from exhaust ducts that are purposefully discharged back indoors following some level of treatment (e.g. filtration). 

The following elements are suggested to be included in the inventory (GSCP):

  • The pollutants known or likely to be present
  • The estimated quantity emitted
  • Emissions/discharge points or locations
  • Any control devices (e.g. for air that is discharged back indoors)
  • Monitoring conducted
  • Compliance with legal regulations (as applicable)

Fugitive source emissions generally require a different methodology to determine the amount of pollutants emitted. Note that specific regulatory calculation or reporting methodology may be applicable for fugitive sources, however one basic method to calculate the emissions from this type of process is a mass balance method where emissions are estimated based on the the chemical composition of materials used (i.e. percentage of VOC content or individual pollutant) and how much of the chemical is used is used annually (i.e. liters/year).

For example, if the VOC content was 5g/L and the facility used 1,000L annually, the annual emissions would be 5,000g (or 5kg). This methodology can also be used to estimate emissions from individual pollutants. In any case the emission estimation method must be applicable to the source type (e.g. for intermittent activities or high change over with different chemistries the quantity could be estimated based on consumption of solvents annually for that process). 

Here is another example.  A total of 100 L of acetone is used for spot cleaning on an annual basis.  The density of acetone is 784 kg/m3.  If we conservatively estimate that 100% is emitted to the environment, we could calculate that 100 L X (784 kg/m3/1000 L/m3) = 78.4 kg of acetone is emitted annually. 

In order to provide a conservative estimate when creating or reporting  air emissions quantities, it is often estimated that 100% of the volatile pollutants will be emitted to the environment. If a percent composition range is provided (i.e. on and SDS) the upper part of the range can be used.  The quantities for each pollutant source can be summed together and entered in the Higg FEM.   Multiple discharge points from a type of emissions source (e.g. printers) can be considered a single emissions source for the purposes of reporting.

In cases, were emissions are purposefully discharged back indoors, it will be necessary to understand the efficiency of any control devices that may be installed or otherwise conduct measurements of the concentrations of emissions.  For example, if you have a grinding machine that exhausts filtered air back into the indoors you may know that the filter is 95% efficient and the grinder creates a particulate mass concentration of 100 mg/m3 in the exhaust.  In this case, a concentration of 5 mg/m3 is emitted into the indoor air. If the machine emits 10 m3 of air per day, then your total quantity of 50 mg per day. 

All of the examples above are basic examples demonstrating the principles of estimating emissions.  The appropriate methodology should be applied by qualified individuals such as a process or environmental engineer.

How this will be verified:

Yes

  • Documentation required
    • An inventory of emissions to air for ALL sources of emissions from production processes
    • Records (test records or estimations) detailing how the quantity of emissions reported were calculated
  • Interview questions to ask
    • Management is able to explain the list of sources for emissions to air and how they inventory each source
  • Inspection - things to physically look for
    • Onsite evaluation of air emission sources matches what is listed
    • Ensure all applicable equipment is listed on sources list
    • Supporting documentation for test results for all sources of emissions (equipment) for those regulated by a governmental/ accredited agency

3. Did your facility add additional refrigerants to any existing equipment in 2017?

  • Refrigerant
  • Quantity of refrigerant added to existing equipment in the last calendar year
  • What method was used to track emissions from this source?
  • What is your plan for fixing this leak?

 This question will contribute to your GHG-emissions calculation so it’s important for you to enter accurate data about leak quantities. Please note that your GHG result is intended to provide directional insight into your opportunities to improve, but is not a formal GHG calculation to be used for public reporting.

Having to add refrigerants to existing equipment indicates the system has a leak.  If CFC-based refrigerants are maintained in the building, you must reduce annual leakage to 5% or less and reduce the total leakage over the remaining life of the equipment to less than 30% of its refrigerant charge.

What is the intent of the question?

The intent of this question is to evaluate whether your facility has refrigerant leaks because these can be harmful contributors to GHG emissions and climate change due to the relatively high global warming potentials (GWPs) common refrigerants have.

If you do have leaks, it’s important to have an action plan to fix the leaks and/or upgrade equipment to eliminate refrigerant leakage such as CFCs.

Technical Guidance:

If CFCs and HCFCs (ozone depleting substances) are used on-site, solutions to phase out these gases should be considered. One solution is to use chemicals with low-GWP such as HFO’s in the applications of refrigerants, aerosol propellants and foam blowing agents. Please refer to the following list of refrigerants with reference numbers to determine which of your refrigerants are important to track and phase out: https://www.ashrae.org/standards-research--technology/standards--guidelines/standards-activities/ashrae-refrigerant-designations.

CFCs and HCFCs are being phased out under an international agreement, called the Montreal Protocol, in favor of HFCs which are potent greenhouse gases with high GWPs, and they are released into the atmosphere during manufacturing processes and through leaks, servicing, and disposal of equipment in which they are used. Newly developed Hydrofluoroolefins

 (HFOs) are a subset of HFCs and are characterized by short atmospheric lifetimes and low GWPs. HFOs are currently being introduced as refrigerants, aerosol propellants and foam blowing agents.

  • For more information on phasing out Ozone Depleting Substances: https://www.epa.gov/ods-phaseout
  • Substances NOT in scope include:
    • The production and consumption of mineral products such as cement, the production of metals such as iron and steel, and the production of chemicals. (CO2)
    • The production of adipic acid, which is used to make fibers, like nylon, and other synthetic products. (N2O)
    • Production, processing, storage, transmission, and distribution of natural gas and crude oil; and extraction of coal. (CH4)
    • Industrial livestock operations, landfills, and anaerobic treatment of wastewater. (CH4)
    • Agricultural soil management, production and application of synthetic fertilizers, and livestock manure management. (N2O)
    • Forestry Practices and Land Use. (CO2)
    • Perfluorocarbons are compounds produced as a byproduct of various industrial processes associated with aluminum production and the manufacturing of semiconductors. (PFC)
    • HFC-23 is produced as a byproduct of HCFC-22 production. (HFC)

Sulfur hexafluoride is used in magnesium processing and semiconductor manufacturing, as well as a tracer gas for leak detection, and is used in electrical transmission equipment including circuit breakers. (SF6)

For additional resources please visit:

How this will be verified:

Full points

  • Documentation required
    • All refrigerant equipment has a log of equipment servicing including refrigerant replacement that is kept up to date
    • These records must show that no refrigerants were added in 2018
  • Interview questions to ask
    • Can the employee(s) responsible for maintaining the refrigeration equipment describe the process and frequency with which they evaluate the equipment for leaks?
  • Inspection - things to physically look for
    • Well-kept records of equipment maintenance
    • Potential refrigerant leaks 

Partial points

  • Documentation required
    • All refrigerant equipment has a log of equipment servicing including refrigerant replacement that is kept up to date
    • Equipment logs show the date, specific type and amount of refrigeration added
    • The source of the leak(s) was identified
    • An action plan and responsible employee are in place to make sure the leak gets repaired rapidly
  • Interview questions to ask
    • Can the employee(s) responsible for maintaining the refrigeration equipment describe the process and frequency with which they evaluate the equipment for leaks?
    • Can the employee responsible for fixing any leaks describe what work he/she is doing to resolve the issue(s)?
  • Inspection - things to physically look for
    • Well-kept records of equipment maintenance
    • Any evidence that leaks are being addressed by staff responsible for maintaining the equipment 

4. Does your facility have control devices or abatement processes for on-site emissions to air? If yes, select all sources of emissions that have abatement processes.

  • Source

  • What control device, abatement process, or safety equipment was used for this source of air emissions?

  • What was the frequency of monitoring?

Suggested Upload: Emission testing records from control devices or abatement processes.

 Answer Yes only if you have control device(s) installed and in operation for all source of emissions from operations.

 Answer Partial Yes if you have control device(s) installed and in operation for some sources of emissions from operations. This question does not include controls for indoor air quality emissions from production processes. 

What is the intent of the question?

The intent of this question is to understand if the facility has effective controls in place to manage and limit its emissions to air from operations.

 Air pollution control or abatement devices are the techniques used to reduce or eliminate the operational emission into the atmosphere of substances that can harm the environment or human health. Example of the devices include dust collection and extract units (DCE), scrubbers and incinerator.

Technical Guidance:

This question primarily applies to operation processes (e.g. utilities) with point source/stack emissions.  For example, this includes boilers and similar equipment. Controls on these emissions may include dust collectors, scrubbers, incinerators, etc.  This also includes the exhausting of emissions from production processes to the environment through designated exhaust stacks/vents. 

Monitoring and maintenance of control and abatement devices should be included in your factory’s preventative maintenance program and in the checklists for ongoing visual inspections so that any problems can be identified promptly. 

The effectiveness and efficiency of your control devices is typically evidenced through monitoring/testing data. Therefore in the case that no regular monitoring is conducted, facilities should answer No to this question.  

Scoring: Full credit will be given based on the extent that the facility has abatement processes or controls processes (when technically applicable) for all identified or potential point source/stack emissions to air that result in lesser quantities of emissions that would otherwise be found if no controls were in place.  This obviously requires confirmation and therefore monitoring/testing data as noted above. 

How this will be verified:

Yes

  • Documentation required
    • Schematics, descriptions or procedures for control devices or abatement processes
    • Records of calibration and maintenance for control devices listed
  • Interview questions to ask
    • Management and responsible employees are able to describe the control devices or abatement processes are in place at the facility and how they reduce emissions
  • Inspection - things to physically look for
    • Review the list of the control devices in the facility are in fact where they should be and are in operation and good working condition (per regular maintenance and observation by responsible staff) for all sources of emissions from operations

Partial Yes

  • Same as “yes” but control devices installed for some but not all sources of emissions from operations. 

Reference: This question can be used to inform responses to The Sustainability Consortium's Home and Apparel Textiles Toolkit. The Air Quality - Manufacturing Key Performance Indicator asks respondents if annual air emissions are tracked and reported by final manufacturing facilities. The facility data can be aggregated by brands to answer TSC's question. 

5. Does your facility have control devices or abatement processes for indoor air quality issues from production processes? If yes, select all sources of air quality issues that have abatement processes.

  • Source
  • What control device, abatement process, or safety equipment was used for this source of air emissions?
  • What was the frequency of monitoring?

 Suggested Upload: Emission testing records from control devices or abatement processes.

 Answer Yes only if you have control devices installed and in operation for all sources of emissions from production processes.

Answer Partial Yes if you have control devices installed and in operation for some sources of emissions from production processes.

What is the intent of the question?

The intent of this question is to understand if the facility has effective controls in place to manage and limit its emissions to air from production process.

Air pollution control or abatement devices are the techniques used to reduce or eliminate the emission into the atmosphere of substances that can harm the environment or human health. Example of the devices include solvent recovery unit.

 Technical Guidance:

This question primarily applies to the non-operational aspects such as production processes that generate emissions that impact indoor air quality.  Some examples of production processes that produce emissions include: 

  • Digital printing units which are producing their own colorants / inks by dissolving the solid colorants (acid, reactive and disperse dyes usually) using solvent systems which includes, glycols, dioxanes among others in house.
  • Coating / lamination units which use solvents
  • Embroidery yarn dyeing units which typically use viscose filament yarn using vat dyes in powder form
  • Footwear assembly units which use spraying systems to color the soles
  • Leather coating / spraying units which use liquid dispensing chambers
  • Transfer printing units which use solvents
  • Dry cleaning processes using halogenated solvents
  • Potassium permanganate (PP) spraying units
  • Molding units which use lamination or fusing processes etc.
  • Curing the fabric/ apparel after dyeing
  • Other solvent or adhesive applications (e.g. gluing or priming) 

Controls for these emissions include fume hoods, local exhaust ventilation, solvent recovery systems, adsorption devices, or filters/bag houses capturing the dust / flock etc. 

Monitoring and maintenance of control and abatement devices shall be included in your factory’s preventative maintenance program and also in the checklists for ongoing visual inspections and other required testing so that any problems could be identified promptly. 

Scoring: Full credit will be given based on the extent that the facility has abatement processes or controls (when technically applicable) for all identified or potential fugitive emissions to air that result in lesser quantities of emissions that would otherwise be found if no controls were in place.

How this will be verified:

Yes

  • Documentation required
    • Schematics, descriptions or procedures for control devices or abatement processes
    • Records of calibration and maintenance for control devices listed
  • Interview questions to ask
    • Management and responsible employees are able to describe the control devices or abatement processes are in place at the facility and how they reduce emissions
  • Inspection - things to physically look for
    • Review the list of the control devices in the facility are in fact where they should be and are in operation and good working condition (per regular maintenance and observation by responsible staff) for all sources of emissions from production processes. 

Partial Yes

  • Same as “yes” but control devices installed for some but not all sources of emissions from production processes.

 

 

Air Emissions - Level 2

6. Has your facility gone beyond permit requirements to achieve a higher level of air performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx), and Particulate Matter (PM)?

  • If yes, specify the level.

 Upload emissions testing results for PM, SO2, and NOx

 Higg encourages air emissions performance that goes beyond compliance. However, there is not currently an air standard that exists for the apparel, footwear, and textiles industry. For now, members of the Sustainable Apparel Coalition have aligned on three levels of performance for air pollutants generated from boilers and generators that we encourage all users to aim to achieve. If an industry air standard becomes available, we will update the tools accordingly.  

What is the intent of the question?

The intent of this question is to demonstrate whether your facility has improved air emissions from combustion devices beyond compliance.

Technical guidance:

Meeting an Air Standard: Air emissions are typically managed to a specified limit as set by local regulations. However in sustainability, it is important to improve beyond compliance to the most aspirational level of air performance possible. Currently, there is no existing air standard for the industry, so The Higg Index Air section leverages a collaboratively-developed set of limits that are aligned with the best available air pollutant guidance.

 The Higg FEM Air section encourages you to reduce pollutant limits as far as possible by setting three levels of limits for combustion devices (e.g., boilers and generator) emitting Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate Matter (PM). These limits were identified by leveraging IFC’s Small Combustion Facilities Emissions Guidelines (link: https://www.ifc.org/wps/wcm/connect/532ff4804886583ab4d6f66a6515bb18/1-1%2BAir%2BEmissions%2Band%2BAmbient%2BAir%2BQuality.pdf?MOD=AJPERES) and standards from Sri Lanka, Belgium, Australia, Germany (more than 50 MW), Japan, and India. SAC or another industry organization will refine these limits over time or replace with another standard if such a standard emerges for the apparel industry.

 You can assess different opportunities in reducing emissions at source against these levels of emission limits. Examples include boiler retrofit to use cleaner fuel, improving control device to reduce emissions, etc.

 Draft Air Standard for Boilers and Generators (Unit of measure: mg/Nm3): 

Small (less than 50 MW)

 

Level 1

Foundational

Level 2

Strategic

Level 3

Aspirational

PM

150

100

50

SO2

2000

1000

400

NOx

650

300

200

Medium (50 MW - 300 MW)

 

Level 1

Level 2

Level 3

PM

150

80

50

SO2

1500

1000

200

NOx

600

300

150

Large (greater than 300 MW)

 

Level 1

Level 2

Level 3

PM

100

50

30

SO2

850

600

150

NOx

510

200

150

How this will be verified:

Yes

  • Documentation required
    • Emission testing results which show facility has gone beyond permit requirements to achieve a higher level of air performance in Nitrogen Oxides (NOx), Sulfur Oxides (SOx), and Particulate Matter (PM) as outlined per the level selected (please refer to HowtoHigg.org for specific level requirements)
    • A plan in place or project description of what was done to achieve it. This should include list of equipment and/or process changes along with records for the change in emissions resulting from improvements made.
  • Interview discussion
    • Management is able to explain the actions resulting in the facility going above and beyond permit requirements
  • Inspection - things to physically look for
    • Reference items listed in plan including equipment or processes used for achieving higher level of air performance.

 

Air Emissions - Level 3 

7. Do you have a process for implementing modernized equipment to reduce or eliminate air emissions and indoor air quality issues at your facility?

 Upload: Documentation of plans/process for equipment upgrades or documentation of recent upgrades

 Select Yes if you have a documented plan to upgrade machinery or if all machinery has been upgraded to the most modern version as that is one of the best ways to control pollutants and achieve a higher level of air performance.

What is the intent of the question?

The intent is for a facility to be able to share or demonstrate advanced practices to control air pollutants.

Modernizing equipment is an effective way to reduce or eliminating air emissions and indoor air quality issue. You can carry out feasibility studies to identify and assess the possibility to upgrade equipment (e.g. replacing equipment, modifying existing equipment, further optimizing abatement equipment, etc.) to reduce emissions (GSCP). 

Technical Guidance:

Older equipment often does not utilize the best available technology (BAT) for air emissions controls.  Therefore, older equipment may result in greater air emissions than newer, more modern, equipment.  Modernizing machinery means retrofitting existing machinery with newer technologies for controlling air emissions or purchasing new equipment with more advanced technologies for controlling air emissions.  

 One example of modernizing machinery is to upgrade refrigeration and/or air conditioning systems so that it is compatible for using refrigerants with lower GWP, or substituting ODS with more environmental friendly refrigerants.

 Another example is the procurement of a new boiler or generator which is powered by cleaner fuels and thus results in less air emissions.

How this will be verified:

Yes

  • Documentation required
    • Documentation of plans/process for equipment upgrades or documentation of recent upgrades
    • List of recent equipment upgrades (if applicable)
  • Interview questions to ask
    • Management is able to describe plan/process for equipment upgrades or documentation of recent upgrades.
  • Inspection - things to physically look for
    • Verify equipment upgrades in facility against plan in place

 

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