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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 Higg questions that are most applicable for your facility. If you don’t have any facility operation or production air emissions, 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 take the time to accurately complete 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

We have all seen smog clouds over our city and know that smog is unhealthy for humans and the environment. This visible pollution is one result of air emissions from your factory, but air pollution can also be invisible...and just as damaging to people and the environment.  

Facility air emissions are commonly generated from:

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

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

Your factory’s discharge 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

How should you go about approaching air emissions?

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 higher 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. 

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.

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 all levels
  • 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
    • Engines
    • Ovens
    • Heating and ventilation
    • Refrigerant device
    • Air conditioning
    • Other sources of known air emissions from facility operations

2Does your facility conduct any of the following processes or use any of the following substances?

  • Yarn spinning or synthetic fiber manufacturing
  • Finishes
  • 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 - 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.

Note: 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

The first step is for the facility to make sure the emission to air are compliant with applicable legal requirements. An air inventory is needed for the facility to track and manage emissions and their sources. To prepare an inventory of 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.

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

  • The pollutants known or likely to be present
  • The quantity emitted
  • The location of emissions
  • Any control devices
  • Frequency of monitoring
  • Compliance with legal regulations 

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.

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.

Recognized sources for air emission limits and guidance include:

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 amounts
    • 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
    • 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
    • Management can explain the source of non-compliance and their plans for coming back into compliance
    • Any improvements made or work done to address any non-compliances. Please take pictures. 
    • Documentation required
    • Interview questions to ask
    • Inspection - things to physically look for

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

  • Source
  • 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 intent of this question is for your facility to know the sources of indoor air quality contaminates and put abatement actions in place to monitor and control these pollutants.

Technical Guidance:

The first step is to make sure facility emissions to air are compliant with applicable legal requirements. An air inventory is needed for the factory to maintain and track the emissions and their sources accordingly. To prepare an inventory, you shall include emissions from all processes, ancillary activities and equipment. Regular review should be carried out to make sure the inventory is up-to-date. 

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

  • The pollutants known or likely to be present
  • The quantity emitted
  • The location of emissions
  • Any control devices
  • Frequency of monitoring
  • Compliance with legal regulations 

GHG emissions are not just 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 following 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. For a more detailed overview of Greenhouse Gas Emissions please visit: https://www.epa.gov/ghgemissions/overview-greenhouse-gases.  

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 2017
    • Interview questions to ask
      • Can the employee(s) responsible for maintain 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 maintain 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.

Answer Partial Yes if you have evidence of plans to install control devices

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:

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. 

Frequency of Monitoring: Data on emissions and ambient air quality generated through the monitoring program should be representative of the emissions discharged by the project 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. 

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 responsbile 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)
  • Partial Yes
    • There is a plan in place to install control devices or implement abatement processes for onsite emissions to air and intial steps are being taken to implement that plan (e.g. invoices for purchased equipment or contracts with contractors)
    • Management can explain the plan for installing control devices or implementing abatement processes for onsite emissions to air
    • Evidence to support there is a plan to install control devices or implement abatement processes for onsite emissions to air  (e.g. purchased but not installed equipment, construction work in preparation of installations, trained staff, etc.)
    • Documentation required
    • Interview questions to ask
    • Inspection - things to physically look for

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 aggregrated 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 device(s) installed and in operation.

Answer Partial Yes if you have evidence of plans to install control devices

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:

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 so that any problems could be identified promptly.

Frequency of Monitoring: Data on emissions and ambient air quality generated through the monitoring program should be representative of the emissions discharged by the project 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. 

Scoring: Full credit will be given based on the extent that the facility has abatement processes (when technically applicable) for all emissions to air. 

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)
  • Partial Yes
    • Documentation required
      • There is a plan in place to install control devices or implement abatement processes to improve indoor air quality and initial steps are being taken to implement that plan (e.g. invoices for purchased equipment or contracts with contractors)
    • Interview questions to ask
      • Management can explain the plan for installing control devices or implementing abatement processes for improving indoor air quality
    • Inspection - things to physically look for
      • Evidence to support there is a plan to install control devices or implement abatement processes for improving indoor air quality
      • r  (e.g. purchased but not installed equipment, construction work in preparation of installations, trained staff, etc.

AIR - 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

The Higg Index 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 that we encourage all users to aim to achieve. If an industry air standard becomes available, we will update the tools accordingly. Please click the guidance icon to view our air performance levels.

What is the intent of the question?

The intent of this question is to demonstrate whether your facility has improved air emissions 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 (Unit of measure: mg/Nm3):

Small

less than 50 MW

 

Level 1

Foundation

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

more 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 - 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:

One example of modernizing machinery is to upgrade refrigeration and/or air conditioning system so that it is compatible for using refrigerants with lower GWP, or substituting ODS with more environmental friendly gases. Factory can also procure new boiler or generator which is powered by cleaner fuels. 

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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