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Wastewater

Wastewater  

Wastewater can be a significant contributor of pollution and contamination for surrounding natural systems and communities if not managed, treated and discharged properly. All facilities have some form of wastewater:

  • Domestic use: toilets, showers, kitchens, cleaning, etc.
  • Industrial use: production, lubrication, cooling, blowdown from compressors or boilers, maintenance, cleaning production machines, etc.

Before answering assessment questions, you will first be asked to define your facility’s approach to wastewater treatment and discharge. The following use and treatment methods will determine which Wastewater questions will need to be submitted for your facility:

  • Industrial and/or domestic wastewater?
  • Offsite treatment, onsite treatment, both onsite and offsite treatment, or Zero Liquid Discharge?

The Higg Wastewater section requires you to:

  • Track quantity of wastewater generated from industrial and/or domestic operations
  • Report all wastewater quality parameters that were found to not meet permits or industry standard(s), such as the ZDHC Wastewater Guideline, in the most recent quality test
  • Report name and quality results from the offsite wastewater treatment plant (if applicable)
  • Describe backup process if regular treatment fails (if applicable)
  • Ensure proper sludge disposal (if applicable)
  • Report whether your site reuses and/or recycles process wastewater as process water (if applicable)

Wastewater Introduction

This section refers to water leaving a site that is not intended for reuse within your facility. Wastewater can be a significant cause of environmental pollution if not handled, stored, transferred, treated, and/or disposed of appropriately.  

If your facility uses water for any aspect of its operations, there will be some form of industrial wastewater or liquid discharge.  This includes all manufacturing and/or commercial activities within your facility site’s footprint, such as industrial processing, lubrication, cooling, maintenance, cleaning, and domestic use (e.g., dormitories, bathrooms, showers, kitchens).  If any of these exist within a facility then the site has some form of wastewater and associated discharges and effluents. 

Wastewater discharge can take on many forms:

  • process (or “trade”) effluents arising from various stages of an industrial, agricultural, or commercial process;
  • cooling wastewater or other non‐contact wastewater (e.g., flushing chillers);
  • blow‐down (e.g., from compressors, boilers);
  • sanitary / domestic wastewater (e.g., from toilets, sinks etc.).

Other types of liquid discharge include:

  • storm water run‐off (sometimes referred to as surface water run‐off) from roofs, hard standing areas, car parks, etc.);
  • firewater

Decisions about the most appropriate or efficient options for managing wastewater (e.g. on‐site treatment, off‐site treatment options for reuse, etc.) will depend on a number of factors, including:

  • Facility location
  • External infrastructure availability
  • Volume of wastewater generated
  • Composition of wastewater
  • On‐site (or off‐site) reuse of treated wastewater
  • Cost
  • Local regulatory requirements

The quantity and quality of the wastewater to be treated will influence/govern the treatment or disposal options for that wastewater stream. For example, there can be significant differences in:

  • Wastewater volume and flow rate
  • Total suspended solids (TSS) content
  • Biological oxygen demand (BOD)
  • Chemical oxygen demand (COD)
  • Potential Toxicity (e.g. from chemicals, medicines/antibiotics etc.)
  • Heavy metal content (e.g. antimony, arsenic, cadmium, chromium, cobalt, copper, cyanide, lead, mercury, nickel, zinc, etc.)
  • pH (acidity / alkalinity)
  • Color
  • Temperature
  • Surfactants
  • Nitrogen and phosphorous content
  • Oil and grease, amongst other 

On-site wastewater treatment is the wastewater treatment plant used and managed by the factory only. After treated by the on-site treatment, the wastewater can meet with relevant limits and be directly discharged into the environment, or into an Off-site 3rd party treatment plant (known as partial onsite treatment). 

Off-site wastewater treatment is a third party enterprise or organization who provides wastewater treatment service for more than two pollutant discharging entities by collecting their wastewater, and the wastewater discharged directly to environment should meet with the relevant limits. The off-site treatment can be public wastewater treatment facility, regional wastewater treatment facility (i.e. industrial park, industry area etc.) 

Zero-liquid discharge (ZLD) is a water treatment process in which all wastewater is purified and recycled; therefore, leaving zero discharge at the end of the treatment cycle. ZLD is an advanced wastewater treatment method that includes ultrafiltration, reverse osmosis, evaporation/crystallization, and fractional electrodeionization. (Source: http://www.aquatech.com/solutions/zero-liquid-discharge/)

Reference to Industry Standards

One of our partner organizations, the Zero Discharge of Hazardous Chemicals (ZDHC) group, has developed a Wastewater Guideline for our industry to use as a guideline to manage wastewater and drive the industry toward the goal of zero discharge of hazardous chemicals.  In FEM 3.0 you will find mention of industry standards, and the ZDHC Wastewater Guideline is one of such standards.  

Wastewater – Level 1

1. Does your facility track its industrial wastewater volume?

  • What was the total quantity of industrial wastewater discharged from your facility in 2017?
  • Which method was used to track industrial wastewater volume?
  • What was the frequency of measurement?
  • What was the final discharge point for your facility’s industrial wastewater?

Suggested Upload: Annual wastewater production monitoring record (quality and quantity)

Wastewater generated includes water that is either discharged, reclaimed/recycled or reused at your site. Please include all manufacturing and/or commercial activities within your facility site’s wastewater generation, including domestic use, as well as wastewater/effluent from dormitories, bathrooms, showers, and kitchens.

What is the intent of the question?

The intent of this question is to ensure that the site knows how much wastewater is being produced and where it is discharged to. By answering this question, facilities can demonstrate how they monitor and manage wastewater volume.  Knowing your volume is an important first step to making decisions on appropriate treatment options.

Wastewater tracking allows complete visibility into daily operations of a facility and what operations impact wastewater volumes. Knowing your wastewater volume is directly linked to ecological impact and operational costs.  Most facilities track process wastewater, but tracking domestic wastewater discharges is important as well.  Consider all the domestic wastewater sources: showers, faucets, toilets, sinks, kitchens, dishwashers, icemakers all contributing to wastewater volume and quality.  Identifying peak volumes for wastewater in a fully operational facility influences wastewater treatment design and operations.

Technical Guidance

  • Wastewater generated includes water that is either discharged, reclaimed/recycled or reused at your site.
  • Please include all manufacturing and/or commercial activities within your facility site’s wastewater generation, including domestic use, as wastewater/effluent from dormitories (e.g., bathrooms, showers, kitchens.) when answering.
  • List the following items for each source:
    • What type of wastewater does your site discharge? (e.g., Industrial)
    • Amount:
      • Industrial: 20,000m3 (Process effluent from Finishing)
      • Domestic water: 19,000m3 (Water from toilets, showers in the dormitory)
    • How frequently does your site measure wastewater volume? (Weekly)
    • What methodology does your facility use to measure wastewater volume? (Water meter)
    • Final Discharge Point (Offsite 3rd party treatment plant) 

How this will be verified:

  • Expectations for Yes  
    • Documentation required
      • Your site tracked the wastewater generated at your facility for the last calendar year for all sources of wastewater
      • Annual wastewater production monitoring record
      • Meter readings or utility bills that verify the accuracy of the annual wastewater production monitoring record
    • Inspection - things to physically look for
      • Is wastewater/effluent directed to a wastewater/effluent treatment plant or does it undergo treatment prior to discharge?
      • Are surface water/storm water drains free from contamination and blockages?
      • Are procedures established to manage wastewater/wastewater discharges being followed? (e.g. management of wastewater, activities etc.)
      • Are spills or leaks to the environment observed?
      • Are the boilers blow down and other membrane cleaning activities where water is collected and tracked as well?
      • Are the flowmeters in place working (in case the facility has select the “meters” method), calibrated and accessible?
      • A picture of flowmeters as evidence has to be taken during the site inspection
      • In the case of estimated data, please verify the water balance is based on available flow meters, equalization tank volumes, flow rate timing, etc.
      • Verify invoices for incoming water and discharge estimation

2. Does your facility track its domestic wastewater volume?

  • What was the total quantity of domestic wastewater discharged from your facility in 2017?
  • Which method was used to track domestic wastewater volume?
  • What was the frequency of measurement?
  • What was the final discharge point for your facility’s domestic wastewater?

Suggested Upload: Annual wastewater production monitoring record (quality and quantity)

Wastewater generated includes water that is either discharged, reclaimed/recycled or reused at your site. Please include all manufacturing and/or commercial activities within your facility site’s wastewater generation, including domestic use, as well as wastewater/effluent from dormitories, bathrooms, showers, and kitchens.

What is the intent of the question?

The intent of this question is to ensure that the site knows how much wastewater is being produced and where it is discharged to. By answering this question, facilities can demonstrate how they monitor and manage wastewater volume.  Knowing your volume is an important first step to making decisions on appropriate treatment options. 

Wastewater tracking allows complete visibility into daily operations of a facility and what operations impact wastewater volumes. Knowing your wastewater volume is directly linked to ecological impact and operational costs.  Most facilities track process wastewater, but tracking domestic wastewater discharges is important as well.  Consider all the domestic wastewater sources: showers, faucets, toilets, sinks, kitchens, dishwashers, icemakers all contributing to wastewater volume and quality.  Identifying peak volumes for wastewater in a fully operational facility influences wastewater treatment design and operations.

Technical Guidance

Tracking flow rate and discharge volume of domestic wastewater is not an uncommon practice.  The behavior we are looking for with asking this is to show that a facility understands how much water is being wasted/ leaving their facility and they are applying that volume to an assessment of water use in your facility.  

If domestic wastewater discharge metering data or actual discharge data is not available, factory could consider estimating wastewater discharge based on actual freshwater purchase (with assumption that all freshwater purchased is equivalent to the amount of wastewater discharge). 

Water use in a facility can also be estimated by number of persons, types of facilities, kitchen, toilet, shower, irrigation etc. For example, auto wastewater calculation tool for estimating domestic wastewater production based on number of persons, number of washrooms/sinks/kitchens/irrigation/percentage of leakage (for example: http://www.ca.kohler.com/savewater/calculators/commercial.htm#top

Given estimation methods are available, however, without the understanding of output as compared to input and use, significant unseen leaks can potentially go undetected.

How this will be verified:

  • Expectations for Yes  
    • Documentation required
      • Your site tracked the wastewater generated at your facility for the last calendar year for all sources of wastewater
      • Annual wastewater production monitoring record
      • Meter readings or utility bills that verify the accuracy of the annual wastewater production monitoring record
    • Inspection - things to physically look for
      • Is wastewater/effluent directed to a wastewater/effluent treatment plant or does it undergo treatment prior to discharge?
      • Are surface water/storm water drains free from contamination and blockages?
      • Are procedures established to manage wastewater/wastewater discharges being followed? (e.g. management of wastewater, activities etc.)
      • Are spills or leaks to the environment observed?
      • Are the boiler blow down and other membrane cleaning activities where water is collected and tracked as well?
      • Are the flowmeters in place working (in case the facility has select the “meters” method), calibrated and accessible?
      • A picture of flowmeters as evidence has to be taken during the site inspection
      • In the case of estimated data, please verify the water balance is based on available flow meters, equalization tank volumes, flow rate timing, etc.
      • Verify invoices for incoming water and discharge estimation 

3. Does your facility track its combined (industrial and domestic) wastewater volume?

  • What was the total quantity of combined wastewater discharged from your facility in 2017?
  • Which method was used to track combined wastewater volume?
  • What was the frequency of measurement?
  • What was the final discharge point for your facility’s combined wastewater? 

Suggested Upload: Annual wastewater production monitoring record (quality and quantity)

Wastewater generated includes water that is either discharged, reclaimed/recycled or reused at your site. Please include all manufacturing and/or commercial activities within your facility site’s wastewater generation, including domestic use, as well as wastewater/effluent from dormitories, bathrooms, showers, and kitchens.

What is the intent of the question?

The intent of this question is to ensure that the site knows how much wastewater is being produced and where it is discharged to. By answering this question, facilities can demonstrate how they monitor and manage wastewater volume.  Knowing your volume is an important first step to making decisions on appropriate treatment options.

Wastewater tracking allows complete visibility into daily operations of a facility and what operations impact wastewater volumes. Knowing your wastewater volume is directly linked to ecological impact and operational costs.  Most facilities track process wastewater, but tracking domestic wastewater discharges is important as well.  Consider all the domestic wastewater sources: showers, faucets, toilets, sinks, kitchens, dishwashers, icemakers all contributing to wastewater volume and quality.  Identifying peak volumes for wastewater in a fully operational facility influences wastewater treatment design and operations. 

Technical Guidance

  • Wastewater generated includes water that is either discharged, reclaimed/recycled or reuse at your site.
  • Please include all manufacturing and/or commercial activities within your facility site’s wastewater generation, including domestic use, as wastewater/effluent from dormitories (e.g., bathrooms, showers, kitchens.) when answering.
  • List the following items for each source:
    • What type of wastewater does your site discharge? (e.g., Combined Domestic and Industrial)
    • Amount:
      • Combined industrial and domestic: 39,000m3 (Combining process effluent from finishing and water from toilets and showers in the dormitory)
    • How frequently does your site measure wastewater volume? (Weekly)
    • What methodology does your facility use to measure wastewater volume? (Water meter)
    • Final Discharge Point (Offsite 3rd party treatment plant) 

How this will be verified:

  • Yes  
    • Documentation required
      • Your site tracked the wastewater generated at your facility for the last calendar year for all sources of wastewater
      • Annual wastewater production monitoring record
      • Meter readings or utility bills that verify the accuracy of the annual wastewater production monitoring record
    • Inspection - things to physically look for
      • Is wastewater/effluent directed to a wastewater/effluent treatment plant or does it undergo treatment prior to discharge?
      • Are surface water/storm water drains free from contamination and blockages?
      • Are procedures established to manage wastewater/wastewater discharges being followed? (e.g. management of wastewater, activities etc.)
      • Are spills or leaks to the environment observed?
      • Are the boiler blow down and other membrane cleaning activities where water is collected and tracked as well?
      • Are the flowmeters in place working (in case the facility has select the “meters” method), calibrated and accessible?
      • A picture of flowmeters as evidence has to be taken during the site inspection
      • In the case of estimated data, please verify the water balance is based on available flow meters, equalization tank volumes, flow rate timing, etc.
      • Verify invoices for incoming water and discharge estimation 

4. Please indicate which wastewater guideline(s) you are reporting against:

  • Permit
  • Wastewater Standard (e.g., ZDHC Wastewater Guideline or other)

For each guideline, provide detailed information on any detections found, including action plans for improvement. If you are reporting to a wastewater guideline you will receive additional points for achieving higher levels of wastewater performance. Please see How to Higg for more detailed information on wastewater guidelines.

Uploads: Test report(s)

If Permit is selected:

  • Is your facility in compliance with its permit and/or contractual agreements? E.g. with the offsite wastewater treatment plant

If Wastewater Standard (e.g., ZDHC Wastewater Guideline or other) is selected:

  • Which wastewater standard are you using?
    • ZDHC Wastewater Guideline
    • BSR
    • IPE
    • Customer/Brand
    • Other

If BSR, IPE, Customer/Brand, or Other were selected:

  • Have you tested and met all parameters specified in the standard?

If ZDHC Wastewater Guideline was selected:

  • Have you tested and met all parameters specified in the guideline? 
  • Which level did your facility meet for conventional parameters in 2017, based on the ZDHC Wastewater Guidelines?
  • Does your test result also show no detection of parameters in Table 2A-N Chemical Groups?

Your factory will only move on to Level 2 and 3 questions if facility is in compliance with permits.

What is the intent of the question?

This question is intended to ensure that your site understands its current performance with wastewater quality. Data reported in this question will help inform Level 2 performance against a higher standard.

The quality of the water discharged by your facility is directly linked to ecological impact and operational costs. It also is directly related to compliance at a facility along with potential disclosure requirements for industry organization transparency.

What is the optional ZDHC Wastewater Guideline?

The Zero Discharge of Hazardous Chemicals (ZDHC) Wastewater Guideline is an OPTIONAL guideline that some brands are requiring of their customers. If you have not heard of ZDHC from your customers, please disregard this reference - you WILL NOT BE PENALIZED if you do not answer the last column in the table for WW-2.1.  

The Zero Discharge of Hazardous Chemicals (ZDHC) Programme is a collaboration of brands, value chain affiliates and associates that releases a ZDHC Wastewater Guideline, which is a unified expectation on wastewater quality for the entire textile and footwear industry. If you would like more information on ZDHC, you may peruse their website and guideline here: http://www.roadmaptozero.com/news/post/zdhc-releases-wastewater-guidelines-to-coordinate-industry-efforts-eliminate-hazardous-chemicals/

Technical Guidance:

1)   Report all parameters for which you have found a detection / are over the limit. We only are seeking to collect information on wastewater problems in order to prioritize action rather than incentivize data reporting.

2)   For Permits:

  • Select Permits
  • Enter results for parameters not met (type number and select unit).
  • Enter limit required by the permit or standard (e.g., limits listed in ZDHC Wastewater Guideline at Foundational level)

3) For Wastewater:

  • Select standard used
  • Enter results for parameters not met (type number and select unit).
  • Enter limit required by the permit or standard (e.g., limits listed in ZDHC Wastewater Guideline at Foundational level)
  • If you choose ZDHC Wastewater Standard, you will be asked an additional set of UNSCORED questions about whether test parameters listed in the ZDHC Wastewater Guidelines been detected in your site's wastewater test report. Note that incoming water testing is also recommended in case of detection of any detox parameter. 

How this will be verified:

  • Yes
    • Documentation required
      • Wastewater test report showing the parameters tracked by the facility (Treated effluent and untreated effluent)
      • Documentation showing that the parameters are recorded and analyzed
      • Sample procedures document
    • Interview questions to ask
      • Are key employees aware of the wastewater discharge points in the facility?
      • Is there a mechanism for employees to identify to management when wastewater is not properly being discharge?
      • Are key employees who deal with the sample procedures properly trained? How often?
    • Inspection - things to physically look for
      • Are sumps/pits receiving wastewater are in good condition and of sound integrity?
      • Are surface water/storm water drains free from contamination and blockages?
      • Are procedures established to manage wastewater/wastewater discharges are being followed? (e.g. management of wastewater, activities etc.)
      • Please provide pictures for each treatment step of the ETP
  • Partial Yes
    • Documentation required
      • Note that table will automatically generate partial points awarded to facility
      • Wastewater test report showing the parameters tracked by the facility
      • Documentation showing that the parameters are recorded and analysed
      • Sample procedures document
    • Interview questions to ask
      • All of the interview questions from yes section above for items tracked
    • Inspection - things to physically look for
      • All of the inspections items listed in the yes section above for items tracked
      • Please provide pictures for each treatment step of the ETP

5. Do you have the name and contact information of the offsite wastewater treatment plant?

  • Name:
  • Address:
  • Ownership:
  • Do you have a copy of the contract with the wastewater treatment plant?
  • Please upload documentation if available

Upload: a) Signed contract with the offsite wastewater treatment plant; b) A permit for your facility to show that they are allowed to discharge into the offsite wastewater treatment plant

This information is important because environmental contamination from improper treatment must be addressed regardless of where the problem originates. This information can help your factory, the community, and local businesses prevent or cleanup accidental environmental contamination in the case of a failure. 

You will receive full points if you know your wastewater treatment plant and are able to upload a contract. Please note that a contract will be required during verification for all factories in China.

What is the intent of the question?

The intent of this question is for the facility to have a relationship and be able to communicate with the wastewater treatment plant.  This also enables troubleshooting and supports continuous improvement. 

This information is important because environmental contamination from treatment problems must be addressed regardless of where the problem originates. This information can help the community and businesses prevent or cleanup accidental environmental contamination in the case of a failure.

How this will be verified:

  • Yes
    • Documentation required - already checked during permit section
      • Signed contract with the offsite wastewater treatment plant
      • A permit for your facility to show that you are allowed to discharge into the offsite wastewater treatment plant
    • Interview questions to ask
      • Check for basic details of the offsite wastewater treatment plant like layout, treatment type (primary, secondary tertiary), etc.
      • Does management have a process in place to renew the contract with the 3rd party off site treatment plant?

6.  Does your facility have a back-up plan if there is an emergency situation related to wastewater?

Select all strategies included in your facility's back-up plan for wastewater

  • Emergency Production Shutdown
  • Holding Tank
  • What is the size of your facility’s holding tank?
  • Secondary Treatment
  • Discharge to Offsite Water Treatment Plant
  • Other Backup Process
  • If other, please describe
  • Please upload documentation if available

What is your facility’s wastewater treatment handling capacity per day?

Upload: Documented back-up process that is sufficient to treat the average daily amount of wastewater discharged by the facility site.

It is critical that your facility have a backup plan in the event of a wastewater treatment failure in order to prevent untreated effluent from being discharged to the local environment. If you do not have a backup process that can handle your average daily capacity, you cannot score points or complete Level 1.

What is the intent of the question?

This question promotes a contingency plan in the event the treatment process fails to prevent untreated effluent from being discharged. If you do not have a back-up process in place, you cannot complete Level 1 as this is critical to preventing accidental environmental contamination in the case of a failure. 

This is critical to prevent accidental environmental contamination in the case of a failure. 

Technical Guidance:

The facility needs to set up and document contingency plan in response to emergencies. It is important to know the wastewater treatment handling capacity per day and the size of holding tank (if facility has holding tank). This information should be compared with wastewater quantities to determine whether you can hold the wastewater during emergency. Holding tanks should not be considered for an exclusive back-up measure.

How this will be verified:

  • Yes
    • Documentation required
      • Documented back-up process that is sufficient to treat the average daily amount of wastewater discharged by the facility site. This should outline either the emergency production shutdown procedures or/and the type of treatment, availability of treatment, procedures for putting back up treatement into operation, responsible person or people for delivering these operations, etc.
      • Any schematics describing the back up treatment options and capacity
    • Interview questions to ask
      • The key employee responsible for the wastewater treatment can articulate what the back-up plan is and demonstrate how and when it would be put into effect
      • Has this back up system been needed? When and why?
    • Inspection - things to physically look for
      • Request the documented back up plan and verify if the area is preset as per the plan
      • Take a picture of the plan, equipment (if on-site), and/or contract (if off-site)

7. Is hazardous sludge (chemical / industrial) disposed of properly? 

How is your sludge disposed of?

  • Hazardous Waste Treatment
  • Incinerated controlled conditions
  • Landfilled
  • Open burning
  • Fuel Blended
  • Composted
  • Fertilizer (applied to land)

Suggested Upload: a) Sludge analysis or test results (if non-hazardous is selected); b) permits or manifests for proper disposal or land application.

If you have hazardous sludge it must be disposed of through a licensed hazardous waste contractor or through incineration under properly controlled conditions.

What is the intent of the question?

You should know if there are any chemical or industrial hazards present in your operations, and, if there are, you need to make sure you do not dispose of these hazards improperly.  

Hazardous sludge needs to be disposed of properly to avoid contaminating the environment. If you put hazardous sludge onto land or burn it openly, you can release serious hazards into the environment.

Technical Guidance:

Sludge should be properly disposed through authorized agent or facility should have licensed by local pollution board to decompose it in premises.  Chemicals should be handled and disposed in accordance with MSDS section 13.  

What is the intent of the question?

You should know if there are any chemical or industrial hazards present in your operations, and, if there are, you need to make sure you do not dispose of these hazards improperly.  

Hazardous sludge needs to be disposed of properly to avoid contaminating the environment. If you put hazardous sludge onto land or burn it openly, you can release serious hazards into the environment.

Technical Guidance:

Sludge should be properly disposed through authorized agent or facility should have licensed by local pollution board to decompose it in premises.  Chemicals should be handled and disposed in accordance with MSDS section 13.  

How this will be verified:

  • Yes
    • Documentation required
      • An inventory of the amounts and types (non-hazardous and hazardous) sludge generated
      • Lab analyses showing the non-hazardous and hazardous (if applicable) components for the various types of sludge
      • Documentation showing methods for disposing each type of sludge
      • For off-site disposal, invoices or delivery records confirming that the types of disposal selected here reflect what's being used in practice
      • If disposal is done via landfilling, open burning, compost, fuel blended, or as fertilizer applied to land, the sludge must be analyzed and documented as non-hazardous and suitable for the particular disposal method.
      • Permits, if applicable for a particular disposal method
    • Interview discussions
      • Is there an in-depth and up-to-date knowledge of the sludge components? How is sludge regularly analyzed to ensure it is properly disposed of?
      • Is management and responsible employees aware of proper disposal methods for each type of sludge
    • Inspection - things to physically look for
      • Site or area and process for disposing of sludge if it is one on-site
      • Please take photographs

8. Is non-hazardous sludge (domestic only) disposed of properly?

Suggested Upload: Sludge analysis or test results

Non-hazardous sludge can be disposed of through any method though you must provide documented evidence that your facility’s sludge is not hazardous.

What is the intent of the question?

You should know if there are any chemical or industrial hazards present in your operations, and, if there are, you need to make sure you do not dispose of these hazards improperly.  

Technical Guidance:

Sludge should be properly disposed through authorized agent or facility should have licensed by local pollution board to decompose it in premises.  Chemicals should be handled and disposed in accordance with MSDS section 13.    

How this will be verified:

  • Yes
    • Documentation required
      • An inventory of the amounts and types (non-hazardous and hazardous) sludge generated
      • Lab analyses showing the non-hazardous and hazardous (if applicable) components for the various types of sludge
      • Documentation showing methods for disposing each type of sludge
      • For off-site disposal, invoices or delivery records confirming that the types of disposal selected here reflect what's being used in practice
      • If disposal is done via landfilling, open burning, compost, fuel blended, or as fertilizer applied to land, the sludge must be analyzed and documented as non-hazardous and suitable for the particular disposal method.
      • Permits, if applicable for a particular disposal method
    • Interview discussions
      • Is there an in-depth and up-to-date knowledge of the sludge components? How is sludge regularly analyzed to ensure it is properly disposed of?
      • Is management and responsible employees aware of proper disposal methods for each type of sludge
    • Inspection - things to physically look for
      • Site or area and process for disposing of sludge if it is one on-site
      • Please take photographs

9. Does your facility treat septic wastewater before it is discharged?

Suggested Upload: a) Documentation that your facility treats septic wastewater before it is discharged; b) Plan to upgrade your septic tank to a more modern wastewater treatment approach.

How does your site unload your septic tank once full? 

  • Describe where it is discharged
  • Describe how it is treated after discharge
  • Please upload documentation if available

Do you have a plan to upgrade your septic tank to a more modern wastewater treatment approach?

Septic wastewater needs to be treated and disposed of properly to avoid contaminating the environment. 

Your facility should begin planning to upgrade your septic system to a more modern form of treatment in order to properly contain pollutants long-term. You will be awarded partial points if you are properly treating and disposing of septic wastewater, but do not yet have a plan to upgrade to a modern treatment system

What is the intent of the question?

You should know if there are any chemical or industrial hazards present in your operations, and, if there are, you need to make sure you do dispose of these hazards properly.  

Septic wastewater needs to be disposed of properly to avoid contaminating the environment. If you do not treat or discharge your septic wastewater properly, you will release hazards into the environment.

Technical Guidance:

Domestic water uses such as washing detergent, floor chemicals and spot cleaner may lead to discharge of few regulated chemicals. A facility should understand, monitor and account for the associated risk of discharging septic wastewater by the following activities:

    1. Establish a process to ensure that septic wastewater is treated before it is discharged.
    2. Appoint a responsible person to manage and monitor the septic wastewater
    3. Contract with approved third party to unload the septic tank contents and keep the disposal record/ invoices  

How this will be verified:

  • Yes
    • Documentation required
      • Documentation (process, schematics of equipment, procedures, responsible persons, etc.) that site treats septic wastewater before it is discharged
      • Documentation describing how the you unload the septic tank and dispose of the waste once full
      • Any permits if required
      • Disposal records/invoices for septic tank contents removal if applicable
      • A time-bound plan that describes the details and milestones for how you are or will be upgrading your septic tank to a more modern wastewater treatment approach
    • Interview discussions
      • Management and responsible employees can describe what specific waste water gets treated in the septic system
      • Management and responsible employees can describe how the site unloads the septic tank once it is full and can tell you roughly how often this procedure is done.
      • Management and responsible employees can describe where septic tank discharge is treated and/or disposed of once removed from the tank
      • Management can speak to plan to their plans upgrade to a more modern wastewater treatment approach and provide their timeframe for doing this
    • Inspection - things to physically look for
      • Take pictures of the septic tank area and sewage pipelines
      • Do the pictures match then plans provided
      • Is there evidence of improper disposal of septic waste or overburdened septic systems? If yes, please make comments and take photos.
  • Partial Yes
    • Same as what is required for "yes" except for plans about upgrading from a septic system.

Wastewater/Effluent – Level 2 

10. Have you requested wastewater quality test results from the offsite wastewater treatment plant? 

Upload: a) Documentation of your request to offsite wastewater treatment plant for wastewater quality records; b) Offsite wastewater treatment plant quality records (if provided)

It is important to be aware of any wastewater quality violations at the wastewater treatment plant in the event that your facility is contributing to environmental contamination. Although your facility does not have authority over the offsite wastewater treatment plant, please provide evidence of your request for wastewater quality results, even if quality results were not provided. This question is intended to provide you with more information in case you are able to take any action to assist the wastewater treatment plan in proper treatment and discharge to the environment.

What is the intent of the question?

The intent of this question is to create connection and accountability between facility and the offsite wastewater treatment plant that is contracted to treat wastewater. The goal is for the facility to be as proactive as possible to confirm their wastewater is compliant.

This information is useful to help understand your situation and identify risk factors and/or opportunities for improvement. 

By requesting the wastewater quality test results from the offsite treatment plant a facility ensures that treated wastewater often discharged from the offsite facility to the environment is compliant in addition to their own facility discharge compliance related to the permit between the offsite treatment plant and the facility. 

Although your facility is not in control of offsite 3rd party treatment, it is important to be aware of any non-compliances and to what extent the is facility contributing to non-compliances. In addition, if your site is contributing to the non-compliance, the question checks to ensure your facility has a plan to help resolve the issue it is causing. This was included in Level 2 rather than Level 1 as a site may not have direct control over offsite treatment or visibility to it. 

Technical Guidance:

Your facility will get credit for this question as long as you can show evidence that you have reached out to the offsite wastewater treatment plant to obtain wastewater quality reports. You will not be penalized if the offsite wastewater party treatment plant refused, as long as you can provide proof of request and denial. 

NOTE: If the 3rd party wastewater treatment plant posts their effluent online, the factory can answer "yes" to this question.

Sometimes the offsite effluent treatment plant may set a standard for facility to discharge wastewater and charge facility more for any exceeding parameters. If this applies to you, please explain the situation and provide examples if relevant to capturing accurate assessment from your facility.  A soft limit is not a permit limit if a surcharge is involved.  They would still be compliant to their permit.  

If you requested results and found that the 3rd party wastewater treatment plant is not in compliance with limits, please describe whether your facility has contributed to the non-compliance. If yes, how has your facility resolved it? If you requested test results, but did not receive them, please describe what happened.

How this will be verified:

  • Yes
    • Documentation required
      • Recent documentation of your request to receive offsite wastewater treatment plant for wastewater quality records and/or
      • Recent (within the year, but ideally more frequently) offsite wastewater treatment plant quality records (if provided)
    • Interview questions to ask
      • Key personnel responsible for the wastewater quality explains the results of the wastewater quality test results collected from the common effluent treatment plant
    • Inspection - things to physically look for
      • Do the sampling results reflect the facility's operational conditions? 

Wastewater/Effluent – Level 3 

11. Does your facility reuse and/or recycle process wastewater as process water (closed loop)?

  • Enter the percentage of wastewater treated and recycled back into your production processes

Suggested Upload: a) Records demonstrating closed-loop recycling (process water to process water); b) List of water reduction achievement(s) according to the location where water is captured for recycling OR the location where recycled water is used.

Answer Yes if you have wastewater treatment in place to recycle 50% or more of your production wastewater back into production processes. The recycled water must be used in production processes - other uses like irrigation, toilets are excluded. Treatment may be chemical or biological such as membrane filtration or Zero Liquid Discharge.

Note on scoring:

  • Recycle 80% or more = full points
  • Recycle 50-79% = partial points
  • Recycle less than 49% = zero points
  • No or unknown = zero points

What is the intent of the question?

This question is focused on incentivizing the innovative technology needed for recycling. 

This technology nearly eliminates freshwater withdrawal for production processes. 

Technical Guidance:

When the wastewater from a given process does not meet quality requirements for another process it is often simply treated and discharged.  If instead a facility treats this wastewater (either chemically or biologically) to meet quality specifications for another process in the facility it would be considered recycling water.  Outside of process optimization to ensure every process runs as efficiently as possible, recycling and reuse of water is the most common mechanisms for reducing freshwater use. For reuse, the wastewater from one process may still meet quality criteria for use in a second process without additional treatment.  This uses the same volume of water multiple times reducing the need for freshwater in the second process.

Recycling 100% of total water use within a facility is closed-loop. This means no significant freshwater use is needed to operate the facility except natural water loss such as evaporation. Zero liquid discharge (ZLD) technologies which involves steps such as pre-treatment, evaporation and crystallization facilitate recovery and reuse of all wastewater.

This water has to be reused again as process water. Other uses like irrigation and toilets are not included.

How this will be verified:

  • Yes
    • Documentation required
      • Facility is able to prove through documented record keeping that they reuse and/or recycle 80% or more of process wastewater as process water. Please refer back to documentation in the Water section to evaluate whether the percentages provided here are correct based on water withdrawal and the water balance (if applicable)
      • List of water reduction achievements according to:
        • the location where water is captured for recycling
        • the location where recycled water is used
      • Interview questions to ask
        • Management and responsible employees can describe/demonstrate how wastewater is reused and/or recycled as process water
      • Inspection - things to physically look for
        • Observation of the equipment in place for the reuse / recycling of process water
        • Detailed descriptions of the equipment (function, benefits for the water consumption, age, maintenance,…)
        • Please take a picture of the equipment
        • Confirm that all reject wastewater goes through treatment (as recorded in the previous questions above) before discharge 
  • Partial Yes
    • Same requirements as for yes, but applying to 50-79% of process wastewater being reused or recycled as process water
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