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7. Protocol for Offsite Verification

Policy Title:         Protocol for Offsite Verification

Policy Number:   VPM - 007

Issue Date:         March 25, 2018

Authorization:    SAC Vice President - Higg Index

Distribution:       Internal – All

                            External – All potential and current Eligible FEM Verifiers

 

Table of Contents

1     Introduction

  1.1      Higg Index FEM Verification Process Chart

2     Higg Index FEM Offsite Verification Information

  2.1      Offsite Verification Fees

  2.2      Offsite Verification Duration

3     Verification Scope

4     Offsite Verification Process

  4.1      Facility Higg FEM Self-Assessment

  4.2      Opening Meeting

  4.3      Management Policies and Implementation Review

  4.4      Permits, Documentation and Procedures Review

  4.5      Dialogue with Management & Facility Environmental Managers

  4.6      Photos

  4.7      Closing Meeting

  4.8      Performance Improvement Plan (PIP)

  4.9      Reporting

5     Verification Records

 

1     Introduction

After Facilities complete the Self-assessment, the information can be verified through an offsite verification, in which the Verifier completes the Verification from a distance without visiting the Facility, or through an onsite verification, where the Verifier visits and completes the Facility. 

Although either an Onsite of Offsite Verification can be used to validate the self-assessment, there are limitations to an Offsite Verification, as compared to the Onsite Verification.  As the Verifier does not personally inspect or see the Facility, they must rely on the Facility to provide information (including photos) that demonstrate or show their program.  Due to these limitations, the Verified Results of an Offsite Verification cannot be shared publicly. 

There are benefits to conducting Offsite Verifications, including:

  • The Verifier does not need to visit the Facility, which reduces costs
  • The Verification timeline is more flexible as it is not limited to the onsite time

If a Facility wishes to Verify Level 2 and/or 3 Chemical indicators, this can only be done through an Onsite Verification. 

1.1    Higg Index FEM Verification Process Chart

The following chart gives an overview of the Higg Index FEM Verification Process.

Picture1.png

2     Higg Index FEM Offsite Verification Information

2.1    Offsite Verification Fees

The total verification price should be negotiated by the company requesting the verification (brand, retailer or manufacturer) and the Verifier and their company. Pricing may depend on several factors, such as the number of indicators and the quantity and quality of supporting documentation which must be reviewed.

It is suggested that all Verification fees be pre-paid. 

2.1.1     SAC Verification Fee

The SAC charges a fee of $185 USD to complete verifications.  This money is collected by the SAC prior to the Facility giving access to higg.org to the Verifier, prior to the Verification commencing. 

2.1.2     Offsite Verification Scheduling

Onsite Verifications are announced, meaning the Facility and the Verifiers know when the Verification will occur.  The Scheduling of the Verification is done between the Verifier/Verification Body and the Facility – the SAC nor the VPM are involved in the scheduling of the Verification. 

2.1.3     Verification Bids and Negotiations

Information that is commonly required by Verification Companies when determining rates include:

  • Facility Invoicing information
  • Name of the company requesting the Verification (Brand/Retailer or Manufacturer)
  • Environmental Processes or Impacts that affect the amount of information in the Self-Assessment, such as:
    • Land Lot size
    • Type of processes
    • Products produced
    • Number of buildings
    • Number of floors in each building
    • Size and type of waste water treatment (if any)
    • Energy Source(s)
    • Air Quality Systems
    • Number of Employees
  • Number of Employees
  • Information that is needed for Verification purposes, such as:
    • Languages
    • Number of sites (if travel is needed between sites/buildings)

Information that Companies requesting verifications typically want to see include:

  • Total Price, broken out by Verification cost, travel, upload, report writing, etc.
  • Who will be conducting the Verification
  • Dates and timelines for Verification completion
  • information, such as address/location, contact person, etc.

2.2    Offsite Verification Duration

The Higg FEM offsite review duration shall be according to the expectations of the organization requesting the verification; the table below can be used to help estimate the duration of the Offsite Verifications. Note this is guidance only, and should be adjusted, as needed, to ensure the verification is accurate and of high quality. Verifiers should fully investigate all factors to determine the required time of the offsite verification. 

 

Person-Day Duration for Offsite Verification

No. of Workers

 Degree of Complexity

High

Med

Low

<1,000

1.5

1.0

1.0

1,000 < 2,000

1.5

1.5

1.0

2,000< 3,000

2.0

1.5

1.5

>3,000

2.0

2.0

1.5

 Notes:

  • One person-day corresponds to approximately 8 hours of effective working time.
  • Verification scheduling, preparation and uploading the verification results into HIgg.org are not included.
  • Reporting time is estimated to be 0.5 person-days per verification.

Complexity Categories of Environmental Aspects

The number of person-days required for the Higg verification are based on three levels of complexity:

  • High: Environmental aspects of significant nature and gravity (generally consisting of all or most of the environmental aspects
  • Medium: Environmental aspects of medium nature and gravity (generally consisting of some of the environmental aspects)
  • Low: Environmental aspects of low nature and gravity (generally consisting of a few environmental aspects)

The result of the applicability test completed by the facility in the Higg Index FEM Self-Assessment can be used to determine the complexity level under which this facility falls.  

The table below provides an example between facility’s profiles and the three complexity categories above:

 Facility Type / Complexity

High

Medium

Low

Industrial wastewater with onsite treatment

x

 

 

Facility with air emissions, no chemicals used onsite and no onsite wastewater treatment

 

x

 

Facility without air emissions, with no chemicals used onsite and o onsite wastewater treatment

 

 

x

3     Verification Scope

The Verifier shall review the accuracy of the following information:

Higg FEM Section

Verification Scope

Verification Method

Comment

Facility’s Profile

Full content of the facility’s profile

Review the accuracy of the information provided

Accurate information is important to ensure quality of the benchmarking functionalities available on the Higg.org platform

Applicability Tests

All applicability questions

Review and verify the answers provided by the facility to the applicability questions. If the applicability questions are answered incorrectly, questions may be added to the questionnaire that the facility must complete and verified.

Accurate applicability test ensures that only the relevant criteria and scoring apply at the facility

Permits

All business license(s) and permits provided

Review the origin and validity dates of the permits

If the facility does not have a valid operating license it will receive a score of ‘zero’ for the entire assessment

Environmental Management

All Level 1, 2 and 3 Criteria provided

Review documentation, discuss answers with the management team and key employees, reviews photos as described in the Higg FEM verification guidance (available at Howtohigg.org)

All criteria shall be reviewed by the verifier.  However, Level 2 and Level 3 criteria are only scored if facility achieves level 1.

Energy and GHG

All Level 1, 2 and 3 Criteria and consumption and/or quality data provided

Verifier shall follow the Higg FEM verification guidance available at howtohigg.org, including:

·     Documentation Review

·     Discussions with Employees and Management

·     Photo Review

Verification of all the quantitative metrics should be conducted by reviewing bills and records provided by the facility.

All criteria shall be reviewed by the verifier.  However, Level 2 and Level 3 criteria are only scored if facility achieves level 1. 

Verification of the quantitative metrics is essential to measure the performance of a facility over time.

Water Use

Wastewater

Waste Management

Air Emissions

Chemical Management

Level 1 can be verified by SAC eligible Generalist Verifiers.

Level 2 and 3 can only be verified by SAC eligible Chemicals Specialist Verifiers.

The Verifier shall follow the Higg FEM verification guidance.

·     Documentation Review

·     Discussions with Employees and Management

·     Photo Review

 

All criteria shall be reviewed by the verifier.  However, Level 2 and Level 3 criteria are only scored if facility achieves level 1.

SAC eligible Generalist Verifiers can verify the full scope of the Higg FEM, excluding the chemical management section Level 2 and Level 3, which must be verified through an Onsite Verification.

 

The verifier shall upload its assessment using the verifier permissions granted to her/him on higg.org; the facility provides this permission.

4     Offsite Verification Process

The verification offsite review shall include the following.

4.1    Facility Higg FEM Self-Assessment

The first step of the Higg Index FEM Offsite Verification is the Higg FEM Self-Assessment, completed by the Facility and uploaded on Higg.org.

The Self-Assessment is designed to:

  • Capture a description of the facility’s profile to customize the assessment for relevant impacts
  • Evaluate environmental practices in place against a set of aspirational practices
  • Capture environmental quantitative metrics to benchmark environmental performance
  • Guide facilities through continuous improvement practices
  • Support supply chain transparency through data exchange between various stakeholders

4.2    Opening Meeting

The offsite verification shall start with an “Opening Meeting” held via a webinar or conference call with facility management, environmental manager(s) and other key staff members to discuss objectives, verification scope and methodology.

4.2.1     Purpose

The purpose of the Opening Meeting is to ensure that both parties – the Verifiers and the Facility – understands the process, that proper expectations are set, and that, ultimately, the Verification is as effective and efficient as possible. 

4.2.2     Agenda

This meeting should include:

  • Introductions from both the verification team and facility management personnel.
  • Discussion of the objectives of Higg verification, including:
    • A reminder that the Higg verification is not an audit, but rather it serves to verify the self-assessment submitted by the Facility.
    • An explanation that Higg is not a pass-or-fail assessment/audit.
    • A discussion of scoring, that there is no ‘minimum score’ in Higg. Instead, Higg focuses on performance monitoring of critical and minimum legal and industry standards, and supporting facility in its continuous improvement.
  • A clarification of the scope of the Verification and criteria to be checked.
  • Discussion on the independence of the assessment team and the need for openness, transparency and ethics, including a review of the conflict of interest in that no Trainers or Consultants can act as Verifiers. 
  • An agreement on how conflicts will be handled.
  • A review of the confidentiality associated with employee dialogues.
  • A review of the confidentiality associated with verification results.
  • Communication of criteria and reporting methodology.
  • An explanation of the next steps, including outcome of the verification (i.e. PIP will be prepared and will be summarized/explained/discussed in the closing meeting).

4.3    Management Policies and Implementation Review

4.3.1     Purpose

The purpose of reviewing management policies and the implementation of those policies is to review management’s attitude, understanding, policies, procedures and stated practices about environmental issues. All sections of Higg Index checklist are relevant and should be covered.

4.3.2     Details

Review of management policies and implementation should be conducted at the beginning of the Offsite Verification; however, it may be necessary to go back to this element later in the verification process to “close the loop” on issues identified at later stages of the verification process.

The staff to be involved in this review include:

  • Senior facility management
  • Maintenance staff and responsible person(s) for environmental areas in the facility
  • Others who have information or knowledge about the management policies and implementation of those policies 

4.4    Permits, Documentation and Procedures Review

4.4.1     Purpose

The purpose of this part of the verification is to review and validate the permits, document and procedures of the Facility. 

4.4.2     Details

Relevant documentation and procedures to be reviewed are described in the Higg verification guidance found at howtohigg.org

4.5    Dialogue with Management & Facility Environmental Managers

4.5.1     Purpose

The purpose of discussions with management is to learn from key personnel about the Facilities programs and policies, and how they are intended to be implemented throughout the Facility. 

4.5.2     Details

Dialogue with managers and dialogs with key personnel who have specific roles and responsibilities for managing environmental issues or environmental management systems will be undertaken via a teleconference call.  Dialogues may also be undertaken with Facility Environmental Managers to establish the level of awareness of environmental issues across the facility and to help identify any issues or good practices on-site.

4.6    Photos

Photos or short video clips (hereafter referred to only as ‘photos’) must be shared the Verifier. 

4.6.1     Purpose

The purpose of the facility providing photos of the physical conditions and implemented practices in all areas of the facility is to establish evidence that activities are consistent with what the factory has presented in their self-assessment scores. 

4.6.2     Photo Guidelines  

Photos should:

  • Accurately show the common practices, actions, and process that are occurring at the factory (no ‘staged’ photos)
  • Be recently taken (generally within 2 weeks of the Verification start date)
  • Be clearly viewable (proper lighting, proper camera angles, etc.)
  • Be provided in a manner that the Verifier can view (using common technology and in a commonly used format, such as .jpg or .pdf)
  • If appropriate, the photos should be labeled or explained to help the Verifier understand the photo, or context to the photo

 

The Facility may request or require that the Verifier delete or destroy the photos when the Verification is complete.  The Verifier is not to use or show the Photos to anyone other than for the purposes of completing the Verification.

4.6.3     Required Photos

Examples of photos that Verifiers should see include:

  • Outside general overview
  • Facility premises and surroundings
  • Inside general overview
  • General photos of production line(s)
  • Key activities and processes that have potential environmental impact, if present, such as:
    • Waste handling and storage area(s)
    • Hazardous substance storage area(s)
    • Hazardous materials transfer area(s)
    • Bulk storage tanks and secondary containment area(s)
    • Wastewater treatment area / plant, including discharge point(s)
    • Water Discharge Point(s)
    • Raw material/chemical and waste storage warehouse/area(s)
    • Boiler room(s)
    • Exhaust vents, stacks, or other air discharge points
    • Waste collection area(s), both Hazardous and Non-hazardous
    • Compressor house(s)
    • Power generator room(s) /area(s)
    • Internal and external transport area(s)
  • Area(s) of potential impact to soil and groundwater, including stained soil and/or distressed vegetation
  • Abatement equipment
  • Good practices

The Verifier may require additional or specific photos at any time during the Verification.  Refer to howtohigg.org for additional information on photos that must be shared. 

4.7    Closing Meeting

4.7.1     Purpose

The purpose of the Closing Meeting is to ensure that both parties – the Verifiers and the Facility – have a joint agreement on the findings, and that the Facility understanding the verification and associated information. 

4.7.2     Pre-Closing Meeting

Before the closing meeting the verifier(s) must:

  • Inform the facility about who should join the closing meeting:
    • Senior Management
    • Staff who will manage the PIP
    • Operations staff who were involved in the review
    • Others, as necessary  
  • Cross-check the collected data
  • Make final decisions on identified issues
  • Determine best practices
  • Prepare explanations and justification
  • Prepare the Performance Improvement Plan (PIP) by entering the criteria which was not met. NOTE: The Verifier completes only a portion of the PIP, the facility is responsible for completing the remainder of the document.   

4.7.3     Closing Meeting Agenda

After the verification process, a Closing Meeting is held with facility via webinar or teleconference. The closing meeting agenda should include, but is not limited to, the following topics:

  • Review scope of work/review
  • Comment on staff cooperation (or lack thereof)
  • Overall evaluation and/or strengths of the facility (if any)
  • A summary of the areas of inconsistencies between the self-assessed and verified results
  • A reminder of the confidentiality of the results
  • Components identified in the PIP and next steps
  • Notification to the facility that Verification results will be completed and uploaded on Higg.org and that the factory can review and post it for benchmarking or sharing, if the factory choses, on Higg.org
  • Answer questions from the Facility
  • Thank you

During this meeting, Verifiers should seek to gain agreement from the Facility on the areas of improvement identified to avoid later disputes.

After the closing meeting, Verifiers shall obtain a signature or approval as necessary and required (e.g. for the Verifier Log) from the facility’s representative.

4.8    Performance Improvement Plan (PIP)

4.8.1     Purpose

The purpose of the PIP is to ensure that the Facility clearly understands their gaps in their performance, so that they know what they could/should do as they work to continually improve their performance. 

4.8.2     Preparation  

After the Offsite Verification is complete, the Verifier will discuss each of the performance improvement areas with the facility.  The Facility is required sign the report (NOTE: This signature do not mean the Facilities agrees with the findings, simply that they received a copy of the findings and that they understand the Verifier’s comments regarding the findings).

Verifiers will explain the following to the facility:

  • There is no minimum score required
  • The facility should prioritize actions to meet the “Critical” item areas and Level 1 criteria (Minimum legal / industry requirements)
  • Recommended approaches for prioritizing may include:
    • Focus on Critical Issues, identified by Brands/Retailors/Customers and the Facility
    • Focus on Level 1 Criteria
    • If/When all Critical and Level 1 Criteria issues are remediated, or when the Facility has the resources to work on other issues in addition to the Critical and Level 1 issues, focus on the issues that are most concerning, most ‘dangerous’ to the factory, workers, and/or local communities, or issues that will make the most impact if/when remediated
  • NOTE: While ‘closing issues’ is good, it is better to focus on and close the more significant issues rather than focusing on and closing a higher number of issues

4.9    Reporting

The Verifier must go onto Higg.org and upload the Verification Report. 

Reporting Requirements include:

  • The Verifier must describe the situation and conditions and give evidence for meeting/not meeting the criterion.
  • For each indicator, a comment shall be provided.
  • The Verifier must also report examples of good practices found during offsite verification.

The verification score is automatically calculated when all the verification results have been entered for every indicator, and is called the “Verified Score.”

5     Verification Records

Verifying organizations must keep all documents and evidence from the Verifications through the entire verification process, including through any quality review activities that may take place, to justify the services performed and answer questions through the quality assessment process.

These include but are not limited to:

  • Facility Higg Index Facilities Environmental Module self-assessment questionnaire
  • Number, name and details from management dialogue(s)
  • Copy of license and permits
  • Evidence for areas of improvement
  • Notes
  • Photos
  • PIP (including factory signatures)

 

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