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Seven practical questions of Higg FEM Verification and its ETP requirements

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Although Higg Facility Environmental Module (FEM) was launched a couple of years ago, facilities applying for the Higg FEM Verification still come to us with various queries around the details of the programme and its specific requirements, particularly around effluent treatment plants (ETP). Below, we answer some of the most common questions about Higg FEM Verification and ETP requirements.  

When is Higg FEM 4.0 coming into effect? 

The technical paper of Higg FEM 4.0 was released back in December 2022 by Sustainable Apparel Coalition (SAC). It will come into effect in November 2023 and all facilities are required to report their 2023 performance on FEM 4.0 framework from this point onwards. 

How many levels and questions are there in Higg FEM Verification? 

There are three levels, ranging from Level 1 to Level 3, with Level 3 being the most advanced level.  

  • Level 1: Compliance & tracking performance 
  • Level 2: Baselining, targets/goals, reductions 
  • Level 3: Aspirational/leading practice 

In total, there are 82 questions as part of the Higg FEM Verification, with the current distribution of questions being 39 for Level 1, 25 for Level 2, and 18 for Level 3.  

Does the Higg FEM ETP assessment only apply to onsite treatment of wastewater facilities? 

No. Under Higg FEM, all domestic, industrial, onsite and offsite treatment of wastewater should be included in performance reports.  

Do I need to have a back-up plan in case of emergency at the wastewater treatment facility? 

Yes, a back-up plan is needed, as continuing production on a malfunctioning onsite wastewater treatment facility may cause damage. In general, back-up plans could include: 

  • Emergency production halt 
  • Installation of holding tanks 
  • Secondary treatment facilities 
  • Discharge to offsite water treatment plant 

 Among these, installing hold tanks is usually the most effective practice, but this requires careful calculation of the holding tank sizes. Proper documentation is also required to show how the back-up plan is fully compliant. 

What are common issues with effluent treatment plants? 

An effluent treatment plant is a complex system, so different issues can easily become evident during an onsite assessment. Throughout the many site assessments we have conducted, our auditors most commonly come across the following ETP issues: 

  • Direct wastewater discharge to the environment without treatment 
  • Ineffective screening of debris and floating elements 
  • Broken motors in the coagulation tanks 
  • Accumulation of foam from inactive blowers in aeration tanks 
  • Floating sludge in secondary clarifiers 
  • Ineffective sludge drying beds 
  • Improper dry sludge storage conditions 
  • Risks of overflowing of ETP  

Is Higg FEM Verification needed for factories that carry no wet processing e.g. dyeing, printing and washing?  

Higg FEM is still needed for factories without wet processing, as the purpose of the Higg FEM programme is to provide a holistic and clear view of the environmental performance of the entire supply chains.   

Is wastewater testing mandatory on a bi-annual basis? 

This is generally the case, but some retailers and brands do require the submission of a clean report annually, so you should always refer to specific buyers’ requirements.  

Are you looking for more details about Higg FEM Verification? Eurofins is an approved Trainer Body for Higg FEM. We are happy to arrange Higg FEM training for you and your suppliers. 

Alternatively, we are also an approved Verifier Body and you can book us for your next Higg FEM Verification!