Scoring: FEM Compliance Guide PDF

**Scoring** The Site Information and Permits section of the FEM is NOT SCORED. This means that you do not get points for being in compliance with basic legal requirements. However, the following scenarios will result in a score of ZERO for the entire FEM as these are considered basic compliance pra...

**Scoring** The Site Information and Permits section of the FEM is NOT SCORED. This means that you do not get points for being in compliance with basic legal requirements. However, the following scenarios will result in a score of ZERO for the entire FEM as these are considered basic compliance practices that must be met to achieve a FEM score. - If your facility does not have a valid operating license. (i.e., if you answer "No" to the question "Does your factory site have a valid operating license?"). - If your facility does not have a required environmental permit. (i.e., if you answer, "Not Available" to the question "What is your status for this permit?" for any required environmental permits). - **Note:** If the permit status is "Not available due to authorization in progress" or "Available but Invalid" the FEM may be scored based on the condition below. - If your facility is no longer able to meet the requirement of obtaining a required permit (i.e., if you answer, "Facility is no longer able to meet the requirement Facilities will first select their facility type(s) from the list of options below. Based on the selected facility type(s) and then additional questions on applicable product categories, materials used, facility processes, and industry sector will apply. **Note:** If applicable, more than one facility type should be selected, for example: - If you are a vertically integrated facility with cut and sew operations as well as wet processing (e.g., dyeing) you would select both "Final Product Assembler" **and** "Finished Product Processing (Product Printing, Product Painting, Product Dyeing, Product Laundering and Product Finishing, Embroidery & Embellishments)". OR If you are a hardgoods facility that assembles final product and manufactures hard components on site, you would select both "Final Product Assembler" **and** "Component / Sub-Assembly Manufacturing (including Packaging)"   +-----------------------------------+-----------------------------------+ | **Facility Type Option** | **Examples ** | +===================================+===================================+ | Finished Product Assembler | Finished goods production/ final | | | product assembly. | +-----------------------------------+-----------------------------------+ | Finished Product Processing | Printing and dyeing of products | | (Product Printing, Product | materials, including wet | | Painting, Product Dyeing, Product | processing, and laundering | | Laundering and Product Finishing, | | | Embroidery & Embellishments) | | +-----------------------------------+-----------------------------------+ | Component / Sub-Assembly | Label, zipper, snap, button, | | Manufacturing (including | elastic buggie, cardboard | | Packaging) | | +-----------------------------------+-----------------------------------+ | Material Production (Raw and | Fabric dye-house, fabric | | intermediate materials are | manufacturer, yarn dyeing, PCB | | transformed into their final | manufacturer, | | state before assembly) | | | | Hardgoods: Metal pieces, wooden | | | | | | laminates, metal plating | +-----------------------------------+-----------------------------------+ | Raw Material Processing (Raw | Yarn spinning | | Materials are processed into | | | intermediate material products) | Hardgoods: foundry, metal | | | processing, | | | | | | plastic injection | +-----------------------------------+-----------------------------------+ | Raw Material Collection & Bulk | Cotton farming and ginning, | | Refining (Materials are | processing of bottles, fabric | | collected/extracted/farmed and | scrap, etc. into new recycled | | refined to bulk commodity state) | materials, forestry, mining, | | | crude oil refinery | +-----------------------------------+-----------------------------------+ How can we confirm the absence of soil and/or groundwater contamination in our facility? ---------------------------------------------------------------------------------------- Having a monitoring system in your tanks and chemical storage areas to ensure there are no leaks, and records of spot checks to ensure no contamination would help demonstrate and confirm. **Does your facility maintain a documented system to identify, monitor and periodically verify all laws, regulations, standards, codes, and other legislative and regulatory requirements for your significant environmental impacts (in addition to areas that are not covered in required permits)? (Ref ID: emsregulationsystem)** **Answer Yes if: **Your facility has documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts **and** the facility is in compliance with all applicable legal and/or other requirements. **Answer Partial Yes if:** Your facility has documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts, but you are currently not in compliance with one (1) or more legal and/or other requirements **and** you have a documented plan to correct the non-compliance(s). **Notes:** - These procedures may be implemented at the manufacturing groups level, but facilities must be able to demonstrate how these procedures are aligned with at the facility level. - This question is not inclusive of the mechanism for monitoring and renewing legally required permits covered in the Higg FEM question "Does your facility have a mechanism in place to regularly review and monitor environmental permit status and renewal (where appropriate) and ensure compliance?" - For this question, significant impacts relates to impacts that have been identified and determined to be significant based on the criteria and guidance for the Higg FEM question "Has your facility identified the significant environmental impacts associated with current operations within the factory premises?"  **If you select Yes, **you will be asked the following sub questions: - Select all topics covered by the system (select all that apply) - Are the findings used to set an improvement plan that is regularly reviewed? - Please upload documentation, if available - If you cannot upload the documents, please describe here: **Suggested Uploads: ** - Documentation that supports the facility's procedures to review and monitor environmental permit status, and renew permits to ensure you are meeting the legal requirement (e.g., documented legal and other requirements monitoring procedure, related job descriptions or duties, list of applicable requirements (legal and other), calendar of review and monitoring activities, corrective action plans, etc.) **What is the intent of the question?** The intent of this question is to ensure that facilities are systematically and proactively identifying and reviewing requirements in applicable laws, regulations, standards, codes and other requirements for their significant environmental impacts.  **Technical Guidance** Understanding, identifying, monitoring, and verifying environmental compliance requirements for legal and other requirements for a facility's significant environmental impacts is important to ensure a facility is operating in compliance with legal and other requirements. Having established procedures should be part of a facility's or manufacturing group's formal environmental management system. These processes should be documented (for example, through a standard operating procedure), maintained and implemented by qualified staff that have a good understanding of environmental regulations and other requirements. Requirements may include: - Legal and other regulatory requirements - Industry or client brand requirements (e.g., industry stakeholder initiatives, brand code of conduct requirements or expectations)  A facility's procedures should include systematic processes to:  - Identify, review, and monitor the scope of regulatory and other requirements for the facility's significant environmental impacts.  - Define Responsible staff/departments and specific duties to ensure implementation. - Establish formal internal review & tracking procedures and documentation (e.g., legal, and other requirements register) - Define a review and monitoring schedule and frequency to identify changes in requirements. - Define processes to address any identified non-compliances or actions required to maintain compliance Periodic review and updates of environmental regulations should be conducted and documented. This review schedule should be defined based on the organizational structure of the facility's or manufacturing group's environmental team and the applicable environmental regulatory and other requirements.   **Resources:** Example regulatory and other requirement tracking template: [**https://howtohigg.org/resources/resources-library/\#templates**](https://howtohigg.org/resources/resources-library/#templates)  **How This Will Be Verified:** **Full Points:** Full points will be awarded for facilities that have documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts **and** the facility is in compliance with all applicable legal and/or other requirements.. **Documentation Required: ** - Supporting documentation that shows the facility has documented procedures to identify, monitor, and verify environmental compliance requirements for legal and other requirements for the facility's significant environmental impacts.  This may include: - A list of applicable legal and other requirements (e.g., legal and other requirements tracking registry) - Job descriptions or list of responsibilities for relevant staff - Documented procedures for the review and monitoring processes that include the review process and frequency.  - Corrective Action Plans, if applicable **Notes:**  - These procedures may be implemented at the manufacturing groups level, but facilities must be able to demonstrate how these procedures are aligned with at the facility level.  - The supporting documentation noted above may be included in various documents, however collectively they must demonstrate that the facility has documented procedures in place to identify, review, and monitor legal and other requirements to ensure compliance. **Interview Questions to Ask** - Staff responsible for environmental management are able to describe the facility's processes to identify, monitor, and periodically verify all regulatory and other requirements for the facility's significant environmental impacts. - Key staff involved in processes are able to describe their role and responsibilities for ensuring compliance with all regulatory and other requirements. **Inspection -- Things to Physically Look For**  - Observations onsite confirm all significant sources of environmental impacts have been identified and applicable legal and other requirements are being complied with. **Partial Points:** Partial points will be awarded for facilities that have documented procedures and defined responsibilities to identify, monitor and periodically verify all laws, regulations, standards, codes, and other requirements for your significant environmental impacts, but you are currently not in compliance with one (1) or more legal and/or other requirements **and** they have a documented plan to remediate the non-compliance(s).