Environmental Standards and Best Management Practices

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Environmental Standards and Best Management
Practices
AAFA Environmental Committee Meeting Washington,
DC Jimmy Summers, URS Corporation November 10,
2008
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Environmental Standards and Best Practices
Document

• Purpose
• Resources used to develop the document
• Overview of the document
• Using the document
• Discussion, Next Steps

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Purpose

• To develop an Environmental Standards and Best
  Practices document or list that can be used by
  AAFA members to implement environmental standards
  and best practices throughout their supply
  chains.
• Should help AAFA members put a program in place
  that helps factories meet expectations of
  retailers and other customers (pass audits).
• Should help AAFA members to enhance their overall
  Sustainability programs

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Resources Used

• World Bank Group/International Finance
  Corporation General EHS Guidelines
• WBG/IFC Textile Manufacturing EHS Guidelines
• Levi Strauss Company EHS Handbook
• WRAPe Audit Protocol Draft
• Other company EHS policies, standards, best
  practice guides, and supplier environmental
  performance questionnaires

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Overview - Environmental Standards and Best
Practices Document

• Contains overall standards and best practices,
  plus a breakdown of 5 specific areas
• Industrial wastewater, domestic sewage, storm
  water, and biosolids management
• Air emissions
• Energy management and conservation
• Hazardous materials storage, handling, and
  transportation
• Solid waste and hazardous waste

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Overview - Environmental Standards and Best
Practices Document

• Contains Standards, marked in red, which are
  intended to be required of all factories
• Contains Best Practices, marked in green, which
  are encouraged, but are voluntary
• The document can be adjusted as desired by
  companies using it, and is intended to be part of
  an overall supply chain environmental management
  and sustainability program
• Wastewater effluent standards and the AAFA RSL
  are intended to be included as attachments

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Overall Standards

• Requires compliance with applicable environmental
  laws and regulations
• Requires that business must be conducted by
  factory in accordance with your companys EHS
  policies and strategies
• Must agree to keep adequate records to
  demonstrate compliance, and that these records
  must be available at any time for review
• Must agree to develop and implement environmental
  policy and management system, supported by senior
  management
• Agree to designate a person with environmental
  responsibilities for the factory, with authority
  to implement the policy
• Agree to consider developing a sustainability
  program

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Wastewater, Storm Water, Biosolids

• Standards include
• All discharges must comply with company effluent
  standards and permit limitations, local laws and
  regulations
• All discharges must be properly treated
• Must have all required permits and authorizations
  in place
• Septic systems must be properly designed and
  operated
• Biosolids must be handled and disposed of
  properly
• Testing must be performed by certified lab
• Must implement practices to minimize exposure of
  pollutants to storm water
• Best practices include
• Should develop a water balance
• Should implement a Water Conservation Plan
• Should identify opportunities to reduce
  pollutants in waste streams, including
  implementing the AAFA RSL

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Air Emissions

• Standards include
• All discharges must comply with all permit
  limitations, local laws and regulations. Must
  use appropriate controls to meet limits if
  necessary.
• Must have all required permits and authorizations
  in place
• Must calculate total annual air emissions for the
  facility, and for major equipment and processes,
  including NOx, SO2, CO, PM, VOCs, Hazardous air
  pollutants, and GHGs. Must maintain records for
  at least 2 years.
• Wastes or effluent streams from air pollution
  control equipment must be managed and disposed of
  properly.
• Best practices include
• No open burning of wastes
• Should calculate total Scope 1 and Scope 2 GHG
  emissions
• Identify opportunities to reduce pollutants and
  toxics in air discharges

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Energy Conservation and Management

• Standards include
• Must have energy usage data available for
  previous 2 full calendar years.
• Data must include quantity used, heat content of
  fuels, and sulfur content information for fuels.
  
• Must include all electricity usage at the
  factory.
• Best practices include
• Should develop and implement an Energy Management
  and Conservation Program for the factory.
• Program should include setting goals, plans for
  improving energy efficiency, and should regularly
  compare actual performance against goals.
• Program should cover all processes and areas of
  energy and fuel usage at the factory.

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Hazardous Materials

• Standards include
• Handling, storage, and transportation of
  hazardous materials must comply with all permit
  requirements, local laws and regulations.
  Procedures must be in place for safe handling,
  storage, and transportation.
• MSDSs for all chemicals used must be on file at
  the factory.
• Must have adequate spill response equipment and
  training.
• Must have up-to-date list of ASTs and USTs.
  Regular inspection and safe filling procedures
  must be in place for these tanks.
• Regular training must be provided to employees.
• Best practices include
• Secondary containment should be provided for all
  ASTs and other hazardous material containers.

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Solid and Hazardous Waste

• Standards include
• Handling, storage, and transportation of solid
  and hazardous waste must comply with all permit
  requirements, local laws and regulations.
• Must maintain records of amounts and types of
  wastes generated, including disposal records
  showing proper disposal.
• Must keep records of materials recycled an
  reused, by type and quantity.
• All solid and hazardous wastes must only be sent
  to properly permitted and authorized facilities
  for further treatment and disposal. Factories
  must ensure and have records proving that
  transporters and receiving facilities have proper
  permits and authorizations.
• Must maintain good housekeeping in waste areas.
• Solid and hazardous waste generation and storage
  areas must be inspected regularly in order to
  detect potential problems.
• Best practices include
• Should develop a Waste Minimization and Source
  Reduction Plan in order to reduce the amount of
  wastes generated by the factory.

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Using the Environmental Standards and Best
Practices Document

• One company is in the process of rolling similar
  standards and best practices out to all factories
  in its supply chain, along with a policy
  statement and strategy.
• The factories will be audited against the
  standards and best practices, and lower scoring
  factories will be encouraged to improve
  performance.
• The idea is to create a baseline of actual
  performance data for factories being used by the
  company.
• Performing 3rd party audits against the document.
  Retailer audits are on-going, and the efforts are
  being targeted towards factories servicing those
  retailers.
• Tie-in with the WRAPe certification program and
  other programs.

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Discussion, Next Steps

• Incorporate comments, finalize document
• Develop audit questions to go with the document?
• Relationship to WRAPe audit protocol?
• Supply chain developments WalMart audits,
  Retail/Major brand working group, others?