Conduct a RCA/CAP for non-conformities
This is the new version of Wastewater & Sludge Guidelines
This version (V2) is published and available to prepare for. It will replace the active version (V1) and take effect from 01 Nov 2026. Until then, continue using Wastewater & Sludge Guidelines V1. View Changelog
Conduct a RCA/CAP for test result non-conformities, as per ‘alerts’ in the ClearStream Report.
ClearStream Report
Once the wastewater and sludge sampling and testing are completed and results are published by the supplier in their ZDHC Gateway account, they can generate and download a “ClearStream Report”.
Wastewater
Parameters that “do not meet” limit values detailed in the requirements are highlighted in the ClearStream Report as a red cell “alerts”.
Sludge
Parameters that are not within the required limits are indicated by a “red cross”.
Root cause analysis (RCA)
A supplier should conduct a root cause analysis (RCA) for these wastewater and sludge non-conformities, either for the input chemical inventory or effluent treatment operations, in order to locate the cause.
For non-conformaties of sludge disposal pathways D, E, F and G, immediate solutions should be included in the CAP and supplier should evaluate if other sludge disposal options are available to dispose accordingly.
Corrective Action Plan (CAP)
The supplier must complete the RCA/CAP details (using the RCA/CAP template) for any non-conformities identified in the ClearStream Report for a specific wastewater testing cycle and upload the completed document, including the RCA/CAP template, to their ZDHC Gateway account to ensure visibility for connected brands.
Long term CAP measures should be implemented to improve the quality of the sludge so that it is authorised and suitable for the original disposal route via source reduction. Treatment modifications and other actions such as moving to disposal pathway A, B and C. Wherever possible, sludge disposal pathways A, B and C should be preferred.