United States        Office of Pollution Prevention    EPA 742-R-00-002
         Environmental Protection   and Toxics (MC-7409)          April 2000
         Agency	Washington, DC 20460	



4>EPA   Enhancing Supply Chain


         Performance with


         Environmental Cost


         Information:





         Examples from Commonwealth


         Edison, Andersen Corporation,


         and Ashland Chemical
     Environmental

     Accounting

     Project
     USEPA

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ACKNOWLEDGMENTS

This document was prepared under Contract No. 68-D5-0008 for the U.S. Environmental Protection
Agency (EPA).  Staff from the Battelle Memorial Institute and EPA assisted in this project.  At EPA,
Susan Meisner and John Nanartowicz were Contract Officers,  Sineta Wooten was Project Officer, and
Susan McLaughlin and Kristin Pierre were the Work Assignment Managers.  At Battelle, Joseph Fiksel
was Project Manager, and Joyce Smith Cooper and Jeff McDaniel were technical contributors and the
report's primary authors.

Each of three case study companies volunteered generous amounts of information to this report as well
as considerable hours for in-depth reviews. At Commonwealth Edison, Tom Tramm led the effort to
provide detailed insights into the company's life cycle costing practices.  At Andersen Corporation, Dale
Olson provided technical contributions and coordinated the Andersen in-house reviews.  Thanks also go
to Andersen's Dan Michaelis, Tim Foster, Kirk Hogberg, and Sharon King for their support and
encouragement of this project. At Ashland Chemical, John Harris led the effort and was supported by
Kent Carleton, Fred Froehlich, and David Vogel  (from The Gauntlett Group, LLC).

EPA is indebted to all of the individuals whose reviews of working version of this document were
essential to developing and enhancing the value of this report.  Those individuals are:

Allen Aspengren
3M Corporation                                    Miriam Heller
                                                 University of Houston
William Bilkovich
Environmental Quality Consultants                    Edward Huller
                                                 The Dow Chemical Company
Scott Clay
Pacific Gas and Electric                              David Kling
                                                 U.S. Environmental Protection Agency
Mary Ann Curran
U.S.  Environmental Protection Agency                 Patricia Layton
                                                 American Forest & Paper Association
John Ehrenfeld
Massachusetts Institute of Technology                  Clare Lindsay
                                                 U.S. Environmental Protection Agency
Holly Elwood
U.S.  Environmental Protection Agency                 Mary McLearn
                                                 Electric Power Research Institute
James Fava
Five Winds International                             Lisa Murphy
                                                 Louisiana State University
Matt Gillen
U.S.  Environmental Protection Agency                 Thomas Murray
                                                 U.S. Environmental Protection Agency
Robert Handfield
North Carolina State University                       Janet Ranganathan
                                                 World Resources Institute

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Naomi Soderstrom
University of Colorado at Denver

Ron Spencer
Dell Computers

Robert Stephens
General Motors Corporation
Leanne Viera
IBM Corporation, Supply Chain Optimization

Steve Walton
Emory University
These case studies are descriptions of initiatives, business practices, and decision-making approaches at
Commonwealth Edison (ComEd), Andersen Corporation (Andersen), and Ashland Specialty Chemical
Company (Ashland). Therefore, the concepts, terms, and approaches presented in this document
represent those used by participating companies, and do not necessarily reflect the position or the views
of the U.S. Environmental Protection Agency nor those of individual reviewers.

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Executive Summary
Companies' information systems typically hide from decision-makers the costs and benefits related to
their environmental, health, and safety (EH&S) performance.  Such costs may include not only those
costs historically associated with EH&S, but also costs associated with material usage, labor, and capital
resources. Heightened recognition of these costs through environmental managerial accounting
approaches these costs often reveals cost-effective opportunities to prevent pollution and eliminate
wastes, and encourages business decisions that are both financially superior and beneficial to the
environment.

Supply chain management is a particularly promising area for the application of environmental
managerial accounting techniques. Many firms already pursue strategies that emphasize eco-efficiency,
i.e., improving material utilization per unit of production. By expanding those efforts to include
purchasing, inventory management, materials handling, disposition and logistics, companies can further
improve environmental and cost performance. Environmental managerial accounting methods enable
them to identify and quantify the most viable opportunities.

This collection of case studies illustrates how supply chain management practices can be improved by
determining the financial impact of business activities that have an impact on a company's
environmental performance.  Moreover, this report shows how environmental managerial accounting
approaches can be integrated into ongoing business processes. The report includes case studies of
multi-disciplinary processes at three companies: Commonwealth Edison,  Andersen Corporation, and
Ashland Chemical Company.  While the approaches vary among these companies, each one provides
valuable lessons for other companies. Brief summaries of each case study are provided below.

Commonwealth Edison

The experience of Commonwealth Edison (ComEd), a large Chicago-based electric utility company with
annual revenues of approximately $7 billion, demonstrates that electric utilities and other companies can
successfully and substantially reduce their costs and environmental burdens with innovative accounting
practices.  In 1993,  ComEd began to recognize that the total cost of managing materials and equipment
was much more than the initial acquisition cost.  In particular, company managers realized that the costs
related to environmental management were often overlooked. This acknowledgment led to ComEd's
first phase of life cycle management activities, which enabled them to minimize the chemical inventories
at generating stations.  These reductions and other early successes prompted ComEd to launch a formal
Life Cycle Management (LCM) initiative in 1995. Since then a small, dedicated LCM staff has formed
effective partnerships with ComEd operating divisions to systematically assess life cycle costs and
benefits.

ComEd's LCM initiative has reduced waste volume while providing over $50 million in financial
benefits.  While these gains include improvements in supply chain management, facility management,
and other business processes, this case study focuses on the supply chain activities.
                                                                                   Page 1

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Andersen Corporation

The activities of Andersen Corporation illustrate how a company can improve its financial and
environmental performance by using environmental managerial accounting information in supply chain
management decisions. As the largest manufacturer of wood windows and patio doors in North America
with annual revenues of approximately $1 billion, this company achieved substantial financial and
environmental benefits when it began incorporating environmental considerations into its purchasing,
materials handling, inventory, and disposition decisions.

In the late 1980s, executives at Andersen released a directive to their staff to reduce emission levels of
toxic chemicals. In response to the directive, Andersen managers formed a Corporate Pollution
Prevention Team whose mission was to eliminate the use, release, and transfer of hazardous chemicals.
This multi-disciplinary team conducted a waste accounting project, developed waste reduction goals, and
justified waste reduction projects by developing several business cases that quantified environmental and
other cost savings.  For example, the team justified the purchase of an improved system for mixing
paints at point-of-use based on the savings from improved material usage rates and reduced waste.

Based on their initial success, company managers recognized that a more systematic implementation of
environmental accounting techniques would improve their ability to make strong business cases for a
wide range of projects. Accordingly, they developed procedures for environmental  cost assessments for
a number of supply chain management activities.  The process leads to more comprehensive and lucid
business cases, including detailed Internal Rate of Return (TRR) schedules that incorporate savings from
increased material efficiency and reduced waste streams.

Ashland  Chemical

While a number of companies have adopted environmental accounting practices, relatively few have
fully integrated these activities into their established cost accounting methods. The Electronic
Chemicals Division of Ashland Specialty Chemical Company achieved this integration during a
manufacturing cost analysis in 1999.  The corporate auditing team and  an external consultant led a
process of identifying and quantifying a number of cost reduction opportunities.   Several of these
opportunities supported the company's overall goal of using materials more efficiently and minimizing
waste.

This case study describes how the company integrated its Manufacturing Cost Analysis and
Environmental Health & Safety (EH&S) Cost Study and provides specific tools that can help companies
realize similar objectives.   These tools include a detailed list of environmental activities, a
representative list of interviewees, and a time allocation worksheet for capturing hidden environmental,
health, and safety (EH&S) costs. The integration effort uncovered at least one sizeable cost reduction
opportunity and has led the company to make EH&S cost considerations an established part of its
broader cost audits.
                                                                                    Page 2

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                      TABLE OF CONTENTS

ACKNOWLEDGMENTS  	


EXECUTIVE SUMMARY	  1


INTRODUCTION	  7


COMED  	  9

    Early Life Cycle Management Activities	9
          Characterizing Waste and By-Product Streams 	9

    Improving the Management of Cleaning Solvents	11
          Inventory Minimization Process	12
          Solvent Inventory Minimization Pilot Studies	15
          New Product Evaluation Process 	17
          Solvent Reduction Results  	17

    Lessons Learned  	19
          Defining the Life Cycle  	19
          Encouraging Holistic Decision-Making 	19
          Considering a Broader Range of Costs	20
          Keys to LCM Success	22
          Areas for Improvement	23

    Looking Ahead  	24


ANDERSEN CORPORATION  	  26

    A Call to Action	26
          Team Formation  	27

    Decision Process  	27
          Identification 	28
          Evaluation	29
          Justification	31
          Implementation	34

    Supply Chain Improvements	35

          Reusable Packaging for Glass 	35

                                                                 PageS

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           Paint Formulation  	36
           Paint Hook Cleaning	36
    Overall Results 	37
    Lessons Learned  	37
    Looking Ahead 	38
ASHLAND SPECIALTY CHEMICAL COMPANY	  40
    Activity-Based Accounting Approach	40
           EH&S Cost Study  	41
           Cost Identification: Identifying Potential Costs with Interviews  	43
           Validation: Confirming the Interview Findings	44
    Breakthrough Process	46
    Final Presentation	48
    Lessons Learned  	49
    Looking Ahead 	50
REFERENCES	  51
                                                                  Page 4

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                          LIST OF TABLES

Table 1. Example of Material Tracking Results	10
Table 2. Solvent Minimization Program	11
Table 3. Inventory Minimization Process	13
Table 4. Product Evaluation Matrix	14
Table 5. Details of the Pilot Study Cost Assessment	16
Table 6. New Product Evaluation Process	17
Table 7. Disposal Cost Savings from Solvent Minimization Program	18
Table 8. ComEd's Life Cycle Stages	19
Table 9. Linking the Life Cycle Stages to Costs 	22
Table 10. Results of ComEd's LCM Initiative	24
Table 11. Andersen's Wastes and Emissions	28
Table 12.1998 VOC Emissions by Process	29
Table 13. Cost and Material  Reductions of the Meter-Mix Project	30
Table 14. Improvements from the Meter-Mix Project 	30
Table 15. Analysis of Non-Financial Elements 	31
Table 16. Meter Mix Internal Rate of Return Schedule	33
Table 17. Improvements in Waste Metrics	37
Table 18. The Gauntlett's Group List of Typical Environmental Activities
     	42
Table 19. List of Personnel Interviewed	43
Table 20. Time Allocation Worksheet	45
                                                                 PageS

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                        LIST OF FIGURES

Figure 1. Solvent Reduction Processes	12
Figure 2. Hazardous Solvent Waste Generation	18
Figure 3. Integration of EH&S Evaluation and Productivity Analysis 	41
Figure 4. Total EH&S Costs by Cost Category 	47
Figure 5. Total EH&S Costs by Activity  	47
                                                              Page 6

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INTRODUCTION


U.S. EPA's Environmental Accounting Project strives to help companies incorporate environmental,
health, and safety (EH&S) costs and benefits into decision-making.  Such costs may include not only
those costs historically associated with EH&S, but also costs associated with material usage, labor, and
capital resources. Heightened recognition of these costs often reveals cost-effective opportunities to
prevent pollution and eliminate wastes, and encourages business decisions that are both financially
superior and beneficial to the environment. The Environmental Accounting Project (EA Project) offers
numerous educational resources that demonstrate successful environmental accounting approaches.

This collection of case studies demonstrates the successful application of environmental accounting tools
and methods in a key business area—supply chain management. Companies are fundamentally changing
how they manage their supply chains. Rigid, arms-length, customer-supplier relationships are giving
way to more tightly interconnected linkages. For example, many companies have suppliers
automatically replenish their  inventory stocks. Other companies outsource product design and
development to key suppliers  Direct interaction with supply chain partners can enable a company
to reduce total inventory levels, decrease product obsolescence, lower transaction costs, react more
quickly to changes in the market, and respond more promptly to customer requests.

Essential to supply chain performance is improving the effectiveness of materials management—the set
of business processes that support the complete cycle of material flows from purchasing and internal
control of production materials, through the planning and control of work-in-process, to the
warehousing, shipping, and distribution of finished products. Managers  can improve their materials
management performance by first understanding how their decisions affect the purchasing, storage,
handling, and asset recovery activities throughout their organization. The other component of supply
chain management is logistics—the activities to obtain incoming materials and distribute finished
products to the proper place, at the desired time, and in the optimal quantities. Companies can greatly
improve business performance by working with suppliers, shippers, distributors, and customers to
improve their logistics activities.

The environmental impact of supply chain management  decisions has received relatively little
focus.  However, a number of leading U.S. companies have  significantly increased their competitiveness
by engaging in such environmental performance-enhancing activities as:

       #  Reducing the obsolescence and waste of maintenance, repair  and operating (MRO)
          materials through enhanced purchasing and inventory management practices.
       #  Substantially decreasing the costs due to scrap and material losses.
       #  Lowering the training, material handling, and other expenses  for hazardous materials.
       #  Increasing revenues by converting wastes to by-products.
       #  Reducing the use of hazardous materials through more timely and accurate materials
          tracking and reporting systems.


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       #  Decreasing the use and waste of solvents, paints, and other chemicals through
          chemical service partnerships.
       #  Recovering valuable materials and assets with efficient product take back programs.

One reason that supply chain managers do not typically address these environmental concerns is
in the structure of traditional cost accounting systems.  Raw material and labor costs are directly
allocated to the appropriate product or process. In contrast, other costs are accumulated into overhead
accounts, which are allocated at a set proportion (e.g., based on the number of units manufactured) to all
products, processes, or facilities.  This allocation method might be appropriate for many overhead costs,
such as rent and upper management salaries. However, this approach can lead to inaccurate costing and
ineffective decisions when significant costs—waste disposal, training expenses, environmental
permitting fees, and other environmental costs—are not allocated to the responsible products and
processes.

Many companies have tackled this  issue by using environmental accounting techniques to
substantially reduce supply chain costs. With these costing methods, companies can systematically
identify environmental costs throughout the supply chain, e.g.,  costs associated with management of
hazardous materials, which typically  are not captured through conventional accounting methods.  Once
the costs (or potential benefits) have been identified, companies can analyze the cost drivers and evaluate
alternative cost reduction opportunities.

The three case studies that follow illustrate how supply chain  management practices can be improved
by determining the financial impact of business activities that have an impact on a company's
environmental performance.   Moreover, this report shows how environmental managerial accounting
approaches can be integrated into ongoing business processes.  The report includes case studies of
multi-disciplinary processes at three companies: Commonwealth Edison, Andersen Corporation, and
Ashland Chemical Company.  While the approaches vary among these companies, each one provides
valuable lessons for other companies.
                                                                                     PageS

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 ComEd
 The experience of Commonwealth Edison (ComEd), a large Chicago-based electric utility company with
 annual revenues of approximately $7 billion, demonstrates that electric utilities and other companies
 can successfully and substantially reduce their costs and environmental burdens with innovative
 accounting practices. In 1993, ComEd began to recognize that the total cost of managing materials and
 equipment was much more than the initial acquisition cost.  In particular, company managers realized
 that the costs related to environmental management were often overlooked.  This acknowledgment led to
 ComEd's first phase of life cycle management activities, which enabled them to minimize the chemical
 inventories at generating stations. These reductions and other early successes prompted ComEd to
 launch a formal Life Cycle Management (LCM) initiative in 1995. Since then a small, dedicated LCM
 staff has formed effective partnerships with ComEd operating divisions to systematically assess life
 cycle costs and benefits.

 ComEd's LCM initiative has reduced waste volume while providing approximately $50 million in
financial benefits. While these gains include improvements in supply chain management, facility
 management, and other business processes, this case study focuses on the supply chain management
 activities.

 Early Life Cycle  Management Activities

 In 1993, ComEd began to recognize that the total cost of managing materials and equipment was much
 more than the initial acquisition cost.  In particular, decision-makers did not always  consider costs
 related to environmental management. This realization catalyzed the company's life cycle management
 efforts.  One aspect of this first phase was material accounting: the identification and characterization of
 waste and by-product streams.

 Characterizing Waste and By-Product Streams
 To analyze its waste and by-product streams, ComEd participated in the development of the Electric
 Power Research Institute's (EPRF s)l Accounting Software Applications for Pollution Prevention
 (ASAPP). The software helps companies gather and track the quantities and management costs for both
 waste and by-product streams.  ComEd has used ASAPP to ensure rigorous record-keeping and thereby
 create defensible and auditable environmental materials information.

 Using ASAPP, ComEd categorizes wastes and by-products as follows: air emissions, aqueous wastes,
 chemicals and oils, coal by-products, PCBs, rad-waste, recycling, or refuse.  ComEd staff use contracting
 records and documents to identify the amount of wastes and by-products managed and associated
 management costs within each category. An excerpt from the ASAPP output from the Crawford fossil
 generating station is provided in Table 1.
     For more information about EPRI, see http://www.epri.com.

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                     Table 1. Example of Material Tracking Results2
Waste
Category
Chemicals
and Oils










Coal By-
products



PCBs


Type
hydrazine/ ammonia/ carbon
lab packs
lab waste
monosodium phosphate
oil/ fuel/ solvent
(non-hazardous)
paints
parts washer mineral spirits
rags (solvent content)
sodium bicarbonate/
ammonium
soil contaminated oil
urbine mineral oil
TOTAL
commercial bottom ash
commercial fly ash
waste bottom ash
waste fly ash
TOTAL
bulk liquid
bulk solid
TOTAL
Waste Quantity Management Costs
Percentage Percentage
Amount Units of Total Amount of Total
85
49
14
3
13
55
495
55
55
5
700
1,579
264
36,372
22,706
914
60.256
20,620
45
20.665
gallons
gallons
gallons
gallons
gallons
gallons
gallons
gallons
gallons
gallons
gallons
gallons
tons
tons
tons
tons
tons
pounds
pounds
pounds
5%
3%
1%
0%
1%
3%
31%
3%
3%
3%
44%

0%
60%
38%
2%

100%
0%

$530
$572
$189
$297
$2,209
$89
$702
$549
$122
$122
$154
$5,535
$763
$235,703
$32,810
$2,968
$272.244
$16,800
$4,526
$21.326
10%
10%
3%
5%
40%
2%
13%
10%
2%
2%
3%

0%
87%
12%
1%

79%
21%

The ASAPP accounting process was quite revealing.  Engineers used the system to identify pollution
prevention opportunities at generating stations by focusing on high waste quantities and management
costs. Based on the ASAPP data, teams at ComEd facilities investigated a number of waste streams
including coal ash, contaminated soil, and waste solvents.  The activities of the standing committee
formed to evaluate solvent procurement, use, and waste are discussed further in the next section.

While the ASAPP software tool helped identify improvement projects, ComEd realized that its
contracting records were not capturing all  of the costs associated with waste and by-product activities.
As an example, the air emission streams (including carbon monoxide, carbon dioxide, lead, nitric oxides,
          2 Management costs included disposal fees, shipping costs, and personnel expenses that could be readily
   allocated to the waste streams. For this initial evaluation, ComEd did not calculate other waste-related costs ranging
   from capital equipment investments to record keeping expenses.
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particulates, sulfur dioxide, and volatile organic matter) contained within the ASAPP database are listed
with a zero management cost because costs including air treatment equipment purchase, operating, and
maintenance costs, emission fees, and record keeping costs were not recorded in the purchase
contracting records. By keeping air emissions as a placeholder for these costs within ASAPP, ComEd
recognized the omission and plans to expand assessments to consider this wider range of costs.

Improving the  Management of Cleaning Solvents

As a result of the ASAPP process, ComEd discovered that one of its largest hazardous waste streams
was spent solvents :  on average, 60,000 gallons were generated each year.  Solvent procurement and use
therefore became one of ComEd's first targets for improvement. As shown in Table 2, a standing
committee, called the Solvents Minimization Program, was formed of representatives from each
department that uses solvents or influences that use.

                         Table 2. Solvent Minimization  Program

                                                         Committee
 Business Processes                                   Representatives
 Procurement and Contracting:                              •   Purchasing
        Vendors are selected, prices are negotiated, and contracts
        are .signed.
 Receiving and Testing:                                    '   Systems material analysis
        The appropriateness of the place of delivery is checked,
        the condition upon delivery is checked, and tests are
        conducted as[.required by.fegulato]^ requirements.	
 Warehousing and Distribution:                             '   stores an'd inventory
        Goods are stored and transported throughout the
        company.
 Operations/ Use and Maintenance:                          *   Operations
        Using the goods to perform the function for which they      .   Maintenance
        were procured.
 Recovery and Disposition:                                 '   Compliance and
        .. ..    ...   ..     . .  ,  .    .  .  .  .                   environmental services
        At disposition, it must be determined what recovery,
        treatment, disposal, and decommissioning options are
        available.

The committee first established a set of goals  and strategies.  The goals were to reduce solvent
inventories, enhance the safe working environment, minimize waste, and lower cost. The  strategies set
forth to meet these goals include two systematic assessment processes: the Inventory Minimization
Process and the New Product Evaluation Process. The Inventory Minimization Process provides initial
improvement by systematically streamlining what is  currently in inventory. The New Product
Evaluation Process acts to maintain and improve upon the gains achieved. As illustrated in Figure 1 and
described below, both processes include a systematic assessment of performance and cost.

                         Figure 1. Solvent  Reduction  Processes

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                  Inventory
            Minimization Process
              Step 1.
              Creation of a data
              catalogue.
                    Step 2.
                    Categorization of
                    catalogue
                    elements.
             Initial
          Improvement
                               Step 3.
                               Collection of
                               supporting
                               information.
                            New Product
                         Evaluation Process
                                      Step 1.
                            Vendor contact and
                           information request.
                     Step 3.
             Primary product
                  screening.
          Step 2.
Verification of new
          product
      application.
   Step 4.
Assessment of
performance.
            Continuous
           Improvement
                                                Step 5.
                                             Assessment of
                                                 cost.
                                                Step 6.
                                                Action
                                               approval.
Inventory Minimization Process
The intent of the Inventory Minimization Process is to eliminate unneeded or poorly performing solvents
from inventories. As listed in Table 3, the process employs six steps:
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                         Table 3. Inventory Minimization Process
 Step	Description
 1. Create data         A list of names, identification numbers, and uses for all solvents in
    catalogue           inventories is compiled.
 2. Categorize          Solvents are categorized by use.
    elements
 3. Collect supporting   Handling and storage and other regulatory requirements are determined for
    information         each solvent.
 4. Assess             Performance is assessed based on issues relating to cleaning ability,
    performance        purchasing and supply management, safety and hygiene, analytical
	reaujrements^and the_enyironment:	
 5. Assess cost        Costs are assessed by business process representatives as they impact
	tMLr.Qwn.an.d.reJated.artiyities.	
 6. Action approval     Recommendations are documented and presented to the committee chair for
	approval.	
For each of these steps, the team members took specific actions. For example, within Step 4, Assess
Performance, six questions were used to assess a solvent's cleaning ability:

Special Issues and Requirements
Question 1.      In your opinion, is this product an acceptable contact cleaner?
Question 2.      Does the product leave a residue?
Question 3.      Is the product corrosive to metals, vinyl, plastics, or insulation?

Performance Ranking
Question 4.      From 1 to 10 (10 being the best), rate how quickly the product evaporates
                compared to other products you have used.
Question 5.      From 1 to 10 (10 being the best), rate how conveniently the product is
                packaged for your use.
Question 6.      From 1 to 10 (10 being the best), rate the product's cleaning abilities.

The first three questions seek information related to special issues or requirements for each solvent.  The
resulting answers are qualitatively incorporated into the overall inventory assessment.

The latter three questions seek a numeric rating from 1 to 10 (1 being the worst rating, and 10 the best)
to be considered in conjunction with the matrix assessment, presented in Table 4.  The matrix provides
criteria within the four performance areas.

The ratings for these four performance areas are combined using

                                  Final Product Rating = £ \vi ru
         ,    . w; = the weighting factor for evaluation area /',

              fy = the rating (from 1 to 10) for criteriay within evaluation area /'.
                                                                                       Page 13

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Table 4. Product Evaluation Matrix
                    worst	best
Evaluation
Area
Purchasing
and Supply
Management
Environment
Safety and
Hygiene
Analytical
Criteria
cost
vendor performance
shelf life
packaging safety
availability of various sizes (unavailability of a
variety of sizes should be rated low)
storage requirements (special storage
requirements should be rated low)
difficulty in dispensing (materials that are difficult
to dispense should be rated worst)
general environmental information from MSDS
regulated by RCRA as listed waste
regulated by RCRA as a characteristic waste
proprietary vs. constituent availability (proprietary
should be rated low)
regulated by the Clean Water Act
listed and/or regulated by SARA
regulated by CERCLA
spill management and disposal instructions on
MSDS
disposal required off-site
adequate labeling on containers
specific health and safety information on MSDS
inhalation risk
skin absorption risk and irritation
ingestion risk
fire and explosion risk
product stability
hazardous decomposition potential
incompatibility
hazardous polymerization potential
venting (engineering) requirements
protective equipment requirements
storage requirements
carcinogenic potential
potential acute and/or chronic health hazard
reproductive hazard
specification analysis
laboratory capability
complexity of analysis
frequency of testing
disposal analysis
1





































2





































3





































4





































5





































6





































7





































8





































9





































10





































                                              Page 14

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Team members use a software program to calculate the final product rating. This program combines the
results of the initial six questions with the detailed evaluation results and creates a historical database of
products that have been accepted or rejected. There is also a "flagging" mechanism so that if a product
cannot meet a minimum critical standard in any assessment area, or for any reason a product has a
special characteristic pertinent to its evaluation, attention can be drawn to the issue.

Solvent Inventory Minimization Pilot Studies
The Solvent Minimization Program committee piloted the Inventory Minimization Process on cleaning
solvents used at the Will County and Crawford fossil generating stations.  Each of the six process steps
is described as follows.

Step 1. Creation  of Data Catalogue
The Compliance Engineer and the Storekeeper for each station developed a list of 15 on-site solvents
and their internal identification numbers. Fifteen cleaning solvents were identified for evaluation.

Step 2. Categorization of Catalogue Elements
First, a survey concerning cleaning solvent use was randomly distributed to "hands-on" users.
Committee members then divided the solvents into three categories based on the uses identified within
the survey: contact cleaners, electrical component cleaners, and general parts cleaners.

Step 3. Collection of Supporting Information
Associated Material Safety Data Sheets (MSDSs) were collected for all cleaning solvents being
evaluated.

Step 4. Assessment of Performance
The 15 cleaning solvents were assessed using the six questions and product evaluation matrix.  Subject
matter experts such as industrial hygienists, and a cross-section of actual end-users supported the
assessment process.

The performance evaluations indicated that the inventory of solvents could be reduced at the Will
County and Crawford stations from fifteen to three: two for contact cleaning and another for cleaning
electrical components and for general cleaning. Of the two recommended for contact cleaning, one was
identified as a superior performer but was also identified as harmful to plastics. Therefore, the second
"well  performing" contact cleaner would be maintained for applications where plastics are involved.

Step 5. Assessment of Cost
In the pilot on the Will  County and Crawford stations, eight cost elements were assessed.  However, only
three of the cost elements were quantitatively assessed. The quantified costs are presented in Table 5.

Step 6. Action Approval
The results of the performance and cost assessments were combined and the final set of three solvents
that were to remain inventory were sent to the committee chair for approval and project initiation.
                                                                                      Page 15

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Table 5. Details of the Pilot Study Cost Assessments
Business
Process
Specification
Development
Procurement
Warehousing
Warehousing
Operations/
Use and
Maintenance
Operations/
Use and
Maintenance
Operations/
Use and
Maintenance
Disposition
Cost
Element
Solvent
specification
cost
Purchase
cost
Carrying
cost of
inventory
Record
keeping cost
Cost of
OSHA and
EPA
citations
Training
cost
Cost of
solvent
misuse
Cost of
waste
disposal
Assessment Details
Assessment Type: Qualitative
The comprehensive characterization of the performance, purchasing,
environmental, and hygienic implications of solvents focuses
decision-making and, as a result, only acceptable solvents are
submitted for competitive bidding. This eliminates the time and
expense of re-specification.
Assessment Type: Quantitative
Information Source: Purchasing records
A $117,695 reduction in annual purchasing costs was realized by
evaluating the products, recommending the lower cost and better
performing products for purchase, and eliminating the rest.
Assessment Type: Quantitative
A $15,771 reduction in annual inventory carrying cost associated with
inventory reductions was realized.
Assessment Type: Qualitative
When solvents are eliminated from purchase, inventory, and use,
their associated stores numbers and MSDS maintenance are deleted
from record keeping activities, thus saving costs.
Assessment Type: Qualitative
Information Source: Committee members from Compliance and
Environmental Services
The likelihood of OSHA and EPA citations and the associated costs
are reduced by the elimination of hazardous solvents from purchase,
inventory, and use.
Assessment Type: Qualitative
Information Source: Committee members from Compliance and
Environmental Services
Cost savings result from the elimination of training requirements
because employees will not need to be trained on the use and
handling of eliminated hazardous solvents.
Assessment Type: Qualitative
Information Source: Committee members from Compliance and
Environmental Services
Because the correct application for a given product is specified, there
is a reduction in the potential for improper solvent use and for
unintended exposure of employees to fumes. Thus, potential
medical problems and time loss are avoided.
Assessment Type: Quantitative
Information Source: Waste management contracts and the ASAPP
database
           The elimination of the generation of chlorinated hazardous waste
           resulted in a $72,581 reduction in annual waste disposal costs.
                                                                Page 16

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New Product Evaluation Process
Once solvent inventories have been minimized through the Inventory Minimization Process, ComEd
employs the New Product Evaluation Process to screen solvents being considered for purchase.  The
purpose of the process is to screen and evaluate new solvents so that only those rated equal to or better
than the existing solvent will be purchased and used.  In this way, inventory minimization is maintained
while the best solvent for the best price is purchased.  As shown below, the process employs six steps.
Since the final three steps are essentially the same as those for the Inventory Minimization Process., only
the first three steps are described.

                        Table 6.  New Product Evaluation Process
 Step
 Description
 1.  Vendor contact
    and information
    request.
After initial contact, the vendor must supply a sample of the product, an MSDS,
and a product description. If for some reason the information supplied by a
vendor is inadequate, the vendor is allowed to correct inadequacies. If the vendor
cannot supply the required information, the product is rejected for use and the
.6y3jM3tJon.PJOcessjs.dj.scontjn.ued.	
There is a possibility that the product already exists as a generic specification or
under a trade name. If the product is the same as a product currently on the
approved bidder's  list, the product will be added to the list. If the product is the
same as a product that has previously been rejected, the nature of the rejection is
investigated. For example, if the previous product was rejected on the basis of
price or packaging, the vendor is afforded the opportunity to correct the
inadequacies. If the product was rejected for technical reasons, the product is no
.J.o.n9.e.r..c.P.nsjde.red.	
A primary screening  is used to evaluate new product applications or products
being evaluated for a new use.  The following questions are answered:
    Does the product meet use specifications?
    Has adequate information been supplied by the vendor including:
    •  Has the MSDS been supplied?
       Is the material a listed waste?
       Is the material a characteristic waste?
       Are there special handling and/ or storage requirements?
       Has the purchasing department qualified the vendor?
       Is the material proprietary?
 2.
Verification of
new product
verification.
 3.  Primary
    product
    screening.
The Solvent Minimization Program standing committee members carried out the Inventory
Minimization Process once at each station to reduce inventories.  In contrast, the New Product
Evaluation Process is utilized by a cross-functional station team on a quarterly basis at a minimum and
more frequently if necessary.

Solvent Reduction  Results

At the Will County and Crawford stations, the total number of solvents was reduced from fifteen to
three. When ComEd extended the process to other stations, they replaced over 100 different cleaning
solvents in ComEd's inventories with non-hazardous substitutes.  As illustrated in Figure 2, the
immediate effect was an 88% reduction of hazardous solvent waste from  1992 to 1994. Because
solvents were a major contributor to hazardous waste volumes, a subsequent result was a 66% reduction
                                                                                       Page 17

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in ComEd's overall hazardous waste generation during the same period. Additionally, whereas in 1991
thirty-two ComEd stations were large quantity hazardous waste generators, by 1994 this program had
reduced this number to thirteen. The program continues to look at other alternatives, such as aqueous
cleaners (McCann, 1995).

                    Figure 2. Hazardous Solvent Waste Generation
.** ouu.uuu
+->
5
CD 250,000-
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 2
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(/) ;<' 1O(J,(J(J(J
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^ ^^ IDU.UUU
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(/5 n
















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m
                                                                n Non-Chlorinated
                                                                  Solvents
                                                                n Chlorinated
                                                                  Solvents and Oils
                                                                • Chlorinated
                                                                  Solvents
                                                                D Naptha
                               1992
1993
1994
The extension to other stations also contributed to substantial cost savings for ComEd. Table 7 lists
savings in disposal costs alone (McCann, 1995).  Since disposal cost reductions are only a small part of
the savings realized, ComEd expanded the effort and created a dedicated Life Cycle Management team
that helps each of the business units develop and apply these cost-reduction tools.

        Table 7. Disposal Cost Savings from Solvent Minimization Program
Costs
Equipment service
Chlorinated solvent disposal
Oil/ chlorinated solvent disposal
Non-chlorinated solvent disposal
Annual Total
Savings
1992
$140,113
$50,095
$22,194
$3,939
$216,341

1994
$135,836
$1;940
$9;702
$7;232
$154,710
$61,631
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Lessons Learned
Defining the Life Cycle
Among the lessons from the Solvents Minimization Program, ComEd realized that potential
improvements in solvent inventories, including cost reductions, could be generalized to all chemical
commodities. In fact, ComEd has renamed its Solvent Minimization Program the Chemical
Commodities Minimization Program. Furthermore, they recognized that improvement efforts could be
expanded from chemical commodities to all resources. Within this context, ComEd has defined
resources to include all materials (input materials, by-products and wastes) and equipment that are
acquired or generated in the course of its operations.

Finally, it was clear that the business, cost, and environmental implications of the decision to acquire
each resource initiated a chain of responses throughout ComEd's businesses. For example, a decision to
procure a solvent made from a hazardous material was found to affect business processes including
specification development, procurement, warehousing, operations, and disposition. To avoid
overlooking potentially significant impacts, ComEd defined the life cycle of each resource to include
four broad stages:

                           Table 8.  ComEd's Life Cycle Stages
                                     Design involves determining needs and
                                     specifying a required resource.

                                     Acquisition involves purchasing (or creating),
                                     storing, and transporting the resource.

                                     Consumption involves the actual utilization of
                                     the resource.
                                     Disposition involves recovery or disposal of the
                                     resource at the end of its useful life.
Encouraging Holistic Decision-Making
While the four-stage life cycle is applicable to all types of decisions, getting decision-makers to
explicitly address all four stages as a part of both day-to-day and project-oriented decisions remains a
challenge. Even the Solvent Inventory Reduction example did not address the entire life cycle. Since the
team began the solvent inventory assessments by focusing on currently used solvents, some
improvement opportunities associated with the cleaning processes themselves were neglected.  If an
assessment started with questions directed at, for example, the need to clean, the following questions
might be asked by the decision-makers:

       # Why are parts considered dirty?
       # How do parts get dirty?
       # Can parts be kept from getting dirty?
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       #  What performance criteria are you trying to enhance by cleaning?
       #  Are there other ways to attain that performance?
       #  How do you know when a part is clean?
       #  What factors influence cleaning frequency?

Confining assessments to the existing set of solvents used by ComEd restricted the range of options
examined.

ComEd decision-makers are now encouraged to start by thinking through associated business processes
and potential opportunities in each of the four stages of the resource life cycle. Decision-makers may
choose to first look at a disposition decision to meet an immediate compliance or pollution prevention
need. In a related analysis, the decision-maker may  decide to look at decisions made in an earlier stage
of the resource life cycle to find a longer-term solution. The expectation is that as decisions are
evaluated in earlier stages of the life cycle, opportunities for greater savings will be identified.

As one step to encourage a broader scope in day-to-day and project decision-making, ComEd developed
the following mles-of-thumb directly linked to the stages of the resource life cycle:

       #  Design or choose resources that last longer, are more efficient, or create less waste.
       #  Acquire resources that actually cost less than others do over time.
       #  Consume resources more efficiently.
       #  Dispose of what is left more economically or find other uses for it.

In addition to these rules-of-thumb, station managers are provided with hazardous and solid waste
reports and a set of standard metrics to track performance related to the disposition stage of the resource
life cycle.  These reports provide annual waste generation and cost trends by waste type. Metrics include
pounds of waste by facility; dollars spent on waste disposal; pounds of waste per employee; and dollars
spent on waste disposal per employee (Hemmady, 1996).  Such information provides a means to
benchmark immediate needs with the expectation that longer-term issues will be assessed when possible.

Considering a Broader Range of Costs
Through experiences within the Solvent Minimization Program and the use of ASAPP, ComEd
identified additional types of costs that could be linked to waste and by-product streams. ComEd
discovered that:

       #  Costs and savings can be attributed to a  variety of business processes throughout the
          resource life cycle.  Several of these costs and business processes are listed in Table
          9. By considering more business processes, additional cost reduction and revenue
          opportunities are highlighted. For example, the consideration of disposition can lead
          to opportunities to obtain revenues through material recovery.
       #  Some costs and savings can be linked directly to business processes as captured
          within existing information systems. For example,

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          # Purchasing costs can be identified from purchasing records, and
          # Waste disposal costs can be identified from waste management contracts and the
             ASAPP database.
       #  Some costs and savings can be linked indirectly to business processes but are not
          traditionally allocated to a specific resource or business process. The cost of
          managing air emissions, reported as "zero" in ASAPP, is one example of such an
          indirect cost.  Costs including air treatment equipment purchase, operating, and
          maintenance costs, emission fees, and record keeping costs have not been included.
          Although these costs and savings tend not to be tracked within existing information
          systems, employees working within each business process can infer them.  Once
          identified, ComEd found these costs and savings relatively easy to qualify but
          sometimes difficult to quantify.
       #  In addition to incurred costs, there are some resources that pose an uncertain risk of
          future costs.   For example, the true costs of "solvent misuse" and "OSHA and EPA
          citations" are dependent upon the nature of the misuse or citation.

Finally, ComEd envisioned the total life cycle cost of a resource to be the cumulative cost incurred or
potentially incurred throughout the resource life cycle. As provided in Table 9, ComEd has linked these
costs to the stages of the resource life cycle to provide a starting point for ComEd decision-makers.

Costs or savings not incurred or potentially incurred by ComEd are not included in ComEd's definition
of the total resource life cycle cost.  For example, the costs associated with property damage and health
impacts caused by acid rain as linked to air emissions are not included as management costs.
                                                                                    Page 21

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                   Table 9. Linking the Life Cycle Stages to Costs
Life Cycle
Stages Direct Costs
Definitions Incurred costs that are
traditionally allocated to an
activity
Stage 1 :
Design
Stage 2:
Acquisition
Stage 3:
Consumption •
Stage 4:
Disposition
Oil, :
•
Preparing
specifications and
drawings
Testing
Disposing of testing
materials
Purchasing
Taxes
Shipping
Financing
Labor
Equipment
maintenance
Incoming inspection
Resource storage
Resource recycling
Resource treatment
Resource transport
Resource disposal
Insurance
Indirect Costs
Incurred costs that are not
traditionally allocated to an
activity
Designer training
Record keeping
Material handling
Storage
Record keeping
Delivery to job site
Employee training
Industrial hygiene
Employee training
Waste analysis
Reporting and record
keeping
Uncertain Costs
Costs that potentially may
be incurred in the future
Managing spills or
accidents in testing
Complying with new
regulations
Managing spills or
accidents in storage
and handling
Disposing and
replacing of obsolete
resources
Resource misuse
Managing spills or
accidents in use
Packaging disposal
Equipment failure
Occupational
exposures and injuries
Complying with new
regulations
Legal liabilities
Employee health
claims
Keys to LCM Success
In the course of deploying the LCM initiative, ComEd has developed a number of important insights
regarding life cycle cost methodology and tool development as well as integration into business
decision-making. Many of these insights are transferable to other companies that are striving to improve
their supply chain management or other business processes. The six keys to the success of ComEd's
LCM initiative are

       #  Applying a systematic approach. By addressing the four life cycle stage and three
          different cost categories, ComEd was able to identify and then reduce costs that had
          been traditionally overlooked.
          3Adapted from ComEd, 1996
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       #  Maintaining a dedicated LCM staff drawn from business units.  The central LCM
          staff supports initial decision-making activities, encourages the use of LCM tools and
          principles in subsequent decisions, and is available for additional support when
          needed.
       #  Engaging cross-functional decision-making teams. The participation of
          representatives from a variety of business units brought more information to decision-
          making, reduced unanticipated implications, and created buy-in among participants
          and the departments they represent.
       #  Using appropriate decision support tools. Tools such as the ASAPP material
          tracking software can greatly help educate decision-making groups about the
          application of life cycle cost methods. For ComEd, the most successful approach has
          been a facilitated session, in which a knowledgeable  and skilled facilitator will guide
          the decision-makers through the process of identifying cost elements, estimating the
          range of costs, and evaluating the results. This type of session can dramatically
          reduce the time required to pilot and demonstrate a new capability.
       #  Beginning with disposition and then working upstream  The original catalyst
          behind ComEd's LCM initiative was  a desire for waste reduction.  Successful projects
          that revealed business benefits in this area provided a basis for moving upstream in
          the life cycle to address inventory and purchasing issues.
       #  Maximizing investment recovery. One of the best ways to minimize life cycle costs
          is through the reuse of existing resources. Special attention should be given to
          alternatives involving idle resources that are already available or can be modified to
          meet current requirements.

Areas for Improvement
There are, however, some issues are still to be resolved.  Potential enhancements to the process could
include:

       #  More effectively engaging financial staff. Engineering and operations personnel
          look to the corporate financial staff for guidance and  support in economic analyses,
          particularly when capital investment is involved.  Corporate groups are accustomed to
          applying powerful analytical tools to strategic financial decisions involving
          significant uncertainty and risk. These groups are naturally reluctant to endorse broad
          application of a life cycle cost management methodology that could be applied
          inconsistently or incorrectly by poorly trained users.  On the other hand, there is
          strong central support for managing resources on the  basis of life cycle costs, and the
          obvious efficiency of distributing powerful decision-making tools  is extremely
          compelling.
       #  Assessing liability costs and other uncertain costs. Considering the full set of
          uncertain costs provided in Table 9 is an iterative process.  For example, evaluating a
          potential liability could spotlight additional improvement opportunities.  As
                                                                                     Page 23

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          experience is gained, the value of considering a wider range of costs becomes more
          apparent.
       #  Applying lessons learned to fuel choice decision-making.  Since fuel selection
          greatly influences a utility company's overall cost structure and environmental profile,
          utilities might be able to improve their overall performance by applying these
          environmental accounting tools.

Looking Ahead

Since ComEd began its life cycle management activities, the company has discovered the benefits of
broadening the scope of decisions to consider a range of business processes and the full range of direct,
indirect, and uncertain costs.  The LCM initiative has simultaneously reduced waste volume and
provided approximately $50 million in financial benefits. As shown in Table 10, this total includes
contributions related to supply chain  management, facility modification, and other business processes.
The financial benefits represent revenues and savings that definitely will be realized through existing
contracts or operating practices. The majority of these contracts are expected to be renewed and
therefore will continue to yield financial  benefits.

                      Table 10. Results of ComEd's LCM Initiative

           Business Process                                Financial Benefit

          Supply Chain management (including materials                ,,,„.-  ....
                    ...     .    . .      ,                     tb^o minion
           procurement and equipment maintenance)

           Facility management (including modification and
                   .
          expansion)

          Other                                                   $4 million

                                                   TOTAL         $50 million
ComEd's overall objective is to make life cycle management a fundamental part of their decision-
making.  Accordingly, the focus of the LCM initiative is shifting from demonstration projects to projects
that integrate effective LCM practices into key business processes.

For example, the generation business units are making life cycle cost analysis an element of the project
authorization and management processes.  Similarly, the transmission and distribution organization is
incorporating life cycle thinking into redeveloped material management decision-making processes. In
each case, LCM integration is part of overall process and organization changes being undertaken to
address other business needs. Active involvement by LCM staff in such business unit organizational
change initiatives will enable effective integration.
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A number of projects are underway to support the process integration efforts. Software development and
targeted training are intended to expand the use of analytical tools for managing life cycle costs.
Alignment of organizational goals and incentives continuing remains a challenge. Pilot projects are
expected to play a continuing role in demonstrating the value of effective life cycle management in
achieving both collective and individual goals.  The development of relevant metrics, useful
performance reports, and efficient information systems will also be important to the life cycle
management strategy.
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ANDERSEN  CORPORATION
The activities of Andersen Corporation illustrate how a company can improve its financial and
environmental performance  by using environmental managerial accounting information in supply chain
management decisions.  As the largest manufacturer of wood windows and patio doors in North
America with annual revenues of approximately $1 billion, this company achieved substantial financial
and environmental benefits when it began incorporating environmental considerations into its
purchasing, materials handling, inventory, and disposition decisions.

In the late 1980s, executives at Andersen released a directive to their staff to reduce emission levels of
toxic chemicals. In response to the directive, Andersen managers formed a Corporate Pollution
Prevention Team whose mission was to eliminate the use, release, and transfer of hazardous chemicals.
This multi-disciplinary team conducted a waste accounting project, developed waste reduction goals,
and justified waste reduction projects by developing several business cases that quantified
environmental and other cost savings. For example, the team justified the purchase of an improved
system for mixing paints at point-of-use  based on the savings from improved material usage rates and
reduced waste.

Based on their initial success, company managers recognized that a more systematic implementation of
environmental accounting techniques would improve their ability to make strong business cases for a
wide range of projects.  Accordingly, they developed procedures for environmental cost assessments for
a number of supply chain management activities. The process leads to more comprehensive and lucid
business cases, including detailed IRR schedules that incorporate savings from increased material
efficiency and reduced waste streams.

A Call to Action

In the late 1980s, executives at Andersen directed their staff to reduce the emission levels of toxic
chemicals. At the time, Andersen regularly used six of seventeen chemicals that are designated by U.S.
EPA as priority  chemicals.   (Andersen emitted or transferred off-site more than 1.1 million pounds of
these chemicals in 1988.)  In addition to this federal requirement to publicly report these emissions, the
state of Minnesota had recently passed a regulation requiring facilities that must report Toxic Release
Inventory (TRI) emissions to develop pollution prevention plans. The law defines pollution prevention
as "eliminating or reducing at the source the use, generation, or release of toxic pollutants, hazardous
substances and hazardous wastes."  Facilities must also identify the specific technically and
economically practical steps that could be taken to "eliminate or reduce the generation or release of toxic
pollutants reported by the facility." Finally, this regulation requires companies to investigate potential
upstream process changes that will reduce or eliminate a toxic release.
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At the time, Andersen's environmental, health and safety staff were already inundated with regulatory
paperwork. Furthermore, Andersen managers anticipated even more stringent environmental regulations
on the horizon4.

Team Formation
For a considerable time, Andersen multi-disciplinary teams have supported technical and business
decision-making for a considerable time.  Teams are established to achieve specific corporate goals,
address operational concerns, and identify and implement improvement projects.  Team members can
include and engage representatives from any function including plant management, materials
management, engineering, finance, purchasing, and research and development.

Andersen managers and staff responded to the call to action by forming the Corporate Pollution
Prevention Team. The team's initial mission was to  eliminate the use, release, and transfer of TRI
chemicals.  Eventually, the team added goals to eliminate the use of chemicals identified in EPA's 33/50
program5 and to reduce the use and emissions of volatile organic compounds (VOCs).  While these
regulatory concerns were the catalyst, one important result was the improvement of many supply chain
activities, including improved material handling processes,  increased recovery of wood wastes and other
materials, and involvement with key suppliers to eliminate the sources of some emissions. The team
was comprised of representatives from technology, business, and engineering groups. They worked
closely with other plant personnel and reported periodically to an executive committee.

The team began seeking ways to reduce toxic emissions while simultaneously achieving business and
other environmental benefits. Several facets of the company's culture supported a team approach to this
challenge, including:

   #     Use of multi-disciplinary teams to address technical and business issues,
   #     Use of established financial assessment methodologies that could be easily modified to
          incorporate environmental costs, and
   #     To support continuous improvement, communication of results both internally to
          technical and business personnel and externally  to Andersen's customers and
          communities.

Decision  Process

Andersen teams generally follow an established decision-making process.  The four basic steps are listed
below. The Corporate Pollution Prevention Team's use of this process follows and demonstrates how
this process helped Andersen realize both economic and environmental goals.
          4 From Adams, L. "Company Closes Window on Emissions:  Andersen Corp. has been named a 'Success
    Story' by the U.S. Environmental Protection Agency after dramatically reducing toxic chemical emissions in its
    finishing operations." http://vwvw.iswonline.com/archives/wood/fnfjan.html.
          5 The U.S. EPA created the 33/50 program to encourage companies to voluntarily reduce emissions of
    seventeen priority chemicals, including six targeted by Andersen. The program name is derived from its goals: a
    33% reduction in emissions by 1992 and a 50% reduction by 1995, using 1988 emissions as a baseline. Having
    reached the program goals one year ahead of schedule in 1994, the 33/50 program was successfully concluded.

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       Identification - Characterize situation, establish goals, and identify technical options
       Evaluation - Determine likely results of improvement projects
       Justification - Prepare a business case with anticipated costs and benefits
       Implementation - Decide, implement project, and communicate results

Identification
The Corporate Pollution Prevention Team began by brainstorming a set of indicators for measuring the
types and volumes of wastes generated. These indicators provided a baseline for measuring
improvement as shown in Table 11.  The Team selected five indicator categories to help them address
regulatory requirements and other  environmental issues, such as water consumption and solid waste
generation. The resulting indicators included both absolute and normalized waste quantities.

                     Table 11. Andersen's Wastes and Emissions6'7
Category
TRI emissions

33/50 chemical
emissions

VOC emissions

Solid waste

Water use

Indicator
TRI emissions
TRI emissions/ units shipped
33/50 emissions
33/50 emissions/ units shipped
VOC emissions
VOC emissions/ units shipped
Solid waste to landfill
Solid waste to landfill/ units shipped
Water used
Gallons of water used/ units shipped
Metric
Tons
Pounds
Tons
Pounds
Tons
Pounds
Tons
Pounds
Gallons

1988 Value
972
-
626
-
3,753
-
23,986
-
412,800,000
-
The team members obtained the waste and emission data from a variety of sources, especially
contracting records and interviews with plant personnel. As the team completed this baseline analysis,
they identified the specific processes that contributed to the five waste streams. An example of this
breakdown is shown in Table  12. Based on the detailed information, the team prioritized improvement
initiatives.
          6The team calculated the normalized metric values, but for confidentiality reasons, they are not presented in
   this report.
          7 Please note that the emissions categories overlap. The 33/50 chemicals are an important subset of the
   TRI chemicals.  Also, some of the VOC chemicals are included in the list of TRI chemicals.

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                       Table 12.1998 VOC Emissions by Process

                                                              VOC Emissions
            Process                                        (Tons)     (Percent)

            Wood Preservative                                  2,490           67%
            Painting                                            780           21%
            Miscellaneous Processes                             2g7           go/
            (storage tanks, combustion, and adhesiyes)
            Vinyl Processing                                     186           5%
                                                   Total    3,753
This information helped the team focus on the processes that contributed most to the facility's overall
pollution levels.  As shown above, most of Andersen's VOC emissions came from the wood
preservative and painting operations.  The team pursued a variety of projects to reduce these wasted
materials. Their method (i.e., decision-making steps 2 through 4) can be illustrated by focusing upon
one particular project. Therefore, the discussion below willconcentrate on the effort to reduce toxic
emissions from their painting operations for Double Hung Windows.  The team identified a variety of
technical options, but found that a meter-mix system was the only one that could improve product
performance and easily integrate with current operations.8

The meter-mix paint blending system mixes pigmentation and cure agents at the point-of-use.  Since the
components are not mixed until just prior to application, only small amounts of paint are wasted and less
paint dilution solvents are required. In contrast, the predecessor system mixed paints in lot-size batches.
Considerable paint was wasted because the two component paints became too viscous if production
delays occurred after the batch mixed.

The improvement goals of the meter-mix system project were to increase process control, and to reduce
paint waste and air emissions from the production lines. When the project was proposed, the team
estimated that converting the paint lines in one area to the meter-mix system would reduce the
company's overall TRI emissions by 1.3% and VOC emissions by 7%.

Evaluation
Next, team members linked cost savings, material savings, and waste reductions to the proposed
meter-mix project. This financial and non-financial information was required to  develop a solid
business case.  While the initial objectives were environmentally driven, the team was able to identify a
number of business benefits for the meter-mix project as shown in Table 13.
          8 Note that the team did not evaluate more fundamental product design issues such as "the need to paint."
   Andersen has since recognized that focusing on incremental options limits the magnitude of potential improvements
   and fails to encourage breakthrough innovations.

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          Table 13. Cost and Material Reductions of the Meter-Mix Project
 Project Goals
Anticipated Material
Reductions
Related Cost Reductions
 Reduce paint and
 solvent wastes
   Reduced pigment and
   solvent use
   Pigment and solvent cost reductions
   Waste treatment, transport, and disposal cost
   reductions
 Reduce TRI and
 VOC emissions
   Reduced TRI and
   VOC emissions
   Decreased emission fees
   Reduced personnel time for record keeping and
   other environmental activities
Andersen teams had always considered the cost savings from anticipated material reductions in their
financial analyses. In contrast, the effort to also quantify the savings associated with decreased waste
management expenses was a novel approach. The team decided to include both material and waste costs
when calculating the financial benefits of the meter-mix and other improvement projects.  While the
material-related savings from the meter-mix project were substantial, these potential savings were not
recognized prior to the pollution prevention team's effort. Thus, the focus on environmental
performance led to some substantial operating benefits. The team's assessment of environmental costs
and material reductions for the meter-mix system is shown in Table 14.

                 Table 14. Improvements from the Meter-Mix Project
Cost Element
Paint Use and Waste Reductions
Paint materials, purchase and shipping
Waste treatment, transport, and disposal
VOC emissions and associated fees
Dilute Solvent Use and Waste Reductions
Solvent materials purchase and shipping
Solvent emissions and fees
Flush Solvent Use and Waste Reductions
Solvent materials purchase and shipping
Solvent emissions and fees
TOTAL ANNUAL SAVINGS
Material
Reductions

3,509 gal./yr.

15,515lb./yr.

8,050 gal./yr.
53,309 Ib./yr.

2,252 gal./yr.
12, 360 Ib./yr.

Annual
Savings

$110,374/yr.
$14,387/yr.
$162/yr.

$58,710/yr.
$560/yr.

$10,687/yr.
$130/yr.
$1 95,01 0/yr.
Percent of
Savings

56.6%
7.4%
0.1%

30.1%
0.3%

5.5%
0.1%

Table 14 links reductions in raw materials and waste materials directly to costs. Material use and waste
reductions have been allocated by material type: paint, dilute solvent, and flush solvent. Listing annual
material reductions and annual savings in the same row allowed the team to easily view benefits by
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material type.  In the case of paint, the annual use and waste reduction totaled 3,509 gallons. Data for
the quantitative assessment were obtained by team members from purchasing and contracting records.

As shown above, the team found that savings related to avoiding material purchases and shipping costs
dominated the cost assessment.  Furthermore, the team found that although quantifying material
reductions associated with emissions provided valuable information to decision-makers, quantifying
emission fees contributed little to the overall cost assessment.

However, the team recognized that they had not quantified all of the cost savings that would be realized.
Additional savings would include those listed in Table 15. For example, by reducing the need to manage
toxic raw materials and wastes, the company decreased its risk of incurring spill cleanup costs, and
related legal liabilities. Thus, the team began to demonstrate how environmental costs influenced the
company's bottom line.

                     Table 15. Analysis  of Non-Financial Elements

 Activity            Non-Financial Assessment
 Material handling    The project eliminates the  costs associated with handling and storing  3,509
 and storage         gallons of paint, 8,050 gallons of dilute solvent, and 2,252 gallons of flush
                     solvent.
 Waste handling      The project reduces costs  associated with handling and storing 3,509 gallons  of
 and storage         waste paint and to train employees in associated safe handling procedures.
 Analysis,            The project eliminates costs associated with material analysis, handling, and
 reporting/ record     reporting/ record keeping (3,509 gallons of paint, 8,050 gallons of dilute solvent,
 keeping             and 2,252 gallons of flush  solvent) and waste (3,509 gallons of waste paint and
                     emission of 81,184 pounds of VOCs) for internal and regulatory audiences.


Justification
After identifying the material and waste reductions, and anticipated cost savings, the team developed a
business case for the meter-mix system.  Since  Andersen teams usually include a payback period and an
internal rate of return (IRR) schedule within each business case, the team calculated the values based on
the future cost savings shown in Table 16.  Several types of cost  savings were included in this financial
analysis:

       #  Paint materials — purchasing and shipping costs
       #  Waste — treatment, transport, and disposal costs
       #  VOC emissions — associated fees
       #  Solvent materials — purchasing and shipping costs
       #  Solvent emissions — material losses and associated fees.

With this cost information, the team demonstrated that the installation of the meter mix system was
attractive  because the quantified costs yielded a 18-month payback and 58% internal rate of
return. The payback calculations were relatively straightforward, as shown below.

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                                        P=II M
Where,
      P = Payback period (months)
      I = Investment ($)
      M = Monthly savings ($/month)

Based on the forecasts in Table 16, the initial investment (I) was $130,100 and the monthly savings (M)
during the first two years averaged $7,146.  With these values, the payback period can be calculated as
18 months.
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                 Table 16. Meter Mix Internal  Rate of Return Schedule
                  YearO    Year 1    Year 2   Year 3    Year 4    Year 5     Total
INVESTMENT
Equipment ($115,541)
Installation and ,«14wn
other expenses (*14'bba)
Total Investment ($130,100)
($115,541)
($14,559)
($130,100)
 COSTS
 Additional, costs              ($109,355)  ($115,302) ($124,941)  ($133,161)  ($140,438) ($623,197)
       Total Costs	($109,355)  ($115,302) ($124,941)  ($133,161)  ($140,438) ($623,197)
 SAVINGS
 Paint Use and Waste Reductions
 Paints purchase             $110,374    $113,685   $117,096   $120,609  $124,227   $585,991
 & snipping
                            $14,387    $15,106   $15,862    $16,655   $17,487    $79,497
Dilute Solvent Use
Solvent purchase
& shipping
Solvent emission
losses & fees
Flush Solvent Use
Solvent purchase
& shipping
Solvent emission
losses & fees
Total Savings
NET BENEFIT
& Waste Reductions
$58,710
$560
& Waste Reductions
$10,687
$130
$195,010
($130,100) $85,655

$60,471
$588

$11,008
$137
$201,165
$85,863

$62,285
$617

$11,338
$143
$207,520
$82,579

$64,154
$648

$11,678
$150
$214,082
$80,921

$66,079
$681

$12,028
$158
$220,857
$80,419

$311,699
$3,094

$56,739
$718
$1,038,633
$415,436
Notes and assumptions:
        #  "Operating costs" are additional costs required to operate point-of-use system
        #  3 % annual increase in material and labor costs
        #  5 % annual increase in all other costs, e.g., waste management

The IRR calculations are more complex but fortunately a variety of software packages, including
standard spreadsheet packages, can compute these values. The internal rate of return is the interest rate
at which the net present value (NPV) of the investment is zero. It takes into consideration the amount
and timing of the costs, savings, and revenues of the investment.9
          9Similarly, companies can directly calculate the investment's NPV. The NPV is based on the company's
    cost of capital and considers the amount and timing of the investment's capital outlays, savings, and revenues. An
    NPV greater than zero indicates a profitable investment and, as with IRRs, the higher the NPV the better.

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The higher the IRR, the better the project.  A money-saving project will have a high IRR because it will
have a positive value even if the future cost savings are discounted heavily. The IRR calculations are
shown below.
 For the meter mix system,

        NPV=0= -$130,1 00 + $85,655 /(! + /##) + $85,863 /(l

               $82,5797(1+ IRR)3 + $80,9217(1 + IRR)4 + $80,4197(1 + IRR)5

Solving this equation by trial-and-error shows that the IRR is 58%.  The trial-and-error approach is
somewhat tedious, but again, many software packages can quickly compute IRR values.
These and other analyses demonstrated the operating and environmental benefits of making this
investment. As shown, the cost savings linked to the loss of purchased material (paint and solvent) that
previously left the facility as waste is the most significant financial benefit.


The team's business case for the meter-mix system included  quantitative assessment of material use and
waste reductions, assessment of additional environmental costs, and IRR schedule.  Thus, the business
case demonstrated how the project supported plant and corporate environmental goals.

Implementation
Since the business case demonstrated the financial and environmental merits of the meter mix system,
managers approved the project and installed the new system  on paint lines in the Double Hung Windows
production area.

For the meter mix and other successful projects, the Corporate Pollution Prevention Team supports
communication by providing the following documentation prior to, during, and upon completion of
project implementation:

       Project Review Sheets summarize input from key plant and corporate personnel prior to final
       approval. Statements from plant managers (including time study comments), environmental
       (including permit status), electrical, machine design engineers, and facility engineers,
       maintenance and health and safety managers are included.
       Plant Communications reports document project status and results, and communicate them
       throughout the organization. Project information include the date of completion, project scope,
       benefits  gained, and the names of project leaders. In  addition, the team presents a summary of
       results at an annual meeting for the operating  managers and support staff.
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In addition to internal communications, Andersen externally publicizes their waste reduction successes
through promotional documentation focusing on environmental protection, as well as by highlighting
environmental awards, such as their recent Minnesota Governors Award.10

Supply Chain Improvements

Based on the success of the meter mix system and other initial activities, the Corporate Pollution
Prevention Team targeted several other areas to reduce toxic chemicals and other wastes. These target
areas included several supply chain activities, such as paint hook cleaning operations, paint operations,
and glass handling.

Reusable Packaging for Glass
Two of Andersen's significant solid waste streams were cardboard packaging and broken glass.
Packaging was highlighted as a high volume waste during the initial analyses of the company's solid
waste stream. While the glass waste stream was not as large, the subsequent  review of associated costs
showed that the material losses  were quite costly. Additionally, a number of employee injuries were
caused by handling broken glass.

The team had determined that the corrugated shipping boxes for incoming glass and accompanying
broken glass were significant solid waste streams, so the team began working with its glass suppliers to
decrease these volumes.  One of the suppliers was able to develop a plastic, reusable packaging system
that:

        #  Essentially eliminated the corrugated waste stream since the plastic containers are
           collapsed after usage and returned to the supplier.
        #  Greatly reduced the glass breakage that occurred during the receiving and inventory
           steps because the reusable containers were more protective.
        #  Reduced Andersen's overall costs by $127,000.  Most of these savings resulted from
           the decreased breakage.
          10Andersen's 1997 award information can be viewed at http://www.moea.state.mn.us/berc/govaward97.cfm.

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Paint Formulation
While the meter-mix project was primarily an internal project and did not address fundamental design
issues, the Corporate Pollution Prevention Team was heavily involved with suppliers during other
projects to reduce emissions from the painting processes.11'12 For example,
Andersen purchasing agents met with their several paint suppliers and requested that they eliminate the
TRI chemicals from their paint formulations.  To provide an incentive for the suppliers, Andersen
committed to work closely with them during the evaluation process and to purchase a substantial portion
of their paint from any suppliers that achieved the goal. Over a three-year period, the suppliers
developed new paints.  The new formulation had to perform  as well as, or better, than the original
chemistry. In 1995, non-TRI solvents, including methyl amyl ketone (MAK), n-butyl acetate, and
isobutyl acetate, were adopted and helped the company reduce its TRI emissions waste stream.

Paint Hook Cleaning
 At Andersen, wood and fiberglass window and door parts were painted using a vertical paint application
 system.  The components were hung from paint hooks  and hangers. When these hooks and hangers
 became coated with the durable paint and needed cleaning, they were immersed in methylene chloride, a
 paint remover. After the cured paint softened, the fixtures were rinsed with xylene. This cleaning
 process released both methylene chloride and xylene and created sludge that had to be treated as
 hazardous waste.


In the 1980's, Andersen made a number of attempts to replace the paint hook cleaning system, but was
not able to find an effective alternative. In 1992, the company tested a paint burn-off, or "oxidation
process,"on this material handling system.  In this process, fixtures are heated and the cured paint is
burnt off resulting in non-hazardous residuals. Since Andersen did not have the type of ovens required
for this cleaning process, the company outsourced the operation to a nearby supplier. A financial
analysis confirmed that outsourcing the activity would significantly lower overall costs, including the
energy costs at the supplier and the cost of additional purchasing transactions.

The project succeeded and reduced methylene chloride  releases from 29,100 pounds in 1988 to 13,000
pounds in 1992.  Because of this improvement, Andersen was able to drop methylene chloride from its
annual TRI report starting in 1993. Additionally, xylene releases were reduced by approximately 50,000
pounds annual cost savings reached $28,000.

While the financial gains certainly justified the project,  the actual impetus was a desire to minimize
worker exposure to methylene chloride.  A focus on pollution prevention and consideration of EH&S
costs (e.g., sludge disposal costs) helped the company achieve this goal.
           11 Several companies have engaged their suppliers to reduce the life cycle costs and impacts of their
    products and services, see US EPA, The Lean and Green Supply Chain: A Practical Guide for Materials Managers
    and Supply Chain Managers to Reduce Costs and Improve Environmental Performance, January 2000.
           12From Adams, L. "Company Closes Window on Emissions: Andersen Corp. Has been named a "Success
    Story" by the U.S. Environmental Protection Agency after dramatically reducing toxic chemical emissions in its
    finishing operations." http://vwwv.iswonline.com/archives/wood/fnfjan.html.

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Overall Results
Since the Corporate Pollution Prevention Team's inception, Andersen has greatly reduced its toxic
emissions, off-site transfers, and other waste streams.  As shown in Table 17, improvements ranged from
18% to almost 100% between 1988 and 1996. In fact, Andersen was recently named a 33/50 Program
Success Story by the EPA because the company substantially reduced the use of three chemicals -
methylene chloride, methyl ethyl ketone and toluene - in its work place.

                       Table 17. Improvements in Waste Metrics

                                                             1988    1996
Cateaorv

TRI emissions
33/50 Chemical
emissions
VOC
emissions

Solid waste
Water use

Indicator
TRI emissions
TRI emissions/ units shipped
33/50 emissions
33/50 emissions/ units shipped
VOC emissions
VOC emissions/ units shipped
Solid waste to landfill
Solid waste to landfill/ units shipped
Water used
Water used/ units shipped
Metric
Tons
Pounds
Tons
Pounds
Tons
Pounds
Tons
Pounds
Thousands
of Gallons
Gallons
Value
972
-
626
-
3,753
-
23,986
-
412,800
-
Value
66
-
66
-
1,507
-
725
-
236,904
-
Chanae
93%
90%
89%
99.9%13
60%
46%
97%
95%
43%
18%
In addition to these environmental gains, the company has achieved a number of operating
improvements. The annual cost savings for the company's improvement projects ranged from $28,000
to $316,000. Finally, Andersen has also realized a number of non-financial benefits. For instance, the
primary justification for eliminating the use of methylene chloride in the paint hook cleaning process
was to improve worker health by eliminating the potentially hazardous compound.

Lessons Learned

The Corporate Pollution Prevention Team and Technology & Business Development Group identified
and implemented a number of projects that reduced waste streams, while providing financial, product,
and operating benefits. The initial goal was to reduce emissions, but the teams justified projects with
business cases that addressed both environmental and material costs. Through their activities, Andersen
has learned the importance of:

   #     Using multi-disciplinary teams, including supplier organizations, to identify, develop, and
          assess improvement options;
          13 Although not completely eliminated, emissions have been reduced far below reportable thresholds.

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   #     Linking environmental costs to categories of materials managed by the plants to help
          decision-makers develop cost and material assessments;
   #     Integrating environmental costs into the company's standard financial assessment method
          to create compelling business cases;

   #     Combining environmental cost information with material use and waste reduction
          information to link business and environmental goals;
   #     Recognizing that environmental accounting tools, especially material tracking activities,
          can enable environmental improvements and identify opportunities for operating
          improvements;

   #     Realizing that quantifying some environmental cost elements is not always required to
          justify environmental improvement projects,;and
   #     Communicating improvements both within and outside the organization helps maintain
          the team's momentum and enables others to replicate their success.


While the efforts are certainly commendable, case study reviewers noted that Andersen's program could be
enhanced by

   #     Focusing on opportunities for substantive innovations in addition to incremental
          improvements of the current operations.
   #     More extensively engaging suppliers and other supply chain partners to understand the
          life cycle costs of Andersen's products. These interactions support product design and
          materials management changes that lower overall supply chain costs.  Andersen has taken
          some significant steps in this direction but hopes to extend this practice in the future.

   #     Using activity-based costing and other techniques to determine the financial significance
          of hidden EH&S activities.
Looking Ahead

Andersen is continuing to reduce the environmental impacts associated with its products and operations.
Thus far, the team efforts have accomplished impressive environmental gains while simultaneously
improving a number of materials management and production operations.

   #     The meter-mix project had a 58% IRR and saved $80,000 annually.
   #     Other projects by the Corporate Pollution Prevention Team reduced costs by up to
          $250,000 annually.
   #     The net environmental result of these and other projects was a 93% reduction in TRI
          emissions, and substantial reductions in all major waste streams.

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   #     Other groups, including the Technology & Business Development Group, have replicated
          the successful use of environmental accounting techniques. For example, an analysis of
          the recovery of waste materials and using the resulting Fibrex™ Composite material in
          one product line demonstrated $250,000+ in annual savings.

The highlighted examples improved the company's material handling, material recovery, and waste
disposition process.  Further efforts will likely influence other materials management processes,
including purchasing and inventory management. As mentioned, Andersen hopes to broader the scope
of future projects by including suppliers and designers. The company recognizes that such an integration
is an iterative process and will build upon their initial successes.

In a variety of ways, Andersen Windows is improving the environmental performance of its operations
and products. Materials tracking and other environmental accounting tools have enabled teams to
support this corporate mission.  Andersen and many other companies have realized that environmental
accounting approaches help them achieve environmental objectives while improving overall operating
effectiveness and efficiency.
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ASHLAND SPECIALTY CHEMICAL COMPANY


While a number of companies have adopted environmental accounting practices, relatively few have
fully integrated these activities with their established cost accounting methods. The Electronic
Chemicals Division of Ashland Specialty Chemical Company piloted an Environment, Health and Safety
(EH&S) cost evaluation as part of their 1999 manufacturing cost analysis.  The corporate financial
auditing team and an external consultant led a process of identifying and quantifying a number of cost
reduction opportunities. Several of these opportunities supported the company's overall goal of using
materials more efficiently and minimizing waste.

This case study describes how the company piloted the integration of its Manufacturing Cost Analysis
and EH&S Cost Study and provides specific tools that can help companies realize similar objectives.
These tools include a detailed list of environmental activities, a representative list of interviewees, and a
time allocation worksheet for capturing hidden EH&S costs.  The integration effort uncovered at least
one sizeable cost reduction opportunity and has highlighted the benefit of making EH&S cost
considerations an established part of its cost audits.


Activity-Based Accounting Approach

As part of Ashland's efforts to continually increase productivity, the company developed a
manufacturing cost analysis (MCA) program and applied it within several divisions.  The goal of these
projects was to identify cost reduction opportunities and begin the implementation process.  The four
steps of a MCA project are

1. Financial Analysis - Gather financial data and segregate it into cost pools.

2. Cost Model - Determine critical activities and assign costs to products.

3.  Breakthrough Team Process - Establish  team, identify cost issues, and  create plans to achieve
    efficiencies and realize savings.

4. Final Presentation - Present findings to management team and obtain approval for recommended
    changes.


MCA project implementation recommendations have included changes in product pricing schedules,
process improvements, and product development opportunities. These projects are initially staffed by
members of the  corporate audit group (2-4) and then augmented by several employees from the sites
under evaluation. MCA projects are typically completed in 10-15 weeks.

When Ashland's Electronic Chemicals Division decided to apply the MCA process to two of its
production facilities in 1999, the division wanted to deliberately incorporate Environmental, Health and
Safety (EH&S) costs.  The EH&S Cost Study would be run concurrently with the MCA process. Plant
and corporate managers anticipated that EH&S costs would be significant and wanted to not only

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understand how to reduce these costs but set the stage for achieving a long term goal of permanently
integrating EH&S costs into the MCA process. Since expertise in evaluating EH&S costs did not reside
in-house, the company retained an external consultant (Mr. David Vogel of The Gauntlett Group, LLC)
to help them with this initial EH&S costing effort. Management determined the EH&S Cost Study
would be a learning opportunity for their staff and internal EH&S costing experience would be portable
to other facilities.

The external consultant focused on helping Ashland during the first half of the Manufacturing Cost
Analysis, as shown in Figure 3. Once the EH&S costs had been identified, the Breakthrough team
incorporated these costs into the final two  steps.  Thus, Ashland pursued opportunities to reduce both
EH&S costs and a number of other costs during the MCA project.
EH&S Cost Study
The three primary steps that occurred during the Ashland EH&S cost study were

       1. Preparation

       2. Cost Identification

       3. Validation
   Figure 3. Point of Introduction of EH&S costs to Ashland MCA Cost Analysis
                                                     Breakthrough
                                                    Team Process
      EH&S Cost Analysis
      Manufacturing Cost Analysis
Preparation began by building an "activity-based" costing model that included some 32 typical EH&S
activities that commonly occur at manufacturing sites (see Table 18). Next, Ashland site personnel and
the consultant refined this model by adding pertinent activities and deleting irrelevant ones. Then,
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working with plant management, the consultant identified the individuals most knowledgeable about the
agreed-upon EH&S activities and created an interview schedule to be followed during the plant visit.

      Table  18. The Gauntlett's Group List of Typical Environmental Activities

 Code   Activity Description	
 01       Training and Preparedness
 02       Obtaining Permits
 03       Tracking Regulatory Requirements
 04       Studies/Modeling
 05       Qualifying/Re-qualifying Supplies and/or Materials
 06       Record Keeping
 07       Developing Environmental Plans, Policies, Procedures, etc.
 08       Communicating Environmental Plans, Policies, Procedures,  etc. with Organization
 09       External Communications, Community Relations, Financial Support to Environmental Groups
          and Researchers
 10       Monitoring and Reporting
 11       Inspections and Audits
 12       Environmental Insurance and Financial Assistance
 13       Protective Equipment
 14       Medical Surveillance
 15       Spill Response
 16       Storm Water Management
 17       Re-engineering to Meet Environmental Objective
 18       Site Studies
 19       Site Preparation
 20       Habitat and Wetland Protection
 21       Operating Environmental Equipment
 22       Maintenance of Environmental Equipment
 23       Waste Management - onsite
 24       Recycling Materials
 25       Handling and Storage of Hazardous Materials
 26       Disposing of Non-Hazardous Wastes - offsite
 27       Disposing of Hazardous Wastes - offsite
 28       Remediation onsite - includes studies, closure, and past-closure care
 29       Remediation offsite - includes studies, closure, and past-closure care
 30       Fines, taxes, penalties

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 31       Litigation and Claims - property damage
 32       Acquisition/Divestiture Due Diligence
As part of these preparatory activities, the consultant visited an Ashland facility for one day to get an
overview of the facility's operations and EH&S activities. This visit and some initial interviews were in
preparation for a more intensive visit to review such activities in greater depth and interview key
personnel while accumulating related cost information.  This subsequent visit was scheduled to coincide
with the presence of Ashland's MCA team on the site.

Cost Identification: Identifying Potential Costs with Interviews
During the plant visit, the consultant individually interviewed a number of employees for about 20-30
minutes each to obtain an understanding of the EH&S activities within their sphere of responsibilities
and to  gather related cost information. The interview process was essential in identifying potentially
significant EH&S costs. Results from this process the EH&S Cost Study team to establish priority
ranking for potentially large costs that called for subsequent data collection.  Costs not deemed
significant were eliminated from further data collection efforts.

Employees were asked to describe EH&S activities and estimate the amount of hours they devote to
these activities, as well as other resources committed to these activities (e.g., materials and supplies,
outside contractor or consulting fees, etc.).  Interviews were deliberately informal, to insure that staff did
not feel constrained in providing information to the consultant.

Additionally, if a corporate group provides EH&S  support to the site, the consultant identified these
activities and interviewed appropriate corporate EH&S staff to obtain information about the amount of
hours and other resources employed (e.g., consultant fees).  In this case study, there were several EH&S
activities supported by corporate effort, and such costs are included in this report. A list of the facility
and corporate EH&S staff is shown below in Table 19. Identification of both corporate and facility
EH&S costs is crucial to obtaining the full costs of EH&S activities within a facility.

                         Table 19.  List of Personnel Interviewed

 Facility Personnel	Corporate EH&S Personnel	

 Acting Plant EH&S Manager (Feb. 1999)    Air Permit Engineer
 Chemical Analyst - Rework/Waste Issues   Air Quality Manager
 Engineering & Maintenance Manager        Industrial Health & Toxicology Manager
 Inventory Specialist                     Permit Tracking & Performance Metrics Specialist
 Lab Technician                         Process  Safety Engineer
 Plant EH&S Manager                    Safety Engineer
 Plant Manager                         Safety Specialist

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 Process Engineer                       Safety Specialist
 Process Engineer                       Water & Waste Specialist
 Production Manager
 Production Supervisor
 Training Manager
 Warehouse Supervisor	
Validation: Confirming the Interview Findings

The results of the interview process highlighted several potentially significant EH&S costs. That
information was used to develop questionnaires seeking additional information on the EH&S activities
identified in the interview process.  Questionnaires and other methods such as safety training logs,
financial records and operational data were used to validate the interview results.  These analytical
activities provided essential supporting data.

The first tool  of the Manufacturing Costs Analysis process was a time allocation worksheet that the
MCA team sent to the entire workforce at the plant. As shown in Table 20, exempt (salaried) and non-
exempt (hourly)  employees were asked to estimate how they spent their time during an average week.
Based on input from the EH&S accounting team, the worksheet included three EH&S categories.

Another method was data anlysis.  The external consultant and supporting team members reviewed
shipping manifests, safety records, training records, and other documents. For example, the training
records confirmed that Ashland was investing a substantial amount of employee time into EH&S
training.  This activity was initially highlighted during the interview process and confirmed with the
company's records.  In light of the significant training costs, the company will continue to review course
content, training methods, and other approaches to maximize effectiveness.

Wherever possible, the significant results from the interviews were investigated and confirmed with one
or more record auditing steps. Auditing steps for Ashland, included reviewing training records for all
personnel to determine hours actually spent on training and looking at operation logs of the waste water
treatment process, identified during the interview process, to calculate actual costs of operation. . This
step greatly strengthened the resulting recommendations.
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                   Table 20.  Time Allocation Worksheet
Area
Process
Percentage of Monthly Time
Receiving:
- Packaging Supplies, Equipment,
Miscellaneous Supplies
- Non-Bulk Raw Materials
- Bulk Raw Materials
- Customer Returns
Lab
- ACT Lab Activities
-WPC Lab Activities
Processing/Blending
- ACT products
- WPC Performance products
Production/Packaging
-TankWagon Fill
- Performance/Core Products, Manual
- Autoline
- Drumline
- ACT Manual
- Miscellaneous Work Orders (MWOs)
Bottling
Reclass
Dumping/Repouring
Waste Disposal
Warehouse
Shipping
Maintenance
EH&S Activities
- Production of plastic bottles
- Reclassifying product (different grade,
changing lot numbers)
- Repouring/consolidating products
- Disposing of Drummed Waste.
Neutralization Pit Activities.
- Warehouse
- Shipping
- Maintenance
- Meetings/Training/Drills
                       - Special Handling/Putting on Personal
                       Protective Equipment
                       - Other on Job Activities (e.g. - special
                       EH&S procedures, lockout-tagout, record
                       keeping, spill response)
Administrative
 - While Doing Your Job
 -Training
 - Meetings
 - Other (Please specify)
TOTAL (should equal 100%)
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Breakthrough Process

A formal part of Ashland's Manufacturing Cost Analyses is a Breakthrough Process to determine which
cost reduction opportunities are most promising. Since both the MCA and the EH&S Costs Analysis
addressed the entire set of manufacturing and supply chain activities, the Breakthrough team was able to
evaluate several areas, including:

       #  Product Pricing - changing the company's pricing structure to better reflect actual
          costs
       #  Product Mix - changing the number or types of products offered to customers
       #  Product Development - identifying how to produce and deliver the new products more
          cost effectively
       #  Resource Efficiency - identifying opportunities to reduce capital investments,
          especially equipment
       #  Process Efficiency- determining how to increase the efficiency of the current
          manufacturing and supply chain processes
       #  Productivity Improvements - evaluating alternative manufacturing approaches


As stated earlier, the EH&S Costs Analysis supported the plant's overall cost improvement project.
Therefore, the Breakthrough team was able to address EH&S cost reduction opportunities.

The Breakthrough Process began by adding team members who were interested, capable, and able to
represent all of the important functions. The final team consisted of 11 individuals from plant
management, engineering, production control, financial auditing, product management, and  human
resources. The team composition was determined during the cost analyses so that team members could
be actively involved in the early stages. This  early involvement helped speed-up and smooth the
transition into the Breakthrough Process.

As soon as the auditing and EH&S teams finalized the cost analyses, the Breakthrough team began its
four-week evaluation. They began by reviewing the summary and detailed results of the two studies. As
shown in Figures 4 and 5, the team evaluated cost information by both category and activity. Only
aggregate levels cost are shown in Figures 4 and 5.  Major cost categories were further subdivided to
support decision-making.
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       Figure 4. Total EH&S Costs by Cost Category
                     Depreciation
                        (11%)
     Corporate (1%)
                                         Labor (32%)
                    Outside
                   Payments
                     (56%)
           Figure 5. Total EH&S Costs by Activity
 Training &
Preparedness
    7%
                   All other
                   Activities
                    31%
     Disposal of
      Hazardous
        Waste
        18%
           Permits and
           Regulatory
           Requirements
              8%
   Waste
Management &
 Hazardous
                         Workers'
                        Compensation
                            17%
Record Keeping
 & Monitoring
     10%
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The in-depth review of the cost results helped the team identify potential cost reduction opportunities.14
The team used Pareto charts which show that "usually 80% of the potential improvements can be
achieved by pursuing only 20% of the opportunities." The team searched for several indicators of cost
reduction possibilities, including

       #  The manufacturing areas that had the highest costs (either total or per pound of
          product).
       #  The specific manufacturing activities that had the highest costs (either total or per
          pound of product).
       #  The support areas and activities (e.g., quality assurance laboratories and EH&S
          activities) that had the highest total costs.
       #  The areas and activities that had costs much higher than expected by manufacturing
          and supply chain personnel (the "surprise factor").
       #  The products that had the highest costs.
Armed with this information, the team evaluated each of the high priority opportunities. The goal was to
determine which specific improvements could be implemented and estimate the likely financial return
from each improvement.  The Breakthrough team used a variety of approaches to complete this step,
including reviewing historical data, benchmarking their plant's performance to other Ashland facilities,
interviewing customers and suppliers to understand which changes were feasible, and engaging plant
personnel in problem solving sessions.

Final Presentation

The Breakthrough step was followed by a presentation to the division's senior management group. The
Breakthrough team reviewed their activities and presented eight cost reduction recommendations that
would yield a significant annual savings.  In addition to these short term recommendations, the team
proposed evaluating a number of other longer-term opportunities that appeared promising but could not
be fully evaluated during the four-week time period.

Several of the cost reduction plans supported Ashland's goal of improving its overall environmental
performance, and one of them was particularly noteworthy.  Based on the results of the EH&S Cost
Study, the team recommended changing the plant's wastewater and by-product neutralization process.
The existing process required a substantial amount of personnel to monitor, record, and adjust the
operation.  The external consultant and internal personnel realized during the EH&S cost study that the
plant already had most of the information and analytical systems necessary to automate the process and
          14 During the interviewing and other cost analysis steps, the teams had already developed several
    promising ideas. However, the Breakthrough team reviewed the results of the cost analysis to confirm those ideas.
    The team also identified a number of opportunities that had been overlooked previously.

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greatly reduce personnel expenses. The Breakthrough team confirmed those findings and estimated that
the annual cost savings would be sizeable.

For each of the recommended changes, the team provided the following information:

       #  Description of the required change
       #  Savings Potential (annual cost reduction)
       #  Estimated Investment
       #  Process Owner (specific individuals responsible for implementing the change)
       #  Target Completion Date (between one and six months)


The team received approval on all of their recommendations and began the implementation phase.
Implementation was only beginning at the time this report was written, so results are not included here.
However, Ashland's focus on quick,  effective implementation was demonstrated by the senior
management group's request for a follow-up meeting four months after the Breakthrough
recommendations. At that time, the team will present the implementation progress and evaluations of
the longer-term opportunities.

Lessons Learned

The Electronic Chemicals Division of Ashland Specialty Chemical Company was able to incorporate a
full set of EH&S costs into its recently completed Manufacturing Cost Analysis.  After an external
consultant helped Ashland identify and analyze the EH&S costs, the improvement opportunities were
judged along with a variety of others. While only one of the EH&S opportunities was included in the
initial set of eight high-priority projects, several others are still being evaluated. Additionally, the
company has taken some steps to begin consistently incorporating EH&S costs into a variety of business
decisions. Some of the lessons from this effort include:

       #  Work with a corporate group to understand their current approach so that EH&S
          considerations can be addressed with minimal changes to the existing process
       #  Leverage an external consultant to  quickly develop EH&S cost accounting
          capabilities
       #  Use a series of interviews with individuals from both the manufacturing facility and
          the corporate EH&S group to identify the major cost issues
       #  Confirm the initial set of cost issues with by reviewing a variety of records, including
          training records,  shipping manifests, and production reports
       #  Initiate the implementation phase by obtaining senior management approval.
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Looking Ahead

Both the Manufacturing Cost Analyses and EH&S Cost Study are relatively new to Ashland Specialty
Chemical Company. Each of the company's business divisions has the authority to choose which, if
either, improvement process will be deployed in their business unit. While the corporate organization
funded the development of these capabilities, continued use will require funding from the business units.
In other words, the longevity of these processes depends upon the team members' abilities to
consistently reveal and implement cost reduction opportunities.

This initial effort to integrate EH&S considerations into the company's broader cost reduction program
proved successful and will continue.  The integration revealed at least one significant cost reduction
opportunity and helped the audit team members better understand the plant's operations. As a
demonstration of the audit team's satisfaction with the results, the team has added an EH&S module to
the cost model that they will use in future projects.

The EH&S cost studies are one part of the company's program to increase the awareness of EH&S
considerations throughout the company and to integrate them into core business decisions. Since the
activity-based costing studies reveal hidden and contingent costs that are commonly overlooked during
supply chain and other decisions, these studies support the company's dual objectives of improving
financial and environmental  performance. Ashland's EH&S organization anticipates that the cost
studies will support several other initiatives including information systems development, supplier
management programs, and chemical management services program.
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REFERENCES
In addition to these references, an extensive set of annotated references on environmental accounting and
supply chain management is provided in The Lean and Green Supply Chain (see below).

Ashland.  1999. "EH&S Costs Baseline Study, Final Draft Report." Internal Documentation, August
      20, 1999.


Ashland.  "Environmental Cost Accounting Project - Easton, PA; Plant Visit to Overview EH&S
      Activities." Internal Documentation, February 12, 1999.


Ashland.  "Manufacturing Cost Analysis; Easton ECD Plant; Breakthrough Team Action Plan." Internal
      Documentation. July 8, 1999.

ComEd. "Maximizing Assets, Minimizing Environmental Impacts Through Life Cycle Management."
      Promotional documentation.  1996.

ComEd. Opportunity Prioritization System. Draft Internal Documentation.  1998.

Decision Focus Incorporated (DFI). Life Cycle Cost Management Case Study of Transformer
      Disposition.  Prepared for ComEd and the Electric Power Research Institute.  1995.


Del George, Louis.  Fulfilling Environmental Commitment Through Life Cycle Management. Presented
      at the POWER-GEN International '96 Conference.  1996.

EPA.  The Lean and Green Supply Chain: A Practical Guide for Materials Managers and Supply Chain
      Managers to Reduce Costs and Improve Environmental Performance.  EPA 742-R-99-003.
      February 2000.

Hall, Tom. "Final Report: Chemical Commodities Minimization Program."  Internal memorandum.
      1992.

Hemmady, Neena.  Pollution Prevention Internship Program, Illinois Environmental Protection Agency
      and Illinois Institute of Technology. Personal Communication. 1996.

McCann, B.M. "Governor's Pollution Prevention Award Application." April 27, 1995.

McLearn, Mary. Electric Power Research Institute (EPRI). Personal communication.  September 4,
      1997.


The Gauntlett  Group.  "List of Typical Environmental Activities." February 1999.

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Tramm, Tom.  Managing Life Cycle Costs with CBMS. Internal Documentation, 1997.
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