A Cooperative Project
between the
U.S. Environmental
Protection Agency
and PWB
 December 1997
 EPA 744-F-97-009
                                                                          PRINTED WIRING BOARD CASE STUDY 7
              PRINTED WIRING
              BOARD PROJECT
        Identifying Objectives for Your

    Environmental Management System

   In 1996, H-R Industries became the first printed wiring board
   (PWB) manufacturer in the U.S. to obtain ISO (International
   Organization for Standardization) 14001 certification. H-R
Industries has proven that you don't have to be a large,
multinational firm to benefit from this certification, or from
having an environmental management system (EMS). A wholly-
owned subsidiary of McDonald Technologies, Inc., H-R
Industries has 300 employees producing multi-layer PWBs at its
manufacturing facilities in Richardson and Bonham, Texas.
    ISO 14000 is the international standard for environmental
management, much like ISO 9000 is the standard for quality
management. ISO 14001 provides the framework for an EMS.
An EMS is a systematic way to review and improve operations
for better environmental performance. Companies have found
economic as well as environmental benefits from implementing
an EMS. Whether or not they intend to obtain ISO 14001
certification, companies have seen that an EMS helps them use
materials more efficiently and streamline operations.

Why an EMS?

    Why would a PWB company like H-R Industries decide to
seek ISO 14001 certification? Before initiating its EMS, H-R
had a good environmental compliance program and was active
in implementing environmental projects to move the company
beyond compliance. These programs were working well;
however, they were strictly the domain of the Environmental,
Health and Safety staff. Without widespread integration of these
programs into other departments in the company, further
environmental improvements were going to be hard to achieve.
H-R Industries viewed an EMS as the way to incorporate
environmental management into all levels of company
operations and decision-making processes. Since implementing
their EMS, awareness of environmental issues has risen in all
employees, from the CEO to workers on the shop floor.
    Other benefits of establishing an EMS have included:
    • long-term economic benefit of balancing and integrating
      economic and environmental interests.
    • consolidation of all environmental programs into one
      coherent system. "It's the glue that holds all your
      environmental programs together," according to H-R
      Industries' Process Engineering Manager.
    • competitive advantage as customers may soon prefer, or
      even require, that suppliers have ISO 14001

"If You Fail to Plan,  You Plan to Fail"

    The stages of an  EMS, as required for ISO 14001, are:
    0   Environmental Policy
    6   Planning
    6   Implementation and Operation
    0   Checking and Corrective Action
    @   Management Review
    These stages form a continuous cycle of reviewing,
revising, and building upon your original EMS to move your
company toward continuous environmental improvement.
    The Environmental Policy and the Planning stages form
the foundation of your EMS. Your company's commitment to
the environment is stated in your Policy. It should include a
description of your commitment to continuous improvement,
pollution prevention, and compliance with relevant regulations.
Your entire EMS will  be designed to implement the principles

set in your environmental policy.
     The Planning stage is critical to the success of your
EMS. If you spend the time to develop a sound, meaningful
plan, you will likely be rewarded with improved
environmental results. As the saying goes, "if you fail to plan,
you plan to fail." This case study focuses on two of the
critical planning steps of the EMS:
• Environmental aspects—identifying the environmental
aspects of your operations and determining which are
• Objectives and targets—setting objectives and establishing
targets based on your significant aspects.

Identifying Environmental Aspects

     All parts of the Planning phase build on identifying the
significant environmental aspects of your operations. An
environmental aspect is any element of your business that can
interact with the environment. The ISO 14001 EMS also
refers to "impacts." Impacts are the actual or potential
changes to the environment resulting from any of the
environmental aspects. The relationship between aspects and
impacts is one of cause and effect, and is best illustrated with
examples, as in Table 1.
     One of the best ways to identify the environmental
aspects of your operation is by developing a Process Map.
This exercise involves mapping every step of your process
and the inputs and outputs associated with each step.
Developing a Process Map is best accomplished as a team
effort. Representatives of a variety of departments and at
diverse levels should be included to produce the most
accurate description of your inputs and outputs. For this step,
and throughout the EMS, working together as a team is likely
to produce the best results.

 Which Aspects are  "Significant?"

     While the ISO 14001 standard establishes the structure
of the EMS, there is a lot of latitude for a company to develop
the content that best fits its operations. For example, each
company selects a method for identifying significant
environmental aspects that best suits its needs. For most
businesses, it is critical to choose a method that is simple and
easy to understand. The method you use also must be clearly
documented. This documentation is needed for the ISO 14001
audit, and also, you will want to review your original list of
environmental aspects to help set future objectives.
     Described below are two methods for identifying
significant aspects. The description of these methods in this
Table 1 : Examples of Environmental Aspects land
Associated Impacts
Environmental Potential IMPACTS of each
Metals discharged
VOC emissions
Scrap generation
Solid waste generation
Water use
Electricity use
Degradation of aquatic
habitat and drinkinjg water supjily
Contribution to smog;
degradation of air quality
Degradation of land,
habitat, water supply
Degradation of land,
habitat, drinking water supply
Use of natural resources
Contribution to global
warming; degradation of air quality
case study does not represent recommendations by EPA, but
is instead provided as general information about how some
companies have appproached the task of identifying
significant aspects. EPA's Design for the Environment
Program will soon begin working with several companies in
the PWB industry to  develop specific information on how to
incorporate pollution prevention and design for the
environment considerations when identifying significant
environmental aspects.

Expertise-Based  Method to Identify Significant

     H-R Industries utilized the expertise of its staff to
determine the significant environmental aspects of its
operations and to set objectives. Managers from the
Marketing, Operations, Environmental Health and Safety, and
Engineering Departments met with the CEO to brainstorm
how the activities of their area impacted the environment.
This team identified  aspects associated with the day-to-day
functioning of the plant, focusing on those aspects over which
they had some control or influence.
     For each aspect identified, they determined the
associated potential or actual environmental impact. The team
came up with a long list of the environmental aspects and
their associated impacts. They then grouped similar ideas on
the list. For example, they identified water use in their
electroless copper process and water use on their alkaline
etchant line as aspects, and grouped both of these into one
"water use" aspect. Next, they set out to determine which
aspects were significant, based on the managers' expertise.

For each aspect they considered the severity, the frequency,
and the location of its impact. After many iterations, they had
a final list of significant environmental aspects.

Criteria-Based Method to Identify Significant

     Other companies have developed a simple set of criteria
to walk them through the steps in identifying their significant
environmental aspects. The table below shows one possible set
of criteria and how to rank them. In the table, aspects are
ranked based on six criteria that were considered most
important to this fictitious facility. The aspects in the table
were then reviewed by a team of employees from different
departments in the company. Reviewers ranked the aspects for
each criteria on a scale of zero to five. The aspects with total
scores of 10 or greater were deemed significant.
     The advantage of this systematic approach is that the
selection process is clearly documented for future review  (and
for the ISO  14001 certification staff). Again, it is important to
select criteria that are simple — the easier the system, the
more likely it will be followed.
     While the criteria, ranking, and scoring method may
work for this facility, it may not accurately reflect the
environmental considerations of others. The specific criteria,
the number of criteria, and the scoring system need to be
determined  by each facility, based on the guidelines described

Guidelines for Identifying Significant Aspects

    Whichever method you find most suitable for
determining your significant aspects, there are some basic
guidelines to follow:
 >•  Refer back to your environmental policy. The method
you choose for selecting significant aspects should be
consistent with your environmental policy, and should reflect
the principles stated in your policy.
 >•  Verify that your method applies to all processes. The
selection method you use to determine which aspects are
significant should be general enough so that it can be applied
to any process in your facility. For example, "worker health
and safety" is a general criterion applicable to all processes,
whereas "worker exposure to formaldehyde" is too specific to
be applied to all operations in your facility.
 >•  Your method should stand the test of tune. You will
need to use the same method when you re-evaluate your
aspects. Make sure the criteria you use for determining
significance are documented and in line with your longer-
term environmental goals.

Setting Your  Objectives and Targets

     Once significant environmental aspects are identified,
use them as the basis for setting your objectives and targets.
Select a manageable number of objectives. The objectives do
not need to address every significant aspect, as shown in
Table 3. To decide which aspects to select, consider some of
the non-environmental factors of each, such as:
•    regulatory requirements
•    technological opportunities or barriers
•    economic and business requirements
•    the team's opinions
Table 2: Example of Criteria to Determine Significant Environmental Aspects*
Criterion > Worker H&S Toxicity Impact on
Nat'l Resources
Metals in wastewater 4 3
VOC emissions 2 3
Generation of scrap boards 3 2
Generation of solid waste 1 0
Water use 0 0
Electricity use 0 0
Potential for
Wasted Disposal $
Materials $
3 4
,1 0
fe 3
4 3
§ 2
3 0
TOTAL Significant?
23 X
16 X
10 X
10 X
Abbreviations: H&S = Health and Safety; $ = Cost
*These aspects, criteria, and rankings were developed for this case study and are not based on an actual facility.

! Tabte 3: Relationship Between Aspects, Impacts, Objectives, and Targets
Environmental Aspects
Melals discharged
VOC emissions
Scrap generation
Solid waste generation
Water use
Electricity use
Potential Impacts of Each Aspect Significant?
Degradation of aquatic habitat X
and drinking water supply
Contribution to smog; reduced air quality
Degradation of landj habitat,_ water supply X
Degradation of land, habitat, X
drinking water supply
Use of natural resources X
Contribution to global warming;
degradation of air quality
Reduce metals in

Not addressed at this time
Maximize recycling of
non-hazardous materials
Reduce water use

Reduce metals entering
waste treatment by 20%

Not addressed at this time
Recycle one additional
material not currently
Reduce water use by 20%

It is important to note that environmental impacts were taken
into consideration in identifying which aspects were
significant, but these business considerations can play an
important role in setting your objectives and targets.
     After achieving some initial successes, your team should
revisit the significant aspects that were not addressed in your
objectives. It is this systematic process of continuously
evaluating environmental aspects and meeting objectives that
drives an organization toward continuous environmental
     EPA's DfE Program would like to thank H-R Industries
for participating in this case study, along with DfE PWB
Project participants from Circuit Center, Inc., and Concurrent
Technologies Corp., who provided advice and guidance.
         Printed on paper that contains at least 50% recycled fiber.
What is the Design for the Environment (DfE)
Printed Wiring Board Project?

     The U.S. Environmental Protection Agency's (EPA's)
Design for the Environment (DfE) Printed Wiring Board
Project is a cooperative, non-regulatory effort in which EPA,
industry, and other interested parties are working together to
develop technical information on pollution prevention
technologies specific to the PWB industry.
     To date, the DfE Project has focused on conducting a
comprehensive evaluation of alternative technologies for
making through-holes conductive. The Project is now
evaluating alternatives to the hot-air-solder-leveling process.
By publishing the results of these evaluations, DfE is able to
provide PWB manufacturers with the information to make
informed business decisions that take human health and
environmental risk into consideration, in addition to
performance and cost.
     The Project also identifies and publicizes other pollution
prevention opportunities in the industry through the
development of PWB case studies such as this one. These case
studies, and other documents from the DfE Project, are
available from:
     Pollution Prevention Information Clearinghouse
     U.S. EPA 401 M Street, SW (7409)
     Washington, DC 20460
     phone: 202-260-1023; fax: 202-260-4659
     e-mail: PPIC@epamail.epa.gov
     DfE PWB information: http://www.epa.gov/dfe
     The DfE Program welcomes your feedback. If you
implement any of the ideas in this series of PWB case studies,
or have any comments, please call the DfE Program at 202-
260-1678 or e-mail us at oppt.dfe@epamail.epa.gov.