A Cooperative Project
between the
U.S. Environmental
Protection Agency
and PWB
 December 1997
 EPA 744-F-97-010
                                                                           PRINTED WIRING BOARD CASE STUDY 8
                 PRINTED WIRING
                 BOARD PROJECT
Building an Environmental Management

            i: H-R Industries' Experience

               jronmental management system (EMS)
                    overwhelming task, especially for a
                  fpzed_ company, but many of the ele-
                                e in place at your facil-
                         yures to track environmental
                           tollution prevention plans
                         a significant head start for de-
                                 board (PWB)  manu-
                                :o EMSs, since they are

                                  .at their existing ISO
                                 "em a significant ad-
                             3nndustries became the
                             UlilnlSO 14001 certifi-
                                    and is a wholly
                      rald Techno^&ies, Inc. With ap-
                      at faifflHSMRichardson and
                               a wide range of multi-
                                itional standard for envi-
                               closely modeled on ISO
                             :cant overlap between the
                           ents are similar, and some are
                          systems, whether for quality or
JwJ^aflflards.  Many oft
 nearly identical. Managem^
                      share common elements including
                     ting procedures, training, recordkeep-
                    itive action.
                                                              This case study introduces the initial steps necessary for devel-
                                                          oping an EMS, and shows the similarity between the requirements
                                                          for ISO 14001 and ISO 9000.

                                                          Do You Need an EMS?

                                                              As cornpanies strive to improve their management of environ-
                                                          mental issues and increase profits at the same time, many have
                                                          found that an EMS can do more than improve their environmental
                                                          performance  it can help them meet their business goals too. By
                                                          providing a systematic way to review and improve operations for
                                                          better environmental performance, an EMS can help a company
                                                          use materials more efficiently and streamline operations.
                                                           Companies that have implemented EMSs have
                                                           experienced benefits such as:

                                                                 better environmental performance
                                                                 cost savings in operations
                                                                 increased efficiency of operations
                                                                 resource conservation
                                                                 lower insurance costs
                                                                 improved public relations
    Even companies not pursuing certification are using the ISO
14001 model for their EMSs because it is quickly becoming the
industry standard for environmental management. By basing your
EMS on the ISO framework, you can go on to apply for certifica-
tion under ISO 14001, if it makes sense for your company. Any
company cian reap the benefits of an EMS, whether or not the
company plans to obtain ISO certification.

First Steps in Creating an EMS

    Getting management buy-in and assessing your current prac-
tices up-front will save you a lot of time when developing your
    Gain management commitment.  Upper management can
demonstrate their commitment by playing an active, visible role in
the EMS implementation process, providing funding and allocat-
ing resources, and promoting employee awareness and motivation.
An EMS should be viewed as a tool to achieve continuous envi-

ronmental improvement, rather than daily "firefighting" just to
keep up with regulatory requirements.
    Review your current environmental programs. Once
you have management commitment, the next step is to conduct
and document a preliminary review of your company's current
environmental programs and management systems.  This
process includes reviewing your existing environmental man-
agement policies, operating procedures, and training programs,
as well as your methods for identifying your regulatory require-
    Determine what's missing. Next you need to evaluate
how closely existing procedures conform to the requirements of
an ISO 14001  EMS. Such a "gap analysis" identifies the actions
necessary to build your EMS. To do this, you'll need to
compare your existing procedures to the five main stages of an
ISO 14001 EMS.
    0   Environmental Policy
       Implementation and Operation
       Checking and Corrective Action
       Management Review
Repeating these five steps forms a cycle of continuous EMS
improvement, with the overall goal of improving environmental

Links Bebveen ISO 14001 and ISO 9001

    If your company is ISO 9000 registered, the gap analysis
may reveal that many of the materials already prepared for your
quality system will be helpful in developing your EMS. This is
because ISO 9000 and ISO 14000 use similar management
frameworks. Table 1 provides an outline of the ISO 14001 EMS
standard and shows corresponding ISO 9001 elements, where
they exist. The ISO 9001 standard is used for comparison in
this case study because it is the most comprehensive of the ISO
9000 series of standards. Most of these comparisons are also
applicable to facilities registered under ISO 9002.
    The most direct linkages with ISO 9001 occur within three
phases of the EMS: Implementation and Operation, Checking
and Corrective Action, and Management Review. The elements
addressed within these phases, such as organizational structure
and responsibility, training, document and records control, and
audit and management review requirements, have direct paral-
lels within the ISO 9001 system. In some cases, however, there
is no direct link between ISO 14001 and ISO 9001.

The H-R Industries Experience

    H-R Industries has been active in reducing the environmen-
tal impact of its operations  in past years through changes such
as using glycol-free strippers and aqueous solder masks. The
company viewed the creation of a formal EMS and ISO 14001
certification as a way to achieve discipline in its environmental
programs, incorporate environmental responsibility into all job
descriptions, demonstrate industry leadership, and gain a mar-
keting advantage.
    When in-house staff at H-R Industries conducted a gap
analysis, they found that they would be able to borrow signifi-
cantly from their ISO 9002 Quality Management System. The
overlap included using the same forms and stamps to indicate
document approval, and using the same procedures and person-
nel for documentation control.
    In general, the company used the same documentation
system for writing EMS policies and procedures as it had for
its quality program. Specific examples of how H-R Industries
used its quality system to develop several EMS elements are
described below.
    O   Environmental Policy. H-R Industries modified its
Qualify Policy to include its environmental policy. The policy
was enlarged to poster-size, signed by all employees, and.
posted as a reminder of the company's commitment.
      Planning. A key element of an effective EMS is
identifying the environmental aspects of your company's activi-
ties, products, and services, and determining which aspects
have significant impacts on the environment. These "signifi-
cant aspects" form the basis for setting your environmental ob-
jectives. Although there is no parallel element in ISO 9002,
H-R Industries extended its ISO 9002 purchasing policy to
address potential environmental impacts by making suppliers
and contractors aware of the environmental aspects associated
with their products. For example, the formality of an EMS
provided the incentive to work with a chemical supplier to
convert their permanganate bath maintenance procedure.
Sodium hypochlorite additions were replaced by permanent
electrodes in the solution for electroregeneration, extending
bath life 2 to 3 times. This change resulted in reductions in
hazardous waste generation, material handling, reporting, and
recordkeeping.  Annual savings totaled over $32,500.
       Implementation and Operation. Essential to both
quality and environmental management systems is the assign-
ment of responsibility, authority, and adequate resources.  To
make the most of limited resources, H-R Industries assigned
the same individuals responsibility for both quality and EMS
elements where there was overlap. For example, the
Safety/Health Officer provides training required by ISO 9002
and ISO 14001. Documentation and records for the Quality
and Environmental Management Systems are controlled and
maintained by the same individual.
    Successful implementation of an EMS also depends on
both management and employees fully understanding and con-
trolling the company's potential impact on the environment.
H-R Industries uses the training framework already in place for


ISO 9002, safety, and employee right-to-know programs to
inform new employees of ISO 14001 EMS requirements.
Training had to be expanded to educate employees about the
environmental aspects of their activities and the potential envi-
ronmental consequences of their performance.  For example,
platers needed to know that dumping a contaminated bath to
wastewater treatment could not only disrupt the treatment
system, but also may cause an unacceptably high level of metals
discharged to the environment.
    According to H-R Industries' Process Engineering
Manager, "With ISO 9002, quality had to become everybody's
business. With an EMS, everybody had to become aware of
how their work impacted the environment." For example,
wastewater treatment operators revised procedures to address
environmental aspects of treatment operations.
       Checking and Corrective Action. H-R Industries
transferred its ISO 9002 procedures for making corrective
action requests directly to its EMS. The EMS Manual simply
refers to the Corrective Action Request form already in use for
quality. For example, such a form might be used for a tank
leak. Similarly, H-R Industries incorporated the records
control and audit procedures established under ISO 9002 into
its EMS.
        Management Review. Management must periodi-
cally review the EMS to evaluate its suitability and effective-
ness. ISO 9001 contains the same requirement. Although there
is some overlap in personnel on the quality and environmental
review committees at H-R Industries, the two systems are re-
viewed separately. The review format and control of meeting
records, however, is the same. H-R Industries feels that
smaller companies may have an advantage in the review
process in that the committees may be composed of the same
Table 1: Similarities Between ISO 14001 and ISO 9001
inclicates :where simiiarities exist between the two systems. 5
ISO 14001 Element
1^. General Requirements
O Environmental Policjr
4.3 Planning
4.3.1 Environmental aspects
4.3.2 Legal and other requirements
4.3.3 Objectives and targets
4.3.4 Environmental management programs
4.4 Implementation and Operation
i^M^l 	 Structure and responsibility
iB."4.2 Training
4.4.3 Communication
EMS documentation
ftAAS Document control
P-T , * 1
4.6 Operational control
4.4.7 Emergency preparedness and response
4.5 Checking and Corrective Action
r^4.5.1 Monitoring and measurement
'x, 4.5.2 _ Nonconformance and corrective
> "- and preventive action
!H3:.5,3 _ Records
sT4.5~4 ~EMS audit
jLfi__ Management Review

ISO 9001 Equivalent
4.2i1 General '
4.lll Quality Policy

Although there is no direct equivalent in ISO 9000, opportunities
for considering environmental aspects may exist in areas such as
contract review, purchasing, handling, storage, packaging,
preservation, and delivery.

4.1. 2 Organization , >
4.18 Training .-,--.. ",'.- ''' '

4.2.1 General
4.5 Document and data control
4.3 Contract review
4.6 Purchasing
4.7 Control of customer-supplied product
4.9 Process control
4.15 Handling, storage, packaging, and delivery


411 Control of inspection, measuring and test equipment
4 14 Corrective and preventive actions
4 16 Control of quality records
417 Internal quality audits
413 Management review

personnel, allowing both quality and environmental systems to
be reviewed at the same time.

Lessons Learned About the EMS Process

    The process of developing an EMS for a small or medium-
sized company need not be overwhelming. H-R Industries' ex-
perience shows that a company can use its existing
environmental policies and procedures, and those developed for
ISO 9002 registration, to help build an EMS that is integrated
with its quality assurance program. H-R Industries' advice is to
begin with simple, achievable goals, and focus on programs
where there is obvious economic benefit. As your EMS
matures, the procedures and programs can be expanded to
further improve environmental performance and to continue in-
tegration of the EMS into other business functions.
    Time required to develop and maintain the EMS: The
time required to implement an ISO 14001 EMS depends on the
current status of your company's environmental programs, the
resources your company is willing to commit, and whether your
organization is ISO 9000 registered. At H-R Industries, it took
about 18 months to obtain certification. During the first year it
took the equivalent of one fourth of an employee's time for pre-
liminary planning and exploring issues. The final 6 months re-
quired the time-equivalent of 1.5 employees to implement the
EMS. For a company without a well-developed system, imple-
mentation may take about 2 years. At H-R Industries, one full-
time employee maintains both environmental and quality
systems; several other employees have EMS responsibilities re-
quiring the time equivalent of an additional half-time employee.
    Certification cost: At H-R Industries, certification cost
SI8,000, which included preliminary and on-site audits, follow-
up audit for deficiency, audit report, registration fee, and auditor
time and expenses. H-R Industries saved on auditor expenses by
scheduling the ISO  14001 certification audit and the ISO 9002
six-month  surveillance audit at the same time and with the same

    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.
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.

Additional Resources for the PWB Industry

In addition to this case study, the DfE PWB Project has pre-
pared other case studies that examine pollution prevention op-
portunities for the PWB industry. All case studies are based on
the experiences and successes of facilities in implementing pol-
lution prevention projects. The other case study topics available
    Pollution Prevention Work Practices
    On-Site Etchant Regeneration
    Acid Recovery and Management
    Plasma Desmear
    Reusing Microetchant
    Pollution Prevention Beyond Regulated Materials
    Identifying Objectives for Your Environmental
    Management System
These case studies, and other documents publii
Project, are available from:
    Pollution Prevention Information <
    U.S. EPA 401 M Street, SW (7409)1
    Washington, DC 20460
    phone: 202-260-1023; fax: 202-2
    e-mail: PPIC@epamail.epa.govJ
    DfE PWB information: http://i
    or www.ipc.org/html/ehstypesj
 The DfE Program welcomes you
 any of the ideas in this series of P\
 comments,  please  let us know of f
 202-260-1678 or via e-mail at oppt
        Printed on paper that contains at li