A Cooperative
Project between the
U.S. Environmental
Protection Agency
and Industry
 July 1998
                      FOR
                      THE
 EPA744-F-98-004
                          NMENT
                      Environmental Management System Bulletin 1
                                                                a
               U.S.EPA
    BULLETIN HIGHLIGHTS
   Benefits of an EMS based
   on DfE concepts
   Real-world examples of
   benefits from the
   Acushnet Rubber
   Company
   ALSO IN THIS BULLETIN
   What is an EMS?
   Facility profile of
   Acushnet
 TonyMelloandRayLelievraof
 Achushnat Rubber Cimpany
 diicuss their facility's EMS.
                     Using
  Design for the Environment
                   Concepts
               in Your EMS
An Environmental Management System (EMS) can provide a company with a
systematic way to improve its operations for better environmental performance.
While an EMS supplies the basic management framework, EPA's Design for the
Environment (DfE) Program provides guidance and tools to help companies
achieve continuous environmental improvement The DfE approach encourages
companies to consider environmental and human health risks in all business
decisions. In addition, it encourages companies to evaluate cleaner processes,
technologies, and workplace practices.


Why Establish a Off-Based EMS?
A DfE-based EMS provides a company with opportunities to go "beyond
compliance" and save money. The DfE approach can help a company meet the
objectives of its EMS by promoting the evaluation of cleaner production
alternatives. By implementing these alternatives, a company can continuously
improve its environmental performance.
In addition, an EMS encourages the systematic evaluation of each area of the
company's operation. An EMS can provide the following benefits:
    improved worker health and safety
    reduced costs  greater efficiency means fewer materials used and less
     time and energy wasted
    increased business opportunities  customers may start requiring their
     suppliers to have an EMS
                                           (continued on page 4)
                                                                      Design for the Environment 1

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      What is an EMS?
      An Environmental Management System (EMS) is a framework that helps a company achieve its
      environmental goals through consistent control of its operations. The assumption is that this
      increased control will improve the environmental performance of the company.  The EMS itself
      does not dictate a level of environmental performance that must be achieved; each company's
      EMS is tailored to the company's business and goals.
      An EMS encourages a company to continuously improve its environmental performance.  The
      system follows a repeating cycle (see figure). The company first commits to an environmental
      policy, then uses its policy as a basis for establishing a plan, which sets objectives and targets for
      improving environmental performance. The next step is implementation.  After that, the company
      evaluates its environmental performance to see whether the objectives and targets are being met.
      If targets are not being met,  corrective action is taken.  The results of this evaluation are then
      reviewed by top management to see if the EMS is working.  Management revisits the
      environmental policy and sets new targets in a revised plan. The company then implements the
      revised plan. The cycle repeats, and continuous improvement occurs.
                                         Commitment
                                          tadPottcy
                                          Continuous            Planning
                                         Improvement
                                                 Implementation
              Ito continuous improvement cycle.
      The most commonly used framework for an EMS is the one developed by the International
      Organization for Standardization (ISO) for the ISO 14001 standard. Established in 1996, this
      framework is the official international standard for an EMS.
2 Design for the Environment

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The five main stages of an EMS, as defined by the ISO 14001 standard, are described below:

Commitment and Policy
Top management commits to environmental improvement and establishes a company
environmental policy. The policy is the foundation of the EMS.

Planning
 A company first identifies environmental aspects of its operations. Environmental aspects are
those items, such as air pollutants or hazardous waste, that can have negative impacts on
people and/or the environment. A company then determines which aspects are significant by
choosing criteria considered most important by the company.  For example, a company may
choose worker health and safety, environmental compliance, and cost as its criteria.  Once
significant environmental aspects are determined, a company sets objectives and targets.  An
objective is an overall environmental goal (e.g., minimize use of chemical X). A target is a
detailed, quantified requirement that arises from the objectives (e.g.,  reduce use of chemical X
by 25% by September 1998).
 The final part of the planning stage is devising an action plan for meeting the targets. This
includes designating responsibilities, establishing a schedule, and outlining clearly defined steps
to meet the targets.

Implementation
A company follows through with the action plan using the necessary  resources (human, financial,
etc.). An important component is employee training and awareness for all employees. Other
steps in the implementation stage include documentation, following operating procedures, and
setting up internal and external communication lines.

Evaluation
A company monitors its operations to evaluate whether targets are being met.  If not, the
company takes corrective action.

Review
Top management reviews the results of the evaluation to see if the EMS is working.
Management determines whether the original environmental policy is consistent with company
values. The plan is then revised to optimize the effectiveness of the  EMS. The review stage
creates a loop of continuous improvement for a company.

                                                                           Design for the Environment  3

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  Facility Profile

  Acushnet Rubber
  Company, Inc.
  New Bedford, *
  Massachusetts
  Three facilities in New
  Bedford, MA employ 1,100
  people combined; one
  facility in Thailand employs
  425 people.
  Designs and
  manufactures
  elastomeric products
  including liquid cast
  polyurethane product lines.
  Customers include Ford,
  Chrysler, General Motors,
  Lexmark, and Xerox.
  Estimated sales for 1997:
  $90 million.
                                       increased employee awareness about the production process, because
                                       an EMS encourages employee involvement in identifying problem areas

                                       improved public relations  an EMS reflects a company's commitment
                                       to minimizing its impact on its employees and the surrounding
                                       community.
Establishing an EMS at

Acushnet Rubber Company

Acushnet Rubber Company, Inc.
in New Bedford, Massachusetts,
established an EMS based on DfE
principles. This bulletin presents
some examples of how Acushnet reduced production costs and improved
worker safety through its EMS.


How the EMS Created  Improvements at Acushnet
Since implementing a DfE-based EMS, Acushnet has realized many benefits.
The company has slashed its use of toxic chemicals, raised production, added
employees, and realized annual cost savings.
In addition, Acushnet has gained a competitive advantage in the marketplace by
becoming one of the first companies in the industry to establish an EMS. In
fact, Acushnet is ISO 14001-certified (see the section, "What is an EMS?").
According to Jack Bailey, Environment, Health, and Safety Director, the EMS
enables the company to weed out inefficiencies and cut costs to a degree not
previously attainable. "We're in business to make money," states Mr. Bailey.
"Our EMS makes good business sense for Acushnet."
Acushnet emphasized two main DfE concepts when establishing its EMS:
       reducing risk to workers and the environment
       implementing cleaner technologies and processes

Reducing Risk to Workers and the Environment Through a

DfE-Based EMS

One of the main DfE concepts is reducing the risk to workers and the
environment. Acushnet considers this risk when identifying the significant
environmental aspects of the company (see the section, "What is an EMS?").
To determine the significance of an environmental aspect, Acushnet uses the
following criteria:
      waste disposal cost
      impact on human health
4  Design for the Environment

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  For More
  Information
  If you would like more
  information about Acushnet
  Rubber Company, Inc., and
  the company's experience
  with establishing an
  environmental management
  system, contact:
  Jack Bailey
  Director of Safety, Health, and
  Environmental Affairs
  Acushnet Rubber Company,
  Inc.
  744 Belleville Avenue
  New Bedford, MA
  02742-6916
  Phone: (508) 998-4058
  Fax:(508)998-4100
  e-mail: jbailey@acushnet.com
Ray Lelievre at Achushnet works with the aqueous cleaner that
replaced TE.
       material cost
       toxicity rating
       likelihood of noncompliance
       energy consumption
       impact on resources, such as labor
Two criteria, impact on human health and toxicity rating, represent the
environmental aspect's risk to humans and the environment. To measure the
human health risk and toxicity associated with an environmental aspect,
Acushnet uses various resources, such as the list of carcinogens or potential
carcinogens from the International Agency for Research on Cancer (IARQ, the
Hazardous Materials Identification System (HMIS) ratings found on a Material
Safety Data Sheet (MSDS), and the list of Toxics Release Inventory (TRI)
chemicals regulated under Section 313 of the Superfund Amendment and
Reauthorization Act (SARA) Tide III.
For example, Acushnet rated trichloroethylene (TCE) emissions as a significant
environmental aspect for three main reasons: hazardous waste disposal costs,
TCE's impact on human health, and TCE's toxicity rating (IARC listed it as a
potential carcinogen). Since TCE emissions were identified as a significant
aspect, Acushnet set an objective to minimize TCE use and set a specific target
of completely eliminating TCE by the end of the fiscal year (see the section,
"What is an EMS?").
                   The first step toward reaching the target was to identify
                   where the TCE was used. Acushnet's suppliers stamped
                   metal parts using a grease coating to facilitate the stamping
                   process. Acushnet used TCE in a vapor degreaser to clean
                   these metal parts. The company convinced their suppliers
                   to replace the grease coating with a water-based lubricant,
                   thereby eliminating TCE use from the cleaning of about 80
                   percent of its parts. For the remaining 20 percent (parts
                   that were cylindrical and required heavier oils in their
                   production), Acushnet incorporated a two-step aqueous
                   cleaner to replace TCE.
                    As a result of these efforts, the degreasers have been shut
                    down. Due to the  elimination of TCE in the facility,
                    Acushnet saves approximately $100,000 annually. More
                    importantly, the company has reduced risk by eliminating
the use of a suspected carcinogen in the workplace.
                                  Implementing Cleaner Alternatives Through a DfE-Based EMS
                                  Another way to improve environmental performance and reduce risk is to
                                  replace traditional processes, technologies, and practices with "cleaner"
                                                                                             Design forthe Environment   5

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 About the Design

 for the Environment

 Program

 The goal of the Design for the
 Environment Program is to
 provide industry with
 information that can help
 companies design an
 operation that is more
 environmentally sound, safer
 for workers, and more cost-
 effective.

 Mention of trade names,
 companies, or commercial
 products does not
 constitute endorsement or
 recommendation for use by
 either the U.S.
 Environmental Protection
 Agency or other firms,
 organizations, or
 individuals who have
 participated  in the
 preparation of this
 publication.

 To obtain additional copies of
 this or other bulletins and
 case studies, or for more
 information about EPA's
 Design for the Environment
 Program, contact:
 EPA's Pollution Prevention
 Information Clearinghouse
 (PPIC)
 US. EPA
 401 M Street, SW (3404)
 Washington, DC 20460
 Phone:(202)260-1023
 Fax: (202) 260-4359
 E-mail: ppic@epamail.epa.gov
 Website: http://www.epa.gov/dfe
alternatives. DfE encourages companies to consider the trade-offs among
performance, cost, and environmental and human health risks when evaluating
these alternatives. Evaluating alternatives is an important part of the action
plan in a company's DfE-based EMS (see the section, "What is an EMS?").
For example, Acushnet identified waste adhesive as a  significant environmental
aspect due to the health risks posed by the adhesive's  VOC content. Three
workers in the adhesive application area led by Tony Mello noticed that
spraying metal parts with adhesive was not an efficient operation, and that the
excess spray posed a health risk to themselves and to  others.

Encouraged by the DfE EMS  to find  alternative processes, the workers
suggested replacing the spraying process with a  cleaner, more efficient process
that dips the metal parts in a vat of adhesives and then spins them in a
centrifuge. Management, along with the shop floor workers, evaluated this
alternative and discovered that the new process:

       worked just as well and also eliminated  the excess spray of the
        adhesive

       would save the company money in reduced labor and less adhesive

       cut the health risk to workers

The money saved from their suggestion will pay for the new system in less
than six months. The company now saves $40,000 per year in labor and
material costs. Through the DfE-based EMS, all employees at Acushnet are
encouraged to continuously seek these types of alternatives that can reduce
risk while improving efficiency.
 A New Way of Thinking
Establishing an EMS requires a change in the way management and employees
think about the environment. An EMS takes all of the elements of a business
and views them as one system. Equipped with this new way of thinking,
Acushnet's workforce is constantly looking for new solutions that will improve
the company's operations. "We think this is a sound strategy," explains Mr.
Bailey. "If it worked for us, there's a good chance it will work for other
companies."


Additional Resources

In addition to this case study, the DfE Program is working to develop tools to
help facilities establish an EMS based on DfE concepts.
6  Design for the Environment
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