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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