Office of Pollution
PttL. 'ISfSiilwiiP:^^ :i;l
III II
EPA
11 II
-------
-------
E
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
-------
-------
Acknowledgments
This Guide was prepared by Abt Associates Inc., Cambridge, MA, with Jean E. (Libby)
Parker as lead author. It is part of an effort to show how Design for the Environment
(DfE) technical work can be used to support development of an Environmental
Management System (EMS). This Guide is based primarily on EMS reference
documents acknowledged in the references section, and on DfE guidance documents such
as the Cleaner Technologies Substitutes Assessment Methodology. The EPA Project
Manager was Karen Chu, with the Design for the Environment Program in the Office of
Pollution Prevention and Toxics. Bill Hanson is Director of the Design for the
Environment Program. Important contributions were made by Carol Hetfield, Heather
Tansey, Ted Cochin, and Jenny Fisher, EPA. The Abt Associates project team included
Cheryl Keenan, Dennis Chang, Susan Altman, and Jonathan Greene. Important
contributions were received from the Eastern Research Group, Inc. (ERG), Lexington,
MA, and from the University of Tennessee, Knoxville Center for Clean Products and
Clean Technologies. The ERG project team included Jeff Cantin, Dave Galbraith, and
Owen Davis. The University of Tennessee project team included Lori Kincaid, Mary
Swanson, and Kerry Kelly. Valuable contributions were provided by Marci Kinter and
Dan Marx of the Screenprinting & Graphic Imaging Association International (SGIA),
Fairfax, VA, and by Foster Knight and Bob Ferrone of The Lexington Group, Lexington,
MA. Useful comments were received from William T. Engel, Jr. of the Strategic
Environmental Management Institute at the University of Florida's Center for Training,
Research and Education for Environmental Occupations (UF/TREEO), Gainesville, FL.
-------
-------
Contents
Foreword i
DfE Program Principles iv
Figure A: DfE Substitutes Tree vi
Figure B: Pollution Prevention Hierarchy vi
How to Use This Guide vii
Figure C: IEMS Process x
Figure D. Road Map between ISO 14001 and IEMS xi
Modules
MODULE 1: LAYING THE GROUNDWORK 1-1
Figure 1-a. The Continuous Improvement Cycle 1-3
Figure 1-b. Functions to Include in Your I EMS Team 1-8
Figure 1-c. Examples of Environmental Aspects and Associated Impacts 1-13
Figure 1-d. How an Activity Becomes an Impact 1-13
Figure 1-e. Generic Process Map for Business Activities 1-15
Figure 1-f. Product X— Extended Responsibility 1-16
Figure 1-g. Input-Output Diagram for a Step in a Manufacturing Operation 1-18
Figure 1-h. Input-Output Diagram for a Copier 1-18
Figure 1-i. Input-Output Diagram for Cleaning a Printing Press 1-19
MODULE 2: CREATING AN ENVIRONMENTAL POLICY 1-25
MODULE 3: DETERMINING SIGNIFICANT ENVIRONMENTAL ASPECTS AND SETTING
OBJECTIVES
Figure 3-a: Ranking Symbols 1-43
Figure 3-b: Information on an MSDS 1-46
Figure 3-c: Screen Printing Exposure Pathways 1-52
Figure 3-d: Dry Cleaning Exposure Pathways 1-53
1-39
MODULE 4: EVALUATING ALTERNATIVES
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
Figure 5-a. Root Cause Diagram 1-113
. 1-69
1-107
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS 1-117
MODULE 7: IMPLEMENTING YOUR IEMS 1-129
Figure 7-a. Sample Environmental Management Project Plan 1-131
Figure 7-b. Sample Environmental Management Project Plan 1-132
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT 1-143
Figure 8-a. Documentation Levels 1-152
Figure 8-b. Levels of stakeholder interest 1-160
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT 1-169
Appendices
APPENDIX A: GLOSSARY A-1
APPENDIX B: SAMPLE QUESTIONS TO ASK YOUR SUPPLIER A-5
APPENDIX C: EXAMPLE PERFORMANCE EVALUATION WORKSHEETS ... A-7
APPENDIX D: EXAMPLE ALTERNATIVES EVALUATION WORKSHEET A-12
APPENDIX E: ALTERNATIVES EVALUATION SAMPLE WORKSHEETS A-19
APPENDIX F: HOW TO EVALUATE COSTS AND SAVINGS OF ALTERNATIVES A-37
APPENDIX G: REFERENCES AND RESOURCES A-49
APPENDIX H: BLANK WORKSHEETS A-57
-------
INTRODUCTION
Foreword
EPA's Design for the Environment (DfE) Program has over
eight years of experience building voluntary partnerships with
industry, public interest groups, universities, research
institutions, and other government agencies to develop cleaner,
safer alternatives to existing products and processes and to
manage change in the systems businesses use to address
environmental concerns. The DfE Program has developed
technical methodologies that provide businesses with
environmental, economic, and performance information on
traditional and alternative manufacturing methods and
technologies. These approaches help businesses integrate
environmental concerns into their daily business activities so
they can reduce cross media impacts, use energy and other
resources efficiently, better manage the risk associated with
using hazardous chemicals, practice product and process
responsibility, and integrate environmental and worker safety
and health requirements. In addition, DfE has gained valuable
experience in communicating with a wide variety of people with
varying degrees of technical knowledge, and in establishing and
maintaining diverse stakeholder groups. The DfE Program is
offering this experience to support the development of
Integrated Environmental Management Systems in
companies.
An Environmental Management System (EMS) is a set of
management tools and principles designed to guide the
allocation of resources, assignment of responsibilities and
ongoing evaluation of practices, procedures, and processes that
a company needs to integrate environmental concerns into its
daily business practices. The EMS developed and outlined by
Tip
Words or phrases in
bold type are
defined in the
Glossary (Appendix
A).
Tip
The IEMS process
described in this Guide
will help you develop a
results-oriented EMS,
but it may not include
all steps or core
elements necessary for
ISO certification.
Bsr Tip
An Environmental
Management System
provides a systematic
way to review and
improve operations for
better environmental
performance and
improved profitability,
by setting up
procedures that
ensure the work gets
done. An EMS requires
both administrative and
technical work.
-------
INTRODUCTION
the International Standards Organization (ISO) in their standard
ISO 14001 is one such example. The ISO 14001 EMS provides
a widely recognized set of principles and standards for
integrating environmental management into quality control and
other business activities. Although the principles discussed in
this document can apply to any EMS based on a plan-do-check-
act approach, this document uses ISO 14001 as a starting point.
In addition to administrative procedures, steps to implement an
EMS involve some technical work, such as identifying and
prioritizing environmental concerns, evaluating options for
addressing those concerns, and measuring the success of
implementing those options. The ISO 14001 standard does not
specify how to carry out the technical work.
The DfE Program's approach to creating an EMS provides the
DfE Program's technical methods to carry out the technical work
of developing the EMS. The technical methods to integrate
cleaner technology business methods with the management
methods required for an EMS are presented in the DfE
Program's Integrated Environmental Management System
(IEMS). This approach emphasizes reducing risk to humans
and the environment, pollution prevention, and wise resource
management. The DfE Program principles follow this section.
Those elements of the EMS that require strictly management or
administrative expertise will be presented so as to demonstrate
how the management and technical elements fit together. More
detail on the management elements will be found in other
referenced sources. This Guide takes you and your company
through the IEMS creation process, step by step.
In January 1999, the DfE Program teamed with the
Screenprinting and Graphic Imaging Association International
(SGIA) to conduct a pilot project with seven screenprinting
11
-------
INTRODUCTION
companies who wanted to develop lEMSs. The pilot project
was designed to enable both the DfE Program and SGIA to
further develop these training materials. This Guide has
undergone major revisions, and the Company Manual Template
was developed in response to lessons learned during the pilot
project.
m
-------
INTRODUCTION
DfE Program Principles
A goal of the DfE Program is to create healthier environments
for workers, communities, and the ecosystem. The DfE Program
accomplishes this goal by promoting system change in the way a
company manages environmental concerns. The DfE Program
principles and approaches are useful in meeting regulatory
requirements and augmenting environmental protection beyond
compliance. Using the DfE Program's approach can help a
company integrate environmental protection by:
*• managing the risk associated with using regulated and
unregulated hazardous chemicals,
>• considering cross-media impacts of activities and
products,
> using energy and other resources efficiently,
»• practicing extended product and process responsibility,
and
>• integrating environmental and health & safety
requirements.
Approach
The DfE approach to creating an IEMS has six main steps:
>• Identify and compare alternatives to evaluate trade-offs
and information gaps.
> Use the DfE Substitutes Tree outline (see Figure A) to
evaluate alternatives.
+ Use the Pollution Prevention Hierarchy (Figure B) to
evaluate and rank approaches.
>• Integrate environmental considerations into daily business
decision making that includes performance and cost to
provide environmental solutions that promote
IV
-------
INTRODUCTION
competitiveness.
Recognize need for a commitment to continuous
improvement.
Work in partnership with stakeholders; engage
participation and support of employees; encourage open
communication.
-------
Figure A: DfE Substitutes Tree
Alternatives to Accomplish Function Options
Option 1
/
Alternative Chemicals
vOption2
. Alternative Processes oPtion 3
Environ-
mental
Issue
Describe
Function
Alternative Technologies
Alternative Work Practices
Figure B: Pollution Prevention Hierarchy
SOURCE REDUCTION
Substitutes
Process Change
Management Work Practices
\ Recycle/Reuse
Control
Technology
Evaluation
Evaluate
Environmental
Effects,
Performance,
Costs
VI
-------
INTRODUCTION
How to Use This Guide
This Guide has been designed to help companies integrate
environmental concerns into business decision making using the
DfE Program's Integrated Environmental Management System
(IEMS). This Guide follows the guidelines of ISO 14001, an
international standard for EMSs, and it is designed to help
businesses set up and implement a simple, straightforward EMS.
This Guide does not intend to give guidance for ISO 14001
certification.
This Guide is laid out in nine modules designed to be completed
through group discussions with your IEMS team members and
other managers and employees as appropriate. Most modules
can be completed in several hours, but some may take longer.
Sessions may be held once a week, once every other week, or
once a month until the job is done. Use whatever time these
modules require for your company. It is more important to
complete each module than to finish in any particular time frame.
Most companies find that it takes about a year to work through
the EMS development process. And it generally takes up to
three years for the EMS to be fully understood and implemented.
Developing a company IEMS is a commitment to change, and
change takes time.
Best results will be achieved by involving everyone in the
company in some way. There are two benefits to involving all
employees: first, they will be more likely to take ownership of
managing environmental concerns; second, they often have
valuable insight into how improvements can be made.
You should consider regular sessions as suits your schedule to
complete the work in each module. You will need to appoint a
responsible person and a committee to lead the development of
vii
Tip
Every choice you and
your employees make
can affect the
environment.
Involving everyone
helps produce cost-
effective long-term
results.
03= Tip
You should not try to
perfect each step on
your first attempt.
Many of the steps will
need to be revisited as
you proceed with
developing the IEMS.
-------
INTRODUCTION
your IEMS. The committee members could also meet regularly
with other employees to provide progress reports and solicit
input. The importance of regular communication and
involvement cannot be overemphasized. Getting people to think
about environmental concerns in their daily work is as important
a process as any step in setting up your IEMS.
Some of these modules will have to be revisited during the
process. For example, it is useful to develop a communication
plan in the beginning, but you will need to add to it as
environmental concerns are identified and as other parts of the
IEMS are developed. Some modules may not be completed at
the outset, but may be revised as needed throughout the process.
Finally, you don't need to do everything at once. This Guide
will help you identify possible projects and then help you
prioritize these projects, given your resources and time. You
may, for example, want to start out by developing the IEMS for
only one part of your company or operation. You can expand
later as your resources permit. It's important to start small with
projects that will achieve success, so that you and your
employees gain experience with the process and build
confidence in your ability to make changes.
What are the Steps in Developing an IEMS?
Each module in this Guide explains a step in the IEMS
development process. The modules contain worksheets to assist
you in completing this work. Figure C is a flow chart showing
the steps in the process. Figure D is a "roadmap" showing how
the IEMS modules relate to the components of the ISO 14001
standard. The Appendices contain a Glossary, example
questions to ask your suppliers about chemical risk, an
alternatives evaluation worksheet and performance evaluation
vm
Tip
A companion
document, A
Company Manual
Template, contains
sample procedures
and formats to help
you document
important components
of your IEMS. Refer
to this Guide
frequently as you
develop your IEMS.
This document is
available on the DfE
website
(www.epa.gov/dfe).
See Appendix G for
details about the
Template.
-------
INTRODUCTION
worksheet from the DfE Printing Project, resources for more
information, and blank forms that correspond to the worksheets
in each module, hi addition to the Appendices, more tools and
guidance can be found on the DfE's website at
www.epa.gov/dfe. hi particular, there is a more extensive Risk
Guide and Cleaner Technology Substitutes Assessment Guide.
Module 1: Laying the Groundwork
This module provides a general discussion of what an IEMS
contains. It will help you build understanding of and support for
your IEMS among your company's managers and employees,
about what an IEMS is and why the company is developing one.
This module also will help you understand how your company
currently impacts the environment by identifying environmental
impacts of your company's products, processes and services.
Module 2: Creating an Environmental Policy
An early step in the process of developing a IEMS is reviewing
your company's current methods for managing environmental
concerns. Next you will write your company's environmental
policy statement and decide on the scope of your IEMS. The
environmental policy will be based on what is important to your
company. This module contains some sample principles and
policy statements.
Module 3: Determining Significant Environmental Aspects and
Setting Objectives
You will need to determine which environmental aspects are
significant, and prioritize them to determine what you want to
address first. This module provides a method to estimate
environmental risk to help you prioritize environmental aspects.
The module then helps you to translate those priorities into
objectives to reduce environmental impact.
IX
Tip
Environmental
aspects are
elements of your
business, such as air
pollutants or
hazardous waste,
that can have
negative impacts on
people and/or the
environment.
-------
Figure C: IEMS Process
Lay the Groundwork
Develop Process
Map and
Identify Aspects
Create Environmental
Policy Statement
Gaps Analysis
Review
and •*- -
Update
Determine Significant Aspects
Consider Environmental Risk
Set Objectives,
Determine Actions
Improve Current Activity
Change Current Activity
Evaluate Alternatives
Operational Controls
L
Set Targets and Project Measurement
Criteria
Implement the System
Continuous
Improvement*
Establish Continuing Improvement
J
Establish
Environmental
Management Project
Establish
Program
Measurement
Criteria
-------
Figure D. Road Map between ISO 14001 and IEMS
Approach
IS 01 40 01 EMS COMPONENTS
Commitment and Policy
Planning
Implementation
Evaluation
Review
IEMS GUIDE MODULES
Module 1 : Laying the Groundwork
Module 2: Creating an Environmental Policy
Module 1: Laying the Groundwork
Module 3: Determining Significant Environmental Aspects
Setting Objectives
Module 4: Evaluating Alternatives
Module 5: Setting Targets and Measuring Success
Module 6: Developing Operational Controls
Module 7: Implementing Your IEMS
Module 8: Building Organizational Support
Module 5: Setting Targets and Measuring Success
Module 8: Building Organizational Support
Module 9: Establishing Continuing Improvement
I
and
'
XI
-------
INTRODUCTION
Module 4: Evaluating Alternatives
Before deciding how you will meet your objectives, it is
important to consider a wide array of approaches. This module
shows how the IEMS methodology considers a hierarchy of
alternatives, which include substitutes, pollution prevention, and
wise resource management.
Module 5: Setting Targets and Measuring Success
For those significant environmental aspects where you have set
an objective, you will need to develop specific targets that
describe how you will achieve your goal and you need to
develop ways of measuring that achievement.
Module 6: Developing Operational Controls
For some environmental aspects, you will need to write
procedures to ensure that activities are performed in a way that
reduces environmental impact. This module lays out how to
develop operational controls, measure for success of those
controls, and provide corrective action when necessary.
Module 7: Implementing Your EMS
Effective implementation is essential to getting your IEMS off to
a good start. This module helps you plan the IEMS development
process and set up environmental management projects for your
objectives.
Module 8: Building Organizational Support
The long-term success of your IEMS will depend on solid
organizational support. Such support includes developing
documentation, meeting training needs, and implementing
effective communication and stakeholder involvement processes.
Module 9: EstabDshing Continuing Improvement
To ensure success and continuing improvement, regular reviews
Xll
-------
INTRODUCTION
of your overall IEMS are needed. These reviews include
progress made in communication, documentation and
developing stakeholders as well as the specific environmental
targets. The reviews provide critical information to ensure
continuing improvement.
How much work each of the steps entails depends entirely on the
scope of work that you decide to undertake. It is not necessary
for your IEMS to include all your operations, especially for your
first effort. As you gain experience in managing environmental
concerns along with your daily operations, you will develop your
IEMS further.
Xlll
-------
-------
MODULE 1: LAYING THE GROUNDWORK
This module contains an overview of Environmental
Management Systems, suggestions for how to build internal
support for your IEMS, ideas for developing your IEMS
management team, and a process for understanding how your
company impacts the environment.
Overview of Environmental
Management Systems
An Environmental Management System (EMS) provides a
systematic way to review and improve operations for better
environmental performance. An EMS can help a company
better meet its compliance requirements. It can also help a
company use materials more efficiently and streamline
operations, thereby reducing costs and becoming more
competitive.
A commonly used framework for an EMS is the one developed
by the International Organization for Standardization (ISO) for
the ISO 14001 standard. Although the EMS described in this
Guide is based on the ISO 14001 approach, the process outlined
in this Guide may not provide for meeting all the requirements of
ISO 14001 certification. The purpose of this Guide is not to
give advice towards certification. It is to demonstrate a technical
means of integrating environmental concerns into company
management so that businesses can become more effective in
reducing their impact on the environment.
In addition, other guides on the market provide useful
Tip
An EMS is a
framework for
managing those
significant
environmental
aspects you can
control or influence.
Tip
Words in bold type
can be found in the
Glossary (Appendix
A).
pagel
-------
MODULE 1: LAYING THE GROUNDWORK
approaches. Developing an IEMS based on this Guide does not
imply endorsement by the U.S. EPA.
The five main stages of an EMS, as defined by the ISO 14001
standard, are as follows.
>• Commitment and policy — top management commits to
environmental improvement and establishes a company
environmental policy.
>• Planning — the company conducts a review of its
operations, identifies legal requirements and
environmental concerns, establishes objectives, evaluates
alternatives, sets targets, and devises a plan for meeting
those targets.
>• Implementation — the company follows through with the
plan by establishing responsibilities, training,
communication, documentation, operating control
procedures, and an emergency plan to ensure that
environmental targets are met.
>• Evaluation — the company monitors its operations to
evaluate whether the targets are being met, and, if not,
takes corrective action.
> Review — the EMS is modified to optimize its
effectiveness. The review stage creates a loop of
continuous improvement for the company (Figure 1-a).
Tip
For more information on
ISO 14001 EMS, check
Appendix G
(References and
Resources).
Tip
Continuously
identifying and
reducing risk leads
to improved
competitiveness and
environmental
performance.
page 2
-------
MODULE 1: LAYING THE GROUNDWORK
Figure 1-a. The Continuous Improvement Cycle
Review
/Commitment^
\^and Policy/
Continuous
Improvement
^^v
f Evaluation )
The advantage of adopting the DfE Program approach is that it
enables your company to consider and plan for managing the
environmental risk of your company's products, processes and
services. The method outlined in this Guide will help your
company compare alternatives to identify the least cost, best
performing and lowest environmental impact option. This
approach will help your company do the following:
»• practice pollution prevention,
»• use resources efficiently,
> avoid shifting problems from one waste stream to another,
»• understand the risks associated with using both regulated
and unregulated chemicals,
> integrate management of worker safety and health
requirements with management of environmental
concerns,
> practice extended product and process responsibility, and
*• manage system change in addressing environmental
concerns.
Screenprinters from the
SGIA/EPAIEMS Pilot
Project have this to say
about what they
learned:
"That you can have a
system to achieve
environmental
improvement Never gave
it much thought before."
"Changed from being
reactive to environmental
regulations to being more
proactive."
"The benefits of having
documented operational
controls."
"General environmental
awareness building
across the board; and
that you can be bottom-
line oriented and
environmentally
conscious at the same
time."
"That the ultimate benefit
is improving the
environment and
improving the bottom line
at the same time."
page 3
-------
MODULE 1: LAYING THE GROUNDWORK
Thus, by using the approach provided in this Guide, you can
develop a IEMS that helps you continuously identify and reduce
risks to people and the environment. This Guide provides
methods to help you consider risk reduction when answering the
following questions.
»• How does your company impact the environment?
>• Which of these environmental impacts are significant?
> How can your company improve its environmental
performance?
Building Support for Your IEMS
Both management and employees need to understand not only
what a IEMS is, but also why they would want one. This step is
designed to get people to think about and discuss the ways in
which a IEMS would benefit your company. Even though you
may already have management support, it is still important to get
employee buy-in to this process.
Set up times to discuss your company's need for a IEMS with
key managers and employees. Recording the discussions
provides important documentation, which can be used to
communicate the benefits of your IEMS to others. One way to
record the discussion is to assign someone the task of writing the
group's comments on a flip chart, so that everyone can see them
for discussion. The following set of general questions will lead
you through the discussion.
Discussion Questions
1. Which environmental and worker safety laws and
regulations is your company required to follow?
2. How does your company define environmental
US. EPA
Through years of
working with
companies, the DfE
Program has learned
the importance of
building support from
participants through
open and frequent
discussion about
mutual concerns.
page 4
-------
MODULE 1: LAYING THE GROUNDWORK
performance?
3. Does lack of time or resources prevent your organization
from taking charge of its environmental obligations? Are
there individuals appointed to be responsible for this
function?
4. What is your company's environmental policy?
5. Does your organization know how its environmental
objectives relate to its business objectives?1
To build support, consider the benefits a IEMS might provide
for your company. A more systematic approach to meeting your
environmental and business goals might contribute to the
following in your company:
> improved environmental performance
* improved worker health and safety
*• improved competitiveness
*• improved compliance and reduced liability
> fewer accidents
*• lower insurance premiums
*• improved public image
> enhanced customer trust
»• better access to capital
*• improved internal communication
*• improved company morale
> reduced operating costs
It will be helpful at this point to create a worksheet comparing
the expected costs and benefits of developing a IEMS.
Adapted from: Environmental Management Systems: An Implementation Guide
for Small and Medium-Sized Organizations. Ann Arbor, MI: NSF International,
November 1996, p.3.
Tip
To help get facility-
wide buy-in to the
IEMS process, find the
workers who are most
enthusiastic with the
process and recruit
them to spread the
word among their
peers. Commitment
from top management
is essential, but you
also need promoters at
all levels of your
company.
pageS
-------
MODULE 1: LAYING THE GROUNDWORK
Worksheet 1-1 provides some general categories of costs and
benefits. When making your comparison, provide specific
examples from the discussion.
Assigning Responsible Persons
Designate, as soon as possible, the Management Representative,
the IEMS Coordinator, and a Committee who will be responsible
for promoting and developing your IEMS. If you have a very
small company, these may all be the same person! However, it is
still important to designate who will be responsible for various
activities. Worksheet 1-2 provides a means to document the
responsible persons. This worksheet can be placed in your
Company IEMS Manual (see the Company Manual Template).
page6
-------
Worksheet 1-1: Costs and Benefits of Developing and
Implementing an lEMSf2
Costs
»• Staff/employee time for:
collecting information
reading and understanding this Guide
preparing worksheets
facilitating IEMS sessions
participating in IEMS development
*• Possible consulting assistance
>• Training of personnel in new procedures
»• Technical resources to analyze
environmental impacts and improvement
options
*• Resources required to make changes
Contact Person:
Benefits
>• Improved environmental performance
»• Expected increased efficiency/reduced cost of
materials
•• New customers/markets
>• Enhanced employee morale
> Expected savings in compliance and overall
compliance monitoring and assessment, and
record-keeping requirements due to changes in
materials used
>• Reduced waste disposal/treatment costs
>• Fewer regulatory requirements
Date completed:
Worksheet 1-2: IEMS Responsibilities
IEMS Function
Management Representative
IEMS Coordinator
IEMS Committee
Contact Person:
Person
Regular Position
Date Completed:
Corresponds to RESP-01 in the Company Manual Template.
2Ibid, p. 5.
page 7
-------
MODULE 1: LAYING THE GROUNDWORK
In addition, Figure 1-b shows the job functions and skills that
would make a strong contribution to your IEMS team. Small
companies might not have a person for each function identified
on the table. The list is provided to identify skills that would be
useful, not to suggest that a company would need all of these on
a team.
Figure 1-b. Functions to Include in Your IEMS Team
Company
Function
Production
Maintenance
Facilities
Engineering
Storage/Inventory
Shipping,
Receiving,
Transportation,
Logistics
Product Design
Quality
Human Resources
EH&S
Purchasing
Sales/Marketing
Public Relations
Accounting/
Finance
Expertise Brought to Project Team
Management of environmental aspects of
production
Management of environmental aspects of
equipment maintenance
Management of environmental aspects of new
construction and installation/ modification of
equipment
Management of environmental aspects of raw
material and product storage and in-facility
transportation
Management of environmental aspects of
shipping, receiving, and transportation
System for examining environmental aspects of
new designs
Quality management system, including document
control procedures
Training on environmental issues
Inclusion of environmental incentives in
performance measurement system
System for complying with environmental
regulations
Management of environmental records
System for procurement (including screening of
suppliers, material composition of components)
Environment-related commitments to customers
System for communicating with public on
environmental issues
System for tracking environmental costs of
operations ,
pageS
-------
MODULE 1: LAYING THE GROUNDWORK
Planning the Process
To effectively implement your IEMS, you will need to set up a
plan for getting the work done. This plan will be unique to your
company. You will identify the steps to take, in the appropriate
order; the decisions that will need to be made; and the resources
and schedules for accomplishing the tasks. Start out by
considering the following points as you plan for your IEMS
development:
*• Determine what level of management involvement is
required and what decisions will be needed from both
middle and senior management.
> Set a deadline for developing your IEMS and establish a
schedule. (See worksheet at the end of this module.)
* Estimate a budget.
>• Determine how you will document your IEMS.
If you have never developed an IEMS before, estimating
resources and time can be difficult. You will need to create a
schedule and estimate resources for completing your IEMS. As
you begin to work on each module, you may want to identify
intermediate steps for which you will set target completion dates.
At some points, you may need to alter the overall schedule.
Worksheet 1-3 will assist you in developing and tracking this
plan. As you go through each module, revisit this worksheet and
list who is participating in each task and your estimated budget
and schedule. Also, Worksheet 1-4 will help you identify and
document the persons responsible for different parts of the IEMS
and the resources needed to support their effort. You may not be
able to completely fill out these budget and resource worksheets
at the beginning of this process. In addition, the items in the
worksheet blocks may change as you work your way through the
IEMS process. These worksheets only present ideas to get you
started.
page 9
-------
Worksheet 1-3: IEMS Development Schedule and
Resources Worksheet
Module
Laying the Groundwork: Identifying
Environmental Aspects
Intermediate steps: (As appropriate)
Making the Commitment: Creating a
Policy Statement and Determining the
Scope
Intermediate steps: (As appropriate)
Determining Significant Environmental
Aspects and Setting Objectives
Intermediate steps: (As appropriate)
Setting Targets and Measuring Success
Intermediate steps: (As appropriate)
Developing Operational Controls
Intermediate steps: (As appropriate)
Evaluating Alternatives
Intermediate steps: (As appropriate)
Implementing Your IEMS
Intermediate steps: (As appropriate)
Setting Up Environmental Management
Projects
Intermediate steps: (As appropriate)
Establishing Continuing Improvement
Intermediate steps: (As appropriate)
Participants
Budget
Target Completion
Contact Person: Date Completed:
page 10
-------
Worksheet 1-4: Persons Responsible for IEMS
Development
Roles
"Management representative" having
responsibility for implementing the
IEMS (in small businesses, this could
be the owner).
IEMS Coordinator
IEMS Team Participants
Identifying and determining
significance of environmental aspects.
Identifying and determining applicability
of legal and other requirements.
Competency-based training.
Operational controls.
Emergency preparedness and
response!
Monitoring and measurement of "key
characteristics" of operations and
activities that can have significant
environmental impacts (i.e., the
"significant environmental aspects.").
Periodic evaluations of environmental
compliance.
Handling and investigating non-
conformance with the EMS.
Records management.
Internal EMS audits.
• Individual(s)
Responsible
Contact Person:
% of Time
Designated
i
Budget
Date Completed:
Note: Most of these blocks will be filled in as development of the IEMS progresses. This worksheet will
help track progress and serve to remind the team and management of necessary assignments.
page 11
-------
MODULE 1: LAYING THE GROUNDWORK
Gathering Information and Identifying
Environmental Aspects: Understanding Your
Company's Possible Impacts
The work in this step mostly involves gathering and organizing
information about your company's activities. Information
gathering involves four activities:
*• map your company's activities and processes,
>• identify inputs and outputs for each activity and process step,
»• identify the environmental aspects associated with each input
and output, and
>• identify regulatory and other requirements.
The process of identifying environmental aspects is best
undertaken through group discussion with all levels of
production employees, office staff, and managers. This helps to
gain insight through different perspectives, and it engages
everyone in the process of understanding the environmental
component of your daily activities.
An environmental aspect is an element of your company's
activities, products, or services that can affect the environment.
Environmental impacts are the changes to the environment
whether adverse or beneficial that result from your company's
activities, products or services. Most elements of your business
operations will have environmental aspects, intended or
unintended.
For example, an unintended aspect of using a cleaning solvent
may be that there are volatile (airborne) emissions produced
during use. The "impact" of these emissions may be hazardous
exposure to workers or the community or a contribution to smog
formation. Another example is the business activity of making
paper copies. The toner cartridges contain chemicals that could
interact with the environment if they are not disposed of
properly. The used toner cartridges with chemical waste would
Each DfE project begins
with a simple mapping
exercise to identify
possible environmental
concerns. Informed
participants then select
a priority concern that
becomes the focus of
the DfE project.
car Tip
An environmental
aspect is any element
of your company's
activities, products, and
services that has the
potential to affect the
environment.
page 12
-------
MODULE 1: LAYING THE GROUNDWORK
be an environmental aspect. The release of these chemicals into a
land fill would be an environmental impact. Figure 1-c lists
examples of environmental aspects and their potential impacts,
and Figure 1-d graphically shows the relationship between
activities, aspects, and impacts.
Figure 1-c. Examples of Environmental Aspects and
Associated Impacts
Environmental
Aspects
Metals discharged to
POTW
VOC emissions
Scrap generation
Solid waste generation
Fresh water use
[ Electricity use
| Exposure to chemicals
during business,
activities
Potential IMPACTS of Each Aspect
Contamination of aquatic habitat and drinking
water supply
Contribution to smog; worker or community
exposure to volatile organic compounds
(VOCs)
Degradation of land, habitat, water supply
Habitat destruction, drinking water
contamination from landfills, wasted land
resources
Depletion of natural resources
Contribution to global warming; degradation
of air quality by electric generating plants
Harm to health of workers, neighbors, wildlife
or plant life
_|
Figure 1-d. How an Activity Becomes an Impact
Activity
Environmental
Aspect
Environmental
Impact
Using a paper copier Used toner cartridges
Discarding toner
cartridges in trash
can release
chemicals to landfills
page 13
-------
MODULE 1: LAYING THE GROUNDWORK
Step 1: Develop a Process Map of Your Company's Activities
and Processes
The first step in identifying environmental aspects of your
business is to develop a map of your company's processes,
products and services. First, categorize your business activities
into areas or steps in the process, so that you can review them
one by one. Some typical areas to consider might include:
Receiving Raw Materials
Storing Raw Materials
Manufacturing Process, Step 1
Manufacturing Process, Step 2 ,
Manufacturing Process, Step 3
Packaging
Process Clean-up
Waste Disposal
Office
Building Maintenance
Shipping Product
Transportation (including employee, sales, and
management staff, parking)
Optional: map customer and supplier activities and
processes that directly relate to your company's activities,
products and processes
>•
>•
Use this list of areas to develop a process map describing the
order in which activities take place in your company. Some
areas may need their own map; others could be parts of a larger
map. Figure 1-e shows a generic process map of a
manufacturing company that might help you to set up your own
map. Worksheets EA-Ola and EA-Olb in the Company Manual
Template also provide a way to document your company's
operations.
Internet {gj
Help
Visit the DfE website for
more tools related to
process mapping.
www.epa.gov/dfe
Tip
These technical
sections are best
developed through
group discussions.
There is no "right" way
to build these lists.
The process, however,
must make sense to
you and be
documented so that
you can review it or
change it later.
page 14
-------
Figure 1 -e. Generic Process Map for Business Activities
Office Operations
Word Processing
Copying
Drafting
Producing Your Product
Receiving
Raw
Material
>
Storing
Raw
Material
¥
Manufacturing
Process,
Stepl
Manufacturing
Process,
Step 2
»
Manufacturing
Process,
Steps
i
r
Process
Clean-Up
Packaging
Waste
Disposal
Shipping
Building Maintenance
Lighting
Cleaning
Heating and Air Conditioning^
Auxiliary ServicefB.g., boilers,
compressors, electrical transformers)
Products
Services
Product X
Product Y
Product Z
page 15
-------
MODULE 1: LAYING THE GROUNDWORK
You will notice that two areas of activities, office operations and
building maintenance, have boxes that are separate rather than
being part of a sequence. This is because the activities identified
under these areas are not related sequentially. Under the area
"Producing Your Product," the activities are connected in steps
required to produce a product or service. This order will be
important to understand later if you decide to work on an aspect
that is part of a sequence of steps.
In addition to the process steps laid out in your map, you should
consider the environmental aspects of your products and
services. For example, does your product or its packaging have
potential impacts on the environment? If so, there may be
opportunities to form partnerships with customers to work on
making changes that reduce the impact. As shown in Figure 1-f,
many companies are extending their responsibility to consider
the upstream impacts of their materials choices and the
downstream impacts of consumer use and disposal of products.
Figure 1 -f. Product X — Extended Responsibility
Origin
Your
Plant
User Jfk Disposal
Step 2: Identify the Inputs and Outputs of Each Activity
The next step in identifying environmental aspects is to identify
the inputs and outputs of each box in the process map you
developed in Step 1. Among those inputs and outputs will be
some that have environmental effects. Figure 1-g shows a
generic step in a manufacturing process. Figure 1-h illustrates
this concept with an example of a business activity (paper
copying) that is an office activity rather than part of an
operational sequence. The second example, shown in Figure 1-i,
Appendix H contains
full-page versions of
the blank
worksheets.
page 16
-------
MODULE 1: LAYING THE GROUNDWORK
shows the process step of press cleaning in printing operations at
ABC company. Figure 1-j shows graphically the general inputs
and outputs of a company's products and services.
page 17
-------
MODULE 1: LAYING THE GROUNDWORK
Figure 1-g. Input-Output Diagram for a Step in a
Manufacturing Operation
Additional inputs (e.g., energy)
Product ^
Input ~~^
MAKE
PRODUCT
—^ Product
Output
Non-product outputs (e.g., wastes)
Figure 1-h. Input-Output Diagram for a Copier
Toner Paper Energy
v v
Original _
Document
COPY
DOCUMENT
Copy of
^Document
Spent Waste Noise
toner paper
cartridges from
mis-copies
page 18
-------
MODULE 1: LAYING THE GROUNDWORK
Figure 1 -i. Input-Output Diagram for Cleaning a Printing
Press
Press Clean Shop
Cleaner Towels
^v ^v
Inked
Press
CLEAN
PRESS
Clean
Press
Soiled Waste
Shop Chemicals
Towels
Figure 1-j. Inputs and Outputs of a Company's Products
and Services
Energy Materials
Chemicals-^
Packaging^-
PRODUCT
Use and
disposal
by
consumer
Waste
Energy Materials
Activities-^
SERVICE
Waste
Use by
consumer
page 19
-------
MODULE 1: LAYING THE GROUNDWORK
Step 3: Identify environmental aspects of each activity
Next you will identify environmental aspects associated with
each input and output. Using your process map developed in
Step 2, identify the environmental aspect of each input and
output. Keep the following key points in mind when identifying
the environmental aspect of a particular activity.
>• Can it interact (beneficially or harmfully) with anything
in the environment?
»• Can it be toxic or hazardous to humans or anything in the
environment?
»• Does it use natural resources?
*• How is it disposed of?
>• If a product, how will it be used and disposed of by the
consumer?
Use Worksheet 1-5 to help you list each process step and its
associated environmental aspect. Appendix H contains a blank
copy for your use.
page 20
-------
Worksheet 1 -5:* Identifying Environmental Aspects
Input/Output
Environmental Aspect
(Quantify if available)
Environmental Impact
Office Activities
Paper (In)
Energy & fuel (In)
Toner (In)
Documents (In)
Waste paper (Out)
Used Toner (Out)
Odors (Out)
Use of paper
Use of energy
Harmful chemicals
Solid waste
Solid waste
Solid and chemical waste
Production of odors
Use of natural resources
Use of natural resources; air quality
degradation
Health and environmental effects**
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Indoor air quality
Manufacturing Process
Press cleaner (acetone,
toluene, MEK, isopropyl
alcohol blend) (In)
Wipers (In)
Energy & fuel (In)
Soiled wipers (Out)
Waste chemicals (Out)
Air releases of press
cleaner (Out)
Chemicals that are toxic to humans
or the environment
Materials that are toxic to humans
or the environment
Use of energy
Production of hazardous waste,
solid waste
Production of hazardous waste,
solid waste
Production of air pollutants
Health and environmental effects*
Health and environmental effects*
Use of natural resources; air quality
degradation
Degradation of land, habitat, drinking
water*
Degradation of land, habitat, drinking
water*
Degradation of air quality*
Products and Services
Product X:
Chemicals
Materials
Packaging
Waste
Energy use
Service X:
Chemicals used
Waste products
Energy use
Chemicals that are toxicio humans
or the environment
Materials that are toxic to humans
or the environment
Production of hazardous waste,
solid waste
Production of hazardous waste,
solid waste
Use of energy
Chemicals that are toxic to humans
or the environment
Production of hazardous waste,
solid waste
Use of energy
Contact Person:
Health and environmental effects*
Health and environmental effects*
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Use of natural resources; air quality
degradation
Health and environmental effects*
Degradation of land, habitat, drinking
water
Use of natural resources; air quality
degradation
Date Completed:
*Use the blank form
Manual Template.
in Appendix H for your data, then use the information to fill in EA-02 in the Company
See Module 3 for information on chemical effects.
page 21
-------
MODULE 1: LAYING THE GROUNDWORK
Step 4: Identify your legal and other requirements
The last step in identifying environmental aspects is to identify
environmental legislative and regulatory requirements that
pertain to your business activities, products, and services.
Regulated concerns that apply to your business should be
included in your system of environmental programs because your
IEMS will integrate all of your company's efforts to manage
environmental concerns.
State and local legal requirements, in addition to federal, need to
be considered. Often states administer federal environmental
and occupational safety and health regulatory programs and may
have stricter and/or different requirements than federal
regulations.
You can obtain information on regulatory requirements from a
variety of sources. State or city departments of environmental
protection might be able to assist you in finding this kind of
information. For example, state technical assistance programs
are often excellent resources and often can provide one-on-one
consultation. In addition, public information offices of both the
Environmental Protection Agency (EPA) and the Occupational
Health and Safety Administration (OSHA) of the Department of
Labor (DOL) can help provide publications that explain
regulations pertinent to your company's activities. Publications
by the DfE Program at EPA and EPA's Office of Enforcement
and Compliance Assurance (OECA) also identify federal
regulations affecting certain industries. Appendix G gives full
citations of the DfE publications, addresses for some resources,
and describes how to obtain them. You can also visit the DfE
Web site at www.epa.gov/dfe. Regulatory information is also
available at the websites of many agencies.
Tip
It is helpful to begin
identifying regulatory
requirements by
making a list of those
regulations that you
know affect your
company. Searching
for additional
information can take
time. Any newfound
regulatory
requirements can be
added into your IEMS
at a later date.
Tip
Even regulations
that may not
directly apply to
your business may
contain important
information about
the environmental
impacts associated
with your type of
business.
page 22
-------
MODULE 1: LAYING THE GROUNDWORK
Worksheet 1-6 will help you organize your search of regulations
that affect your business. In many cases, very small businesses
are exempt from some regulations. Still, the problems addressed
by the regulations may affect your business and may be concerns
you would want to address in your IEMS. Thus, it is worthwhile
to familiarize yourself with regulations, just to identify concerns
and determine whether any of them apply to your operations.
Use Worksheet 1-6 to keep track of regulations that apply to
your business.
Worksheet 1-6*: Regulations
Regulatory
Agencies
Regulations
That Apply
to My
Business
Sector
Contact Person:
Business
Operations
Potentially
Affected
Date Completed:
Does it Apply to
My Business?
"Corresponds to Table LR-01 in Company Manual Template.
page 23
-------
MODULE 1: LAYING THE GROUNDWORK
In addition to regulations, industry codes of practice and other
non regulatory guidelines can help point to environmental
aspects of your business activities. Your trade association also
may be able to help identify useful publications.
The following case study shows how "Company A" set up a
process for creating an environmental management system and
some of the benefits of doing so.
Case Study: Company A
EMS Development
Company A is a 20-person manufacturer of large custom, metal
machine parts for industrial customers. To initiate its EMS, the
company formed a small EMS implementation team that includes
the managers of quality, purchasing, and human resources and
is led by the owner's son. This team developed the
environmental policy for review and approval by the owner,
and, equally important, set up a structure for involving all
employees in the EMS process. Employees receive general
environmental awareness training during some of the company-
wide Friday meetings, and have been involved in identifying
environmental problems and solutions in their areas of
responsibility.
Company A's comprehensive approach to environmental
management yielded immediate results. After identifying oil
usage as a significant environmental aspect, a team of workers
and managers identified faulty gaskets as the primary cause of
oil leaking from the machines. By replacing these gaskets, the
company cut its oil use by 50%. This change, as well as more
general improvements in work environment and worker safety,
caused the local environmental enforcement agency to reclassify
Company A as a^jaon-hazardous waste generator (it had been
classified as a hazardous waste generator). The company also
reports significant improvements in the environmental
awareness of management and workers; though less tangible,
this change in attitude may prove equally significant over the
long run.
page 24
-------
US'
Your discussion should
be comprehensive and
detailed enough to give
you some idea of what
will need to be done to
develop an IEMS for
your company.
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
MODULE 2: CREATING AN
ENVIRONMENTAL POLICY
This module will help you review your company's current
methods for managing environmental concerns, develop an
environmental policy for your company, and determine the
scope of your IEMS. Sample environmental policy statements
are presented at the end of the module.
Understand How Your Company Currently
Manages Environmental Concerns
This step is designed to help you review how your company
currently handles environmental and human health concerns and
compares current practice with where you would like to be. In
some references, this is called a "gaps analysis" because it is
designed to uncover ways to improve your management of these
concerns. This step is best developed through discussions with
groups of employees representing different functions in your
company, especially line managers and line -workers. You'll
need to involve people that have the day-to-day working
knowledge of your company's operations. It is important for
everyone to understand what the IEMS involves and why it is
being implemented. In this way, they can then explore
alternatives to your current practices, so as to improve both
environmental management and cost savings for your company.
It will be helpful to keep a list of answers for future reference.
Discussion Questions
1. Does your company have an Environmental, Health &
Safety Policy?
> Is this policy written down?
*• Where is it located?
> How many employees know about this policy?
US. EPA
Principles that can be a
part of your
environmental policy
include a commitment to
risk reduction, pollution
prevention, and wise
resource management.
Tip
The environmental
policy is the
foundation of the
company's IEMS.
Through it, top
management should
communicate goals
such as preventing
pollution and
minimizing risk to
workers and the
environment.
page 25
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
> How did they learn of it? Is it included in a
training or orientation program?
>• Do employees have the opportunity to make
suggestions regarding environmental concerns?
>• What points are included in this policy?
2. Does your company have specific environmental or
health & safety goals?
>• Are these documented?
> How are these communicated to employees?
*• Is there a way of tracking whether goals are met?
»• Are there penalties within the company for not
achieving the objectives?
> Is there a way to change these goals when changes
in processes, production, or activities occur? How
are these changes communicated?
3. Does your company have a process to identify all
environmental, health & safety regulatory requirements?
>• Has your company conducted compliance audits?
> Has your company received any fines or penalties
requiring corrective action?
Tip
Remember to consider
worker health and
safety, as well as
people outside your
plant, when evaluating
known health concerns.
Tip
The EPA National
Enforcement
Investigations Center
(NEIC) has recognized
the way in which an
EMS improves a
company's compliance
record by providing a
guidance document for
developing a
"compliance-focused"
EMS. (See Appendix G
for more information.)
page 26
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
»• Has your company experienced difficulties in
complying with regulations?
+ Are some regulations difficult/costly to meet?
* Does your company know whom to contact at
local, state, and federal regulatory agencies in the
event of environmental accidents or compliance
concerns?
> Does your company have a mechanism for staying
up to date on changing regulations?
How does your company evaluate risk to human health &
safety and the environment caused by your business
operations? How is this information incorporated into
planning for business activities/production?
Is there a process within the company to review any
changes in products or processes with an eye toward
environmental concerns?
6. Are there policies and procedures regarding procurement
and contracting that consider environmental concerns?
7. What training is offered at your company that would
support environmental objectives?
> Do employees receive environmental, health & safety
training? What percent of employees? Which ones?
»• How is that training documented? Where are the records
kept?
*• Is there provision for regular training on environmental,
health & safety requirements?
8. Does your company have a procedure for responding to
suggestions regarding environmental concerns that it may
B^ Tip
Reviewing these
questions in six
months and, again, in
one year provides a
good way to track
progress in
developing your
IEMS.
page 27
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
receive from customers, neighbors, or employees?
> Is there a process for soliciting and recording any
"suggestions"? Where are these records kept?
> Is there a process for following up on any of these
suggestions to be sure that appropriate action was
taken?
9. How does your company keep track of its documents?
> Is there a filing system?
> How many people are familiar with the system?
>• How many people have access to it?
*• How could someone find information relating to
environmental, health & safety concerns? Are there
Material Safety Data Sheets (MSDS) available? Does
your company have documented standard operating
procedures for plant operations, emergencies, or
document control?
»• How are decisions made about when to dispose of
documents?
10. How does your company identify potential accidents or
emergency situations?
*• Are emergency procedures documented?
>• How do employees find out about them? Is there
regular training?
>• Are these procedures periodically tested, evaluated, and
revised as needed?
>• Have there been failures in response to accidents or
emergency situations?
>• Is there a communications plan in place in the event of
emergencies?
11. Does your company have a way of measuring the
Tip
As you discuss these
questions, it will be
beneficial to write
down the answers for
reference as you
proceed with the
following modules.
«• Tip
You should review
this policy statement
as you complete the
modules following
this one to determine
whether changes
need to be made.
page 28
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
environmental effects of any of its operations?
>• Are there records kept?
> How long?
> Are these records reviewed regularly with an eye to
whether performance has improved or worsened?
12. How does your company track its environmental costs?
* Does your company track environmental costs such as
on- and off-site waste handling and treatment?'
> Does your company track regulatory compliance costs
such as labor costs for labeling, manifesting waste
and/or permitting, and record keeping?
>• When purchasing materials and supplies, does your
company consider things like handling costs, OSHA
training, and shelf life?
*- Are the above costs allocated to overhead accounts or
traced to products or activities?
Environmental Policy Statements
An environmental policy is your declaration of commitment to
the environment and worker health and safety. This policy
serves as the foundation for your IEMS, and provides a unifying
vision of environmental principles that will guide the actions of
employees and management. This policy statement serves as the
framework for setting environmental objectives and targets, and
will be brought to life in your plans and business activities.
Consider the scope of your environmental policy statement for
that will also determine the scope of your IEMS.
Refine Your List of Issues
Review the environmental aspects identified in Module 1.
Make a list of general environmental concerns that could be
addressed in your company's environmental policy statement.
Internet
Help
Visit the DfE website for
more tools related to
gaps analysis:
www/epa.gov/dfe
page 29
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
Set Your Boundaries
Think also about the scope of your policy. Decide whether it
will include activities beyond internal operations, such as
supplier environmental performance or customer product use.
Remember to consider the company's property beyond plant
walls up to the "fenceline." Consider how to include contractors
working at your site, and consider companies you use for
outsourcing. You will want to drop issues from your list that do
not fall within the boundaries set for your policy statement. As
you begin your IEMS, you may want to define your boundaries
within the company. As you gain experience, you may choose
to expand the scope of your IEMS to include environmental
issues important to your customers and suppliers.
Draft Your Environmental Policy Statement In General Terms
Address your list of specific issues in general terms in your
policy statement. For example, if chemicals in your water or air
are a concern because they potentially impact the community,
you could express a commitment to review and, where feasible,
make changes in the chemicals used by your company, or make
sure you are managing them appropriately. Or, if solid waste in
landfills is a concern in your area or to your company, you
could express a cornmitment to reduce the solid waste your
company produces.
Next, think about how to put commitments into action. For
example, your commitment to reduce solid waste may be
achieved through a pollution prevention program and/or a
program to design products or services that result in minimal
waste generated by the consumer. Also, these programs may be
implemented one at a time over a several-year period, as part of
your commitment to continuing improvement.
page 30
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
Sample Policy Commitments
It is important to think through which commitments your
company will be capable of addressing. Do not include
commitments in your policy that the company will not be able to
carry out. The following is a checklist of commitments or
principles that you may wish to consider including in your
policy statement:
Comply with applicable environmental or worker safety
laws/regulations.
Work to achieve pollution prevention.
Prevent accidents.
Identify opportunities for risk reduction associated with the
processes and chemicals used in your plant, the supplies
procured, the products produced, and the disposal of waste
products.
Consider the life cycle (from raw materials extraction and
processing to use and eventual disposal) of products
produced, including packaging, so as to affect how suppliers
and end users impact the environment through your
products.
Continue improvement in your use of cleaner technologies
and processes, and in the safer use of chemicals.
Practice wise resource management, including conservation
of limited resources and reuse and recycling of materials.
Consider which goals of industry or your trade association
could be adopted for your environmental policy statement.
Make sure top management commits to the environmental
policy statement. If possible, the company president should
sign and date it. The final environmental policy statement
should be posted or distributed to employees and other
interested parties.
Resource
Review the Company
Manual Template for
examples of how to
document your policy.
page 31
-------
MODULE 2: CREATING AN ENVIRONMENTAL POLICY
Examples
The following are sample environmental policy statements that
in some way incorporate most of the principles listed above.
page 32
-------
YOUR COMPANY (ABC)
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
This is a sample policy. Adapt for your company.
ABC Company is committed to managing health, safety and. environmental (HS&E) matters
as an integral part of our business. In particular, it is our policy to assure the HS&E
integrity of our processes and facilities at all times and at all places. We will do so by
adhering to the following principles:
COMPLIANCE
We will comply with applicable laws and regulations and will implement programs and
procedures to assure compliance. Compliance with HS&E standards will be a key ingredient
in the training, performance reviews, and incentives of all employees.
RISK REDUCTION, PREVENTION, RESOURCE MANAGEMENT
We will seek opportunities, beyond regulatory compliance requirements, for reducing risk to
human health and the environment, and we will establish and meet our own HS&E quality
standards where appropriate.
We will employ management systems and procedures specifically designed to prevent
activities and / or conditions that pose a threat to human health, safety, or the
environment. We will look for ways to minimize risk and protect our employees and the
communities in which we operate by employing clean technology, including safe technologies
and operating procedures, as well as being prepared for emergencies.
We will strive to minimize releases to the air, land, or water through use of cleaner
technologies and the safer use of chemicals. We will minimize the amount and toxicity of
waste generated and will ensure the safe treatment and disposal of waste.
We will manage scarce resources, such as water, energy, land, forests, in an
environmentally sensitive manner.
COMMUNICATION
We will communicate our commitment to HS&E quality and to our company's environmental
performance to our employees, vendors, and customers. We will solicit their input in
meeting our HS&E goals and in turn will offer assistance to meet their goals.
CONTINUOUS IMPROVEMENT
We will measure our progress as best we can. We will review our progress at least on an annual basis. We
will continuously seek opportunities to improve our adherence to these principles and to improving our
environmental performance, and we will periodically report progress to our stakeholders.
{Signature}
President
Date
Adapted from: Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations. Ann Arbor, MI: NSF International, November 1996, p.3.
page 33
-------
SAMPLE POLICY
This is the environmental policy of a small environmental services
company specializing in waste-water treatment and laboratory analysis of
effluent. The policy should be signed by the company's President.
We supply quality products and services. This requires the commitment of
everyone working in this institution to pursue our activities safely, protecting our
health and preserving the environment.
To realize this vision we will:
• Establish and review periodically our environmental goals within a program
of continual improvement.
• Comply with legal requirements pertinent to our industry and with the
requirements of other initiatives we enter into in accordance with our
commitment to offer quality products and services.
• Conduct laboratory analyses and supply environmental services without risk
to workers' health.
• Operate the laboratory with a mirilTnum of waste, in current and future
operations.
• Pursue our work with a minimum of disturbance to our neighbors and the
community.
• Maintain our vehicles in optimal condition to minimise their consumption of
fuel and their emissions to the atmosphere.
• Manage our chemical products safely, principally to prevent spills in their
storage and transport.
This policy and any subsequent modifications should be familiar to all employees
and available to the public. Implementation of this policy is a primary objective of
the President and the responsibility of all employees.
{Signature}
President
Date
page 34
-------
CASH STUDY: COPY PLUS SERVICES
Sam Worth, owner of a copy center business, was attending a conference on issues
affecting small businesses. The conference was the first of this type that gam had
attended. His business, Copy Plus Services, has five centers located in the western
suburbs of Chicago. Each center provides a full range of copy services including fax,
binding, computer usage, video conferencing, and blueprint service. The centers are run
S4 hours a day and seven days a week. Sam grew the business from, a simple copy
center located in Elgin, Illinois, five years ago and is planning to go national with the
business.
During one of the small group sessions, Sam and five other attendees were discussing
how their businesses affected the environment. One of the presentations had mentioned
a new standard — ISO 14001 Environmental Management Systems — which applies to
service businesses as well as manufacturers. None of the people in Sam's small group
was familiar with the standard. They decided to share with one another what they'd
been doing in their businesses to protect the environment and then review the ISO 14001
standard.
Naturally Sam's five copy centers recycled waste paper. However, beyond that Sam had
never thought of other environmentally conscious programs that they could implement.
He was a bit embarrassed that he had not really given it much thought. He has had
complaints of odors bothering the people in stores adjacent to his centers. In an attempt
to appear as if he had given it some thought, Sam told the group that he had a good
quality program which he thought addressed environmental issues, and that one of his
centers had received an ISO 9001 quality award for doing quality work.
For the most part, the other members of the group had also not given environmental
programs much thought. They didn't have any specific issues confronting them and
were somewhat concerned about embarking on a program for which they could not see
any beneficial return and that might be a big cost to the business. Since they had never
dealt with the EPA, they were leery of the possibility that EPA might come into their
business if they participated in the ISO 14001 program.
One of the group members said that, from what she had read on environmental
programs in Business Week, there were benefits to be derived by undertaking such a
program. Since these programs had to be integrated into the overall business plan, it
seemed important that top management provide the leadership in incorporating
environmental stewardship. She cited some examples of this from case studies she had
read, as well as from her personal experience. One of the examples was an ice cream
business in Chicago, which increased its overall productivity by focusing on energy
efficiency. In addition, an international clothing distributor used the environment as a
major selling point for its product.
After Sam returned home from the conference, he sat down and thought about what had
been discussed in the small group session. He wanted to start an environmental
program in his business but was not quite sure how to proceed. He decided to draft an
environmental policy for his Copy Plus Service before going to bed, and present it to his
staff at their weekly meeting the following Tuesday.
At the meeting Tuesday, Sam presented his environmental policy to his staff. Sam's
staff was composed of the managers of the five centers, a finance manager, and himself.
page 35
-------
The reaction from the group was split. Two of the managers felt that, other than
'ecyoling the paper, there wasn't anything of significance that they could, do within their
business. The other three seemed to think that this was something worth pursuing. The
finance manger was on the fence. While she acknowledged, that there might be some
.deas for them to pursue, she was concerned that it would add cost to the business. The
copy business was a low-margin business and competition was increasing.
Although Sam knew that everyone wasn't equally
committed, they all agreed to pursue the idea further. The
finance manager and the two managers who were
enthusiastic would review Sam's environmental policy to
determine whether it was appropriate for the business. If
so, they would help figure out how it could be incorporated
into the business. Sam suggested that they might want to
talk with someone else in the copy business to see what they
are doing about environmental programs. The finance
manager said that she knew someone from The Body Shop, also in the mall, who had
worked on a committee to develop their environmental program. They all agreed that
the friend should be invited to join them for a meeting as an outside observer and
advisor.
"3? Tip
Sam may have had a better
response if the managers
had all participated in
developing the policy
together.
When the three managers met, Laura Witherspoon from The
Body Shop, a neighboring store in one of the malls, was able
to attend. She agreed to provide her perspective and ideas
in establishing an environmental management system. The
first order of business was for them to explain their
operation to her.
Tip
So far Sam has only
involved managers. He
should now include
employees from all levels
of the company.
Copy Center Operations
Each copy center produces a million copies per year using
premium grade paper. Of that output, 70% is single-sided copies. Bach copy center also
does a significant amount of blueprint business. There are fifteen employees per center.
Bach center's energy bill is $50,000 per month. The majority of the work is done during
9 AM to 6 PM business hours. They recycle approximately 100,000 pieces of paper per
year in each center. Each center uses 400 toner cartridges and two gallons of ammonia
per month. Supplies are stored on shelves in a back room and chemicals are stored
either in metal cabinets or next to the machines (for easy access). Copy Plus Center
customers come both through newspaper advertising and pamphlets, and through their
Web site.
Equipment: The copy machines and computers are three to five years old. They are
typically left on 34 hours a day. The managers are not sure if any of the chemical
products used in the copy and blueprint equipment have an impact on the
environment.
Location: The Copy Plus centers are in shopping malls and residential areas.
Businesses in the area such as restaurants have expressed concern over the odors
coming from the centers.
Delivery Service: Each center has vans providing customer pickup and delivery. In
addition, the vehicles are used to pick up supplies for the centers.
Cleaning Service: Bach center contracts with a cleaning service that cleans the
facilities. A waste disposal company handles the waste, and recycling is
subcontracted.
page 36
-------
Training: Employee training focuses on running the equipment and administrative
procedures, including paper recycling.
Considering this information, Laura suggested that they approach environmental
management system implementation not just from the standpoint of the copy center
operation but from a total systems approach. Laura presented a simple input/output
model to begin the process of understanding the environmental aspects of the
business. The three managers immediately recognized the possibility and benefits of
this approach. They asked Laura if she would be willing to prepare a rough plan that
described this approach in more detail, and outlined a typical copy center
environmental management system. Laura agreed because she remembered how
difficult it was to get the synergy in her own organization. She felt that she could
assist them with this.
page 37
-------
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
From your work in Module 1, you have probably identified a
number of "environmental aspects" associated with your
company's activities. This module will help you prioritize those
aspects. It will also help you determine which one(s) you will
want to work on first. Do not expect to work on all the
environmental aspects identified. "Continuous improvement"
implies that this is an on-going process where you address some
concerns now and others in the future.
Your operations may have many environmental aspects, but they
may not all be significant. First, by ranking each aspect against a
set of environmental criteria (e.g., toxicity, wasted materials),
you can determine which are most significant. Next, to select
which significant environmental aspects (SEAs) you will work
on, rank each aspect against practical criteria (e.g., technical and
economic feasibility) and benefits criteria (e.g., improved
health). For those aspects you select, you will set objectives in
terms of the improvements you hope to make.
Deteraiining which aspects are significant includes making
subjective decisions. For this reason, you will improve results
by having a team of people who represent different job
categories. They can provide a cross-section of operational
experience when you work on this module.
US. EPA
DfE projects emphasize
integrating evaluation of
both risk and resource
conservation into
performance and cost
evaluations.
page 39
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Create a Working List of Environmental
Aspects
When you developed a list of environmental aspects using the
process map of your company's activities, you may have
identified a large number of environmental aspects. This is not
surprising, since virtually all of your business activities could
interact with the environment in some way. In order to identify
which environmental aspects are significant, we will review
environmental risk information. However, ranking your
environmental aspects using environmental risk information can
be a labor-intensive process. Therefore, you may want to create
a smaller list of environmental aspects to rank using risk
information.
First, create a list of selection criteria that suit your company.
Below is a list of examples to help you get started:
>• Which aspects might affect your company's ability to comply
with regulations and other requirements?
>• Are there pollution prevention opportunities?
>• Are there potential cost savings or business opportunities
(e.g., potential customers who require their suppliers to have
EMSs)?
+ Are there concerns that might be shared by customers or
suppliers?
>• Is there "low-hanging fruit" that might provide early
successes which can serve both to educate employees and to
build confidence in the IEMS?
* Are there opportunities to integrate environmental with
worker health and safety requirements?
»• Are there community concerns regarding your company's
activities?
In describing the
approach used to
identify and prioritize
SEAs, one
screenprinter stated
that his company:
"Brought in a cross-
section of staff and
conducted facilitated
brainstorming. They
then captured the
information in a matrix
to help prioritize
aspects."
Another said his
company used
"common sense." He
said,
"A quick walk around
any print shop will
produce at least
enough SEAs to get an
IEMS project under
way."
page 40
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Are there unregulated hazardous chemicals that could be
managed better or substituted?
Are some of your "solutions" to environmental concerns or
regulations shirting waste from one media (air, water, land)
to another?
Could resources be used more efficiently, e.g., energy, water,
materials?
You may want to use all or some of these, and you may think of
others specifically related to your company's circumstances.
Create a list of criteria and use that to select a group of
environmental aspects to rank.
There are several ways to make this selection. One way is for
the IEMS team to review the list of environmental aspects and
vote on their top concerns. Set a target number to rank, say ten,
and let the top ten environmental aspects be your working list.
When you have a reduced list of environmental aspects (e.g.,
ten), you are ready to rank them using environmental risk
information to determine which are significant environmental
aspects.
Using Environmental Risk Information to Rank
Your Environmental Aspects
Although you will not attempt a formal risk assessment for your
IEMS, this module will help you apply your working knowledge
and judgment about the chemicals and materials your company
uses, and the way in which they are used, to select environmental
goals to help create healthier working conditions, communities,
and environments. This section presents a brief introduction to
the concept of risk and to ranking symbols. Then it presents
methods to gather chemical and material effects information and
Tip
Remember: "aspect"
refers to the potential for
environmental impact. A
significant aspect would
have the potential for
large impact, either
because impact is likely
to occur under current
operating conditions, or
because there is
potential for serious
impact. Even aspects
that are well-controlled
should be considered for
their potential for impact
should controls fail.
page 41
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
rank aspects according to effects; a method for making
judgments about exposure to chemicals and materials and rank
aspects according to exposure; a method for laying out risk as
well as other environmental concerns and ranking aspects
considering these factors. In addition, methods for ranking
environmental aspects as projects in terms of cost and expected
improvements are presented as a way to prioritize projects that
your company will undertake to get started on your IEMS.
Risk
Risk assessment, in brief, is a process that integrates the work of
several sciences to determine the kind and degree of
environmental and human health impacts potentially produced
by exposure to a chemical or material.
Risk is composed of two parts: toxicity (hazard or "effects") and
exposure. Toxicity is the ability to cause harm to the health of
humans, wildlife, or vegetation, as well as the type and
seriousness of that effect. You will collect the information
needed to form a judgment about effects in Worksheet 3-1. You
will review the chemical effects information for each aspect and
give a rank based on your judgment of the seriousness of the
effects of this chemical or substance.
Exposure is the amount of material with which workers, the
community, or the environment come into contact. The amount
is determined by both severity and time of contact. Severity
refers to the amount of material that one can come into contact
with at any one time. The time of contact depends on the
number of times that contact occurs in a given period (the
frequency of contact) and the duration of the contact. You will
collect the information needed to form a judgment about
exposure in Worksheet 3-2.
«• Tip
Visit the DfE website for
more tools related to risk.
www.epa.gov/dfe
page 42
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Contact with humans and animal or plant life is characterized as
occurring along pathways. These pathways describe the routes
along which the substance must travel, before it enters an animal
or plant, and how the substance is taken up by the living
organism. Several pathways for human exposure include:
> breathing the material (inhalation pathway),
*• touching the material (skin or dermal pathway), and
*• ingesting (eating or drinking) the material (oral pathway).
Using Ranking Symbols
One way to rank environmental aspects is to use symbols
representing a range of high (H) to low (L). Whatever ranking
you use (Figure 3-a shows an example), phrase the meaning
consistently across all ranking categories; this is most
straightforward if you think of "high" as meaning a project you
would ultimately like to undertake and "low" as one having
lesser priority. Thus, when considering environmental effects, a
chemical receiving a "low" rank would be one with low impact
or good environmental performance.
Figure 3-a: Ranking Symbols
r
1 Symbol
H
M-H
M
M-L
L L
Meaning
High
Moderately High
Moderate
Moderately Low
Low
~i
IEMS Meaning j
Most environmental impact
More environmental impact
Medium environmental impact
Lower environmental impact
Lowest environmental impact i
Identify and Rank Potential Human Health and
Environmental Effects of Chemicals and
Materials
To rank the environmental aspects associated with chemicals and
See Appendix B for a list
of sample questions to
ask your suppliers.
page 43
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
materials used in your business operations, you will need to find
information on the human health and environmental effects
associated with those chemicals. Without this information, you
cannot identify the potential impact of each chemical on the
environment Unfortunately, there is no single and comprehensive
source of information for most chemicals. Information that will
help you understand the effects associated with the chemicals you
use may be located in several different sources.
By taking the time and effort to find information about the
chemicals you use, you will be able to understand the potential
effects of the chemicals on humans and on the environment.
You will also know how to use them in a way to minimize or
avoid harmful effects. You can decide whether you want to
continue using your current chemicals, or find alternatives that
would mitigate any potential harmful impact.
Sources of information about chemicals include:
Manufacturer's Safety Data Sheets (MSDSs). These are
supplied by the manufacturer according to OSHA regulation.
You should receive a MSDS with any chemicals you
purchase. They should be kept hi a location that is available
for review.
Your suppliers. Ask them for hazard and exposure
information on any products you purchase. Ask them to
supply the environmental information that is not on the
MSDS.
Your trade association.
EPA or state environmental agency.
Online sources in various websites, e.g. various EPA
programs. (EPA's DfE Program website contains a Risk
Guide with additional information.)
Tip
Remember, any chemical
strong enough to take the
place of human labor or to
make human labor easier
is strong enough to have
some kind of
environmental risk
associated with it. The
challenge is how to best
manage that risk.
page 44
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Organize the information you have into a format that will enable
i
you to make comparisons between aspects. You may find that
sometimes there exists very little information for a particular
chemical. That discovery in itself is useful. By using this format
and showing where information gaps occur, you will know that
whatever decision you make now about using a specific
chemical may change if information becomes available at a later
date. Although you may want to use the chemical now, you may
need to make adjustments later when more information becomes
available. Worksheet 3-1 will help you organize your
information on the chemicals you use in your business activities.
The column headings list the categories and specific information
needed. The final column asks for your judgment about the
ranking of the environmental concerns associated with the
chemical or material under consideration.
Figure 3-b lists the kinds of information OSHA requires on an
MSDS. Most of the kinds of data listed below can be used to fill
in the columns on Worksheet 3-1. Much of the environmental
information will have to be found elsewhere.
In addition to carcinogenicity information and qualitative
descriptors of health hazards (e.g., sensitizer, causes dizziness,
etc.), MSDSs sometimes include quantitative toxicity values,
which are important for assessing chemicals hazards. These
include lethal dose (LD) and lethal concentration (LC) measures,
which are typically from laboratory studies done on small
mammals such as rats, mice, or rabbits. These measures are used
to give guidance as to the dose required to kill a human. This is
important information; however, interpreting its meaning is
difficult. In general, if you are comparing several chemicals that
have LD or LC measures, the lower measure is the most potent
page 45
-------
(it means that it takes less to be lethal). Therefore, you would
have to be more careful using the chemicals with the lower LD
or LC measures, as compared to those having higher measures.
Be sure to record any quantitative toxicity values found on an
MSDS, as well as the more qualitative information.
Figure 3-b: Information on an MSDS
As defined by the Occupational Safety 8e Health Administration (OSHA) (39 CFR 1910.1200), an
MSDS is written or printed material concerning a hazardous material which contains the following:
The identity of the hazardous material (except as provided for materials that are trade
secrets).
The physical and chemical characteristics of the hazardous chemical (such as vapor pressure,
flash point).
The physical hazards of the hazardous chemical, including the potential for fire, explosion, and
reactivity.
The health hazards of the hazardous chemical, including signs and symptoms of exposure, and
any medical conditions which are generally recognized as being aggravated by exposure to the
chemical.
The primary route (s) of entry.
The OSHA PEL (Permissible Exposure Level), the ACGIH (American Conference of
Governmental Industrial Hygienists) Threshold Limit Value, and any other exposure limit used
or recommended by the chemical manufacturer, importer, or employer preparing the MSDS,
where available.
"Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual
Report on Carcinogens (latest edition) or has been identified as a potential carcinogen in the
International Agency for Research on Cancer (IARC) Monographs (latest editions) or by OSHA.
Any generally applicable precautions for safe handling and use which are known to the
chemical manufacturer, importer, or employer preparing the MSDS, including appropriate
hygienic practices, protective measures during repair and maintenance of contaminated
equipment, and procedures for clean-up of spills and leaks.
Any generally applicable control measures which are known to the chemical manufacturer,
importer or employer preparing the MSDS, such as appropriate engineering controls, work
practices, or personal protective equipment.
Emergency and first aid procedures.
The date of preparation of the MSDS or the last change to it.
The name, address, and telephone number of the chemical manufacturer, importer, employer
or other responsible party preparing or distributing the MSDS, who can provide additional
information on the hazardous chemical and appropriate emergency procedures, if necessary
page 46
-------
c
o
'•§
1
o
(/}
*5*
Q)
•i—
•i—
111
13
+3
|
c =
01
(0
1
X
' 1 |
O cfl
§ (0
13
i I
• will
g J; r=
** 42
(/) fH f»
U (0 C
j£ 2
111 '5*
C
111
>»
w
(J I*.
!j= « 1
UJ £• .C
jc 5 o
^ 1 1
«£ ^0 CO
= °" a
CO 3
1 ^
•o
2
I_
55
(0
§
.w
2
o
__
Q
c
_o
"a
c
c-
V i* £? -
S 81 •£
I'll" 0 ' 1 £
| | J |^.| | | |
o) ^- prr Q- m "" £ ^ §
£ooujSi>OH =
saojnos
uoi)euijoju|
joadsv
IBILOUJUOJIAU^
.a
_0
f-
•*— C
. . ° o.
^> O Q-
o O .§
07 ' T—
0 $
'c *-e
O '(0
^ c
fr
O j_ (0
c CD m' *—
E ° 3 'R
^: m ON
0 o < v
Q.
Q.
(U O O O
>> T- n c
c
.0
CO" 1
Q •§ o
i 5 i
s
E
CD
6
1
1 ^
CO JB
TJ'
0
Q.
O
O
Q
c:
0
2^
Contact
-SJ
•S
I
)le EA-03 in Company Manual
j_i
CO
H
o
•t-l
a Corresponds
CO
Q
CO
0
c
o
TJ
I
0
.a
CO
o
c
3
O
U
.CO
,2
.0
co
1
1
A
DS, but other resources may be needed. In particular, acute effects are usually reported on
CO
0
1
for these columns might come
=
o
to
1
"co
'•£
CO
0.
o
but often will have to be found elsewhere. LC refers to lethal concentration. Inhalation LC50
CO
0
CO
CO
Q
CO
lie effects are sometimes on N
p
!»
O
MSDS sheets.
percent of the test organisms at the end of the specified exposure period. LD refers to lethal
o
i
0
TJ
f a chemical in air that causes
o
.0
to
is the concentr
by the skin, or injected that is estimated to cause death in 50 percent of the test animals.
0
CO
13
O
1
en
•*-*
1
0
sz
o
CO
'o
0
CO
o
0
.CO
o
3
0
CO
o
TJ
divided by the body weight, e.g., mg/kg.
S
1
•o
expressed in terms of amount
0
CO
CO
*— '
co
TJ
0
to
s
fi
lot include environmental effe
o
TJ
to
CO
I
Q
CO
5
TJ
lation found on an MSDS, but it is not a part of the press cleaning example. For more
t
c
.|
*o
CO
TJ
'2.
0
•*->
'o
0
Q.
X
0
C
CO
CO
0
TJ
1
Q.
"0
0
1
.CO
1
ig quantitative toxicity values, refer to the Risk Guide provided on the DfE Program website.
k_
1
e-
_0
s.
lated data, including methods
£D
r
.CO
information on
O)
Q.
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Rank Exposure to Chemicals and Materials
In detennining exposure, the amount of material as well as the
frequency and duration of contact must be considered. An
important element in exposure is contact. If there is no
possibility of contact occurring, then there may be no exposure
and therefore no risk. In some cases, as when a toxic substance
such as lead is embedded in a product such that no contact
occurs during use of that product, the toxic substance may still
leach out of that product if it is disposed of in a landfill. The
possibility of contact throughout the use and disposal of a
product should therefore be considered. If, however, a toxic
substance is contained such that neither humans nor the
environment would come into contact with it, then exposure
would be low. In ranking such a chemical use the rank given to
the "Workers, " "Community," and "Environment" would be
"Low" (L). In ranking exposure, it is, therefore, necessary to
consider how contact might occur and whether, in fact, it does.
Severity (Quantity)
Determining the quantity of chemical or material that humans or
the environment are exposed to can be difficult, especially if the
substance becomes diluted in air as vapor or dust or in water.
Potential exposure is affected by both the amount of a chemical
product used and the concentration of the subject chemical in the
product. First, determine the quantity used per time period
(shift, week, month, year). If the chemical of interest is part of a
product, then apply the percentage that the chemical constitutes
in the product to the total Usage of the product to determine the
quantity used of that chemical. For example, a product may be a
single, pure chemical (such as a solvent), or it may be a dilute
water-based mixture, with the active ingredients being only a
small percentage of the total amount. The higher the
concentration, the higher the potential exposure to that
page 48
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
ingredient. See the Exposure section of the Risk Guide on the
DfE website for more information on evaluating the exposure
amount and ingredient concentrations.
*
Exposure Time
In addition to quantity, the duration of contact determines the
exposure to a chemical or material. How often is the chemical or
material used and for how long? The time period used should be
related to that used for quantity. For example, if you measure
quantity per month, then the time periods should show how
many times (frequency) and for how long (duration) it is used
per month. Use whatever time frame works with your business
operation, but be consistent.
Personal Protective Equipment
The use of personal protective equipment (e.g., gloves, eye
protectors, breathing masks) can greatly alter exposure to a
chemical or substance, for the personal protective equipment
provides a barrier that prevents or reduces contact. Even though
personal protective equipment is used, some exposure may occur
because people are not perfect in their adherence to instructions
and because equipment fails. Consider the possibility of failure
when making judgments about exposure to chemicals and
materials.
Pathways
Substances can come into contact with living organisms through
air, water, land, and other solids. For example, chemicals and
substances can be inhaled from the air in the form of dust,
vapors, and mists. Humans can ingest chemicals and substances
in liquids or food. Substances can get into liquids or food by
falling into them from the air, or by food coming into contact
with chemicals on surfaces or hands. Finally, touching the
chemical or substance can occur when dust, mists, or vapors
Tip
See the Exposure section
of the Risk Guide on the
DfE website for more
information on evaluating
the exposure amount and
ingredient concentrations.
page 49
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
contact bare skin or when unprotected hands touch contaminated
surfaces. Animal and plant life can take up chemicals and
substances from the environment in much the same way. Figures
3-c and 3-d show some typical exposure pathways for chemicals
used in business operations. When ranking aspects, determine
how contact might occur; then decide how severe that contact
actually is and how much time is involved (the frequency and
duration of contact). (For consistency in comparisons between
criteria, apply the same time period to every aspect in your
ranking exercise.)
Worksheet 3-2 will help you think about the exposure for each
chemical you consider. This chart can be filled in for each
chemical or material and represents your best judgment about
exposure. The rank for each can then be placed in the last
column. The rank represents your judgment.
page 50
-------
(/)
1
"tt
i!
"D
iu
"H
0
Chemi
o
Q)
3
W
O
s?"
LU
cvi
CO
+J
(D
CD
(0
J^
o
CO
3
2
0
T3
81
o
Q.
X
j~
C
2
>,
5
^:
15
°"
i
c _
2 =
.!= Q>
1 E
Ul
>.
•=
3
c=
O
u
J2
Q)
O
§
111
~ i? ~
c «
111
c o •=
a "i i *
3 "« S O
X •= Q
c
~"
"re > m
Ills
fc o 's 2v
n *• &
°- a. S
cu
F
£
3
0)
O
Q.
fi
u
c
0)
cr
£
u.
'c
1
Q
*>. a> I
S Q. =
"£ TJ Q.
re cu ...
3 W g
0 => I
<*rf
<*^
u
0)
Q.
^
C
_o
*+s
0)
Q.
O
i
^
_i
Ul
D.
D.
^
I
OS
~ "(O
'co 5
c
o
to
CO
c
U)
s
.0
03
0)
Q.
i cc?
in "o
^
1
T—
fl)
Q.
-? tc?
CM T3
g" « "I -5 |
(D ^ tij Q- O C (jj
CO ^ ^ .£2 CO -Q <0 L—
G)
tc
1 §
Q. "0
•b
"o.
E
o
0
CD
"co
Q
o
CD
Q.
ts
s
o
0
T3
2
a.
cu
o
a.
w
J8
CD
CD
O)
CD
tu
ra
CO
a>
Q.
Q.
Q.
CO
CD
^r <"-
•s
CD
CD
T3
I
E
E
O5
S
Q.
it!
Q
CD
o
CD
2
a
^
CO
CD
O
ts
CD
CO
CO .
^ I
CO ""
3 CD
Q. _eo S=
"S CD *^
f ts te
S E £
E °
CD "co
Q. O
§
CO
o
Q.
s
O>
C ®
I - i
o- .<2 _§
CD >< CO
CO CO >
3 T3 CD
S 8.1
1 E2 "S
to
_ _ o
CO ,_
.9 o
E w fc
l^i
o
u_
10
CD
O)
re
a.
I— V-'
FF
-------
£
I
I
Q.
C
•4=
QJ
Si
U
V
m
I
Dl
CM
IO
0)
D)
-------
•5
i/l
O
Q.
en
c
'c
TO
^J
u
b
Q
ip
no
3
V)
o>
01
(Q
O.
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Ranking Your Significant Environmental
Aspects
Now you will put the Effects information together with the
Exposure information and consider some additional information.
The following paragraphs explain how to use Worksheet 3-3 to
rank significant environmental aspects.
Regulatory Concerns
For each aspect, refer to the regulations associated with it that were
identified in Module 1 and decide how important these are to your
company. For example, an aspect might be regulated, but your
company might be small enough that it was exempt from the
regulation. The regulatory concern for your company might
therefore be considered low (i.e., not important enough for a
project). On the other hand, your company might have an
environmental aspect to which a regulation applies. If you can stay
in compliance easily, you might also rank the regulatory concern
low. Or, if the cost of compliance is large or you have experienced
difficulties in meeting compliance, you may rank this high
(meaning that it may be a good candidate for a project). You do
not need at this point to define your aspect in terms of an
environmental concern. That will show up as you rank the
remaining columns for this aspect.
Chemical and Material Risk
Place both the ranking for effects and the ranking for exposure
from Tables 3-1 and 3-2 in the columns. The effects rank for
humans would be placed in both the worker and community
columns.
page 54
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Worker Safety
Look at the information in Worksheet 3-1 under worker safety and
apply a judgment of ranking. Enter this rank in the worker safety
column.
Other Community Issues
There are a variety of community concerns that might affect your
designation of a particular activity as a significant aspect. These
are issues other than pollution. Some examples are the noise level
or odor produced by your plant; increased traffic caused by your
business; and increased light needed for your operations. You may
come up with others specific to your operation and your
community. Worksheet 3-3 provides a place to document and rank
these issues. Place the rank from this worksheet in Worksheet 3-5.
Worksheet 3-3: Community Issues
Operation
Aspect
Community Issues (List)
Rank
Contact Person: Date:
page 55
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Natural Resources
This criterion should be used to identify the use of water, energy,
and other environmental resources, such as forests or land. The
rank that you give to a particular aspect under this criterion is
highly subject to the specific circumstances, and values of your
company and community. For example, a high rate of water use
would be of higher concern in a desert region than in a region
where water is more plentiful. This column allows you to consider
what resource issues you might associate with a particular aspect.
The rank you give is based on your judgment related to your own
specific circumstances. Other natural resource issues include
generation of solid waste and its contribution to landfills in your
area. Worksheet 3-4 provides a place to document and rank these
natural resource concerns. Place the rank from this worksheet in
Worksheet 3-5.
Worksheet 3-4: Natural Resources Use
Operation
Aspect
Natural
Resources
Used
Rank
Contact Person: Date:
Overall Ranking and Significance
Review the columns for each aspect and make a judgment as to
whether each aspect should be determined H, H-M, M, M-L, L in
rank. After all the aspects have been given an overall rank,
determine which of them you believe are significant for your
Tip
Remember: The ranks
have no intrinsic
meaning. They are
merely a shorthand for
expressing your judgment
about priorities.
page 56
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
company. Place a yes (Y) or no (N) in the final column.
Ranking Environmental Aspects: Examples
The following example shows you how to rank the aspects
identified in Module 1 using the criteria in Worksheets 3-5a and
3-5b. Examples of both small and large projects are included. It
is important that you think through even solutions that seem
obvious, because sometimes you might find a better solution.
Refer to Figure 1-h and Worksheet 1-5 to refresh your memory
on this example.
Example 1: Toner Cartridges
In this example, a copy machine is used to make paper copies as
part of day-to-day business activities. The inputs are toner,
paper, and electricity (energy) to run the copies. Outputs
include spent toner cartridges, \vaste paper from poor quality
copies, noise, and usable copies. There are no restrictions on
use of the copier. Spent toner cartridges are simply discarded
with the office trash.
Let's consider the use of toner in copying. Unused toner is
considered as an input, while used toner is considered as an
output. The same product generates different concerns at
different stages of its use. Let's look at the criteria for each in
Worksheet 3-5a. The worksheet shows the aspects identified in
Figure 1-h. Only the two toner input and output aspects are
scored for this example, for illustration. However, in a real
exercise, all the aspects would be scored.
Tip
If you are pursuing ISO
14000 certification, you
will have to address each
significant aspect. You
may want to consider
reducing the number of
significant aspects to two
or three in the beginning
and add more as your
company grows in
experience with the IEMS
process.
page 57
-------
Example'
0
0)
T3
r
0
I
0
«S
1
*-»
1
0)
W
0
0
Q
B
5
cd
in
CO
*
0
Worksf
Significant
0)
s
.52
73
o>
IS
•o
re
1
Q>
0
p- p
Overall
Ranking
Natural
Resources:6
Community
Issues:*1
||
Environment
Eff/Exp°
Community
En7Expc
3 ui
Regulatory
Concerns
1
Operation
CD
5
CD
O.
re
Q_
01
a
o
0
2
i
-
-
^
^
^
-
|
CD
C
Documents
Q.
re
a.
I
>
x
X
-
X
^
^
X
CD
I ^
la
0
•a
O
TJ
'S
a.
o
0
Q
O
Contact Pers
CD
W
e
*' c
1s iS
1 of
id. n
S CD §
•J5 to >
1 | «
£k S
co re 3
|° §
O^ 13
Q. O
c -e c to
S ° ^^
91 ° OT
< re *-- w
UJ -g •§. w
CO 5 CD .2> E
st§"iS
11 111
c re x re 3
O CD UJ t OT
S- CD "S5 . CD
CD ~° tj CD "0
t CD OT 3
o o S= '5 o
O = UJ Z =
(3 .Q O "O O
CD
D.
re
X
111
OT
S
Ranking Notes for
azardous waste regulations.
s:
o
2
"o
OT
O
**
CD
3
•a
o
CD
O)
•a
1
re
o
CD
-*-•
CD
T3
'OT
i
emicals us
o
CD
4—*
O
*-«
CD
•o
1
t_
Q.
CD
o
^
re
E
r/>
Regulatory concern!
'• identified these in Module 1 .
CD
re
jz
2
1
3
£
CD
O
I
"5
>,
JQ
S
O
S.
E
re
r cartridge
CD
1
CD
f
•^
CD
•o
"w
_c
w
re
•c
CD
to
s
TJ
re
to
Effects of Chemical
sure. Frequency of impact,
!
o
c
E
2
1
E
CD
CD"
OT
•s
Q.
4^
0
o
•5
Q.
_C
O)
•c
•o
1«
cD
f
-*-^
'CD
"D
CD
CD
Q.
Q
•s
c
E
re
OT
CD
O)
TJ
t
re
o
However, since the
1
therefore, would be
S8
D>
•o
I
8
CD
*^
C
!|»
o
•o
CD
to
.to
^
CD
1
CD
jz
•*— »
CD
O
§
o
o
6
"5
CD
.a
•o
3
O
5
t
"cc
to
•o
c
re
*j
re
Workers: Worker he
CD
_C
.>.
0
TJ
§
to
*^
f the toner
E
1
1
o
c
0
1
*5
E
2
o
5
».
•s
>t^
re
to
T5
re
c—
"re
CD
_to
.ti
mmun
Community: The co
le cartridges if they are placed in a
.^
•*-•
"S
•s
o
'o.
OT
§
OT
re
o
'jr
CD
6
to
CD
O)
XI
re
o
t_
o.
>«
CD
1
E
>,
•£
D
O
•5
c
o
o
t
£Z
g>
le
E
Environment might
used cartridge.
CD
•*-*
CD
O
£?
E
^-»
o
T3
O
•D
C
e
CD
O
O
O
re
0
jz
D)
E
•5
i_T
i
i
fc_
*<—
_o
CD
^
~3
i
S
landfill.
Natural Resource U
00
10
CO
O)
re
a.
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
How to Obtain Overall Rank: this can be done in two ways.
1. Look across the columns and assign a total that in your
judgement best reflects the individual ranks in each column.
2. Assign a number from 1-5 to each rank such that H = 5 and L
= 1. Sum these across the columns and then divide by the
number of columns used to get an average rank for that row.
For toner input the total would be 11 (counting each risk
column as 2 because they have two scores and disregarding
other community issues because it was not applicable). Divide
by 9 (the number of columns used). The average rank would
be 1.2, which corresponds with M-L. Place M-L in the Total
column.
Meaning of Environmental Aspects Rank: The total rank for
toner used as an input is M-L and for used toner as an output is M-
H. These ranks tell you that toner cartridges as waste outputs of
your copying generate more concern than they do as new inputs.
Your main concern would be to reduce any potential impact of the
used toner cartridges. You could reduce potential impact in at least
three ways:
> ensure that the cartridges are not opened either before or after
use, to avoid exposure to the chemicals;
* ensure that the cartridges are recycled according to the
distributor's instructions, so that there is neither concern for
ecological exposure to the chemicals in landfills, nor a
contribution to the solid waste going into landfills; and
> reduce the number of waste toner cartridges by cutting down on
unnecessary copying.
Example 2: Chemical Use and Waste
A second example will provide more points to consider in
developing objectives. Consider the chemical inputs and the
chemical waste outputs of a "Press Cleaning" example.
page 59
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
In this example, a printer uses a chemical press cleaner (solvent
mixture) to manually clean the press after each print run. An
uncovered bucket of cleaner is kept at press-side along with a bin
of clean, cloth wipers and an uncovered container of soiled wipers.
To clean the press, the printer scrapes excess ink from the press for
reuse, dips one or more wipers in the press cleaner and wipes the
press; wipes the press with one or more clean, dry wipers; and
places soiled wipers in an open bin. Soiled wipers are transferred
to a closed storage container at the end of the shift. Most of the
resulting ink/solvent mixture is contained on the wipers, but excess
is captured in drums and disposed of as a hazardous waste. Soiled
wipers are sent to the laundry weekly.
Thus, the inputs are the press cleaner and clean wipers. Outputs are
reusable ink, soiled wipers, and waste ink/solvent mixture. The
environmental aspects include the waste ink/solvent mixture and air
and water emissions of press cleaner. Air emissions of press
cleaner occur both in the print shop (from the uncovered bucket of
cleaner, the cleaning operation itself, and the storage container of
soiled wipers), and at the laundry (from the soiled wipers). We will
score the two aspects of chemicals used in press cleaning and waste
from those chemicals.
Tip
Refer to Figure 1-iand
Worksheet 1-5 to refresh
your memory on this
example.
page 60
-------
cy
^j
13
<
73
§
0)
(A
D
"73
jy
,35
E
0)
i
13
1
<
D)
35
t\\
c.
tmm
£
t.
0)
0)
G
3
(Q
0)
4-9
6
A
rt
Worksheet 3-51
Exampleb
=
CO
o 2
.£?
c/5
E &
1 =
•*-»
O
O)
10
« s
= 3
IS o
z 8
"
ommunity
lssues:d
0
It
(0
cE
is
s
13
S
•o
(0
15
u
E
OJ
0
ivironment
Eff/Expc
UJ
>,
'E °Q.
3 X
c Lu
*•• *^
O UJ
o
S3 °g-
1 3
IS
? c
re CD
— o
Q£ "
"S
0>
Q.
0
1
Q.
O
Q.
55
D)
CD "C
co co
CD CD
Q. O
^
I
Ig
-5
_J
£
i
„. 1
^
^^
X
s
X
Toxic chemical
constituents
, ^
1
O)
CD
LU
1
X
X
^
1
_J
S
X
_
^
X
X
Waste chemicals
0
Hi
£
nclude re
£
O)
'E
£,
^
(D
CO
.£'
CD
iure Worksh
8
Q.
fi
•D
C
CO
!fc
LU
l_
I
O
M—
s of waste
CO
o
5
JS
input or to
c
CO
CO
CO
•o
Z!
Q.
•5
o
T3
c
CO.
•s
Q.
0)
O)
to
D.
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Meaning of Rank
The total for input chemicals is M and M-H for output (waste). If
you compare all the ranks, it would seem that the waste chemicals
in this example, using assumed criteria, constitutes a more
significant concern than do the other activities.
Grouping Environmental Aspects
In reviewing your company's list of environmental aspects you may
discover that some aspects occur in more than one process step.
Energy use is a good example. It might be effective in some
circumstances to combine all the process steps having energy
aspects, and develop a facility-wide strategy and program for
achieving improvement. Understand, however, that the energy
aspect should be ranked in each process step to determine its
relative importance in that step. For example, energy use in office
work might be a different priority than energy use in a
manufacturing step. In addition, standards and procedures
developed to reduce energy use would be different for each process
step. Consequently, although you might achieve certain
efficiencies through a facility-wide effort, your actual
environmental improvement will be attained through objectives set
for each process step.
Consider "Practical" Criteria Also
In order to determine which significant environmental aspects will
become projects, it is important to consider the economic and
technical feasibility and the time frame for your company. It is also
important to consider what improvements could be expected from
each project. Selecting high-priority projects is desirable from an
environmental perspective, but there is value in undertaking some
short term, "easier to implement" projects which may not be ranked
high in environmental risk. The easier projects provide a useful
learning experience, boost confidence as people see results, and
Tip
You do not have to
evaluate alternatives
for all significant
environmental aspects.
Therefore, it is
important to consider
the "do-ability" of each
project and to
determine what
improvements might be
achieved by each
project before deciding
which ones to
undertake.
Tip
Remember: If your
company is considering
ISO certification, you
will have to
demonstrate action on
every SEA.
page 62
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
focus attention on environmental goals.
In the examples above, deciding to reduce the volume of copying
and to recycle toner cartridges used in your office copier is a
relatively short-term, low-cost environmental project to set in place
as shown in Worksheet 3-6. Determining how to deal with
chemical waste products could be a longer process: the obvious
solution may not be the best, and a project that appears difficult and
long-term may turn out to have a simple solution. The many
alternative approaches to dealing with waste products can range
from chemical substitutions to changing the nature of the wastes,
changing work practices to reduce the volume of the waste, and
changing disposal methods. Your final environmental program
might include changes in each of these phases. In the example,
although ink wastes may have the highest environmental risk rank,
addressing those problems could be longer-term and more costly.
On the other hand, doing so might yield greater cost savings than
the quicker, cheaper toner cartridge example.
You need not rank your practical criteria; you can consider them
by simply describing the practical considerations for each potential
project. Worksheet 3-6 helps you lay out the considerations for
each significant environmental aspect. At this point the worksheet
provides you with a "first cut" qualitative judgment, to help choose
aspects for further work. Aspects not selected at this time may be
suitable for future projects.
page 63
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Worksheet 3-6: Criteria to Select
Environmental Projects
Project to
Address
Aspect
Toner (In)
Used Toner
(Out)
3ress cleaner
(In)
Waste Ink (Out)
Soiled Wipers
(Out)
Time
Frame
N/A
Short (1
month)
Longer
evaluation
Longer
evaluation
Cost
N/A
Negligible;
time to write
procedure
Employee time
Employee
time, process
change
Contact Person:
Technical
Feasibility
N/A
Easy
Needs help
from
suppliers, etc.
Needs help
from
suppliers, etc.
Total
Feasibility
N/A
Excellent
More difficult
More difficult
Date Completed:
Finally, compare in general the expected improvements to be
gained by working on each aspect. Like any undertaking in a
business operation, you should be able to describe what you expect
to get before you undertake the project! First, develop a list of
benefits criteria. These might include such things as:
*• Reduced human health impacts
»• Reduced environmental impacts
>• Cost savings
> Improved community relations
>• Improved employee morale
>• Customer benefit
Again, these particular criteria might not fit your company. Make a
list of criteria identifying kinds of improvements that could be
derived from undertaking environmental projects. These expected
improvements need not be ranked; simply describe the potential for
each criterion to be achieved. Worksheet 3-7 illustrates the two
examples.
Tip
Considering the
benefits does not
mean undertaking an
analysis of potential
outcomes. It means
identifying the kinds of
improvements that
might be achieved by
implementing a
particular project and
then deciding what
value (priority) that
improvement has for
your company.
page 64
-------
W
4->
C
E
o
Q.
™™
St
c
s
o
0.
i
CO
0
(/>
^
b
0)
•o E
0) 0)
*• >
to 2
HI i
0)
5
o
^
+rf
c Z
||
o 75
O (£
to
O)
c
03
to
w
o
0
'c
0)
c
2
'>
£
Human Health1
Q>
Q.
3
Z
z
i
1
CD
£
•3
£
CD
CD
£
'c'
CD
O
CD
E
o
CO
O)
c
'c
CO
CD
•a
§0
CD S
•c
o
fc
CD
CO
5
o
CO
•b"
o
o
O
CD
O
CO
c:
I
CD
CD CD
E1/5
O CO
CO 5
ll
CD x:
O o*
1 2
CO £
CD
IS
E
o
O
52
CD
O
Si
•a
o
o
CD
JC
0)
^3
2 >,
£
CD .CD
1 i|
CO CD
CD"
I
a.
E
CD
O "-
CO co
Improve worker
health
CD
CO
CD
O
ol o
c.
CD
1
01
CO
CD
•g
it
QL
Q_
^)
"CD
0
UJ
CO
CD
-c n S
en c to
3 CO CO
O " >
£ O "O
m S g
£03
111
•5
£ ^
® =" to
CD **™ 5
^ ^^ "O **^
SC r* CO
o ™ 3 *~
£ C 2 TO
8
,-1 3
^ CD O
I'll!!
fe e
x> CO Q.
C ^ 2"
"CD °
IIInS
•a
*J
CD
Q.
E
o
O
CD
§
C
CD
a.
t3
2
0
O
•
"co
o
CD
i
E
8-
e"
CD
•S
O
5
0)
D)
CO
Q.
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
Overall Summary of Ranking
Worksheet 3-8 illustrates how to put together the results from
ranking the significant environmental aspects with the results
from the economic, technical and improvements worksheets so
that you can determine which will make the best projects for
your company at this time. Projects not chosen now can be
developed later. The example illustrates that while chemical
waste may present one of the most involved projects in terms of
feasibility, it may also provide the greatest improvements. The
final decision rests with your company and should reflect both
your values and your needs. You may want to undertake both a
short-term and a long-term project.
Worksheet 3-8: Overall Ranking
Summary
Process Step
Aspect
Toner (In)
Used Toner
Chemicals
Chemical
Waste
Aspect
Total
M-L
M-H
M
H
Feasibility
Total
N/A
H
M-L
M-L
Contact Person:
Benefits
Total
N/A
M
M-H
H
Significant
Y/N
N
Y
Date Completed:
Setting Objectives
The point of the priority setting exercises, of course, is to reduce
your company's impact on the environment. The process
outlined in this Guide describes two approaches: making your
current activities and processes the best they can be and making
significant changes in the products your company uses or
produces, and in the processes or activities of your company. If
you intend to seek ISO 14000 certification, you will need to take
Tip
It is important to
recognize that the
tables are merely a
tool to help you
summarize your
judgment and organize
your thoughts. The
ranks placed in the
tables do not have any
intrinsic value but are
used for purposes of
comparing the results
to each other.
page 66
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
action on each SEA identified. If you are not seeking
certification, you can be more flexible in undertaking projects.
Module 4 describes the process of evaluating alternatives for
those SEAs you believe will require changes. Module 6
describes the process of developing operational controls for the
SEAs that will not involve significant changes at this time. (You
may decide to evaluate alternatives and make changes in these
later.)
At this point, general objectives can be developed for each SEA
identified. These objectives should be consistent with your
company's environmental policy and also with your company's
compliance requirements. Using the examples ranked on the
worksheets above, a company could specify its objectives as
follows:
>• Reduce the waste from used toner cartridges.
*• Reduce the environmental impact of press cleaning.
These objectives state the desired outcome in terms of the
desired improvement in environmental impact, not in terms of
the specifics of how it might be accomplished. For example, the
objective of reducing waste from toner cartridges is open as to
how that might be accomplished. One could reduce the use of
toner cartridges, ensure that the recycling program is adhered to,
or stop using copiers and printers that have toner cartridges in
favor of another technology. Likewise, reducing impact from
the press cleaning process can be accomplished in different
ways.
In looking at these two objectives, one might note that the toner
cartridge objective might be met by writing and posting a
procedure that ensures recycling of the cartridges and by
making sure that people who change the toner cartridges have
page 67
-------
MODULE 3: SIGNIFICANT ENVIRONMENTAL ASPECTS AND OBJECTIVES
sufficient training in this procedure. On the other hand
determining how to reduce the impact of chemical wastes may
involve some greater changes that would be provided by
operational controls and training alone. In this case, an
alternatives evaluation would be necessary. After an
alternative is identified, of course, operational controls and
training would be needed for the new product, process or
activity.
It is important to take on what you can finish. In the beginning,
tackle the SEAs that you can handle, what is environmentally
important, and whatever is urgent. Your company can start on
any remaining SEAs when you have completed the first ones.
page 68
-------
MODULE 4: EVALUATING ALTERNATIVES
MODULE 4: EVALUATING
ALTERNATIVES
In this module we explore ways to evaluate alternatives for
environmental aspects that you want to change. In Module 6 we
will review how to write and implement operational controls for
significant aspects where you are not evaluating alternatives. As
examples of alternatives evaluations, we will show one project
having a quick, low-cost solution and one requiring greater
analysis and longer-term implementation: the examples of toner
cartridges and press cleaning chemicals. The objectives from the
end of Module 3 were as follows:
*• Reduce the waste from used toner cartridges.
*• Reduce the environmental impact of chemical wastes from
press cleaning. The environmental aspect is vapors released
to air during the press cleaning process and at the industrial
laundry where used press wipers are sent. Identification of
this significant aspect occurred when the laundry called the
company and said they had received complaints from the
local regulatory agency regarding solvent traced to the
printer's press cleaning wipers. The information for this
example comes from the DfE Program Lithography Case
Study 1. (See DfE Program website for Case Study.)
This module will help you determine how to work toward the
objectives you selected in Module 3. In some cases, this might
U.S.EPA
The DfE Program
emphasizes the
importance of evaluating
an array of alternatives
before determining
appropriate action. The
best solution may not be
the most obvious and risk
reduction, like pollution
prevention, may save you
money.
page 69
-------
MODULE 4: EVALUATING ALTERNATIVES
not be a difficult process. In others, however, the solution might
not be obvious. For example, you may have identified the waste
from the use of a chemical as a significant aspect and determined
that alternative practices exist. You may have then set an
objective of reducing the environmental impact from that chemical
as it is used in your business processes. One alternative way to achieve
that objective would be to target that chemical for replacement, but that
may not be the best solution for your company. It is important,
therefore, to consider other options for managing the environmental
impact of that chemical as it is used by your company, as well as the
option of replacement. This module will walk you through a process of
evaluating options for substitution. It will also help you develop
achievable targets having both environmental and economic advantages.
Step 1: Define the Baseline
The baseline is your current chemical, activity or technology that
is the source of the environmental aspect. The process map you
developed in Module 1 is a convenient tool for defining
boundaries of the baseline.
Usually it is fairly straightforward to determine at what point in
the overall process the baseline begins and ends. The definition
can make a big difference, however, in the scope of an
alternatives evaluation and in the variety of alternatives examined.
In our press cleaning example above, the baseline could be
defined in different ways, depending on exactly how the
environmental aspect is specified. If one identifies the
Screenprinters in the
SGI A I EMS Pilot Project
had this to say about the
DfE method:
"The DfE method forces
one to evaluate all
aspects-health, safety,
regulatory,
environmental. The
method helps you to
make informed decisions.
"The process
standardizes methods
used to assess risk and
resource efficiency. It
makes it easier to
compare "apples to
apples." While some
matters are still
judgement calls, having a
frame of reference to
work within ensures that
the standards used to
make those calls are
constant and logical."
page 70
-------
MODULE 4: EVALUATING ALTERNATIVES
environmental aspect as vapors contaminating the work area, then
the baseline would be use of the product producing the vapors
and whatever ventilation hoods or personal protective equipment
are used. If, however, the environmental aspect is identified as
the regulated chemical discharges from the laundry when washing
the press wipers, then the baseline becomes the chemical product
used to clean presses and the work practices that leave large
quantities of the solvent in the press wipers when they are sent to
the laundry. In the first case, alternatives might include different
chemical cleaning products and also different kinds of ventilation
equipment and personal protective equipment. In the second
case, alternatives would include products, work practices and
methods of reducing solvent left in used wipers. Be sure to
capture all you need when you define your baseline.
Step 2: Identify the Function
Next, define the function of the activity with which the
significant environmental aspect is associated. Defining the
function helps to broaden your perspective in developing
alternatives because it allows you to step back from that specific
part of the process and think holistically about how things might
be done differently. Looking at earlier parts of the process will
inform you about potential alternative practices. Defining the
function often opens up opportunities that may be missed by
focusing only on the process step. Here are two examples:
Example 1
Aspect identified: Waste from toner cartridges used in copier.
Internet |I
Help
Visit the DfE website
for more tools related
to evaluating
alternatives.
www.epa.gov/dfe
page 71
-------
MODULE 4: EVALUATING ALTERNATIVES
Baseline: Day-to-day copying activities in an office environment
with no restrictions on use of the copier. Spent toner cartridges
are discarded with office trash.
Function of toner cartridges: to deliver the chemicals to make
clear copies.
Example 2 .. ...
Aspect identified: air and water emissions from solvent used for
press cleaning.
Baseline: Manual cleaning of press using a chemical press
cleaner (a blend of acetone, toluene, methyl ethyl ketone, and
isopropyl alcohol) and cloth wipers to wipe down the press, with
no restrictions on the amount of cleaner or number of wipers
used. Chemicals and soiled wipers are kept in uncovered
containers during the work day and closed containers after work
hours. Waste ink/solvent mixture is collected in drums and
disposed of as hazardous waste. Wipers are collected and sent to
laundry.
Function of press wash: to ensure good quality printing by
thoroughly cleaning the press during and after the printing
process.
Step 3: Develop a List of Alternatives
The important question to ask is how this function could be
accomplished in other ways that might prove to be
environmentally preferable, while still meeting cost and
performance concerns. Different levels and kinds of alternatives
should be considered. For example:
page 72
-------
MODULE 4: EVALUATING ALTERNATIVES
> Substitute products
+ Reduce product use, through technology changes and
improved work practices
*• Improve treatment technologies
*• Improve disposal technologies
Example 1: List the alternatives for reducing the waste from
used toner cartridges
*• First, are there substitute products that could be used in place of
toner cartridges? Probably not, given current technology and the
fact that the toner cartridge specifications are required by the
make and model1 of the printer.
*• Is there a way to reduce the use of the toner cartridges, thereby
reducing the waste product? By defining copier needs, the '''
quantity of copying could possibly be reduced by encouraging
the use of electronic transfer of information within the
company, in place of distributing paper copies.
*• Improved treatment technologies — does not apply for this
example.
*• Improved disposal technologies. The disposal alternatives
include throwing in the trash or recycling.
Example 2: List the alternatives to the current press wash
process v
+ Substitution: First ask the question, is there any way to
achieve the required product quality with the use of less or
no press cleaning solution? You may consider
page 73
-------
MODULE 4: EVALUATING ALTERNATIVES
substitutions in another part of the process, such as the
type of ink, so that less or different press cleaning solution
could be used. Or, you could also consider substituting the
press wash solution for a less volatile cleaner.3 Such
substitution may require other process changes to work.
You could also consider using disposable cleaning wipers,
which would eliminate the releases and exposures at the
laundry. In doing so, however, you may create a problem
of hazardous waste at the landfill, thereby merely
transferring the problem from one location to another
rather than solving it.
Reducing use of the product: reduction in use of the press
wash solution might be brought about by scheduling jobs
to require less cleaning (e.g., heavy coverage jobs after
light coverage; dark colors after light colors), or by
implementing inventory control procedures that discourage
operators from using more wash than necessary (e.g., by
limiting the amount of wash kept at press-side). In
addition, a study could be made to determine what
methods are used by press operators who use the least
solvent. Their methods could be used to train others.
Responsible recycling/reuse: Possibly the waste press wash
solution could be reused one or more times; if not on the
press, then in other clean-up applications.
Improved treatment technologies: Soiled wipers can be run
through a centrifuge to capture excess solvent prior to
being sent to the laundry, but fire regulations should be
3"Volatile" means that the substance evaporates easily.
Tip
Think broadly when
developing
alternatives.
Sometimes an
alternative that is
upstream or
downstream from your
process will produce
better results than will
a change of chemicals
or another in-process
change.
page 74
-------
MODULE 4: EVALUATING ALTERNATIVES
consulted to ensure this doesn't impose a fire hazard.
> Improved disposal technologies: What are alternatives for
disposal? Sending the wipers to the laundry; extracting
waste solvent from the wipers and reusing the solvent for
other cleaning jobs, then sending it to be burned as a fuel;
using disposable wipers and throwing mem in the trash.
Worksheet 4-1 will help you organize the functions and
alternatives for your evaluation. Create your own worksheet from
the significant environmental objectives you selected in Module
3. Some of these boxes can be filled out by brainstorming within
the team working on the IEMS, but some will require further
work before they can be completed. Some additional sources of
information include chemical product suppliers, machinery
manufacturers and suppliers, workers on the line, trade
associations, technical magazines associated with your business,
or other businesses like yours. You may be surprised at how
much information you will uncover. One way to proceed might
be to assign each member of the team one area of information to
collect, and then have them use it to fill in the chart at the next
team meeting. It's important to collect as many ideas as possible
and then narrow down your list of alternatives to evaluate. By
keeping your mind open in your initial brainstorming you may
uncover worthwhile alternatives that are not obvious.
page 75
-------
Worksheet 4-1:* Potential Alternatives
Significant Environmental Aspect: Waste toner cartridges
Baseline: Spent toner cartridges are discarded in trash.
Function: Provide ink for duplicating
Current Practices
Potential Alternatives
Products
Toner Cartridges
N/A
Technologies
Paper
More electronic media use would reduce need for toner
cartridges
Work Practices
Unlimited copier use
More careful about use of printing could reduce quantity
of toner needed
Recycling/
Reuse
Discard in trash
Follow manufacturer's directions to recycle
Treatment
N/A
N/A
Disposal
See
Recycling/Reuse
Above
See Recycling/Reuse Above
Contact Person:
Date Completed:
* Document these results in Section AE of the Company Manual Template.
page 76
-------
Worksheet 4-1:* Potential Alternatives
Significant Environmental Aspect: Press washing
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone,
toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press,
with no restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled
wipers are kept in uncovered containers during the work day and closed containers during
after hours. Waste ink/solvent mixture is collected in drums and disposed of as hazardous
waste. Wipers are collected and sent to laundry.
Function: Provide crisp print quality by effectively cleaning press.
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Current Practices
Prod. A (current)
Current blankets,
Cloth wipers,
Current ink
Work Practice A
Leave solvent in
wipers
Leave solvent in
wipers
Laundry
Contact Person:
Potential Alternatives
Prod. B
Prod. C
(Special formulation)
Different blankets;
Disposable wipers;
Different ink
Work Practice B
Work Practice C
Reuse of solvent for other clean up.
Extraction of solvent from wipers
Trash
Drain
Hazardous Waste
Date Completed:
Document these results in Section AE of the Company Manual Template.
page 77
-------
MODULE 4: EVALUATING ALTERNATIVES
Step 4: Set the Scope of the Evaluation
You have now reached a critical decision point in your
evaluation of alternatives. You must decide how detailed an
evaluation is feasible. Keep in mind the cost of performance
testing as you choose alternatives to evaluate.
When you have selected alternatives to evaluate, place these
alternatives in the appropriate parts of your process map
developed in Module 1. If necessary, create new segments of the
process map so that you can show how the alternative fits into
your process.
The following worksheets show the kinds of information that
should be collected for each set of alternatives to yield a decision
about which option would be the most feasible, both technically
and economically, for your company to reduce its environmental
impact. These tables will also give you the information needed
to frame specific measurable targets for your environmental
programs.
Each alternative requires developing several kinds of
information:
>• health,
>• safety,
>• environmental effects,
>• performance capabilities,
»• cost,
>• effects on resource use, and
page 78
-------
MODULE 4: EVALUATING ALTERNATIVES
*• regulatory concerns.
This information will help you integrate human health and
environmental concerns into your usual decision-making criteria
of performance and cost. The following worksheets are
designed to help you organize this information in a way that
makes comparisons easier. The following sections take you step
by step through the evaluation process.
Example 1
To develop alternatives on copier toner cartridges, your company
would conduct brainstorming sessions about the options for
more use of electronic media within your office and otherwise
reducing the need to use the copier in your office activities.
Developing ways to cut down on copying can extend the life of
toner cartridges and reduce the volume requiring disposal. Steps
that seem appropriate and desirable can be recorded and
incorporated into your targets. You could establish a dual goal
of reducing the volume of copying and 100% recycling of toner
cartridges. Module 6 explains how to develop operational
controls to ensure reduced environmental impact. Module 7
explains how you can make your goals into an "environmental
project."
Most of the alternatives for Example 1 do not require substantial
changes and would be implemented by designing guidelines for
use and maintenance of the copier, i.e., operational controls.
While these alternatives could be evaluated using the steps
below, we will not include this example in the sample
worksheets. Example 2 provides a more thorough example of
page 79
-------
MODULE 4: EVALUATING ALTERNATIVES
the evaluation process, and we will focus on that.
Example 2
To develop alternatives to reduce air and water emissions caused
by press washing, a full evaluation would require research for
each of the alternatives identified. (You may view such an
extensive analysis on the DfE Website. See Appendix G.) You
may not have the resources to do a full evaluation at this time,
but you can research any of the alternatives you choose. The
point of identifying a range of alternatives is to let you choose
the options to evaluate with full knowledge of the range
available to you, rather than in response to preconceptions. For
example, you could choose to evaluate one set of alternatives
now and another set at a later date as part of a continuing effort.
Step 5: Evaluate Potential Human Health and
Environmental Effects of Alternatives 4
Worksheet 4-2 through 4-6 shows the kind of information
needed to evaluate the environmental effects of alternative
products. Refer to Module 3 for explanation of the elements.
Worksheets 4-2 through 4-6 correspond to worksheets 3-1
through 3-5 in Module 3.
4A11 information in worksheets is created for purposes of illustration and does
not represent real data.
Tip
The worksheets
presented in this
section are designed
to be "one-size-fits-
all." Unfortunately,
not all evaluations will
be the "same size."
Adapt these
worksheets to suit the
needs of your
evaluation.
page 80
-------
._ CD *
o 3 "Q
*•" 73 CD
2 W =
jj 0 CD Q
I IP
*- "o » g.
IH ^ X? —•
"(3 *" *"
1 I § s
C •§ c ca
(D 8 = 5
+J co .E co
o >, -a o
n Q. CD ~p
•*• O ^ M
SO. CO N
O != CO
to CO E
C T3 £ <2
JBL S- n\ Co
-0
CC= -0 CD
O CD CO
o * i a
^ JC yj yj
^ >* "O ~O
C i § 1
II 1 _ CO CO
•o | s 1
S E § I
™ to •*= c
.P CD • "o
fl) "o CD T>
,^^ *^ ^5 rt^
(0 ^" CO "5
W 0 CD °
8 f «
1 |||
I ® E "c
jQ. 3 O
^C ^
- , t ^~
• • *•— ' t- Q
^* . o r£
V . ~ ^^ tf)
••• QJ ^ -"^I
ij^ CO C *""
"^^ *"^
1> _ § j/5
^u o 2 ^
W 1 " f .S
^ U £ 4± *"
+i rn ° C3)
S .E « •§ 8
E s 1 ^ 1
i 111 is
«.. U § 1 <
^ 1 i ^ -3
* I'll
•M f- ° 8 •§ & c
go | |i | |
w c s | -1 i S
_b ^ CD' 5 jx: -g co
5 £ 1? Ml
> ^ « .s- o> 1 .a>
> — CO 5 £ co (0
£J
>
£
^_
re
3
^
fl)
re
w
ka
0>
^S
o
2.
| _
f §
III »
!s||
uj 5 UJ UJ
2
«
1
5
w
C 2;
o o>
0 E
1
2 °0
>* '£
o
J2 £
8 o
UJ c
j= ra
i v
T5 ^
s g
1 <
c
10
3
Z
o
15
'
0)
Q
o
'is
re
c
1 ..
Is £ o o » <^
re 3 'e ^ v> S"
Q p. m re &• re DC
>.. C O O) -n O I-- c
saojnos
uoi^euuojui
w
1
0 ?
g £
Greater than 50%
— all chemicals in
(n
Q
w
.23 b' ^ '
t3 c <
111
CL dQ CD
c>-
I
x:
(0 EQJ|X-O-QQ-OOO
O) ^~ ^ ^~ CO O
lcc§>SSSoEoEo
c^-
>. £ ra
i § i
0)
0) 0)
"c CD
•£ co
.iz "O
^j-
^
-*-*" >•*
<~ (jj
1 s
a
< ^ co" ^
p c: S 'o Q_
I E » 1 S
* 5- 1 < S
ui E ~ tK a.
11 O (Q 1 1 Q
i 2 '£ < t
w g 2 a 15
O T- o ui o
SS
in
CM
CD
1
CO
0)
O)
-------
C"
I
-Q S -r
.c p »B .2
f 1 i. i
0)
e 8 1
!t= <2 « -o J2 o t§
o
'§
t
S E?
11
_ M „ **
.j- o> § *§ £ "oj .E §
0) «5 — _ ,*P ^^ -j- (fl (O
> _ O en ^~ ^^ -^•* n ® E
O
S ^
| a --i1
•1 H OT C? 1
1 1 S5 | 1
c S p ° 1
is i&!
e
U)
CM
0)
C;
0)
"I
I
5
.CD"
.U
| CD' E
E > o
H § £ 2
O) 5 O *O
£ 8 S. E
O"
CN-
B
"3
>.! 5
1 8 i
i
of ^
0) Q)
— E
5 • * ® co.y CD ca-gco
-r- CO O)
rf S 2 .5
K _i *C ^
la. LU O °
u. o. co g,
"5 < < - eo
'E LU co Q. c*5
CD tj- O °-
g 8 1
C
CO
CD" o jz
•# •» m- » 's "^
^ O CO r- CO CD
=! CO CD £ C -rj
0 2 T3 CO *= O
D) 2 CO 3 E 0 CO
j= E CD ca o c oi
CO (0 f— c > 13 CD
co"
c
Sr "° *=
•s 8 1
IE!
S O CD
.>- 0 TJ
E
«8 "CO & _
CD •*= CO _- S
8 S S- § . tf g
C t> (0 W O) -^ *O
"c "S" o cS -1 <5 of
£ co y i:;^ 73 Si
< t3
o •§. .2.
by £. s 2
f^ i u) n
c CD
a> ja
S !S
11-
co m CD
(0
CD
O)
O
O
C
•§
a>
CN
CO
cu
D)
co
a.
-------
CO
*1
o co
S Q.
1"
73 CD
r i
C£ OH
X
^ o
S s
CO = Q-
CO § C 0 |>
§ | | 1 1
oo <- 1 t §
8 <
CD -a
co m
CO
to <
a> T3
HI
CO CO
S§ <
0) 73
E JJJ
CO CO
a> -a
CO ro 3
8 <
CD "O
CO ^i
CO CO
0)
CD
CO
CO
(1)
E
CO
CO <
•a
c.
a>
CO
CO
CO
0)
ro
CO <
of
O)
= -i c <
.0 B o TJ
•§ g Jl I
III?
||| j.
CO o O D. O
•" O ^2 = Q. iJ
Q. CO CO CO CO
2 *-- T-
Idl^llt
Q _i a. CL O CO
•g OJ O C
If^^i *f
CO m CD ±3 ^ Q. .—
,5 ^ cox o •§"'«.,•
b
"S
"SJ
"5.
E
o
O
CD
S
Q
O
S2
0
a.
I
I
a See Section AE of the Company Manual Template.
b Most Information for this column can be found on the MSDS.
ources may be needed. In particular, acute effects are usually reported on MSDS sheets.
(0
c Partial information for these columns might come from the MSDS, but other re
Isewhere.
CD
Chronic effects are sometimes on MSDS sheets, but often will have to be found
d MSDSs usually do not include environmental effects.
emergency preparedness plan.
t™
e There may be information on the MSDS that would be useful for preparing you
squired to obtain those effects. For example, a person can drink a certain amount of Scotch.
k_
f This rank is based on the potential effects of the chemical and not on the dose
make a difference ultimately in making a judgment. However, one can still make a qualitative
e impacts. For more discussion of the role of "dose" see the Hazard Guide on the DfE web sit
«j
Drinking a large quantity of Scotch, however, can be lethal. Therefore dose doe
ranking about whether Scotch, cola, water, milk or juice have beneficial or negat
i quantitative toxicity values, refer to the risk Guide provided on the DfE Program website. The
CD
Note: For more information on risk related data, including methods for interpretin
nt real data.
o>
data on this table were constructed for purposes of illustration and do not repres
to
CO
I
a.
-------
c o> «=
CO *~ ™
— . ™ w
o 52 E
M JTT »
£• 0) .3
8 f TJ
To ^ c
— TJ "•
>» a> TJ
W §• =5 S
13 n. w JJJ
p* O ^^ TJ"?
(I) -2 « «
•M TJ w W
ti g g g
^ c" § 1
SO C.3
_^ w
>, TJ S
W f | 0
13 >> 2 i
.O £ qj ,=
^^ dj Q* fl.
i* C *5 -"
*•• C *S IS
CD m" **~ co
(0 2 « ?
o ° •§ •=
& ||l|
^^ ctf 3 r" 3
c ? i S o
^^ C "* 2? '*J
IP S | « c
S w c w W
1 l| ! 1
mco V; 5 S
o ._ to o
._ '?• H >. 0) O)
0) E t» « = c
0 j= 2» ^ 8 =
^ *^ O *" (D fl>
'•P 01 S | * ""
S .S .ts ^ .b
/j\ C O 0) (/) Z.
r- 5 « o ™ ui
T3 •* — o o *-
C/) .. $ c Jl e
^! g f = ^ g
n I I - 8 E
> S S f f S
^ CQ 0 X. TJ W
Q.
3
2
CD
TJ
0>
(/>
o
0.
X
UJ
^
£
CQ
1
m
Q.
n
ii I C
o
.5-
'c
i
o
o
1
b.
Q
• • ^3
1 1
C 0)
2 "g
'> >
C iJ-
UJ 'S
to
•
To
F
Human:
Inhalation, Den
Oral
§ -
£ UJ
0 0-
-S St
^ =
Q. §
ra E
c a.
o '^
2 §•
0) UJ
a.
(U
E
P
(11
S
3
8.
X
UJ
^
o
0)
tr
£
LL
i
k.
Q
a>
if-
'•5 S .2
i ^ s
"
SJ .3
••s =
c -o
M
5
,. „
£* S
"O (/)
C (0
3 _CD
LU
0_
0_
X
0
w - ra
Q) o 'pr
E tr ro
•J= g> 0)
in 73 "G
c
0)
Q.
s. 0 ^ |
."= .— >.
k_r
'co
All for workers,
inhalation for
community
CD
c
o
t)
o
CO
CO
0)
CO
CO
CD
CO
CO
0)
i
0
E
CO
CO
UJ
0)
en
ra
Q.
-------
1
5
'55
2 _
Q £
1 | I
•s « I
= -£ 0
< .£ 0
CO
- 0 .°
i-~ "CO -Q £
o 3 .a CD
•I lit •
£ "TO "a> -§
Ero co~ -.„ _- c
CD ff 5 •;=
«_ > CD 0 £
CO .2 to D. 0
-c a) co ca o
0
ca
CO
0
ro
CO
CO
CO
Is
a. o
0 0
.22 75
5
uj o o 8 g-
8: § 1 ? s
0 -D § CO CD
^ S CO E 1
_ jcu g co o
CD
5
CO
'
CD
O
C.
CD
^ D)
| £ -i
tn . TI "o
— CD CO
o <° .°- .E
ills.
CO >^ Q
o .S> co _
T- o -o .£
^
"O O)
CD '£
Q. CO
S % |
0)
CD -S
its
CD > CD
CO
Technologie
Work
Practices
CD
Recycling/R
use
^ CO 0)
.>• CD c ^-,
r> c ^3 q>
'rn § C O>
§ -s > i
S E E "£
^ O P CD
.S co >{= o
LU
0_
Q.
^
IZ
"ro
CD
TJ
c
o
1
IS
c
CO
CD
>
0
D)
CD
CD
It
. ! .
lc .9- §•
C D) ••=
III
•o _ ro
$ s >>
i i. i-2
Q) Iw Q) C (D
S -S o o eo
I I 1 1 1
•ti CD D)
1 i 1 f
1 1 1 1
H O S- 55
co
CO
o
Q.
'Q
a)
CO
Q
%
Contact Per
TJ
2
Q.
0)
CL
co
•£
CD
XJ
CD
O)
c
CD
O)
1
CD
2
CD
Q.
CD
£
_>,
Q.
Q.
ro
0)
I-
~'t>. "°
111
Q. ro CD
111
S I "
E °
CD
fc - °
§ ro <=
^00
CO 'c TJ
•s I -g
^ O CO
'•p 0 c
i £ s
§--2
>* "ft
ft! —i
§£l
o
CD o
Q- ,„
-n co CD
s 1 8
Q. O Q.
Z5
Q.
8 S
IBs
-C
o
= £
E 2i
0
ro
CD
>, 4g
ro TJ
= |5
"SB
CO
O)
to
Q.
FF
-------
Worksheet: 4-4: Alternatives Evaluation: Community Issues
Significant Environmental Aspect: Press Cleaning
Alternative
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Community Issues (List)
no additional issues
Contact Person:
Rank
Date:
Worksheet: 4-5: Alternatives Evaluation: Natural Resource
Use
Significant Environmental Aspect: Press Cleaning
Alternative
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Natural Resources Used (List)
no additional issues
Contact Person:
Rank
Date:
page 86
-------
•B
nT* 3%
O O
K 0 TJ S
W ^j JB o
t\} CO "rt
Q. -^ co .2
C Q. "O ®
••S £ m ""^
—, g- w "S
JS « « E
t: ^ - «
M _ e c
0) g I |
E g" S g
o S "g 1
^ * w a,
i tsl
W * .2- ^
fl) £* 5 w'
C o> o ^
•= E ^ £
C - to r-
C co ^ !r
L. C B ,2
O0> § S
3 3 TO
^j •* f"
(D -2 o = •
S !iH
Sn tr! SJ J5 2
•M g ^ fe «
CD "2 "2 o S
ij C 3 0 W
_^__ QJ Q ^^
• ••• ;J* ^g ^3
JT -Q E S c
O (0 TO W (0
"""* O ® ^
• • Q^ aM W Qi
C C tl TJ O
OCO C fl?
« ° TO —
•5 ° 52 >. R
m o) 5 (8
^ w .2 -o g>
j cu *- .,, s
—3 g .0 •£ fl
(0 a £ g 52
S "TO w > o>
i H!*I
Q) o £ = & g
> « '5 3 S8 -^
•fl 0) 5. -o | 0
f* O CD 03 3 /ii
fl) W CU *S S ••
+j a> j= c S t3
"3 O_ "^ O TO CO
^ ^ = « £ a
Worksheet 4-6:a .
Baseline: Manual cleaning ol
and cloth wipers to wipe dovu
wipers are kept in uncovered
in drums and disposed of as
Significant Environmental As
tv
T3 CO
0} ^
» 1 i
% E >
C 0)
Q. S
— 0)
2 .E
^m ^
0) "^
> ^
o 2
•^ CD
2 P
3 =
P8 0
2 S
*
>
*s °
1 1 8
£ E 3
o —
O
CO >i
•2 IS
1 *
5 w
.* E J°-
<0 S m
K 2 |
•s > uj
.S c
S iu
td >,.
S -f A
•O § &
C *•"• • m
« | m
«3 £
0 -1 UJ
O fc
& UJ
^* CO
2 S
TO CO
IS
Alternative
w
X -J
TO CO
C C
CO TO
'e "c
X -1
i ^
-J- ^
5:3
i!
X -I
Products:
Blend A (Baseline)
Blend B
| Technologies |
1 Work Practices |
Recycling/Reuse
V)
&
1
^
.TO
"c
TO
•5
X
^
2
X
X
^
1 Treatment: Centrifuge |
TO
O
Q.
Q
a.
1
^_i
TO
Q
Contact Person:
CD
s§
><
o> S?
1 =
Q. QJ
1 &
t— tn
"to §
3 -^
c "^
^ o
^ w
1 «
S s
a Corresponds to SEA-01 in Com
b Effects/exposure
0 Noise, traffic, light, odor.
d Include such items as resource
CO
u>
D)
-------
MODULE 4: EVALUATING ALTERNATIVES
Step 6: Evaluate the Performance of Alternatives
Evaluating the performance of your alternative chemical products
requires several steps, as described below. Performance
evaluations can be expensive to perform. Consider the cost of the
evaluation when deciding how many and what kind of alternatives
to test.
Describe the baseline. The baseline is the standard chemical,
activity, or technology that is currently used. The baseline also
includes the boundaries of the baseline, its process steps and how
they are performed. This ensures that (1) a similar process is used
to evaluate the performance of the baseline and alternatives where
possible, or (2) when a different process is used due to the nature
of the alternative (e.g. technology), differences will be noted and
understood. The alternatives will then be compared to this
baseline.
Example: The baseline for press washing is manual cleaning of
press using a chemical press cleaner (a blend of acetone, toluene,
methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to
wipe down the press, with no restrictions on the amount of cleaner
or number of wipers used. Chemicals and soiled wipers are kept
in uncovered containers during the work day and closed containers
during after hours. Waste ink/solvent mixture is collected in
drums and disposed of as hazardous waste. Wipers are collected
and sent to laundry.
Identify the most important performance traits for the selected
process area. Some sample performance traits include the
following: how well does it work, how long does it take, how
easy is it to use, and how easy is it to install?
Example: The most important performance traits for press wash
are that it work quickly to cut ink, require minimal wiping to
remove any oily residue, dry quickly, and not adversely affect print
quality.
Tip
Cost data for your cost
evaluation should be
collected during the
performance
evaluation There may
be more uncertainty in
the cost data if you
wait to develop it until
after the performance
evaluation. See Step
8 for information on
what kind of data will
be needed for your
cost evaluation.
Tip
See Appendix C for
sample performance
evaluation worksheets
from the DfE Printing
Project.
page 88
-------
MODULE 4: EVALUATING ALTERNAT(VES
Determine how the alternatives will be compared with the
baseline. One example of a quantitative comparison is measuring
the time it takes to complete a task. One example of a qualitative
comparison is using a scale, such as ++ representing "much more
favorable than the baseline."
Example: We will use a comparison scale from -2 to +2, where -2
represented "much less favorable than the baseline," +2
represented "much more favorable," and a 0 represented "no
difference with the baseline."
Select the operating conditions for testing the baseline and
alternatives and conduct the evaluation. The operating
conditions should be realistic and consistent for the baseline and
alternatives. If you cannot test an alternative at your facility (e.g.,
new equipment), have the supplier provide off-site service or
performance test data. Conditions should be as similar as possible
for each test, or the results will not be comparable. Examine work
practices as well to ensure similar application from test to test.
Other elements that may affect testing include room temperature
and humidity. Make a list of what things might affect your test
results and try to make sure that they are similar for each test.
Example: Evaluate the baseline and alternatives using the same
size printing run, the most commonly used ink formulation, the
same application procedures, and the same printed image.
An evaluation example is shown in Worksheet 4-7.
page 89
-------
Worksheet 4-7:* Performance Comparison of Alternatives
Significant Environmental Aspect: press cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl
ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no restrictions on the
amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered
containers during the work day and closed containers during after hours. Waste ink/solvent mixture is
collected in drums and disposed of as hazardous waste. Wipers are collected and sent to laundry.
Function: ensure crisp print quality by effectively cleaning press
Blend A (baseline)
Product B
Technologies
Work Practices
Recycle/ Reuse
Treatment:
Centrifuge to
recover Blend A
Disposal
How well it works
0
0
(Did not show much
difference from
baseline)
+
(demonstrates that
worked well, but is not
comparable to
products above)
Time
0
0
"+"
Contact person:
Ease of use
0
0
Overall Performance
Evaluation
0
0
"+"
works well to recover
solvent
Date Completed:
*Document these results in Section AE of the Company Manual Template.
page 90
-------
MODULE 4: EVALUATING ALTERNATIVES
Step 7: Evaluate what regulations may be
triggered by using each alternative
For each alternative being considered, make sure you understand
the applicable regulations. This may influence your choice of
alternatives. Identify what management controls might be
required by these regulations. Also consider what additional cost
might be attributed to the regulation. Some of the costs associated
with using a product or process may be attributable to a regulation
triggered by using that product or process. These would be the
regulatory cost and should be included on Worksheets 4-8 and 4-
9.
page 91
-------
Worksheet 4-8:* Regulatory Comparison of Alternatives
Alternative
Product
Blend A
Blend B
Technologies
Work Practices
Recycle/ Reuse
Treatment
Centrifuge
Disposal
Applicable
Regulations
same as Worksheet
4-2
none
possible local fire
regulations
Required Controls
same as Worksheet
4-3
none
May not be allowed
Contact Person:
Regulatory Cost
Items 1
SARA reporting,
PPE, Chemical fume
hoods, fire controls
none
Overall
Regulatory
Concerns
Evaluation
H
L
H
Date Completed:
*Document results in Section AE of the Company Manual Template.
11nclude: paperwork triggered, reporting requirements, cost of controls,
personal protective equipment and any other costs that may be attributed to
regulations associated with using that product or process. It is not necessary
to quantify on this table. See Step 8 and Appendix F for more ideas.
page 92
-------
MODULE 4: EVALUATING ALTERNATIVES
Step 8: Evaluate the cost of the baseline and
alternatives
Determine the cost of each alternative, including: raw materials,
labor, disposal costs, (all from Step 6) and regulatory costs (from
Step 7). Include all the cost categories in the baseline and the
alternatives. It's important to document all costs, even those that
are the same for the baseline and for the alternatives.
Documenting all costs gives you a reference later to answer
questions and to support further evaluations. Figure 4-a shows
possible costs associated with regulations that may be hidden in
overhead in your company's accounting system. Be sure to
include these hidden costs when completing the worksheets.
See Appendix F for more discussion of environmental cost
accounting.
page 93
-------
MODULE 4: EVALUATING ALTERNATIVES
Figure 4-a. Examples of Environmental Costs Incurred by
Firms*
Regulatory
• Notification
Reporting
Monitoring/testing
Studies/modeling
Remediation
Recordkeeping
Plans
Training
Inspections
Manifesting
Labeling
Preparedness
Protective equipment
Medical surveillance
Environmental
Insurance
Financial assurance
Pollution control
Spill response
Stormwater
management
Waste management
Taxes/fees
Upfront
Site studies
Site preparation
Permitting
R&D
Engineering and
procurement
Installation
Conventional Costs
Capital equipment
Materials
Labor
Supplies
Utilities
Structures
Salvage value
Back-End
Closure/
decommissioning
Disposal of inventory
Post-closure care
Site survey
Voluntary
(Beyond Compliance)
. Community relations/
outreach
> Monitoring/testing
> Training
» Audits
• Qualifying suppliers
• Reports (e.g., annual
environmental reports]
• Insurance
. Planning
. Feasibility studies
• Remediation
• Recycling
• Environmental studies
. R&D
« Habitat and wetland
protection
• Landscaping
• Other environmental
projects
• Financial support to
environmental groups
and/or researchers
• Future compliance costs
• Penalties/fines
• Response to future
releases
Remediation
Property damage
Personal injury
damage
Legal expenses
Natural resource
damages
Economic loss
damages
Corporate image •
Relationship with
customers •
Relationships with
investors «
Relationship with insurers
Relationship with
professional staff
Relationship with
workers
Relationship with
suppliers
« Relationship with
lenders
• Relationship with
host communities
• Relationship with
regulators
•Taken from "An Introduction to Environmental Accounting as a Business Management
Tool: Key Concepts and Terms," EPA 742-R-95-001.
page 94
-------
MODULE 4: EVALUATING ALTERMATfVES
Evaluating the cost of the baseline and alternatives requires
several steps, as described below.
Annual operating costs
Collect annual operating costs for your baseline and alternative.
Use Worksheet 4-9a to help you collect cost information.
Review Worksheets 4-2 and 4-8 to assist you in evaluating
environmental costs. Be as thorough as possible when
considering costs, but don't worry about how you classify costs.
For example, you may wish to consider personal protective
equipment as a regulatory compliance cost, especially if its use is
required by regulations. Alternatively, you may wish to classify
all protective equipment as "materials." Use Worksheet 4-9a to
record operating costs.
page 95
-------
1 "°
ro 2 i
7? CO CO
.§ co E
||l
o — • Q)
Q. 'O 13
§• CO _CD
CO T3 TT
~ C g
T| CO
TO CO .52
. CO CD
CD O i=
C "r— ^
ocx
1^1
!• ° 1
Q) CD -x
CO O
^ 3 .W
^~^ CO ™2
® CD •-
E .0. CD
(jj- 5 "K
1 2 5
CD
2 -Q i«
- E 3
CD 5 0
ISt
T5 o CD
P i_ i£
CO CD CO
"S § i>
131 ^
CD u- T3 C?
S ° i2 C
-*^ U-i t—
WCO C CD 3
*-* 3 C CO
"B Ills
8 51 8 -
VJ 0 .E T3 tO
D) g § § 1
f ill!
& i ii t i
1 I till
C Q. co co" g 5
1 S &|| a
o. M- « w
•j w o 5J 2 co
TO < D> ^ CD 5
lillll
j. ^ 0 CD 0 CO
d) i 1 f "8 1
2 = § 5 5 CO
^ liJ 2 ^ P «g
£ lilli
O *s g 5 i. S.
> ,2> co o g- .w
> W m "o xi -a
O)
^•J
j2 to
O CL O
HOC
t
•Q
.2
•"•
I
•5
u.
CD
U
i
3
_C
CD
1 I
fO — •
3 5"
I 3
4rf
0)
E
a> 2*
•JS CO
CO C
g i
(0
.Si
'•£!
13 o
S* |
S -i
"3
•c
i
Alternative
in
o>
m"
CO
To
CD
E
CD
.0
'co co
CO ±±
O 3
Q. CO
E
O
O
CM"
o
o
o_
te-
f
w
q
«£
c\
S
CD
"5
CI
CO
1 ^
8 «
a. m
3
»
»"
E
g
0
O
C
w
CN
or
CQ
•a
0
m
Technologies
to
Work Practice;
"35
O CD
c? S
CD CD
OL UL
D
y>
o
*&
o
o
CM
O
O
CM"
1
co"
&>
o
o
CM
O
Q!
V*
CO
'c
Treatment:
Centrifuge
0
\
u
Q
CD
"S
Q
f t
c
Contact perso
to
en
cu
D)
cs
Q.
-------
MODULE 4: EVALUATING ALTERNATIVES
Potential Annual Revenue Effects
Environmental projects may save you money not only by
reducing your costs, but also by generating revenues. For
example, an alternative may increase your product throughput
because the activity takes less time to complete, or product
quality may be improved enabling you to sell more of your
product. The alternative may also let you recover materials
previously disposed of, and generate revenues through sales of
the reclaimed material (such as recovering metal scrap which can
be sold to scrap dealers). These annual revenue effects should
be considered using Worksheet 4-9b. If these potential revenues
are difficult to quantify, you can consider them qualitatively in
your evaluation by making a note in the last column of
Worksheet 4-9d. In general, a reduction in materials needed
would show up on Worksheet 4-9a: Annual Operating Costs. In
this example, the reduction in press cleaning solvent needed due
to switching to a less volatile blend (much less lost through
evaporation during use) does show up in the first column of
Worksheet 9-a. The revenue effects shown in Worksheet 4-9b
are caused by reusing the solvent recaptured by the centrifuge for
other cleaning operations (not press cleaning). In other words,
the centrifuge saves on the purchase of other kinds of cleaning
solvents than the ones being considered for press cleaning.
page 97
-------
Worksheet 4-9b: Potential Annual Revenue Effects
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene,
methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no
restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers are
kept in uncovered containers during the work day and closed containers during after hours.
Waste ink/solvent mixture is collected in drums and disposed of as hazardous waste. Wipers are
collected and sent to laundry.
Alternative
Products:
Blend A or B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Product
Throughput
none
0
Contact Person:
Product
Quality
none
0
Reuse of or
Sales of
Recovered
Materials
none
$34,000
Date:
Total Revenue
Effects
0
$34,000
page 98
-------
MODULE 4: EVALUATING ALTERNATIVES
Initial Investment Costs
Collect initial investment costs for each alternative. If any of
your alternatives will require an investment in new equipment,
you will need to consider these costs. These not only include
capital costs, but also other one-time costs accompanying your
investment, such as installation costs ornew equipment training.
Use Worksheet 4-9c to help you collect these costs.
page 99
-------
II
y Jid (/)
CO CD 0
£^- CO W
^ w 'D
8 8.1
CO 'g ra
^ T3 C
P. ci) g
o. 8 •"
O _ c
.£2 ? "~
X5 CO Q)
m — "o
S- 8 1
§18
43 CD M
CD f •—
^ 0 CD
>» . 3
Jf to "c
m ijj §
E .|-|
iii
.3 CD ^)
>. c ro
QJ 3 ^^*
c c >
42 >- .
8 £ |
m /i) ~-*
« 2 o
0 CO -p
73 — CD
f" U j^**
CD *•— CO
-Q ., D)
f § 1
CD g T3
m CO J"
TO l—
CD CD CD ^
* 15 £ .£ ^
W « c 43 1
« E S Q I
O O- c o
LJ CO ~ CD •t-'
•M •§ S g §
r* D) P is £ S
1 4-9c: Initial Investmer
ronmental Aspect Press Cleanin
jal cleaning of press using a chei
wipe down the press, with no res!
ainers during the work day and c
/aste. Wipers are collected and s
8'> c o = 5
C 03 4=1 O W
_ UJ 2 co " g
1 lilll
w c to i= Q .c
> .2* co o c w
>• 03 CQ 73 3 co
>
MM JO.
43 w
o o
H 0
i
0
0
D)
£
1
S.
1 I
•e c
45 fi
CO H
"c
.2 c
11
in m
0 <2
0 S
c
_o
50
a 1
CO Q.
D)
— , .C
1 1
'E .c
« 1*
Q. UJ
Utility Systems/
Connection
Purchased
Equipment
Alternative
CD
1
CD
C
C
CD
O
c
CD
0
C
u)
8
co
i
0}
c
o
c
CD
O
C
0
o
c
Products
Blend A or B
Technologies
Work
Practices
Recycle/Reuse
8
h-_
£
0
f
o <2
•8 |
1. 0 f,
Q ° £
O
CN
°*
O
S
m
w-
§
C3
0
§
o
in
V
co-
Treatment:
Centrifuge
o
Q.
CO
Q
CD
Q
Contact Person:
CO
CD
T3
C
CO
CD
CO
§.
CD
CD
CO
CD
O>
C
co
D)
re
a.
-------
MODULE 4: EVALUATING ALTERNATIVES
If a change in your processes or activities will affect your costs
and savings over many years, the analysis should look at long
term costs and savings. A critical component of assessing a
project where costs and savings may occur over several years is
incorporating the notion that the value of money changes over
time - commonly called the "time value of money." Most
businesses prefer to have money sooner rather than later. If you
have money today, you have the opportunity to use it now to
grow your business. See Appendix F for more information on
how to obtain the net present value of your initial investments, if
you wish to make that calculation.
Cost Comparison
Use Worksheet 4-9d to list and rank the results of each cost
table.
Tip
Remember that your
accountant can assist
you in making these
calculations.
page 101
-------
MODULE 4: EVALUATING ALTERNATIVES
Worksheet 4-9d: Cost Comparison of
Alternatives
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a
blend of acetone, toluene, methyl ethyl ketone, and isopropyl alcohol)
and cloth wipers to wipe down the press, with no restrictions on the
amount of cleaner or number of wipers used. Chemicals and soiled
wipers are kept in uncovered containers during the work day and closed
containers during after hours. Waste ink/solvent mixture is collected in
drums and disposed of as hazardous waste. Wipers are collected and
sent to laundry.
Alternative
Products
Blend A
Blend B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Total
Operating
Costs
$35,495
$8,820
$9,120
Total
Investment
Costs
$0
$17,700
Contact Person:
Annual
Revenue
Effects
$0
$34,000
Rank
H
L
L
Date:
Document results in Section AE of the Company Manual Template.
Step 9: Evaluate Results
Use Worksheet 4-10 to compare performance, regulatory
considerations, cost, and environmental effects for alternatives.
page 102
-------
Worksheet 4-1O:* Evaluation of Alternatives
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl
ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no restrictions on the
amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered
containers during the work day and closed containers during after hours. Waste ink/solvent mixture is
collected in drums and disposed of as hazardous waste. Wipers are collected and sent to laundry.
Alternative
Chemical
Product A
(current
baseline)
Product B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Performance
Rank1
0
0
Uf«
Contact Person:
Regulatory
Considerations
Rank2
H
L
H
Cost
Rank3
H
L
L
Environmental
Effects 4
H
L
M-L
Overall
Evaluation5
Poor due to
effects
Good due to
effects & cost
Good due to
effects &
savings
Date Completed:
*Document results in Section AE of the Company Manual Template.
1 Take from Worksheet 4-7 Performance Comparison of Alternatives.
2 Take from Worksheet 4-8 Regulatory Comparison of Alternatives.
3 Take from Worksheet 4-9d Cost Comparison of Alternatives.
"Take from Worksheet 4-4: Criteria to Determine Environmental Impact.
5 Rank the desirability of each alternative. This is a judgment call.
Note: For more information on the methodology for comparing alternatives,
refer to both the DfE Website and the Cleaner Technologies Substitutes
Assessment, A Methodology Resource Guide, DfE, U.S. EPA 744-R 95-
002, Dec. 1996.
page 103
-------
MODULE 4: EVALUATING ALTERNATIVES
Interpretation of Results
Performance
The rank of "0" for product A reflects that it is the baseline.
The rank of "0" for product B indicates that it's performance is
very similar to the baseline. The + shown for the centrifuge
shows that it performs well, but is not directly comparable to the
products above.
Regulatory Considerations
Ranks show that product A has many regulations associated
with the chemicals it contains, but product B chemicals have
little or not regulations. The centrifuge is rated high because
some states have regulations that may prohibit the use of
centrifuges for recovering solvent from wipers. Also, the
explosive nature of Product A ingredients would affect the type
of centrifuge used. If product B were used with the centrifuge,
the regulatory concern might not apply.
Cost
The rankings show the high cost associated with using product
A compared to the low cost of using product B. In addition, the
low cost rank for the centrifuge reflects the cost savings
affected by re-using reclaimed solvent.
Environmental Effects
The high rank for product A reflects the serious impact of the
chemicals contained in it, while the low score for product B
reflects the low impact of that product's chemicals. The M-L
rank for the centrifuge reflects the reduction in use of solvent
with some continuing exposure to the solvent for workers who
transfer the wipers from bins to the centrifuge. There would
also be some community exposure from venting the centrifuge
out doors. In addition, it reflects the concern with the
possibility of explosion of the centrifuge while extracting these
solvents.
page 104
-------
MODULE 4: EVALUATING ALTERNATIVES
Conclusion
From both a cost and environmental perspective, switching to
product B and using the centrifuge would make sense.
Remember, like all other aspects of your IEMS, evaluating
SEAs and alternatives is an ongoing process. What you cannot
accomplish this year, you can plan on doing next year. Take it
step by step to avoid being overwhelmed.
page 105
-------
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
For each objective you set for your significant environmental
aspects in Module 3, you will set a corresponding target. A
target is a detailed performance requirement. Using the Module
4 press cleaning example, assume that the alternatives evaluation
showed that the Company could reduce air and water releases
both in the plant and at the laundry by substituting Product B,
and that this shows an acceptable level of performance and cost.
The environmental target then could be stated as follows:
Reduce air releases of regulated chemicals in press
cleaner by 80% in the plant, and reduce the volume
of regulated chemicals on used wipers by 40% by
the end of a 13-month period through product B
substitution and improvements in work practices.
The evaluation showed you what is possible in terms of reducing
air and water releases, and also showed you the best means to
accomplish that objective. When you frame your target consider
how you will measure the results. You will need to establish
ways of measuring your progress in meeting the targets, in order
to both evaluate your process and document success. Time
frame is also important. How long will it take you to implement
the program, which includes training people, acquiring new
product, phasing out old product, acquiring equipment, defining
new work procedures for several steps of the production process,
and establishing operational controls for changed processes?
Measuring Results
Some say that "an EMS without an effective monitoring and
measurement program is like driving at night without the
headlights on - you know that you are moving but you can't tell
oar Tip
State your target in terms
of the environmental
improvement to be
achieved, rather than the
means of achieving it.
For example, "reduce air
releases of X" rather
than "substitute X." The
desired improvement
may continue for a long
time, but the means may
change with
circumstances.
«• Tip
Be sure to consider
what operational
controls may be
needed for any new
processes. Refer to
Module 6 for help.
107
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
where you are going!"5
For each target, identify a measurement for success, e.g. volume
of waste or energy used or percent of cartridges recycled (see
Worksheet 5-1). These measurements, also called performance
indicators, should be:
>• simple and understandable,
>• objective,
* verifiable,
*• linked to production, and
>• relevant to your objectives.
Below are some sample performance indicators:
»• tons of SO2 released per unit of electricity produced,
» pounds of hazardous substance "X" emitted per unit of
product, or per dollars of sales, and
>• percentage reduction in the discharge of a material in a
given year versus that in a base year.
Measure changes in the aspect (e.g., reduced waste) with respect
to production or sales rather than by itself in order to evaluate
environmental improvement. Changes in the aspect can be
caused by changes in the sales volume with no real
environmental improvement. Each measure should be an
indicator of where problems may be occurring in the process.
Worksheet 5-1 is designed to assist you in tracking your
measurement indicators.
Tip
Environmental Management System: An Implementation Guide for Small and
Medium-Sized Organizations, NSF International, Ann Arbor, Michigan,
November 1996, p. 49.
Measuring and
evaluating
environmental
performance is an
ongoing process.
108
-------
Worksheet 5-1: Environmental Performance Measurement
Indicators
Aspect
Waste
Toner
Cartridge
Objective
Recycle
cartridges
Indicator
Number
bought /
number
recycled
Date
Checked
monthly
Contact Person:
Who
Checked
Office
manager
Result
1
missing
Corrective
Action
Discuss
problem with
copier
maintenance
person
Date Completed:
109
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
In the toner cartridge example, the performance indicators might .
be the number of toner cartridges used and the number sent for
recycling. In the case of the air emissions from the press
cleaning, measurements could include:
>• amount of press cleaner used per 1,000 images printed,
>• amount of press cleaner saved over a selected time period,
*• amount of press cleaner used at each press per 1,000
images printed,
> amount of fluid collected from wipes before sending them
to the laundry, and
>• levels of solvent in water reported by POTW associated
with laundering this company's press wipes.
You may be able to think of more. It is important to recognize
that each "indicator" measures something different. The first
one measures "input" with respect to "output." This ratio is
important because changes in use of press cleaner can be caused
by fewer print runs, as well as more efficient use of the cleaner
during the production process. To be sure that you are
measuring success rather than simply reduced production, be
sure to include output in your measurement criteria. You may
also need to include more than one kind of measurement to
understand the results and be able to evaluate the process.
The second measurement allows you to compare a current time
period with previous time periods with respect to press cleaner
use, which could help to indicate efficiencies in use, such as
better work practices. Again, this comparison should not be
made without reference to output over the same time period.
Number three also provides a comparison among different work
practice methods. Number four shows how much press cleaner
is being reused and the reduction in burden on the laundry, and
number five shows the success in reducing water releases at the
laundry. In a sense, number five is the "acid test" of whether
your goal is being met. Without success here, the achievement
of the targets within your plant would be meaningless because
U.S.EPA
Experience has
shown the
importance of setting
up measurement
criteria to assess
how things are
going.
110
-------
MODULE 5: SETTING TARGETS AND MEASURfNG SUCCESS
the original problem was the water releases from the laundry
caused by the wipes. Each of the other measurements shows
success in the achievement of targets that are steps toward your
final goal. Also, some of these measures can be used to
determine cost savings related to particular steps and to the
overall goal. Most important, each measure is an important
indicator of where problems may be occurring in the process.
If you use special equipment to measure environmental
performance, it is important that you maintain and calibrate the
equipment on a regular schedule. Again, designate a person to
be responsible for this task, provide appropriate training on
maintaining the equipment, and document the calibrations
schedule. Worksheet 5-2 provides a sample log for calibration.
Worksheet 5-2: Calibration Log
Indicator
Measurement
Method
Contact Person:
Equipment
Used
Equipment
calibrated:
date/method
Date Completed:
Determining Causes of Problems
You will need to establish a method to determine the causes of
failing to meet a target. In some cases, the cause might not be
difficult to understand. Other times, however, the cause might
not be obvious.
One method is called "root cause analysis." This method can be
applied here to identify causes for not meeting targets. You can
also use it to determine the possible causes of a potential impact.
You should determine the root cause of each of your significant
aspects.
111
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
The root cause diagram, shown in Figure 5-a, will help you
organize your thinking when you analyze your company's
potential for environmental impact. This analysis can be done by
one person or by a group, with one person writing down the
ideas produced. Each diagonal line represents a main
component of the production process. Your company may have
different or additional components (for example, "disposal")
beyond those represented here. Each horizontal line stemming
from the diagonal represents an important element contributing
to each of the main components. For example, elements of work
practices might contribute to the labor component. This diagram
is simply a device to help organize the analysis of the cause of
potential environmental impacts. Use it if it helps, but don't get
hung up on trying to make it work.
Tip
For more information on
constructing a "Cause
and Effect Diagram," go
to www.sytsma.com/
tqmtools. cause, html
112
-------
Figure 5-a. Root Cause Diagram
c
'co
E CD
CD O
8
.CD £ o o
.* o t- ti
Q O Q. Q.
c 0
t ~
o o
•Ss
ii "3 -g
Oi ^ 0
•^ -4—* C,
-3 C O
^! O D.
lis
• <"" f""
o 0 'to
3; "0 E
0
feS
1?
>, U)
c = J2
3 £ CO
O -;r O
^1 1
•o 3? 0
c -i -S
jO
| co To o
c •• w -^ a)
2 IS I-S5
•5 S.l|i
£15 8 S
113
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
The following are typical, but not necessarily obvious, causes of
problems:
> poor communication,
> faulty or missing procedures,
» equipment malfunction (or lack of maintenance),
>• lack of training,
> lack of understanding (of requirements), or
»• failure to enforce rules.
Be sure that you have considered these possibilities in your
environmental impact analysis.
Taking corrective action
Once you document a problem with respect to meeting targets,
the company must be committed to resolving it. Take action as
quickly as possible. First, make sure assigned responsibilities
for actions and schedules are clear.
Employees in the shop may recognize the need for corrective
action and provide good ideas for solving problems. Find ways
to get them involved in the improvement process. It's important
to determine whether a lapse is temporary or due to some flaw in
the procedures or controls. For this reason, communicate any
findings to employees, and provide any follow-up training for
changes in the procedures that may result. The following is a
checklist to help complete corrective action. Have you:
> Identified the problem(s)?
»• Identified the cause(s)?
>• Come up with a solution for each?
> Implemented the solution(s)?
>• Documented the solution(s)?
> Communicated the solution(s)?
> Documented the action(s)?
114
-------
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS
Worksheet 5-3 is a sample Corrective Action Notice that will
assist in documenting the resolution process.
Worksheet 5-3:* Corrective Action
Notice
Issue Date:
Solution Due
Date:
Requested by:
Issued to:
Problem Statement:
Most Likely Causes:
Suggested Solutions:
Action Taken:
Measured Results:
Corrective Action Closed by:
Date:
Contact for Notice:
Date completed:
*Report results on TCA-01 in the Company Manual Template.
115
-------
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
c
As mentioned at the end of Module 3, for every environmental
aspect your company determines to be significant (SEA), it is
desirable that one of two actions be taken. Action may include
either:
>• Evaluating alternatives to make changes in processes in
order to reduce the potential for impact, or
* Writing operational control procedures for activities or
steps in a production process where the potential impact
may be well controlled.
In writing operational controls for an SEA, determine the
environmental objectives desired, set targets for performance
and write operational controls (procedures) to ensure that the
objective will be met. Your company may already have
procedures in place. These should be reviewed to be sure they
are consistent with EMS objectives. This module describes the
process for setting objectives, developing operational controls,
and creating the organizational support for ensuring that those
objectives are met.
If you determine that process changes should take place in order
to address an SEA, the IEMS emphasizes the need to evaluate
alternatives before setting targets. Module 4 describes the
process for evaluating alternatives.
The following are some examples of the kind of activities that
might be improved with operational controls6:
> management/disposal of wastes,
6Adapted from Environmental Management Systems: An Implementation Guide
for Small and Medium-Sized Organizations. See References (Appendix G) for
more information.
Tip
ISO 14000 requires action
to be taken on each SEA.
If you are not pursuing ISO
certification at this time,
you could focus on
selected SEAs.
Tip
Objective: Overall
environmental goal, based
on the environmental
policy, which is quantified
where practicable.
Target: Detailed
performance requirement
based on an environmental
objective.
117
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
>• approvals for using new chemicals,
>• storage & handling of raw materials and chemicals,
> wastewater treatment,
> building and vehicle maintenance,
> transport,
»• operation and maintenance of equipment,
> management of contractors,
>• marketing and advertising, and
>• acquisition or construction of property and facilities.
The process of setting targets and ensuring their success has
several steps which are discussed in more detail below. These
include:
> determining the possible causes of potential impact,
> setting measurements for the desired environmental
performance,
> drafting operational controls,
>• designating persons responsible for maintaining
operational controls and for reviewing the success of the
controls,
>• developing training for persons assigned responsibility,
>• taking corrective action when objectives are not met, and
> establishing a DfE environmental review for new
processes and products.
1. Determine the possible causes of
potential impact
For all of your significant environmental aspects, you should
determine the cause of the impact. In some cases, the cause
might seem obvious. However, sometimes the root cause of the
problem is not the most obvious cause. Use the "root cause"
analysis described in Module 5 to help your EMS team get to the
cause of the impact prior to developing your operational
controls.
U.S.EPA
Experience has
demonstrated the
importance of written
procedures and
thorough employee
preparation and
involvement.
118
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
2. Set targets and measurements for
environmental performance
As discussed in Module 5, you need to set a target for each
objective and establish measurements for environmental
performance indicators. The targets should reflect correction of
the root cause identified above. Measurement indicators should
document changes in the causes identified above. Using the
indicators, you can determine if your operational controls are
helping you meet your objectives.
3. Draft operational controls
Next, for each significant aspect which you have decided to
address with procedures, draft operational controls. (For some
aspects, you may choose to make process changes instead, as
explained in Module 4.) Review each of the causes identified in
your root cause analysis that would contribute to the
environmental impact of a significant aspect. Address the causes
by drafting operational controls.
Operational controls may already exist for some of the activities
associated with a significant aspect. Identify which aspects have
written procedures that describe operational controls, and which
aspects will need to have procedures developed. In some cases
the procedures that you have in place to comply with
environmental and health and safety regulations may be useful to
meet your IEMS objectives. Worksheet 6-1 below will help you
track which aspects will require procedures to be developed.
US'
Tip
DfE Partner Jeff
Adrian of the John
Roberts Company
has provided
operational control
examples. Seethe
Case Study at the
end of this module.
119
-------
r
CO
gl |o
5 o 2, v
.2 o o» Q ^
Q. 0
o s
1
*3 "S "a
•- c o
m *•• 2
s.0"
0
1 §
**
^^
^^
o
S
c
iii!
w
ll
o5 o
> co
0 E
o>
8 g
o3
I
CO
E
8
I"
c
Q)
0
8
g =
.E o>
§:•§!
o co co
0 E E
o
| ..ill fe 1
E c -e >< c"p "S
1 £ o £ 8 i E.
o
o o
r^ O)
0) ^
5 O
1
"o.
O
O
•s
Q
c
£
CD
D.
ct
'c
O
1
S-
1
1
1
I.
1
o
CD
C
o
t
O
O
2
tn
T3
o
Q.
(/)
§
O
9
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
It is important to involve the people who will implement the
procedures in drafting them. You can accomplish this in several
ways: . .
>• Meet with workers and have them describe current
procedures. Discuss the environmental objective desired,
and how to write operational controls (procedures) to
ensure that the objectives will be met.
*• Or, have someone (possibly an intern) interview the
workers to establish current (undocumented) procedures;
then draft (or revise) operational controls. Have the
workers and a manager review the draft.
*• Keep the written operational controls simple and concise.
They should include the appropriate actions, precautions,
and notifications required. Focus on activities that may
lead to significant impacts and avoid getting
overwhelmed by trying to control every activity and
process.
4. Designate responsibility for maintaining
and reviewing controls
Designate those people responsible both for maintaining the
controls and for reviewing them to ensure that procedures are
followed and deviations corrected. Generally, the workers
responsible for the significant aspect under consideration will be
responsible for implementing the operational controls. The
immediate line manager would most likely be responsible for
regular review of the controls. It is helpful to list those people
responsible for each set of procedures. Worksheet 6-2 will help
with documenting responsibilities.
121
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
Worksheet 6-2: Operational Control
Responsibilities
Significant
Aspect
Waste toner
cartridges
Procedures (list)
-save package from new
toner cartridge
-place waste cartridge in
package
-follow supplier
instructions for return of
used toner cartridges
Contact Person:
Responsible for
maintaining
controls
Copier
maintenance
person
Date Completed:
5. Develop training
Achieving success in meeting environmental objectives for each
significant aspect depends upon making sure that each person
responsible for maintaining or reviewing controls has received
adequate training. After operational controls are drafted,
develop a training program that ensures everyone understands
both the controls and their own role in ensuring that they are
followed. Training can include on-the-job training. Worksheet
6-3 identifies some of the decisions to be made when setting up a
training plan. This worksheet helps you identify, plan for, and
track the training needs of your employees. Include this training
with any general environmental training to create an integrated
training plan for your IEMS. See the John Roberts case study at
the end of this module for an example of training materials one
printing facility prepared to support an operational control.
Tip
The training described
here relates to
operational controls.
More information on
training for
environmental
awareness and
regulatory training can
be found in Module 8.
122
-------
W
o
o
o
1
&_
0
8
fe
B
Q.
9
1
i-
«
i
(0
4-1
(D
0
Worksh
— (
§ '« 'c
lie
28-r
4) C
&*-
o
ll
o
o
^
Q
c
X
a
£
c
1
C
J
0.£
I *
*«
1 Si
2 z
H
M O)
o 'w jjv
Q. w ._
0) o
QiM-
w
3
T3
CU
0
S
a.
S
Q.
a5
8f
e i
OS
a>
•— &
CCO "S
+-* ^.
^ Ji C
5 5 .2,2
2
(JJ ^
C c
S 03 CO
e« Q-
CO V
£
0) =
-------
MODULE 6: DEVELOPING OPERATIONAL CONTROLS
6. Take corrective action when objectives
are not met
Take action to correct failures in operational controls as quickly
as possible to meet environmental objectives. Use the process in
Module 5, to take appropriate corrective action when your
operational controls are not helping you meet your objectives.
«* Tip
If the problem cannot be
resolved, review Module
4 to determine a need
for evaluating
alternatives.
124
-------
CASE STUDY FROM THE JOHN ROBERTS COMPANY
Example of an Operational Control For Cleaning Press Blankets
Steps
1. On the first turn of the cylinder, use a solvent saturated shop towel pad (as is the
current practice) to loosen and remove most of the ink from the blanket's surface.
3. With a second shop towel pad that has been first dipped into water and then wrung out,
remove the balance of the ink from the blanket's surface on the second turn of the
cylinder.
3. Start the press as before.
Critical points
By not using water on the first turn of the cylinder, the full strength of the Press Wash is
available to move the ink. So, do not blend down Press Wash with water.
It is not necessary that the blanket be absolutely dry after the second turn of the cylinder.
Rather, a slight film of water (think of how'the sidewall of your car's tires look after just
washing the car) will not be problem on startup of the press. The first few sheets will very
easily carry this moisture off.
By using a second pass with a water wipe, clays, starch and paper dust are better removed. A
water wipe should be easier to slide across the blanket than a drywipe.
Care does need to be taken in just one respect, and that is in the area of the blanket cylinder's j
grippers. Excess Press Wash or moisture there has the potential of being spun off the cylinder |
onto the stock if not removed.
Towel usage
When the solvent shop towel pad is dirty, discard it in the safety cans as before.
The water wipe shop towel pad now becomes the solvent shop towel pad and a new pad (from
clean shop towels) is made up for the water wipe step.
125
-------
CASE STUDY FROM THE JOHN ROBERTS COMPANY
Example of Training for Operational Controls
As part of training, the Director of Environment and Safety distributed additional materials to
all employees involved with press "blanket cleaning. Because this operational procedure
documents a new and standardized method, there were many questions from employees. The
director prepared additional written information, including: 1) a background sheet telling
employees why this procedure was important, and 3) a Q&?A list addressing issues that had
come up in training.
These materials and the associated training were done to ensure that employees knew why the
procedure was needed and what part they were to play in consistently implementing it.
Training for Press/Blanket Washing
New Procedures Background
Background
As some of you may already know, the elimination of Blanket Wash 2316 is necessitated by
the tightening of environmental regulation.
Blanket "Wash 3315 is a blend of solvents that includes the chemical 1,1,1 Trichlorethane
(TCA), a chemical that has been banned internationally by the Montreal Protocol..
The reason for this is that TCA is an upper level ozone depleter, destroying the ozone layer
that shields us from the harmful effects of the sun's ultraviolet radiation.
While still being manufactured today, TOA is being taxed at ever higher rates until it will no
longer be manufactured in 1995.
Additionally, because Blanket Wash 3316 evaporates readily to the atmosphere, the other
chemicals in the blend contribute volatile organic compounds (VOC's), which when combined
with nitrogen oxides Cfrom the burning of fossil fuels) and sunlight, leads to the formation of
smog in the lower levels of our atmosphere.
The replacement for Blanket Wash 3315 will be the use of the much less volatile, and thus less
harmful, Press Wash.
Because Press Wash solvent works at a different rate that the discontinued Blanket Wash
3315, a new cleaning procedure will have to be followed.
This new procedure, though somewhat different than today's method, will work nicely to clean
pressi blankets. ,,,v__^^^mCT^CTm_.
126
-------
CASE STUDY FROM THE JOHN ROBERTS COMPANY
Training for Press/Blanket Washing Questions You May Have
If we can stall buy solvent blends that contain some 1,1,1 Triehlorethane (TCA), why do we
need to make the change now?
Well, there are several reasons. First, there are some health concerns with TOA, so we want to
eliminate any exposure as much as we possibly can. Second, in an effort to discourage the use
of TCA now, the government is increasing taxes on this chemical (and other targeted
chemicals), making the product unduly costly. Third, this is a reportable usage chemical,
which requires that we complete Form R (a complicated procedure) that is also public
information. It is better that we have no reportable chemical usage because if we do, then we
are also brought into the regulatory loop on many other time consuming and costly programs.
Fourth, John Roberts has made a commitment to reduce its total emissions as part of the
Minnesota Toxic Pollution Prevention Plan and we will be accountable for reaching these goals.
Fifth, as a responsible member of the community (in which many of us live as well as work), it
is the right thing to do for the betterment of our.environment.
Will this new procedure slow down my work and reduce my productivity? Will I be penalized
because of this?
Unquestionably, this new procedure will slow things down slightly, but not by much. Even
with the older Blanket Wash, pressmen would often use two turns of the cylinder to complete
the cleanup of the blanket. Understanding that the blanket does not need to be completely dry
will save otherwise wasted time. So the only remaining time element is the need to switch to a
water wipe shop towel pad and the time to take care to wipe the blanket ends, especially the
cylinder gap. Management's commitment to environmental responsibility supports your
efforts.
What if I find I need more shop towels? Won't this new procedure use a lot more shop towels?
If it turns out that you need more shop towels, they are available (we ordered extra last week
and have them in stock). Testing that we have already done has shown that towel rotation
(where the water wipe pad becomes the new solvent wipe pad and clean towels are then used
for the new water wipe pad) works very well.
Can I use a sponge instead of a shop towel pad for the second (water) wipe?
Yes, it's possible to use a sponge instead of a padded shop towel for the water wipe. But if you j
do choose to use a sponge, you will have to use less wiping pressure or you wiH squeeze the
water out of the sponge onto the blanket leaving the blanket too wet. Try it and see if you like
it. You may find a shop towel water wipe easier to control.
Can I mix water with the Press Wash and do it all at one time? Why might this not be a good
procedure?
Yes, again it's possible to do this, but it's not recommended. Here's why. When you add water
to Press Wash, you dilute the Press wash's ability to cut the ink in the first place. This may
mean more work and slower cleaning. Also, Press Wash contains surfactants that make it able
to mix with water, and it is these surfactants that tend to remain on the "clean" blanket that
cause problems with both the ink roller train and the water fountain systems. It's good to
127
-------
remove surfactants as completely as possible, and this is best done with a separate water wipe.
Can I just use a dry stop towel pad to wipe the blanket completely dry instead of a second water
wipe? Would I toe better off?
Well, for the reasons listed above, it's not recommended to use a dry shop towel second wipe.
Aside from the fact that some feel a dry shop towel is harder to move across the blanket (it
tends to drag), how would you clean the blanket of water solubles such as starches, clays and
paper dust? The only reason I can think of to completely dry the blanket would be to ease
your fear of "throwing"solvent drops on the work after startup. This is addressed by taking a
little care on the second (water) wipe, especially at the ends of the blanket in the cylinder gap.
128
-------
MODULE 7: IMPLEMENTING YOUR IEMS
You will ensure the success of your IEMS by developing the
capabilities and support mechanisms to achieve your
environmental policy, objectives, and targets. This module will
cover planning for and setting up environmental management
projects for each objective. In addition, this module covers tools
that will help you keep your IEMS on track: a new product
review process, a regulatory compliance tracking system, a
pollution prevention tracking log, and an Emergency
Preparedness and response plan development process.
Setting Up Environmental Management
Projects
This section will help you set up environmental management
projects developed to achieve each objective and target selected
in previous modules.
The three main elements in developing an environmental
management project are:
*• identifying the person responsible for achieving the
environmental objectives and targets in each relevant
function and level;
*• establishing the means or action plan for achieving targets
and objectives; and
* implementing timetables.
An outline for such a program might include:
129
-------
MODULE 7: IMPLEMENTING YOUR IEMS
> objective,
»• target,
*• person(s) responsible,
f budget,
»• date of expected completion,
>• date of actual completion, and
> performance indicators for measurement.
Let's continue working with the two examples from Module 3:
>• Recycle used toner cartridges.
»• Reduce the environmental impact of chemical wastes
from cleaning a printing press. Remember, the
environmental aspect is the air releases during the press
cleaning process and the water releases at the commercial
laundry where the used press wipes were sent.
Figures 7-a and 7-b show example projects for the above two
sample objectives and targets.
130
-------
MODULE 7: IMPLEMENTING YOUR IEMS
Figure 7-a. Sample Environmental Management Project
Plan
Environmental Management Project Plan
SEA: Waste from Copy Toners
Date
Environmental Objective: Reduce the waste from used copy toner
cartridges
Performance Indicator Measurement: Number of cartridges
purchased vs number mailed and number remaining in stock in
one-year period.
Target: 100% recycling of used toner cartridges in conformance
with manufacturer instructions.
Action Plan: Train persons in charge of replacing toner
cartridges. Create a check list for dates cartridges mailed for
recycling.
Responsibility: Office Manager
Budget: One hour training
Schedule: One month
Review: Monthly by company manager.
Corresponds to OTP-02 of the Company Manual Template.
131
-------
MODULE 7: IMPLEMENTING YOUR IEMS
Figure 7-b. Sample Environmental Management Project
Plan
Environmental Management Project Plan
SEA: Chemical Wastes from Press Cleaning
Date.
invirorunental Objective: Reduce the Environmental Impact of
Chemical Wastes from Press Cleaning
Performance Indicator Measurement: Amount of fluid reused;
reduction in vapors measured at laundry provided by laundry.
Target 1: Reduce air releases of cleaning fluid by 80% in plant
by end of 12-month period
Action Plan 1: Substitute Product B cleaning fluid, train printers
in new product use
Responsibility: Printing Press Manager
Budget: Cost of new fluid
Schedule: Six months
Review: Monthly by company manager.
Action Plan 2: Substitute best work practice, train printers in
best work practice
Responsibility: Printing Press Manager
Budget: Time for training and evaluation of results
Schedule: One year
Review: Monthly by company manager.
Performance Measurement: Amount of Product B substituted for
current product in one-year period and reduction in total product
used over one-year period.
Target 2: Reduce releases to the water at laundry by 40% after
12-month period.
Action Plan: Remove excess fluid from wipes prior to sending to
laundry; reuse recovered fluid
Responsibility: Shop manager
Budget: Cost of centrifuge, time to process wipes
Schedule: 12 months
Review: Monthly by company manager.
m
Corresponds to OTP-02 of the Company Manual Template.
132
-------
MODULE 7: IMPLEMENTING YOUR JEMS
As you can see from Figure 7-b, more than one target can be
used to accomplish an objective, and more than one action plan
to accomplish a target. You need to outline the steps necessary
to achieve each target and make sure that the responsibility for
completion is assigned, the time frame specified, and a budget
given to ensure completion. Appendix H contains a blank
worksheet to assist you in planning your environmental projects.
Review New Products, Processes, and
Activities
Change is an important part of business survival for most
companies. Products, technologies, ways of doing things are
updated regularly. To avoid creating new "significant
environmental aspects" that must be addressed later, it is helpful
to integrate new processes, products, and activities into the
environmental management program that you are developing for
the rest of your company. You can do so by setting up a
procedure for reviewing new processes, products, or activities
while they are in the planning stage. One way to accomplish this
is to create a sign-off form to be circulated among the people
responsible for or affected by the new process or product,
including those responsible for the area of the company where
the new process or activity will be implemented. Worksheet 7-1
is an example of such a sign-off form. The worksheet is a model
that should be modified to reflect your company's activities and
environmental policy.
Resource EH
The results of your
environmental projects
plan can be documented
on OTP-02 in the
Company Manual
Template.
Tip
Conduct an
Environmental Review
when buying a new
product, making a new
product, changing an
existing process,
developing a new
process, or
undertaking new or
changed activities.
133
-------
Worksheet 7-1: Environmental Review of New Processes,
Products and Activities
Area of
Company
New Process,
Product, or
Activity
Manager/Date
Environmental
Review by
Manager/Date
Environmental
Effects
Pollution
Prevention
Opportunities
Contact for form: Date Completed:
134
-------
MODULE 7: IMPLEMENTING YOUR IEMS
Compliance Tracking
If your company does not already have a method in place for
tracking regulatory compliance activities, this IEMS Program
provides the opportunity for developing one. A tracking system
will help you integrate this aspect of environmental control into
your IEMS Program, future planning, and your annual
management review. Worksheet 7-2 provides an illustration.
«• Tip
Investigate the legal
requirements that may be
associated with documenting
your company's compliance
before you design the
worksheet that you will use.
Worksheet 7-2 is an example
of components that are
useful, but regulations differ
by locality. One source to
review would be EPA's Small
Business Compliance Policy.
135
-------
Worksheet 7-2:* Compliance Tracking Log
Person
Responsible
Regulation
Compliance
Check Date
Results and
Root Cause
Corrective
Action/Date
*
Compliance
Verified/ Date
Contact Person: Date Completed:
•Document results on CA-01 in the Company Manual Template.
136
-------
MODULE 7: IMPLEMENTING YOUR JEMS
Root cause analysis and the corrective action notices described
above are useful in examining failures in compliance and
ensuring that corrective action occurs.
Pollution Prevention: Ideas and Tracking
Pollution prevention is another environmental management tool
that is important to integrate with your company's business
activities. Pollution prevention means reducing or eliminating
waste at the source. The focus is more on waste than on
environmental risk. There is a hierarchy of solutions for
pollution prevention:
1. source reduction,
2. reuse/recycle, and
3. treatment.
Before deciding on major changes, an evaluation of alternatives,
as described in Module 4, should be completed. There are,
however, many different ways in which your company could
successfully implement pollution prevention activities, especially
if employees are encouraged to think about how to implement
pollution prevention in their work practices. Some examples
would include reuse and recycle of office paper, turning off
lights/equipment when not in use, and keeping the lid on solvent
containers.
You may develop specific programs that incorporate pollution
prevention, such as the toner cartridges example above, and you
137
-------
MODULE 7: IMPLEMENTING YOUR IEMS
may also want to encourage pollution prevention practices across
the company. Measuring pollution prevention achievements is
different from, and often more difficult than, measuring
environmental achievements in general. Simply measuring the
reduction in a waste stream might mean only that the waste has
been transferred to another medium, not reduced. It is therefore
important to measure the reduction at the source of waste
generation. It may also be important to measure the activities
that your company directs towards pollution prevention. The
following are existing sources of information that your company
may have that would help you track pollution prevention:
> Permit applications
> TRI reports
>• Purchasing records
* Utility bills
> Hazardous waste manifests
>• Material Safety Data Sheets
In addition, administrative procedures can be set in place that
support pollution prevention activities. Below is a checklist to
help you consider opportunities for your company:
» Establish procedures in each company area for identifying
pollution prevention opportunities.
> Have a chemical or raw material inventory system in
place.
138
-------
> Assess how many objectives have been met through
pollution prevention.
Worksheet 7-3 provides a tracking log for pollution prevention in
your company.
Worksheet 7-3: Pollution Prevention Tracking Log
Area of
Company
Pollution
Prevention
Activity
Date Started
Results
Measurement
Method
Person Responsible
Contact: Date Completed:
139
-------
MODULE 7: IMPLEMENTING YOUR IEMS
Emergency Preparedness and Response
It is important to include environmental concerns in your
emergency preparedness and response plans and training. The
following steps will help you integrate plans for reducing the
potential environmental impact of accidents, spills or other
emergency situations.
>• Appoint a person responsible for integrating
environmental concerns. This can be the person already
responsible for Emergency Preparedness and Response or
someone from the IEMS team who will work with that
person.
>• Identify the potential environmental impacts of potential
emergency scenarios.
*• Develop response procedures to minimize these impacts
and integrate them into the emergency preparedness and
response plans.
>• Conduct training for employees affected by these new
procedures.
Worksheet 7-4 will help you identify your needs so that you can
develop a plan.
140
-------
Worksheet 7-4: Environmental Emergency Preparedness and
Response
Potential Emergency
Scenario
Potential
Environmental Impact
Action
Required
Procedures
Needed
Training
Needed
141
-------
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Effective organizational support is important to achieving long
term success for your IEMS. This module will cover training,
documentation, stakeholders and communication.
Training to Get the Job Done
It's very important that people receive the training needed to get
work done in a way that is consistent with your objectives.
Training is needed both in technical work and for general
awareness on the part of all employees. The following are some
examples of areas where training is needed:
* legal requirements,
> ability to recognize new problems,
* technical work needed to solve problems,
»• procedures to implement operational controls,
+ any new procedures or needs related to significant
environmental aspects, and
> awareness of the company's environmental policy and the
IEMS and its objectives
In addition to environmental or worker health and safety training
that your company may currently carry out, you will have
specific training requirements associated with significant
environmental aspect operational controls, as your IEMS
develops. Module 6 addressed the training for that phase of your
Tip
Don't overlook the
need for on-going
training when
experiencing
employee turn-over.
Be sure that new
employees are trained
soon after they arrive.
143
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
IEMS. Training plans developed during completion of that
module should be integrated with the training identified in this
module.
Go through the Action Steps listed below and use Worksheet 8-1
to help you identify, plan for and track the training needed to
assist in developing and putting your IEMS in place. You will
probably be able to identify some general training needs now, but
will need to return to this module to add specific technical
training needs that may be identified as you proceed with the
IEMS.
Action Steps
1. Identify all job functions that affect the environment.
Small companies may wish to identify individuals.
Identify who is responsible for employee health and
safety.
2. Identify the training and type of training these people
currently receive that relates to environmental, including
health and safety, concerns.
3. Determine if IEMS education could be included in this
training or whether there should be special IEMS training,
at least in the beginning.
144
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
4. Identify training materials or programs available outside
your company. Some places to check include:
>• Trade Associations
> Small Business Association
> EPA materials
>• State Department of Environmental Protection
> Suppliers
> Certified Contractors
145
-------
c
Cu
CL
0)
1
H
T-
00
1 •
0>
0
1
1
_0)
•— ^
0 g
5^ 0.
W
0)
0:1
c
.2
'"S «
a. ra
E Q
0
O
at
•a
3
m
O)
c
0)
0)
^s
.E
o
•4-1
O
X
V)
0)
0)
Training N
O) ,„
C c
1 1
1 1
52 '>
•o c
j3 m
t>-
C-
O-
S2
^^
O
8
c
O
'£
E c
h- o
•s I
Eo co
^
.y
o
nvironmental P
01
CO
HI
ro
b' —
Q. 0
E £2
03 CD
CO D.
M
C
•o
£
re
mergency Prep
Response
LJ oS
s
(D
&
Q.
Ol
c
o
'•s
=3
T3
S
Q_
TJ
*J
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Documenting Your Work
When undertaking a new activity like IEMS development,
documenting discussions, plans, targets, and programs is
crucial. Documentation ensures that no information is lost,
and lets you track your performance. Much of this
documentation will become the content for your company's
IEMS Manual. The companion document to this guide, the
Company Manual Template, provides a template for your
own documentation development. Documentation is
important to the success of your IEMS for several reasons:
> Word-of-mouth information is rarely communicated
consistently, whereas written information is more
likely to be constant from person to person and over
time.
» Creating documentation helps you assess the progress
of your IEMS. Some inconsistencies show up only as
you commit your ideas to paper, and having a record
allows you to check on progress and evaluate results.
>• Documentation is vital to maintaining consistency in
an IEMS over time and from department to
department. In most companies, change is a fact of
life: new products are developed, the company grows,
employees change positions or leave the company.
Accurate documentation will make it much easier to
maintain an effective and flexible IEMS during these
changes.
Resource HI
Review the Company
Manual Template for
sample documentation
to help you develop your
own IEMS Manual.
U.S.EPA
Experience has
proven the value of
documenting
meetings, decisions,
and study results,
and of making that
documentation
accessible to those
who need it.
147
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
What is Documentation?
The term "documentation" has many different
interpretations. The term can refer to any or all of the
following:
>• instructions for doing something;
>• records of what was done;
*• policies developed;
>• printed matter that is given or sent to clients,
regulatory agencies, customers, and the public; and
>• any electronic copy of the items above.
How a company interprets "documentation" will depend on
its particular experience. For example, documentation could
include environmental impact statements, process manuals,
or even the local newspaper that reports your company's
activities. Other examples might include environmental
training records and OSHA manuals. All of the work
completed to develop your IEMS also provides
documentation.
How to Develop Your Documentation
The basic steps in preparing IEMS documentation include:
Step 1: Determine how EMS documentation can be integrated
into existing documents.
Before you dive into your documentation, learn how deep
the water is. Find out what documentation already exists,
Tip
Documentation is
usually the single most
overlooked
administrative
procedure in most
companies, but it can
play a vital role in EMS
development.
Determining what you
need from your
documents, both for
future reference and to
teach procedures to
others, will help you
understand the overall
needs that you want
your IEMS process to
meet.
Tip
Remember that you
will not finish most of
the modules in this
Guide the first time
through. You will
probably overlook
items that will be useful
for your IEMS
documentation during
your first search.
Simply add items as
you think of them later
in the process.
Whoever is in charge
of documentation will
therefore need to plan
for later additions.
148
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
what its purpose is, and whether it works. The goal of this
search is to locate materials you can use to begin your EMS
implementation and documentation. Many companies use
the same format for all their documents. An example of
existing documentation might be a quality plan or tracking
reports.
Step 2: Tailor the documentation to your organization's
individual needs.
You will probably have to compromise in producing
documentation that meets your needs while also meeting
your budget. Here are some questions to help you determine
what fits your needs:
> How can you extend those documents that already exist
rather than creating new ones?
* Does your business operate in a single location or many?
This will affect who creates some of the documents and
where they are located. It may also affect how many
versions of a document might be necessary to cover
different circumstances.
*• What is your current computer capability? Many
companies use an electronic system to maintain
documents.
> What security precautions do you need? As a computer
system becomes larger and can be accessed by more
people, electronic information can more likely be edited
149
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
and destroyed. Security, or at least restrictions on who
can change data, can be a critical issue for many
companies.
Step 3: Determine a format for all documents.
Before developing your IEMS documents, plan the format
(document and page appearance) for the documents to be
created. If a company standard exists, use it. If not, the
need for IEMS documentation provides an opportunity to
create a standard company format. Consider whether pages
are single- or double-sided and why; choose margins,
header, footer, typefaces, text, headings, etc. Include plans
for bulleted and numbered lists, tables, and even paragraph
spacing. Once you have a consistent format for documents,
anyone who writes one will use the established electronic
format and fill in the necessary text. All documents will
look like part of an organized, integrated system. Most
important, documents will be it easier to read and
understand!
Step 4: Prototype each document.
Prototyping means visualizing what you will need in the
document and creating an outline for it before you actually
have information to fill in. This practice is useful not only
for document preparation, but for the IEMS process as a
whole. As you visualize what you will need in the
document, you will gain understanding about what you will
need from the process of developing your IEMS. It's a way
150
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
of "outlining" your IEMS process as well as designing
documents.
Who should do the prototyping? The best people to do this
are the people who will use the document. Involving them
in the process gives document users the power to develop
documents they will actually use - effective documents.
The following questions will help your "prototypers" design
documents. Consider these questions for each document
you identify as necessary for your company.
»• What is the document's purpose?
+ Who will use it, and how will they use it?
> How long should the document be?
> What must be included in the document? Which
information is most critical?
> Is it process-focused? Process focus rather than
regulation- or program-focus helps people who use the
documents to better understand how their jobs fit into the
rest of the company functions.
»• How is the information best arranged? Will the user read
sequentially or randomly?
Example: A Tiered Documentation System
The tiered documentation system consists of four "levels" of
documents. The system can be shown as a pyramid with the
environmental management system manual at the top and
151
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
records at the bottom (see Figure 8-a).
Figure 8-a. Documentation Levels
IEMS
System
Manual
Procedures
and References
Operating and Work Instructions
Forms and Records
\
The pyramid shape illustrates a hierarchy in which the
amount of detail, degree of specificity, and number of pages
all increase as you progress from the top to the bottom of the
figure.
Creating an Outline for the Process
It will be helpful at this point to develop some idea of what
your IEMS documentation will look like, and thereby
determine the work needed to fill it in. Doing so will help to
plan the development of your IEMS. Create an outline for
the process of developing your IEMS and your Company
Manual or other form of documentation that suits your
company. What and how much documentation you include
depends upon your company's needs. The following
outlines a sample Company Manual:
152
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
1. Environmental Policy
2. Environmental Action Responsibilities Assignments
3. Environmental Documents and Their Location
4. Identification of Environmental Aspects
5. Identification of Legal Requirements
6. Identification of Significant Environmental Aspects
7. Development of Objectives, Targets, and Action
Plans
8. Conducting an Alternatives Evaluation
9. Development of Operational Controls
10. Environmental Training (Awareness and Task-
Specific)
11. Emergency Preparedness
12. Review of New Products and Processes
13. Documentation and Document Control
14. Communication with External Stakeholders
15. Conducting a Compliance Assessment
16. Conducting an Internal Assessment
17. Taking Corrective Action
18. Management Review
The actual content of your outline will be filled in as you
proceed to develop your IEMS.
Document Control
Documents must be easy to find and kept up to date.
Consider the following points regarding your document
control. Two worksheets follow this section. Worksheet 8-
Resource fUS
Take a look at the
accompanying Company
Manual Template for
sample procedures and
formats to help you
document important
components of your
IEMS.
153
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
2 will help you develop documents and Worksheet 8-3 will
help you manage your documents once they have been
created.
Sound document management ensures that:
>• they can be located;
* they are periodically reviewed, revised as necessary, and
approved for adequacy by authorized personnel;
> the current versions of relevant documents are available
at all locations where operations essential to the effective
functioning of the system are performed;
>• obsolete documents are promptly removed from all
points of issue and points of use, or are otherwise
assured against unintended use; and
*- any obsolete documents retained for legal and/or
knowledge preservation purposes are suitably identified.
154
-------
^m
Q
J^JI
(d
§
o
o
Q
csi
CO
Worksheel
1 s
^ a
o <§ 8
> •? 8
> Z 0
3 c «>
111
< 0 _J
•"£ s> ^ "H
nil
0?
S. o> "co
.ff = Q
w S -~.
WgO
III
o S o
2 jii c"
W j_
1
<3
0>
rvi
orresponds to CS-:
o
in
10
-------
••M
O
•1
o
0
0)
£
8
Q
CO
% *
00
Q)
1
O
^•fc
>
2
0) ^
01 o>
O y
T3 T3
o 5*
zs
c
o
'•s
o
o
—I
'g
0)
c
(0
£:
0)
Q.
Oi
^
5
0
i
a
Docum
£
"S
a.
E
o
O
.2
to
Q
c
1
(D
a.
n
"c
0
O
(O
in
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Working with Stakeholders
Stakeholders are anyone who has a stake in your company's
environmental performance. Stakeholders can play an
important role in helping your company develop an IEMS.
Employees have strong stakeholder interest in your company
and can provide strong support for IEMS development.
Customers, suppliers, and neighbors can provide useful
input. In addition, establishing partnerships with trade
associations, suppliers, professional associations, and
community colleges can be very helpful in developing parts
of your IEMS. This section addresses the kind of
stakeholders you may wish to include in the process and the
potential benefits of including stakeholders. While
involvement of employees is critical to the success of your
IEMS, how far you proceed with including additional
stakeholders is your decision.
Stakeholder Roles
Consider why you would want to include internal and
external stakeholders and what roles they can play. Before
engaging stakeholders, be clear on what you expect their
role to be. What do you want from them? What do you
intend to tell them? Consider the following:
*• Internal stakeholder (e.g., employee) participation can
facilitate implementation of environmental projects as
employees "take ownership" of the IEMS process and
the process changes it may bring;
U-S.EPA"
The DfE Program has
found that including a
variety of stakeholders
in a project provides
proven benefits. DfE
stakeholders include:
industry, government,
labor, environmental
groups, and others.
Their inclusion
ensures both a mix of
viewpoints and a
wealth of different
experience and
training that contribute
to a project. This level
and breadth of
stakeholders may not
be available to a small
company, but opening
your IEMS planning
process to a variety of
stakeholders will
improve results.
157
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
* Different stakeholders bring useful perspectives to
identifying environmental issues, often identifying issues
that might otherwise have been overlooked;
>• Participation by all types of stakeholders can add
credibility, transparency and value to your IEMS;
>• Involving external stakeholders can help them
understand your business operating constraints;
>• Sometimes being an environmental leader can gain
customer recognition and loyalty, and involving
customers in your IEMS helps them recognize your
leadership.
*• Forming partnerships with customers and suppliers can
help to identify shared concerns and ways to cooperate to
resolve them. There may be ways that your company can
help your customers meet their environmental
management needs. Forming partnerships with suppliers
can help your company obtain important information and
may help you meet your IEMS goals.
Identifying Stakeholders
Almost every organization will have a wide array of internal
and external groups that may be interested in and helpful
partners to that organization. These groups will not be
homogenous. Each will have its own priorities and
perspectives, and each will have something different to
contribute in support of your IEMS.
The following list provides types of stakeholders:
«• Tip
Working together with
your customers to
identify common needs
in managing
environmental concerns
can help to build long
term relationships.
158
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Internal Stakeholders
*• Employees
» Shareholders
»• Customers
> Suppliers
*• Investors & Insurers
»• Trading Partners
External Stakeholders
»• Neighbors
*• Community
+ Organizations
* Environmental Groups
* Larger Companies
* The Media
> The Public
* Local Government
You may want to start with those stakeholders who have
expressed interest in your operations. If you wish additional
input, you can contact the following sources in your effort to
locate suitable stakeholders:
> ask your organization's own employees, including
plant/site managers and public relations personnel;
> contact local officials for suggestions;
+ contact a local planning agency for suggestions;
* contact local schools, community colleges, or
Tip
Remember, your
stakeholders'
concerns may be
very different from
what you expect, and
even less difficult to
resolve than you may
think. The only way
to find out is to talk
with them.
159
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
universities; or
> contact a national advocacy group to elicit suggestions as
to which local or national groups may be
interested/suitable.
How to Work With Your Stakeholders
The next stage of the process is to establish dialogue with
stakeholders. You may view this as an opportunity to
further refine your understanding of the various interests of
the groups.
Develop stakeholder participation in stages and learn as you
go. You might think about the different kinds of
stakeholders as forming ever broader circles around your
business (see Figure 8-b). Begin with the innermost circle
and work outward.
Figure 8-b. Levels of stakeholder interest
Neighbors
160
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Communications
When working with either internal or external stakeholders,
including your IEMS team, effective communication will
facilitate a smooth implementation of your IEMS. You will
want to follow these effective rules of communication:
Begin early h the process.
Let people know what you are doing. In most cases, you
will need the cooperation of several people within your
company to gather information and develop an IEMS that
will work. In small and large organizations alike, early
communication will pay off in greater acceptance of the
resulting system.
Set your communication objectives.
Decide what you want to achieve in your communication.
Setting this goal will help you get the right message across
without overwhelming people with too much information,
spending too much time, or missing the mark. It is helpful
to create an IEMS communication policy for your company.
The policy should outline what kinds of information will be
communicated to external stakeholders, and how the
company will document and respond to communications
from external stakeholders. In addition, the policy should
discuss how the company will report environmental health
and safety (EH&S) incidents, such as spills, accidents and
"near misses". The policy should include who reports what,
to whom, and when.
Tip
It's important to revisit
the communication
plan at various stages
of your IEMS
development to add
any additional
communication needs
for each piece of your
IEMS.
Tip
Create and maintain a
list of everyone you
can think of who would
be interested in your
company's
environmental
activities. Include how
you could reach them.
You can then make a
decision about where
to begin. You could
start with staff and
later add other
audiences if that suits
your capabilities and
needs. It is helpful to
make your
communication list as
complete as possible
to start with but pare it
down to start out.
Begin small, and then
you can use the list to
expand when ready.
161
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
Communicate regularly and integrate EMS
communication.
To build support for the IEMS, try to communicate on a
regular basis. Some simple means of regular communication
can usually be accomplished without straining resources -
for example, a bulletin board posting, email messages, or
articles in the organization newsletter. Don't forget to
consider direct wof d-of-mouth communication, particularly
in smaller organizations. Talking directly with key
individuals at intervals may be the best mechanism for
ensuring good communication. Use existing channels of
communication to get the message out on your IEMS
activities.
Consider various methods of communication when
informing stakeholders about your company and what you
are doing, or plan to do, to protect the environment.
Methods may include:
>• discussion in company meetings;
> company website;
>• scheduling tours of your facility;
>• producing a fact sheet about your company's activities,
the EMS program, and why and how your company
would like to include stakeholders;
> establishing a phone line to answer questions, record
concerns, etc.;
>• going to local schools, community colleges, universities,
162
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
or civic organizations, such as the Rotary, that may
provide a focal point of interest about your company; and
»• holding public meetings when you feel it is appropriate.
Bisure that stakeholder dialogue is a two-way process.
The stakeholders will want to know that their comments and
concerns are being listened to and taken into account. You
need to convey that your organization is genuinely and
actively including them.
Worksheet 8-4 will help you develop criteria.
163
-------
lolders
0)
"m
to
£
•*j
D)
.C
if
o
^S
^"•*
*.
i
00
•5
Q)
1
O
5
C 5?
o J2
52 §
0) Q.
Q. (/)
a>
1
0) g
How to
communica
with/tell the
^
II
i * §
* §
1 ~
1 -
>• —
c
UJ
S2
0>
T3
O
i
a
*rf
CO
I_
o
>-
tn -
Memo, bulletin
board, meeting
suggestion box
intranet
^
*
O)
3
1 =
!•§
"co
"S
CD
It
= 15
UJ Q.
to
CD
CD
"o.
UJ
"5.
CO
&
CD
.E CD" v 'ft 9 CD t eg
•SJwra^ i? s 2 =
a i S1 f ft ! £ !i
2fco> > c 2 > e
•C C O -C C O
I- CD 0 h- CD 0
CO _ CO
CO iS CO *2
•ti UJ "ti LLI
C III C. _
ll El
C CO C CO
2. o .^
._ j5* w .— G* w
c 's JS = "5 S
lil Q. Q. UJ Q. Q.
CO
o
J2
O)
'CD
-5? g
c E
E o
^ *C/)
fi o
T3
1
Q.
E
o
O
CD
to
Q
c
o
S2
CD
Q_
ts
C
0
O
CO
4B
f
1
CO
o
o
CO
CD
•c
O
Q.
CD
Cf.
-------
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT
To complete this worksheet, think about ways to use your
current means of communication to begin your dialogue.
Consider which methods will work to convey your message
to each group, and which will work to obtain the
information you want to get from each group. The means
that you choose may be different for each stakeholder group.
In addition to communicating with your stakeholders, it is
important to track their communication to your company and
the response made to that communication. A procedure for
documenting and responding to stakeholder communication
should be established and a person appointed to be
responsible for carrying it out. Worksheet 8-5 will assist
you in setting up and documenting each communication.
The following Case Study shows how "Company B" set up
a process to train and then use its internal stakeholders to
identify environmental concerns and some of the benefits
achieved.
«• Tip
Make use of current
technology. A
company website can
be used to
communicate your
company's
environmental policy
and other important
elements of your
IEMS. It can also be
used to solicit
comments and
suggestions from
stakeholders.
165
-------
Worksheet 8-5: Stakeholder Communication Record
Date Communication Received:
Type of Communication:
Received From:
Address/Telephone Number/E-Mail:
Content of Communication
(attach copy if possible):
Will ABC Company Respond?
Date of Response:
Person Responding:
Nature of Response
(attach copy if possible):
Are Internal Actions Necessary?
(If Yes, fill out a Corrective Action
Form.)
Contact Person:
Y N
Y N
Date Completed:
Corresponds to CS-02 of the Company Manual Template.
166
-------
Case Study: Company B — Working With Stakeholders
Company B is a 30-person company that manufactures sangria and chile salsa. With
strong senior management backing and support from a local consultant, Company B
focused initially on building environmental consciousness among its employees. To all
of its workers and managers the company offered general environmental awareness
training as well as more specific training on how to identify specific environmental
issues. Employees then split into 10 teams, each charged with identifying the
environmental issues associated with a specific area of operation, from the acquisition
of raw materials through to product delivery. Based on the work of these teams,
Company B developed a list of its most important environmental issues and concrete
objectives and plans for improvement.
The key to Company B's success lay in using participatory teams to define new
environmental problems and develop solutions. For example, .the company identified
waste of raw materials as an environmental issue, and teams from several areas found
ways of reducing waste. Company B now requires its suppliers to use stronger
containers to avoid materials spoilage. More significantly, the team from the mixing
area realized that by using a spray nozzle to clean out left-over orange juice
concentrate Ca key ingredient in sangria) from large supply containers, it can recover
an additional 3,000 pounds of concentrate (6% of its total consumption, valued at
$4,SOO) per year. Company B gained an even greater economic benefit by revising its
process for cleaning and sanitizing its stainless steel tanks, reducing use of an iodine-
based cleaning fluid by 11,000 liters per year, or 90%, at an estimated yearly savings
of $7,000.
Other benefits the company has realized include improved compliance, a safer work
environment, and reduced emissions from its transport vehicles thanks to improved
maintenance. The environmental awareness of all employees has increased
significantly, with some workers extending their new-found environmental
consciousness to their homes. The company has also publicized its participation in-the
EMS project to the local community in an effort to improve its community relations and
to help improve the environmental awareness of the community.
167
-------
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Now it's time to step back and look at the total picture. Your
IEMS constitutes an overarching "Environmental Management
Program" made up all of the elements we have covered above
and a few additional elements that we will cover in this module.
The framework of your IEMS Program at this point includes:
>• Company Environmental Policy
» Environmental Aspects Review Process
»• Objectives, Targets and Environmental Management
Programs
*• Measuring Environment Performance and Taking Corrective
Action
*• Operational Controls
>• Documentation Plan
* Stakeholder Strategy
*• Communication Plan
The final steps in developing your EMS include:
*• detennining program measurement criteria,
*• setting up an internal assessment process, and
*• establishing a management review process.
'U.S.EPA"
Principles emphasize the
importance of continuing
improvement.
Environmental '
improvement requires
work in steps. It will not
be achieved overnight,
but must be viewed as a
long-term, evolving
process.
Resource HI
Review the Company
Manual Template for
sample procedures and
formats to help you
document important
components of your IEMS.
169
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Step 1: Determine program measurement
criteria
Determining measurement criteria, also called environmental
performance indicators, will help you evaluate the success of
your overall DBMS program. The purpose of these indicators is
different from the specific measurement criteria you developed
for evaluating progress toward individual objectives. These
performance indicators focus on how well the overall system for
improving environmental management is functioning. Select
performance indicators that will help you and your employees
decide whether success has been achieved or whether
improvement in procedures needs to be made. It is easier for
management and staff to understand how things are going if
they have benchmarks as guidelines.
You will need performance indicators that describe how well
your environmental policy is being implemented. In addition,
you will need performance indicators for all of the various
components of your DBMS. The measurement criteria selected
for each component of your IEMS will probably be different.
For example, how will you measure the success of
communication, documentation, stakeholder outreach, or
training programs?
One approach is to measure the activities, for example, number
of meetings held with stakeholders, number of documents
created, number of employees trained, or number of hours of
training. Activity, however, does not always mean results.
170
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Consider the objective of each IEMS component and define a
way to measure results so that you would feel satisfied that the
objectives are achieved. To measure results effectively, your
methods should be:
+ simple
> flexible
> consistent
*• ongoing
>• usable (i.e., results communicated)
+ accurate (i.e., reliable data produced)
Worksheet 9-1 will help you organize your thoughts.
171
-------
Worksheet 9-1: IEMS Program Measurement Criteria
Company Name —
— -~^^ Measurement
""""•^--^^^ Elements
IEMS Components ^"""---^^
Environmental Policy
Communication Plan
Stakeholders Input
Environmental or IEMS Training
Review of Aspects
Operational Controls
Environmental Review of New
Processes and Activities
Setting Objectives & Targets
Environmental Management
Project 1
Environmental Management
Project 2
Documentation
Regulatory Compliance
Pollution Prevention
Other
Objectives of
Component
Activity
Measures
Results
ndicators
Review
Period
Contact person for form: Date Completed:
172
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Here are some examples of IEMS results measurements for
various program components that can be tracked over time:
*• number of significant environmental aspects included in
environmental projects plan
*• number of environmental objectives and targets met
»• pounds of hazardous waste generated per unit of production
> employee sick leave absences related to work environment
* percentage of employees completing environmental training
>• average time for resolving corrective action
> energy or water use per unit of production
>• percentage of solid waste recycled/reused
+ number of complaints from community; number of
responses to complaints
>• number of pollution prevention ideas generated from
employees
>• resources used per unit of product or service
*• pollution (by type) generated per unit of product or service
*• per cent of products for which life cycle assessment has been
conducted
> number of products which have a recycling program
* number of instances of non-compliance
It is the results shown by these environmental performance
indicators that will become the basis for your plans for next year
and for establishing continuous improvement.
173
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Step 2: Set up an internal assessment
process
To make sure that your IEMS is achieving the general goals
outlined in your Environmental Policy, you will need to
establish procedures for an assessment process and assign
people to be responsible for accomplishing the assessments on a
regular basis. In general, assessments are conducted through.
interviews, examination of documents, observation of activities,
and review of results of measurements. Assessments should be
conducted regularly, for example, on every quarter. The
purpose of the assessment is to develop information for
management review and to take corrective action where needed.
The assessment procedures should describe:
>• the activities and areas to be considered in assessments,
»• the frequency of assessment,
>• the responsibilities associated with managing and
conducting assessments,
> the communication of assessment findings,
> assessor competence, and
> how assessments will be conducted.
Assessments may be performed by personnel from within the
organization or by external persons selected by the organization.
In either case, the persons conducting the assessment should be
in a position to do so impartially and objectively. Use
Worksheet 9-1 along with Worksheet 9-2 and 9-3 to help you
set up your assessment process. The Worksheet 9-2 specifies
174
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
some of the factors that will be examined during the assessment
and Worksheet 9-3 will help you track correction of non-
conformities.
These forms alone will not be enough to conduct assessments.
First, the categories should match what is appropriate for your
company. Second, each category will probably require
subheadings to fully describe what you need to check about
each category to be assessed. These worksheets are more of a
summary log with suggestions about what you might want to
include. Although every part of your IEMS program should be
assessed regularly, all parts need not be assessed at the same
time, nor on the same schedule. Make this IEMS work to help
you ensure that your IEMS program is doing what you want it
to do.
175
-------
Worksheet 9-2: Internal Assessment Checklist
Internal Assessment Team:
Date of Internal Assessment:
Signed:
IEMS Procedures:
Check each item assessed, including auditing of records, where applicable (codes in parentheses refer
to the Worksheet number ("WS") in this Guide, followed by the document number in the Company
Manual Template):
Environmental policy (Module 2)
Environmental objectives (progress; implementation of action plans)
IEMS responsibilities (WS 7-2, RESP-01)
Identification of Environmental Aspects (WS 1-5, P-EA)
Identification of Legal Requirements (WS 1-6, P-LR)
Identification of Significant Environmental Aspects (WS 3-3, WS 3-6, P-SEA)
Development of Objectives, Targets, and Action Plans (WS 5-1, P-OTP)
Conducting an Alternatives Evaluation (WS 4-1 to 4-6, P-AE)
Development of Operational Controls (WS 6-1 to 6-3, P-OC)
Environmental Training (Awareness and Task-Specific) (WS 8-1, P-ET)
Emergency Preparedness (WS 7-5, P-EP)
Review of New Products and Processes (WS 7-3, P-NPP)
_ Documentation (WS 8-2, WS 8-3, P-D)
Conducting a Compliance Assessment (WS 5-4, P-CA)
Conducting an Internal Assessment (WS 9-2, WS 9-3, P-IA)
Taking Corrective Action (WS 5-3, P-TCA)
Management Review (WS 9-4, P-MR)
IEMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person:
Date Completed:
Corresponds to LA-01 of the Company Manual Template.
176
-------
Worksheet 9-3: internal Assessment Record
Internal Assessment Team:
Date of Internal Assessment:
Signed:
Major Non-Conformities Observed
1.
2.
Minor Non-Conformities Observed
1.
2.
3.
Is ABC Company making progress in meeting its IEMS objectives?
Is ABC Company adhering to the commitments in its environmental policy?
Suggestions for Improving IEMS:
Contact Person:
Date Completed:
Corresponds to IA-02 of the Company Manual Template.
177
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Review your company's environmental aspects and
objectives
As part of your internal assessment, it is critical that you
regularly review your company's environmental aspects and
objectives. Over time, you will probably add to the list of
environmental aspects and you may need to re-rank the aspects
as your activities change and as new information becomes
available. Here are some things to check:
>• New process review — have any changes introduced new
environmental aspects?
>• Worksheets from the most recent environmental aspect
identification and ranking exercises — is there new
information on chemical effects? If so, update your
worksheets.
>• Communication received from stakeholders — do any
comments suggest a need for re-ranking your aspects?
>• Environmental objectives and targets — what new ones will
your company set for this time period?
> Pollution prevention program — has information become
available from this effort that would add aspects or
objectives?
>• Assessment program — have your assessments turned up
information on where your IEMS and environmental
programs could be improved? Would this information be
useful in your aspect identification process or in redesigning
your objectives?
Tip
Regularly revisiting your
environmental aspects
and objectives is an
essential step in
developing an EMS that
achieves the goal of
continuous environmental
improvements.
178
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
The regular review of aspects can be used to change the
priorities you set last time., or it can be used to examine a part of
your company's activities that you set aside last time. The
regular review can be part of a planned "phasing in" process,
wherein different parts of your company's operations are
reviewed until all your company's activities are included in your
IEMS. The regular review of aspects is the foundation for your
company's continuing improvement.
Step 3: Establish a senior management
review process
To maintain continual improvement., suitability, and
effectiveness of your environmental management system, and
thereby its performance, your organization's senior management
should review and evaluate the environmental management
system at defined intervals, such as quarterly. The scope of the
review should be comprehensive, though not all elements of an
environmental management system need to be reviewed at once,
and the review process may take place over a period of time.
The worksheets in Steps 1 and 2 provide information for the
management review. Review of the policy, objectives, and
procedures should be carried out by the level of management
that defined them. Following is a checklist of some of the
things that should be included in the management review:
* results from assessment,
> the extent to which objectives and targets have been met,
179
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
>- the continuing suitability of the environmental management
system in relation to changing conditions and information,
and
>• concerns amongst relevant interested parties.
Questions for management to consider include:
>• Is our environmental policy still relevant to what we do?
>- Are roles and responsibilities clear and do they make sense?
>• Are we applying resources appropriately?
*• Are we meeting our regulatory obligations?
» Are the procedures clear and adequate? Do we need others?
Should we eliminate some?
* What effects have changes in materials, products, or services
had on our IEMS and its effectiveness?
>• How effective are our measurement and assessment
systems?
>• Can we set new measurable performance objectives?
> What effects have changes in materials, products, or services
had on our IEMS and its effectiveness?
>• Do changes in laws or regulations require us to change some
of our approaches?
>• What stakeholder concerns have been raised since our last
review?
>- Is there a better way? What else can we do to improve?
Create a continual improvement plan and check progress.
Document observations, conclusions, and recommendations for
180
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
necessary action. Assign action items for follow-up, and
schedule the next regular review. Worksheet 9-4 will provide a
place to record management review information.
181
-------
Worksheet 9-4: Management Review Record
Date of review meeting:
Persons present at meeting:
Conclusions:
Actions to be taken/Person(s) responsible:
Signed:.
Management Representative
Plant Manager
Worksheet 9-4 corresponds to MR-01 in the Company Manual Template.
182
-------
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT
Congratulations!
This completes your IEMS. Hopefully, the management
system accompanied by the annual process of review and
renewed objectives will bring its own rewards in greater
productivity, reduced costs and healthier environments!
183
-------
-------
APPEWDfCES
alternatives evaluation - A systematic evaluation of alternative ways to accomplish a
task that reviews the cost, performance, and environmental impact of each alternative
under consideration. Ideally, the range of evaluation would include alternative chemicals,
products, processes, technology, work procedures, and disposal methods.
ancillary material - Material input that is used by the unit process producing the product,
but is not used directly in the formation of the product.
aspect, environmental - Element of an organization's activities, products, and services
that can interact with the environment.
assessment - An estimate or determination of the significance, importance, or value of
something.
certification - Procedure by which a third party gives written assurance that a product,
process, or service conforms to specified requirements.
compliance - An affirmative indication or judgment that the supplier of a product or
service has met the requirements of the relevant specifications, contract, or regulation;
also the state of meeting the requirements.
continual improvement - Process of enhancing the environmental management system
to achieve improvements in overall environmental performance, in line with the
organization's environmental policy. Note - The process need not take place in all areas
of activity simultaneously.
corrective action - An action taken to eliminate the causes of an existing nonconformity,
defect, or other undesirable situation in order to prevent recurrence.
effects - Refers to changes, actual or potential, caused by a chemical, activity, or process
as it comes into contact with humans or the environment.
environment - Surroundings in which an organization operates, including air, water,
land, natural resources, flora, fauna, humans, and their interrelation.
Appendices, page 1
-------
APPENDICES
environmental assessment - A systematic, documented, periodic and objective review by
company management of facility operations and practices related to meeting
environmental requirements. The assessment is a systematic, documented verification
process of objectively obtaining and evaluating evidence to determine whether specified
environmental activities, events, conditions, management systems, or information about
these matters conform with selected criteria, and communicating the results of this
process to management.
environmental management system (EMS) - Organizational structure, responsibilities,
practices, procedures, processes, and resources for developing, implementing, achieving,
reviewing, and maintaining the environmental policy.
environmental objective - Overall environmental goal, arising from the environmental
policy, that an organization sets itself to achieve, and that is quantified where practicable.
environmental performance - The measurable results of the environmental management
system, related to an organization's control of its envkonmental aspects, based on its
environmental policy, objectives, and targets.
environmental performance evaluation - Process to measure, analyze, assess, report,
and communicate an organization's environmental performance against criteria set by
management.
environmental performance indicator - A specific datum selected, such as volume of a
chemical used, which will provide measurable information regarding progress toward
meeting a specific environmental goal.
*
environmental policy - Statement by the organization of its intentions and principles in
relation to its overall envkonmental performance, which provides a framework for action
and for the setting of its environmental objectives and targets.
environmental target - Detailed performance requirement, quantified wherever
practicable, applicable to the organization or parts thereof, that arises from the
envkonmental objectives and that needs to be set and met in order to achieve those
objectives.
Appendices, page 2
-------
APPENDICES
function - Performance characteristic.
hazard - The ability to cause damage.
impact, environmental - Any change to the environment, whether adverse or beneficial,
wholly or partially resulting from an organization's activities, products, or services.
inputs and outputs - Material or energy that crosses a unit process boundary. Example
— Materials may include raw materials, products, emissions, and waste.
interested party - Individual or group concerned with or affected by the environmental
performance of an organization.
life cycle - Consecutive and inter-linked stages of a product system, from raw material
acquisition or generation of natural resources to the final disposal.
life-cycle assessment (LCA) - Compilation and evaluation, according to a systematic set
of procedures, of the inputs and outputs of materials and energy and the potential
environmental impacts of a product system throughout its life cycle.
life-cycle characterization - Element of the life-cycle impact assessment phase in which
the potential impacts associated with the inventory data in each of the selected categories
are analyzed.
media - The means or substance through which something is transmitted, e.g., air, water,
or soil.
objective, environmental - Overall environmental goal, arising from the environmental
policy, that an organization sets itself to achieve, and that is quantified where practicable.
pollution prevention - Pollution prevention means reducing pollution or waste at the
beginning of a process. The underlying theory to this approach is that if you don't
generate waste in the first place, there is nothing to treat or dispose of.
prevention of pollution - Use of processes, practices, materials, or products that avoid,
reduce, or control pollution, which may include recycling, treatment, process changes,
control mechanisms, efficient use of resources, and materials substitutions.
Appendices, page 3
-------
APPENDICES
procedure - A specified way to perform an activity.
process - A set of interrelated resources and activities that transform inputs into outputs.
product - Any good or service.
risk - This is the probability that something undesirable will happen from exposure to a
hazard.
risk assessment - Risk assessment is the process of gathering data and making
assumptions to estimate short- and long-term harmful effects on human health or the
environment from exposure to hazards associated with the use of a particular product or
technology.
root cause - A fundamental deficiency that results in a nonconformance and must be
corrected to prevent recurrence of the same or similar nonconformance.
stakeholders - Those groups and organizations having an interest or stake in a company's
EMS program (e.g., regulators, shareholders, customers, suppliers, special interest groups,
residents, competitors, investors, bankers, media, lawyers, insurance companies, trade
groups, unions, ecosystems, cultural heritage, and geology).
substitutes - A chemical, product, process, or technology, which may be substituted for
another to perform the same function or achieve the same end result.
target, environmental - Detailed performance requirement, quantified wherever
practicable, applicable to the organization or parts thereof, that arises from the
environmental objectives and that needs to be set and met in order to achieve those
objectives.
volatile - Ability to evaporate easily.
waste - Any output from the product system that is disposed of.
Appendices, page 4
-------
APPENDICES
(From Solutions for Lithographic Printers, Question 8.)
This appendix contains questions focused on getting information on chemical hazards of
products used in press wash. Modify the questions to suit the chemical products that your
company uses. The entire document can be found on the DfE website under industry
projects.
What questions should I ask my blanket wash supplier?
Your supplier can be a valuable source of information for evaluating both the wash you
use now and any substitute wash. Ask your supplier the questions listed below to gain
important health and environmental information about the blanket wash you are currently
using or a substitute blanket wash you may consider testing.
1. What chemicals are in the blanket wash?
> Send me a copy of the MSDS.
*• What chemicals are in this wash that are not listed on the MSDS?
2. Which regulations might be triggered when using this product?
>• Are there 'any HAPs (Hazardous Air Pollutants under the Clean Air Act) in this
wash?
* How do you suggest I comply with the applicable regulations?
What is the volatile organic compound (VOC) content and
vapor pressure of the wash?
Tip
The lower the VOC
content, the better.
The lower the vapor
pressure, the better.
What health risks are associated with the use of the
blanket wash?
>• What types of short-term symptoms, such as dizziness,
headache or nausea, might I experience by using these products on a daily basis?
>• Does this product contain any chemicals with adverse long-term health effects?
* When using this product on a daily basis, what type of ventilation do I need?
Appendices, page 5
-------
APPENDICES
5. Do I need to be concerned if workers get this wash on their hands or skin?
6. What are the best ways to use the wash to minimize both the health risk and
waste generated?
7. Do I need to change the way I currently use blanket wash to make this product
work best?
8. What is the proper method for disposing of the used blanket wash and wipers?
>• Will my used wipers or used blanket wash be considered hazardous waste under
RCRA?
> Once the wash is mixed with other chemicals, such as inks or fountain solutions,
what is the proper disposal method?
9. Do I need to take any special precautions when laundering used wipers?
10. Do any of the chemicals in this product present a risk to aquatic species?
Appendices, page 6
-------
APPENDICES
This appendix contains two worksheets designed for evaluating the
performance of ink remover and emulsion and haze remover for
screenprinting. These worksheets can be adapted for other performance
evaluations. These worksheets also can be found on the DfE website,
as Appendices I and J in the Cleaner Technology Substitutes
Assessment for the DfE Screenprinting Project.
Appendices, page 7
-------
INK REMOVER EVALUATION SHEET
Evaluation #
Facility name and location:
Date:
Time:
Ink Remover employee's name:
Screen identification and history
Screen size
Screen condition and threads per
inch
Mesh
(Record mesh material type and type
of mesh treatment, (e.g., abraded,
calendared, etc.) if any)
Number of impressions of the
screen's last run
Ink type
Ink color
Fill in the blank or circle the appropriate characteristic. Make any
notes or comments in the space to the right.
Screen Condition
• Enter the identification marking (tracking) code for the screen:
•Estimate how much ink -was left on the screen?
inches x inches
• Note screen condition including any rips, holes, corrosion:
• Record the screen mesh size: threads/inch
• Mesh type:
• Mesh treatment:
• Circle one:
Solvent-based, UV, Water-based
• Specify manufacturer and series #:
• Circle one:
Blue, Black, Other (specify):
Appendices, page 8
-------
ESK REMOVER EVALUATION SHEET
Evaluation #
Emulsion type
% Ink Coverage
Drying Time
Ink Remover Dilution
Quantity of Ink Remover Used
Time (enter time from application of
ink remover until screen is ready for
the next step)
Physical effort required
(circle rating and comment)
How many wipes did you use?
Was a pressure washer used?
Examine screen after ink removal.
• Circle one:
Capillary film, Direct photo, Dual cure, Other
(specify):
• Specify manufacturer and series #:
• Check one:
0 - 25%...D. 25 - 50%.,.D 50 - 75%.,.D ' 75 - 100%.. .D
Time between end of press run and start of ink removal with product
(hours or mins.; specify units)
Performance
(enter ratio) or "none"
oz.
Note: Do not include screen positioning or clean up time.
mins.
Low, Moderate, High
(check one) Yes No
Did the ink remover effectively and easily remove the ink? (Also note
any side effects of the product on the screen)
Comments or suggestions - Record any comments and note anything unusual about the reclamation on a
separate sheet of paper, (e.g., did you have to reapply the product? why was the screen hard to clean?)
Appendices, page 9
-------
INK REMOVER EVALUATION SHEET
Evaluation #
Facility name and location:
Date:
Time:
Screen Reclamation employee's name:
Fill in the blank or circle the appropriate characteristic. Make any notes or
comments in the space to the right,
Screen Tracking
Screen identification
• Enter the identification marking (tracking) code for the screen:
Performance
Drying Time
(Specify units; hours or
mins.)
Time from ink removal completed to start of emulsion removal:
1 Time from emulsion removal completed to start of haze removal:
Dilution
Emulsion Remover
• Haze Remover
(ratio) or none
(ratio) or none
Quantity of Product Used
Enter # of ounces used:
• Emulsion Remover
Enter # of ounces used:
• Haze Remover
ounces
ounces
Product Use Time (enter
time from application of
product until screen is ready
for the next step)
1 Emulsion Remover
Haze Remover
nuns.
nuns.
Appendices, page 10
-------
APPENDICES
Was a pressure washer
used?
For emulsion removal? (check one) Yes
No
For haze removal? (check one) Yes
No
Physical effort required
(circle one for each step and
describe the level of effort)
• Emulsion Remover:
circle one: Low, Med., High; Describe if the stencil dissolved easily or
slowly, and if a great deal or very little scrubbing took place:
• Haze Remover:
circle one: Low, Med., High; Describe the effort required for haze
removal:
Examine screen after
emulsion removal.
1 Is there any ink haze or stencil stain on the mesh? If so, describe:
• If any emulsion is still present, describe the residue left on the screen in
detail:
Examine screen after
reclamation is complete.
No
• Can the screen be reused for all jobs? check one: Yes
If "No", describe why the screen cannot be reused: (e.g., Is there is a
ghost image? Can the screen be used for reverse printing? Can it be used
for close tolerance -work? Can transparent inks be used with it?)
Examine the substrate
image after the screen is
reused. Comment on the
print image quality.
Comments - Record any comments and note anything unusual about the reclamation on a separate sheet.
(e.g., did you have to reapply the product? why was this screen more difficult to clean?)
Appendices, page 11
-------
APPENDICES
This study presents a worksheet that can be adapted to evaluate sets of alternatives.
From "A Worksheet to Help You Choose a Better Wash," Case Study #4 from the DfE
Lithographic Printing Project.
Appendices, page 12
-------
APPENDICES
LITHOGRAPHY PROJECT BULLETIN 4
A Cooperative Project
between the
U.S. Environmental
Protection Agency
and the
Printing Trade
Associations
Nationwide
October 1996
U.S.EPA
-«»..*«*.
This Bulletin highlights
How to Find a Better
Blanket Wash for
Your Company
•The Blanket Wash Comparison
•A Description of Nine Different
TilTT/ll)ir'SHUt-t-ET'N)
•Questions to Ask When You Call
•What You Can Do to Compare
Blanket Washes: A Checklist
Other Chemicals for Your Shop
A Worksheet to Help YOU
choose a Better Wash
There are many factors to consider when choosing a blanket wash or other press chemical
that is best for your shop. Perhaps the most obvious are purchase price and performance.
But there are other, less obvious factors that are just as important. How flammable is the wash?
Is it a regulated material? How hazardpus is it to worker health or to the environment? Even
if it is cheaper to buy, a wash that is more hazardous, or one that is regulated, may have large
hidden costs that make it more expensive in the end.
The worksheet contained in this bulletin identifies many of these costs, both obvious and not
so obvious. Use it to compare your blanket wash options - it may help you find a blanket wash
that is better for your shop.
The Worksheet How Does it Work?
The worksheet can help you compare test blanket washes to your normal wash. Complete
the worksheet after you (or your press operators) know how well the test wash works
(this may take a week or two of use): When you answer the questions and add up the
scores, the worksheet will tell you if the test wash may be a better choice for your shop.
AH information needed for the worksheet is available from:
• the press operators in your shop who have been using the test wash
• the Material Safety Data Sheet (MSDS) that comes with the blanket wash
• your blanket wash supplier
v ?jjjjjirf final Worksheet Score Is...
jj-.sKJ^fVGreaJeritrian zero
t ^X\. t& $ "^^ ^ * V
"V? M«< ,'<-•> y""f. * T~
{•v SST Less than zero
(»»••**«&
Equal to zero*
Then...
•> -& * j.
f=& "Jhe test wash maY be a better choice than
* your normal blanket wash "\ f **
=^ The test wasfi may not be a better choice
ifor your facility than your normal blanket wash
f
=r> The test wash Is approximately the
same as your normal wash
*Tf the test wash appears\o be approximately the same as your normal wash overall,- fook at each
Jpdiyidua! ^category Which is most important to you? Different scores in that category fpay still
, ^ fiel|3> you decide which blanket wash fs best for your shop \
•<*} Jt r.~ - S r ' W * , *.* f
Appendices, page 13
-------
APPENDICES
Could a substitute blanket wash be a better choice for your facility?
Use the scorecard below to figure out whether a substitute blanket wash may be a better choice for your facility.
Add the scores to see if the substitute wash is better, worse, or the same as your current wash.
Test Wash:
Supplier Name and Phone:
Compare the test wash to the blanket wash you normally use for the following questions and enter the score of your
answer in the column on the right:
Compared to your normal blanket wash.
-2
Scores
-1 0 1
Enter
Score
Below
Much more More Same Less Much less
Is the amount of test wash used to clean each blanket:
U What does the press operator think of the test blanket wash? Is it Much worse Worse Same Better Much better
Consult MSDS forms and contact the blanket wash supplier to answer questions 5-9:
Compared to your normal blanket wash.
-2
Scores
-1 0 1
Is ths vapor pressure of the test wash: Much higher Higher Same Lower Much Lower
Is tho flash point of the test wash: Much lower Lower Same Higher Much higher
Add all nine scores on this worksheet to get the total score for this test blanket wash. Total [
Remember, when adding negative numbers -2 + 2 = 0.
What does the score mean?
A score greater than zero means the test wash may be a better choice than your facility's regular wash,
a score of zero indicates that the test wash is approximately the same, and a score of less than zero
indicates that the test wash may not be a better choice for your facility.
Design for the Environments
Appendices, page 14
-------
APPENDICES
Worksheet Quest ions
What Do They Mean?
Purchase price: Compared to your normal blanket wash, Is the price per gallon of the
test blanket wash much more, more, the same, less, or much less?
The most obvious difference between two blanket washes is the cost to buy them. Compare
the cost per gallon of your normal wash to the test wash. Answer "much more"
if the test wash costs twice as much as your normal wash or "much less" if it is half the
price or less. Factor in dilution ratios for those washes that are shipped as concentrates.
Amount used per cleaning: Compared to your normal blanket wash. Is the amount
of test wash used to clean each blanket much more, more, the same, less, or much less?
The more wash you use each time you clean a blanket, the more it costs you. Ask press
operators how much of the test wash is needed to clean the blanket compared to the amount
of normal wash. Answer "much more" if it takes twice as much test wash or "much less" if it
takes less than half as much to clean the blanket.
Time to clean a blanket: Compared to your normal blanket wash, Is the time
required to clean a blanket with the test wash much more, more, the same, less, or
much less?
Press downtime costs money. If the test wash takes twice as long .to clean the blanket, answer
"much more". Answer "much less" if the test wash takes only half as long as your normal wash.
Press operator opinion: Compared to your normal blanket wash. What does the press
operator think of the test wash? Is it much worse, worse, the same, better, or much better?
Ask press operators to compare the test wash to the normal wash on odor/blanket swell, the
time required for the press to come back to color, the effort required to use the washes, and
any other factors they think are important. Combine these into an overall score for this ques-
tion.
Hazardous chemicals: Does the test wash contain hazardous chemicals as defined by
environmental laws or the Occupational Safety and Health Act (OSHA)?
Contact the supplier or manufecturer for this information. A variety of environmental regula-
tions apply to hazardous materials because of their potential dangers to people and the envi-
ronment. Violations may result in large fines. At the very least, using a regulated hazardous
chemical may increase compliance costs. Ask your blanket wash supplier if the blanket wash,
or its waste, is'considered hazardous under any environmental law (such as RCRA, CAA, CER-
CLA, or EPCRA - Section 2, etc.) or under OSHA. Never mix hazardous and non-hazardous
wastes. The hazardous chemicals in a blanket wash, as defined by OSHA, are usually listed in
Section 2 of the MSDS form. If this section says "none", your test wash probably does not con-
tain OSHA hazardous chemicals. But beware. The MSDS lists OSHA hazardous chemicals only.
The blanket wash may still contain chemicals defined as hazardous by other environmental reg-
ulations. If this section is blank, ask your supplier. See Questions to Ask When You Call
Your Blanket Wash Supplier for more information.
Use the
Worksheet to
Choose a Better
Roller Wash Too!
Design for tie Environment El
Appendices, page 15
-------
APPENDICES
If the test wash vapor pressure (in mmHg) is
Between 1.5 times higher and 1.5 times lower
Between 1.5 times and ten times lower
More than ten times lower
Evaporation: Compared to your normal blanket wash. Is the
vapor pressure of the test wash much higher, higher, the same,
lower, or much lower?
Sec MSDS Section 3 - Physical and Chemical Characteristics - for
vapor pressure information. Vapor pressure is a measurement of
how quickly a chemical evaporates. The higher the vapor pres-
sure of a blanket wash, the quicker it evaporates. If a blanket
wash has hazardous ingredients, they can evaporate into the air in
your shop, enter the lungs of your workers, and pollute the sur-
rounding environment. If the vapor pressure of your test wash is
less than the wash you arc currently using, it may evaporate less in your shop. Vapor
pressure is usually expressed in mmHg. Call your supplier if the vapor pressures of the
washes arc expressed in different units. 10 mmHg is usually a regulatory cut-off, bi/t the
lower the vapor pressure the better.
Environmental Regulations and Worker Health: Compared to your normal
blanket wash. Is the percentage VOCs of the test wash much higher, higher, the same, lower,
or much lower?
Contact supplier or manufacturer for this information. The amount of Volatile Organic
Compounds (VOCs) in your blanket wash can affect your costs of complying with
environmental regulations, especially Clean Air Act regulations on emissions from your shop.
VOCs contribute to lower level smog and may have health concerns. If the test blanket wash
has low or no VOC content, your environmental compliance responsibilities (and costs) may
be lowered and the health and safety of your employees may be improved. You might need to
contact your blanket wash manufacturer for this item (see Questions to Ask When You Call
Your Blanket Wash Supplier for more information). Score "much higher" if the percentage
VOC content of the test wash is two times or more that of the normal wash or "much lower" if
the percentage VOC content of the test wash is two times or more lower. Score "same" if with-
in 10%.
Flammability: Compared to your normal blanket wash. Is the flash point of the test wash
much higher, higher, the same, lower, or much lower?
See MSDS Section 4 - Fire and Explosion Data - for flash point information. The flash point
is one measurement of the temperature at which a chemical will ignite. In general, as flash
point increases, so does safety. Even though the minimum flash point for flammability is 100° F
and for hazardous wastes is 140°F, the higher the flash point the better. A less flammable chemi-
cal may save you money on your property insurance as well as exempt you from costly storage
and record keeping requirements of environmental and safety regulations such as RCRA and
OSHA. Contact your insurance underwriter for a reappraisal to determine the cost savings from
using a less flammable blanket wash at your shop. If the flash point of the test wash is two
times lower than the normal wash, mark "much lower" on the worksheet. If the flash point of
the test wash is more than two times higher, mark "much higher" on the worksheet. Score
"same" if within 15°F .
Other: Compared to your normal blanket wash. How does the test wash compare on any
other factors? Much worse, worse, same, better, or much better?
Compare the performance of the test wash to your normal wash on any other factors
important to your shop. Some examples include acceptability of wash to commercial laundry,
corrison of press parts, wash availability, dilution, and availability of recycled containers.
Score
Much higher
Higher
Same
Lower
Much lower
Appendices, page 16
-------
APPENDICES
Why a Worksheet?
The worksheet provided with
this; bulletin gives you a place
to keep information about the
washes you try out at your
shop. Make extra copies of the
blank worksheet and record
information about each' blanket
wash you test. After trying a
variety of washes, you can use
the completed worksheets to
compare them and find trie
one that is best for your shop.
The worksheet is not a
scientific evaluation and
may not cover every potential
cost. If a test wash scores
significantly better than
your normal wash, this
means the test wash might
be a better choice, but
does not guarantee it.
The Hidden Costs of Your Blanket Wash
The environmental, health, and safety costs of blanket washes are often hidden.
If your test wash is less harmful to your workers or the environment, or is less
flammable than your current blanket wash, you may save money by using it even
if it costs more per gallon. Potential savings include:
=*- Decreased regulatory costs (such as disposal costs, pollution control
equipment permitting, permitting fees, training, fines)
•=» Improved worker health and safety
=» Decreased insurance costs (such as workers compensation, fire, and liability)
=* Other decreased costs (such as energy)
Choosing a Better Wash — An Example
By testing a variety of washes you may be able to find one that is cheaper to use and better
for the environment. During the DfE Uthography Project (see page 6 for more information),
a vegetable ester wash was found that worked well and cost less than a petroleum-based wash.
Cost per wash was calculated based on price per gallon, time required to wash a blanket, number
of towels, and amount used. Results showed the vegetable ester wash was cheaper to use
per blanket than the petroleum-based wash at one facility, but was more expensive at another
facility. While savings may be even greater when factors such as those on the worksheet are also
considered, these mixed results show how important it is to evaluate products in your own facility.
Use the Worksheet to Choose
Other Chemicals for Your Shop
The nine worksheet questions can be easily adapted to compare other
chemicals, such as roller washes, you test in your shop. These nine questions
are important to consider when making any chemical decisions for your facility.
Design for tfie Environment
Appendices, page 17
-------
APPENDICES
,
Test Blanket Wash for a Set
Amount of Time:
a Discuss blanket wash
tests with press operators
o Set a trial period of one
or two weeks with press
operators
o Record major observations
during test period
Collect Information from:
a Press Operators
a Material Safety Data
Sheets
-s- Vapor pressure
information from
MSDS Section 3
"* Flash point
information from
MSDS Section 4
o Blanket Wash Supplier
«*• Percentage VOC
content
=s> Is blanket wash
considered hazardous
under environmental
regulations or OSHA?
Complete Worksheet:
a Enter each score in work-
sheet column
a Add scores for final result
Complete Evaluation:
o Does the final result
indicate potential
improvement?
a Are there other benefits or
costs of the test wash that
are not on the worksheet?
Don't Give Up
Keep in mind that the process of choosing a better blanket wash will require some
experimentation and an open mind. Not every blanket wash will work well at your shop
right away, but some may work better as press operators become more comfortable with
them. For this reason, allow a set period of time for trying a blanket wash, and stick to it.
For more ideas on cost saving ways to reduce pollution and waste at your facility, see other
Design for the Environment (DfE) Bulletins for the Lithographic Industry.
Questions to Ask When You Call Your Blanket Wash Supplier
To complete the worksheet you will need to ask your supplier some important questions:
(Some blanket wash manufacturers may supply this information on the MSDS, but they
are not required to do so.)
ri Does the blanket wash contain chemicals deemed hazardous
under any environmental statute or OSHA?
CT What is the percent Volatile Organic Compound
(VOC) content of the blanket wash?
CJ What is the Vapor Pressure of the wash in mmHg?
About the Design for the Environment Lithography Project
The goal of the Design for the Environment (DfE) Lithography Project is to provide lithographers
with information that can help them design an operation which is more environmentally sound,
safer for workers, and more cost effective.
Concentrating on the process of blanket washes, the partners of the DfE Lithography Project,
in a voluntary cooperative effort, evaluated 37 different blanket wash products. Information
was gathered on the performance, cost, and health and environmental risk trade-offs of the
different types of substitute blanket wash. For more details on the
evaluations, please refer to the booklet, Evaluating Blanket Washes:
A Guide For Printers.
In addition to the Lithography Project, similar DfE projects are currently
underway with both the screen printing and flexography industries.
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 (PPIQ
Phone: (202) 260-1023
Fax:(202)260-0178
U.S.EPA
401 M Street, SW (3404)
Washington, DC 20460
E-mail: ppic@epamail.epa.gov
DfE Web page: http://es.inel.gov/dfe
Recycled/Recyclable
Prated wiA Soy/Crab Ink n #fK M cortaiB at tet SOW rctyded fttt
Appendices, page 18
-------
APPENDICES
IX E: ALTERNATIVES
EVALUATION SAMPLE WORKSHEETS
This appendix presents an alternatives evaluation conducted by a small company. The
Significant Environmental Aspect (SEA) they identified was chemical hazard to workers
from a solvent.
Appendices, page 19
-------
APPENDICES
SCREEN ROOM COST IMPROVEMENT PLAN
Summary: A significant cost savings opportunity exists in our
Screen Room operations by changing the method we use chemicals
and also the vendor. Estimated yearly savings are $40,000. This is
attain by replacing the . BnH A "Cleaner" and K™^ &
Cleaner" with Sc-aM c, cvwve/r; and replacing the , fcrcvnA 6
"Stencil Remover" with 6rat\\ o "Stencil Remover". The biggest
$ impact is the difference in price and yield oftx&rA G "Stencil
Remover". The price is $45/gal. compared to $85/gaI. and the yield
is estimated to be twice as much. The increase in yield is a direct
result of not using the . &r»nd K "Cleaner".
Brand G Ctew^ is non-hazardous. It contains no
cyclohexanone, xylene or glycol ether. The flash point is 122F.
Brt^d A, -Cleaner is considered a hazardous chemical. It
contains cyslohexanone and ethylbenzene, which the state of
California has determined to cause cancer. The flash point is 50F.
It has been an ongoing goal to eliminate the need of BrW)d A
"Cleaner" because of safely concerns. This proposal accomplishes
this and attains a significant cost saying.
COST SAVINGS DETAILS - Sheet Fed Operation
There are several steps performed in the Screen Room that use the
above chemicals as well as others. The following will be a
comparison of present methods to the proposed methods
highlighting usage, time required in the process, and noting
potential savings in chemical and labor costs.
Appendices, page 20
-------
APPENDICES
AH Savings are based on 50 screens/day cycling through the
Screen Room:
Initial Screen Cleaning after removing from printing press:
Present Method
I. Spray2oz. Ofi&wvi % C.|-e«m«r- onto the ink
side of screen
U. Squeegee off ink into small bucket below screen
ffl. Repeat steps 1 and 2
IV. Wipe with cloth rag saturated with 3 oz. of E>mnd A
"Cleaner". Repeats this operation an average of 3 times
V. Wipes with dry rag
VI. Total time: an average 5.5 minutes (This depends on
UV or Solvent ink used or whether black ink was used)
Proposed Method
I. Spray 1 oz. of Brand C- Ckww' onto the ink
side of screen
n. Squeegee off ink into small bucket below screen
IE. Repeat steps 1 and 2
IV. Spray 1 oz. of e^nd C- Cl?0n0r\ on cloth rag and
wipe clean
V. Total time: an average of 4 minutes
Cost Comparison
I. Cost Elements:
1. Brand B ci^pin^r' - $800/55gals. or
.114/oz.
2. B.rairtf A Ci^Aiw - $590/55gals. or
.084/oz.
3. firar«t C- Cl-^rw - $735/55gals or
.104/oz.
Appendices, page 21
-------
APPENDICES
II. Present Method:
1. 4 oz. of. Bow\d-^ £k(M^L..... - $ .456
2. 9 oz. of BoxpA A, CAecvner - .756
'Total Chemical Cost -$1.21
III. Proposed Method:
1. 3 oz. of * Srpkt^ O Ckftrev - $ .315
Total Chemical Cost - $ .315
IV. Yearly Chemical Savings:
50 screens/day X 250 workdays/year X $.895
savings/screen = S3.1 ..188
V. Yearly Labor Savings:
50 screens/day X 250 work days/year X
1.5 minute savings/screen / 60min./hour
X$10/hour = $3.125
Reclaiming Process for Screens. Of the 50 screens that cycle
through the Screen Room, only 30 (est.) screens go through this
additional step to remove the emulsion.
Present Method
I. Spray 5 oz. of &W £ frcxfock t on both sides
II. Power Rinse w/water -1 side
HI. Spray both sides with.. SrorA £> ?o?AiAtf 2. -90oz.
IV. Power rinse with water -1 side
V. Brush with Br^ao ?<-ockcV 3 -bothsides-1.4oz.
VI. 10 minutes queue time so #V will work
VH Power rinse with water - 1 side
VIE. Move, to Rinse tank
IX. Total time: an average of 8 minutes
Appendices, page 22
-------
APPENDICES
on both sides
- 1 side-45oz.
Proposed Method
I. Spray 5 oz. of Bn?,r,4 c^
n. Power rinse w/water - 1 side
ffl. Spray with Brand o Pa?4wc^
TV. Power rinse w/water - 1 side
V. A) 25 % of screens: Brush with BaWi G
-bpthsides-1.4oz.
B) 75% of screens: Wipe with cloth rag saturated with
S™M c- £rvdutt ij— 2 sides-2oz. : Go to step VIII**
VI. 25% of screens; 10 minute queue time so #VA will
work
Vn. 25% of screens: Power rinse w/ water - 1 side
VIII. Move to Rinse tank
IX. Total time: an average 6 minutes
**This is possible because of the elimination of Br&rx\ A.
A, Cleaner" which locks the image into the mesh.
&w<\ C- ProAwoV 2, will only be needed on dark colors,
part, black.**
II.
Cost Comparison
Cost Elements:
1. Brand kJVcrtvidr 3- -$l,045/55g8ls. Or
.148/oz.
2. firard E> fr£?awcY i • $85/gaI. (4 gals. Are
mixed with 51 gals. Of water) or .012/oz. of blen.
3. 8rM Cr jRnocloicA-2- . $45/gal. (2 gals. Are
mixed with 53gals. Of water) or .006Yoz. of blend
4. E*W £ ?s^Ud-3 - $175/5gals. Or.273/oz
5. Bnand C/^rodwd <^ - $42/5gaIs. (1 quart is mixed
with 5 gals. Of water) or .003/oz. of blend
Present Method:
1. 5 oz, of firarxl c,_PtxxU»dr
-------
APPENDICES
3. 1.4 oz. of d o ftt^Aci- 5 - .388
Total Chemical Cost $2.25
II. Proposed Method:
1. 5 oz. of rc\ivi C- jProdiivH' i - $ .740
2. 45 oz. of BrftrxH C> R^d^ 2. .270
3. 25% of screens: 1.4 oz. of
75% of screens: 2 oz. of
8>rtxnA G fro^rtd' H~ .022
Total Chemical Cost $1.40 to $1.03
IE. Yearly Chemical Savings:
12.5 screens/day(25% of total) X 250
workdays/year X $.85 savings/screen + 38.5
screens/day(75% of total) X 250 workdays/year
X$ 1.22 savings/screen = $14,398
IV. Yearly Labor Savings:
30 screens/day X 250 workdays/year X 2 minutes
savings/screen / 60min./hour X $10/hour= $JL5_OQ
YEARLY SAVINGS IN SCREEN OPERATIONS:
CHEMICAL SAVINGS = $25,586
LABOR SAVINGS = 5.625
TOTAL $31,211
Appendices, page 24
-------
APPENDICES
DESIGN ART
Develop Preliminary
Layout
RECEIVE MATERIALS
Appendices, page 25
-------
APPENDICES
PREPARE EMULSION AND SCREEN
Strotch
mesh &
attach to
frame
Apply emulsion or
caplRary film to
mesh & dry
.Wash to
reveal Image
and dry
INK PREPARATION
tfork order*
from
Account
^Management.
y Yes
Customer
approval
Appendices, page 26
-------
APPENDICES
PRINT
Register press for
production run
INPUT/OUTPUT SUMMARY
NC Process Flow Maps
RECEIVE MATERIALS
I Store Shipment
Inputs
a Energy
a Building Space
O Safe Storage
Q Reoordkceping
Outputs
P Leaking Containers
a Waste Products
0 Spills (?)
)1 Inventory Control
Inputs
Q Energy
D Recordkeeping
Outputs
O Expired Products
U Waste Products
III Material Handling & Preparation
Inputs
a Energy
a Recordkeeping
Outputs
Q Empty containers
Appendices, page 27
-------
APPENDICES
DESIGN ART
I Collect Customer Specifications
Inputs
D Energy
a Paperwork
Outputs
a Unusable Artwork
Q Waste Packaging Materials
II Develop Preliminary Layout
Inputs
Q Energy
Q Paperwork
a Proofing Materials
Outputs
a Spent Printer Toner (cartridge)
D Paper
a Unusable Artwork
n Waste Packaging
III Customer Approval
Inputs
a Energy
a Paperwork
IV Final Layout
Inputs
D Energy
Q Paperwork
V Digital Output to Film
Inputs
Q Energy
D Paperwork
D Film Stock
u Imaging Device
u Imaging Material
Outputs
u Spent Imaging Materials
O Waste Film
Appendices, page 28
-------
APPENDICES
PREPARE EMULSION AND SCREEN
1 Stretch Mesh & Attach to Frame
Inputs
Q Frame
D Mesh
Q Adhesive
D Energy
Q Paperwork
Outputs
Q Minimal Air Emissions
O Waste Adhesive
U Waste Mesh
a Waste Frame (potential)
a Used Razorblades
TI Apply Emulsion or Canitlarv Film to Mesh and Dry
Inputs
D Energy
a Paperwork
Q Activator
a Film or Emulsion
a Water
Outputs
Q Expired Emulsion
O Waste Emulsion
Q Waste Activator
III Expose Negative
Inputs
a Energy
a Paperwork
a Film Positive (or negative)
Q UV Bulbs
Outputs
a UV Bulbs
a Film
IV Wash to Reveal Imapc & Dry
Inputs
a Energy
a Water
a Light Bulbs
Outputs
D Waste Water
D Used Light Bulbs
V Bloeko'it&Pinholc
Inputs
a Energy
a Paperwork
a Blackout
u Water
a Tape
Outputs
U Waste Water
U Waste Blockout
u Waste Blockout Applicator
a Expired Materials
Appendices, page 29
-------
APPENDICES
INK PREPARATION
I Color Match Approval
Inputs
O lincrgy
D Paperwork
o Ink
a Substrate
D Containers
D Solvents
D Additives
D Mesh
D UV Bulbs
Outputs
a Waste Ink
a Mixing Sticks
D Empty Containers
a Color Proofing
D Substrate
U Used Shop Rags
a Waste Mesh (potential)
Q Wasto Frame (potential)
jl Mix Ink
Inputs
D Energy
D Paperwork
D Containers
O Substrate
D Solvents
O Ink
D Ink Additives
Outputs
n Waste Ink
a Waste Ink Additives
Q limply Containers
Q Substrate
a Mixing Sticks
U Used Shop Rags
Appendices, page 30
-------
APPENDICES
PRINT
I Press Set-up
Inputs
D lincrgy
Q Paperwork
Outputs
Q Used Shop Rags
II Register 'Press For Production Run
Inputs
D Shop Rags
O Additives
Q Solvents
D Paperwork
a lincrgy
D Substrate
a Ink
Outputs
a Used Shop Towels
D Tape
Q Setup Paper
a Waste Substrate
a Waste Ink
Inputs
o Energy
Q Shop Rags
D Paperwork
O Solvents
D Additives
Q Substrate
Q Ink
Q Coatings
U Adhesives
Outputs
O Used Shop Rags
o Waste Inks
o Waste Solvent
o Spills (possible)
cj Used Ink Containers
a Tape
Appendices, page 31
-------
APPENDICES
SCREEN RECLAIMING
J Applv Ink Remover
Inputs
a Solvent
a Shop Rags
D Squccgoo
D Ink Remover
O Storage Container
Outputs
D Used Shop Rags
D Waste Ink
o Spills (possible)
It Rinse
Inputs
D Energy
a Walcr
Outputs
a Waste Water
HI Remove ICmutsion or Capillary Film
Inputs
Q Energy
o Shop Rags
Q Water
D Stencil Remover
a Scrubbers
Outputs
a Waster Water
Q Tape
O Used Shop Rags
D Spills (possible)
IV Rinse
Inputs
a Energy
D Walcr
Outputs
a Waste Water ,
V Remove Ilfl/.c
Inputs
u linergy
D Water
o Ha;ce Remover
D Scrubbers
a Shop Rags
Outputs
a Waster Water
Q Used Shop Rags
0 Spills (possible)
VI Rinse
Inputs
Q lincrgy
u Water
Outputs
a Waste Water
VII Dry
Inputs
a- Hncrgy
Appendices, page 32
-------
APPENDICES
FINISHING, PACKAGING, & SHIPPING
I Finishing Activities
inputs
a Paperwork
u Hnergy
a Pinshing Materials
u Finishing Tools
Q Tape
Outputs
u Waste Material
u Trimmings
u Adhesive
u Spent Kinishing Materials
a .Spent Finishing Tools
II Packaging Activities
Inputs
D I Cnergy
D Paperwork
Q Pallets
D Boxes
Q Packing Materials
Outputs
o Broken Containers
O Packaging Waste
III Shipping Activities
Inputs
O Transportation
Q linergy
D Paperwork
Outputs
D Refused Product
D Transportation limissions
SIGNIFICANT ENVIRONMENTAL ASPECTS (SEAs)
1) Reduce VOCs
2) Contain lead contamination (water table)
3) Rtnployee health and safety
Appendices, page 33
-------
APPENDICES
Worksheet 8-1: Functions and .Alternatives
Aspect
***»*
*nc<».
DaeCompIe
Alternatlv* Products
tST^^?
rcvi« / iv\fc. \re*v
Brrirvj C- Cl-tfan-ev'
Oro.** C*»W
ed:
Alternative
Technologies
evcv
*VS^W?
Alternative Work
Practices
Recycling/
Reuse
Treatment
Disposal
Contact Person:
Worksheet 8-2:
Chemical Product
Baseline
Bwuvlcctawr
-BrtnloeiiKn*
, . . — • •
Alternative Products Environmental Effects Comparison
Known Effects1
HM^R.
f&W
Management of Effects*
*>t lov<^
*?\oV<*^
^JfKitV.S'f T^v^
K«* ft«u
Cost of
Mgmt1
^
*"~
use
WA
MA
NA
Effects
Score
MtetSln to the "Environmental Concerns Worksheet" in Module 5 for the "known effects."
1 List protection required for each effect.
J Identify cost items.
Appendices, page 34
-------
APPENDICES
Worksheet 8-3: Performance Comparison of Alternatives
how well does It work how long does It take how «asy Is It to use
total
c/Vearw
V/SU-a.1
4 v«iV».
«V
sX
Worksheet 8-4: Regulatory Comparison of Alternatives
Regulation* Rtqutrad
(IW)
Control* Required
(tot)
Cost of Regulations
Total
Bmrvi A
Appendices, page 35
-------
APPENDICES
Worksheet R-S: Cost Comparison of Alternatives
raw
material
labor
disposal
tout cost
savings '
f
/H.'/J
Evaluation Worksheet
Appendices, page 36
-------
APPENDICES
This appendix presents a rudimentary introduction to project financial analysis - whole
textbooks have been written on this subject! While you may not quite need that level of detail
for assessing your baseline and alternatives, a list of other resources is included in Appendix
G (References and Resources). Your accountant can assist you in your analysis as well.
Appendices, page 37
-------
APPENDICES
There are many factors to consider when evaluating alternatives. Will the alternatives
perform as well? What are the environmental effects of alternatives? How much will
each alternative cost? Module 4 describes ways to evaluate alternatives for
environmental aspects that you want to change. This Appendix further describes one of
those steps - Step 8: Evaluate the cost of the baseline and alternatives - and provides an
example and guidance on where in your business to find cost data necessary for this
evaluation step.
Many costs, especially environmental costs (waste hauling or disposal costs, for example)
are often "hidden" in overhead accounts. These costs are usually unintentionally omitted
from a financial analysis. If an alternative will reduce the amount of waste generated, for
example, thereby reducing waste disposal costs, this savings may be omitted from a
conventional analysis. Other costs and savings may not be included in a financial
analysis because they are "less tangible," or difficult to quantify. Table #.1 gives
examples of some of these costs. When evaluating alternatives, it is important to fully
assess potential costs and benefits of the alternative, as well as your baseline costs, to
provide a complete picture of the relative costs and savings.
Table #.1: Examples of Potentially Hidden and Less Tangible Costs
Potentially Hidden Costs Less Tangible Costs |
Up-front: site preparation, permitting,
installation
Back-end: site closure, disposal of
inventory, post-closure care
Regulatory: training, monitoring,
recordkeeping
Liability: Superfund, personal injury,
property damage
Future regulatory compliance costs
Employee safety and health
compensation
Organizational image
Evaluating the cost of the baseline and alternatives requires several steps as described
below. A description of these steps is followed by an example.
Step 1: Map baseline and alternatives. Module 1 describes how to develop a map of
your company's processes, products, and services. This map is important to
understanding the activities occurring in your facility that cost you money. To also
understand the potential costs and savings of alternatives, it is important to develop
process maps for alternatives if the alternative will vary your current processes. For
example, Figure #.1 shows a metal finisher's baseline cleaning process using a solvent,
which is collected and shipped off-site for proper disposal. One alternative examined by
the metal finisher was installing a distillation system that could recover 95% of the spent
solvent. Figure #.2 shows the process map with the distillation system - spent solvent is
collected, recycled on-site, and re-used in the cleaning process. The map helps you
Appendices, page 38
-------
Figure #.1 Current Cleaning Process
Solvent
Energy
Product
Input
Cleaning
Spent
Solvent
APPENDICES
Product
Output
Figure #.2 Alternative Cleaning Process
Product
Input
Make-up
Solvent
Energy -
-Recovered Solvent-
Cleaning
Product
Output
-Spent Solvent-
Distillation
Appendices, page 39
-------
APPENDICES
visualize the differences between the baseline and alternative, and can help guide you in
collecting cost data.
Note: Remember to include
potentially hidden and less
tangible costs.
Step 2: Collect annual operating costs for
baseline and alternatives. Using the process maps
from Step 1 you can now begin collecting annual
operating costs for both your baseline and
alternatives. Use Worksheet 4-5a to help you collect cost information. Table #.2 lists
examples of some of these costs that may be relevant to your baseline and alternatives.
Costs that are the same for the baseline and the alternative can be omitted from the
analysis. In the solvent cleaning example, labor time and energy required for cleaning
remains the same for both the baseline process and the solvent recycling alternative.
Therefore, these costs can be excluded from the analysis.
Be as thorough as possible when considering costs, but don't worry about how you
classify costs. For example, you may wish to consider personal protective equipment as a
regulatory compliance cost, especially if its use is required by regulations. Alternatively,
you may wish to classify all protective equipment as "materials."
Environmental projects may save you money not
only by reducing your costs, but also by generating
revenues. For example, an alternative may increase
your product throughput because the activity takes
less time to complete, or product quality may be
improved enabling you to sell more of your product.
The alternative may also let you recover materials previously disposed of, and generate
revenues through sales of the reclaimed material (such as recovering metal scrap which
can be sold to scrap dealers). These annual revenue effects should be considered using
Worksheet 4-5b to assist you. Quantify these revenue effects if possible, and add them to
the total operating costs in Worksheet 4-5d. If these potential revenues are difficult to
quantify, you can consider them qualitatively in your evaluation by making a note in the
last column of Worksheet 4-5d.
By convention, costs (or outflows) are usually denoted by a negative (-) sign while an
inflow (or revenue) is denoted by a plus (+) sign. Make sure to keep these signs correct
when adding revenues to costs. For example, if the annual operating cost of your
alternative is -$20,000, but the alternative will generate an additional $10,000 in
revenues, your total annual operating cost would be -$10,000.
Note: Remember that changes
in one process may affect costs
in other processes. You should
include these costs as well.
Appendices, page 40
-------
APPENDICES
Table #.2 Annual Operating Costs
Materials (Purchase, delivery, storage)
Raw materials
Solvents
Catalysts
Personal protective equipment
Maintenance supplies
Direct labor (Wages, benefits)
Operating
Supervision
Inspection
Utilities
Electricity
Steam
Water
Fuel
Waste management (Labor, materials)
On-site handling
Treatment
Storage
Hauling
Disposal
Regulatory compliance (Labor, materials)
Labeling
Manifesting
..Recordkeeping
Permitting
Reporting
Protective equipment
insurance
Commercial general liability
Workers' compensation
Health insurance
< Pollution liability
Future liability
Fines/penalties
Legal costs
Business shutdown
Personal injury
Property/natural resource damage
Remediation
Step 3: Collect initial investment costs for each alternative. If any of your alternatives
will require an investment in new equipment, you will need to consider these costs. These
not only include capital costs, but also other one-time costs accompanying your
investment, such as installation costs or new equipment training. Use Worksheet 4-5 c to
help you collect these costs. Table #3 lists examples of these costs that may be relevant
to your alternatives.
Step 4: Calculate net present value for the baseline and alternatives. The next step
enables you to compare the baseline and alternatives to determine which options appear
to be most financially attractive. Because a change in your processes or activities may
affect your costs and savings over many years, the analysis should look at long term costs
and savings. For example, if you are considering installing new equipment that will last
for 10 years, your analysis should include the costs and savings that will accrue to you
over the 10 year period. This is especially important for environmental projects which
often times reap benefits over the long term.
Appendices, page 41
-------
APPENDICES
Table #.3 Initial Investment Costs
Purchased equipment (Purchase, tax, delivery)
Construction/installation
Consultant/contractor fees
Process equipment
Storage and materials handling equipment
In-house
Equipment rental
Safety/protective equipment
Monitoring/control equipment
Vendor fees
Laboratory/analytical equipment
Start-up/training (Labor, materials)
Waste handling/treatment equipment
Consultant/contractor fees
Initial spare parts
In-house
Safety/environmental training
Utility systems/connection
Electricity
Trials/manufacturing variances
Water
Vendor fees
Steam
Permitting
Fuel
Consultant/contractor fees
HVAC
In-house
Plant air
Permit fees
Inert gas
Vendor fees
Sewerage
Other
Refrigeration
Buildings
Plumbing
Land
Planning/engineering (Labor, materials)
Contingency
Working capital (cash, inventory)
Consultant/contractor fees
In-house planning/engineering
Procurement
Vendor fees
Site preparation (Labor, materials)
Consultant/contractor fees
In-house
Demolition & clearing
Equipment rental
Equipmentfrubbish disposal
Disposal
Grading/landscaping
Vendor fees
Appendices, page 42
-------
APPENDICES
A critical component of assessing a project where costs and savings may occur over
several years is incorporating the notion that the value of money changes over time -
commonly called the "time value of money." Most businesses prefer to have money
sooner rather than later. If you have money today, you have the opportunity to use it now
to grow your business, for example. Put another way, there is a cost if you receive the
money tomorrow instead of today. For example if you receive $1,000 today and put it in
the bank receiving 10% interest, at the end of the first year you would have $1,100. This
is clearly preferable to receiving $1,000 a year from now. Thus, because $1 today is not
equal to $1 tomorrow, you need to adjust the value of future dollars to reflect their
diminished value to you today.
The mechanism for making this adjustment is called a discount rate. A discount rate is a
percentage that is applied to future costs or revenues to determine its present value.
Typically, for business decisions, the discount rate chosen represents the business 's cost
of capital plus some level of desired return on an investment plus an additional margin to
account for uncertainty. Your accountant will be able to assist you in selecting an
appropriate discount rate for your analysis.
To calculate the present value (PV) of a cost or savings in the future, use the following
equation:
PV-
J. Y —
where FV = the future value of a cash flow (i.e., a cost or cash outflow, or a
revenue or cash inflow) received in year t, and
r = the discount rate.
For example, the present value of a $1,000 revenue you expect to receive over the next
four years would be:
$1000 $1000 $1000 $1000
(i+o.io)1 (i+o.io)2+(i+o.io)3+(i+o.io)'
or:
Year
1
2
3
4
Total
Future Value
$1000
$1000
$1000
$1000
Present Value
$ 909
$ 826
$ 751
$ 683
$3169
The net present value (NPV) can then be calculated as follows:
Appendices, page 43
-------
APPENDICES
where ZPV is the sum of the present values of the cash inflow or outflows and
I = the initial investment cost.
In our above example, if the initial investment cost is $1000, then the NPV equals $2169
($3169 - $1000). If your alternative won't require an initial investment - for example,
you are substituting a toxic chemical with a less hazardous chemical, but there are no
changes in your equipment, then NPV is equal to the sum of the present values ($3169 in
the above example).
Note: In financial analyses, a cost (or
outflow) is usually denoted by a
negative (-) sign while an inflow (or
revenue) is denoted by a plus (+) sign.
NPV can be calculated using a financial
calculator, spreadsheet software like Excel,
using project profitability analysis
or
software such as P2/FINANCE (see the
resources list at the end of this Appendix).
Step 5: Assess the costs and savings. The last step is to evaluate your baseline and
alternatives from a cost and savings perspective. The difference between the alternative
and baseline is entered hi Worksheet 4-6. A positive number indicates that the alternative
saves money, while a negative number indicates that the alternative is more expensive
than the baseline. The alternative with the greatest NPV is the most profitable one.
Note: Remember that your accountant can assist you hi these calculations.
Example: Baseline vs. Alternative Cleaning Processes
As described above, as part of its EMS, a metal finisher examined methods for reducing
solvent use hi cleaning. Recovering solvent via a distillation system was one alternative
identified. The cost and savings analysis of the baseline versus alternative follows.
Step 1: Map baseline and alternatives. These processes are mapped in Figures #.1 and
#.2.
Step 2: Collect annual operating costs for baseline and alternatives. The current
annual costs for the baseline are shown in Table #.4. These costs are readily available
from purchase orders. Because labor and electricity costs for the cleaning operation
remains the same for the baseline and alternative, these costs are omitted from our
analysis.
Appendices, page 44
-------
APPENDICES
Table #.4 Annual Operating Costs - Baseline
Annual Operating Costs $/year
MATERIALS
Solvent 11,631
WASTE MANAGEMENT
Solvent disposal 19,041
Annual operating costs for the alternative are shown in Table #.5. Material costs include
make-up solvent (because 95% of the solvent is recovered from distillation, make-up
solvent must be added) as well as oil and filters for the distillation system. Electricity
costs are for operating the distillation system only (electricity use for cleaning is the same
for both the baseline and alternative), these costs are available from the equipment
vendor.
Table #.5 Annual Operating Costs - Cleaning with Solvent Recovery
Annual Operating Costs $/year
MATERIALS
Chemicals
Oil
Filters
WASTE MANAGEMENT
Disposal
UTILITIES
Electricity
6692
375
2284
439
241
These operating costs are entered into Worksheet 4-5a. Note that there are no potential
annual revenue effects for the alternative project so Worksheet 4-5b is not included.
Step 3: Collect initial investment costs for each alternatives. The initial investment
costs for the distillation system, provided by the equipment vendor, appear in Table #.6.
These costs are then entered in Worksheet 4-5c.
Table #.6 Initial Investment Costs for the Distillation System
Investment Costs ^ . Cost in $
PURCHASED EQUIPMENT
Distillation system
START-UP/TRAINING
Start-up & Training
26,200
750
Appendices, page 45
-------
(A
Ui
O
a
ui
o.
(0
o
o
D>
'J=
2
0)
Q.
O
(0
c
<
I
(0
o
I
i
-1
18,1
POO
^
£ =
o>
o
0
o
& o
ii
I!
1
w c
Iw CQ
CO
.22
5
*-»
si
CO
CO
•n
**
a
E
0)
to
i
N
)
o"
•o
J
o
T—
CO
[f
•*•
^—*
T~
1
C
CQ
<
0
o
o
1
4
,_
X
co
o>
CQ
3
0
o
O
1 Investmer
.2
'E
I
o
w-fc
Worksheet <•
1
o
)
•
°-
ti
II
$2
2*
gl
X*
Site
preparation
c,I
'i 1
si i
Utility
systems/
connection
o ?
(0 °>
it
3 ir
Q. <1)
Alternative
!
1
!
i
'
!
!
1
1
A (Baseline)
3
n
3)
rf
D
O
O
c\
CQ
W
+5
ft
E
<^
0
c
Comparisc
o
o
i
•o
«n
Worksheet -
*r**x
(' fl^
5 '|S
xS**
»*""* /ft
yg
J Q,
c 5
L -
£
$
o
1 Investment
sent Value)
II
CO
O
1 Operating
sent Value)
!£
Alternative
~*
V
\
;j
co
O)
°H.
«^T
CO
CN
Z
(V1
CO
CN
CD
3
CD
CQ
>
4?
O
±:
"o
o
•43
nj
3
C8
UI
1
J-
Worksheet
i
i
i
11
>
»
>
i
>
-------
APPENDICES
Step 4: Calculate net present value for the baseline and alternatives. Next, the net
present value for the baseline and alternative is calculated using the company's discount
rate of 10%. Because the lifetime of the distillation system is 15 years, operating costs
are assessed over 15 years. These costs are entered in Worksheet 4-5d. Remember that
cash outflows (such as investments or operating costs) are entered using a negative (-)
sign while inflows (revenues) are denoted by a plus (+) sign.
Step 5: Assess the costs and savings. Worksheet 4-5d shows that the NPV for the
baseline is -$233,293 while the NPV of the alternative is -$49,346. The difference
between the alternative and baseline (alternative minus baseline) is entered in Worksheet
4-6. A positive number indicates that the alternative saves money, while a negative
number indicates that the alternative is more expensive than the baseline. Worksheet 4-6
shows that the distillation system will save the metal finisher $183,947 over 15 years.
Getting Started - Where to Find Cost Data
You now have the tools to evaluate the cost and savings of your alternatives. However,
you may not be sure where to find the data necessary for conducting this analysis. To
assist you, Table #.7 lists costs and sources for these data in your business. Note that
when collecting similar cost data for your alternatives, suppliers and vendors are
frequently a good information source.
Future assessments can benefit from improving your business' current cost tracking
system. While at first glance this may seem intimidating, you can begin to incorporate
these costs into your accounting framework one step at a time. Begin by tracking a few
costs on a routine basis, selecting the most significant costs first. You may want to begin
by examining the costs associated with environmental issues to gain a better awareness of
how they affect your business' bottom line. Use this awareness to focus your efforts on
specific cost areas that appear to have the most importance to your business. As your
level of knowledge increases, you can expand your cost tracking system to include other
cost data. Eventually you will have a system that meets your needs and provides you
with extensive crucial business information.
Appendices, page 47
-------
APPENDICES
Table #.7 Where to Find Costs
Cost Category
Process Chemicals
Ancillary Chemicals
Storage Space
Waste Treatment
Testing
Disposal
Training
Personal Protective
Equipment
Insurance
Production
Taxes/Fees
Environmental Compliance
Maintenance Labor
Maintenance Materials
Water Usage
Electricity Usage
Steam Usage
Data Elements
Usage Rates
Unit Costs
Usage Rates
Unit Costs
Total Square Footage
Cost/Sq. Ft.
Flow Rates
Total Chemical Costs
Number of Tests/Year
Cost per Test
Type and Quantity Disposed
Unit Costs of Each
Number of People
Number of Trainings
Lengtri of Training
Hourly Labor Rates
Type and Quantity Used
Cost per Item
Type and Coverage
Premium
Machine Down Time
Machine Rates
Labor Rates
Sewer Use Tax
Chemical Use Tax
Water Use Tax
Volume of Weight of
Each Taxed Item
Hours of Labor for All
Compliance Tasks
Hours of Labor
Tasks Performed ,
Amount of Materials
Costs of Materials
Annual Usage Rate
Cost/Gal, or Cu. Ft.
Annual Usage Rate .
Cost/kWh
Cost of Production
Fraction of Total
Used by Process
Where Found
Production Records
Purchase Orders
Prod. Specifications
Purchase Orders
Actual Measurement
Rental Contract
WWT Log Sheets
Purchase Orders
Environmental Files
Invoices
Manifests
Invoices
Training Records
Wage Rate Sheet
Stock Room or Inventory ~~
Capital Budgets
Invoices
Prod. Records
Operating Budget
Personnel Records
Water Bills
Environmental Records
Water Bills
Water, Chemical
Usage Records
Estimates, Salaries, or
Environmental
Management Records
Maintenance Log
Maintenance Log
Purchase Orders
Flow Meters or Logs
Town Water Bills
Equipment Specs.
Utility Bills
Fuel Bills, Boiler
Maintenance Logs,
Count of Processes
Using Steam
Who to Ask
Foreman
Billing Dept.
Product Engineers
Billing Dept.
Maintenance or Engineering
Billing Dept.
WWT Operator
Purchasing Dept.
Environmental Manager
Accounts Payable
Environmental Manager
Accounts Payable
Environmental Manager
or Contractor
Personnel Dept.
Environmental Manager
Purchasing Dept.
CFO, Accountant
Accounts Payable
Production Manager
Finance Dept.
Personnel Dept.
Accounts Payable
Environmental Manager
Local POTW
Production Manager,
Purchasing
Environmental Manager
Maintenance Dept.
Shop Foreman
Maintenance Dept.
Purchasing Dept.
Production Manager
Accounts Payable
Production Manager
Accounts Payable
Accounts Payable
Maintenance Dept.
Plant Walk-Through
Source- Appendix C of Total Cost Assessment for Environmental Engineers ana Managers (.Jonn w ney
-------
APPENDICES
General Resources
The ISO 14000 Handbook, edited by Joseph Cascio, Chairman, US Technical Advisory Group to
ISO/TC 207, CEEM Information Services, Fairfax, Virginia, 1996.
Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations, NSF International, Ann Arbor, Michigan, November 1996.
Developed with funding through a cooperative agreement with the U. S. EPA, Office of Wastewater
Management and Office of Enforcement and Compliance Assurance.
EPA Position Statement on Environmental Management. Federal Register: March 12, 1998
(Volume 63, Number 48), pp. 12094-12097. '•"'.''
Design for the Environment, Building Partnerships for Environmental Improvement, Design for the
Environment, U. S. EPA, EPA/600/K-95/002, September 1995.
Federal Environmental Regulations Potentially Affecting the Commercial Printing Industry, Design
for the Environment, U. S. EPA, EPA744B-94-001, March 1994.
"Compliance-Focused Environmental Management System — Enforcement Agreement Guidance,"
EPA-330/9-97-002R, U. S. EPA, Office of Criminal Enforcement, Forensics and Training, August
1997, Revised January 2000.
"Improving Environmental Performance and Compliance: Ten Elements of Effective Compliance
Systems." Enforcement Cooperative Program of the Commission for Environmental Cooperation,
June2000. (www.cec.org) .: '
Government Printing Office (GPO)
The GPO website provides links to the full text of the Code of Federal Regulations (CFR), Federal
Register notices for the past several years, and other resources.
Website: www.access.gpo.gov/nara/
The Clean Air Technology Center (CATC)
A source of general information on air emissions-related technology.
Telephone: 919-541-0800
Website: www.epa.gov/tnn/catc
Appendices, page 49
-------
APPENDICES
The RCRA, Superfund & EPCRA Hotline offers information and publications that are relevant to
RCRA.
Telephone: 800-424-9346
Website: www.epa.gov/epaoswer/hotline
The Office of Water
The Office of Water, especially the Office of Wastewater Management, can be contacted for
information on Clean Water Act provisions that relate to the printing industry.
Telephone: 202-260-5700
Website: www/epa/gov/OW
The Safe Drinking Water Hotline can provide information on issues related to the Safe Drinking
Water Act.
Telephone: 800-426-4791
Website: www.epa.gov/OGWDW/
The Superfund Website provides general information on CERCLA.
Website: www/epa.gov/superfund
The Chemical Emergency Preparedness and Prevention Office website offers information on the
emergency response aspects of EPCRA, which are administered under the Chemical Emergency
Preparedness and Prevention Office.
Website: www/epa.gov/swercepp/
The Toxics Release Inventory website provides information on the Toxics Release Inventory
reporting requirements, which are implemented by the Office of Pollution Prevention and Toxics.
Website: www.epa.gov/opptintr/tri/index.html
The Occupational Safety and Health Administration (OSHA) website provides information on the
Occupational Safety and Health Act, OSHA regulations, standards, interpretations, and other
information.
Website: www.osha.gov/
Appendices, page 50
-------
APPENDICES
Technical Resources
Cleaner Technologies Substitutes Assessment, A Methodology & Resource Guide, Design for the
Environment, U. S. EPA, EPA744-R 95-002, December 1996.
Cleaner Technologies Substitutes Assessment, Industry: Screen Printing; Use Cluster: Screen
Reclamation, Design for the Environment, U. S. EPA, EPA744-R-94-005, September 1994.
Information on developing a Cause and Effect (Fishbone) Diagram is available at:;
www. sytsma. com/tqmtools/cause.html
Cost Resources
Journal Articles/Publications
Aldrich, James. R., 2000. "P2 and the Bottom Line - Choosing Variables: What Factors Should
You Include when Analyzing the Value of a P2 Project?" Pollution Prevention Review. John Wiley
& Sons, Inc. Summer.
Aldrich, James. R, 1999. "P2 and the Bottom Line - Net Present Value," Pollution Prevention
Review. John Wiley & Sons, Inc. Summer.
Aldrich, James. R., 1999. "P2 and the Bottom Line - Internal Rate of Return," Pollution Prevention
Review. John Wiley & Sons, Inc. Spring.
Aldrich, James. R, 1998. "P2 and the Bottom Line - Depicting Financial Impacts Over Time,"
Pollution Prevention Review. John Wiley & Sons, Inc. Autumn.
Aldrich, James. R., 1998. "P2 and the Bottom Line - The Time Value of Money," Pollution
Prevention Review. John Wiley & Sons, Inc. Summer.
Kennedy, Mitchel, 1998. "Critical Issues of Total Cost Assessment: Gathering Environmental Cost
Data for P2," Pollution Prevention Review. John Wiley & Sons, Inc. Spring.
Pojasek, Robert B., 1998. "Practical Pollution Prevention - Activity-Based Costing for EHS
Improvement," Pollution Prevention Review. John Wiley & Sons, Inc. Winter.
Pojasek, Robert B., 1997. "Understanding a Process with Process Mapping," Pollution Prevention
Review. John Wiley & Sons, Inc. Summer.
U.S. EPA, 1995. An Introduction to Environmental Accounting as a Business Management Tool:
Appendices, page 51
-------
APPENDICES
Key Concepts and Terms (EPA 742-R-95-001).
White, Allen L., Becker, M., and Savage, D., 1993. "Environmentally Smart Accounting: Using
Total Cost Assessment to Advance Pollution Prevention," Pollution Prevention Review. John Wiley
& Sons, Inc. Summer.
Software Tools
P2/FINANCE (Pollution Prevention/Financial Analysis Cost Evaluation System) This software
provides spreadsheets (Microsoft Excel) for evaluating the profitability of pollution prevention and
other types of projects. It can be downloaded free of charge from EPA's web site:
www.epa.gov/opptintr/acctg
E2/FINANCE (Energy and Environment /Financial Analysis Cost Evaluation System) This software
is useful for evaluating the profitability of energy efficiency, pollution prevention and other types of
projects. It can be downloaded free of charge from Tellus Institute's web site: www.tellus.org
Web Sites
The US EPA Environmental Accounting Project web site (www.epa.gov/opptintr/acctg) contains
case studies and other documents.
Other Resources
Design for the Environment Printing Project, Lithography Case Study 1, Managing Solvents and
Wipes. U. S. EPA, EPA744-K-93/001, October 1995.
Designing Solutions for Screen Printers, An Evaluation of Screen Reclamation Systems, Design for
the Environment, U. S. EPA, EPA744-F-96-010, September 1996.
Solutions for Lithographic Printers, An Evaluation of Substitute Blanket Washes, Design for the
Environment, U. S. EPA, EPA744-F-96-009, September 1997.
EMS Gap Analysis, The Lexington Group, Environmental Management Consultants, Inc., ©1997.
For a full list of DfE Program publications, contact EPA's Pollution Prevention Information Center,
1200 Pennsylvania Ave., N.W. (7409), Washington, DC 20460.
Phone: 202/260-1023; Fax: 202/260-4659
E-mail: ppic@epa.gov
http://www.epa.gov/opptintr/library/ppicdist.html
Appendices, page 52
-------
APPENDICES
DfE website: http://www.epa.gov/dfe
The John Roberts Company
9687 East River Road
Minneapolis, MN 55433
(612) 755-0394
Ecological Benefits Assessment Model (EBAM)
What does EBAM do?
> Estimates the ecological benefits of risk management alternatives in economic terms.
*• Estimates the dollar value of the ecological benefits of risk management alternatives on
recreational fishing.
*• Estimates the dollar value of environmental damages.
Technical Contact:
Lynne Blake-Hedges
U.S. Environmental Protection Agency
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-7241
E-mail: blake-hedges.lynne@epa.gov
Chemical Screening Tool for Exposure and Environmental Release (ChemSTEER)
What does ChemSTEER do?
>• Estimates occupational inhalation and dermal exposures during chemical manufacturing,
processing, and use activities.
*• Estimates chemical releases to air, water, and land that are associated with chemical
manufacturing, processing, and use.
For more information about the tool, contact:
Scott Prothero
U.S. Environmental Protection Agency
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-1566
E-mail: prothero.scott@epa.gov
Appendices, page 53
-------
APPENDICES
Use Cluster Scoring System
What does the UCSS do?
>• The Use Cluster Scoring System (UCSS) is a computer-based, risk-screening system with
information about nearly 3,200 chemicals in the 380 clusters — or families — into which
these chemicals are grouped. For example, instead of considering a single chemical that
happens to be a paint stripper, the cluster of chemicals that perform as paint strippers is
considered.
>• The UCSS accesses hazard and exposure data that are extracted from the Toxics Release
Inventory (TRI), the Integrated risk Information System (IRIS), and other readily accessible
risk assessment related databases.
>• The UCSS then uses a simple system to score and rank chemicals and their respective
clusters. The program was developed to identify clusters of chemicals of potential concern to
EPA.
For additional information about the Use Cluster Scoring System, contact:
Franklyn Hall
U.S. Environmental Protection Agency
OPPT, Economics, Exposure & Technology Division
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-9596
E-mail: hall.franklyn@epa.gov
Graphical Exposure Modeling System (GEMS)
What does GEMS do?
>• GEMS will connect outdoor air, surface water, soil, groundwater, and multimedia models
with some of the environmental and population data needed to run the models.
>• GEMS will estimate environmental concentrations in a variety of environmental media.
>- GEMS will have graphics capabilities for displaying data and environmental modeling
results.
For more information about the model, contact:
Lynn Delphire
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Phone: 202-260-3928
E-mail: delphire.lynn@epamail.gov
Appendices, page 54
-------
APPENDICES
Exposure, Fate Assessment Screening Tool (E-FAST)
What does E-FAST do?
* Provides screening-level estimates of the concentrations of chemicals released to air, surface
water, landfills, and from consumer products.
> Estimates potential inhalation and ingestion dose rates resulting from these releases.
*• Modeled results, estimates of concentrations and doses, are designed to be conservative.
For more information about the model, contact:
Tom Brennan - ' •,
U.S. Environmental Protection Agency
401M Street, S.W. (7406) ; , ,
Washington, D.C. 20460 ........
Phone: 202-260-3920
E-mail: brennan.thomas@epamail.gov
Appendices, page 55
-------
-------
APPENDICES
APPENDIX H: BLANK WORKSHEETS
This appendix contains blank copies of all the worksheets presented in the Implementation Guide, for
your use. The worksheets are identified by the same numbers used in the Guide. For example,
Worksheet 6-1 would be the first worksheet found in Module 6.
Appendices, page 57
-------
APPENDICES
Worksheet 1-1: Costs and Benefits of Developing and
Implementing an IEMS
Costs
Contact Person:
Benefits
Date completed:
Appendices, page 58
-------
APPENDICES
Worksheet 1-2: IEMS Responsibilities
IEMS Function
Person
Regular Position
Management Representative
lEMS Coordinator
IEMS Committee
Contact Person;
Date Completed:
Corresponds to RESP-01 of the Company Manual Template.
Appendices, page 59
-------
(0
UJ
o
a
UJ
a.
a.
4-*
CD
CD
JC
0)
u
o
CO
CD
O
LH
*j
O
0)
CD
Q:
•D
§
(D
"S
TJ
CD
r
•M
CD
0
CD
CD
D
Worksheet 1-3: IEMS
c
o
4=
0)
o.
E
o
O
"S
E1
re
0)
D)
TJ
3
m
w
re
fa.
r
re
rt
UU
Module
•o
c
to
, .
CD
1
•*-»
s-
Making the Commitment: Creating a Po
Determining the Scope
Intermediate steps: (As appropriate)
08
.0.
f
0)
1
Planning the Process: Decision Points, 1
Participants, Schedule & Plan
Intermediate steps: (As appropriate)
T3
C
03
W
oS
o
o
o
O)
'N
Determining Significant Aspects: Priorit
Setting Objectives
Intermediate steps: (As appropriate)
Developing Operational Controls
Intermediate steps: (As appropriate)
o
(O
to I
ul
-------
CO
HI
o
Q
111
Q.
Q.
D)
'^
CD
to
•o
CO
CO
5
TS
r~
Making Improvements: Evaluating Alten
Targets
Intermediate steps: (As appropriate)
s_
o
•£_
£
•e
o
Q.
Q.
to
Implementation: Building Organizational
IEMS
•
Intermediate steps: (As appropriate)
0)
_c
to
CO
CD
2
eo"
•5
CD
1"
Q.
Setting Up Environmental Management
and Achieving Success
Intermediate steps: (As appropriate)
Establishing Continuing Improvement
Intermediate steps: (As-appropriate)
T3
CD
"5.
E
o
0
CD
"CO
Q
Contact Person:
0)
O)
(0
Q.
s
T3
c
0)
Q.
Q.
-------
CD
CD
4-*
g
"0
0
Q
0)
LLJ
^^
O
4—
0
a
1
Persons Resp
. .
"CT*
1 Worksheet 1-
D)
•a
3
DQ
&*
.§ «
H c
«. 0)
o '55
^g
lg
!5 o
> a
!g |g
_ t£
in
&
o
on
O)
CD
CD
a.
'Z o
O (11
e" having responsibility f
35, this could be the owni
.> CO
to- CD
"Management represent
the EMS (in small busin
IEMS Coordinator
CO
CO
CL
'0
••E
co
CL
CO
CO
UJ
CO*
t>
CD
CL
75
•£
CD
significance of environm
0)
C
Identifying and determir
CD
f
applicability of legal and
c
C
*?«
Identifying and determir
requirements.
O)
'c
Competency-based trail
Operational controls.
nd response.
CO
CO
Emergency preparedne
73
C
co
CO CD
.2 **
to of
§.==-
° a
nt of "key characteristics'
lificant environmental im
ispects.").
QJ *— TO
c o —
S w fl
Monitoring and measun
activities that can have
"significant environmen
ironmental compliance.
C
CD
Periodic evaluations of
to
UJ
CD
non-conformance with th
o>
_c
Handling and investigat
Records management.
.52
'•5
co
CO
UJ
'co
1
03
03
"3.
E
o
O
OJ
to
Q
1 Contact Person:
CD
CD
W
•a
co
to
CO
£
O)
o
O
2
CD
CD
CD
I
I
cS
CO
CO
E
a.
CO
UJ
CD
CD
Q.
o
CD
73
CO
CO
C
CD.
D)
i!
'> CD
I*
o -E
-Q CD
CD E
CO CD
II
si
tp
CM
to
0)
O)
co
a.
0)
a
a.
-------
(0
UJ
o
5
z
UJ
CL
lental Aspects
c
c
0
>
c
LU
D)
Jfc
"t«
^^
Jlk
2
^
UT>
Y—
•£
(D
1
b
•s
§.
E
15
*;
C
0)
I
1
c
UJ
imental Aspect
ify if available)
2 =
.h «
> 3
C CT
UJ -*
^
1
O
53
s
Q.
C
Office Activities
•
Manufacturing Process
Building Maintenance
Products and Services
T3
y>
~a.
E
o
O
Q
g
fe
Q.
Contact
s
1
1
the the Company Manual T<
c
•—
CM
O
&
c
.=
«*— '
0)
T3
CD
T3
_3
^
0)
JZ
p
o
to
£
0)
•*-*
0)
05
to
0)
O)
(U
Q.
Q.
-------
APPENDICES
Worksheet: 1 -6* Regulations
Regulatory Agencies
Regulations That
Apply to My Business
Sector
Contact Person:
Business Operations
Potentially Affected
Date Completed:
Does it Apply to My
Business?
•Corresponds to Table LR-01 in the Company Manual Template.
Appendices, page 64
-------
(0
01
o
Q
HI
Q.
Q.
C
o
•-P
(0
E
o
w
(D
It
*^
HI
•g
"•H
C
J>
O
Q.
S
C
(D
£
c
o
1
•D
1
0
td
(0
if
(D
I
(0
^
CO
*
(D
H
C/J
s^
1«
O
5
c
UJ
ro
E
3
^ •&
b *^
5 ^
|
1 1
§| 1
* S §
0 O C
£ -a >
8= c c
ill n a>
(0
1"
£
£ o
-§" S
« s
0 o
UJ C
JC "
2f o
^B ^
Q.
O
^
•2
CD
^>
o
0
n
if
O
{2
Q)
Q.
-s
1
O
TO Q
ts
i2 *
1 °
II
^•2
1^
fc =
cS |
E £
w ^
co^
particular, acute effects are usually reported on
LC refers to lethal concentration. Inhalation LC50
c
•D
0
-a
(D
0
c:
0
JD
>,
esources ma
k.
t_
0)
=1
4-*
-Q
co"
a
CO
' CD
£
1
a>
I
4-1
.C
O)
E
CO
1
1
81
0)
-*-•
£
c
.0
"m
C-
|
"ro
••e
05
o!
o
p'
l__
0
1
o
TJ
=J
£
5
5
0)
=
>
0)
•g
•4— '
.a
!
(A
S
CO
i sometimes on ^
s
03
tj
CD
.0
1
.C
o
.
£2
1
CO
CO
Q
CO
2
specified exposure period. LD refers to lethal
cause death in 50 percent of the test animals.
CD
£
73
CD
CD
«4-^
ra
st organisms i
0)
•+-•
*&
^-*
c
CD
Q.
O
to
C
£
03
(U
air that causes d
c
"co
.0
0)
o
03
^
o
1
§
(1)
£
2
1
(0
•43
(0
CD
_W
-^->
(0
-I-*
E
s
p
L
o
c"
'^.
V)
0)
£
£"
T3
(!)
•e
O
CO
JD
(0
jf"
H~*
^
>,
JQ
1
S
S
E
0
•5
CO
•s
0
8
T3
^
.
P>
0
body weight,
0
£
£>
•o
0
•o
'>
T3
1
of chem
terms of amount
_c
S>
Q.
%
£
CO
03
CD
•o
"ro
•tg
_j
«
iviron mental effe
0
0
T3
"o
0
"^3
^>
03
=3
Q
CO
S
T3
0
O
"8
•o
1
Q.
(D
S
'3
O
J^
to
a:
CD
.C
-*-*
S
fi
2
c/>~
0
3
ra
.£•
o
!i
0
>
:ing quantitati'
I
e-
.8
C
£
co
|
i
E
o>
c
73
75
I
T3
TJ
.8
(D
?
.i
0
O
'ra
*£!
•—
(D
O
£
"Q
z
.2
'co
1
a
o
Q.
10
(O
0>
D>
n
Q.
u>
Q.
OL
-------
(O
UJ
o
I
<
/laterals
«£
TJ
i
CO
"3
IT
1
2
ID
2
CO
$
• •
CM
CO
rksheet
1
(0
Q.
3
Q
2
O
•o
tn
o
a.
&
c
&
flj
^
l
1
i
c
2
>
Ui
£»
'E
3
O
O
12
JO
> -s
c ™
UI
•• 5"_"
= .2 re _
c to E 2
i To § O
x^a
_ o "c
ll.s-8:
0» g g. — '
O" Q. in
0)
E
1
(0
o
Q.
X
UJ
3 5
0 g
£ CO
0 a)
= 2
i yj
u Q
2> ^
= *-•
= o
~ 0
o !2
= 3
D tD
a> ^
! I
I 1
= .0
a s
ro. E
<•> 5
~ o
tf g-
3 OJ
S ®
D- *•'
lc.5
•a
3. " "
"^ S TO
^- ^ 0
§**" *-' "*~*
"o = •£
f ingredient in
How many ho
ote: For more
5- S Z
co
to
o
ra
m
Q.
8
0)
Q.
Q.
-------
CO
UJ
o
a
"2.
Ill
Q.
I
3
£
3
E
0
CO
i
CO
0)
.c
0)
•J5
o
ns
oi
J
(A
0)
CO
_W
'E
I
E
o
0
1
Q.
**
C
Operatioi
•
1
TO
Q
cz
OT
CD
Q.
ts
1
o
O
(O
0)
'• O)
(0
Q.
w"
0>
0)
a
a,
-------
(0
IU
o
5
§
a.
a.
<
0
W
0
e
3
O
W
0
IT
1
LM
Jj
fi
z
i
CO
•s
0
w
j£!
o
a
•a
o>
=3
(A
0)
IM
3
O
0)
{£
s
3
13
•s
0)
Q.
^
C
C
1
d>
Q.
0
03
15
Q
C
o3
Q.
•s
a
"c
O
CO
to
-------
(0
UJ
o
o
UJ
Q.
Q.
12
t>
CD
»
<
fE
O)
to
CD
C
f*
0)
Q
0
CD
•1^
6
U)
CO
4-i
CD
CD
Works
i
*J
re
•- ?
0)
CO
= °>
u -J£
> 5
O re
a:
0
2 §
"re o
*T8
i §
E $
o
||
(A
E
is
(D
^
•o
Chemical an
Environment
Eff/Expc
>,
C Q.
C UJ
IE
o
l°x
II
^ (0
o c
a t~
re a>
Q.
0
1
ffl
a.
O
a.
0
O
1
Q
O
«/>
| Contact Per
U)
-Sj >;
m E'
Q. Q)
1 iS
"CD ,; I/)
§t |
CO CO «^
xl 1
CO Q
1^ $
6 CD ZD
o° 8
to SEA-01 in tt
nput and outpi
ure
light, odor.
terns as Resoi
11 1"| 1
O c LU "Z. c
O)
to
o
O)
re
Q.
uT
Q.
Q.
-------
APPENDICES
Worksheet 3-6: Criteria to Select Environmental Projects
Project to Address
Aspect
Time Frame
Cost
Contact Person:
Technical
Feasibility
Total Feasibility
Date Completed:
Appendices, page 70
-------
(0
UJ
o
Q
ILI
Q.
M
c
£
0)
s
i
73
§
Q.
• •
s.
CO
1)
3)
S
ff
£
5
Expected
provements
E
-------
Ill
o
Q"~*
2
LU
Q.
OL
I
3
O)
i
c
frt
cc
i
0
O
00
1
CO
"0
0
SI
(/)
^d
o
re
<-> -7
u= ^
c >•
O)
w
"re
0
H
JS
§
IY1
LLI
S
H
5
'55
CO
0)
u.
1
H
•s
CD
0.
Q.
55
u
11
C W
Q. <
•B
"S
a.
E
0
O
CD
to
Q
c:
CD
Q.
t3
CO
•£
o
O
CN
t>-
0)
O)
(0
Q.
v>
0)
u
s
c
0)
Q.
Q.
-------
APPENDICES
Worksheet 4-1:* Potential Alternatives
Significant Environmental Aspect:
Baseline:
Baseline
Potential Alternatives
Products
Technologies
Work Practices
Recycling/
Reuse
Treatment
Disposal
Contact Person:
Date Completed:
* Document these results in Section AE of the Company Manual Template.
Appendices, page 73
-------
I
f-
1
0
a.
1
c
0
£M
g
o
1
T3
§
2
(/)
I
0
_|
C
n
i
CB
3
1
HI
0)
0
•+-1
r*
*••
0
tfl" I ^
•HO 1
0 H= 1
c™ """" c
J« /n in
w 42 -^
•^ O OJ CO
*•• S •—
O *ii "55 •=
^ m s .i
> 111 me/}
c
£
UJ
-
m
X
, o
||
£
1 i
C *- p
J2§ |1
S -o '? 0
ill a iS ill
•o
c
3
1
,_
<
1
E
o
O
(0
>1
n
1
2-
°- o
5" §
•8 £
OJ U
«1
Sg
(0
E
3
Z
Q
o
75
u
0
o
'"S
75
c
•o
a C
fiMJ
IliikJi
saojnos
•T 9 1
re
c
^3 o
< •-=
Q>
Dl
re
Q.
0)
0)
u
s.
-------
ENDICES
a.
a.
<
"S
n>
a.
1
&
m
a
1
a>
|contact P
o .= -g
"S 1 B 8 Iti
S 8|g Q
S. « E to «
£ ^-o-o £
. ,., .E .3^ g> C
3 £ TO E "S
S Si 5 s
2 §1"- 1
>S
El g|s§ £ &
(DOT S^gjC .00)
= « §••£•§ CD >< i
STS g^2a>.9 -So
-a c tt^ w = o c
^8 &S-8F S-8
E« S^2^ S 1
«J3 Eg.21 •£§
§ -2 g 3 1 . § c
g g 5 ffJI J3 S S
^ 3«^S |1
|1 gl|| |i
1? 1 Hi 1 !
.CO^ * TJ S5 «5 „: 9 Q.
i/is:^) ^c§;^£i_
Q«^ "5 5 1 1 •» g «
COx:§co-S2
xEoreajScfeg-S^e
|| |l!i«|!|!
•i-8cl||5Q!S.Mif
uJSiS^I-gglid
lll"iaa|5#EJ
0 E 0 -ffi « >>.w m = ^ g "S
liSjsi^?°J!l
"Zl^gfiE-ggSiS |
iiisliiiliil
(0^ O 2 -o
D)
m
a.
*\
0)
a.
a.
-------
11
Ul
in
a.
S
O
•o
cu
U)
o
a.
x
LLI
S.
E
o
o
,2
I
I
5 ™
E wr
73.
O
a.
CD
•B
..•s.
Q.
1
CO
•4-J
CD
TJ
D)
to
'
SB-
c u= *;
&
s
•B E
S>
g.
^ £2
2 S
w -o
s s
.E E
ai
"
CO
OT OS
OT
C
II
~ $
-------
APPENDICES
Worksheet: 4-4: Alternatives Evaluation: Community
Issues
Significant Environmental Aspect:
Alternative
Community Issues (List)
Contact Person:
Rank
Date:
Appendices, page 77
-------
APPENDICES
Worksheet: 4-5: Alternatives Evaluation: Natural
Resource Use
Significant Environmental Aspect:
Alternative
•
Natural Resources Used (List)
Contact Person:
Rank
Date:
Appendices, page 78
-------
•g
1
i
§
1
0
S_
>
C
LU
fl)
*!•
I
t.
4^
0)
Q
O
4-1
d
o>
6
c
+3
d
1
UJ
8
•i
^^^
fl)
•M t5
-s o>
rt
1 at
St 1
t> |
0) c
^ in
W .. c
^ 0) ffl
•f™ c o
k = «=
0 a> '£
5M «"
m (o
•c a>
§|z
Q. a
— 0)
2|
a> •g
•D
— Q)
^ j£
3 3
CO O
Z w
Q£
>•
IP
ill
0 —
O
,_
^ *J
o ^
§ OT
i^l
C
C JQ_
!ffi g uj
CO g« ^"
'5 w
i |A
•n = Q.
1 l«s
w » 5;;
2 1 m
•P "
^
S *• *a.
o •£ i2
SI
o c
« 0)
si
^3
j>
.2
i
1
>
•g
0)
Q.
O
O
(D
TO
Q
•j
O
s
B
a>
CD
s
i
s
1
r- O' «-
p "a w
«i ° «
S •£ g
Ǥ^i
O 3 •— *-*
-= co .—
O O .c
s-e g
- S w
CO
•a
QllJZ =
-------
w
LU
O
S
UJ
CL
85
M
£:
0)
'o
c
o
C/J
1
Q.
CM
O
O
0
c:
o
t ..
r? «
LL Q.
*. 3
S 5
1 c
4-1 c
0 2
0 >
^* III
(0 •£
Jid TO CD C=
i_ o e .0
O •= "m "5
•»» m " c
^ £> CO 3
> to m u.
0)
u
(Q
EC
O
O 'SS
I£H *3
fc" CD
0> 3
D- «
0)
O
0)
M
U—
O
i
LU
(1)
E
12
TI
1
4d
"33
Howw
$
Alternati
TJ
"S
Q.
O
0
CD
1
C
Cfl
OJ
Contact
•2
Q.
1
"S
3
C
f
t
O
0
(D
"o
UJ
c:
_o
(D
to
•—
J2
t/>
E
•g
CD
E
=3
O
o
Q
(V
O)
CC
Q.
w"
d>
(U
Q.
Q.
-------
OT
UJ
O
Q
Z
UJ
o.
Q.
CO
n\
1
ffj
c*
fli
SJj
^^
^
..
O
C
o
w
ffl
Q.
c
|[^
O
o
s_
O
J_J
13
3
O)
(D
DC
*
do
I
^
j_j
CD
0)
*
^:
o
o *
+J CC
"5 "5
0) >
0) UJ
°^ «
S oi
cu o
> c
O o
O
^.^
CO
o
0
^
o
™
3
CJ
.S
I
•J ni , .
D.O: jp.
= 0 ^
— c/>
0 to to
HI O O
f O ^
C 1. CD
M^
i||
CO
d>
O)
re
a.
tn
co
o
c
cu
Q.
Q.
-------
(0
UJ
o
5
§
In
o
o
0)
4
s
•a
3
^9 W
A 1
i |
•t*** C
0 S
0) >
.£ ID
0) •£
if s g
o ? f?
> .S 18
> to m
0)
S S w
^&3
at
3 15
3 .2
li. _1
0)
J
5
5
2
o
Di 0
o>
E
0)
0) O)
•*•* CB
II
c/>
s
5
0
•s
S.
5
IS
Alternative
•
1
t j
c
Contact pers
CO
0)
w
a)
u
T3
I
-------
APPENDICES
Worksheet 4-9b: Potential Annual Revenue Effects
Significant Environmental Aspect:
Baseline:
Alternative
Product
Throughput
Contact Person:
Product Quality
Reuse of or
Sales of
Recovered
Materials
Date:
Total Revenue
Effects
Appendices, page 83
-------
(0
LU
O
Q
UI
Q.
Q-
<
1
O
O
»^J
^mm
0
1
0
•a
P £
€Z
CO ~
•2£ CO .S co
> CO CD
c
— J2
f 1
h- O
0)
£
o
i
1
a.
"3. en
t!: !=
5 S
CO H
"c
3 %3
t/5 ^
5C in
£
e
o
1
CO
& 1
co a.
g
*^. «^
5> «
.=
u
S.
-------
APPENDICES
Worksheet 4-9d: Cost Comparison of Alternatives
Significant Environmental Aspect:
Baseline:
Alternative
Total
Operating
Costs
Total
Investment
Costs
Contact Person:
Annual
Revenue
Effects
Rank
Date:
Document results in Section AE of the Company Manual Template.
Appendices, page 85
-------
APPENDICES
Worksheet 4-1 0:* Evaluation of Alternatives
Significant Environmental Aspect:
Baseline:
Alternative
Products
Technologies
Work Practices
Recycle/Reuse
Treatment
Disposal
Performance
Rank1
Contact Person:
Regulatory
Rank2
Cost
Rank3
Environ-
mental
Effects4
Overall
Evaluation5
Date Completed:
*See Section AE of the Company Manual Template.
1 Take from Worksheet 4-7, Performance Comparison.
2 Take from Worksheet 4-8, Regulatory Cost Comparison.
3 Take from Worksheet 4-9d, Cost Comparison.
4 Take from Worksheet 4-4, Criteria to Determine Environmental Impact.
5 Rank on a scale of low to high to reflect the desirability of each product. This is a judgment
call.
Note: For more information on the methodology for comparing alternatives, refer to both the DfE
website and the Cleaner Technologies Substitutes Assessment, A Methodology Resource
Guide, DfE, U.S. EPA 744-R 95-002, Dec. 1996.
Appendices, page 86
-------
APPENDICES
Figure 5-a. Root Cause Diagram
c
'5
ii £
£ o
It
.ro t
e
a. a.
(0
TS
•c
o
IS
:J± 0>
"H O
8
O (D CO
a:1® E
,8)
'w
0)
X.
\
O
O
o
*»
'(5
N
o
A
(0
I
0)
Appendices, page 87
-------
M
•M
O
4-1
S
t3
C
i
1
3
ff\
m
CD
CM
•a
&
o
0)
£
O
O
-f3
5
T3
0)
to c
Q 0
0
to
_o
0)
S1
O
•s
0)
Q.
TJ
CD
•t-t
CD
Q.
O
O
TO
Q
C
o
tf\
Contact Pen
CO
CO
-------
V)
UJ
g
Q
UJ
Q.
Q.
0)
0
_J
c
+3
1_
^
!ffl
^ VI
f J
wx
cvi
w
0
"is
C/J
^>
b
S
IS
b.
l-o
c °
0) 4*^
EQ}
e
Q. .e
'5 *
o- '53
UJ -o
•o
0)
0)
3
c
1
Q.
'5
• o-
111
•a
o
I
a>
E
£
3
V)
(0
(B
IS
o
T3
•
•a
[P
CD
a.
o
O
0)
13
a
o
2
0)
a.
1 Contact
o>
to
0)
01
(0
Q.
to
8
0)
a
a.
-------
0)
B
0
z
o
1
^f
^*%
0)
Correctiv
*.
CO
10
1 Worksheet
(D
fo
Q
cu
Q
c
,0
•g
Q
to
•
1
Q
CD
1
Requested by:
Issued to:
Problem Statement:
w
CD
CO
CO
O
•53
o
JX
Suggested Solution;
1
CO
c
0
1
Measured Results:
JD
CO
Q
jj1
•o .
0)
CO
_o
Corrective Action C
1
"5.
E
8
•il
a
Contact for Notice:
•Si
•2
!
"co
3
§
the Company 1
c
o
<
o
1
CO
•c
O
Q.
CD
05
0)
O)
§.
0)
0)
Q.
Q.
-------
V)
III
o
Q
a.
a.
(0
Q)
3
£
o
4-»
CM
o
0
™?j
TO
o
;P
5
&
n
w
<
_
1
CD
*! ^, TJ
C +30)
O a> C
to
Q
1 Contact Person:
42
D
S.
5
•*•
*^,
0
5
s
|
5
O
CD
3
C
«
>
O
0
5
a.
)
)
5
J
-------
(0
w
o
a
u
a.
Q;
3
C
S
1
0
IP
15
Q)
csi
(0
*J
m
\1/
•C
C/7
yV
fe
j*^
^
L.
"o ^
C ^ w
§.•2 S
W •= C
w 2 o
te. E o
f
:=.
w
1
T3
O
8
Q.
13
S.
(J
^
*••
m
u
F
c
O)
w
•
•
•s
a.
o
0
(U
•*-*
Q
c
o
S2
(U
a.
•s
1
o
O
CM
O>
0)
O)
(0
a
a>
u
S
0)
a.
-------
UJ
o
Q
•z.
Ill
Q.
Q.
W
o
JJ
c
3
To
o
•45
1
o
Q.
O
s_
o
M-
Cu
E
0)
1
CO
(0
o
o
1
o
g
-r O
«• ^
o w'E
i °I
.0
"S «
"5. «
E Q
o
o
0)
•o
m
"2 *L
d> o)
5 _•
2
5
o
o> ...
c »
i z
i—
« Di
c -° -C
iir=
« a. o O
Q. w T
^£
3
•o
O
2
a.
i
(/)
"O
QJ
QJ
"a.
E
o
O
0)
1o
Q
c
o
2
0
Q.
t3
JS
c
o
O
CO
0>
0>
, D)
(Q
Q.
0)
O
0)
D.
Q.
-------
CO
UI
o
UJ
a.
«
•i
:|
<
1
CO
"5
3
•o
£
Q.
c
o
^
o
Q.
j2
1
H
|
c
S
'>
c
UJ
1
c
If
'i 1
iu a:
•+T
3
I
a.
w"
Ij
d) >_
Z 0
C
a
0
o
"S
1.
*
Q
t
CD
1
CO
s
CD
73
§
o>
I
CO
s
•
T3
^J
CD
a.
E
o
O
S
CO
Q
,
£
|
*s
CO
•£
0
O
a>
o>
f
a>
a.
-------
(0
Ul
o
Q
UJ
0.
Q.
D)
O
j?
^^
o
L.
1-
s
Vg
ro
B.
£
0
O
*
cvi
• •
o>
w
0
Worksh
i
8
c
.2
"5.
o 13
U Q
•£
tO
ts
^
I
OJ
o 13
U Q
1
ra
o
•5
o
a:
•u
ns
1
8 £
c 13
.2 a
11
o .c
O O
c
1
*3
O)
(2
Person
Responsible
ri
0)
O)
Q.
E
o
0
1
Q
if
Contact Perso
1
•5.
t
(U
l-i.
1
i
*5
^
1
s
0)
•4— 1
g
o
c
0
^
*Document resi
in
o
a>
O)
(0
Q.
aT
S
a.
Q.
-------
CO
UJ
o
"S
m
a.
Si
O)
0
-1
O)
1
d
i_
H
c
o
v^
^^
5?
J~
Q)
v«
Q.
C
0
¥3
3
O
Q.
. i
CO
1
N
0)
Q)
f*
Sm
V.
O
^^
^
«
'w
I!
0) 0>
^^ cc
c
(1)
e-o
w °
CQ ^<
(U 1)
w
i^
(/>
I£
•o
0)
r
43
CO
42
IS
Q
c
"c
CD
I
Q.
M
.2 g.
^ 0
OL <
*l
a c
£ o
<0
Completed
0)
Q
•&
ca
o
O
(O
o>
Q)
O)
CO
Q.
W
s
0)
Q.
Q.
-------
§
o
fr
0
QC
•n
§
8
(D
C
TJ
0
ra
0
Q.
0
ra
1?
0
i
3
C
0
£
d
&•
"^
c
Hi
^!
i
i^*
0
0
*
£
0
•o
0)
•o
1
0)
'E
2
T3
0)
T3
0)
0)
W
3
•a
0)
s
a.
•a
fi
'5
c
1
_
0)
1 ts
c o.
w E
(0
1
"o
a.
u
c
a>
O)
>- o
0) ~
E «
21 S
.2 °
I
o
a.
,
,
,
•
O)
0)
01
(0
Q.
w"
O
'•&
C
0)
Q.
a.
-------
I
5
2
LU
a.
§
n
D)
C
•2
ro
H
00
•g
«!
^ °-
> V)
0>
OH
C
tfS ...
J) OJ
0
"S
en
•o
3
ffl
•— £
0) D)
3 J
C
2
H
0
X
w
•a
s
D)
'E
S
?*
11
is
M '>
"o c
"^
•y
1
CL
E
8
•I
Q
o
S2
(D
D.
•s
CO
1=
o
O
CO
o
0)
D)
w
T3
0>
a
-------
O
4=
J3
^
§
£
3
O
O
Q
m m
CM
CO
+•»
Workshee
1 s
i i
o o
5=5
a> ra
111
"ra
llP
! 1° j
•2 o s
&
= o> IS
.S> c o
« is •»
w g o
0)
Si!
O > fl>
p . . "a
£ ^ E
^^ c o
•i 1 5
O ^ Q
Q **
..
IS "o
E 5
O ™™
UU ^"* ^^
a> £ E
•= 5 o
c a>
a> 'B
JS (w
0) Q
Q
List Existing
Documents
-
•*••.
^
-
**«,
^
-
•**.
^*"
^
-
••••,
""*"
^,
List Documents
to be Created
-
**^.
*""*
•
-
**+,
""""•
^
-
•»^.
^^
^^
-
. «*^.
"""^
^
-
**,.
*^*"
^_
•y
•SJ
CD
Q.
o
O
0)
15
Q
| Contact Person:
-2
15
I
K
1
i
^>
Q.
|
CD
zS
• 1 J
^
?
Corresponds to
0>
o>
0)
O)
ra
a.
(i
'•B
o
a.
a.
-------
w
UJ
o
Q
LU
a.
E
«••
"S
0
O
"tf
0)
£
0
O
Q
CO
CO
15
E
C/3
V1*
"£
0
5
-------
(0
111
o
S
tii
Q.
Q.
<
0)
/•h
Q)
73
O
0)
"^
55
^m
••Ml
•|
D)
3_
O
4f
00
JLJ
0)
0
•d
w
0
0)
c ^
o <2
J2 o
0> Q.
Q- v>
0)
a:
c
a>
^
||
CU _fm
O £ *^
0 X
o
E
-
ft
^
ts
i
E
0)
=
1^^
o
«
^*
,0
1
.2 ® In
•£ E £
0) C g)
*4^ O ^^
O *- C
Q. > —
LU
(A
a>
w 2
You
Stakeho
•y
CD
"S
Q.
E
o
O
^
Q
c
^
CD
D_
•5
2
o
0
^"
CD
1
|2
"CD
s
2
!
§
=
o
b
5
2
!:
-
D
0)
D)
(0
Q.
0)
u
s
0)
Q.
-------
APPENDICES
Worksheet 8-5: Stakeholder Communication Record
Date Communication Received:
Type of Communication:
Received From:
Address/Telephone Number/E-Mail:
Content of Communication
(attach copy if possible):
Will ABC Company Respond?
Date of Response:
Person Responding:
Nature of Response
(attach copy if possible):
Are Internal Actions Necessary?
(If Yes, fill out a Corrective Action
Form.)
Contact Person:
Y N
Y N
Date Completed:
Corresponds to CS-02 of the Company Manual Template.
Appendices, page 102
-------
APPENDICES
Worksheet 9-1: IEMS Program Measurement Criteria
Company Name
^"^s^^^ Measurement
^"""^^^ Elements
IEMS Components ^"""•-->^^
Communication Plan
Stakeholders Input
Environmental or IEMS Training
Review of Aspects
Operational Controls
Environmental Review of New
Processes and Activities
Setting Objectives & Targets
Environmental Management
Project 1
Environmental Management
Project 2
Documentation
Regulatory Compliance
Pollution Prevention
Other
Objectives of
Component
Activity
Measures
Results
Indicators
Review
Period
Contact person for form: Date Completed:
Appendices, page 103
-------
APPENDICES
Worksheet 9-2: Internal Assessment Checklist
nternal Assessment Team:
Date of Internal Assessment:.
Signed:
IEMS Procedures:
Check each item assessed, including auditing of records, where applicable (codes in
parentheses refer to the Worksheet number ("WS") in this Guide, followed by the
document number in the Company Manual Template.):
Environmental policy (Module 2)
Environmental objectives (progress; implementation of action plans)
_ IEMS responsibilities (WS 7-2, RESP-01)
Identification of Environmental Aspects (WS 1-5, P-EA)
Identification of Legal Requirements (WS 1-6, P-LR)
Identification of Significant Environmental Aspects (WS 3-3, WS 3-6, P-SEA)
Development of Objectives, Targets, and Action Plans (WS 5-1, P-OTP)
Conducting an Alternatives Evaluation (WS 4-1 to 4-6, P-AE)
Development of Operational Controls (WS 6-1 to 6-3, P-OC)
Environmental Training (Awareness and Task-Specific) (WS 8-1, P-ET)
Emergency Preparedness (WS 7-5, P-EP)
Review of New Products and Processes (WS 7-3, P-NPP)
Documentation (WS 8-2, WS 8-3, P-D)
Conducting a Compliance Assessment (WS 5-4, P-CA)
Conducting an Internal Assessment (WS 9-2, WS 9-3, P-IA)
_ Taking Corrective Action (WS 5-3, P-TCA)
Management Review (WS 9-4, P-MR)
IEMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person:
Date Completed:
Corresponds to LA-01 of the Company Manual Template.
Appendices, page 104
-------
APPENDICES
Worksheet 9-3: Internal Assessment Record
Internal Assessment Team:
Date of Internal Assessment:
Signed:
Major Non-Conformities Observed
1.
2.
Minor Non-Conformities Observed
1.
2.
3.
Is ABC Company making progress in meeting its IEMS objectives?
Is ABC Company adhering to the commitments in its environmental policy?
Suggestions for Improving IEMS:
Contact Person:
Date Completed:
Corresponds to IA-02 of the Company Manual Template.
Appendices, page 105
-------
-------
-------
------- |