United States
Environmental Protection
Agency
Office of the
Administrator
(2131)
EPA 233-B-00-003
May 2000
THE SMALL BUSINESS
SOURCE BOOK ON
ENVIRONMENTAL AUDITING

-------
  The Small Business
    Source Book on
Environmental Auditing
 U.S. Environmental Protection Agency
     Small Business Division
       Washington, DC
          May 2000

-------
NOTICE

This document has been prepared to assist those interested in environmental auditing for small
business. The document describes publicly available sources of information and training on
environmental auditing that, after review, appeared relevant to small business. This document does not
address all sources of information and training on environmental auditing.

The U.S. Environmental Protection Agency (EPA) does not make any guarantee or assume any liability
with respect to the use of any information contained in this document. It is recommended that users of
this document requiring additional information or advice consult a qualified professional.

The inclusion of commercial products and services in this document does not constitute an
endorsement by EPA.
                                            Page i

-------
ACKNOWLEDGEMENT

This document was prepared under the direction of the U.S. Environment Protection Agency's (EPA)
Small Business Division.  There were numerous reviewers from government and private organizations.
Additionally, the following provided important advice and/or reference materials:
•  Small Business Ombudsman, Maine Department of Environmental Protection
•  Tennessee Small Business Assistance Program
•  New Jersey Department of Environmental Protection
•  Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA)
•  Iowa Waste Reduction Center, University of Northern Iowa
•  Florida Small Business Assistance Program

The products and services included in this document were contributed for review by commercial and
government sources. The project team is thankful for their timely cooperation.
SUGGESTED IMPROVEMENTS

Although every reasonable effort was made to make this document useful to small business, it is
recognized that improvements are always possible. Comments and suggested improvements are
welcome and should be directed to:

                           U.S. Environmental Protection Agency
                                 Small Business Division
                                     Mail Code 2131
                                    Ariel Rios Building
                              1200 Pennsylvania Avenue, NW
                                 Washington, D.C.  20460
                                          Page ii

-------
TABLE OF CONTENTS

INTRODUCTION	1
CHAPTER 1: GENERAL INFORMATION	4
  1.1 SOURCES OF GENERAL AUDITING INFORMATION	4
CHAPTER 2: AUDIT STANDARDS AND GUIDANCE	7
  2.1 SOURCES OF AUDIT STANDARDS AND GUIDANCE	7
CHAPTERS: AUDIT CRITERIA	11
  3.1 NON-REGULATORY CRITERIA	11
  3.2 ENVIRONMENTAL REGULATORY CRITERIA	13
CHAPTER 4: AUDIT TOOLS	17
  4.1 PROTOCOLS AND CHECKLISTS	17
  4.2 SUPPORTING INFORMATION	28
CHAPTER 5: AUDIT TRAINING COURSES	39
  5.1 AUDIT COURSES TARGETED TOWARD AUDITING AND/OR SMALL BUSINESSES	39
  5.2 ISO 14001 AUDITING, ENVIRONMENTAL MANAGEMENT SYSTEMS AUDITING, AND RELATED
     AUDITING COURSES	40
                                  Page iii

-------
INTRODUCTION

The Small Business Source Book on Environmental Auditing (Source Book) provides information on
environmental auditing (auditing) resources relevant to small businesses. Large businesses have long
recognized the value of auditing as a tool that helps minimize liability, avoid compliance costs
associated with new projects, and identify opportunities for improved operating practices. However,
small businesses have been slower to accept auditing as a valuable business practice. The Source
Book should be useful to small business owners, representatives, and assistance providers to learn
about auditing practices and the value of auditing, by directing them to the most relevant sources of
information and training.

What Is Environmental Auditing?
EPA defines environmental auditing as a periodic, objective, and documented assessment of an
organization's operations compared to audit criteria. Audit criteria may be compliance requirements
such as regulations or may be management practices that benefit the environment.  In either case, an
audit provides information on the operational status of an organization compared to management's
environmental performance expectations. For example, if management expects the organization to be
in compliance with regulations, an audit will provide information on whether compliance has been
achieved or not, and if not, what specific measures are required to achieve compliance.

Why Conduct an Environmental Audit?
It is useful to think of an audit as a diagnostic exam and operations "tune-up." By conducting the exam
(i.e., audit), a business gains a better understanding of where its operations stand compared specified
criteria, such as compliance, management systems, or "greening." The audit will indicate what needs
to be done to allow operations to meet the criteria so a business can take action and improve its
efficiency. Like other "tune-ups," an audit should be performed periodically or whenever needed. Also,
for those not sufficiently knowledgeable, training or the services of an expert may be needed for advice
or troubleshooting in conducting an audit.

Source Book Organization
The Source Book has five chapters presented  in a sequence most would typically undertake to
understand auditing, develop an audit program, and conduct an audit.

Chapter 1 provides "overview" resources, such as general books, journal articles, and  case studies,
that will  help small businesses determine whether or not to conduct an audit.  These resources
describe audit programs, different types of audits, and lessons learned that will help small businesses
understand the scope of auditing and make decisions on the type of audit that may best apply to its
operations. The main benefit of these materials are that they contain information on all aspects of
auditing, or information on auditing within the context of environmental management systems.

Chapter 2 provides resources that will help small businesses establish a sound structure for an audit
program. These resources include auditing standards and guidance, as well  as information on auditor
qualifications. These documents are relatively short and provide essential information for designing an
audit program,  preparing for an audit, or evaluating outside consultants.  These documents also can be
used as planning checklists. The limitation of these documents is that they do not provide extensive
background information or learning tools. While these documents may be essential for starting up an
audit program,  those looking for a more in-depth understanding of auditing may need to seek additional
materials or training to supplement this knowledge base.
                                            Page 1

-------
Chapters 3, 4, and 5 provide information on resources that allow an organization to design its audit
program based on business goals and objectives.  Chapter 3 lists audit criteria, from the federal
regulatory requirements, to environmental management systems criteria of the International
Organization for Standardization (ISO). Chapter 4 lists sources of tools that combine the audit process
described by sources in Chapter 2 with the audit criteria information found in Chapter 3, thus guiding
the user through a review of a facility's operations against specified criteria. Chapter 4 includes
checklists and protocols, "how to" compliance assistance  materials, and audit data and environmental
program database information systems.  Finally, for those organizations that would like outside
assistance in  developing and implementing an audit program, Chapter 5 provides information on
publicly available audit training courses.

How the Information Is Presented
The Source Book  lists many sources of information applicable to small business audit programs. To
guide users of the Source Book, each chapter begins with a table that lists all sources contained in that
chapter, including  the author, publisher, date of publication, number of pages, price, and small business
auditing relevancy classification. The table is followed by short summaries of each source.  The
summaries describe the material, how it can be used, its benefits and limitations, and how to obtain
copies.  Each source has an icon to the left of its summary which indicates what type of resource the
item  is.  The following table indicates the icon designation for each source type.
          Icon
     Source Type
Icon
Source Type
                        Book/Booklet or Brochure
                                              Software
                        Checklist
                                              Standard/Guideline
                        Manual
                                              Training Course
        or
Reference Web site
              Web site
Each included source of auditing information is classified 1, 2 or 3 based on its relevance to small
business auditing. The criteria for each classification are as follows:
Relevance
Classification
1
2
3
Description
Most Relevant - Source is designed so that small businesses can easily extract portions
and apply it to its operations. Users of these sources require minimal previous auditing
experience.
Somewhat Relevant - Many portions of the source are relevant, but not all.
Less Relevant But Still Useful - Source has some portions useful to small businesses, but
the information may be more difficult to extract than from sources classified 1 or 2.
The usefulness of Source Book information to a particular business depends in part on the business
type and the business's commitment to environmental management.  Each of the sources included
should be useful to some small businesses, but there is not one source perfect for all.
                                            Page 2

-------
How the Information Was Obtained
Information was collected from state small business assistance providers, state environmental
agencies, professional auditing groups, trade associations, diverse sources on the Internet, and experts
in the auditing field from government, academia, and private organizations.  Potential Source Book
materials were reviewed to determine their applicability to auditing and relevance to small businesses.
All included sources are publicly available.
                                             PageS

-------
CHAPTER 1: GENERAL INFORMATION

When considering whether to conduct an audit or implement an audit program, many businesses
should first look to sources of information that will lead to a better understanding of the benefits and
limitations of auditing. These materials typically include books, journal articles, and case studies. They
describe audit programs, different types of audits, and lessons learned.  General information materials
provide background that will help small  businesses understand the scope of auditing and make
decisions on the type of audit that may best apply to its operations. These general information
materials are beneficial because they provide a broad overview. In some cases, materials are
prepared for a general audience and focus on auditing as one of many environmental  management
activities small  businesses could undertake for environmental management improvement.

1.1 Sources of General Auditing Information
Document Title
The EAR Bookshelf (Web
site of Auditing Book
Reviews)
Environmental Audits,
7th Edition
Iowa Audit Training Manual
ISO 14001 Environmental
Management Systems: A
Complete Implementation
Guide
Practical Guide to
Environmental
Management, 7th Edition
Author/Publisher/URL
Environmental, Health & Safety
Auditing Roundtable
www.auditear.org/bookstore.htm
Lawrence Cahill, Government
Institutes Publishing
www.govinst.com
Iowa Waste Reduction Center,
Department of Natural
Resources (IDNR)
www.iwrc.org
Environmental Resources
Management
Frank Friedman, Elf Atochem
North America, Inc.,
Environmental Law Institute
Date
1999
1996
2000
1999
1997
Number
of Pages
Web site
727
25, plus
appendices
800+
473
Relevance
2
3
1
2
3
Cost
Free
$79
Free
$370
$39.95
            EAR Bookshelf (Web site of Auditing Books and Book Reviews), Environmental, Health
& Safety Auditing Roundtable, 1999, Free, www.auditear.org/bookstore.htm

The EAR Bookshelf is a list of publications on auditing reviewed by the Environmental, Health & Safety
Auditing Roundtable (EAR) (formerly Environmental Auditing Roundtable).  The books were selected
based on their usefulness to those in the auditing profession and the book reviews provide more
detailed critiques than are available in this Source Book, as well as additional books unavailable for
review for the Source Book. The Web site expects to include books written by EAR members that
pertain to the environmental, health, and auditing field.  The book reviews are useful for small
businesses seeking professional critique prior to purchasing publications.
                                           Page 4

-------
        Environmental Audits, Seventh Edition, Lawrence Cahill, Government Institutes Publishing,
1996, 727pages, $79, Available atwww.govinst.com

This book provides an overview of environmental auditing, a description of the audit process and advice
on key issues, such as how to: select the audit team, use audit protocols and checklists, define audit
scope, gather information during the audit, and prepare an audit report that facilitates corrective action.
One section of the book describes specific types of environmental audits, including compliance,
management systems, waste contractor audits, property transfer audits, and pollution prevention
audits. The main challenge to small businesses in using this book is in determining which information
is most relevant to the small business's program. EAR critiques of this book (see
www.auditear.org/evnaud.htm) have suggested adding a glossary or index to make the book more user
friendly. Despite these limitations, the book has been referred to as one of the few sources of
comprehensive and general information on environmental auditing and environmental audit programs.
       Iowa Audit Training Manual, Iowa Waste Reduction Center (IWRC) and Iowa Department of
Natural Resources (IDNR), 2000, 25 pages plus appendices, Free, Available at www.iwrc.org

This concise manual introduces small businesses to the Iowa audit-disclosure policy and shows
businesses how auditing and the audit policy can be used. The training manual provides a step by step
walk through of the environmental compliance audit process, factors to consider when setting up an
audit, and specific factors to  consider when conducting an audit of local, state, and federal
environmental regulations that apply to businesses in Iowa.  The manual also shows businesses in
Iowa how they can take advantage of the newly promulgated Iowa self-audit law. The limitation of the
manual is that it does not describe how to audit specific environmental regulations.  The manual,
however, conducts a review of several regulations that apply to small businesses and notes how the
audit policy may, or may not, apply to the specific media area.  Overall, the document is useful to
businesses in Iowa who want to conduct audits under the Iowa policy. It is also applicable to
businesses outside of Iowa who would like more information on environmental auditing and potential
opportunities for disclosing audit findings  under environmental regulatory agencies (i.e., EPA, state
EPAs)  audit policies and the  findings within specified time periods.
        ISO 14001 Environmental Management Systems: A Complete Implementation Guide,
Environmental Resources Management, 1999, 800+ pages, $370 including four quarterly updates

This two-volume document walks the user through the process of understanding the ISO 14001
Environmental Management System (EMS) and provides tools for developing and implementing an ISO
14001 EMS. The document provides several case studies on how to implement ISO 14001 at facilities
ranging from small resorts to larger industries, based on typical environmental impacts and regulatory
requirements applicable to those operations. The document provides detail on aspects such as part-
time and contract employees, assigning environmental responsibilities to non-environmental staff, and
methods of ensuring that key equipment is calibrated. The document also contains several checklists
that can be used for self-auditing or to evaluate the scope of a third party auditing consultant. The
limitation of the document is that it does not include the actual ISO 14001  Standard. The document
does a thorough review of paraphrasing the Standard, and contains many detailed  case studies and
"recommended approaches" that make this one of the more comprehensive and useful  publications
available on ISO 14000.
                                           PageS

-------
       Practical Guide to Environmental Management, 7th Edition, Frank Friedman, ElfAtochem
North America, Inc., Environmental Law Institute, 1997, 473 pages, $39.95, For copies call (202) 939-
3800

This book provides practical knowledge of company environmental management programs based on
the experiences of the widely respected author at a large multinational chemical company. Included is
a 60-page chapter on auditing and its relation to a comprehensive environmental management
program.  Auditing topics include: benefits and risks (including legal issues associated with EPA and
the Securities and Exchange Commission),  key components of designing an effective auditing program
based on factors that EPA and industry have observed, methods of ensuring the integrity of the auditing
program,  and national and international auditing policies. The book is useful for practical information
regarding environmental auditing programs  and their role as part of larger environmental management
programs. The book provides substantial value to businesses developing environmental management
programs that include auditing.
                                           Page 6

-------
CHAPTER 2: AUDIT STANDARDS AND GUIDANCE
This chapter presents process or qualification standards for conducting audits. These documents are
relatively short and provide the user with essential information for designing an audit program,
preparing for an audit, or evaluating auditors. The strength of these documents is that they provide
information that is brief and easy-to-use.  These documents can be used as planning checklists. The
limitation of these documents is that they do not provide extensive background information or learning
tools.  Because they focus on the audit process or auditor qualifications, they also do not provide
information on environmental requirements (e.g., regulations). While these documents may be
essential for starting up an audit program, or understanding the components of an audit program, those
looking for more in-depth understanding of auditing may need to seek additional materials or training to
supplement this information.

2.1 Sources of Audit Standards and Guidance
Document Title
14010-96 ANSI/ISO Guidelines
for Environmental Auditing:
General Principles
1401 1-96 ANSI/ISO Guidelines
for Environmental Auditing:
Audit Procedures - Auditing of
Environmental Mgmt. Systems
14012-96 ANSI/ISO Guidelines
for Environmental Auditing:
Qualification Criteria for
Environmental Auditors
Application for Certified
Environmental Auditor
Board of Environmental Auditor
Certifications, EMS/ISO 14000-
Plus Qualification Criteria for
Environmental Auditors
Board of Environmental Auditor
Certifications, Qualification
Criteria for Environmental
Compliance Auditors
List of Environmental Air
Compliance Auditors for Small
Businesses
Standard Practice for
Environmental Regulatory
Compliance Audits
Standards for the Performance
of Environmental Health and
Safety Audits
Standards for the Professional
Practice of Environmental,
Health, and Safety Auditing
Publisher/URL
ASTM
www.astm.org
ASTM
www.astm.org
ASTM
www.astm.org
Canadian Environmental
Auditing Association
www.ceaa-acve.ca/
certification.html
Board of Environmental
Auditor Certifications
www.beac.org
Board of Environmental
Auditor Certifications
www.beac.org
New Jersey Small Business
Assistance Program
www.state.nj.us/dep/
opppc/AUDGUID9.htm
ASTM
www.astm.org
Environmental Health and
Safety Roundtable
www.auditear.org
Board of Environmental
Auditor Certifications
www.beac.org
Date
1996
1996
1996
1999
1999
1999
1999
2000
1993
1999
Number
of Pages
4
6
6
34
2
6
10 pages,
plus a list
of auditors
12
5
18
Relevance
2
2
2
2
2
2
1
2
2
2
Cost
$27
$27
$27
Free
Free
Free
Free
New-
Price
Unknown
Free
Free
                                          Page 7

-------
          14010-96 ANSI/ISO Guidelines for Environmental Auditing: General Principles,
American Society for Testing and Materials, 1996, 4 pages, $27, Available at www.astm.org or by
calling (610) 832-9585

This guideline provides the general principles of auditing that are applicable to ISO 14001 audits. Any
activity defined as an ISO 14001  environmental audit should meet the criteria in the ISO 14010
guideline. It is useful for small businesses that would like to understand the principles of auditing;
however, this information may also be available in other sources about auditing that contain information
with more extensive background.
          14011-96 ANSI/ISO Guidelines for Environmental Auditing - Audit Procedures -
Auditing of Environmental Management Systems, American Society for Testing and Materials,
1996, 6 pages, $27, Available at www.astm.org or by calling (610) 832-9585

The ISO 14011 International Standard establishes audit procedures that provide for planning and
conducting an audit of an EMS to determine conformance with  EMS audit criteria. It is useful for
businesses that would like to  plan for or conduct audits of environmental management criteria and
assure that the audit meets the standards of ISO 14011.
          14012-96 ANSI/ISO Guidelines for Environmental Auditing: Qualification
Criteria for Environmental Auditors, American Society for Testing and Materials, 1999, 6 pages, $27,
Available at www.astm.org or by calling (610) 832-9585

This guideline provides guidance on qualification criteria for environmental auditors and lead auditors
and is applicable to both internal and external auditors. It should help small businesses evaluate
minimum qualifications for environmental auditors that conduct ISO 14000 audits.  The limitations of
this document are that it does not establish criteria for the selection and composition of audit teams,  nor
does it specify qualifications for media-specific audits, compliance audits, or industry-specific audits.
For further information on audit teams, reference is made to ISO 14011.
         ' Application for Certified Environmental Auditor (including qualification criteria),
Canadian Environmental Auditing Association, 1999, 34 pages, Free, Available at www.ceaa-
acve. ca/Certification, html

The 34-page application includes the standards for a Certified Environmental Auditor. The standards
include minimum criteria for professional experience, auditing experience, training, and personal
attributes and skills.  The standards in the application are useful for small businesses to compare with
the qualifications of auditors.  The limitation of the standards is similar to that of others, in that criteria
do not include experience in a particular industry that might be most useful for small business.  Still, the
application is an easy source of professional qualification standards to obtain and use for evaluating
auditors.
                                            PageS

-------
          Board of Environmental Auditor Certifications, EMS/ISO 14000-Plus Qualification
Criteria for Environmental Auditors, Board of Environmental Auditor Certifications (BEAC), 1999, 2
pages, Free, Available at www.beac.org

The Qualification Criteria provide the minimum  level of education, professional experience, audit
experience, training, references, and testing for BEAC environmental auditor certification for those
auditors conducting audits against ISO 14000 or Environmental Management Systems Criteria.  The
Qualification Criteria for EMS/ISO 14001-Plus Auditors is useful for small businesses to compare with
the qualifications of consultants, or to be aware of the qualifications of BEAC-certified auditors. The
limitation of these criteria is similar to that of other audit certifications, in that the criteria do not include
experience in a particular industry that might be most useful for the small business.  Still, the
Qualification Criteria are an easy source to obtain and use for evaluating auditors.
          Board of Environmental Auditor Certifications, Qualification Criteria for
Environmental Compliance Auditors, Board of Environmental Auditor Certifications (BEAC), 1999, 6
pages, Free, Available at www.beac.org

The Qualification Criteria provide the minimum level of education, professional experience, audit
experience, training, references, and testing for BEAC environmental auditor certification. The
Qualification Criteria for Environmental Compliance Auditors is useful for small businesses to compare
with the qualifications of auditors, or to be aware of the qualifications of BEAC-certified auditors. The
limitation of these criteria is similar to that of other audit certifications, in that the criteria do not include
experience in a particular industry that might be most useful for the small business.  Still, the
Qualification Criteria are an easy source to obtain and use for evaluating auditors.
          List of Environmental Air Compliance Auditors for Small Businesses, New Jersey
Small Business Assistance Program, Office of Pollution Prevention and Permit Coordination, 1999, 10
pages of auditor qualifications and auditor selection criteria, plus a list of auditors, Free, Available at
www.state.nj.us/dep/opppc/AUDGUID9.htm or by calling (877) 753-1151 or (609) 292-3600

This document provides the required qualifications for an air compliance auditor for small businesses in
New Jersey. Qualifications include professional experience, education, and specialized seminars
related to air compliance auditing. These qualifications can be used to evaluate businesses that are
considering hiring an outside auditor to review their operations with respect to air compliance. The
document also provides guidance for small businesses in selecting an auditor, developing and
negotiating contracts, and building a relationship with the auditor to assure that the needs of the small
business are met. Despite its focus on New Jersey, the qualifications and the criteria are useful for any
small business that needs to evaluate or select an auditor for conducting an audit against air
compliance criteria.
                                             PageS

-------
          Standard Practice for Environmental Regulatory Compliance Audits, American Society
for Testing and Materials, 2000, 12 pages, New Standard - Price Unknown, Available at www.astm.org
or by calling (610) 832-9585

This 12-page document is a voluntary consensus standard for conducting environmental regulatory
compliance audits. It describes the audit process that distinguishes environmental compliance audits
from less formal evaluations and other types of audits.  It addresses auditor independence; professional
proficiency of the auditor, audit team and audit process; required elements of each audit; audit scope;
definitions; and legal considerations. The document is useful for small businesses that would like to
understand a standard audit process, to evaluate proficiency of auditors, and to plan their own audits.
This document may be an essential first step for small businesses that intend to commence a formal
audit program that meets nationally recognized auditing standards. The standardized terms and
definitions and description of roles and responsibilities are especially useful as a reference when
discussing audits with others.
          Standards for the Performance of Environmental, Health and Safety Audits,
Environmental, Health and Safety Roundtable, 1993, 5 pages, Free, Copies can be obtained by
sending your request via E-mail to KathyEAR@aol.com or calling (480) 659-3738

These standards were developed by members to provide minimum criteria for the conduct of
environmental, health and safety audits.  Included are general standards on auditor proficiency, due
professional care and independence, the conduct of audits, and audit reporting. The EHSAR may
make available its list of members who subscribe to these and other EHSAR standards.
          Standards for the Professional Practice of Environmental, Health, and Safety
Auditing, Board of Environmental Auditor Certifications, 1999, 18 pages, Free, Available at
www.beac.org

This 18-page document provides standards BEAC members on environmental, health, and safety
auditing.  It describes requirements for auditor independence; professional proficiency of the auditor,
audit team, and audit process; required elements of each audit; determining audit scope; managing the
audit function in an organization or business; and definitions.  The document is useful for small
businesses that would like to understand the BEAC audit process, to evaluate proficiency of external
auditors and consultants, and to use as a guide for planning audits.
                                           Page 10

-------
CHAPTER 3: AUDIT CRITERIA

In contrast to audit standards (Chapter 2), which define how an audit should be conducted, audit criteria
define how the small business should be, or would like to be, operating. These criteria include regulatory
requirements, such as federal, state, or local laws and regulations.  They also include non-regulatory
criteria such as environmental management systems standards, best management practices for
businesses and agriculture, green product standards, or sustainable practice standards.  Note that
despite being not required, many of the "beyond compliance" criteria are crucial to the safe and efficient
operation of a facility. Beyond compliance criteria in areas such as energy efficiency or environmental
management systems (EMS) can reduce operating costs, allow small businesses to reduce their
compliance requirements, and allow small businesses to constantly identify areas where  environmental
impact can be reduced.  Furthermore, many businesses that generate hazardous waste are required by
federal or state law to reduce the quantities of waste generated through pollution prevention.  Thus,
pollution prevention and EMS audit criteria provide opportunities for satisfying these requirements.

3.1 Non-regulatory Criteria

Non-regulatory criteria define particular attributes of an organization's environmental program or specific
environmental activities.  While non-regulatory criteria may, in some cases, be developed by a
government agency, the non-regulatory criteria usually describe optional activities.  In auditing, non-
regulatory criteria include environmental management systems, pollution prevention practices, or green
product attributes.
Document Title
14001-96 ANSI/ISO Environmental
Management Systems -
Specification with Guidance for Use
14004-96 ANSI/ISO Environmental
Management Systems - General
Guidelines on Principles, Systems,
and Supporting Techniques
Compliance Focused
Environmental Management
System-Enforcement Agreement
Guidance
EPA Region I Star Track Program
Leadership Through Environmental
Management Systems and
Compliance Auditing
Green Seal Standards for
Environmentally Friendly Products
Publisher/URL
ASTM
www.astm.org
ASTM
www.astm.org
U.S. EPA
http://es.epa.gov/
oeca/oceft/neic/
12elmen.pdf or
http://es.epa.gov/
oeca/oceft/neic/
pubstxt.html
U.S. EPA Region I
www.epa.gov/
regiond /steward/
strack/applicat.html
Green Seal
www.greenseal.org
Date
1996
1996
1997
1998
1992-
1999
Number of
Pages
14
31
15
6
2-5 pages
each
Relevance
2
2
2
2
1
Cost
$39
$47
Free
Free
Free
          14001-96 ANSI/ISO Environmental Management Systems - Specification with Guidance
for Use, American Society for Testing and Materials,  1996, 14 pages, $39, Available at www.astm.org

ISO 14001 is an International Standard that can be used as audit criteria for conducting audits of a
facility or organization's environmental management system.  This document specifies requirements for
                                            Page 11

-------
an environmental management system, to enable an organization to formulate a policy and objectives
taking into account legislative requirements and information about significant environmental impacts. It
applies to those environmental aspects which the organization can control and over which it can be
expected to have an influence.  It does not itself state specific environmental performance criteria.

In addition to its use as audit criteria, the Standard allows small businesses to seek certification, or self-
declare its conformance to the Standard. Some small businesses have used ISO 14001 EMSs to
distinguish themselves in their market. The limitation of this document is that it contains little guidance
on how to implement the ISO 14001 requirements and limited information on how to conduct an audit
against these requirements. This Standard is equally applicable to large and small businesses, although
some small businesses have expressed the concern that the formal documentation of environmental
activities required by the Standard places an unreasonable resource burden on them.
          14004-96 ANSI/ISO Environmental Management Systems - General Guidelines on
Principles, Systems, and Supporting Techniques, American Society for Testing and Materials, 1996,
31 pages, $47, Available at www.astm.org or by calling (610) 832-9585

ISO 14004 complements ISO 14001 by providing guidance on how a company can implement ISO
14001 and on how to audit a facility against the ISO 14001 criteria. The document provides examples
that complement each item in the 14001 Standard. For example, ISO 14001 states that a facility should
identify the aspects of its operations that may impact the environment, while ISO 14004 describes the
different operations of a facility that may impact the environment.

The ISO 14004 guideline is useful for those who would like more information on the ISO environmental
management system standards than can be found in 14001.  In the absence of ISO 14001, the 14004
Standard is a useful planning tool,  perhaps more useful than 14001 since 14001 provides only what
information and programs are necessary, not how that information or program might be developed and
organized. The limitation of ISO 14004 as audit criteria is that ISO 14004 does not contain the exact ISO
14001 criteria.  Thus, facilities looking to achieve ISO 14001 certification (there is no ISO 14004
certification) would be required to look at both documents.  Nevertheless, for those facilities looking to
develop an ISO 14001 EMS and review their EMS against the ISO criteria, ISO 14004 provides all the
information  necessary to get the facility through the certification process.
          Compliance Focused Environmental Management System - Enforcement Agreement
Guidance, Steve Sisk, U.S. EPA National Enforcement Investigation Center (NEIC), 1997,  15pages,
Free, Available at http://es.epa.gov/oeca/oceft/neic/12elmen.pdfor
http://es.epa.gov/oeca/oceft/neic/pubstxt.html

NEIC's Compliance Focused Environmental Management System provides a set of environmental
management system (EMS) criteria recognized by U.S. EPA as having a specific emphasis on regulatory
compliance. The EMS contains the traditional components of a strong environmental management
program, including setting an environmental policy, developing targets and objectives, defining
environmental roles and responsibilities, measuring performance, and conducting periodic internal
inspections and reviews. The NEIC EMS criteria are more explicit in their compliance and pollution
prevention focus than ISO 14001.  The criteria list 12 elements of an EMS that are similar to ISO 14001.
In addition to the criteria, the document contains guidance for regulators on the time period  necessary to
implement an EMS. The document is useful to small and medium-sized businesses that would like to
audit their EMS or assure that an audit of their EMS includes a review of compliance management.


                                           Page 12

-------
         1 EPA Region I Star Track Program Leadership Through Environmental Management
Systems and Compliance Auditing, U.S. EPA Region I, 1998, 6 pages, Free, Available at
www.epa.gov/region01/steward/strack/applicat.html

The EPA Star Track Program was designed to recognize companies that have demonstrated leadership
in their environmental management programs through establishing an environmental management
system,  maintaining a strong record of complying with environmental laws and regulations, and
implementing pollution prevention in business operations. The Star Track Program requires periodic
auditing.  The document is the application package that businesses are required to complete to be
considered for the program. The document is useful for small businesses interested  in a review of the
components of EPA-recognized environmental management programs.  The limitation of the document is
the small amount of detail compared to other criteria.  Its main use is to improve understanding and
assist in planning to incorporate components of a strong environmental management program into
business operations. For small businesses in EPA Region I (New England), the criteria also provides
information on an opportunity to achieve recognition for a formal environmental management program.
          Green Seal Standards for Environmentally Friendly Products, Green Seal, 1992-1999, 2-
5 pages each, Free, Available at www.greenseal.org

Green Seal is a nonprofit standard-setting organization that evaluates products and awards a Green Seal
Certification Mark to products that meet their standards. As of January 1999, Green Seal had
established standards for the following products:
•  Tissue Paper (GS-01)                       •   Clothes Washers (GS-22)
•  Re-Refined Engine Oil  (GS-03)               •   Clothes Dryers (GS-23)
•  Compact Fluorescent Lamps (GS-05)         •   Dishwashers (GS-24)
•  Water Efficient Fixtures (GS-06)              •   Cooktops/Ovens/Ranges (GS-25)
•  Printing and Writing Paper (GS-07)            •   Watering Hoses (GC-01)
•  Household Cleaners (GS-08)                 •   Alternative  Fueled Vehicles (GC-02)
•  Paper Towels and Paper Napkins (GS-09)     •   Plastics Labeling Systems (GC-04)
•  Coated Printing Paper  (GS-10)               •   Showerheads (GC-06)
•  Paints (GS-11)                             •   Paper Products Used in the Preparation of
•  Windows (GS-13)                              Food (GC-08)
•  Newsprint (GS-15)                         •   Residential Air Conditioning Systems (GC-09)
•  Reusable Utility Bags (GS-16)               •   Fleet Vehicle Maintenance (GC-10)
•  Refrigerators (GS-20)                       •   Powdered Laundry Bleach (GC-11)
•  Freezers (GS-21)                          •   Anti-Corrosive Paints (GC-03)
                                             •   Window Films (GS-14)

These standards are useful for small businesses in auditing procurement practices against green product
standards.  For small businesses that produce such materials, these standards are useful as audit
criteria to determine the extent to which the small business' products are environmentally friendly.

3.2 Environmental Regulatory Criteria

Regulatory criteria are those that a business is required to meet under federal, state,  local or tribal law.
This section provides an overview of the major federal environmental regulations that may apply to small
businesses.  The citations  in this section may be one of the later references to which  small businesses

                                           Page 13

-------
turns to during their environmental program development, since compliance assistance tools and
protocols are often easier to use. The sections of the Code of Federal Regulations (CFR) described
below can be  used as a guide to EPA regulatory requirements.  The regulatory requirements can be
used as minimum audit criteria for facilities that may be subject to federal environmental regulations.  Be
aware that most small businesses are subject to many state, local, and/or tribal requirements that are
not included in this Source Book. State environmental requirements can be obtained from the Small
Business Assistance Program or Small Business Ombudsman in each state, or the state offices of
environmental protection.  Local requirements can be obtained from local government offices such as the
department of public works, health,  sanitation, or sewer authorities.
Document Title
Code of Federal Regulations -
Refrigerants - CFC Air Pollution
Control Requirements, 40 CFR 82
Code of Federal Regulations - Oil
Spill Planning, 40 CFR 112
Code of Federal Regulations -
Direct Discharge Permitting
Requirements,
40 CFR 122
Code of Federal Regulations -
Management of Pesticides, 40
CFR 150-1 86
Code of Federal Regulations -
Hazardous Waste Management,
40 CFR 260-273
Code of Federal Regulations -
Used Oil Management, 40 Part
279
Code of Federal Regulations -
Underground Storage Tanks,
40 CFR 280
Code of Federal Regulations -
Emergency Planning,
40 CFR 355, 370, and 372
Code of Federal Regulations -
Pretreatment Requirements,
40 CFR 403
Code of Federal Regulations -
Toxic Substances Management,
40 CFR 761
Publisher/URL
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l. info/b
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
U.S. Gov't. Printing Office
www.epa.gov/epacfr40/chapt-l.info/
Date
1999
1999
1999
1999
1999
1999
1999
1999
1999
1999
Relevance
2
2
2
2
2
2
2
2
2
2
Cost
Free
Free
Free
Free
Free
Free
Free
Free
Free
Free
          Code of Federal Regulations - Refrigerants - CFC Air Pollution Control Requirements,
40 CFR 82., U.S. Government Printing Office, 1999, Free, Available at www.epa.gov/epacfr40/chapt-
l.info/

This section of the CFR provides regulatory requirements for managing equipment that contains ozone
depleteing substances such as refrigerants (cloroflourocarbons or CFCs).  It includes requirements for
leak detection, certifying technicians who perform work on vehicle and non-vehicle refrigeration
equipment, and  certifying equipment used to recover or recycle CFCs.
                                            Page 14

-------
          Code of Federal Regulations - Oil Spill Planning, 40 CFR 112, U.S. Government Printing
Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria in
determining whether a small business is required to develop and implement a spill prevention control and
countermeasures (SPCC) plan. The criteria also includes required components of the plan. These
requirements are useful as regulatory criteria for any small business that may use or store petroleum
products and/or vegetable oils in quantities approaching or exceeding 1320 gallons, or as best
management practice criteria for facilities that have smaller amount of these substances.
          Code of Federal Regulations - Direct Discharge Permitting Requirements, 40 CFR 122
and Effluent Guidelines 40 CFR 400-471, U.S. Government Printing Office, 1999, Free, Available at
www. epa. gov/epacfr40/chapt-l. info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for facilities
that discharge wastewater directly to waterways, culverts, streams, or any method other than an
underground injection or to a sanitary sewer system.  The criteria in this section includes requirements
for obtaining permits, effluent limitations by industry, and permitting requirements for discharges of
contaminated storm water.
          Code of Federal Regulations - Management of Pesticides, 40 CFR 150-186, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for small
businesses that store, manufacture, or apply pesticides.  The sections may be most useful to small
businesses include Parts165 (pesticide disposal), Part 166 (storage), Part 171, certification of pesticide
applicators, and Parts 180-187 (pesticides in food and animal feed). The remaining sections focus on
pesticide registration and packaging procedures for facilities that manufacturer or package pesticides.
          Code of Federal Regulations - Hazardous Waste Management, 40 CFR 260-273, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria in the
following areas: determining whether a waste is a hazardous waste, storing, labeling, and shipping
hazardous waste containers, hazardous waste manifests, hazardous waste recycling and treatment,
special requirements and exemptions for small quantity generators of hazardous wastes, and managing
universal wastes (batteries, fluorescent lamps).  The requirements most applicable to small businesses
are likely to be found in 40 CFR 261, 262, and 273.
          Code of Federal Regulations - Used Oil Management, 40 CFR 279, U.S. Government
Printing Office, 1999, Free, Available at www.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for facilities
that generate, store, collect,  transport, or burn used oil.  Requirements contained in this section include

                                            Page 15

-------
management and labeling of containers, where and how used oil can be burned for energy, and limits on
transportation with and without a permit.
          Code of Federal Regulations - Underground Storage Tanks, 40 CFR 280, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for facilities
that own or operate underground tanks that store oil, fuels, or otherwise hazardous substances.
Requirements contained in this section include the definition of an underground storage tank,
requirements for tank materials, monitoring, inspections, recordkeeping, and financial assurance.
          Code of Federal Regulations - Emergency Planning, 40 CFR 355, 370, and 372, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for facilities
that store, use, or manufacture hazardous chemicals.  Part 302 includes a list of reportable quantities
and notification requirements for reporting releases or spills of hazardous materials, such as chemicals,
metals, oils, or pesticides.  Part 355 includes requirements for notifying local emergencies planning
agencies for facilities that use, dispose, or release certain quantities of hazardous substances. Part 370
and 372 include requirements for notifying state and local emergency planning agencies for facilities that
store certain quantities of hazardous chemicals.
          Code of Federal Regulations - Pretreatment Requirements, 40 CFR 403, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria to evaluate
whether facilities that discharge wastewater to a public sanitary sewer system are meeting discharge
requirements.  Combined with 40 CFR 122, this section provides limitations for these discharges based
on the Standard Industrial Classification (SIC) code of the small business.
          Code of Federal Regulations - Toxic Substances Management, 40 CFR 761, U.S.
Government Printing Office, 1999, Free, Available atwww.epa.gov/epacfr40/chapt-l.info/

This section of the CFR provides regulatory requirements that can be used as audit criteria for facilities
that store or used materials containing asbestos, lead, polychlorinated biphenyls (PCBs), and other toxic
substances. It includes requirements for protecting workers and other people who may come in contact
with toxic substances, including reporting, labeling, handling, and disposal requirements.
                                            Page 16

-------
CHAPTER 4: AUDIT TOOLS

Audit tools are used to support or implement an audit program. Tools may include audit checklists or
protocols that present audit criteria in a format that allows easier use by the auditor.  Tools may also
include audit finding ranking systems, compliance assistance documents or software, or any other
material that the auditor would use during the audit process, not described in the other chapters.

4.1 Protocols and Checklists
Document Title
Business Guide for Reducing
Solid Waste
Choosing an Environmental
Consultant, Guidance for
Small Businesses
Consolidated Screening
Checklist for Automotive
Repair Facilities and Checklist
Guidebook
Environmental Auditing,
California Compliance Guide
Environmental Auditing,
Federal Compliance Guide
Environmental Management
Guide for Small Laboratories
The Environmental Self-Audit
for Small Business: A Quick
and Easy Guide to
Environmental Compliance
Environmental Self-Evaluation
Guide for Small Business, Tool
#1 : A Practical Guide to
Environmental Compliance
Green Seal Choose Green
Report, Energy Efficient Indoor
Lighting
Green Seal Choose Green
Report, General Purpose
Cleaners
Green Seal Choose Green
Report, Lawn Care Equipment
Green Seal Choose Green
Report, Office Products
Green Seal Choose Green
Report, Vehicle Maintenance
ISO 14001 Mini Gap Analysis
Managing Chemicals Safely,
Putting It All Together
Author/Publisher/URL
U.S. EPA
www.epa.gov
New York State Environmental
Facilities Corporation, Small
Business Assistance Program
U.S. EPA
www.ccar-greenlink.org
Environmental Resources
Management, Specialty
Technical Publishers
Environmental Resources
Management, Specialty
Technical Publishers
U.S. EPA
www.epa.gov/smallbusiness/
help. htm
New York State Small Business
Environmental Ombudsman,
www.empire.state.ny.us/
sbeo/default.htm
Pennsylvania Department of
Environmental Protection
www.dep.state.pa.us
Green Seal
www.greenseal.org
Green Seal
www.greenseal.org
Green Seal
www.greenseal.org
Green Seal
www.greenseal.org
Green Seal
www.greenseal.org
Transformation Strategies
www.trst.com/gapanal.htm
Chemical Education Foundation
www.chemed.org
Date
1993
1999
1997
1999
1999
1998
1994
1996
1997
1998
1998
1997
1996
1998
1996
Number of
Pages
41, plus
worksheets
29
32
350+
365+
53
30
38
9
7
7
5
4
Web site
24
Relevance
1
1
1
2
2
1
1
1
1
1
1
1
1
2
3
Cost
Free
Free
Free
$365
$419
Free
Free
Free
Free
Free
Free
Free
Free
Free
$1.25
                                          Page 17

-------
Document Title
Mercury: Managing, Recycling,
Disposing - A Business Guide
to Conducting a Mercury Audit
Motor Vehicle Repair
Facilities: Model Facility Guide
Multimedia Inspection
Checklist
Protocol for Conducting
Environmental Compliance
Audits of Hazardous Waste
Generators Under the
Resource Conservation and
Recovery Act
Protocol for Conducting
Environmental Compliance
Audits of Treatment Storage
and Disposal Facilities Under
the Resource Conservation
and Recovery Act
Protocol for Conducting
Environmental Compliance
Audits Under the
Comprehensive Environmental
Response, Compensation, and
Liability Act
Protocol for Conducting
Environmental Compliance
Audits Under the Emergency
Planning and Community
Right-to-Know Act
A Self-Assessment Workbook
for Small Manufacturers
A Self-Audit Checklist for Dry
Cleaners
The Small Business
Environmental Assistance Site
Visit Manual
Waste Minimization Plan for
Small Quantity Generators as
Required by the Mississippi
Comprehensive Multimedia
Waste Minimization Act of
1990
Author/Publisher/URL
PA Department of
Environmental Protection
www.dep.state.pa.us
Maine Department of
Environmental Protection
State of Tennessee, Dept. of
Environmental and
Conservation
U.S. EPA
www.epa.gov/oeac/ccsmd/
profile.html
U.S. EPA
www.epa.gov/oeac/ccsmd/
profile.html
U.S. EPA
www.epa.gov/oeac/ccsmd/
profile.html
U.S. EPA
www.epa.gov/oeac/ccsmd/
profile.html
Rutgers, The State University of
New Jersey, Office of Industrial
Productivity and Energy
Assessment
http://oipea-www.rutgers.edu/
documents/doc f.html
Pennsylvania Department of
Environmental Protection
(www.dep.state.pa.us), Office
of Pollution Prevention and
Compliance Assistance
Iowa Waste Reduction Center,
University of Northern Iowa
Mississippi Department of
Environmental Quality
www.deq.state.ms.us/newweb/
homepages. nsf
Date
1999
1999
1999
1998
1998
1998
1998
1998
1997
1999
1998
Number of
Pages
4
26
5
72, plus
appendices
112, plus
appendices
45
12, plus
appendices
83
4
64
6
Relevance
1
1
1
2
2
2
2
1
1
1
1
Cost
Free
Free
Free
Free
Free
Free
Free
Free
Free
Free
Free
Page 18

-------
        Business Guide for Reducing Solid Waste, U.S. EPA, Office of Solid Waste and Emergency
Response, November 1993, 41 pages plus worksheets, Free, Available at www.epa.gov-Search by
document number: EPA/530-K-92-004

This document provides background information on waste reduction and recycling, a description on how
to develop a waste reduction program, a walk-through of the waste assessment process, and potential
options for implementing solutions to issues discovered in the waste assessment.  The document is
useful to facilities that would like to implement an audit program that includes assessments of solid waste
management activities compared to environmental management systems criteria (components of a
successful solid waste program), and best management practice criteria (waste reduction, recycling,
composting, purchasing, and implementation options). The document also provides information useful
as audit standards guiding the  reader through the steps in the waste assessment process. The
worksheets at the end of the document provide a framework for determining  waste generation and
calculating costs, current waste reduction activities, targets for further reduction, and implementation
options. The limitation of the document is that the user may  need to seek technical assistance for
exploring specific technical opportunities for waste reduction once the assessment is complete. Still, the
document provides a useful framework for the waste reduction program. If backed by information on
specific opportunities, it  provides a valuable resource for those businesses interested in a sustainable
waste reduction program.
        Choosing an Environmental Consultant, Guidance for Small Businesses, New York State
Environmental Facilities Corporation, Small Business Assistance Program,  1999, 29 pages, Free,
A vailable by calling (800) 882-9712 or (518) 457-4100 (NY Small Business Assistance Office main
number is (800) 780-7227)

This booklet provides information on factors to consider when small businesses decides to retain an
environmental consultant.  It discusses when a consultant might be useful, steps for hiring the consultant,
locating consultants, preparing a request for proposal, reviewing proposals, the proposed working
relationship between the business and the consultant, contracts,  potential problems, and assuring a
positive ongoing relationship after the work is complete. The document does not provide examples of
specific projects or a list of consultants.  However, it does provide sources where the small business may
locate consultants, and provides tools that could be useful for auditing and compliance assistance
projects. The document complements some of the auditing standards (see Chapter 2) which identify key
characteristics of those qualified to conduct environmental audits.
      Consolidated Screening Checklist for Automotive Repair Facilities and Checklist
Guidebook, U.S. EPA, December 1997, 32 pages, Free, Available atwww.ccar-greenlink.org, E-mail:
ccarinfo@unicom.net, or by calling (888) GRN-LINK (476- 5465) or (913) 498-2227

This document provides a two-page checklist for automotive repair and auto body shops to evaluate a
comprehensive list of environmental requirements including used oil, air conditioner repair, antifreeze
recycling, solvent use, underground storage tanks, vehicle washing, storm water management, and other
issues. The checklist is accompanied by a 30-page guide that explains each question and the answers
that auto repair facilities can strive for to maintain compliance  and/or prevent pollution. The document is
useful for vehicle repair, equipment repair, and other maintenance activities at other small businesses.
The major benefit of the document is that it provides a comprehensive list of major requirements that
apply to auto repair activities in an easy-to-use checklist. The limitation of the document is that it does

                                            Page 19

-------
not describe all requirements in detail (in particular underground storage tanks), thus requiring the user
to gather some additional information to assure compliance (much of which can be obtained at the
associated www.CCAR-Greenlink.org Web site).  Nevertheless, the document is useful as a day-to-day
checklist and auditing tool for nearly all the EPA requirements for an auto repair shop.
       Environmental Auditing, California Compliance Guide, Environmental Resources
Management, Specialty Technical Publishers, 1999, 350+pages, $365 including four quarterly updates,
Available at www.stpub.com, by E-mail at orders@stpub.com, or by calling (800) 251-0381 or (604) 983-
3434

This document is an audit tool that contains background information on California air, wastewater,
hazardous waste, and hazardous materials management requirements, an explanation of the
requirements, and audit protocols for these audit criteria. The guide is useful as the basis of an audit
program to determine compliance against these requirements.  It includes a walk-through of audit
preparation, auditing, and scoring for each criteria.  While the depth of information is useful, those new to
the regulations may find the amount of information challenging to determine what applies to them.
Despite this limitation, the tool is useful for an audit program and provides a comprehensive listing of the
complex California requirements organized into an audit tool.
       Environmental Auditing, Federal Compliance Guide, Environmental Resources Management,
Specialty Technical Publishers, 1999, 365+ pages, $419 for CD-ROM, $419 for paper copy, and $619 for
both CD-ROM and paper copies (both include four quarterly updates), Available at www.stpub.com, by
E-mail at orders@stpub.com, or by calling (800) 251-0381 or (604) 983-3434

The Federal Compliance Guide parallels the California Compliance Guide (see previous).  It includes
sections on air quality, drinking water, facility management systems, hazardous materials, oil and
petroleum, solid waste, special pollutants (asbestos,  lead , PCBs), and the Toxic Substances Control
Act.
        Environmental Management Guide for Small Laboratories, U.S. EPA Small Business
Division, 1998 (update available in June 2000), 53 pages, Free, Available at
www.epa.gov/omisbo1/lab.pdforby calling (800) 368-5888

This document provides information designed to help staff in small laboratories better understand their
responsibility for good environmental management. While its purpose is to assist in development and
implementation of environmental management programs that meet federal EPA regulatory requirements,
it is also useful as an auditing tool.  The guide reviews environmental areas (air, water,  hazardous and
biological waste management, emergency planning, etc). For each area, the guide presents the
requirements that apply to laboratory operations,  and includes a self-audit checklist of key compliance
requirements. The guide also provides pointers to OSHA and DOT requirements that, although not
included in the guide, often apply to laboratory operations. The guide is useful to any small business
with laboratory operations as a self-audit tool. It is also useful for businesses that use laboratories and
may want to assure the labs are in compliance with EPA regulations. The Guide can be a useful tool as
a starting point for small businesses (As well as medium and larger) to manage the environmental issues
associated with laboratory operations, with additional state-specific assistance from state small business
assistance programs.
                                            Page 20

-------
      The Environmental Self-Audit for Small Business: A Quick and Easy Guide to
Environmental Compliance, New York State Small Business Environmental Ombudsman, January
1994, 30 pages, Free, Available at www.empire.state.ny.us/sbeo/default.htm or by calling (800) State-NY

This document provides a multimedia checklist to conduct audits of small businesses against criteria
related to air pollution, water pollution, land use, solid waste, and hazardous materials.  The document
provides an overview of requirements, rather than many of the details. For example, the discussion of
hazardous waste management informs the small business of requirements to "properly" separate
incompatibles and "properly" label containers, but does not provide information on which wastes need to
be separated, how they should be separated, or what specific labeling requirements apply. The
document is useful for small businesses that would like an overview of requirements. It would also be
useful for a medium-sized business with operations that may impact the environment in several media
(air, water, land) and would like to be aware of the scope of requirements to which they may be subject.
The limitations of the document are that the user would need to have many supporting documents, such
as regulatory fact sheets or the regulations themselves in order to conduct a thorough audit of its
operations.
      Environmental Self-Evaluation Guide for Small Business, Tool #1: A Practical Guide to
Environmental Compliance, Pennsylvania Department of Environmental Protection, November 1996,
38 pages, Free, Available at www.dep.state.pa.us or by calling (717) 783-1323

This document provides background material and audit checklists to evaluate a small business's
operations with respect to compliance programs in air quality, water, storage tanks, municipal waste
(including solid waste landfills), residual waste, and hazardous materials/hazardous wastes. The
document is targeted toward small businesses by including regulations that are likely to affect small
businesses in the self-evaluation guide, and omitting those that would apply only to large industries. The
main benefit of the checklists is that they allow small businesses to determine  if it has programs in place
for complying with the major categories of regulations.  It also provides contact information and a list of
technical assistance resources, within PADEP, EPA, and private organizations such as universities,
consulting companies, and state industrial partnership and resource centers. The document also
provides location and ordering information for U.S. EPA Sector notebooks. The main limitation of the
document is that it omits many of the detailed compliance requirements to which small businesses may
be subject.
        Green Seal Choose Green Report, Energy Efficient Indoor Lighting, Green Seal, 1997, 9
pages, Free, Available at www.greenseal.org (a small fee may be requested when ordering directly from
Green Seal at (202) 331-7337, ext. 31)

Green Seal Choose Green Report on Energy Efficient Indoor Lighting provides background information
on environmentally preferable light bulbs and lighting fixtures, and provides quality ratings for over 25
different types of lighting equipment (including specific brand names), including downlighting, ceiling
fixtures, wall/sconces/bathroom fixtures, and track/general/portable lighting.  The report is useful for
conducting internal energy audits, to evaluate recommendations provided by outside consultants, and to
allow consideration of energy efficiency into purchasing decisions.  The report discusses light intensity,
energy consumption, light bulb performance, light clarity, light quantity and quality, and options for
installing new lights in existing fixtures. The report does not include information on environmental


                                            Page 21

-------
compliance or Clean Air Act Standards. It simply provides information to allow the user to make better
informed decisions that can save the small business money in energy costs while assuring that the
business's lighting needs are met.
        Green Seal Choose Green Report, General Purpose Cleaners, Green Seal, 1998, 7 pages,
Free, Available at www.greenseal.org (a small fee may be requested when ordering directly from Green
Seal at (202) 331-7337, ext. 31)

Green Seal Choose Green Report on General Purpose Cleaners provides background information on
environmentally preferable cleaning products that can help small businesses reduce the exposure of its
employees to hazardous chemicals, reduce OSHA compliance requirements, and reduce EPA
hazardous waste disposal requirements. The report discusses the risks and benefits of conventional and
greener cleaners, provides checklists on how to evaluate whether a cleaner is truly  environmentally
preferable, and provides performance and quality ratings for over 30 different brands of general purpose
cleaners. The report is useful as a checklist for conducting internal audits that include a hazardous
materials inventory.  It is also useful to evaluate recommendations provided by outside consultants
(perhaps a hazard communication plan and waste disposal costs can be avoided by switching cleaners),
and to allow for the purchase of environmentally preferable products that meet the small business's
performance needs.  The report does not include information on environmental compliance or
hazardous waste or OSHA Standards.  It simply provides information to allow the user to evaluate
current options,  make better-informed decisions that can protect workers, and minimize compliance
costs.
        Green Seal Choose Green Report, Lawn Care Equipment, Green Seal, 1998, 7 pages, Free,
Available at www.greenseal.org (a small fee may be requested when ordering directly from Green Seal
at (202) 331-7337, ext. 31)

Green Seal Choose Green Report on Lawn Care Equipment provides background information on
environmentally preferable lawn care equipment, and provides quality ratings for over 15 electric
powered and 30 gasoline powered lawn mowers (including specific brand names).  The report describes
the benefits of electric powered and four-cycle gasoline powered engines in terms of reduced impact on
the environment and overall equipment quality.  The report is useful for small businesses that are making
purchasing decisions on lawn care equipment because it identifies environmentally preferable products
that compare with the performance standards of more polluting products. The report is also useful for
small businesses to evaluate contractors who may perform lawn care services.  The report does not
include information on environmental compliance or Clean Air Act Standards. It simply provides
information to allow the user to make better-informed decisions when trying to purchase or use
environmentally preferable lawn equipment.
        Green Seal Choose Green Report, Office Products, Green Seal, 1997, 5 pages, Free,
Available at www.greenseal.org (a small fee may be requested when ordering directly from Green Seal
at (202) 331-7337, ext. 31)

Green Seal Choose Green Report on Office Products provides background information on
environmentally preferable office products that contain recycled content, are recyclable, or are more
energy efficient than conventional products. The report includes organizational products (file folders,
binders, and labels) and desktop products (writing pads, index cards, pencils and pens, floppy disks, self-

                                            Page 22

-------
sick notes) that can help small businesses reduce its impact on the environment while meeting its
product performance needs. The report is useful as a checklist for conducting internal audits of typical
office operations. It is also useful to ease the process of purchasing environmentally preferable products
that meet the small business's performance needs.  The report does not include information on
environmental compliance or hazardous waste or OSHA Standards.  It simply provides information to
allow the user to evaluate current options and to make better-informed decisions that can reduce the
small business's impact on the environment.
        Green Seal Choose Green Report, Vehicle Maintenance, Green Seal, 1996, 4 pages, Free,
Available at www.greenseal.org (a small fee may be requested when ordering directly from Green Seal
at (202) 331-7337, ext 31)

Green Seal Choose Green Report on Vehicle Maintenance provides background information on
environmentally preferable products found in maintenance shops, including coolants, motor oils, and car
wash detergent. The report provides opportunities for buying recycled materials and reducing
environmental impact.  The report also lists six brands of motor oil, four brands of engine coolant, and
three brands of detergent that meet current performance standards of conventional products, but are
either of recycled content or of less toxicity than the conventional alternative. The information in the
report can be used as best management practice and good housekeeping criteria for an internal audit.
The report is also useful to evaluate recommendations provided by outside consultants, and to allow for
the purchase of environmentally preferable products that meet the small business's performance needs.
The report does not include information on environmental compliance or hazardous waste  or OSHA
Standards. It simply provides information to allow the user to evaluate current options, make better-
informed decisions that can protect workers, and minimize compliance costs.
      ISO 14001 Mini Gap Analysis, Transformation Strategies, 1998, Free, Available at
www. trst. com/gapanal.htm

This audit tool is a checklist that can be used to conduct an initial assessment of a small business's
operations with respect to the environmental management systems (EMS) criteria in ISO 14001  (a gap
analysis).  The Web site asks the user to review 16 statements based on the ISO 14001 EMS standard.
The small business indicates the company's degree of conformance with each statement, and is
provided with an overall score, comment about status, as well as next steps. The limitation of this tool is
that it is intended to be an initial high-level analysis, rather than a detailed operations level audit.  Small
businesses may be able to use this tool, combined with one of the EMS Standards (ISO 14001 or
EPA/NEIC Compliance-Based EMS) to conduct an  internal EMS audit, conduct an initial review, or
compare against the work of an outside consultant.  Overall, this is a very useful no-cost tool for
evaluating environmental management systems.
        Managing Chemicals Safely, Putting it All Together, Chemical Education Foundation, 1996,
24 pages, $1.25, Available at www.chemed.org

The document provides information on preventing chemical accidents and managing chemicals in
accordance with OSHA requirements.  The document describes chemical safety program components,
provides short checklist points for reviewing potential accidents, and discusses communication
mechanisms such as product and drum labeling.  The document is useful for getting started with
chemical safety and hazardous waste management programs and those looking for tips on how to

                                            Page 23

-------
improve their programs. Information in the document is also useful for minimizing waste disposal costs.
The limitations of the documents are its general content and a focus on practices, rather than regulatory
requirements.  Despite this limitation, the document provides a good overview, some important
management techniques, and a guide to setting up a chemical safety program all of which are useful in
setting up a chemical safety and hazardous waste management program.
        Mercury: Managing, Recycling, Disposing - A Business Guide to Conducting a Mercury
Audit, Pennsylvania Department of Environmental Protection, 1999, 4 pages, Free, Available at
www.dep.state.pa.us (click on Pollution Prevention and Compliance Assistance, and then P3Erie)
or by calling (814) 332-6839

This document is a brief, yet thorough audit protocol for conducting an audit of business operations that
may include mercury. The document includes a one-page list of potential mercury-containing items,
followed by 11 questions related to mercury management. The audit criteria in the protocol are
management systems criteria, as the protocol asks questions related to managing mercury and having a
program in place to assure that the environmental, health, and safety aspects of mercury are considered
where mercury is purchased or used. The limitation  of this protocol is that it does not provide detailed
regulatory requirements or regulatory citations. The  document recommends that those who answer "not"
to any of the audit questions to contact PADEP or visit the PADEP Web site to learn about the regulatory
requirements and how to comply.  Despite this limitation, the document is a useful tool for small
businesses to identify items that may potentially contain mercury and to determine whether those
materials are being managed safely and in accordance with PADEP requirements.
        Motor Vehicle Repair Facilities: Model Facility Guide, Maine Department of Environmental
Protection,  1999, 26 pages, Free, Available at (207) 287-6188

This document provides an overview of key regulations applicable to motor vehicle repair operations and
several checklists for conducting assessments of these operations.  The document is useful for those
conducting  compliance and "beyond compliance" assessments of vehicle repair or other maintenance
shop operations. The checklist questions are presented such that "yes" answers indicate the facility is
complying with Maine requirements, while "no" answers indicate the facility is out of compliance. Of
special note are chapters on oil filters, rags and  absorbents, and tires.  The limitations of the document
are that it does not include regulatory citations, does not include all regulatory requirements that may
apply to these operations, and includes requirements that are only applicable in Maine.  Nevertheless,
the document provides a comprehensive overview of the air, water, waste management, and good
housekeeping issues that apply to vehicle maintenance operations, and provides a number of clearly
presented checklists that are useful for conducting self-assessments. For facilities located in other
states, this  document is still a good starting point, since the Maine-specific requirements are more strict
than the federal requirements.
      Multimedia Inspection Checklist, State of Tennessee Department of Environment and
Conservation, Division of Community Assistance,  1999, 5 pages, Free, Available at (615) 532-8006

This checklist covers the state's major environmental regulatory program areas and is useful for any
business.  The checklist includes questions on general observation, emergency plans, air emissions,
pesticides, water, radiation, hazardous waste, solid waste, PCBs, underground storage tanks, injection
wells, mines, and pollution prevention. The questions are clearly presented and should be simple for

                                            Page 24

-------
small businesses to answer. The document is useful for small businesses that would like to review its
operations and determine the regulatory areas that apply to its operations and some of the compliance
requirements. The limitation of the document as a self-assessment tool is that the "correct" answers for
all of the questions are not always obvious, and some questions are merely to gather information. Given
this limitation, the checklist is best used for a facility to understand the environmental aspects of its
operations and then to consult with the Division of Community Assistance to interpret the results.
However, unlike other checklists that may be developed solely for information gathering purposes of the
Department of the Environment, this checklist does ask many questions that provide compliance
requirements, giving the small business an opportunity to be introduced to these requirements in many of
the program areas. Note that although the document was prepared by the State of Tennessee, the
checklist would be useful to small businesses in other states as well.
        Protocol for Conducting Environmental Compliance Audits of Hazardous Waste
Generators Under the Resource Conservation and Recovery Act (RCRA), U.S. EPA, October 1998,
72 pages plus appendices, Free, Available at www.epa.gov/oeca/ccsmd/profile.html or by calling (800)
490-9198

The protocol provides a checklist to be used by those conducting environmental regulatory compliance
audits of facilities that generate hazardous waste to evaluate those facilities' compliance with RCRA.
The protocol begins with a definition of terms and then a guide to the sections of the protocol applicable
to the three classes of hazardous waste generators (those that generate less than 100 kg/month, 100-
1000 kg/month, or greater than 1000 kg/month).  The appendices include lists of hazardous wastes to
assist the facility in determining which wastes are hazardous wastes. The protocol is  formatted in two
columns, with the first column listing the regulatory  requirement and the second listing the auditor review
activities. The protocol is useful for small or medium-sized businesses that have some familiarity with
hazardous waste issues or environmental regulations, and provides a comprehensive walk-through of
the RCRA generator requirements. The limitations  of the document are that new users or very small
businesses may prefer to begin self-audits with other tools that present most (rather than all) of the
requirements in a short (i.e. one-to-ten page) multimedia checklist,  rather than a comprehensive protocol.
For those businesses looking to evaluate the protocols of auditors,  this document provides a good base
for comparison.
        Protocol for Conducting Environmental Compliance Audits of Treatment Storage and
Disposal Facilities Under the Resource Conservation and Recovery Act, U. S. EPA, December
1998, 112 pages plus appendices, Free, Available at www.epa.gov/oeca/ccsmd/profile.html or by calling
(800) 490-9198

The protocol provides a checklist to be used by those conducting environmental regulatory compliance
audits of facilities that treat hazardous waste, store hazardous waste on site for longer than 90 days (or
in some cases longer than 180 or 270 days), or dispose of hazardous waste through landfilling or
incineration under the federal hazardous waste regulations (RCRA). In addition to the audit checklist, the
document includes background information on EPA's Audit Policy, how to use the protocol, key
compliance requirements, definitions of key terms, typical records to review, typical features to inspect,
and a checklist index. The protocol is useful for small or medium-sized businesses in chemical, metal
finishing, wood preserving, or other industries that may be required to store their hazardous wastes for
extended periods of time.  The protocol is also useful for businesses that would like to audit disposal
facilities that accept waste from the small business, to assure that the waste is being properly managed.
The limitation of this protocol is that it is very detailed (which may be a benefit to some in that the


                                            Page 25

-------
protocol can be relied on to thoroughly assess compliance).  The extensive detail may contain more
information than small businesses can easily manage and may be more useful for those with some
environmental management experience.  Thus this document would more likely be useful to a consultant
or outside auditor hired by the small business, rather than the small business itself.
        Protocol for Conducting Environmental Compliance Audits Under the Comprehensive
Environmental Response, Compensation, and Liability Act, U.S. EPA, December 1998, 45 pages,
Free, Available at www.epa.gov/oeca/ccsmd/profile.html or by calling (800) 490-9198

The protocol provides a checklist to be used by those conducting environmental regulatory compliance
audits under the federal Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), also known as Superfund.  The protocol begins with an introduction to the regulations
governing reporting and responding to releases of hazardous substances, and continues with description
of the process of evaluating a contaminated site,  conducting a remedial investigation, selecting
remediation methods, removing contaminated materials, involving the community in cleanup, and
maintaining an administrative record.  The protocol is useful for small businesses that may use or
manufacture hazardous substances that may be  released to the environment, or small businesses that
owns property on which contamination has occurred.  The protocol provides a checklist of regulatory
requirements from initial reporting through cleanup. Even if a facility has not had a release that caused
contamination in the past, the protocol is useful for its checklist or reporting requirements. It is useful to
small businesses that store quantities of hazardous or extremely hazardous substances,  because it
explains regulations that can be difficult to interpret if a facility were simply to look at the Code  of Federal
Regulations. As with the EPCRA protocol (see below), a table in an appendix includes a list of all
hazardous and extremely hazardous substances that may make a facility subject to these requirements,
allowing the facility to do a self-check to determine if the requirements apply. The limitations of the
protocol are that it does not indicate which chemicals are likely to make a small business subject to the
regulations.  The CERCLA requirements are more likely to apply to laboratory or manufacturing
operations than  service providers, such as auto repair, dry cleaners, or printers. Thus many facilities
may not need this protocol. The major benefit of the protocol is that it provides a structured format for
reviewing the potentially complex requirements of CERCLA and a method of evaluating remediation
contractor proposals and activities.
        Protocol for Conducting Environmental Compliance Audits Under the Emergency
Planning and Community Right-to-Know Act, U.S. EPA, December 1998,  12 pages plus appendices,
Free, Available at www.epa.gov/oeca/ccsmd/profile.html or by calling (800) 490-9198

The protocol provides a checklist to be used by those conducting environmental regulatory compliance
audits under the federal Emergency Planning and Community Right-to-Know Act (EPCRA). The protocol
begins with an introduction to the regulations governing planning for releases  of hazardous chemicals
stored, manufactured, or used at a facility, and is then followed by the checklist which walks the user
through  several sections of the Code of Federal Regulations that cover emergency planning and
reporting requirements. The protocol is useful for small businesses that may store quantities of
hazardous or extremely hazardous substances because it explains regulations that can be difficult to
interpret if a facility were simply to look at the Code of Federal Regulations. A table in an appendix
includes a list of all hazardous and extremely hazardous substances that may make a facility subject to
these requirements, allowing the facility to do a self-check to determine if the requirements apply. The
limitations of the protocol are that it does not indicate which chemicals are likely to make a small
business subject to the regulations. The EPCRA requirements are more likely to apply to  laboratory or


                                           Page 26

-------
manufacturing operations than service providers, such as auto repair, dry cleaners, or printers. Thus
many facilities may not need this protocol. The major benefit of the protocol is that it provides resources
for the small business to make its own applicability determination. In contrast to some  of the other more
complex regulations, the smaller scope of the EPCRA requirements would likely allow small businesses
to rely on this protocol as a comprehensive, yet not overly complex, resource for EPCRA compliance.
       A Self-Assessment Workbook for Small Manufacturers, Rutgers, The State University of
New Jersey, Office of Industrial Productivity and Energy Assessment, 1998, 83 pages,  Free, Available at
http://oipea-www. rutgers. edu/documents/doc_ f. html

This workbook provides a small manufacturing company with a step-by-step method to improve
operations and reduce costs through energy conservation, waste minimization, and improved
manufacturing productivity. The workbook is organized in three basic sections that the user can
complete in series or concurrently.  The workbook includes checklists that cover the manufacturing
process (raw material usage, final product, and plant subsystems used in the manufacturing process)
and help the user focus on the processes and identify all energy consuming equipment. The workbook
also contains 21 recommendations and examples of cost saving projects identified by the Department of
Energy's Energy Analysis and Diagnostic Center and the Industrial Assessment Center programs. The
recommendations include fluorescent tube replacement, compacting trash, water savings measures, and
suggestions on how to maximize boiler operations among other projects. The book has few limitations.
A small manufacturer can easily use the workbook to perform a self-audit of the manufacturing process,
the plant's subsystems, and  current waste minimization procedures.  The workbook lists all the
equipment an auditor will need to collect the recommended information and provides sample
calculations. For non-manufacturing businesses, the workbook includes potentially useful examples of
cost savings through roof insulation, lighting recommendations, and waste  reduction recommendations
including water saving  measures, recycling programs for wooden pallets and corrugated cardboard, and
trash compacting.
      A Self-Audit Checklist for Dry Cleaners, Pennsylvania Department of Environmental Protection
(PADEP), Office of Pollution Prevention and Compliance Assistance, 1997, 4 pages, Free, Available at
www. dep. state, pa. us

The checklist provides a self-audit tool for Pennsylvania dry cleaners on the environmental requirements
of dry cleaning operations, and the aspects of an environmental management program applicable to dry
cleaners.  The  checklist asks questions related to training employees, storing materials, minimizing leaks
and spills, maintaining good housekeeping, modifying costly procedures, retrofitting older equipment,
using care with floor drains, and developing a marketing plan.  The limitation of the checklist is that it
does not cite regulatory requirements; thus, those using the checklist are uncertain which of the checklist
items are required by law or regulations and which are good management practices. However, in
contrast to checklists that ask general questions, this self-audit tool asks many specific questions, where
the good management practice or regulatory requirement is specified in the  question itself. For those
who would like more information on the regulatory citations, the checklist provides contact information
within PADEP. Overall, the checklist is a useful tool for dry cleaners in  Pennsylvania and in other states
to evaluate their operations with respect to compliance requirements and opportunities to reduce
environmental  impact through the use of good management practices.
                                            Page 27

-------
        The Small Business Environmental Site Visit Manual, Iowa Waste Reduction Center,
University of Northern Iowa, 1999, 64 pages, Free, Available at www.iwrc.org
This booklet provides a step-by-step approach for small business assistance providers who conduct site
visits as part of an overall compliance assistance program. It includes chapters on developing a site visit
program, available technical assistance tools, the site visit audit process, and special considerations. It
is most useful for small business assistance providers who will be conducting site visits or environmental
audits and offer compliance assistance. It is also useful for small businesses who will be conducting self-
audits, or who hire consultants to conduct audits.  The limitations of the document are its focus on
process, rather than regulatory criteria.  However,  the document brings in many compliance assistance
resources and audit process checklists that would be very useful for a small business interested  in
environmental auditing. Overall, this document provides a very good overview of auditing and the audit
process targeted directly toward small businesses and small business assistance providers.
      Waste Minimization Plan for Small Quantity Generators as Required by the Mississippi
Comprehensive Multimedia Waste Minimization Act of 1990, Mississippi Department of
Environmental Quality, 1998, 6 pages, Free, Copies are available by writing to the Mississippi Dept. of
Environmental Quality, Attn: Environmental Resource Center, P.O. Box20305, Jackson, Ml 39289-1385

This three-page questionnaire  is required to be completed by small quantity generators (SQGs) of
hazardous waste in Mississippi. The questionnaire walks the user through components of a waste
minimization program and allows the user to consider aspects of waste minimization efforts. The
document is useful for small businesses that generate hazardous waste or that generate any wastes and
would like to reduce the volumes generated. The questionnaire does not provide any guidance on waste
minimization technologies, management strategies, or green purchases that might aid small businesses
in reducing  waste generation.  For users in Mississippi,  in helps meet a regulatory requirement.  For
users outside of Mississippi, it  provides questions for the small business to consider as it manages and
minimizes its hazardous waste.

4.2 Supporting Information
Document Title
1998 Resource Guide for
Small Business Air Emission
and Multimedia Assistance
Audit Builder Software
ChemAlliance.org
Community Outreach:
Making it Easy, Ideas and
Examples
Compliance Assistance
Package for Hazardous
Waste Generators
Author/Publisher/URL
Iowa Waste Reduction Center
EHS Technologies Corporation
Partially funded by EPA
www.chemalliance.org/
RegTools/index.htm
Chemical Education
Foundation
www.chemed.org
New Jersey Department of
Environmental Protection
Date
1998
1999
1999
1999
1996
Number of
Pages
84
Software
Software
94
20, including
appendices
Relevance
1
2
1
1
1
Cost
Free
$99 to
$2,000
Free
$23
Free
                                            Page 28

-------
Document Title
Compliance Manual for
Indiana's Vehicle
Maintenance Shops
Dakota Auditor:
Environmental, Health, and
Safety and EMS Auditing
Software
Enhancing the Link with
Your Customer: Preparing
for Environmental, Health,
and Safety Assessments
Environmental Management
Systems: An Implementation
Guide for Small and
Medium-Sized Organizations
EPA Small Business
Gateway
Facility Pollution Prevention
Checklist
GreenWare Environmental
Audit Software
How to Reduce Your Energy
Costs: The Energy Efficiency
Guide for Businesses,
Industry, Government, and
Institutions
Incentives for Self-Policing:
Discovery, Disclosure,
Correction and Prevention of
Violations, U.S. EPA Audit
Policy
Massachusetts Crash
Course for Compliance and
Pollution Prevention
National Automotive
Compliance Assistance
Center
National Metal Finishing
Resource Center
Author/Publisher/URL
Indiana Department of
Environmental Management,
Compliance and Technical
Assistance Program
www.state.in.us/idem/ctap/
index. html#vehicle
Dakota Software Corporation
www.dakotasoft.com/
product/auditor.html
SOCMA
http://socma.rd.net/reskit.html
U.S. EPA, Office of Wastewater
Management
www. e pa . g o v/OWM/fdf s/
finalgu.pdf
U.S. EPA Office of Small
Business Ombusdman
www.epa.gov/smallbusiness/
help. htm
Pennsylvania Department of
Environmental Protection
(www.dep.state.pa.us), Office
of Pollution Prevention and
Compliance Assistance
GreenWare Environmental
Systems, Inc.
www.greenware.com
Pennsylvania Department of
Environmental Protection
(www.dep.state.pa.us), Office
of Pollution Prevention and
Compliance Assistance
U.S. EPA
Massachusetts Office of
Technical Assistance for Toxics
Use Reduction (OTA)
www.state.ma.us/ota/
otapubs.htm
Coordinating Committee for
Auto Repair
www.ccar-greenlink.org
www.nmfrc.org
Date
1998
1999
1996
1996
2000
1997
2000
1996
1995
1998
1999
1999
Number of
Pages
154, plus
attachments
Software
30
156
Web site
2
Software
72
6
40 for
workbook;
74 for
toolbox
Web site
Web site
Relevance
1
2
2
1
1
1
3
1
1
1
1
2
Cost
Free
Varies
$98
Free
Free
Free
Varies
Free
Free
Free
Free
$0-1257
year
Page 29

-------
Document Title
P2/E2 Pollution
Prevention/Energy Efficiency
Site Visit Program
Paints and Coatings
Resource Center
Printers National
Environmental Assistance
Center
Printers Protecting the
Environment Workbook
Product Stewardship
Resource Guide
Understanding the
Hazardous Waste Rules: A
Handbook for Small
Businesses -1996 Update
Author/Publisher/URL
PA Department of
Environmental Protection
www.paintcenter.org/
com pass, cfm
www.pneac.org/pneac.html
Florida Dept. of Environmental
Protection, Small Business
Assistance Program,
www.dep.state.fi. us/air/outreac
h/sbap/index.htm
Chemical Education
Foundation, www.chemed.org
U.S. EPA
Date
1999
1999
1999
1999
1998
1996
Number of
Pages
Web site
Web site
Web site
93
83
25 plus
inserts
Relevance
1
2
2
1
2
1
Cost
Free
$0-125
$0-125
Free
Free
Free
        1998 Resource Guide for Small Business Air Emission and Multimedia Assistance, Iowa
Waste Reduction Center, University of Northern Iowa, 1998, 84 pages, Free, Available by calling (800)
422-3109 or by writing to SBAP Resource Guide, Iowa Waste Reduction Center, University of Northern
Iowa, 1005 Technology Parkway, Cedar Falls, Iowa 50613-6951

This book contains a state-by-state bibliography of compliance assistance tools available to small
businesses. It is a comprehensive  listing of compliance assistance tools developed by small business
assistance providers from all 50 states.  The bibliography includes one-to-two sentence descriptions of
documents available in each state.  The documents contained in the bibliography include compliance
assistance centers, fact sheets, booklets, guidebooks, comprehensive manuals, regulatory summaries,
and other information all targeted toward helping small businesses prevent pollution and achieve
compliance. The book contains a 3 1/4" floppy disk with a search engine so that the reader can sort
through  the bibliography by source  topic, state,  or environmental media. Most of the materials in the
bibliography are available free of charge.
      Audit Builder Software, EHS Technologies Corporation, 1999, Price ranges from $99 to $2,000
depending on user needs, Available at (856) 786-4035

Audit Builder Software is a software package that includes audit protocols, report generation, and the
ability to manage audit data. The software provides protocols for EPA, OSHA, DOT, and state
regulations, and allows the user to edit the protocols to include best management practices and pollution
prevention audit criteria that may not be in the regulations. The program is useful for small to medium-
sized businesses for maintaining regulations, developing facility-specific protocols, generating audit
reports, and tracking audit data.  The software is comprehensive,  thus requiring the auditor to determine
which protocol questions apply to the facility. It must be kept up to date, requiring the user to periodically
                                            Page 30

-------
contact state regulatory agencies to determine whether the protocol is current or to purchase additional
updates.  Audit Builder can help small businesses conduct audits, manage its audit data, produce clear,
presentable audit reports, and assure compliance.  When combined with compliance assistance
materials from state small business agencies, the software can significantly increase a business's ability
to maintain an audit program.
       ChemAlliance.org, Compliance Assistance Web site for Chemical Industries (Partially funded by
U.S. EPA), 1999, Free, Located atwww.chemalliance.org/indexmain.asp

ChemAlliance.org is a Web site designed to provided regulatory and compliance assistance information
to businesses involved with chemical processing.  The site includes a regulatory handbook with a "virtual
plant tour," a step-by-step review of key regulations, and other features to help businesses better
understand how regulations apply to their operations. It also includes a collection of self-assessment
resources such as checklists on compliance, risk assessment, environmental management systems, and
pollution prevention. Furthermore, it includes links to contacts for pollution prevention and compliance
assistance, a glossary of environmental and regulatory terms, and other resources available on the
World Wide Web.  The Web site is useful as a first stop for small businesses that process or otherwise
deal with chemicals in their operations, and provides a good complement to materials available from
state small business assistance providers.  The checklists provide audit criteria for conducting self-
assessments and the other resources are useful for developing corrective actions to audit findings. The
limitation of the Web site is that it is focused on the process chemical industry. Thus, it is useful for all
businesses with a chemical focus, and for those that are looking for general compliance assistance
information.  The significant amount of information is well presented, making it easy for the user to locate
and review information.  Overall, this source is a useful first step for many businesses and a key source
of information for process chemical businesses.
        Community Outreach: Making it Easy, Ideas and Examples, Second Edition, Chemical
Education Foundation, 1999, 94 pages, $23, Available at www.chemed.org or by calling (703) 527-7747

This document is a 94-page booklet on implementing community outreach programs for companies that
deal with chemicals. While the booklet is written for companies that deal with chemicals, the focus is on
community outreach activities and programs that could apply to any small or medium-sized business.
The booklet's main benefit to audit programs is that it defines elements of a community outreach
program, including elements of programs focused on product stewardship, information distribution,
emergency response, general education, advocacy, community advisory groups, and community events.
The booklet could be used to generate an in-house checklist to evaluate a business's community
outreach activities. Included in the booklet are 50 pages of case study highlights of community outreach
programs, with examples from each of the above categories, contact information, and hours spent on
each assignment. Compliance is not this booklet's goal, and it is useful for businesses that not only want
to maintain a strong  environmental program, but also want to communicate that program to the public.
Overall, this booklet  has few limitations, as it can be used as a reference for developing a community
outreach program, or as the basis for auditing community outreach activities. Note that the Chemical
Education Foundation has many additional compliance assistance materials available on its Web site
(www.chemed.org) for free.
                                            Page 31

-------
        Compliance Assistance Package for Hazardous Waste Generators, New Jersey Department
of Environmental Protection, 1996, 20 pages including appendices, Free, Available at
www. state, nj. us/dep/enforcement/home.htm

This document provides an overview of the federal EPA hazardous waste requirements, which have
been adopted by the State of New Jersey. The document is applicable to all businesses (large and
small), with no specific industry focus.  It is most useful to small and large quantity generators of
hazardous waste. The document separates the Code of Federal Regulations (CFR) by topic area as a
business would likely consider them, presenting the requirements in a list format that makes them much
easier to understand than in the CFR directly. With each requirement (e.g., personnel training), the
document lists the elements of that requirement (e.g., key training components, frequency, etc.) that
must be included to assure compliance. While not presented in checklist form, the document could be
used as an internal checklist for hazardous waste compliance. At a minimum, the document is useful for
the  small business to better understand hazardous waste rules, and to be able to ask questions about
specific sections of the rules from DEP, EPA, or other experts.  Document appendices include a manifest
tracking log, weekly container storage area inspection log, New Jersey hazardous waste contact
information, and a list of commercially permitted hazardous waste facilities.
       Compliance Manual for Indiana's Vehicle Maintenance Shops, Indiana Department of
Environmental Management, Compliance and Technical Assistance Program, 1998, 154 pages plus
attachments, Free, Available at www.state.in.us/idem/ctap/index.html#vehicle or by calling (317) 232-
8172 or toll free at (800) 451-6027, press 0 for operator and request extension 2-8172

This comprehensive compliance manual provides details on the rules and regulations affecting vehicle
maintenance shops in Indiana. The manual covers environmental regulations of the Indiana Department
of Environmental Management (IDEM), U.S.  DOT, and OSHA. The manual also includes fire and
building services information, and waste prevention and minimization recommendations. The manual is
most useful for small businesses that deal with vehicle maintenance activities. The extensive
compliance assistance portion of the document guides the user through the different types of vehicle
repair activities and the associated regulatory requirements with each.  The compliance assistance
portion contains several lists of compliance requirements that could be used as internal checklists to
verify compliance. The attachments contain  information useful for setting up an  environmental, health,
and safety program at a facility, including worksheets for developing a hazard communication plan,
assigning responsibilities for various environmental activities,  preparing a chemical inventory, and
certifying CFC recovery systems.  The attachments also include sample hazardous waste manifests and
shipping labels.  The limitation of this document is that it does not contain brief checklists or protocols
that could be extracted to conduct a self-audit. While much of the information necessary to conduct an
audit is contained in the document, the lack of checklists may mean the document has too much
information for a brief review.  This limitation  can be overcome, however, by obtaining checklists or
protocols from other sources such as CCAR-Greenlink or other states where vehicle maintenance or
auto repair audit checklists have been developed.  The Indiana guide is extremely comprehensive and
could be used either as the basis for making  new checklists or as a complement to other audit tools.
                                            Page 32

-------
      Dakota Auditor: Environmental, Health, and Safety and EMS Auditing Software, Dakota
Software Corporation, 1999 update, Prices vary, Purchasing information available at
www.dakotasoft.com/product/auditor.html or by calling (716) 381-8710

Dakota Auditor is a software program that provides audit checklists for all EPA and state environmental,
health, and safety compliance criteria and ISO 14000 environmental  management systems criteria. The
software program is an audit tool in that the audit criteria are presented in checklist format and can be
used to create audit reports and track audit findings.  The program is useful for small or medium-sized
businesses that are developing an internal audit program and would  like to use one source of information
for audit criteria, checklists, and information management. One benefit of this software is the ability of
the business to add its own checklist questions or best management practice criteria to the checklists
and easily incorporate these criteria into its audit program. For businesses looking to establish long-term
programs, Dakota Auditor may present an efficient tool to conduct audits, assure compliance, and
manage audit data.
        Enhancing the Link with Your Customer: Preparing for Environmental, Health and Safety
Assessments, Synthetic Organic Chemical Manufacturers Association, 1996, 30 pages, $98 (for non-
members), Available at http://socma.rd.net/reskit.html

SOCMA is the trade association for the batch and custom chemical manufacturers. The guide was
designed to assist chemical companies preparing for environmental, health, and safety audits of the
facility by customers.  The guide takes the user through the stages of an assessment including planning,
the assessment itself and follow-up.  The guide includes a survey that allows the user to gather pertinent
information on training, personnel, permits, and issues associated with air, water, solid and hazardous
waste, as well as safety and health issues such as occupational exposures. In addition, the guide
includes a housekeeping checklist to ensure the user's facility is in good condition prior to the audit.  The
guide is useful for small businesses that is preparing for an environmental assessment.  The guide
includes information on loading/unloading and product distribution, and is geared towards manufacturers.
Even if a facility is not a manufacturing facility, the guide is effective in directing the user towards
gathering pertinent information.  It does not indicate if a business is in compliance or which regulations
apply.  Rather it focuses on the audit process and steps a facility can take to prepare for an audit.  The
guide is especially helpful for small businesses preparing for an external audit.
        Environmental Management Systems: An Implementation Guide for Small and Medium-
Sized Organizations, U.S. EPA, Office of Wastewater Management, November 1996, 156 pages, Free,
Available at www.epa.gov/OWM/pdfs/finalgu.pdf

The Guide provides an overview of environmental management systems (EMSs) and their applicability to
small and medium-sized businesses.  The Guide includes case studies, "helpful hints," sample
procedures for implementing portions of an EMS, and recommendations for implementing EMSs.
Approximately one-third of the Guide's 150 pages focus on developing an EMS, while the rest of the
Guide provides case studies and implementation tools.  Because the Guide is based on the ISO 14001
EMS audit criteria, small businesses could also use the Guide to ensure that its EMS meets the ISO
14001 criteria, or use the information in the Guide to review against an outside auditor's proposed EMS
criteria.  The Guide is useful for small businesses that want to understand EMS criteria.
                                            Page 33

-------
       EPA Small Business Gateway, U.S. EPA, Office of Small Business Ombudsman, Current, Free,
Available at www.epa.gov/smallbusiness/help.htm

The EPA Small Business Gateway is a Web site intended to provide small businesses a single location
to begin their search for information related to environmental management.  It provides links to state
assistance programs, state environmental agencies, EPA hotlines, and national compliance assistance
centers, as well as compliance assistance materials, information on water and energy conservation, and
a list of publications. It is useful as a starting point for small businesses wanting to learn more about
compliance and pollution prevention and the resources available to them.  It is also useful to supplement
information received from other sources and to obtain general information (i.e., EPA  audit policy related
to small businesses) useful to small businesses. If a small business has Internet access, this Web site
should be the first place to start searching for environmental management information an a list of useful
local contacts.
4
      Facility Pollution Prevention Checklist, Pennsylvania Department of Environmental Protection,
Office of Pollution Prevention and Compliance Assistance, April 1997, 2 pages, Free, Available at
www.dep.state.pa.us (click on Subject/Pollution Prevention/Compliance Assistance) or by calling (717)
783-0540

This two-page pollution prevention (P2) checklist is useful for small businesses in any state that would
like to conduct an internal audit of their operations with respect to pollution prevention criteria, and to be
able to evaluate consultants who offer P2 audit services. The checklist provides 13 categories of
operations that may take place at small businesses and then identifies three-to-ten P2 opportunities for
each operation.  Each opportunity is a potential resource savings for the small business and a method of
reducing the business's impact on human health and the environment. The checklist provides examples
of engineering controls (e.g., using foot pedals to control water usage), process controls (e.g., frequent
sludge removal from cleaning processes), and management systems methods (e.g., accounting for
waste treatment and disposal expenses as a direct cost of producing a product) of implementing a P2
program and taking specific actions to reduce waste.  Many of the questions focus on solvent, cleaning,
metal plating, painting, or oil/water separator operations, thus making the checklist most applicable to
these operations, rather than service industries or food processing. While the document is most useful
for businesses with these operations, the document contains general questions about water
conservation, energy usage, spill prevention, and materials handling that can be used by all  businesses,
small and large.
      GreenWare Environmental Audit Software, GreenWare Environmental Systems, Inc., 2000,
Prices range from $699 for a single user to $3,999 for multiple assessments and multiple users.
Available atwww.greenware.com, E-mail at greeninfo@greenware.com, or by calling (416) 363-5577

GreenWare Environmental Audit Software is a self-assessment and management tool for conducting
environmental audits. Two of the most useful products are software ISO 14001 environmental
management systems audits, for implementing an environmental management system that meets the
ISO 14001 audit criteria. These software products are designed to provide companies and/or their
consultants with a complete electronic tool set for use in evaluating, implementing, monitoring and
auditing environmental management systems for their conformance to the ISO 14000 standards. Each
product contains the following features,  including: a document management system; full customization,


                                            Page 34

-------
report-writing and word-processing capabilities; automatic linkages and scoring; customizable views for
draft, final, manual and electronic documents; internal and external document configuration (including
WWW); extensive guidance and on-screen instruction including context-specific ISO text document
controls, verification and password protect features; links to multiple locations and users; and special
diagnostic features  that automatically evaluate the completion and status of the electronic documents.
The software can be linked with financial auditing software so that small businesses can manage its
environmental management systems and its financial audit data. The software is useful for small
businesses that would like to incorporate their audits into an existing data management tool with the
audit criteria incorporated with audit data. While some small businesses may find the software more
formal than is necessary.  It is also useful for medium sized or larger businesses that have multiple
facilities and would  like a prepared software program to manage their data.
        How to Reduce Your Energy Costs: The Energy Efficiency Guide for Businesses,
Industry, Government, and Institutions, Pennsylvania Department of Environmental Protection, Office
of Pollution Prevention and Compliance Assistance, 1996, 72 pages, Free, Available at
www. dep. state, pa. us

This book provides small businesses opportunities for saving energy that is expended for lighting,
heating, ventilating, air conditioning, hot water, machines, and the overall building.  The book also
provides a checklist for a self-energy audit and tools to develop an energy management system. The
book is useful for small businesses to evaluate and improve energy usage of current operations through
focused operation and maintenance.  The book is also useful for small businesses during purchasing
processes to evaluate the energy efficiency of new products, for annual budgeting, for remodeling or
building add-ons, or to upgrade maintenance programs to include an energy conservation focus. The
book is useful because it provides examples of actual costs of different energy alternatives and methods
for calculating savings for several aspects of operations,  such as different types of building doors, HVAC
systems, electricity purchases (based on different rate systems), lighting, security, and windows. It can
be used to conduct self-audits, to develop an energy conservation program, to evaluate proposed
process evaluations (or audits) of energy consultants, or simply as a guide  to include energy
conservation in future business planning.
        Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of
Violations, U.S. EPA Audit Policy, U.S. EPA, 1995, Published in the Federal Register on December
22, 1995 (60 FR 66706), 6 pages, Free, and Proposed Modifications to the Policy on Compliance
Incentives for Small Businesses and Request for Public Comment, U.S. EPA, Published in the
Federal Register on July 29, 1999 (64 FR 4116), Available from the Audit Policy Docket at (202) 260-
7548 or (202) 564-4187.  Also available at www.epa.gov/fedrgstr/EPA-GENERAL/1999/July/Day-
29/g19437.htm

These documents explain U.S. EPA's enforcement policy for disclosure of potential compliance issues
discovered in an environmental audit and proposed modifications to the policy.  The documents explain
how small businesses may report potential compliance issues to EPA and receive a waived penalty, or
penalty reductions, provided that the compliance issue is corrected by the facility within a specified time
period.  Note that the  small business policy applies only to small businesses, while the audit policy
applies to small and large businesses.
                                            Page 35

-------
       Massachusetts Crash Course for Compliance and Pollution Prevention, Massachusetts
Office of Technical Assistance for Toxics Use Reduction, 1998, 40 pages as workbook and/or 74 as
toolbox, Free, Available at http://state.ma.us/ota/ota.htm or by calling (617) 626-1060

The Crash Course manual provides a comprehensive course on the environmental, health, and safety
requirements and pollution prevention practices for auto body shops. The manual also contains
information that would be useful to general auto repair shops or small businesses that maintain their own
fleet vehicles. The document is one of the most comprehensive compliance assistance materials
available to small businesses because it includes health and safety as well as environmental
requirements. It  includes a plain-language description of the basic environmental, health, and safety
issues and regulations that apply to Massachusetts auto body shops, a comprehensive self-audit
checklist to help shops review their compliance, and information on pollution prevention opportunities.
The manual also provides regulatory and assistance contact information within Massachusetts. The
manual is organized such  that the user can fairly easily turn to the desired section, read about the
requirements, and then move on to the checklist. However, while Massachusetts is the focus, there is
sufficient discussion of EPA requirements, EPA contacts, and pollution prevention opportunities that
apply in any state to make this document worthwhile to businesses in all states.
       National Automotive Compliance Assistance Center, Coordinating Committee for Auto
Repair, 1999, Free, Available at www.ccar-greenlink.org (Web site partially funded by U.S. EPA)

The National Automotive Compliance Assistance Center provides many audit tools, self-assessment
checklists, federal and state compliance assistance and pollution prevention documents, and links to
additional state programs and documents.  The center is useful for small businesses involved in auto
repair or who have vehicle repair or building maintenance activities as part of their operations.  The
limitation of the Web site is that it does not contain information on all state regulatory requirements for
waste disposal of antifreeze, used oil, and solvents, all of which may be regulated differently from state to
state. The Web site does contain links to state environmental agencies, so that the user can find the
appropriate contacts if the needed information is not directly available on the Web site. Similar to other
compliance assistance centers, this Web site can answer many questions and provides many useful
tools for small businesses to conduct self-assessments of and make improvements to their
environmental management activities related to auto repair.
       National Metal Finishing Resource Center, 1999, Cost ranges from $0-$125/year, Available at
www.nmfrc.org

The National Metal Finishing Resource Center is a Web site intended to provide compliance assistance
information to metal finishers.  The free site provides information on environmental news and regulatory
updates, but does not provide access to compliance assistance materials. The pay site ($40-$125/year)
provides access to compliance assistance materials that may assist small businesses in assessing its
operations with respect to environmental laws and regulations and pollution prevention opportunities.
                                            Page 36

-------
        P2/E2 Pollution Prevention/Energy Efficiency Site Visit Program, PA Department of
Environmental Protection, 1999, Free, Available at www.dep.state.pa.us

This brochure describes the Pennsylvania Department of Environmental Protection's (PADEP's) P2/E2
program, which provides free pollution prevention and energy efficiency audits to industry and
businesses, farming operations, and municipalities with good compliance records.  The document
recommends that businesses that would like a free audit to complete An Environmental Self-Evaluation
for Small Business (available at www.dep.state.pa.us, or 717-783-9981) prior to the free site visit to
determine whether the business may have significant compliance issues which it would like to correct
prior to inviting DEP to the facility. The brochure is simply designed to promote the program and  has
little value on its own. The brochure and the program only apply to businesses within Pennsylvania.  For
Pennsylvania businesses, the contact information and the site visit program can be useful for small
businesses to conduct self-assessments, and to determine how to evaluate their opportunities for waste
reduction, energy efficiency, and cost savings through better environmental and energy management.
Note that many other states have similar programs through the state Small Business Assistance
Program (usually found within the state department of environmental protection, or the state office of
economic development).
       Paints and Coatings Resource Center, 1999, Cost ranges from $0-125, Available at
www.paintcenter. org/compass. cfm

The Paints and Coatings Resource Center is a Web site intended to provide compliance assistance
information to small businesses involved in painting and coating metal materials. This free site includes
links to federal and state compliance assistance programs. More in-depth information is available for an
annual fee of $40 to $125.
       Printers National Environmental Assistance Center, 1999, Cost ranges from $0-125, Available
at www.pneac.org/pneac.html

The Printers National Environmental Assistance Center is a Web site intended to provide compliance
assistance information to small businesses involved in the printing industry. This free site includes links
to federal and state compliance assistance programs.  More in-depth information is available for an
annual fee of $40 to $125.
        Printers Protecting the Environment Workbook, Florida Department of Environmental
Protection, Small Business Assistance Program, 1999, 93 pages, Free, Available at
www. dep. state, fl. us/air/outreach/sbap/index. htm

The document is the workbook from a Florida workshop on environmental issues affecting printers.  The
workshop is designed to educate printers on hazardous waste generation, water discharges, and air
pollution issues and regulations affecting their operations. The workbook contains background
information describing printing processes and their potential environmental impacts, along with checklists
on the regulatory requirements under each section.  The document is useful to printers in all states for
understanding environmental requirements and conducting self-assessments. The limitation of the
document is its focus on printers. While other businesses may find some value in reviewing the

                                            Page 37

-------
document as a method of reviewing their own operations, the document is most useful as a
comprehensive compliance assistance and self-audit checklist for printing operations.
        Product Stewardship Resource Guide, Chemical Education Foundation, April 1998, 83 pages,
Free, Available at www.chemed.org or by calling (703) 527-6223

This guide is similar to the Audit Source Book, with a focus on chemical handling and environmental
protection related to chemicals management. The Resource Guide provides over 70 pages of sources of
information on general health and safety, environmental and pollution control, emergency planning and
response, hazardous  materials transportation and regulations, regulatory compliance, product
stewardship, and trade associations. The guide focuses on the chemical industry, and nearly all the
materials are available through the Chemical Education Foundation (regardless of the author or
publisher).  The limitation of this document is similar to the limitations of the Audit Source Book, in that it
directs the user to other materials, rather than directly providing information.
        Understanding the Hazardous Waste Rules: A Handbook for Small Businesses - 1996
Update, U.S. EPA, June 1996, 25 pages plus inserts, Free, Available at
www.epa.gov/smallbusiness/help.htm or by calling (800) 368-5888

This document provides background information and details on how small businesses can comply with
the federal hazardous waste regulations. The document defines hazardous wastes, lists hazardous
wastes typically generated by small businesses and the wastes' associated waste codes, explains how
to determine the quantity of waste generated, how to obtain an EPA identification number, requirements
for conditionally exempt small quantity generators and small quantity generators, and requirements for
managing waste on site.  The document concludes with a  list of state environmental protection agencies
and their contact offices for hazardous waste management. The document is useful for small businesses
that would like a walk-through of the hazardous waste requirements, or would like to conduct a self-
review of its waste generation activities. The document has limited use in auditing because it does not
have a summary checklist or brief audit-review tool. However, the document is easy to read, and
provides essential information that would be useful to any  small business that would like to better
understand requirements for generating, storing, managing, and disposing of hazardous waste.
                                            Page 38

-------
CHAPTER 5: AUDIT TRAINING COURSES

5.1 Audit Courses Targeted Toward Auditing and/or Small Businesses
Course Title
Orientation to
Environmental Auditing
Training for
Environmental Air
Compliance Auditors For
Small Businesses
Provider/URL
PRIZIM Inc.
www.PRIZIM-lnc.com
New Jersey Small Business Assistance
Program, Office of Pollution Prevention and
Permit Coordination, and Cook College,
(732) 932-9271
www.state.nj.us/dep/opppc/AUDGUID9.htm
Number
of Days
1-4
Varies
Relevance
1
1
Cost
$200+/
person/day
Varies
         Orientation to Environmental Auditing, PRIZIM Inc.,  1-4 days, Cost starts at $200 per
person, per day (minimum class size of 8) and varies depending on course location and specific
requirements of attendees or sponsoring organization. For more information, contact PRIZIM Inc., 316
E. Diamond Avenue, Suite 201, Gaithersburg, MD 20877, (301) 840-9316

This training course provides an introduction to auditing targeted toward small to medium-sized
businesses, and small business assistance providers. The one-day course includes an overview of the
audit process, discussion of audit terminology, internal vs. external audits, audit tools, techniques for
gathering audit evidence and evaluating facility performance (including interviewing and document
reviews), audit reporting, and methods of prioritizing audit findings. The one-day course includes
several exercises and discussion to allow attendees to practice the techniques in the classroom or at a
nearby facility.  The four-day course generally includes visits to a local facility where attendees will use
audit tools, evaluate facility performance, develop audit findings, and  begin to draft corrective action
items for the facility.  The course is useful for small to medium-sized businesses that are interested in
an orientation to auditing and who would like to be able to determine how a formal auditing program
may benefit their business operations.  The course is also useful for small business assistance
providers that would like to  improve their techniques for planning site visits and to be better able to
provide auditing expertise to small businesses. Overall, the course provides a detailed review of
auditing, combined with practical skills training to allow attendees  to better conduct their own internal
program, or to be better able to evaluate independent auditors who may visit their facility.
         Training for Environmental Air Compliance Auditors for Small Businesses, New Jersey
Small Business Assistance Program, Office of Pollution Prevention and Permit Coordination, and Cook
College, Information is available at www.state.nj.us/dep/opppc/AUDGUID9.htm or by calling (732) 932-
9271

The New Jersey Small Business Assistance Program offers a training course in conducting
environmental audits for compliance with Clean Air Act requirements in New Jersey.  The course  is
useful for small businesses with manufacturing, printing, painting, or processing operations that may
generate air pollutants. The course trains those businesses to conduct internal audits, or to evaluate
outside consultants. Specific Clean Air Act topics include air permits in New Jersey, operating permits,
pollution prevention, and  preparing air emissions statements. The limitation of this course is its focus
on New Jersey Clean Air Act requirements only. Thus, its use may be limited for those in other states.
                                           Page 39

-------
Despite this limitation, the course provides a good standard for evaluating external consultants, or for
training in-house staff on important and challenging regulations.
5.2 ISO 14001 Auditing, Environmental Management Systems Auditing, and Related
    Auditing Courses

ISO 14001 audit training courses are used to receive information and practice a wide range of
information from developing a general understanding of the ISO Standard, to developing an EMS audit
program, to honing audit-related skills. Classes vary in length and may include the development of an
EMS program, hands-on training, writing audit findings, and extensive interaction with other
professionals.  Training courses are an individual choice based on company needs and previous
knowledge of the attendee.  Most of the training listed below is geared toward EMS and ISO 14000
implementation and will discuss in some detail the audit process itself. The vast majority of the
companies listed offer ANSI-RAB or similar types of certification training courses for those individuals
wanting lead auditor certification. The courses listed below are targeted toward enhancing attendee
understanding  of the auditing standards to be able to conduct audits. The major limitation of these
courses is that they are not always relevant to the environmental issues at the small business facility.
When registering for a class, to maximize the value of the class, it is important for the small  business to
determine whether the instructor is familiar with key environmental regulations and plant operations, or
whether the small business should receive separate training on environmental issues and regulations
prior to attending an ISO training course.
Company
Applied Quality
Systems
Competitive Edge
Environmental
Management
Systems, Inc.
Eagle Group USA,
Inc.
Excel Partnership,
Inc.
Executive
Enterprises
Global Quality
Institute
Web site/Information
www.aqsperformance.com
www.isoedge.com
www.eaglegrpusa.com
www.xlp.com
www.eeiconferences.com
www.globalquality.com
Types of Courses Offered*
ISO 14000 overview, internal
auditor, and ANSI-RAB lead
auditor.
Lead auditor, internal auditor,
and implementation training.
Hands-on audit practice, ISO
14000 internal quality auditor,
auditor upgrade/refresher, lead
auditor, and gap analysis
courses.
Training courses for ISO 14000
from overview to advance
accreditation.
Courses on ISO 14000 and
auditing.
Courses on ISO 14000
interpretation, documentation
and implementation, integration
with ISO 9000, and improving
performance through internal
auditing.
Relevance
2
2
2
2
2
2
Cost
Range**
$995+
$595-
$1,595
Varies
$295-
$1995
Varies
$595-
$895
                                            Page 40

-------
Company
Government
Institutes
International Quality
and Environmental
Services
ISO 14000 Plus
Auditing Training
MGMT Alliances Inc.
Pillar Management
Associates
PRIZIM Inc.
Quality System
Development
SGS International
Certification
Services, Inc.
Stat-A-Matrix
Web site/Information
www.govinst.com
www.iques.com
Board of Environmental
Auditor Certifications
www.beac.org
www.mgmt14k.com
www.pillarassociates.com
www.PRIZIM-lnc.com
www.iso14000.net/qsd
www.necnet.org
www.thesamegroup.com
Types of Courses Offered*
ISO 14001, implementing and
auditing your EMS, process
safety management auditing,
internal auditor training for the
ISM Code and ISO 9000,
International environmental
auditing, and environmental,
health, and safety audit
courses.
Courses in internal auditing,
implementation and
documentation, and ISO 14000
overview.
Unique training for BEAC
members and others interested
in EMS auditing.
ISO 14000 lead auditor course.
ISO 14000 lead auditor,
introduction for the CEO,
aspects and impacts, and
internal auditing.
Audit program development,
general EMS auditing,
advanced auditor skills, and
special training for government
agencies.
Courses in lead auditing,
management system
integration, EMS internal
auditing, and an executive
overview and interpretations of
ISO 14000.
Course in environmental
compliance auditing, EMS
internal auditor, EMS
implementation, and lead
auditor training.
Courses in lead auditor training,
internal auditing, interpreting
and implementing ISO 14000,
and integrating ISO into a
quality management system.
Relevance
2
2
2
2
2
2
2
2
2
Cost
Range**
$795-
$1,999
Call for
costs
Varies
$1,585
Varies
Varies
$245-
$895+
$595-
$1,695
$595+
*Some courses are accredited by ANSI-RAB and can be used toward lead auditor certification.
**Check Web site for most current prices and schedules. Price varies with length of class. Some companies offer discounts
for group registration and for attending more than one class in a 12-month period.
                                                     Page 41

-------
—•'  -»...--
         Applied Quality Systems, 2585 Hamline Avenue North, Suite A, St. Paul, MN 55113, (651)
633-7902, www.aqsgerformance.com

AQS has a course for ISO 14000 internal auditing that provides the attendee with terminology,
definitions, background, history, and the rationale for an EMS.  In addition, the class discusses the roles
and responsibilities of an auditor, provides information to refine the auditor's interview and note-taking
skills, and tips for the auditor. The attendee will also receive information on planning and conducting
effective audits, documentation, how to develop an EMS audit  report, and preparing a closing meeting.
This class is targeted toward individuals responsible for planning and performing audits or who may be
a member of an audit team.  A complete list of courses,  dates,  times, costs, and agendas is available
on the Web site.
         Competitive Edge Environmental Management Systems, Inc., 27777 Franklin Road,
Suite 300, South field, Ml 48034, (734)207-4988, www.isoedge.com

Competitive Edge offers courses in ISO 14000 implementation, internal auditing, and lead auditor
training. The agendas list the specific content for each class including hands-on exercises. The two
most useful classes for small business are the internal auditing and ISO 14000 implementation
courses.  They provide specific information on developing an EMS, including performing initial reviews,
developing a manual, and auditing a facility.  The implementation course is geared toward those
individuals responsible for developing and implementing an EMS and the auditing  course is
recommended for those attendees that will perform the audits.  A complete list of courses, dates, times,
prices, and agendas is available on the Web site.
         Eagle Group USA, Inc.,  100 West Big Beaver, Suite 200, Troy, Ml 48084, (248) 355-4421,
www. eaglegrpusa. com

Eagle Group has an extensive list of training courses by category on their Web site.  Courses include a
hands-on audit practice course, an  ISO 14000 internal quality auditor, auditor upgrade and refresher
courses, lead auditor courses, a course on performing a gap analysis, and more. Courses are geared
toward specific groups and small businesses should choose courses based on their need and the
background of individuals performing audits. A complete list of courses, dates, times, prices, and
agendas is available on the Web site.
         Excel Partnership, 75 Glen Road, Sandy Hook, CT 06482, (203) 426-3281, www.xlp.com.

Excel Partnership offers an extensive list of training courses for ISO 14000, ISO 9000, and ISO Guide
25. The courses range in complexity from an overview to advanced accreditation classes. Key
courses include a three-day EMS Internal Auditing, and a three-day ANSI-RAB Accredited Advanced
EMS Auditor Course for Quality and Environmental Professionals.  The Excel Partnership offers
additional courses related to environmental audit criteria including:  Implementing an ISO 14001
Environmental Management System (three-day), Understanding Environmental Regulations  (two-day),
and ISO 14001 Overview (one-day). A complete list of courses, dates, times, prices, and agendas is
available on the Web site.
                                           Page 42

-------
         Executive Enterprises, Two Shaw's Cove, New London, CT 06320, (800) 831-8333,
www. eeiconferences. com

Executive Enterprises offers courses in ISO 14000 and auditing. At this time Executive Enterprises is
not accredited by ANSI-RAB as a trainer. Courses may not be offered as frequently as some other
training institutes. A complete list of courses, dates, times, prices, and agendas is available on the
company Web site.
     El-
         Global Quality Institute, 102 Rosedale Avenue, Brampton, Ontario L6X 1K1 Canada, (905)
452-9788, www.globalquality.com

Global Quality offers courses on ISO 14000 interpretation, documentation and implementation,
integrating it with an existing QMS, and improving performance through internal auditing. The
interpretation course reviews the development of ISO 14000 and provides an analysis of the
components and an understanding of the documentation requirements. The improving performance
course through auditing teaches the attendees how to interpret the ISO 14000 Standard and be
effective EMS auditors. All courses include case studies.  The above courses will benefit small
business wanting an understanding of basic ISO 14000 principles and how to interpret the Standard. A
complete list of courses, dates, times, prices, and agendas is available on the company Web site.
     El-
         Government Institutes, ABS Group Inc., 4 Research Place, Suite 200, Rockville, MD
20850, (301) 831-8333, www.govinst.com

Government Institutes offers a wide range of auditing courses, including a general environmental,
health, and safety audit course, courses on ISO 14000 implementation, and lead auditor training.
Classes range from an introduction to lead auditing giving the small business a wide range of training
options to meet all the needs of the business. At this time, Government Institutes does not have a
class certified by ANSI-RAB.  The environmental, health, and safety audit course provides a solid base
for general auditing.  A complete  list of courses, dates, times, prices, and agendas is available on the
Web site.
         International Quality and Environmental Services, 41820 West Six Mile Road, Suite 100,
Northville, Ml 48167, (248) 344-4466, www.iques.com

IQuES offers four ISO 14000 courses: internal auditor, implementation, documentation, and an
overview course. The courses provide step-by-step interpretation of the requirements and
responsibilities of management, writing environmental policy and  procedures, establishing an
implementation plan, and preparing audit checklists, conducting interviews, and reporting on ISO
findings.  The classes are targeted toward senior-level managers, personnel  involved in developing and
implementing the ISO Standard, and personnel involved in performing the audits. Small businesses
need to select classes based on their needs. A complete list of courses, dates, times, prices, and
agendas  is available on the company Web site.
                                           Page 43

-------
—•'  -»...--
         ISO 14000 Plus Auditing Training, Board of Environmental Auditor Certifications, 5 days,
www.beac.org

This 5-day training course is a minimum requirement for auditors to achieve certification as an ISO
14001-Plus EMS auditor. The course reviews the five major topics of an environmental management
system, and incorporates those into key business processes and regulatory requirements.  In contrast
to traditional ISO 14000 courses, this course trains attendees on how to assess systems for managing
substantial compliance in key regulatory areas. Upon completion of the course, attendees will have
greater knowledge of environmental compliance requirements and management systems to be able to
assess a business's system for achieving substantial compliance.  Other sections of the course include
identifying environmental aspects and impacts of business operations, and applying professional
auditing practices.  The course is useful to those businesses that would like to conduct environmental
management systems audits that include a thorough review of compliance issues, for small business
assistance providers that would like to learn more about the links between management systems and
compliance, and for small businesses to compare the qualifications of outside consultants.
         MGMTAlliances Inc., 301-1529 West 6th Avenue, Vancouver, British Columbia V6J 1R1,
(604) 733-2899, www.mgmt14k.com

MGMT Alliances offers one course on ISO 14000 lead auditing.  The course provides attendees with
the knowledge and skills required to perform audits for environmental compliance and determine the
effectiveness of an EMS.  The course also provides an in-depth analysis of the ISO 14000 Standard
itself. Upon completion of the course, attendees will receive accreditation from EARA and ANSI-RAB.
This  course would be useful for small businesses that have a current in-depth knowledge of ISO 14000
and want to maintain a certified lead auditor on staff. A complete list of courses, dates,  times, prices,
and agendas is available on the company Web site.
     El-
         Pillar Management Associates, 322 Poindexter Lane, Lexington, SC 29072, (803) 808-
3287, www.pillarassociates.com

Pillar Management offers courses in ISO 14000 training, lead auditor, introduction, aspects and
impacts, and internal auditing. The usefulness of the courses will depend on the needs of the small
business. A complete list of courses, dates, times, prices, and agendas is available on the above Web
site.
         PRIZIM Inc., 316 E. Diamond Avenue, Suite 201, Gaithersburg, MD 20877, (301) 840-9316,
www. PRIZIM-Inc. com

PRIZIM offers standard and customized training in EMS auditing (see description in Section 5.1)
nationwide. PRIZIM has trained many state government agencies in small business auditing and offers
unique training for federal government auditors, as well as for commercial businesses.
                                           Page 44

-------
     El-"'
         Quality System Development,  105 Woodside Court, Leitchfield, KY 42754, (502) 257-9997,
www. iso 14000. net/qsd

Quality System Development provides courses for ANSI-RAB lead auditor, integration of ISO 14000
with a current ISO 9000 management system, EMS internal auditor, and executive overview and
interpretation. The two most useful courses for small businesses  interested in ISO 14000, EMS, and
auditing are the internal auditor's course and the overview course. The other courses are more
advanced and apply to businesses that have a strong background in ISO and EMS and want a lead
auditor.  The courses are geared toward personnel involved in developing and implementing an EMS
and in auditing the facility. A complete list of courses, dates, times, costs, and agendas is available on
the company Web site.
         SGS International Certification Services, Inc., 5925 Airport Road, Suite 300, Mississagua,
Ontario L4V 1W1, (905) 676-9595, Training schedules are available at www.necnet.org or
www. sgsicsus. com

SGS offers courses in environmental compliance auditing, EMS internal auditor and lead auditor
training, and EMS implementation. The environmental compliance auditing course is useful for small
businesses developing a general auditing system that is not necessarily geared toward ISO
14000/EMS implementation. This course provides protocols and checklists and reviews and critiques
examples of auditing systems, workshops, and case studies. A complete list of courses, dates, times,
costs, and agendas is available on the company Web site.
         SLA T-A-MA TRIX, One Quality Place, Edison, NJ 08820-1059, (732) 548-0600,
www. thesamegroup. com

STAT-A-MATRIX offers four courses in auditing and ISO 14000. They include lead auditor training,
internal auditing, interpreting and implementing ISO 14000, and integrating ISO 14000 into a QMS. A
basic understanding of the ISO 14000 Standard is developed in the interpretation course. The lead
auditor training and internal auditing courses require prior knowledge of the ISO Standard and EMS.
Attendees can use the interpretation class as a pre-requisite for attending the lead auditor and the
internal auditing training.  A complete list of courses, dates, times, costs, and agendas is available on
the company Web site.
                                           Page 45

-------