United States
          Environmental Protection
          Agency
Office of Pollution  EPA 745-K-94-009
Prevention and Toxics    May 1994
7408
          EPA's 33/50 Program
          Company Profile
Douglas & Lomason Company
                            Printed on Recycled Paper

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                                     THE 33/50 PROGRAM
    This Company Profile is part of a series of reports being developed by EPA to highlight the accomplishments
of companies participating in the 33/50 Program.  The  33/50 Program is an EPA voluntary pollution reduction
initiative that promotes reductions in direct environmental releases and offsite transfers of 17 high-priority toxic
chemicals. The program derives its name from its overall goals - an interim goal of a 33% reduction by 1992 and
an ultimate goal of a 50% reduction by 1995.  The program uses 1988 Toxics Release Inventory (TRJ) reporting
as a baseline. In February, 1991, EPA began contacting the parent companies of TRJ facilities that reported using
33/50 Program chemicals since  1988 to request their participation in the 33/50 Program.  As of April, 1994, a total
of 1,216 companies had elected to participate in
the Program, pledging to reduce emissions of the
17  target chemicals by  more than 355 million
pounds by 1995.  Companies are encouraged to
set  their own reduction targets, which may vary
from the  Program's  national 33%  and  50%
reduction goals.   Company commitments and
reduction pledges continue to be received by EPA
on a daily basis.
    The 1992 TRJ data revealed that releases
and transfers of 33/50  Program chemicals de-
clined by 40% between 1988 and 1992, surpass-
ing the Program's 1992 interim reduction goal by
more than 100 million pounds. This accomplish-
ment,  together with evidence from analysis of
facilities' projected releases and transfers of the
17 priority chemicals, reported to TRJ under the
Pollution Prevention Act, offers strong encourage-
ment that the 33/50 Program's ultimate goal of a
50% reduction by 1995  will be achieved.
17 PRIORITY CHEMICALS TARGETED
       BY THE 33/50 PROGRAM
              BENZENE
      CADMIUM & COMPOUNDS
      CARBON TETRACHLORIDE
            CHLOROFORM
      CHROMIUM & COMPOUNDS
              CYANIDES
        DICHLOROMETHANE'
        LEAD & COMPOUNDS
      MERCURY & COMPOUNDS
       METHYL ETHYL KETONE
     METHYL ISOBUTYL KETONE
        NICKEL & COMPOUNDS
      TETRACHLOROETHYLENE
              TOLUENE
       1,1,1 -TRICHLOROETHANE
        TRICHLOROETHYLENE
              XYLENES

     Also referred to as methylene chloride
    EPA is committed to recognizing companies
for their participation in the 33/50 Program and
for the emissions reductions they achieve.  The
Program issues periodic  Progress Reports, in
which participating companies are listed and highlighted. In addition, Company Profiles, such as this one, are being
prepared to provide more detailed information about companies that have written to EPA describing significant
emissions reduction initiatives.  Information presented in these profiles is drawn primarily from the company's
written 33/50 Program communications and the annual TRJ reports submitted by their facilities (including Pollution
Prevention Act data reported to TRJ in Section 8 of Form R).  All company communications to EPA regarding
the 33/50 Program are available to the public upon request.

    EPA does not endorse the performance, worker safety, or environmental acceptability of any of the technical
options discussed in this Profile.  Mention of any product or procedure in this document is for informational
purposes only, and does not constitute a recommendation of any  such product or procedure, either express or
implied, by EPA.
   For information on the 33/50 Program, contact the TSCA Hotline at (202) 554-1404 or contact 33/50
   Program staff directly by phone at  (202) 260-6907 or by mail at Mail Code 7408, Office of Pollution
   Prevention and Toxics, U.S. EPA, 401 M Street, SW, Washington, D.C. 20460.
 33/50 Program Company Profile: Douglas & Lomason Company

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                  Douglas  & Lomason Company
   Douglas  &  Lomason  Company reduced  its
total  releases and  transfers of  33/50  Program
chemicals by 88% from 1988 to 1992, surpassing its
reduction goal for 1995.  Douglas  & Lomason has
been  active at all of its facilities in ongoing efforts
to reduce total releases and transfers of 33/50 Pro-
gram chemicals.  The company has estimated that
additional efforts will bring total reductions to
94%  by 1994.

      I.  CORPORATE BACKGROUND

   Douglas  & Lomason Company is a manufac-
turer of automobile and truck components, primar-
ily seat and trim parts. The company is headquar-
tered in Farmington Hills, Michigan and currently
operates 16 manufacturing facilities nationwide. In
1988, 7 facilities reported to TRI, one of which has
since closed.

   In 1988, Douglas & Lomason reported releases
and transfers of four 33/50 Program chemicals:
methyl ethyl ketone, toluene, 1,1,1-trichloroethane,
and xylene.  The company also reported relatively
small releases and transfers of several non-33/50
TRI chemicals at its facilities.
   Releases and Transfers of TRI Chemicals
      Reported by Douglas & Lomason1
               (1000 pounds)
                            988
  33/50 Chemicals
    Methyl ethyl ketone
    Toluene
    1,1,1-Trichloroethane
    Xylenes
    Chromium/Nickel

  33/50 Subtotal

  Other TRI Chemicals

  Total2
 27
263
 96
214
600

 64

663
1992

   8
  39
   0
  27
  74

 109

 183
   1 Data only for facilities participating in the 33/50
    Program.
   2 Columns may not sum to totals due to rounding.
     II. 33/50 PROGRAM GOALS AND
   POLLUTION REDUCTION ACTIVITIES
Douglas & Lomason  Company
achieved an  88% reduction in releases
and transfers of 33/50 Program chemi-
cals by  1992, surpassing its goal of an
80% reduction by 1995.
    33/50  Program  chemicals  have  been used
primarily in two processes:  painting metal seat
and  trim  parts, and molding  foam seat pads.
Methyl ethyl ketone, toluene, and xylene are used
as solvents for applying paint  to metal seat and
trim parts.  The company used 1,1,1-trichloroeth-
ane as a solvent for applying a mold-release agent
to the molds used to produce foam seat pads.

    Douglas & Lomason reported 599,755 pounds
of releases and transfers of 33/50 Program chemi-
cals in 1988, all of which were air emissions. Table
I, at  the  end  of this profile,  presents data on
releases and transfers of TRI chemicals for  the
company,  while Table II provides these data for
several of  the  facilities that have implemented
successful  pollution reduction projects.
    Douglas & Lomason established a company-
wide goal of reducing total releases and transfers
of 33/50 Program chemicals by 80% by 1995, based
on 1988 levels.  At the time the company set this
goal in 1991, releases and transfers of 33/50 Pro-
gram chemicals had already been reduced by 60%.

    Two  Douglas & Lomason  facilities -  La
Grange, GA and Amory, MS -- did not  report to
TRI in 1988 and, therefore, were not included in
the 1988 company baseline. These facilities have
subsequently begun reporting to TRI.  Although
the releases and transfers from  these two facilities
have been relatively  small, accounting for 8% of
company-wide releases and transfers of TRI chemi-
cals  in 1992, the company plans  to incorporate
these two facilities into their progress reports to
the 33/50  Program  for  1994.   This additional
reporting has been  prompted  by the company's
successful participation in the 33/50 Program.

    To meet its 33/50 Program goals, Douglas &
Lomason has  undertaken a  number  of source
reduction activities, primarily product and process
reformulation.   The  company  has completed
 33/50 Program Company Profile:  Douglas & Lomason Company

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projects to reduce chemical use in both the mold-
ing and painting processes.

•   Implementing a new mold-release  agent for-
    mulation. The Havre-de-Grace, MD, facility
    manufactures foam seat pads using a molding
    process.  This process involves applying a wax
    mold-release agent  to the  mold to facilitate
    the removal of  the finished molded product.
    Douglas & Lomason's traditional mold-release
    agent, which contained 1,1,1 -trichloroethane as
    a solvent, was  replaced  with  a water-based
    formulation.    This  substitution  completely
    eliminated the use of 1,1,1-trichloroethane, a
    reduction of 350,000 pounds.

•   Using  "high-solids" paint formulations.  At
    one facility, Douglas & Lomason manufactures
    metal  trim  parts which  are painted.   The
    amount of solvent, such as toluene, xylene, and
    methyl ethyl ketone, used in these  paints was
    reduced  through  the  use of  reformulated
    "high-solids" paint.  "High-solids" paint uses a
    reduced percentage of solvent in formulating
    the paint, thereby increasing the percentage of
    solids.  This approach resulted in emissions
    reductions  of over 70,000 pounds of 33/50
    chemicals at the Phenix City, AL, facility.

•   Using water-reducible paint. At several facili-
    ties, Douglas & Lomason manufactures metal
    seat frames which are painted for rust protec-
    tion.  The  use  of solvents in the paint was
    eliminated by using water-reducible paints, in
    which the solvents (in this case toluene and xy-
    lene)  are replaced  with  ethylene glycol and
    water.  This approach was used at the Co-
    lumbus, NE, facility, resulting in reductions of
    86,454 pounds of toluene and xylene releases
    between  1988 and 1992.
Douglas & Lomason estimates that its
total reductions in releases and transfers
of 33150 Program chemicals will reach
94% by 1994.
    Eliminating the use of paints. Solvent use has
    also been reduced or eliminated through the
    implementation  of two  new processes that
    eliminate the need  to paint certain  parts.
    First, the spray-application of rust inhibitors
        Douglas & Lomason's Progress
         Towards Meeting 33/50 Goals
 I
 o
 o
 o
 
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transfers of 33/50 Program chemicals by 88% be-
tween  1988  and 1992, a  reduction of  525,285
pounds. This reduction in releases and transfers
was achieved despite an  increase  in production
between 1988 and 1989.

    As part of Douglas & Lomason's efforts, the
Havre-de-Grace, MD, Red Oak, IA, and Colum-
bus, NE facilities have completely eliminated their
use of 33/50 Program chemicals.  The company  as
a whole has completely eliminated the use of 1,1,1-
trichloroethane.

    Douglas & Lomason's projections for 1994,  as
shown  in  their  Pollution  Prevention Act (PPA)
Reporting (Table III), indicate that the company
plans to continue reducing releases and transfers of
33/50 Program solvents. Total releases  and trans-
fers of 33/50 Program chemicals are projected to
be reduced to 34,460 pounds in  1994, for a 94%
reduction from 1988 levels.

      IV. SUMMARY OF DOUGLAS  &
         LOMASON'S EXPERIENCE

    Douglas &  Lomason  Company has  been
extremely successful in its 33/50 Program participa-
tion.  By 1992, Douglas & Lomason had already
surpassed its 1995 goals of reducing releases and
transfers of 33/50 Program  chemicals  by  80%.
Douglas & Lomason has achieved these  successes
through a variety of product and  process  reformu-
lation projects. This success is projected to contin-
ue, and Douglas &  Lomason expects to achieve
further reductions in releases and transfers of 33/50
Program chemicals  in  1994.  The company is
projecting that  reductions will  reach 94% from
1988 levels by 1994.
 33/50 Program Company Profile:  Douglas & Lomason Company

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                                                               Table I
                                                  Douglas and Lomason Company (1)
                                          Releases and Transfers of TRI Chemicals, 1988-1992
                                               (all data from TRI unless otherwise noted)
Chemical
Methyl ethyl ketone




Toluene




1,1,1 -Trichloroethane


Xylene (mixed isomers)




Chromium & Nickel

33/50 Program Chemicals




Non 33/50 Program Chemicals




All TRI Chemicals




Percent Change. 1988-1992
33/50 Program Chemicals
Non 33/50 Program chemicals
All TRI Chemicals
Year
1988
1989
1990
1991
1992
1988
1989
1990
1991
1992
1988
1989
1990
1988
1989
1990
1991
1992
1989
1990
1988
1989
1990
1991
1992
1988
1989
1990
1991
1992
1988
1989
1990
1991
1992




Surface
Total Air Water
Emissions Discharges
(pounds) (pounds)
27,128
39,000
29,800 (3)
7,700 (3)
8,240 (3)
262,851
174,000
76,500 (3)
55,900 (3)
39,100 (3)
96,259
384,000
8,300
213,517
219,000
124,680 (3)
39,200 (3)
27,130 (3)
173
500
599,755
816,441
239,780 (3)
102,800 (3)
74,470 (3)
59,675
119,372
84,775
77,020
109,020
659,430
935,813
324,555 (3)
179,820 (3)
183,490 (3)

-88%
83%
-72%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18
0
0
18
0
0
0
0
2,621
250
0
0
0
2,639
250
0
0

-
-
-
Transfers Percent
Off-site Change
Transfers for Treatment/ Total Releases 1988-1992
to POTW Disposal/Other and Transfers (2) Total Release
(pounds) (pounds) (pounds) and Transfer
0
0
0
0
0
0
0
• o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,900
2,900
0
0
0
3,900
2,900
0
0

—
• -
-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
250
0
0
250
0
0
0
4,004
750
10
0
0
4,004
1,000
10
0
0

--
-100%
-100%
27,128
39,000
29,800 (3)
7,700 (3)
8,240 (3)
262,851
174,000
76,500 (3)
55,900 (3)
39,100 (3)
96,259
384,000
8,300
213,517
219,000
124,680 (3)
39,200 (3)
27,130 (3)
441
500
599,755
816,441
239,780 (3)
102,800 (3)
74,470 (3)
63,679
126,643
87,935
77,020
109,020
663,434
943,084
327,715 (3)
179,820 (3)
183,490 (3)

-88%
71%
-72%




-70%




-85%


-100%




-87%






-88%




71%




-72%




Notes: (1) Includes data only for facilities that participate in the 33/50 Program.
       (2) 1991 and 1992 Total Releases and Transfers do not include on- or off-site recycling or energy recovery.
       (3) Includes data provided by company in progress reports to the 33/50 Program.

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                              Table II
                   Douglas and Lomason Company
Releases and Transfers of TR1 Chemicals at Selected Facilities, 1988-1992
              (all data from TRI unless otherwise noted)
Facility/Chemical Year
Douclas & Lomason Co., Havre De Grace, MD
1,1,1-Trichloroethane 1988
1989
Other 33/50 Program Chemicals 1989
All 33/50 Program Chemicals 1988
1989
All TRI Chemicals 1988
1989
1990
1991
1992
Doufilns & Lomason Co., Phenix City, AL
Methyl ethyl ketone 1989
1990
1991
1992
Toluene 1988
1989
1990
1991
1992
Xylene (mixed isomers) 1988
1989
1990
1991
1992
33/50 Program Chemicals 1988
1989
1990
1991
1992
All TRI Chemicals 1988
1989
1990
1991
1992
Douclas & Lomason Co., Red Oak, I A
Toluene 1988
1989
1990
1991
1992
Transfers
Surface Off-site
Total Air Water Transfers for Treatment/ Total Releases
Emissions Discharges to POTW Disposal/Other and Transfers (1)
(pounds) (pounds) (pounds) (pounds) (pounds)

56,347
350,000
13
56,347
350,013
57,097
351,021
25
20
20

15,000
3,800 (2)
1,100 (2)
740 (2)
21,492
43,000
15,000
12,000
13,000 (2)
68,804
62,000
49,000
20,000 (2)
5,300 (2)
90,296
120,000
67,800 (2)
33,100 (2)
19,040 (2)
108,263
182,000
99,800 (2)
33,100 (2)
19,040 (2)

21,866
25,000
22,000
26,000
19,000

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,900
2,900
0
0

0
0
0
0
0

0
0
0
0
0
4,004
500
10
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0

56,347
350,000
13
56,347
350,013
61,101
351,521
35
20
20

15,000
3,800 (2)
1,100 (2)
740 (2)
21,492
43,000
15,000
12,000
13,000 (2)
68,804
62,000
49,000
20,000 (2)
5,300 (2)
90,296
120,000
67,800 (2)
33,100 (2)
19,040 (2)
108,263
185,900
102,700 (2)
33,100 (2)
19,040 (2)

21,866
25,000
22,000
26,000
19,000

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                                                                   Table II
                                                        Douglas and Lomason Company
                                     Releases and Transfers of TRI Chemicals at Selected Facilities, 1988-1992
                                                    (all data from TRI unless otherwise noted)
Facility/Chemical Year
Xylene (mixed isomers) 1988
1989
1990
1991
1992
Other 33/50 Program Chemicals 1989
1990
All 33/50 ProEram Chemicals 1988
1989
1990
' 1991
1992
All TRI Chemicals 1988
1989
1990
1991
1992
Douclas & Lomason Co., Columbus, NE
Toluene 1988
1989
1990
1991
Xylene (mixed isomers) 1988
1989
1990
1991
33/50 Program Chemicals 1988
1989
1990
1991
All TRI Chemicals 1988
1989
1990
1991
1992
Transfers
Surface Off-site '
Total Air Water Transfers for Treatment/ Total Releases
Emissions Discharges to POTW Disposal/Other and Transfers (1)
(pounds) (pounds) (pounds) (pounds) (pounds)
21,866
24,000
39,000
11,000
12,000
158
500
43,732
49,158
61,500
37,000
31,000
43,982
49,252
61,750
37,000
45,000

45,674
33,000
21,000
3,200 (2)
40,780
32,000
21,000
1,000 (2)
86,454
65,000
42,000
4,200 (2)
86,704
65,250
73,250
81,200 (2)
95,000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21,866
24,000
39,000
1 1 ,000
12,000
158
500
43,732
49,158
61,500
37,000
31,000
43,982
49,252
61,750
37,000
45,000

45,674
33,000
21,000
3,200 (2)
40,780
32,000
21,000
1,000 (2)
86,454
65,000
42,000
4,200 (2)
86,704
65,250
73,250
81,200 (2)
95,000
Notes: (1) 1991 and 1992 Total Releases and Transfers do not include on- or off-site recycling or energy recovery.
       (2) Data provided by company in progress reports to the 33/50 Program.

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                                                       Table HI
                                           Douglas and Lomason Company (1)
                                          Pollution Prevention Act Reporting (2)
Chemical
Toluene


Xylene (mixed isomers)


33/50 Program Chemicals


Non 33/50 Program Chemicals


All TRI Chemicals


Percent Chances , 1 99 1 - 1 994
33/50 Program chemicals
Non 33/50 Program chemicals
All TRI Chemicals
Energy
Recovery
Off-Site
Year (pounds)
1991
1992
1994
1991
1992
1994
1991
1992
1994
1991
1992
1994
1991
1992
1994




2,382
1,070
860
27
150
0
2,409
1,220
860
87
160
0
2,496
1,380
860

-64%
-100%
-66%
Treated
On-Site
(pounds)
0
0
0
0
0
0
0
0
0
485,000
521,000
530,000
485,000
521,000
530,000

—
9%
9%
Percent
Percent Total Change
Change Production 1991-1994
Quantity 1991-1994 Related Production
Released Quantity Wastes Related
(pounds) Released (pounds) Wastes
50,000
31,000
12,000
1 1 ,000
12,000
0
61,000
43,000
12,000
85,109
109,007
95,007
146,109
152,007
107,007

-80%
12%
-27%
52,382
32,070
-76% 12,860
1 1 ,027
12,150
-100% 0
63,409
44,220
-80% 12,860
570,196
630,167
12% 625,007
633,605
674,387
-27% 637,867

-80%
10%
1%


-75%


-100%


-80%


10%


1%




Notes: (1) Includes data only for facilities participating in the 33/50 Program.
       (2) Actual data for 1991 and 1992; projections for 1994.

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