Documenting Your
Environmental Management Plan
A Workbook for Small Business
Small
Business
Division
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Acknowledgements
Documenting Your Environmental Management Plan - a Workbook for Small Business (Workbook) was
produced under the direction of the Environmental Protection Agency's (EPA) Small Business Divi-
sion. The EPA Small Business Division is grateful to those who reviewed the initial drafts and provided
many constructive suggestions. This group included Small Business Ombudsmen, as well as repre-
sentatives of state Small Business Assistance Programs, the National Compliance Advisory Panel,
trade associations, and EPA. Their contributions were vital in making this Workbook a practical and
useful small business environmental management tool.
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Table of Contents
Introduction
Definitions 4
I,
Environmental Policy 6
Responsibilities 9
Getting It Written Down—Environmental Manual 16
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Making Progress Over Time—Setting Goals 32
Keeping Track of Information—Recordkeeping 36
Keeping Track of Information — Document Control ......................................... 42
Master Schedule of Reports, Notifications, and Permits ................................ 47
Communication 54
Training 59
Keeping Your EMP Alive and Well 67
Summary 77
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Introduction
Documenting your Environmental Management Plan—A Workbook for Small Business
(Workbook) is for business owners who are committed to improving environmental manage-
ment within their business operations. Why does your company need an Environmental Management
Plan (EMP)? It helps you to keep track of all of your environmental management activities so you can
better streamline and organize them, helping to keep the time and effort employees have to devote to
them at a reasonable level. Done well, the EMP will make environmental management easier and
more natural for everyone who is involved in it at your business. Employees appreciate that the EMP
spells out exactly what's expected of them. The EMP provides a framework to ensure your business is
in compliance with environmental regulations. It also allows you to more easily see opportunities for
improvement and cost savings that may even take your business beyond compliance. Finally, if you
have been thinking about developing an Environmental Management System (EMS) that would be certi-
O fied or recognized by an organization outside of your business, developing this EMP will put you in a
u good position to do that. (For more information about EMSs, see httpV/www.epa.gov/ems/.)
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2 As the business owner or leader of this effort, you will probably find it useful to read through this
JE Workbook from beginning to end to get an overall picture of what the EMP entails and the issues you
can expect to encounter along the way. Each section includes an introduction to explain the tasks to
be completed, a worksheet to help you through the steps, and an example from one of two hypothetical
small businesses^ a furniture refinishing company and a marina. The examples will give you an idea
of how that portion of the EMP might look once it is completed.
After you have reviewed this Workbook, you can work with others in your business to build your EMP
one step at a time. You may want to appoint an Environmental Team to help pull it together. The idea
is to make steady progress without biting off so much at one time that working on the EMP begins to
detract from day to day business operations that are obviously your first priority. The important
thing is to do a good job of putting the EMP in place, working away at it a little at a time, even if it
takes a year or more.
Much of what you need in order to put together an EMP is likely already in place at your business.
This includes records, procedures, and training that your business is doing to comply with environ-
mental laws and regulations. By going through this Workbook, you can apply a management system
to these existing elements, much as you apply accounting principles to bring order to your business'
financial transactions.
The Workbook is designed to go hand in hand with the Practical Guide to Environmental Management for
Small Business (Guide). The Guide provides more detail about the steps to take to improve your busi-
ness' environmental management activities. The Workbook gives you a place to keep and organize all
of the information you compile while doing it. The table on the following page provides a crosswalk
between the Guide and Workbook sections to ease your information transfer. It is not necessary to
have the Guide to begin working on your Environmental Management Plan, but if you would like to
obtain a copy, call the U.S. EPA Small Business Division at 800-368-5888 or download it from
www.epa.gov/ems/. U.S. EPA's Small Business Division has also compiled factsheets entitled Plug-
ging Into Best Environmental Management Practices for Small Business for certain business sectors. If your
business is represented by one of these sectors, this information may be helpful as you put together
your EMP.
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-r.-
This table provides a crosswalk between the Workbook and the Guide so you can review related
background information and the pertinent steps to take as you begin working on a particular
worksheet.
Documenting Your Environmental
Management Plan - A Workbook
for Small Business
Practical Guide to Environmental Management
for Small Business
Environmental Policy
Responsibilities
Getting it Written Down -
Environmental Manual
Making Progress Over Time -
Setting Goals
Keeping Track of Information -
Recordkeeping
Keeping Track of Information -
Document Control
Master Schedule of Reports,
Notifications, and Permits
Communication
Training
Keeping the EMP Alive and Well
Summary
IV. Keeping the Program Alive
IV. Keeping the Program Alive
II. Responsible Environmental Basics
IV. Keeping the Program Alive
III. Saving Money Through Sound
Environmental Management
IV. Keeping the Program Alive
II. Responsible Environmental Basics
II. Responsible Environmental Basics
II. Responsible Environmental Basics
V. Taking it Outside Your Facility
II. Responsible Environmental Basics
III. Saving Money Through Sound
Environmental Management
IV. Keeping the Program Alive
VI. Summary
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Definitions
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Wiile it is good to avoid unnecessary jargon and acronyms, it helps to have a shared under-
standing of a few terms so that everyone in your company understands how the Environmen-
tal Management Plan works and what their role is. Defined words are italicized throughout the docu-
ment.
Applicable Laws
The laws of Congress, including the rules, regulations, requirements, and policies promulgated under
those laws, as well as state and local laws, rules, regulations, requirements, and policies governing
protection of the environment and protection of public health and safety.
Best Management Practices (BMPs)
Good practices that apply the most up-to-date knowledge and technology to achieve and maintain a
level of environmental performance that goes beyond what is necessary to comply with applicable
laws.
Corrective Action
A specific way to correct an existing problem or non-conformance when performance deviates from
expectations set out in the EMP.
Critical
A term we use in this workbook to indicate the responsibility, goal, function, or element of the EMP
necessary to make sure your company handles spills properly, keeps its employees safe, and stays in
compliance with environmental regulations.
Environmental Management Plan (EMP)
The actions an organization is taking to determine how it affects the environment, complies with
regulations, keeps track of environmental management activities, and meets environmental goals
and targets. It also documents key elements of environmental management including the environmen-
tal policy, responsibilities, environmental manual, applicable standard operating procedures and BMPs,
recordkeeping, document control, reports, communication, training, monitoring, and corrective ac-
tion.
Environmental Management System (EMS)
An organizational approach to environmental management that incorporates quality improvement
principles (sometimes referred to as "Plan-Do-Check-Act") to develop, achieve, review, and maintain
an environmental policy. Broad EMS elements include planning, implementation, checking and correc-
tive action, and management review.
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Environmental Manual
The collection of information that identifies applicable laws and outlines the organization's approach
to complying with or exceeding their requirements.
Environmental Policy
A statement of the organization's commitment to the environment. It is at the heart of the EMS and
the framework for planning and action undertaken through the EMS.
Goal
A general statement of a desired outcome to be achieved through the business' EMP.
Important „,
A term used in this workbook to indicate the responsibility, goal, function, or element of the EMP that o
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helps your company be efficient or proactive, to save money or time, or increase the respect and '£
goodwill of employees and community members.
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Environmental Policy
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Ai environmental policy shows that managing environmental issues is a high priority for your
business. It is like a rudder because it steers all of the additional steps your business will take
to put together its BMP. Later, when you are dealing with all the details that inevitably come along
with environmental management, it will be useful to refer back to the environmental policy to distin-
guish the important issues from distractions and to decide in what order to tackle things.
An environmental policy begins with a declaration of your business' commitment to the environment.
It usually includes a commitment to prevent pollution and to continuously improve environmental
performance. Many businesses also commit to keeping employees and community members safe as
part of their environmental policy. In addition to a declaration, the environmental policy states how the
business will live up to its declaration.
The environmental policy does not have to be lengthy or wordy. The more to the point, the more
effective it will be in communicating your intent. When putting the policy together, consider what
your company is trying to achieve with your environmental activities and how you will accomplish
your goals. It should only include strategies and actions that you are willing to commit your business'
resources to. Also think about how the policy will be regarded by employees within your business.
Later, once you get it fine tuned, you will find that your environmental policy can be helpful to commu-
nicate your business' approach to environmental management to local officials, customers, and others
outside your company.
A sound environmental policy makes a commitment to comply with applicable laws, implement pollu-
tion prevention ideas, and put in place Best Management Practices (BMPs) that are reasonable, effective,
and appropriate for your business. It should also be specific to your business activities and reflect your
business' unique culture.
Use the worksheet on the following page to help you and your team create an environmental policy that
suits your business. Keep in mind that the policy will be periodically reviewed and improved. The
important thing is to get something down on paper that you feel your company can stand behind and
live up to.
Before or at the same time your business is developing the
environmental policy, consider issuing a memo or statement
to all employees officially kicking off the effort to develop an
EMP. If employees understand that the goals of the EMP are
important to you as a business owner, they are more likely to
feel that achieving them is an important part of their jobs.
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Environmental Policy Worksheet
Stepl
Think about what your company wants to achieve through your environmental policy. Brainstorm a
list of action words or very short phrases that reflects your company's environmental commitment to
your employees, customers, and the community.
Step 2
Drawing on the list of words and phrases you have brainstormed above, put them together into a one
or two sentence statement.
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Environmental Policy Examples
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The management and staff of Cove Marina are committed to preserving and protecting the beauty of our
nation's water so that future generations can also enjoy these precious resources. In support of this
commitment, we strive to support clean boating and marina practices at our marina and utilize the
opportunity to educate our patrons on sound practices. Our goal is to lead the way by exemplifying
responsible use of the "river" resource. Operations at Cove Marina are conducted in a manner aimed at
achieving and maintaining compliance with all environmental rules and regulations. We strive to
continually improve our environmental performance and encourage and expect the day-to-day activities
of employees at all levels of our company to support our environmental goals.
Finley Furniture preserves your heirlooms while protecting the Earth. To accomplish this, the people of
Finley Furniture will produce a high quality product using safe and environmentally sound business
practices and work to foster a culture focused on excellent environmental performance. Finley Furniture
follows through on this commitment by complying with environmental laws and regulations, wisely
investing resources toward managing environmental affairs, and training all employees in the knowledge
and skills necessary to carry out their job in a safe and environmentally responsible way.
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Responsibilities
H-ving roles and responsibilities clearly written out helps employees understand what part of
nvironmental management activities they are responsible for and how their role relates to the
roles of others. By establishing who is responsible for what, the EMP helps to increase accountability
within the company and motivates employees to take more personal responsibility for environmental
management because the tasks are well defined and not overwhelming. By making sure all tasks are
assigned, it is less likely that they will fall between the cracks or that environmental management
activities will backslide if a key employee leaves.
Each small business is unique and has to work out environmental roles and responsibilities in a way
that fits into its particular organization and culture. When assigning responsibilities, it may be
helpful to distinguish between critical and important ones. It is also beneficial to find a balance of
responsibilities among all employees so that environmental management will not take up too much of
anyone's time and will truly be a team effort.
After you have defined responsibilities, you need a way to communicate them to each employee. This
is best done formally by giving each employee their own copy of their specific environmental responsi-
bilities, signed by the company owner or personnel manager, with a copy also being placed in their
personnel file. This way, they can be assured that they are within the scope of their job when doing
assigned environmental duties and have the opportunity to ask for clarification if they have
questions.
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Spread responsibilities among employees. For example:
1 - Each manager could be responsible for all environmental
requirements within her/his department; or
2- Different individuals could specialize in different
environmental responsibilities across the entire company.
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Assignment of Environmental Responsibilities
Position
Environmental Responsibilities
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Designation = critical or important.
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Examples of Environmental Responsibility Assignments
Environmental Responsibilities at Cove Marina
Position
Owner
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Environmental Responsibilities
Critical
Oversee environmental policy and Environmental Management Plan (BMP).
Oversee environmental manual.
Serve as primary contact for regulatory inspectors.
Commit resources to achieve environmental goals.
Important
Review audit results and progress on achieving goals and revise EMP as needed.
Update employees annually on environmental policy and goals.
Incorporate environmental procedures into patron contracts.
All
Employees
Critical
Attend training on and understand role in emergency action plan.
Attend training on and follow environmental Standard Operating Procedures (SOPs)
and Best Management Practices (BMPs).
Participate in annual review of marina environmental policy and goals.
Dockmaster
Critical
Act as marina's Emergency Coordinator for emergency action plan.
Maintain emergency action plan and train employees on it.
Track and inform Owner of changes to regulations affecting marinas.
Maintain environmental permits and provide quarterly reports.
Develop environmental SOPs and train employees on them.
Important
Educate patrons about marina's environmental policy and procedures and monitor
their activities for conformance.
Store
Manager
Critical
Educate patrons about environmental concerns related to product use, equipment
rental, and maintenance activities.
Important
Work with appropriate marina employees to evaluate effectiveness of environmentally
sound products.
Stock environmentally sound products that have proven to be effective.
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Environmental Responsibilities at Cove Marina (continued)
Position Environmental Responsibilities
Maintenance Critical
Manager Oversee management of wastes generated by employee activities and compile
quarterly waste data reports.
Perform sampling required by wastewater permit and submit reports.
Important
Monitor employees' use of environmental SOPs and BMP's.
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Environmental Responsibilities at Finley Refinishing
Position
Business Owner
•Environmental Responsibilities
Critical
Oversee and approve environmental policy.
Authorize annual budget for environmental program.
Important
Establish and lay out expectations for the Environmental Team.
Review the environmental policy and the Environmental Management Plan (EMP)
annually to make sure they are in keeping with business strategy.
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All
Employees
Critical
Attend training and know their role in the emergency response plan.
Attend training in and follow environmental Standard Operating Procedures (SOPs.)
Be familiar with the environmental policy.
Important
Understand environmental goals and targets and know role in helping to achieve them.
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Environmental
Team
Members
Critical
Guide the collection of information needed to gage environmental compliance and
performance.
Put together the EMP and review and revise it annually.
Important
Set goals and targets annually to improve environmental performance.
Shop
Supervisor
Critical
Act as Emergency Coordinator and maintain emergency response plan.
Oversee hazardous waste management program.
Oversee environmental SOPs used in each shop.
Train employees on environmental SOPs and emergency procedures.
Important
Train employees on their role in achieving goals and targets.
Maintain an up to date process map for each shop.
Conduct performance checks in course of normal work responsibilities to observe
whether employees are following environmental SOPs.
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Environmental Responsibilities at Finley Refinishing (continued)
Position
Production
Control
Assistant
(Environmental
Coordinator)
Environmental Responsibilities
Critical
Maintain environmental manual.
Track and inform Environmental Team of changes in regulations.
Identify environmental training requirements for each employee.
Important
Work with Shop Supervisor to follow up on audit findings and make sure corrective
and preventive actions are carried out.
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Getting It Written Down - Environmental Manual
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One of the greatest benefits of an EMP is that everything pertaining to environmental man-
agement is written down and can be found in one place. This helps ensure that tasks are done
consistently throughout the business. The environmental manual outlines the requirements of appli-
cable laws and how your business plans to meet them.
Your business most likely already has many written documents about your environmental manage-
ment activities. Begin by finding them all and arranging them in a logical order. Then, beginning
with the activities your business must do to keep in compliance, figure out where your gaps are, what
you have and what is missing. This is probably the most time consuming task of putting together the
EMP, but it will more than repay itself in time saved in the future because your EMP will allow you to
find information when you need it, even if the responsible person is not around.
Now you need to assemble the underlying information you have gathered into an environmental manual
that will help your business follow its EMP. The environmental manual describes how environmental
management activities are organized within your business. It is usually easiest to arrange this by
the major areas of environmental regulations such as hazardous waste management, air compliance,
or spill preparedness. Use the sample outline on the next page in conjunction with the Environmental
Manual Planning Worksheets at the back of this section to help make sure you have the basics
covered.
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Sample Environmental Manual Outline
Environmental Management Overview
I Person(s) in charge.
I Overview of regulations that apply.
I System for monitoring changes in regulatory requirements.
Emergency Preparedness
Person in charge.
Compliance status (specific regulations that apply).
Procedure for updating Emergency Plan.
Availability of Emergency Plan.
Description of training program.
Description of records.
Hazardous Waste Management
Person in charge.
System for identifying hazardous waste streams.
Inventory of hazardous waste streams and how they are managed.
Compliance status (specific regulations that apply).
Summary of permit requirements (if applicable).
Description of training program.
Description of records.
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Air Management
Person in charge.
System for identifying air emissions.
Inventory of air emissions.
Compliance status (specific regulations that apply).
Summary of permit requirements (if applicable).
Description of training program.
Description of records.
Wastewater
Person in charge.
Compliance status (specific regulations that apply).
Copy of current sanitary sewer ordinance.
Summary of permit requirements (if applicable).
Description of training program.
Description of records.
Storm Water Management
I Person in charge.
I Sifcejirainage map.
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> Location of drains and outfalls and their downstream connections.
I Compliance status (specific regulations that apply).
I Summary of permit requirements (if applicable).
I Description of training program.
& Description of records.
c Note that this sample outline is not a complete list. For example, it does not include regulations
g -j5 pertaining to very specific substances such as polychlorinated biphenyls (PCBs), pesticides, or chkr
Q c rofluorocarbons (CFCs). It is very important to develop a complete understanding of the requirements
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>• & ments of applicable laws apply to your business, contact your state Small Business Assistance Pro-
•J, | gram.
t» •> Once you have the general outline developed for each area, you should include these additional details:
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Environmental Plans and Permits
These are plans and documents that you are required to have to comply with regulations or that you
choose to have to manage your environmental affairs better. Examples include your current emer-
18 gency plan, any current environmental permits your business holds, and your annual environmen-
tal training plan. Your environmental manual should list each of these and tell where the most
current copy can be found.
Environmental Standard Operating Procedures (SOPs)
Having written environmental SOPs helps to make sure that important tasks don't get overlooked
and are easy to communicate. They can make cross-training easier, so that someone will be avail-
able to perform a critical function even if the regular employee is away. They can make turnover
easier because the person hiring will have a better idea of what each job entails. A good SOP spells
out what it is about, who it applies to, and what needs to be done in a step-by-step manner. You
should also include the date the it was first issued and the latest revision date. If your business is
ISO 9001 certified, you already have SOPs for your major business processes. This will give you a leg
up because all you have to do is make sure environmental management aspects are covered within
them. You may also have safety SOPs for certain tasks to which environmental aspects can easily be
added.
An environmental SOP can stand alone or consist of steps within a more comprehensive SOP for a
process within your business. For example, the procedure for turning a chemical waste over to the
person responsible for arranging its shipment would be one that can stand alone. ASOP for a spray
painting operation would include overall instructions on how to apply paint coatings as well as
covering environmental aspects such as' keeping air emissions, like volatile organic compounds
(VOCs), to a minimum; steps for cleaning the paint gun in order to generate as little waste as
possible; and steps to contain and manage the wastes that are generated. At the end of this section
there is a worksheet to guide you in developing environmental SOPs.
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Best Management Practices (BMPs)
After you have developed environmental SOPs for your business operations, it is a good idea to look
outside your business for BMPs that are appropriate to your business. Sources include industry or
trade associations for your type of business, university and state pollution prevention assistance
programs, state Small Business Assistance Programs, and the U.S. EPA Small Business Division.
If you find BMPs that apply to your business, take them to your Environmental Team to consider
whether they would be desirable and feasible to adopt. Include any BMPs that your business uses in
the environmental manual.
Following are three worksheets to help you pull together your environmental plan. The first worksheet
will help you outline the environmental manual for your business. The second worksheet is to assign
responsibility and target dates for developing sections of the environmental manual that aren't com-
plete. The third worksheet will guide you in developing a standard operating procedure for a particular
process.
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Environmental Manual Planning Worksheets
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Environmental Manual Section Guide
Section Title:
Section #:
Applicable Regulations'
1.
2.
3.
Person in Charge:
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Required Plans, Records, and Documents:
1.
2.
3.
4.
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Associated SOPs:
1.
2.
3.
4.
Associated BMPs:
1.
2.
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Environmental Manual Task List
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Section # & Title Applicable Laws Task(s) Person Target
Responsible Date
Example
Emergency
Preparedness
29 CFR 1910.120,
Wis. Adm. Code
NR615.
1. Revise emergency response
plan to meet requirements.
2. Update training requirements
and develop schedule.
Micky Smith
9/30/02
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Examples of Environmental Manual Section
Cove Marina Environmental Manual
Section 4 - Air Management
Person in charge
Business Owner.
System for identifying air emissions
Annual survey of activities on site that generate air emissions.
Inventory of air emissions
Inventory of Air Emissions — January 2002
Boat engine exhaust
Car engine exhaust
Welding machine
Airless spray paint gun
Aerosol spray paints
Paint removal
Gasoline-fueled
Gasoline-fueled
Various metals
Various paints
Cans - assorted manufacturers
Sanding (produces dust)
# of boats and hours vary
# of cars and hours vary
Usually less than 8 hours/day,
mately 20 hours/week
approxi-
Intermittently 8-10 hrs/ day on no more
than 2 boats at a time
Average 10 cans/day
Intermittently 8 - 10 hrs/day on
at a time
1-3 boats
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Compliance status
According to staff from the Wisconsin Small Business Assistance Program, Air Quality Regulations
are enforced for Cove Marina by the State Department of Natural Resources (DNR). They advised
that we submit a list of emission sources to DNR and ask for a determination of compliance status.
We submitted the list on 4/12/02. In a follow-up call on 5/12/02, DNR representative stated that these
activities would not require a permit because the emission levels are below thresholds that trigger the
need for a permit. However, an increase in welding and sanding activities would call for re-evaluation
of our status.
See also
4/12/02 letter to DNR from S. Smith, Owner, Cove Marina and 6/1/02 letter from DNR to S. Smith,
Owner, Cove Marina.
Summary of permit requirements
Not applicable.
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Description of training program
Maintenance Manager trains employees in BMPs for spray paint operations, container management,
and bottom sanding operations that reduce air emissions. They are also given training on filling out
log books for spray paint, sanding, and welding activities. Training takes place after hire, before they
engage in any activities that result in air emissions, with an annual update thereafter.
Descriptions of Records
Log books for spray painting, welding, and sanding activities.
Finley Refinishing Environmental Manual
Section 3 - Hazardous Waste Management
Person in charge
Shop Supervisor.
System for identifying hazardous waste streams
Monthly monitoring of waste containers. Annual comprehensive survey of shop activities.
Inventory of hazardous waste streams and how they are disposed (2001 data):
Type of Waste Amount Generated
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Compliance status
EPA ID number - WID 473253456. Finley Refinishing is a small quantity generator that must meet
the requirements of Wis. Adm. Code NR 610. These include the following:
Determine if wastes are hazardous;
Determine the quantity of hazardous waste generated;
Notify EPA of hazardous waste activities;
Ship hazardous waste to a licensed facility using a hazardous waste manifest;
Submit an annual report to Wisconsin Department of Natural Resources (DNR);
Comply with packaging, labeling, and marking requirements;
Meet container management requirements;
Develop and maintain emergency procedures;
Meet preparedness and prevention requirements; and
Train employees.
Summary of permit requirements
Not applicable.
Description of training program
Shop Supervisor trains new employees after hire and before they conduct any activities that generate
hazardous waste. Shop Supervisor provides an annual update and refresher training to all employees
whose activities generate hazardous waste. Shop Supervisor attends a half-day annual update train-
ing given by outside provider. Training includes waste identification, container management SOPs,
emergency procedures, and updating waste log.
Description of records
Shipping documents (manifests, land disposal restriction paperwork, packing slips);
Notification of hazardous waste activity;
List of satellite accumulation areas;
Monthly hazardous waste inventory;
Weekly container inspection logs;
EPA ID number;
Employee training records;
Employee position descriptions and training requirements; and
Annual hazardous waste activity report.
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Standard Operating Procedure (SOP) Worksheet
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To get organized, review the Environmental Manual Task List table (on page 22) to identify SOPs that
need to be developed or revised. List them in the left column of the table on the next page. In the
second column from the left, document why you are developing the SOP (e.g., to support environmen-
tal requirements, OSHA, DOT goals, or Best Management Practices and list them in the environmental
SOPs status). This will assist you in prioritizing SOP development.
Step 2
Review the Assignment of Environmental Responsibilities table (on page 11) to determine who needs
to be involved with developing each SOP and list them in the third column from the left of the table on
the next page. Assign a target date to complete development of the SOP.
Step 3
For each SOP that needs to be developed:
A. Write a statement of what this SOP is about.
B. State who this SOP applies to.
C. Meet with the employees who usually perform the part of the task that is being described in this
SOP. Ask them to help you write down the steps. Keep in mind that if SOPs have never been
written down before, you may discover that there may be a lot of things going on with what you
thought was a simple process. If this begins to develop as you talk with employees, then consider
whether there might really be more than one SOP needed to adequately cover all the aspects of the
process you selected.
D. Combine the information you put together in Steps A- C to develop a draft SOP. Then share it
with the employees you consulted for their comment and input before finalizing it.
Step 4
Periodically review your environmental manual and environmental SOPs to be sure they reflect any
recent changes to environmental regulations or to processes within your business.
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Status of Environmental SOPs
Target
Description of SOPs (newer revised) Why Written Who Should Be Involved n
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Example 1
SOP for annual waste stream inventory
(new)
Example 2
SOP to reduce air emissions from methyl-
ene chloride stripping (revise chemical
stripping SOP)
Environmental coordinator
Safety coordinator
Shop supervisors
Environmental coordinator
Safety coordinator
Stripping shop supervisor
5/15/02
6/01/02
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Example SOPs
Note: The following example SOPs focus mainly on the environmental aspects of these tasks. They do not
include detailed safety procedures and precautions that may apply to these activities.
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Cove Marina
SOP for Bottom Paint Repair
Date Issued Date Revised
3/31/01 4/24/02
Prepared by
S. Smith, Dockmaster
Scope
This SOP pertains to repair of small areas of hard bottom paint only (less than ten square feet).
Larger jobs involving hard bottom paint must be conducted in the spray paint booth under the SOP
for Bottom Repainting. Repair of boats with ablative bottom paint is not permitted at Cove Marina,
but the Dockmaster can refer boat owners to a nearby boatyard.
Personal Protective Equipment (PPE)
1. Refer to PPE Plan to select PPE for each task below.
2. Retrieve appropriate PPE from the PPE cabinet near the employee lockers in the main repair
building.
Remove Paint from Damaged Area
1. Sand boats only in the main repair building or the adjacent covered maintenance bay to prevent
sanding dust from blowing away.
2. Place non-absorbent tarp under the area of the boat to be sanded. Tarps are stored in plastic bags on
shelf above the sanding equipment.
3. Use vacuum sander only for mechanical sanding.
4. Contain dust from manual sanding within tarped area.
5. When done sanding, vacuum dust from tarp; fold, bag, and put away tarp.
6. Empty dust out of sander and vacuum and place, with used sand paper, into the drum labeled
"Hazardous Waste - Sanding Solids," replace the lid tightly when done.
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Prepare Surface for New Paint
1. Retrieve acetone container from flammable liquids storage cabinet. Carry it to the work location in
the drip pan hanging on the wall beside the cabinet, along with rags from bin labeled "Cleaning
Rags." (Do not use paper towels for surface preparation.)
2. Keep acetone container in drip pan throughout the process in case of spills.
3. Position drip pan under area to be cleaned.
4. For cleaning, pour acetone onto rag, wipe surface, and repeat until clean. Replace lid tightly on
acetone container.
5. Dispose of used rags in drum labeled "Solvent Contaminated Rags," replacing the lid tightly.
6. If acetone spilled into drip pan, retrieve from the flammable liquids storage cabinet the container
labeled "Acetone for Reuse" and carry it to the work location in the second drip pan, along with the
funnel. Pour spilled acetone into the "Acetone for Reuse" container using the funnel, while continu-
ing to keep the second drip pan beneath it. Replace the lid tightly when done.
7. Return acetone container(s) to flammable liquids storage cabinet, carrying them in the drip pan.
Return drip pan(s), unused rags, and funnel (if used) to storage locations.
Note: If any acetone spills outside of drip pan, follow emergency action plan.
Paint Surface
1. Place absorbent floor covering in an area big enough to capture all overspray. (Absorbent floor
covering is stored on the shelf above the spray paint equipment.)
2. Spray surface holding nozzle 12" from surface. Disengage trigger at the end of each pass at edge of
sprayed area. Spray at steady speed to keep excessive coating and overspray to a minimum.
3. When finished painting, record quantity and product number of paint used in Paint Log, located on
top of the paint storage cabinet.
4. Clean spray gun using the SOP for Solvent Cleaning.
5. Place absorbent floor covering pieces that are dry and not heavily covered with paint in bin labeled
"Reusable Floor Covering," located on shelf above spray paint equipment.
6. Place paint-contaminated absorbent floor coverings, stir sticks, or rags in the drum labeled "Paint-
Contaminated Solids," taking care to replace the lid tightly.
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Finley Refinishing
Hazardous Waste SOP 12 - Stripping Shop — Container Management
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Date Issued Date Revised
December 2001 January 2002
Applies to
Employees in the paint stripping shop.
1. Use only the containers listed in the table on the next page for shop waste streams.
2. Always keep waste container lids tightly closed except when adding waste.
3. Do not combine different wastes into the same container.
4. Keep your waste container in its designated catch tub to prevent spills and leaks onto the floor or
work benches. Although your supervisor performs weekly container inspections, if you notice that
a waste container has leaks, bulges, or any other abnormal condition, notify your supervisor imme-
diately.
5. If you are using a drip pan or catch tub to collect rinsate or sludge as you work, do not leave your
station unattended without transferring waste to the proper container.
6. When any waste container has been filled to its "max fill" line (equal to 90% full), write FULL on
the cap and notify your supervisor. (Supervisor will transfer it to the hazardous waste storage area
by the end of the day.)
7. Retrieve an empty container from the shop storage room and inspect it to be sure there are no
visible leaks or deformations and that the cap fits tightly. If it passes inspection, label it according
to the table on the next page before you place any waste in it. If it does not pass inspection, turn it
over to your supervisor with a trouble ticket.
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Finley Refmishing Container Management:
Waste Type
Rags from methylene chloride process.
Container Type
Label
DOT spec plastic five gal pail with lid.
"Waste rags contaminated
with methylene chloride"
Rags from solvent stripping (other than
methylene chloride).
UL-approved twenty gal ignitable
waste can.
"Waste rags contaminated
with toluene, MEK"
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Tack cloths from mechanical sanding
process.
Five gal plastic or metal pail with lid.
"Non-hazardous waste
rags"
Sludge from methylene chloride
stripping process.
DOT spec five gal plastic pail with lid.
"Waste sludge, contains
methylene chloride, lead"
•* E
Sludge from solvent stripping (other
than methylene chloride).
DOT spec thirty gal metal drum with
lid.
"Waste sludge, contains
toluene, MEK, lead"
Solvent waste from furniture rinsing.
DOT spec closed-head thirty gal metal
drum.
"Waste solvents, contains
toluene, MEK, acetone"
31
Wastewater from furniture rinsing
(methylene chloride stripping process).
DOT spec closed-head five gal pail.
"Wastewater, contains
methylene chloride"
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Making Progress Over Time - Setting Goals
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A goa/ is a general statement of a desired outcome to be achieved through the business' EMP.
JL ^Setting goals to improve your business' environmental management connects your EMP to daily
business activities. Goals are linked to the environmental policy and provide a vision of the direction
you want to go in over the long term.
Be sure that goals are realistic and fit within the mission and overall business strategy of your
company. Setting goals with unreasonably high expectations may frustrate and discourage employ-
ees. On the other hand, goals should inspire action by capturing a clear vision of where you and the
Environmental Team want to take environmental performance within the business. It is important to
select no more goals than your company has the resources to address at any one time. For a small
business just getting started, this number is typically five goals or fewer. Because the number of goals
a small business can effectively tackle at once is limited, identify those goals that that are critical to
your business' environmental performance and tackle those first. For example, confirming compli-
ance with environmental regulations and putting systems in palce to maintain compliance may be a
critical priority. There may also be waste reduction or water or energy conservation activities that are
compelling because of the potential for large cost savings for your business.
Your initial goals may be fairly general, such as to reduce the amount of waste generated. After you
have fully developed the EMP and have done some audits to see where you stand, you will be in a good
position to set more focused goals for improvement, and to select the goals that will add the most value
to your business. Targets are specific, shorter term steps towards achieving your goal, and are often
measurable. When coupled with measurable targets, meaningful goals become the drivers for environ-
mental performance improvement. How to select targets is discussed in the section on Keeping the
EMP Alive and Well - Monitoring and Corrective Action.
This is a good time to stall; thinking about targets &
measures. Further discussion occurs in the section on
Keeping The EMP Alive and Well.
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Worksheet for Setting Goals
Stepl
Brainstorm a list of possible goals to improve your company's environmental management. They may
have to do with compliance or they may be about reducing your business' use of resources, or prevent-
ing impacts to the environment. Don't worry about the difficulty of achieving a goal or its relative
importance during the brainstorming session. List the goals you come up with in the left column of
the Environmental Goals to Consider table on page 34.
Step 2
Go over the list of goals you developed during Step 1. For each goal, decide whether it is critical
(necessary to keep employees safe, prevent and respond to spills, or achieve compliance), or important
(helps your company manage its environmental affairs more efficiently and proactively, save money,
and increase the respect and goodwill of employees and community members). Indicate its signifi-
cance in the middle column of the table on page 34.
StepS
For each goal, indicate in the right hand column the degree of difficulty involved with achieving the
goal. Consider the budget, number of staff, degree of effort, and other resources needed to achieve the
goal.
Step 4
Select at least three goals to work on for the next several months to a year. Critical goals should be
your first priority. If these issues are under control, consider selecting the goals that have the biggest
return for the invested effort. If you can't come to agreement, then the Environmental Team can vote
on them or you, as the business owner, can decide.
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1.
2.
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Environmental Goals to Consider
Significance1
Difficulty2
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Example Goals
1. Verify compliance with all environmental regulations.
2. Verify the appropriate management of all waste streams.
3. Communicate the Environmental Policy to all employees.
f \_! * .. . .. 1 . , i
1. Update Emergency Response
2. Reduce hazardous waste.
3. Reduce energy use.
4. Reduce VOC emissions.
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king Progress -
tin? Goals
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35
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Keeping Track of Information - Recordkeeping
There are several good reasons to keep good records of your environmental management activi-
ties. Because most inspectors start with a close look at your environmental records, having
them in good shape helps your business get off on the right foot during an inspection. For this reason,
when getting organized, it is best to begin with records that are needed to meet regulatory require-
ments. After that, you can decide what information has additional value to you such as records that:
• Would be useful during an urgent situation involving your businesses' environmental matters
such as a spill or a complaint from the neighbors!
• Are essential to protect your business from legal and financial troubles down the road;
• Substantiate whether your business is performing to the level it committed to in its BMP', and
• Give you valuable data on business performance, or would be helpful in demonstrating to your
customers that your business is "green."
On the next page is an example master file list that gives you a simple system to organize your
environmental management files and records that go along with EMP and environmental manual. It
covers the most common environmental recordkeeping requirements. However, to make sure
nothing is missing, be sure to go back to your environmental manual and review the required docu-
ments and records listed in each section to make sure they are included in your master file list.
36
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Sample Master File List
Emergency Preparedness
I Emergency call list and decision tree.
I Spill reporting call list.
I Copies of emergency plans such as hazardous waste contingency plan! spill prevention, control, and
countermeasure (SPCC) plan! and storm water spill preparedness plan.
I Summary of annual emergency plan exercises.
I Documentation and critique of incidents that triggered emergency plan.
> Reports of spills to regulatory agencies.
Training Records
While many different environmental regulations require training, most companies find it easiest to
organize them according to employee. In each employee's file include'
I Position description including environmental responsibilities.
I Training plan (see Section on Training for information on how to develop employee training plans).
> Training certificates and the agendas or topics list for each training session, in chronological order,
with the most recent training first.
Waste Management
> Correspondence with regulators (inspection reports, regulatory interpretations, and other corre-
spondence).
> EPA Generator ID number(s).
> Current hazardous waste permit and associated documents and correspondence.
I Records of waste determination.
) Hazardous waste shipment paperwork.
> Special waste shipment paperwork such as universal waste batteries, lamps, and mercury switches,
used oil, PCB and non-PCB ballasts.
> Solid waste tipping records.
I Inspection records.
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Correspondence with regulators (inspection reports, regulatory interpretations, and other corre-
spondence).
I Current permits for major or minor sources and associated documents and correspondence.
I Emission calculations for potential to emit (PTE).
I Annual air toxics inventory.
I Inspection records and chemical usage records as required by permit conditions (e.g., VOC records,
pressure drop inspections, operating hours).
Wastewater Management
I Correspondence with local wastewater treatment plant authority.
> Copy of current sanitary sewer ordinance.
I Pre-treatment permit (if applicable) and associated documents and correspondence.
Storm Water Management
I Inventory of storm water drainage and outfalls from your property (include map).
> Storm water pollution prevention plan.
I Maintenance plan for storm water infrastructure.
I Storm water permit (if applicable) and associated documents and correspondence.
> Storm water annual reports and sampling results (if applicable).
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Master File List Worksheet
Stepl
Begin by reviewing Assignment of Responsibilities table and the environmental manual to identify what
files and records you need to keep track of. On an index card, sticky note, or some other system that
allows for manipulation, write the name of the file, what area of the environmental manual it relates to,
and a brief description of what it contains. Here are a couple of examples-
Environmental Manual Section 3: Waste Management
Contains hazardous waste manifest, (initial and confirmation copies,) Land Disposal Restriction
paperwork, and tracking sheet for hazardous waste shipments, in order by shipment date.
Environmental Manual Section 4: Air Management
Contains material safety data sheets (MSDSs) for all the raw materials we use that contain volatile
organic compounds (VOCs), a list of annual use rates, and calculation for annual VOCs emitted.
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Example Master File List
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Cove Marina Master File List
Date Issued
12/29/00
Date Revised
1/15/02
> Environmental Management Plan
I Written Plans
# Emergency Action Plan
# Waste Management Plan
# Hazard Communication Plan
I Patron Contract Language
I Compliance Records
# Correspondence with regulators
# Copies of regulatory inspections (if any)
I Employee Records
# Job descriptions
# Training records
# Certifications (pesticide applicator)
> Chemical inventory and material safety data sheets
I Hazardous Waste
# Notification of Regulated Waste Activity and ID number
# Manifests and land bans
# Bill of lading for recycled goods or non-hazardous waste
# Certificates of disposal
# Waste determinations, profiles, lab tests
# Waste generation data
# Proof of Insurance disposal companies
I Storm Water
# Permit
# Sampling and inspection results
# Annual report
# Storm water management pollution prevention plan
I Wastewater
# Permit
# Sampling results
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Master File List for Finley Refinishing
Wisconsin FID number WI348592
Date Issued
1/2/00
Date Revised
1/2/02
I Environmental Management Plan
> Spill Preparedness
# Emergency call list
# Emergency response plan
# Employee training records
# Annual exercises
# Spill notifications, reports, and response critiques
I Emergency Planning and Community Right to Know
# Correspondence with regulators
# Employee training records
# Chemical inventory
# Material safety data sheets
# Annual chemical inventory reports (Tier 2)
> Hazardous Waste
#• Correspondence with regulators
# Notification of regulated waste activity and ID number
# Employee job descriptions
# Employee training records
# Waste generation records
# Shipment paperwork (manifests, land ban paperwork, etc.)
# Hazardous waste services contract
> Air Management
# Correspondence with regulators
# Minor source permit
# Employee training records
# Emission calculations
# Inspection and chemical usage records as required by permit
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Keeping Track of Information - Document Control
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42
Once you understand what records your business needs to keep, how can you keep track of it all
as time goes on? By tackling it in a systematic yet simple way; a document control system
makes sure that each vital file or record has somebody looking after it to make sure it stays up to date
and is available to those who need it. Before assigning responsibility, look at each file or record on the
master file list you put together in the last section and ask yourself "what is the purpose of collecting
this information?" Some good reasons to hold onto a file or document are 1) it is critical to make sure
your company handles spills properly, keeps its employees safe, and stays in compliance with environ-
mental regulations! 2) it is important for helping your company to be efficient or proactive, to save
money or time, or increase the respect and goodwill of employees and community members; and, 3) it
will help you stay out of financial and legal trouble from future environmental claims.
To keep your document control system simply do three things:
1. As much as possible, keep everything in one place. The exception is when there is a compelling
reason for the information to be located elsewhere. For example, each shop should have its own list
of spill control supplies and personal protective equipment available in that shop.
2. For information that changes or gets updated periodically, assign the most logical person to be
responsible for keeping track of updates and changes. For example, for environmental SOPs per-
taining to a particular shop, it makes sense for that shop's supervisor to be responsible for main-
taining them.
3. Use a document control index that all employees have access to so everyone knows what version is
the most up to date and who is responsible for maintaining it.
4. If records are maintained electronically, make sure they are backed up by a hard copy, especially if
they are required for compliance purposes. The document control index should identify where both
electronic and hard copies are kept, and how often electronic records are backed up by a hard copy.
Use the Document Control Worksheet on the following page to help get your business' environmental
documents under control.
Federal and state regulations change frequently Contact
your state small business assistance provider for regular
updates.
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Document Control Worksheet
Stepl
Review your master file list and environmental manual to identify all of the environmental documents
your business needs to keep track of. List them in the left column of the table on the next page.
Step 2
Consider the purpose in keeping each document and designate its purpose (critical, important, history
or liability prevention). If you can't determine a good purpose for keeping the document, take it off the
list. Indicate the purpose of keeping each document in the second column from the left.
StepS
Refer back to the Assignment of Environmental Responsibilities table (on page 11) to identify the
person or position who will be responsible for updating the document when needed, keeping each
version of the document on file, and making sure the revised document gets to those who need to see
it. Indicate the name or position of the person responsible for each document in the third column from
the left.
Step 4
For each document, determine a date of issue. For each subsequent revision, list both the issue date
and the latest revision date. Indicate the appropriate issue date and, if applicable, revision date(s) in
the fourth column from the left.
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Step 5
Decide how often the document should be reviewed to make sure it is still current and appropriate for
business operations. Consider allowing documents to go no longer than one year before being re-
viewed, revised, and reissued. Indicate the frequency of revision for each document in the fifth column
from the left in the table on the next page.
Step 6
Decide who needs to get a copy of the document (or its electronic file) when it is revised. Indicate these
individuals in the far right hand column.
Step?
Consider the most strategic location(s) for each document (either posted or on file). Go back to the first
column and indicate in parentheses below the name of the document where it will be kept and/or
posted so that employees and others can review it.
Consider using your birthday or anniversary date as the
revision date.
If you shut down for inventory, that would be an ideal time to
update documents.
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Document Control Index
Document Purpose1 Person Issue Date & Review
(location) Responsible Revision Dates Frequency
Distribution
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44
1Purpose - C = Critical (related to compliance, safety, or spill preparedness)
I = Important (related to efficiency, prevention, cost savings, community goodwill)
L = Liability protection
H = History
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Example Document Management Index
Document Management Index for Cove Marina
Document Pur- Person Date(s) Review Distribution
(location) pose1 Responsible Issued Frequency
Environmental Management
Plan and Environmental
Manual
(Binder in Main Office,
Dockmaster's Office, and
Main Repair Building)
Emergency Action Plan
(Environmental files, and
posted in Dockmaster's
office, Main Repair Building,
and Fueling Station)
Patron Contract Language
(Business records, filed by
patron name)
Hazardous Waste Inventory
(Environmental files)
Fueling SOP
(Environmental files, and
posted at fueling station)
Drydock SOP
(Environmental files,
Dockmaster's office)
Bottom paint repair SOP
(Environmental files, and
posted in Main Repair
Building)
Topsides resurfacing SOP
(Environmental files, and
posted in Main Repair
Building)
C
C
I
C
C
C
C
C
Business
Owner
Dockmaster
Business
Owner
Maintenance
Manager
Dockmaster
Dockmaster
Maintenance
Manager
Maintenance
Manager
2/15/00
1/28/01
1/14/02 (issued)
3/15/02
2/16/01 (issued)
1/2/02
3/18/01 (issued)
2/12/02
1/3/01
1/17/00 (issued)
3/6/02 (issued)
9/12/01 (issued)
2/21/02
1/13/01 (issued)
2/21/02
1/13/01 (issued)
Annual
Annual or as
needed
Biannual
Annual
Annual
Annual
Annual
Annual
Dockmaster,
Maintenance
Manager
All employees
Patrons,
Dockmaster, Store
Manager, Fueling
Attendant
Fueling Attendant
Business Owner
Maintenance
Technician
Maintenance
Technician
Maintenance
Technician, Fueling
Attendant
45
1Purpose - C = Critical (related to compliance, safety, or spill preparedness)
I = Important (related to efficiency, prevention, cost savings, community goodwill)
L = Liability protection
H = History
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Document Management Index for Finley Refinishing
Document Pur- Person Date(s) Review Distribution
(location) pose1 Responsible Issued Frequency
Environmental Management
Plan (Environmental files,
binder in Shop Supervisor's
office)
Environmental Manual
(Binder in Environmental
files, on Shop Supervisor's
desk, and Production
Control Assistant's desk)
Emergency Response Plan
(Environmental files, on
clipboard located by phone
in main office, stripping
shop, finishing shop,
shipping office)
Hazardous Waste Inventory
(Environmental files,
posted on bulletin board in
break room)
Chemical Stripping SOP
(Environmental files,
posted by each chemical
stripping workstation)
Mechanical Stripping SOP
(Environmental files,
posted by each mechanical
stripping work station)
Finishing SOP
(Environmental files,
posted by each finishing
shop work station)
C
C
C
C
C
C
C
Business
Owner
Production
Control
Assistant
Shop
Supervisor
Production
Control
Assistant
Shop
Supervisor
Shop
Supervisor
Shop
Supervisor
3/16/02
2/28/01
2/14/00 (issued)
3/12/02
3/16/01 (issued)
4/15/02
3/12/01
3/25/00
3/14/98
4/2/02
1/3/02
10/4/01
1/16/99 (issued)
3/16/02
2/23/01 (issued)
3/16/02
2/23/01 (issued)
4/11/02
2/17/01 (issued)
Annual
Annual or as
needed
Annual or as
needed
Quarterly
Annual
Annual
Annual
Shop Supervisor,
Production Control
Assistant.
Business Owner,
Shop Supervisor,
Shop Lead
Workers
Business Owner,
Production Control
Assistant, Strip-
ping Shop Employ-
ees, Finishing
Shop Employees
Shop Supervisor,
Finishing Shop and
Stripping Shop
Lead Workers.
Production Control
Assistant, Strip-
ping Shop
Workers
Production Control
Assistant, Strip-
ping Shop
Workers
Production Control
Assistant, Finish-
ing Shop Workers
'Purpose - C = Critical (related to compliance, safety, or spill preparedness)
I = Important (related to efficiency, prevention, cost savings, community goodwill)
L - Liability protection
H = History
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^^^^^^^^^^^•^^••^^^•^•^•^^B
Master Schedule of Reports, Notifications, and Permits
fBlhis part of your EMP lists what reports your business is required to file with regulatory agerr
JL cies to comply with environmental regulations. You should also keep track of additional notifica-
tions to regulatory agencies that your business has made, such as reports of spills or releases, or filing
with EPA as a generator of hazardous waste. The reason you want to get these issues organized is so
your business doesn't find itself in a vulnerable position by missing a regulatory deadline or failing to
get a permit application in on time, potentially causing a permit lapse that could disrupt operations.
Here are examples of some (but not all) of these reports and notifications:
Type of Report Frequency
Notification of hazardous waste activity.
Hazardous waste activity report.
Air emissions permit application.
Annual air emission inventory.
Petroleum Storage Tank Registrations.
"Tier 1" or "Tier 2" emergency planning report.
One-time with updates as needed.
Annual or biannual.
One-time with periodic renewals.
Annual.
One-time and change-in-service notifications.
Annual.
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47
If any of your activities require an environmental permit, you also need to keep track of when the
permit will expire so you can submit an application for renewal or close it out in a timely way. If you
are not certain what reports, notifications, and permit applications your business is required to file,
this would be an excellent time to bring in your state Small Business Assistance Program to help you
get started.
In addition to reports that you must submit to regulatory agencies, there are likely to be reports that
you need to prepare internally that provide data and information necessary to fill out the required
report. You may also produce internal reports to provide information needed to track progress toward
meeting goals.
Once you are aware of all the reports and notifications that your business needs to maintain, you need
a simple system to manage them. Work through the following worksheet to develop an Environmen-
tal Master Schedule to help keep track of what needs to be done when and by whom. Include as part
of the annual cycle a review of current regulatory requirements to see if reporting or notification
requirements have changed.
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Master Schedule Worksheet
Stepl
Review the environmental manual and the Master File List to identify all the reports, notifications, and
permits your business must file with regulatory agencies. Make an index card (or other system) for
each report noting to what agency (or agencies) the report must be submitted, the person responsible
for compiling and submitting the report, any supporting internal reports or data necessary to produce
the report, and person(s) responsible for providing that information. Put the due date for each report
in one of the upper corners of the index card.
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March Ist Annually
Hazardous Waste Activity Report
Submit to: Wisconsin DNR
Person Responsible: Production Control Assistant
Supporting Internal Report or Data:
1) Hazardous waste shipment manifests and packing slips - Shipping & Receiving Clerk
2) Weekly waste inventory logs rolled up monthly - Shop Lead Workers
Step 2
Put the index cards in order by due date. Use them to fill out the Environmental Master Schedule
Worksheet on the following page. This will serve as a guide for all who are involved with environmen-
tal reports for the coming year. (As an alternative, master schedule information can be recorded on a
calendar.)
Step 3
At least annually, review the requirements of regulations to see if reporting or notification require-
ments have changed and revise the Environmental Master Schedule as needed.
Step 4
Check with the Environmental Team to see if new internal reports are needed to fulfill revised goals
or if any internal reports previously done are no longer needed. Revise the Environmental Master
Schedule accordingly.
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Environmental Master Schedule
Report (Agency Due Person Supporting Internal Data/ Date Submitted
submitted to) Date Responsible Report (Person Responsible) and Initials
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Example Environmental Master Schedule
Cove Marina Environmental Master Schedule
Report (Agency Due Person Supporting Internal Data/ Date Submitted
submitted to) Date . Responsible Report (Person Responsible) and Initials
Waste Generation
Data (Internal - to
document genera-
tor status)
Stormwater -
visual inspections
(Internal - required
by permit)
Wastewater -
sampling reports
(City Sewer
Authority)
Wastewater -
permit application
(City Sewer
Authority)
Stormwater -
permit application
(Wisconsin DNR)
Environmental
Reports Organizer
for calendar year
2003
(Environmental
Team)
Quarterly.
Quarterly.
15th of third
month of
each
quarter.
October 17,
2002.
(Current
three-year
permit
expires
January 17,
2003.)
April 1,
2005
(Current
five-year
permit
expires
July 1,
2005.)
12/31/02
Maintenance
Manager
Maintenance
Technician
Maintenance
Manager
Dockmaster
Dockmaster
Business
Owner
Weekly Waste Inspection Logs
(Maintenance Technician)
4/12/02 SLS
4/6/02 PDB
3/15/02 SLS
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Finley Refinishing Environmental Master Schedule
Report (Agency Due Person Supporting Date Submitted
submitted to) Date Responsible Report Person Responsible and Initials
Annual Chemical
Inventory
(Internal - OSHA
requirement and
for spill prepared-
ness planning)
Annual Hazardous
Waste Activity
Report
(Wisconsin DNR)
Annual Tier 2
Report
(County LEPC, City
Fire Dept., Wiscon-
sin DEC)
Review require-
ments and revise
Schedule for
calendar year 2003
(Internal)
Minor Source Air
Permit
(Wisconsin DNR)
1/15/02
3/1/02
7/1/02
12/31/02
5/31/04
Shop
Supervisor
Production
Control
Assistant
Shop
Supervisor
Production
Control
Assistant
Annual purchasing records
(Accounts payable specialist)
Waste inventory data rollup
(Shop Lead Workers)
Annual purchasing records
(Accounts payable specialist)
Annual Inventory of Air Emissions
(Shop Lead Workers)
1/8/02 BCL
2/23/02 JAK
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Example Environmental Master Schedule in Calendar Format
FEBRUARY
SUNDAY MONDAY
TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY
3
10
17
V 24
4
11
18
25
5
12
19
26
Weekly hazard-
ous waste data
rollup to
Production
Control
Assistant
- Shop Lead
Workers - g
13
20
27
7
14
21
28
Hazardous
waste
shipment data
to Production
Control
Assistant
- Shipping and
Receiving ..
Specialist -
8
15
Annual
Hazardous
Waste Activity
Report due to
DNR3/1
- Production
Control
Assistant -
22
2
9
16
23
J
-------
c
MARCH
SUNDAY
MONDAY
TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY
3
10
17
V 24
4
11
18
25
5
12
19
26
6
13
20
27
7
14
21
28
Annual
Hazardous
Waste Activity
Report due to
DNR
- Production
Control
Assistant - 1
8
15
22
29
2
9
16
23
3^/
53
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Communication
• f your business is very small, communication about environmental matters among employees
-Mjnay be accomplished in the natural course of day-to-day interactions. But, for many businesses,
making sure everyone who has a need to know stays in the loop requires some dedicated effort. This
section explains the part of your EMP that will make sure that employees and supervisors stay
involved with environmental management, understand your business' environmental policy, and can
provide a consistent message about your business' commitment to environmental performance. It will
also make sure your business is providing information to employees and others as required by regula-
tions. As your EMP comes together and your business develops a track record of environmental excel-
lence, you may also wish to more actively promote your business' EMP with customers and commu-
nity officials. This can be added to the Communication Plan when you feel ready to do so.
54
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Communication Plan Worksheet
stepi
Identify ways to inform all the employees at your business about the EMP and its goals and list them
in the Internal Communication Opportunities table on the next page. To get this information out
efficiently, you may want to look for opportunities through existing business meetings or events.
Step 2
Using the External Communication Opportunities table on the next page, identify all the people
outside of your company who need to, or would be interested to, know about your business' EMP. State
at least one reason why it would be strategic or beneficial for your business to inform them of the EMP.
Step 3
Referring to the information you developed in Steps 1 and 2, decide who will be included in the
Communication Plan for the coming year, how you are going to get the information to them, and who
will be responsible. Organize this information using the table on page 57. (Helpful hint: If you do not feel
your business is ready to present its EMP "to the world," you can leave out people listed in Step 2 until next
year, when you can consider this question again.)
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Internal Communication Opportunities
When How
Example
Annual employee performance reviews
Handout with environmental policy and this
year's goals.
External Communication Opportunities
Who Reason to Inform How
Example
Mayor
To demonstrate our business wants
to be a good neighbor.
Talking points presented at quarterly break-
fast meeting.
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Current Communication Plan
Issue Date
Who?
What?
How
Person
Responsible
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Example Communication Plans
Cove Marina Communication Plan
Date Issued Date Revised
January 2001 January 2002
• Who? What? How and When? Person
Responsible
^ Communication
^
58
Staff
Patrons
Community
EMP and goals and targets.
BMPs for pollution prevention.
Policy for cancellation of lease
for non-compliance with
environmental policies.
Waste disposal practices.
Suggestions for improvement.
Environmental commitment.
New environmental efforts.
Update during annual meeting.
Contract Language.
Newsletter.
Postings - dock area.
Posting at dumpster.
Bulletin board at picnic area or
bathrooms.
Invitation to information sessions.
Annual picnic on Marina grounds.
Policy posted on docks, at entrance,
and in office.
Host student field trips.
Owner
Dockmaster
Owner
Finely Refinishing Communication Plan
Date Issued
January 2001
Date Revised
January 2002
Who What How and When? Person
Responsible.
All employees
Shop employees
Sales staff
Chemical product
suppliers
Chamber of
Commerce
Environmental policy and
current goals.
Environmental goals and
targets.
Customer education on EMP.
Preference for less hazardous
products.
Environmental policy.
Presentation during annual meet-
ing.
Updates in business newsletter.
Chalk talk at weekly production
meeting.
Check in during monthly sales
meeting.
During annual contract negotiation.
Presentation at annual small
business reception.
Business owner.
Human resources
manager.
Shop supervisor.
Sales manager.
Purchasing
manager.
Business owner.
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Training
etting employees trained in everything they need to know to carry out their environmental
management responsibilities is one of the biggest challenges facing a small business owner.
Training is required by many environmental regulations. Employees need to understand how their
responsibilities contribute toward meeting the goals of your EMP if you are going to make progress.
Here are some suggestions for setting up an effective training program. While getting the training
program established, set priorities so that you work on getting critical training in place first: (l) train
those who handle chemicals on what to do if there is a spill or release; (2) make sure you have training
programs as required by regulations; and (3) train employees on good practices that improve effi-
ciency, save time or money, or help your business be proactive.
Use your environmental manual to determine what training is required by applicable laws to develop a
comprehensive list of training requirements. Then, refer back to the Assignment of Environmental
Responsibilities table to set up training so that each employee gets the training he or she needs, but
does not sit through training they don't need.
The Training Plan itself should include what training needs to happen, what type of training it will
be, and who is responsible. There should also be a target date and a completion date for each task in
your Training Plan. It is usually easiest to set up a Training Plan for the coming year. After that you
can review training requirements and revise the plan on an annual basis.
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Contact your state small business assistance provider for
help in determining training needs.
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Training Plan Worksheet
Stepl
Refer to your environmental manual to identify training that is required by applicable laws and list
them in the table on the next page.
Step 2
Refer to the Assignment of Environmental Responsibilities table (on page 11) to understand how many
employees need what type of training. This will help you decide whether it is more efficient to devote
a class to the training topic or to conduct training one-on-one or on the job (OJT). Use the table on
page 62 to help with the analysis.
StepS
Develop a Training Plan for each employee. Use the top part of the form on page 63 to establish
training requirements. Use the bottom part of that form to keep track of each employee's training.
Step 4
Using the information you developed in Steps 1 through 3, fill out the table on page 64 to develop a
Annual Training Plan for your business.
60
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Summary of Required Training
Training Topic
Example
Hazardous waste handling and emergency procedures
Code Citation
Wise. Adm. Code NR 610.
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Training Overview
Training Requirement
# of Employees to Train
How Often?
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Individual Employee Training Plan
Employee's Name:
Employment Date: / /
Termination Date: / /
Job Title:
Type of Training
Training Plan
Training Requirements
7.
Date of Training
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63
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Annual Training Plan
What and Who?
Type1
Trainer
Frequency Completed
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64
1Key for type of training:
OJT = on the job training.
Chalk Talk = short updates during weekly production meetings.
Class = classroom.
1 on 1 = one-on-one meeting with talking points on a handout.
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Example Training Plans
Cove Marina Train ing Plan
Date Issued
January 2000
Date Revised
January 2002
What and Who? Type1 Trainer Frequency Completed
Emergency procedures -
all employees
Hazardous waste - all employees
Storm water pollution prevention -
all employees
Wastewater for Maintenance
Technician
Class
Class
1 on 1
Class
1 on 1
Dockmaster
Maintenance
Manager
Dockmaster,
Maintenance
Manager
Maintenance
Manager
Maintenance
Manager
Annual (March)
Annual (July)
As needed
Annual (July)
Annual
3/15/02 SLN
See log sheet.
See log sheet.
3/1 5/02 SRS
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65
1Key for type of training:
OJT = on the job training.
Chalk Talk = short updates during weekly production meetings.
Class = classroom.
1 on 1 = one-on-one meeting with talking points on a handout.
-------
Finley Refinishing Training Plan
Date Issued
January 2000
Date Revised
January 2002
What and Who? TVPe1 • Trainer Frequency Completed
Emergency response plan for
shop employees.
Emergency response aware-
ness training for all other
employees.
Hazardous waste for shop
employees.
Hazard communication for
shop employees.
Hazmat Shipping for Environ-
mental coordinator.
Air permit requirements for
paint booth operators.
EMP orientation for new
employees.
EMP goals.
Class
Class
Class
Chalk talks
OJT
Class
Class
Chalk talks
OJT
1 on 1
Annual Employee
Meeting
Shop Supervisor,
HR Manager
Business owner,
Shop Supervisor
Production Control
Assistant
Shop Supervisor
Shop Supervisor
HR Manager
Outside contractor
(ABC Hazmat Inc)
Production Control
Assistant
Shop Supervisor
HR Manager and
Shop Supervisor
Business Owner
Annual
Annual
Annual
Quarterly
As needed
Within 30 days of
hire and annually
Every three years
Annually or when
permit require-
ments change
Within 30 days of
hire
Annual
1/7/02 JAL
LLE
1/5/02 JAL
AEC
1/7/02 JAL
1/24/02 BTC
3/15/02 BTC
2/20/02 BTC
3/10/02 BTC
Ongoing
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66
'Key for type of training:
OJT = on the job training.
Chalk Talk = short updates during weekly production meetings.
Class = classroom.
1 on 1 = one-on-one meeting with talking points on a handout.
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Keeping Your EMP Alive and Well
This part of the EMP helps you verify if you are on the right course and gives you a method for
getting back on course if you find you have strayed. There are three components to monitoring:
l) environmental compliance monitoring, 2) environmental performance monitoring, and 3) manage-
ment review, and corrective action.
Environmental Compliance Monitoring
This function determines whether your business is in compliance with regulations and whether
employees are following SOPs and BMPs that contribute to compliance. Audits are a good way to
determine compliance with regulations and to observe whether employees are following SOPs and
BMPs. These can be done internally or by an outside party. You can enlist supervisors to do perfor-
mance checks in the course of their daily work. It is a good idea to conduct a comprehensive compli-
ance audit every few years to help ensure that you have not overlooked any new activities within your
company that may affect the environment or any new or changed regulatory requirements. Your
state Small Business Assistance Program may be able to assist with compliance auditing. The Com-
pliance Monitoring Worksheet will help you set priorities and assign responsibility for audits.
Environmental Performance Monitoring
This activity verifies whether or not goals stated in the EMP are being achieved. To do this, you need
some way to measure progress towards your goals. Measures are usually expressed in numbers - tons
of waste generated, pounds of volatile organic compounds (VOCs) emitted. For example, if your goal is
to reduce hazardous waste, then your measure might be the pounds of waste generated over a year's
time. A target tells you by how much you want to achieve your goal, as expressed by your chosen
measure. For example, if your goal is to reduce waste, and your measure is the amount of waste
generated per unit of product, then a target might be to reduce that amount by 10 % within one year.
Now you are getting very specific. This is useful to everyone in your company who has to help achieve
your company's environmental goals because now they know exactly what they should be shooting
for. The Performance Monitoring Worksheet will guide you in identifying meaningful targets.
As your EMP matures, goals and targets need to be revisited. You may choose to keep the same goal
but change the target to reflect a higher performance expectation. Or, you may choose to retire certain
goals and adapt new ones to reflect new environmental management challenges your business is
facing. The idea is that the goals and targets work together to fuel ongoing improvement to the EMP.
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Don't forget that production-based targets should be measured
using some system that takes changes in production into account.
For example, reduce the amount of water used by 10% for every
1,000 units produced. This way shifts in production will not
misrepresent the progress you have made.
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Management Review
As the business owner, you want to make sure that the BMP meshes well with your overall business
strategy and continues to add value to your business over the long haul. This means that on a regular
basis you need to review the goals of the BMP, consider the system of action and accountability it has
established throughout your company, and look at the results of monitoring to see how well the BMP
is working to achieve compliance and to meet its stated goals. Also consider how much value the BMP
is returning to the business for the effort invested. Are environmental management costs higher or
lower than this time last year? Are employees more comfortable with their environmental responsi-
bilities? Is it taking less time overall for your business to meet regulatory requirements? Are you
sleeping better at night?
Even if you have been involved in the BMP all along, it is a good idea to set aside some time at least
once a year to make sure you are "seeing the forest through the trees." You are probably in the best
position to determine when certain procedures, goals, or targets in the BMP have outlived their useful-
ness and need to be updated or eliminated. Whether or not you want to enlist others in performing the
management review is your decision. It may make sense to seek out the opinions of your key supervi-
sors and members of your Environmental Team. However you decide to approach it, you can use the
Management Review Worksheets as a guide.
Corrective Action
This is where the rubber meets the road. If you have a system to identify problems but then fail to
correct them, you may be worse off than when you started, especially if the problem affects whether or
not your business is in compliance with applicable laws. Once you have a finding that indicates a
problem, you need to do four things' l) investigate the root cause of the problem; 2) create a solution
to correct the existing problem as well as preventing the problem from happening again! 3) assign
responsibility for corrective and preventive actionl and 4) check back later to see if the problem has
indeed been solved. The Corrective Action Worksheet will help you work through this process.
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Compliance Monitoring Worksheet
Stepl
Based on their experience, ask members of the Environmental Team to identify what areas of environ-
mental regulations they believe the business should audit to verify compliance.
Step 2
Decide what criteria to use to prioritize auditing efforts for the coming year. Some criteria you may
want to consider: 1) likely to have a high degree of non-compliance, 2) likely to be the focus of a
regulatory inspection in the near future, 3) poses a high potential risk to employees, the community,
or the environment, and 4) poses a high degree of liability if not properly managed.
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Apply your screening criteria developed in Step 2 to the list of areas to be audited developed in Step 1
to come up with two to three areas to emphasize in audits during the coming year. List them in the
table on the next page and indicate for each area whether a full compliance audit is warranted or
whether selected areas will be targeted for evaluation.
Step 4
Decide what resources and methods the business can apply to fulfill audit plans identified in Step 3.
Some methods to consider: i) assign the responsibility within the business, 2) seek low cost or no cost
resources outside your business such as the state Small Business Assistance Program, or peer ex-
change with or mentoring from another business that you are not in direct competition with, and
3) hire a consultant. Identify in the table on the next page who will be responsible for each audit.
*•§
69
StepS
Identify in the table on the next page a target date for completion.
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' -4 '.**- -
Audit Plan for the Coming Year
Environmental
Management Area
Audit Type1
By Whom
By When
'Audit Type
Performance check: Regular observation of selected activities in the course of daily activities during a given time period
by supervisor, manager, or other designated person.
Targeted compliance audit: An audit of selected compliance points for a major or minor area of environmental regula-
tions.
Full compliance audit: A thorough audit covering every applicable compliance point for a major area of environmental
regulations.
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Worksheet for Performance Monitoring
Stepl
For each goal you selected in the section on Making Progress Over Time—Setting Goals, decide what
is the best way to measure progress toward meeting that goal. (Helpful hint: to keep it simple, use
data that is already available, such as purchasing records, if it can provide any kind of a meaningful
measure. This may be better than having employees take time to collect new data, especially in the
early stages of the EMP.)
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01
Step 2
For each goal, decide by how much you want to improve and set a target. Be sure to set realistic
targets. Achieving targets in the first year will help employees feel encouraged about their progress and
provide momentum for more challenging goals and targets in future years.
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Step 3
Assign responsibility for gathering the information needed to confirm whether your company has met
its target.
71
Step 4
Use the table on the next page to plan environmental performance monitoring for the coming year.
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Environmental Performance Monitoring for the Coming Year
Goal
Target
Responsible for Monitoring
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Example of Goals and Targets
Goals and Targets for Cove Marina
Verify compliance with all environ-
mental regulations.
Identify and list applicable regulations by 6/30/02.
Develop a system to stay current with new requirements by 12/31/02.
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Verify the appropriate manage-
ment of all waste streams.
Begin monitoring dumpster weekly for wastes that do not belong by
3/31/02.
Update employee training on waste management practices by 6/30/02.
Create clearly designated and marked areas for patrons to leave
acceptable wastes by 9/01/02.
Educate patrons on use of site disposal options and unacceptable
materials by 9/30/02.
Communicate Environmental
Policy to all employees.
Present Environmental Policy to employees and their families at annual
picnic, July 2002.
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Goals and Targets for Finley Refinishing
Update Emergency Response
Plan.
Finalize written plan, train all employees, and put in place coordination
agreements with outside responders by 6/30/02.
73
Reduce hazardous waste.
Reduce pounds of hazardous waste generated per unit produced by
10% by 12/31/03.
Analyze hazardous chemical product use in comparison with purchas-
ing for opportunities to reduce disposal of excess products by 6/30/02.
Evaluate effectiveness of environmentally preferable stripping solvents
by 12/31/02.
Reduce energy use.
Determine payback period to upgrade furniture drying equipment with a
more energy efficient model by 9/30/02.
Reduce VOC emissions.
Attain a 30 % reduction by replacing finish spray guns with HVLP
equipment by 9/30/02.
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Management Review Worksheet - Performance
Stepl
Take time to review the EMP as well as results of audits and performance monitoring conducted over
the past year or so.
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Step 2
Consider these questions '•
Are we achieving compliance with environmental regulations? If not, do we know why not?
74
Is our environmental policy still appropriate for our business' activities and culture?
Are we meeting our goals and targets? If not, why not?
Are our goals and targets still adequate for keeping our business on track with our environmental policy?
Management Review Worksheet - EMP
Stepl
Has the EMP added value to the business by:
Making environmental compliance more effective? yes no
Making environmental management less time consuming? yes no
Causing changes to processes or procedures that reduced liability? yes no
-------
no
Causing changes to processes or procedures that saved money? yes
How does the EMP detract from the business? What can be done to prevent or reduce this from happening?
Step 2
Based on your responses to the questions in Step 1, what are the three most critical issues that need
to be addressed to improve the EMPl If you have critical issues taken care of, what are the three most
important^
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3.
75
Step3
Meet with your Environmental Team and discuss the changes you came up with during Step 2 and
why you are suggesting them. Discuss how these changes can best be made, and assign responsibility
for following through on making them.
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Corrective Action Worksheet
Stepl
Describe in one or two sentences the identified problem.
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Step 2
Investigate the problem by asking members of the Environmental Team and any employees, who
work in the area where the problem is occurring, what they believe the root cause of the problem to
be.
Step 3
Determine possible corrective and preventive actions that your business can undertake to respond to
the problem. You may want to involve members of the Environmental Team in a brainstorming
session to develop a list of possible corrective and preventive actions.
76
Step 4
From the list of corrective and preventive actions developed in Step 3, decide which one or two will be
most effective and feasible given resources available. Write a memo briefly stating the problem, what
corrective and preventive actions the business will take, and who will be responsible to take them.
StepS
Distribute the memo to everyone who needs to know about it. Check in on those who have follow up
responsibilities to make sure they understand what needs to be done.
Step6
Decide how much time should pass before checking to see if the corrective and preventive actions are
working. Put a reminder for yourself on your calendar so you don't lose track of this as time goes on.
Step?
When the time comes, evaluate the results of the corrective andpreventive actions and consider whether
the BMP needs to be revised to reflect a better approach to this particular issue for the future.
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Summary
If you have read through this Workbook from beginning to end, you can see that the process of
developing an Environmental Management Plan can be tackled in a series of manageable steps that
are connected by a flow of information and ideas. Each step illuminates the path ahead, helping your
business to make steady progress towards organizing environmental management in a way that adds
value to your business and fits with its culture. The process is designed with built in opportunities to
review and improve performance so that the EMP itself will better serve your business as time goes
on. This way you can start out simple and build confidence with early success. By revisiting the EMP,
it remains a vital tool that grows with your business' capabilities and reflects its strategic direction,
rather than being just another dust-covered document.
Some last things to keep in mind: take your time. It is better to develop the EMP over a period of
several months to a year than to feel that the effort required has detracted from your core business
activities. Define the boundaries at the beginning of the process and stay within them. For example,
will your EMP cover the entire business to start out with or will you focus on key processes? Is your
initial focus on assuring compliance with applicable laws, or do you have an interest in environmental
performance that goes beyond compliance? At what stage do you want to share your EMP with people
outside of your business? Making these fundamental decisions early on will make the efforts that you
and your employees invest more focused and likely to succeed.
Once you have established your EMP, you may want to give some thought to whether it would be
beneficial to your business to pursue outside certification as a formal Environmental Management Sys-
tem (EMS) or verification through a recognition program such as U.S. EPA's Performance Track. For
example, if one of your major customers is requiring that you have an EMS, or will be doing so in the
future; this could be a compelling reason to take your EMP to the next level. For more information
about certification, performance track, and EMS principles see www.epa.gov/ems.
Finally, remember that you are not isolated. Your state Small Business Assistance Program as well
as the U.S. EPA Small Business Division can assist you with nitty gritty questions about regulatory
requirements or broad issues of environmental management. If you are not certain how to get in
touch with your state Small Business Assistance Program, consult www.smallbiz-enviroweb.org/, or
call the U.S. EPA Small Business Division at 800-368-5888, and they can refer you to the appropriate
contacts. When you contact them, you may wish to request the companion publication to this Work-
book, A Practical Guide to Environmental Management for Small Business, as well as any available summa-
ries of Plugging into Best Environmental Management Practices for Your Small Business for your type of
business. The U.S. EPA Small Business Division and its state partners are there to open the door to
small business owners who need to solve environmental management challenges. All you need to do is
knock on the door and come on in.
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