lectorStrategies
A Guide to Developing
   Metal Finishing Facilities
  "36



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The Terms We Use
CFR: Code of Federal Regulations

Cross-Functional Team (CFT): The CFT is made up
of members of each major operation within your
facility who represent their area or department in
several facets of the EMS and serve as an infor-
mation resource.

Environmental Aspect: An element of your facili-
ty's activities, products, or services that can or
does have an impact on the environment.

Environmental Impact: Any change to the envi-
ronment, whether  good  or bad,  resulting from
your facility's activities, products, or services.

Environmental   Management  Representative
(EMR): A member of your facility's top manage-
ment who: identifies all EMS tasks and  makes
sure they are completed on time; reports periodi-
cally to  the  management group; and demon-
strates top management's commitment to the EMS.

Environmental Policy: Your facility's statement of
 its main environmental commitments.

 ISO 14001: A standard set by the  International
 Organization for Standardization that is primarily
 concerned with "environmental management."

 Significant Environmental Aspect (SEA): An envi-
 ronmental aspect  that has, or potentially has a
 significant impact on the environment.

 Nonconformity: A discrepancy between  your
 facility's actual EMS  activity and a related proce-
 dure in your EMS Manual.
Where to Find  More EMS
Information
If you have questions about EMS, there are many
sources of information available to you. You can
get information online by visiting the following
Web sites:
• Visit EPA's Web site at www.epa.gov/sectors/
  metalfinishing  to download  an  electronic
  version of this document, including forms you
  can fill out to create your own EMS Manual.

• Visit EPA's Web site at www.epa.gov for infor-
  mation  about  environmental regulations,
  tools,  and  compliance  guidance. Information
  specifically about  EMS can  be  found at
  www.epa.gov/ems/.

• Visit EPA's compliance  assistance Web site at
  www.epa.gov/compliance/resources/publications
   /assistance/sectors/chemicalpub.html  for  a
   list of EPA compliance tools.

• Download  EPA's  list of environmental  assis-
   tance providers for small businesses, "A
   Resource   Directory  of  Small   Business
   Environmental Assistance  Providers"  [EPA-
   233-B-02-001]  March  2002,  85  pp., from
   www.epa.gov/sbo/pubs.htm.

  I Visit the U.S. Small Business Administration at
   www.sba.gov for information about services
   available to small businesses.

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 Part  I:
 Steps  of  an
 Environmental
 Management
 System
Define the Scope

of Your Facility's

EMS and Assign

Responsibilities

What
** * '   * -*' ~ *
An EMS' scope is how much of a facility's activi-
ties the EMS covers. For example, the scope of
your facility's EMS may be all of the operations
occurring on site at the plant—from the point of
entry of raw materials and energy to the point of
exit  of finished products. Or, your scope may
extend even further to include your suppliers and
contractors. EMS responsibilities should be
assigned  to individuals who can competently
complete the tasks.

Who
While your facility's characteristics will determine
who should be responsible for implementing
your EMS, the following concepts are common
across all facilities:
• One person can't develop and implement the
  entire EMS. An EMS involves everyone.
• Managers must reinforce the importance of
  EMS tasks.
• Employees with EMS  responsibilities must
  know that they have management support.

• Authority and resources must be made avail-
  able to employees with EMS tasks.

• Managers should evaluate each employee's
  performance of their assigned EMS duties.

• EMS assignments should be put in writing (see
  Sample Form 1:  EMS Responsibilities, on the
  next page).

Select an EMS Team, made up of the following
people:

• Environmental Management Representative
  (EMR): The EMR  is a member of your facility's
  top management who: identifies all EMS tasks
  and makes sure  they are completed on time;
  reports periodically to the management group;
  and demonstrates top management's commit-
  ment to the EMS.

• EMS Coordinator: The EMS Coordinator leads
  the EMS Team  and ensures support for the
  EMS. The EMS Coordinator also makes sure
  that all EMS tasks are completed and maintains
  the EMS Manual under the leadership of the
  EMR.  In  a small facility, the EMR  and EMS
  Coordinator may be the same person.

• Cross-Functional Team (CFT): The CFT is made
  up of members of each major operation within
  your facility who represent their area or depart-
  ment in several facets of the EMS and serve as
  an information resource. The CFT meets regularly.

Why

The scope ensures that your facility's EMS is the
right size and assigns responsibility for EMS
tasks. Assignments won't get done if employees
don't know whose job it is to do them.
                          Guide to Developing an EMS for Metal Finishing Facilities

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How
A discussion between your facility's top manager
or owner and key employees will quickly lead to
a determination of the scope—what your EMS
does and does not cover and why. It is important
to assign the members of your EMS Team as
soon as possible, as they will play key roles in
developing your EMS.

Train employees who are assigned EMS tasks to
make sure they are able to carry out their respon-
sibilities. Training  can  take  many different
forms—from structured training classes to a two-
minute chat once a week—as long as employees
understand  and can perform their  job when  it
comes to the environment. To find out more on
assigning responsibilities, see the "Who" section
of each step in this document.
Sample Form 1: EMS Responsibilities
EMS Function
Environmental
Management
Representative (EMR)
EMS Coordinator
Cross-Functional Team
Name Regular Position
Simon Cutright
Carol White
Willie Scott
Darnell Jenkins
Julia Jordan
Paula Lingo
Jonathan Ash
Maria Lopez
Oz Glenn
Facility Manager
EH&S Manager
Manufacturing Supervisor
Injection Molding Line
Finishing Line
Packing Supervisor
Packing Line
Sales Supervisor
Building Maintenance
 Guide to Developing an EMS for Metal Finishing Facilities

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*• I
            ' t •
             J< I
Create Your
Environmental
Policy Statement
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Aji envlrblimerital pjDlicy.sjates the main environ-
mental commitments Of your facility and guides
the actions of employees and top management. It
also demonstrates your facility's environmental
performance commitments to  employees, cus-
tomers, and the public.

Who
Your EMS Team drafts your environmental policy.

Why
The policy sets the standard for how your facility
interacts with the environment. It is a statement
to employees, customers, and the public on how
important the environment is to your facility. It
recognizes that environmental performance is an
important component of good business decisions.

How
Your EMS Team should develop the policy that
outlines your facility's commitment to improved
environmental performance. Examples of com-
mitments that should be stated in your EMS poli-
cy (as presented by EPA's National Environmental
Performance Track) include:

• Compliance with legal requirements and any
  voluntary commitments;

• Pollution prevention;

• Continuous improvement  in environmental
  performance,  including non-regulated  areas;
  and

• Communication with your community about
  your facility's  environmental performance and
  the operation of your EMS.
                                    Once your EMS Team drafts your policy, they
                                    should sign it. Then, prominently display your
                                    policy throughout the facility to remind employ-
                                    ees and visitors of your commitment to the envi-
                                    ronment. You can find interesting ways to remind
                                    your employees of the policy, such as printing the
                                    policy on T-shirts, coffee mugs, or identification
                                    badges. Top management should announce the
                                    policy to all workers to demonstrate its business
                                    importance.


                                    Treat your environmental policy the same way
                                    you treat other types of company policies in deci-
                                    sion-making, internal and external communica-
                                    tion, implementation, and review. If your facility
                                    has a policy for quality control, consider building
                                    on it to develop your environmental  policy. All
                                    employees and on-site personnel must be aware
                                    of the policy and implement it as they do their
                                    daily activities.
                        Guide to Developing an EMS for Metal Finishing Facilities

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                           Sample Environmental Policy

  Star Plating is committed to improving the environment. We will do so by complying with
  all environmental laws and regulations. Star Plating also commits to:
     Minimize the amount of waste generated;
     Ensure the safe disposal of waste;
     Reuse and recycle whenever possible;
  •   Reduce emissions into the water and air;
  •   Use energy, water, and metals efficiently throughout our operations;
  •   Reduce human exposure to toxic materials in the facility and in the community;
  •   Monitor our environmental performance; and
  •   Continuously seek opportunities to improve on these principles.

  At Star Plating, the environment is everyone's job, because we live here too.
  Facility Manager:   Date:
Cross-Functional Team:
Date:
Guide to Developing an EMS for Metal Finishing Facilities

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 Identify Your
 Environmental
What
Environmental aspects are the elements of your
facility's activities that either impact the environ-
ment or could potentially impact the environ-
ment. For example, a spill from a parts washer is
an environmental aspect because of its potential
impact on water or land.

Who
Assign people with process knowledge to determine
your facility's environmental aspects. Or, assign the
EMS Team to this task, with help from process-
specific employees. Assign someone, such as the
EMS Coordinator,  to ensure that your environ-
mental aspects are reviewed regularly to reflect
facility changes, like new processes or materials.
Why
Knowing your facility's  environmental aspects
allows you to manage your facility's impacts and
potential impacts on the environment.

How
There are several ways to identify your environ-
mental aspects, such as:

• List the operations that fall within the scope of
  your EMS.

• Diagram your facility's inputs and outputs or
  processes  to identify their environmental
  aspects.

• For each of your facility's operations, list the
  environmental aspects (environmental inputs
  such as water, energy, and raw materials) and
  environmental outputs (such as those that are
  discharged to water, air, or land).

Use Sample  Form 2: Environmental Aspects and
Impacts, below, to list the environmental aspects
by operation, along with  their actual or potential
impacts (quantified to the extent possible).
Sample Form 2: Environmental Aspects and Impacts
Operation I Input/Output Environmental Aspect Environmental Impact
1 ! (quantify if possible) ' ^

Material receiving/
storage



Surface preparation


Cardboard boxes
Wood pallets
Plastic film
Energy (gasoline-
powered fork lifts)
Abrasive blasting
(cabinet)
Stripping solutions,
acids, caustic cleaning
solutions
Trichloroethylene
degreaser
Energy (2.500 kWh/mo.
For all operations and
administration)
Rinse water
Cardboard waste (500
lb./mo.)
Wood waste (500 lb./mo.)
Plastic waste (70 lb./mo.)
Air emissions (6 gal
gasoline/mo.)
Spent blasting media
(average 50 Ibs/mo.),
participate air emissions
Spent acids and solutions
VOC air emissions, spent
degreasing solutions
Air emissions
Wastewater sent to
pretreatment unit, then to
POTW (gal/mo.)
Depletion of landfill space, air
pollution from transport
Depletion of landfill space, air
pollution from transport
Depletion of landfill space, air
pollution from transport
Depletion of oil, air quality
degradation
Air quality degradation,
depletion of landfill space
Depletion of landfill space, air
pollution from transport, air
quality degradation, water
quality degradation
Depletion of landfill space, air
pollution from transport, water
quality degradation, air quality
degradation
Depletion of energy-producing
resources, air quality
degradation
Depletion of water supply, water
quality degradation
                             Guide to Developing an EMS for Metal Finishing Facilities

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Operation i Input/Output ! Environmental Aspect , Environmenta| |m ,
1 (quantify if possible) !

Metal finishing
processes




Wastewater
pretreatment


Laboratory
operations

Building and ground
maintenance


General
administration
Zinc and nickel plating
solution
Hard chrome plating
solution
Rinse water
Energy
Rinse water
Spent adds
Spent caustic cleaners
Treatment chemicals
Sulfldes and other air
contaminants
Energy
Lab wastes
Testing
Energy
Landscaping
Lawn maintenance
Energy from gasoline
Paper/office trash
Product transportation
Energy
Spent plating solution, air
emissions, sludge
Spent plating solution, air
emissions, sludge
Rinse water sent to
pretreatment unit, then
POTW
Air emissions
Treated effluent, sludge
Treated effluent, sludge
Treated effluent, sludge
Treated effluent, sludge
Air emissions
(See above)
Paper waste (40 Ib/year or
6.67 lb/1000 units)
Air emissions
(See above)
Water use
Herbicide and insecticide
runoff and/or leaching
Air emissions
Paper waste (40 .b/year or
6.67 lb/1000 units)
Air emissions
(See above)
Depletion of landfill space, air
pollution from transport, air
quality degradation, depletion of
zinc and nickel
Depletion of landfill space, air
pollution from transport, air
quality degradation, depletion of
chromium, worker health
Depletion of water supply, water
quality degradation
Depletion of energy-producing
resources, air quality
degradation
Depletion of water supply, water
quality degradation, depletion of
landfill space, air pollution from
transport
Water quality degradation,
depletion of landfill space, air
pollution from transport
Depletion of natural resources,
water quality degradation.
Depletion of landfill space, air
pollution from transport
Air quality degradation, worker
health
(See above)
Depletion of landfill space, air
pollution from transport
Air quality degradation
(See above)
Depletion of water supply
Water quality degradation
Air quality degradation,
depletion of oil
Depletion of trees, depletion of
landfill space
Air quality degradation,
depletion of natural resources,
depletion of landfill space (tires,
etc.)
(See above)
Guide to Developing an EMS for Metal Finishing Facilities

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 Identify Relevant
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                        _^
                      ents
^Whif'i>% 'Jfr:! ^ ; V ,'
 Once you determine your facility's environmental
 aspects, yofi mustde\/eiop a procedure to identify
 and access the legal and other requirements that
 are applicable to them. In addition to the federal
 regulations listed on  the  next  page in the
 Overview   of  Federal  Environmental   Laws
 Applicable to  Metal Finishing, be  sure to check
 with your state and local authorities to determine
 other applicable requirements.

 Who
 The EMS Coordinator determines applicable reg-
 ulatory requirements.
Why
Identifying and having access to the legal and
other  requirements that are applicable to your
environmental aspects is a crucial step in meeting
your environmental commitments.

How
Determine your regulatory requirements by list-
ing all of the environmental regulations that are
applicable to your environmental aspects. Visit
the National  Metal Finishing Resource Center's
Web site at www.nmfrc.org/ for updated infor-
mation about applicable regulations. See Sample
Form 3: List of Legal and Other Requirements, for
an excerpt of a table you can use to track your
legal and other requirements.
                              Guide to Developing an EMS for Metal Finishing Facilities

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  Overview of Federal Environmental Laws Applicable to Metal Finishing*
    Federal Environmental Laws
   Clean Air Act (CAA)
   [40 CFR Parts 50-99]
   Establishes ambient and
   source emission standards and
   permit requirements for
   conventional and hazardous air
   pollutants.
   •  Title'V air permits and/or
      follow the standards for
      hazardous air pollutants
      under the NESHAP
   ป  State air permits	
   Clean Water Act (CWA)
   [40 CFR Parts 100-145, 220-
   232,410-471]
   Establishes standards and
   permit requirements for water
   pollutants, including sources
   that discharge directly to a
   water body or to a public sewer
   system. Also includes storm
   water management
   requirements.
   Resource Conservation and
   Recovery Act (RCRA)
   [40 CFR Parts 240-299]
   Establishes regulations and
   permit requirements for
   hazardous waste management.
   Also creates standards for
   underground storage tanks that
   hold oil or hazardous
   substances.
   Toxic Substances Control
   Act (TSCA)
   [40 CFR Parts 700-799]
   Comprehensive
   Environmental
   Response, Compensation
   and Liability Act (CERCLA or
   "Superfund")
   [40 CFR Parts 300-311]
   Emergency Planning and
   Community Right-To-Know
   Act (EPCRA)
   [40 CFR Parts 350-374]
   Hazardous Materials
   Transportation Act (HMTA)
   [49 CFR Parts 100-180]
                                                Applicability of the Laws
The Clean Air Act established a list of hazardous air pollutants
(HAPs). Thirty-three substances in the TRI database for SIC
3471 (metal finishing) are HAPs. EPA promulgates emission
standards for listed source categories. These standards are
known as National Emission Standards for Hazardous Air
Pollutants (NESHAPs). Two NESHAPs affect the metal
finishing industry.
•   Chromium Electroplating (40 CFR 63, Subpart N).
•   Halogenated Solvent Degreasing/Cleaning (40 CFR 63,
    Subpart T).
•   Aerospace Manufacturing and Rework Facilities (40 CFR
    63,Subpart GG).	
The CWA regulates the amount of chemicals that are released
by direct and indirect wastewater/effluent discharges. Facilities
that discharge directly into a body of water must obtain a
National Pollution Discharge Elimination System (NPDES)
Permit. Facilities that discharge to a POTW must adhere to
specified Pretreatment Standards. These standards include
concentration-based limits on the discharge of a given
chemical or toxic by a facility. There may be state or local
conditions that require more stringent requirements than the
guidelines.
•   Metal Finishing Effluent Guideline (40 CFR 433).
•   Electroplating Effluent Guideline (40 CFR 413).
RCRA classifies wastes such as solid waste sludge and
requires certain methods for treatment, storage, and disposal.
One of the classifications under RCRA is hazardous waste. A
material is a hazardous waste if it meets the definition of solid
waste (40 CFR 261.2) and exhibits one of the characteristics of
a hazardous waste (40 CFR 261.20-24) or is listed as a
hazardous waste (40 CFR 261.31-33). A hazardous waste is
subject to Subtitle C generator (40 CFR 262), transporter (40
CFR 263) and Treatment, Storage, and Disposal Facility
(TSDF) (40 CFR 254 and 265) requirements.

Within RCRA Subtitle C, EPA has subcategories of hazardous
wastes called "F" listings. F hazardous wastes include spent
solvents (F001-F005) and electroplating wastewater treatment
sludge (F006).	
Regulates the use, development, manufacture, distribution,
and disposal of chemicals.
Establishes a program for cleaning up contaminated waste
sites and establishes liability for clean-up costs. Provides
reporting requirements for releases of hazardous substances.
Establishes a program (the "Toxic Release Inventor/1) to
inform the public about releases of hazardous and toxic
chemicals. Reporting requirements apply to companies that
use, process, or store specific chemicals over certain
quantities.
Establishes standards for the safe transportation of hazardous
materials.
* Check with your state and local authorities to determine other requirements your facility must meet.
   Guide to Developing an EMS for Metal Finishing Facilities

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Sample Form 3: List off Legal and Other Requirements (Excerpt)

Material
Use*
Air
Emissions
Air
Emissions

Air
Emissions

Air
Emissions


Corporate Directive

40CFR Part 50

40CFR Part 51

40CFRPart52
40CFRPart60
40CFR 60.420 and
60.43C (Boiler
emission standards
for sulfur dioxide and
particulate matter)
Facility Strategy,
Planning, and
Implementation
NAAQS National
Primary and
Secondary Air
Quality Standards
Emission of
Hazardous Air
Pollutants
Emission of
Hazardous Air
Pollutants
Verification of
Emissions




X

X

X

X





X

X

X

X


X


X

X

X

X


X


X

X

X

X


X


X











X











X






















                           Guide to Developing an EMS for Metal Finishing Facilities

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   Determine
^•^^Si^M   -
   Significant
       **                 •
                      mental
   What
   Significant environmental aspects (SEAs) are the
   aspects of your facility that have potentially sig-
   nificant impacts on the environment.

   Who
   The EMS Coordinator and CFT determine which
   of the environmental aspects are significant. The
   EMS Coordinator updates these determinations
   whenever the environmental aspects of the facility
   change.

   Why
   Prioritizing your  environmental aspects  helps
   your facility's management focus on managing
   the environmental aspects that have the greatest
   current or potential impact to the environment.

   How
   There are many ways to determine the  signifi-
   cance of your environmental  aspects. Whatever
   way you choose, be sure to document your deci-
   sion  process. The point is to  look at all of your
   aspects and determine—in a common sense, sys-
   tematic way—which of their impacts is environ-
   mentally significant. One way to determine the
   significance of your environmental aspects follows:

   1. The EMS Coordinator uses the lists of environ-
     mental aspects (Sample Form 2) and compiles
     a  master  list of environmental  aspects on
     Sample Form  4:  Determining  Significant
     Environmental Aspects. Where appropriate,
     aspects are grouped. For example, if consump-
     tion  of energy is listed as an aspect in  several
     areas, the  Coordinator could choose to group
  these so that energy use appears once on the
  master list.

2. The CFT then rates each aspect according to its
  impact in the following categories:

  • Regulator concerns;

  • Pollution;

  • Risk, including effects of chemicals  and
    materials, impact on workers, impact on the
    surrounding community, impact on the envi-
    ronment, safety, and noise; and

  • Natural resource use.
3. Using Sample Form 4, aspects are assigned a
  relative value of 1 to 5, where:

  1. 1 stands for low impact (or risk, or potential
    for regulatory issues);

  2. 2, for medium-low;

  3. 3, for medium;

  4. 4, for medium-high; and

  5. 5, for high.

  The CFT uses information recorded on Sample
  Form 2 and Sample Form 3 to assist in rating
  each impact.

4. A total score is developed for each aspect by
  adding the scores for each category. With all
  but the  last column  of Sample Form  4 com-
  plete, the CFT makes a final determination con-
  cerning which aspects are significant, based on
  the magnitude of the  impact. As a general
  guide, the aspects that score the highest points
  are considered significant. The CFT, however,
  should use its best judgment in  determining
  significance.

5. Aspects identified as significant are listed on
  Sample Form 4.

6. At  this  point, the CFT could  make an initial
  effort to develop indicators for the SEAs.

7. Repeat this procedure on an annual basis.
    Guide to Developing an EMS for Metal Finishing Facilities

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Sample Form 4: Determining Significant Environmental Aspects
1=Low; 2=Medium-low; 3=Medium; 4=Medium-high; 5=High
Iซ .. . . . . I Requlatory r-, ., .- ,-,- , Natural Overall ~. .,. .~
Operation Aspect mpacts _ ' Po ution Risk „ _ Significant?
^ i Concerns Resources ! Score 3
General
administration
General
administration
Laboratory
operations
Laboratory
operations
All operations
All operations
All operations
All operations
Surface
preparation /
finishing
processes
Surface
preparation
Metal finishing
processes
Chrome
plating
Wastewater
pretreatment
Wastewater
pretreatment
Building /
ground
maintenance
Building /
ground
maintenance
Paper
waste
Vehicle
emissions
Lab
wastes
Air
emissions
Non-
hazardous
solid
waste
Use of
energy
Use of
water
Sludge
generation
Metal and
cyanide
emissions
Organic
emissions
from
degreaser
Metal use
Chromium
air
emissions
/ human
exposure
Chemical
use
Air
emissions
Herbicide/
pesticide
Air
emissions
Depletion of
trees, landfill
space
Air quality
degradation,
use of oil,
landfill space
Landfill space,
air pollution
from transport
Air quality
degradation,
worker health
Landfill space,
air pollution
from transport
Depleting
energy
producing
resources, air
quality
degradation
Depletion of
water supply
Landfill space,
air pollution
from transport
Air quality
degradation
Air quality
degradation,
worker health
Landfill space,
air pollution
from transport,
use of natural
resources
Air quality
degradation,
worker health
Use of natural
resources,
water quality
degradation,
landfill space,
air pollution
from transport
Air quality
degradation,
worker health
Water quality
degradation
Air quality, use
of oil
1
1
1
1
3
1
1
3
3
4
1
4
1
2
1
1
1
1
1
1
1
1
1
2
3
3
3
4
2
2
1
1
1
1
2
2
2
4
4
4
4
3
4
3
2
2
2
1
1
1
1
1
2
4
4
4
4
2
4
4
2
2
1
1
4
4
5
5
8
10
10
13
14
12
12
15
7
8
5
4
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
                         Guide to Developing an EMS for Metal Finishing Facilities

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 Set Operational
  '  • '  '       *'
 Wlisrt      !;;<'^r'
*   -J  t |_        i. >J       !
ป Operational  controls are documented  proce-
dures,- workt Instructions, best  practices,  posted
 placards^ ปand,iact[0(\pfans that cover situations
 where tKeir1'absence could  lead  to deviations
 from  the  environmental policy.  For  instance,
 without  which you might deviate from your com-
 mitment to comply with legal requirements or to
 achieve  environmental performance  improve-
 ment. At least one operational control should be
 in place  for each significant environmental aspect
 (SEA) to ensure  compliance with  legal require-
 ments and company policies (e.g., procedures,
 work instructions or posted placards) or to achieve
 improvement objectives (i.e., action  plans).


 Form 9: Links Between SEAs, Goals, Confpletion
 Dates, Operational Controls, and Monitoring and
 Measurement in Section 11 provides examples of
 types of operational controls for addressing com-
 pliance  assurance and  environmental  improve-
 ment objectives.

 Document procedures for emergency  prepared-
 ness  and  response  (EP&R) that describe  the
 "who, what, and when" of:

 1. Assessing  the potential  for accidents and
   emergencies;

 2. Preventing incidents  and their  environmental
   impacts;

 3. Responding to incidents (emergency plans and
   procedures);

 4. Routine testing of emergency plans and proce-
   dures; and

 5. Mitigating impacts associated with  accidents
   and emergencies.
Because  many  EH&S  regulatory programs
require emergency plans and/or procedures, you
probably won't  have  to start from  scratch.
Examples of requirements related to EP&R that
may apply to you are listed on the next page.

Some  facilities  address these  requirements
through Integrated Contingency Plans that com-
bine the requirements of regulatory programs
into one consolidated plan. For information about
this  streamlined  approach,  and electronic
versions  of  federal  government guidance  for
consolidated plans,  visit www.epa.gov/region1/
enforcement/epcra/oneplan.html.

Who
The EMS Team ensures that operational controls
are adequate and fills any gaps you find with new
operational controls.
Why
Your operations and activities that are associated
with SEAs must be under control to comply with
your environmental policy.  Operational controls
ensure that  operations and activities  (such as
wastewater discharge  monitoring, waste man-
agement, environmental performance  improve-
ment) are carried out effectively.

How
Your facility may already document most of the
operational controls you'll  need. Even  so, it's
important to survey your entire facility  and its
operations to match existing operational controls
with your list of SEAs.
  Guide to Developing an EMS for Metal Finishing Facilities

-------
Regulatory Driver
RCRA
CWA
OSHA
CAAA
EPCRA
Requirement
Contingency Plan (LQG), Preparedness and Prevention
Plan (LQG and SQG)
Spill Prevention, Control and Countermeasure Plan (SPCC)
and Storm Water Pollution Prevention Plans (SWPPP)
Process Safety Management
Risk Management Program
Community Right-to-Know Reporting and Coordination with
Local and State Emergency Response Committees
Guide to Developing an EMS for Metal Finishing Facilities

-------
F
Set  and  Pursue

Your Gojils  and

Action  Plans
         • •:   •/
What     /
Goals and action plans help your facility continu-
ously improve its environmental performance.
Your goals should have measurable targets and
completion dates (for example, pounds of waste
reduced by a certain date). Some of your goals
should also exceed your current compliance com-
mitments. Action  plans  should include means
and time frames for completion. You can think of
documented action plans as operational controls
that ensure you meet your performance improve-
ment objectives.

Who
Your EMS Team ensures that performance
improvement goals are  set and attained. Top
management commits to meet the goals.

Assign people to measure progress toward your
environmental  performance goals. Also assign
people to take action when progress is not being
made.

Why
Setting  goals helps, your  facility continuously
improve its performance while reducing environ-
mental impacts.

How
Start by listing your facility's significant aspects
then determine your goals. Use Sample Form 5:
Goals to help you keep track of them. Here are
the steps:

1. Be sure that your goals are realistic and fit your
  facility's mission and business strategy.

2. Be sure the goals reduce your impacts on the
  environment, have a timeline, and are measur-
  able. For each goal, decide how  to measure
                                             performance,  and  determine how the goal
                                             relates to your environmental policy. Keep in
                                             mind that you'll need baseline data to compare
                                             progress.

                                           3. Set an action  plan to achieve the goals. See
                                             Sample Form  6: Action Plans for a  sample
                                             action plan.

                                           4. Measure progress toward goals on a routine
                                             basis.
  Guide to Developing an EMS for Metal Finishing Facilities

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   Typical Activities and Operational Controls at Metal Finishing Facilities
              Activity
Purchase of Raw Materials
Raw Material and Waste Storage and
Handling
Shops and Facility Maintenance
Wastewater Management
Air Quality Management
          Operational Control
Subcontractor Requirements
Chemical Inventory Procedure
Above-ground Tank Inspection
Spill Reporting and Clean-up
Secondary Containment Inspection
Hazardous Waste Area Inspection
Bulk Storage and Containment
Bulk Liquids Transfer
Containerized Material Storage
Hazardous Waste Satellite Accumulation*
Container Labeling*
Empty Container Handling*
Hazardous Waste Operations Procedure
Control of Discharge and Disposal
Waste Consolidation Guidelines
Waste Manifest/Chain of Custody
Environmental Compliance Assessment
Checklist
Maintenance and Machine Shop  Checklist
Disposition of Fluorescent Bulbs, Batteries, and
Mercury Items
Critical Ranges of Vital WWTP Operational
Indicators
Other Wastewater Plant SOPs
Centralized Air Pollution Control
SOPs
Regulatory Reporting Calendar	
                              Guide to Developing an EMS for Metal Finishing Facilities

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Sample Form 5: Goals
Goal
Reduce water purchased
by 50% in the first 5
years
Reduce energy used by
25% in the first 5 years
Reduce land disposal of
hazardous sludge by
50% and achieve an
overall reduction of
wastewater sludge
generated in the first 5
years
Reduce annual
emissions of TRI metals
and cyanide by 50% in
the first 5 years
Use or recycle off-site
98% of metals by the fifth
year
Reduce organic
emissions by 90% by the
fifth year
Examine nontoxic
substitutes for processes
whenever possible
Significant Related Policy Performance
Environmental Measurement
Aspect Indicator(s)
Water use
Energy use
Sludge generation
and disposal
Metal and cyanide
emissions
Metal use
Organic emissions
from degreaser
Human exposure to
toxic
materials/chromium
emissions
Use energy, water,
and metals efficiently
Use energy, water,
and metals efficiently
Minimize the amount
of waste generated,
ensure safe disposal
of waste, reuse and
recycle
Use energy, water,
and metals efficiently
Use energy, water,
and metals efficiently;
reuse and recycle
Reduce emissions to
water and air
Reduce human
exposure to toxic
materials in the
facility and in the
community
Monthly water bills
Energy usage from
electric bill, natural
gas bill, gasoline
receipts
Sludge generation
records, annual waste
summaries, and
hazardous waste
manifests
TRI reporting data
Purchasing records
and TRI data
TRI reporting data
Processes changed
 Contact Person: Willie Scott
Date Completed: 11/13/03
Next Scheduled Update: 11/13/04
Sample Form 6: Action Plans
           Significant Environmental Aspect
                                     Goal

                               Action Plan
                             Review Cycle
           Significant Environmental Aspect
                                     Goal
                               Action Plan
                             Review Cycle
              Water use
              Reduce the amount of water purchased by
              50%
              Analyze how water is used and what can be
              done to minimize water use. Consider different
              potential rinsing methods.	
              Willie Scott will review every 6 months
              Energy use
              To reduce the amount of energy used by 25%
              Analyze how the energy is being consumed
              and what can be done to use this energy more
              efficiently.	
              Willie Scott will review every 6 months
 Guide to Developing an EMS for Metal Finishing Facilities

-------
           Significant Environmental Aspect
                                   Goal#1

                               Action Plan
                             Review Cycle
                                   Goal #2
                               Action Plan


                             Review Cycle
          Significant Environmental Aspect
                                      Goal
                               Action Plan
                             Review Cycle
           Significant Environmental Aspect
                                      Goal
                               Action Plan
                              Review Cycle
           Significant Environmental Aspect
                               Action Plan
                              Review Cycle
                Sludge generation and disposal
                To reduce the land disposal of hazardous
                sludge by 50%	
                Analyze how much sludge is being recycled vs.
                land applied, and examine ways to increase
                the amount being recycled	
                Paula Lingo will review every 6 months	
                Achieve an overall reduction of wastewater
                treatment sludge generated in the first 5 years
                of the EMS	
                Examine why sludge is being generated and
                look at ways to decrease this	
                Willie Scott will review every 6 months	
                Metal use/use of natural resources	
                Use or recycle off-site 98% of metals	
                Analyze how metals can be better used by the
                processes and how we can recycle more of the
                waste metals off site	
                Willie Scott will review every 6 months	

                Organic emissions from degreaser	
                Reduce organic emissions by 90%	
                Analyze why these emissions occur and
                minimize the reason(s) that these emissions
                occur	
                Willie Scott will review every 6 months	

                Human exposure to toxic materials/chromium
                emissions	
                Examine the use of less toxic substitutes for
                processes whenever possible	
                Examine the use of less toxic alternatives in all
                of our surface preparation and metal finishing
                processes	
                Carol White will review every 6 months
                     For all significant aspects
                                            $100/year for meetings; if capital investment is
                                            required then this budget will be determined at
                                            that time.	
                                            1/03, manufacturing meeting with relevant
                                            manufacturing staff and EMS team to discuss
                                            the goal and brainstorm ideas. 2/03, EMS
                                            team and relevant manufacturing staff testing
                                            the best ideas. If testing reveals an idea worth
                                            pursuing, then the EMS team will make sure
                                            that idea will be pursued and reassessed every
                                              months.
Contact Person: Carol White
Date Completed: 11/35/02
Next Scheduled Updated: 11/25/03
                               Guide to Developing an EMS for Metal Finishing Facilities

-------
 Set  Up an
 Enijployee Training
 ••fe  "  1  *<$ Wsj^t ซ
 Program
          i
-------
r- * i Associated Job . .-, ... _.
Environmental _ .. Instruction Responsible Person
, . | Functions
Aspect














Sludge generation and
disposal




Metal and cyanide
emissions








Metal use







Organic emissions
from degreaser
Human exposure to
toxic materials

^^^^mmffitfij^^^^m
Maintenance










Wastewater treatment




Sludge handling


Wastewater treatment



Parts rinsing





Parts racking



Maintenance




Degreasing
All employees

^^•^•^•^••••H
Turn thermostats to a
more cost-saving
temperature when the
building and office are
empty; inspect and fix
air leaks on a regular
schedule; replace
older, inefficient motors
with newer, efficient
models instead of
repairing
Employees should
follow procedures
properly when treating
waste

Employees should now
segregate sludge
before disposal
Employees should
follow procedures
properly when treating
waste
Employees should
monitor the drip time
over the various rinse
tanks and withdraw the
parts at the proper
speed
Employees should rack
parts to minimize
solution dripping on
other parts
Employees should
make sure drip boards
are in place and
process solutions are
properly filtered
Employees should use
the new degreaser
properly
Ensure new processes
are being used
properly
••••^^^^^^^^^^^
Plant manager










Environmental
manager



Environmental
manager

Environmental
manager


Plating supervisor





Plating supervisor



Plant manager




Plating supervisor
Plant manager

Guide to Developing an EMS for Metal Finishing Facilities

-------
                      'the process for proactive
 interrll{ฎ|f3fi5
-------
      Sample Form 8:   Communications Program Matrix
Potential What We
Stakeholder(s) Environmental Want to Tell
Interest Them
Employees






Neighbors







Customers




• Safety of workers
• Protection of the
pnvironmpnt
Gl IVIIWIIIIIdll
• Competitiveness



Expansion of
facility, near
residences
• Run-off into creek
behind wastewater
treatment plant


• Major client
considering
requiring EMS for
suppliers

Environmental
policy





Environmental
policy and
EMS plans





Environmental
policy and
EMS plans


What We
Want Them to
Tell Us
How to get it
done





Their
environmental
concerns,
particularly
regarding
planned
expansion


Specific EMS
requirements
that might
ensue

How We Will When We Will Person
Communicate Do It Responsible
with/Tell Them
Memo, bulletin
board, meetings,
suggestion box,
Intranet




Meetings, open
house, flyers,
suggestion box,
Web site




Above, plus inserts
in direct mail
advertising, or
invoices and on our
Web site
Initial training for
new employees,
EMS update at
annual picnic,
as needed via
training program
for specific
workers
Town meeting in
November (for
expansion
discussion)
Annual open
house
Web site
(ongoing)
Ongoing and as
billing occurs



EMR, CFT, and
training
personnel





EMR with
communications
representative
(as appropriate)




Marketing lead
and facility
president


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raMpi
&S4eVl%ซJ@?!  .    -:i^wmx^^*>>ฐ*s?^#&   .
[Documentation is a requirement of an:.EMS/but it
             u     •          ••->.-•.
shoulanoffae the mam emphasis.-Limrryour doc-
umentation efforts to  the minimum necessary.
EMS  documentation  is  different than EMS
records. EMS documentation describes what you
do and how you do it, while EMS records demon-
strate that you are doing what the documentation
said you would do.

Some sort of EMS Manual,  either electronic or
hard copy, can be your EMS documentation and
should:

D Describe the core elements of your EMS and
  how the elements interact; and

D Provide direction to related documentation.
People in each area of your facility that has envi-
ronmental impacts should contribute to EMS doc-
umentation. The EMS Coordinator compiles the
information into a report or environmental database.
Keep your EMS documentation simple. Your EMS
Manual doesn't  need to describe every detail of
your EMS. Instead, it can reference other docu-
ments  or  procedures.  Update your EMS docu-
mentation as needed, based on any  system
improvements you put in place. Take a  look at
"Star Plating's" EMS Manual, which is included in
Part II of this publication.

Documentation can be  in  electronic or hard copy
format. Make sure that your documentation is
legible  and that the most up-to-date version is
available on site. Documentation should be avail-
able for all EMS  components, including:

n Your environmental policy;

D Your organizational chart or lists/tables of key
  responsibilities;

D A description of how your facility satisfies the
  EMS requirements;

D System-level procedures (for example, proce-
  dure  for corrective and preventive action);

D Activity- or process-specific operational  control
  procedures/work instructions; and

D Other EMS-related documents (such as emer-
  gency preparedness and response plans, train-
  ing plans, etc.).
Documentation describes the elements of your
EMS,  demonstrates compliance with environ-
mental regulations, and lists key employees.
If you already have documentation for  certain
regulations or permits,  use it for your EMS
instead of recreating it.
Guide to Developing an EMS for Metal Finishing Facilities

-------
                         :eeping mea is that
H Monitors  operations and  activities  that can
  have significant environmental impacts and/or
  compliance consequences;

• Tracks performance (including your progress in
  achieving your goals);

• Calibrates and maintains monitoring equip-
  ment; and

• Periodically evaluates compliance with applicable
  laws and  regulations through internal audits.

The measurement process uses records and gen-
erates records. Records prove that the processes
that make up your EMS are being implemented.
Records management helps you  decide which
records you will keep, how you will keep them,
and for how long. You should  also think about
how you will dispose of  records  when you  no
longer need them.

If your facility  has an ISO 9001 (or other) man-
agement system,  you should  already have  a
process in   place  for managing  records.  This
process could be adapted for EMS purposes.


Who
EMS procedures and work instructions designate
who  performs measurement activities,  who
records completion  of EMS activities, and who
manages the records that are created. The intent
of the EMS is to make as much of the measure-
ment and record keeping as practical the respon-
sibility of people whose jobs could significantly
impact the  environment. The EMS Coordinator or
department where  the  environmental  activity
occurs is responsible for  managing the relevant
records.
Why
Measurement and record keeping helps you man-
age your organization. The  results of pollution
prevention and other efforts are easier to demon-
strate when current  and  reliable data are avail-
able. These data can help you demonstrate the
EMS' value to top management.

The  purpose  of  records  management is to
demonstrate that your facility is  implementing
the EMS as designed. While records have value
internally, you also may need to give them to oth-
ers (such as customers, a registrar, or the public),
as proof of EMS implementation.
   Note on Measuring Performance
 How
 Choose a limited number of factors that can have
 a big impact on the outcome of a process, then
 determine how to measure those factors.

 See Sample Form 9: Links Between SEAs, Goals,
 Completion  Dates, Operational  Controls,  and
 Monitoring and Measurement for a sample form
 you can customize to show the link between
 measurement and your SEAs.

 Here are some things to consider as you deter-
 mine your facility's process for records management:

 • Identify which EMS records are required. Look at
   your other procedures and work instructions to
   decide what evidence is  needed. Also consider
   records that are required by legal requirements.
                                Guide to Developing an EMS for Metal Finishing Facilities

-------
 • Focus on records that add value. If records
   have no value or are not specifically required,
   don't collect them. The records you choose to
   keep should be accurate and complete.

 • Create forms to implement your EMS.  When
   these forms are filled out, they become records.
   Forms should be simple and understandable.

 • Establish a records retention policy and stick to
   it. Make sure that your policy takes into account
   records (retention requirements  specified in
   environmental regulations. For example, haz-
   ardous waste  manifests must be maintained
   for a specified period of time under RCRA.

 • Consider who needs access to what records in
   what circumstances.
I Consider using an  electronic EMS  records
 management system if your facility uses com-
 puters extensively.  Maintaining records elec-
 tronically can  provide an excellent means for
 rapid retrieval  of records as well as controlling
 access to sensitive records.

I Think about which records might require addi-
 tional security.  Do you need to restrict access to
 certain records? Should a back-up copy of critical
 records be kept at another location? Should a hard
 copy of some records be kept in case an inspector
 arrives and your computer system is down?
Sample Form 9: Links Between SEAs, Goals, Completion Dates,
Operational Controls, and Monitoring and Measurement
(Significant Goal Operational Monitoring and Completion Progress to
Aspect Control Measurement Date Date
Metal Cyanide
Emissions
Water Use
Human
Exposure to
Toxic
Materials/
Chromium
Emissions
Maintain
compliance
Reduce
water use
Investigate
potential
for
reduction
• Title V
Permit
• Air
Emissions
Abatement
Equipment
O&M
• Water use
reduction
Action Plan
• Human
exposure
to toxic
materials
Action Plan
• Air Emissions
Abatement
Equipment
Monitoring
Log
• Compliance
aqdit
• Regulatory
reporting
• EMS audits
• Monthly water
bills
• EMS audits
• Human
exposure
reduction
tracking
metric
• EMS audits
Ongoing
50% by
January 2009
Complete
study by
January 2005
Ongoing
10%
reduction as
of January
2004
Best
available
technologies
have been
identified and
vendors have
been
contacted.
Guide to Developing an EMS for Metal Finishing Facilities

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EMS jnternal/audis assess wheiherjyour EMS|is]
adequate-and verify~that~your~EMS~plansaare'
being followed. By identifying and reporting EMS
deficiencies to your management, you are able to:

• Maintain management's focus on the environment;

• Improve the EMS and its performance; and

B Ensure the cost effectiveness of the system.
Your EMS must include a well-defined process for   jo ensure an effective EMS internal audit program:
ensuring that:
                                              S Develop internal audit procedures;
                                              using your internal quality auditors as EMS audi-
                                              tors. See Sample Form 10: Sample Internal Audit
                                              Checklists for samples of checklists you can cus-
                                              tomize to conduct your own internal audits.
                                              EMS internal audits ensure that your system will
                                              continue to work well in the face of accidents,
                                              emergencies, changing rules, staff turnover, etc.
                                              By regularly evaluating your EMS, you will  be
                                              able to identify which parts of the EMS are work-
                                              ing well and which need improvement. Your EMS
                                              needs  to  change as  your facility adapts and
                                              grows. You will need a nonconformance, correc-
                                              tive, and preventive action process to deal with
                                              system deficiencies.
 I Problems are identified;

 I Root causes are investigated;

 I Corrective and preventive actions are assigned
  and implemented; and

 I Actions are tracked and their effectiveness verified.
Who
Select  and train EMS  internal  auditors on an
ongoing basis. Commercial EMS auditor training
is available, but it may be less expensive to coor-
dinate  with  local  businesses, community col-
leges, or other organizations to sponsor an audi-
tor training course.

Train auditors on auditing techniques, the con-
cept of management systems, and, if possible, on
environmental  regulations,  facility  operations,
and environmental science. While some auditor
training can take place on the job, make sure that
an experienced auditor takes part in your facility's
first few EMS audits.

Auditors should  be independent of the activities
being audited. If your facility has a quality man-
agement system, you may want to think  about
                                              O Determine how often you will conduct audits;

                                              9 Select and train your auditors; and

                                              • Keep records of your audits.
                                              Conduct  internal  audits at least  once a year.
                                              Auditors base their evaluation on interviews with
                                              employees,  observations, and documentation
                                              instead of just going down a list and making sure
                                              that all documentation is in place.

                                              Work with your EMS  Coordinator to determine
                                              the questions and observations that will tell you if
                                              your EMS is reducing risk, improving environ-
                                              mental performance, and facilitating compliance.
                                              Review the sample internal audit checklists pro-
                                              vided. Once you have gathered all the informa-
                                              tion and drawn conclusions, present a report to
                                              top management. The EMS Team can work with
                                              top management to make any needed changes to
                                              the EMS.

                                              The steps to develop a well-defined  process for
                                              your EMS include:

                                              B Identify the problem;

                                              S Find the root cause;
                                Guide to Developing an EMS for Metal Finishing Facilities

-------
 • Come up with a solution;
 • Implement the solution;
 • Document the solution;
 • Communicate the solution; and
 • Evaluate the effectiveness of the solution.

 Preventing problems  is generally cheaper than
 fixing them after they occur. Start thinking about
 problems as opportunities to improve!
Sample Form 10: Sample Internal Audit Checklists
Environmental Policy
Questions Findings/Observations
1 . Do you know the facility's Environmental
Policy?
2. What are the keywords of the Policy?
3. How does the Policy relate to your job?
4. What is your understanding of the facility's
EMS and your role?
ADDITIONAL QUESTIONS:





Environmental Aspects
Questions
(Look for documentation of planning/evidence
of implementation)
1 . Are you aware of the aspects and the
significant environmental aspect in your
department?
2. What are they?
3. Where can they be found?
ADDITIONAL QUESTIONS:
Findings/Observations

•



Goals
Questions
1 . Do you know what the goals for the
significant environmental aspects are?
2. Where can these be found?
3. What is the status or progress on the
goals with which your department is
involved?
ADDITIONAL QUESTIONS:
Findings/Observations




Guide to Developing an EMS for Metal Finishing Facilities

-------
Training, Awareness, and Competence
Questions
1 . Have you received awareness training on
the facility's environmental management
system and the significant environmental
aspects in your department?
2. Have you received training on your role
and responsibility to conform with the
facility's:
a. Environmental Management System
b. Emergency preparedness and response
3. Are you aware of the potential
consequences of departure from your
environmental work practices (environmental
impact)?
ADDITIONAL QUESTIONS:
Findings/Observations




Communication
Questions Findings/Observations
1 . Have you received information on the
facility's Environmental Management System
and significant environmental aspects?
2. How (e.g., facility newsletter, department
meetings, training, posters, pocket cards)?
3. Do you have an example?
4. If you had a concern about the EMS or any
environmental concern, what would you do?
ADDITIONAL QUESTIONS:





Document Control
Questions
1 . Do you have access to current versions
of your department's action plans,
procedures, and/or environmental work
instructions?
2. Where are they kept?
3. If there are any postings in the
department check to see if they are
current.
ADDITIONAL QUESTIONS:
Findings/Observations




                         Guide to Developing an EMS for Metal Finishing Facilities

-------
               .,,,,,,	,-ป^.
                            ^
ftB|iJ^*f^B8^r'ซ
,;t|1ieiiraoQ|l|ajdo a conTi^foliirisiyej.ri;
of your EMS elements don't need to be reviewed
at once. Review of the policy, goals, and proce-
dures should be carried out by the level of man-
agement that  defines them. The management
review should include:

• Internal audit results and status of preventive
   and corrective actions;

• Progress in meeting goals;

• The suitability of the EMS in relation to chang-
   ing conditions and information; and

• Concerns of interested parties.

Who
Top management  reviews EMS items  prepared
by the EMS Team.

Why

Management reviews inform top management of
the status of your EMS and offer a great opportu-
nity to keep your EMS efficient and cost effective.
If your top management finds that EMS proce-
dures and other activities don't add value, elimi-
nate them.
 How

 Your management review should answer the fol-
 lowing questions:

 • Is our environmental policy still relevant?

 • Are roles and responsibilities clear and do they
   make sense?

 • Are we applying resources appropriately?

 • Are we meeting our regulatory obligations?

 • Are the procedures clear and adequate? Do we
   need others? Should we eliminate some?

 • What effects have changes in materials, prod-
   ucts, or services had on our EMS?

 • How  effective  are pur  measurement and
   assessment systems?

 • Can  we  set  new  measurable  performance
   goals?

 • Do we need to change some of our approaches
   because of changes in laws or regulations?

 • What stakeholder concerns have been raised
   since our last review?

 • Is there a better way? What else can we do to
   improve?

Create a continual improvement plan and check
progress against your plan. Be sure to document
your observations and conclusions, through the
use of a record such as the one provided as
Sample Form 11: Management Review Record.
Assign action items to the EMS Team to ensure
follow-up on each item and schedule the next
management review.
Guide to Developing an EMS for Metal Finishing Facilities

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Sample Form 11: Management Review Record
 Date of review meeting: 4/5/2004
                               Position
                               Owner and president
                               Plant manager and EMR
                               EH&S manager
Persons present at meeting:
Name
Mike Baker
Joe Stevens
Carol White
 Conclusions
 This is the first quarterly management review. It appears that the EMS is up and running, but
 reinforcement is needed. Employees show an awareness of the general concepts of the
 EMS,  but are not always aware of how they fit into the process and how their job is different
 as a result of the EMS. Next month we will have a meeting for all managers and supervisors.
 At the meeting the EH&S manager will teach the supervisors what key points need to be
 emphasized to workers. Each supervisor is to have a meeting with their staff to go over
 these  points. This meeting should be documented—including date, time, and attendees.

 We are encouraging all supervisors to come to the next supervisor meeting with examples of
 what techniques work and what techniques do not work; our goal is to get all staff to uphold
 the work instructions that are part of the EMS. For those areas of the plant that do not have
 specific work instructions in the EMS Manual, the supervisor will motivate folks to come up
 with efficiency ideas. We have decided that at the end of the fiscal year, the staff person
 who comes up with the best EMS idea will get 10 percent of the savings that resulted from
 the idea. The contributor's supervisor will be favorably viewed, as well.  	
 Actions to be taken
 Manager and supervisor meeting
 Supervisor meeting with their staff
                                       Person(s) responsible
                                       EH&S manager
                                       Every supervisor	
 Signed: Joe Stevens
        Plant Manager and EMR
                                       Mike Baker
                                       Owner and president
                             Guide to Developing an EMS for Metal Finishing Facilities

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Below is a Sample EMS Manual for a hypothetical
metal finishing facility.


Star  Plating  EMS

Manual

Prepared by: Joe Hagenburger

Approved and Authorized by: David Shaw (President)

Main Point of Contact for the EMS: Carol White

Mailing Address: P.O. Box 000
              Plating, IN 00000

Phone: (000) 000-0000   Fax <000) 000-0001

Email: cwhite@starplating.com

Purpose off This Manual
This  EMS Manual defines the scope of Star
Plating's Environmental Management System
(EMS) and provides a linkage  of system docu-
ments to  the  various elements  of  the ISO
14001:1996 standard.

The control of this Manual is in accordance with
the  Star Plating Environmental Procedure for
Document Control. All copies of this EMS Manual
not  marked "CONTROLLED DOCUMENT"  are
uncontrolled and should be used for reference
purposes only.
                                       Amendments to this Manual will be issued by the
                                       Environmental  Management  Representative
                                       (EMR)  or designee following approval  by the
                                       Plant Manager.

                                       CONTENTS
                                       1.0
                                       SCOPE, STRUCTURE, AND RESPONSIBILITY
                                       2.0
                                       ENVIRONMENTAL POLICY
3.0
ENVIRONMENTAL ASPECTS
4.0
LEGAL REQUIREMENTS
5.0
SIGNIFICANT ENVIRONMENTAL ASPECTS
6.0
OPERATIONAL CONTROLS
7.0
GOALS AND ACTION PLANS
8.0
TRAINING, AWARENESS, AND COMPETENCE

9.0   •
COMMUNICATION
10.0
EMS DOCUMENTATION AND DOCUMENT CON-
TROL

11.0
MONITORING, MEASUREMENT, AND RECORDS

12.0
EMS AUDITS, NONCONFORMANCE, AND
CORRECTIVE AND PREVENTIVE ACTION
13.0
MANAGEMENT REVIEW

RECORD OF REVISIONS
 Guide to Developing an EMS for Metal Finishing Facilities

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1.O
Scope, Structure, and Responsibility
The Star Plating EMS provides a mechanism for
environmental management throughout all areas
and departments at the facility in [Fictional State
Name].  More  specifically, it  covers operations
beginning at the points of entry of raw materials
and energy, to the point of exit of finished manu-
factured products.  In addition to manufacturing
processes and activities, all other on-site opera-
tions fall within the scope of the EMS, including
maintenance, grounds-keeping, and offices.  The
EMS takes waste disposal into account in evalu-
ating the environmental impacts of on-site activi-
ties, even though Star Plating may not be the final
disposer of its waste. The EMS covers environ-
mental aspects that  a  facility can control  and
directly  manage and those it cannot  control or
directly manage but can be expected to have an
influence.
2.0
Environmental Policy
The Star Plating Environmental Policy (Policy) is
endorsed by the Facility Manager. The policy cov-
ers all activities at the facility. The Policy includes
a  commitment to continual improvement and
pollution prevention as well as a commitment to
meet or exceed relevant environmental legisla-
tion, regulations, and other requirements. The
Policy will be reviewed annually by top manage-
ment, communicated to all employees, and made
available to the public in  accordance with  the
Communication with Stakeholders  procedure.

Reference Material
ISO 14001 Standard (4.2)

Applicable Procedures and Forms
Communication with Stakeholders
EMS roles, responsibilities, and authorities are
defined at relevant functions and levels within the
facility. Top management provides the resources
essential to the implementation and control of the
EMS, including: training; human resources; spe-
cialty services; financial resources; and technical
and  informational  services. The  Environmental
Management Representative (EMR) has primary
responsibility for  establishing,  operating, and
maintaining the EMS. An EMS Coordinator pro-
vides routine EMS support and reports directly to
the EMR. Members of the Cross-Functional Team
(CFT), which includes members from each major
operation within the  facility, are responsible for
representing their area or department in several
facets of the  EMS, such as identifying environ-
mental aspects, determining significant environ-
mental aspects (SEAs), setting goals, implement-
ing action plans, reviewing and  tracking  EMS
internal audits results, and serving as an informa-
tion resource.

Reference Material
ISO 14001 Standard (4.4.1)
3.O
Environmental Aspects
Star Plating has established a procedure for iden-
tifying the environmental aspects that the facility
controls and over which it may be expected to
have an influence.

Reference Material
ISO 14001 Standard (4.3.1)

Applicable Procedures and Forms
• Procedure for Environmental Aspects,
  Objectives and Targets, and Action Plans
• Form for Significant Environmental Aspects
• Form for Linking SEAs, Objectives and
  Targets, and EMS Operational Control
  Procedures to Measurement Indicators, Job
  Functions, Responsible Parties, and Applicable
  Processes
• Procedure for Identification of Legal and Other
  Requirements
• Procedure for Environmental Review for New
  Purchases, Processes, and Products
                                Guide to Developing an EMS for Metal Finishing Facilities

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 4.O
 Legal Requirements
 Star Plating has established a procedure for
 identifying, accessing, and communicating legal
 and other requirements to which the facility sub-
 scribes. The EMS Coordinator identifies, com-
 municates to appropriate parties, and makes
 available changes to local regulations. At least
 annually, the EMS Coordinator reviews the most
 current national, regional, provincial, state, and
 local legal  and other requirements as applicable
 to Star Plating.  Star Plating also  has established
 a procedure to secure approval from regulatory
 agencies for processes and activities affecting air
 emissions, waste management or water dis-
 charges, as well as the method for other envi-
 ronmental  approvals.

 Reference Materials
 ISO 14001 Standard (4.3.2)

 Applicable Procedures and Forms
 • Procedure for the Identification of Legal and
  Other Requirements
 • Procedure for Obtaining Agency Approval
 • Form for Legal and Other Requirements
5.O
Significant Environmental Aspects
Star Plating  has established a  procedure for
determining which of its environmental aspects
will  be  considered  significant.  Discussions
regarding significance are recorded in CFT meet-
ing minutes. The SEAs are reviewed at least semi-
annually by the  CFT or when there is a new or
changed process or activity at the facility. The
EMR maintains CFT minutes and other records.

Reference Material
ISO 14001 Standard (4.3.1)

Applicable Procedures and Forms
• Procedure for Environmental Aspects,
  Objectives and Targets, and Action Plans
• Form for Significant Environmental Aspects
• Form for Linking SEAs, Objectives and
  Targets, and EMS Operational Control
  Procedures to Measurement Indicators, Job
  Functions, Responsible Parties, and Applicable
  Processes
 X Procedure for Identification of Legal and Other
  Requirements
 a Procedure for Environmental Review for New
  Purchases, Processes, and Products
6.0
Operational Controls
The Star Plating CFT is responsible for identifying
operations and activities associated  with SEAs
that  require  operational   controls.   Work
Instructions cover the environmental control of
specific operational  activities  and are  usually
activities specific in their application.

Star Plating has a procedure for identifying and
controlling the SEAs of suppliers and contractors.

Star Plating has an  environmental procedure to
identify the potential for and to respond to acci-
dents and emergency situations and for prevent-
ing and mitigating  the  environmental impacts
that may  be associated  with them. Emergency
methods are reviewed by the CFT on an annual
basis and after the occurrence of  accidents or
emergency situations.

Reference Material
ISO 14001  Standard (4.4.6 and 4.4.7)

Applicable Procedures and Forms
• Procedure for Contractors and Sub-contractors
• Procedure for Emergency  Preparedness and
  Response
• Form  for Emergency Preparedness and
  Response Requirements
• Worksheet for Linking SEAs to Operational
  Controls, Measurement Indicators, Job
  Functions, Responsible Parties, and Locations
  of Documents
 Guide to Developing an EMS for Metal Finishing Facilities

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7.0
Goals and Action Plans
The Star Plating CFT has developed goals for
each SEA that define:

I.The performance goals  (Investigate/Study,
  Control/Maintain, or Improve) for each SEA;

2. The specific, quantified  targets that define
  those performance goals; and

3. The planned deadlines for the achievement of
  those targets.

Goals are developed considering: SEAs; techno-
logical options and  financial, operational, and
business plans; and the views of interested parties.

The CFT establishes action plans as a means to
achieve goals. These plans define the principal
actions to be taken, those responsible for under-
taking those actions, and the scheduled times for
their implementation. The action  plans are devel-
oped by the CFT and approved by top management.

Star Plating  also has established a procedure to
ensure that environmental management applies
to new developments and new or modified activ-
ities, products, or services.

Reference Material
ISO U001 Standard {4.3.3 and 4.3.4)

Applicable Procedures and Forms
• Procedure for Environmental Aspects,
  Objectives and Targets, and Action Plans
• Procedure for Environmental Review for New
  Purchases, Processes, and Products
• Forms for Action Plan
• Project Environmental Checklist
8.0
Training, Awareness, and Competence
Star Plating identifies,  plans, monitors, and
records training needs for personnel whose work
may have a  significant impact upon the environ-
ment. Star Plating has established a procedure to
train employees at each relevant function and
level so they are aware of the environmental pol-
icy,  SEAs,  their  roles and  responsibilities  in
achieving conformance with the policy and pro-
cedures,  and with the requirements of the envi-
ronmental  management  system. The training
coordinator is  responsible  for  maintaining
employee training records. Appropriate records
are monitored  and  reviewed  on a  scheduled
basis. Competency is determined by the employee's
supervisor  as  specified  in the  Procedure  for
Environmental Training and Awareness.

Reference Material
ISO 14001 Standard (4.4.2)

Applicable Procedures and Forms
• Procedure for Environmental Training and
  Awareness
• Training Needs Analysis Matrix
• Training Needs Analysis—Procedures and
  Work Instructions by Area/Department
O.O
Communication
Star Plating has established and will maintain a
procedure for internal and external communica-
tions regarding the EMS. Star Plating has consid-
ered a process for external communication on its
SEAs and has decided to make that information
available upon request.

Reference Material
ISO 14001 Standard (4.4.3)

Applicable Procedures
• Procedure for Communication with
  Stakeholders
• External Stakeholder Communication Record
                                Guide to Developing an EMS for Metal Finishing Facilities

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 10.0
 EMS Documentation and Document
 Control
 This EMS Manual describes the core elements of
 the  management system  and  their interaction
 and provides direction to related documentation.
 These documents define the mechanisms for the
 establishment, implementation, and maintenance
 of the EMS and ensure that the system is main-
 tained in accordance with the environmental pol-
 icy and  goals and is communicated to suppliers
 and contractors. These  procedures are facility-
 wide in their application.
 11.O
 Monitoring, Measurement, and
 Records
 Star Plating has established a procedure to mon-
 itor and measure the key characteristics  of its
 operations and activities that can have a signifi-
 cant impact on the environment. This procedure
 includes calibration  and maintenance require-
 ments and ensures that records will be retained.
 The procedure also  describes requirements to
 calibrate and  maintain  monitoring  equipment,
 and to evaluate compliance with relevant envi-
 ronmental legal and policy requirements.
Star Plating has established an  environmental
procedure for controlling EMS  documents. This
procedure describes  where documents can  be
located  and how and when they are reviewed.
The procedure ensures that current versions are
available and that obsolete documents are prompt-
ly removed from use or are suitably identified.

Reference Material
ISO 14001 Standard (4.4.4 and 4.4.5)

Applicable Procedures and Forms
• Procedure for Document Control
• Master Document List
 Star Plating has a procedure to identify, maintain,
 and dispose  of environmental  records. These
 records include training records and the results of
 audits and reviews. They are readily retrievable
 and protected against damage, deterioration, and
 loss. The Areas and Departments maintain their
 own environmental records.  Record and docu-
 ment retention is also specified in the procedure.

 Reference Material
 ISO 14001 Standard (4.5.1, 4.5.3)

Applicable Procedures and Forms
• Procedure for EMS and Regulatory
  Compliance Audits
• Procedure for Monitoring and Measurement
• Environmental Measurement Indicators Log
• Calibration Log
• Compliance Tracking Log
• Environmental Records
• Index of Environmental Records
Guide to Developing an EMS for Metal Finishing Facilities

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12.0
EMS Audits, Nonconformance, and
Corrective and Preventive Action
Star Plating has a procedure for conducting peri-
odic system audits that ensure the EMS has been
properly  implemented and maintained. A sum-
mary of these audits is provided to top manage-
ment. Audits are performed according to a sched-
ule that is based  on the  environmental impor-
tance of an activity, the results of previous audits,
and the audit schedule. Auditors are trained and
audit  records  are  kept with the Audit Program
Leader.

Star Plating has a procedure for defining respon-
sibility and authority for handling and investigat-
ing nonconformances, for taking action to miti-
gate impacts, and for initiating and completing
corrective and preventive action. Any changes in
procedures resulting from corrective and preven-
tive actions are implemented and recorded.
13.0
Management Review
Star Plating has a procedure for EMS review by
top management. Top management reviews all
elements of the EMS at least annually to ensure
its continuing suitability, adequacy, and effective-
ness. Meeting minutes record these reviews and
are kept by the EMR or designee.

Reference Material
ISO 14001 Standard (4.6)

Applicable Procedures and Forms
Procedure for Environmental Management
System Management Review
Management Review Record
Reference Material
ISO 14001 Standard (4.5.4, 4.5.2)

Applicable Procedures and Forms
• Procedure for EMS and Regulatory
  Compliance Audits
• Internal EMS Audit Checklist
• Form for Internal EMS Audit Schedule
• Procedure for Corrective and Preventive
  Action
• Corrective and Preventive Action Request
• Corrective and Preventive Action Tracking Log
 Record of Revisions
 Revision Date  Description
                      Sections Affected
                               Guide to Developing an EMS for Metal Finishing Facilities

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 The following are blank forms you can use to start
 developing your own EMS Manual. Be sure that
 your facility's company policies and the most
 recent  federal,  state, and local  requirements
 are  incorporated.  To download an  electronic
 version  of  these  forms,  visit www.epa.gov/
 sectors/metalfinishing.
Form 1: EMS Responsibilities
| EMS Function Name




































I Regular Position


















For documenting requirements in ISO 14001 Standard (4.4.1)
Guide to Developing an EMS for Metal Finishing Facilities

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Form 2: Environmental Aspects and Impacts
Operation input/Output ^Sj^^f Environmenta, Impact












































































































For documenting requirements In ISO 14001 Standard (4.3.1)
•aO Guide to Developing an EMS for Metal Finishing Facilities

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  Form 3: List of Legal and Other Requirements
For documenting requirements in ISO 14001 Standard (4.3.2)
 Guide to Developing an EMS for Metal Finishing Facilities

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 Form 4: Determining Significant Environmental Aspects
  Operation    Aspect
Pollution   Risk
 Natural    Overall

Resources   Score
                                „.   .,.   .„
                                Significant?
For documenting requirements In IS014001 Standard (4.3.1)
                                Guide to Developing an EMS for Metal Finishing Facilities

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  Form 5: Goals
IGoal ! Significant
Environmental
Aspect






















Related Policy











Performance
Measurement
Indicator(s)











                               Date Completed:               Next Scheduled Update:
For documenting requirements In ISO 14001 Standard (4.3.3 and 4.3.4}
Guide to Developing an EMS for Metal Finishing Facilities

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Form 6: Action Plans
           Significant Environmental Aspect
          	 	          _Goai_
            	           	   Action Plaji
                             Review  Cycle
           Significant Environmental Aspect
                                     Goal
                               Action Plan
                             Review Cycfe
           Significant Environmental Aspect
                                     Goal
                               Action Plan
                             Review Cycle
           Significant Environmental Aspect
                                     Goal
                               Action Plan
                             Review Cycle
           Significant Environmental Aspect^
                                     Goal
                               Action Plan
                             Review Cycle
           Significant Environmental Aspect
                                     Goal
                               Action Plan
                             Review Cycle
           Significant Environmental Aspect
                                     Go_a|
                               Action Plari^
                             Review Cycle
                     For all significant aspects
 Contact Person:        Date Completed:               Next Scheduled Updated:
 For documenting requirements in IS014001 Standard (4.3.3 and 4.3.4)
                             Guide to Developing an EMS for Metal Finishing Facilities

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  Form 7: EMS Work Instructions
1 Significant .
Environmental Functions Instruction Responsible Person

































































/






























For documenting requirements In ISO 14001 Standard (4.4.6 and 4.4.7)
 Guide to Developing an EMS for Metal Finishing Facilities

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Form 8: Communications Program Matrix
Potential
Stakeholder(s) Environmental
Interest






























What We What We
Want to Tell Want Them to
Them Tell Us






























How We Will
Communicate
with/Tell Them















When We Will
Dolt















Person 1
Responsible 1















For documenting requirements in IS0 14001 Standard (4.4.3)

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 Form 9: Links Between SEAs, Goals, Completion Dates, Operational
         Controls, and Monitoring and Measurement
(Significant Goal Operational Monitoring and Completion Progress to
Aspect Control Measurement Date Date
































































































For documenting requirements In ISO 14001 Standard (4.5.1 and 4.5.3)
Guide to Developing an EMS for Metal Finishing Facilities

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Form 10: Sample Internal Audit Checklists
Environmental Policy
Questions Findings/Observations
1.
2.
3.
ADDITIONAL QUESTIONS:




Environmental Aspects
Questions Findings/Observations
1.
2.
3.
ADDITIONAL QUESTIONS:




Goals
Questions
1.
2.
3.
ADDITIONAL QUESTIONS:
Findings/Observations




Training, Awareness, and Competence
Questions Findings/Observations
1.
2.
3.
ADDITIONAL QUESTIONS:




Communication
Questions Findings/Observations I
1.
2.
3.
ADDITIONAL QUESTIONS:




Document Control
Questions Findings/Observations I
1.
2.
3.
ADDITIONAL QUESTIONS:




For documenting requirements in ISO 14001 Standard (4.5.4 and 4.5.2)
                            Guide to Developing an EMS for Metal Finishing Facilities

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 Form 11: Management Review Record
  Date of review meeting:
  Persons present at meeting:
  Name
Position
  Conclusions
 Actions to be taken
        Person(s) responsible
 Signed:
For documenting requirements in ISO 14001 Standard (4.6)
 Guide to Developing an EMS for Metal Finishing Facilities

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Guide to Developing an EMS for Metal Finishing Facilities

-------