Sector W: Wood and Metal Furniture
                                           and Fixture Manufacturing Facilities
           U.S. EPA Office of Water
           December 2006
 What is the NPDES stormwater permitting program for industrial
 Activities, such as material handling and storage, equipment maintenance and cleaning, industrial
 processing or other operations that occur at industrial facilities are often exposed to stormwater. The
 runoff from these areas may discharge pollutants directly into nearby waterbodies or indirectly via
 storm sewer systems, thereby degrading water quality.

 In 1990, the U.S. Environmental Protection Agency (EPA) developed permitting regulations under the
 National Pollutant Discharge Elimination System (NPDES) to control stormwater discharges associated
 with eleven categories of industrial activity. As a result, NPDES permitting authorities, which may be
 either EPA or a state environmental agency, issue stormwater permits to control runoff from these
 industrial facilities.

 What types of industrial facilities are required to obtain permit
 This fact sheet specifically discusses stormwater discharges from wood and metal furniture and fixture
 manufacturing facilities as defined by Standard Industrial Classification Major Group 25 and (SIC
 2434). Facilities and products in this group fall under the following categories, all of which require
 coverage under an industrial stormwater permit:
    4 Wood Kitchen Cabinets (SIC 2434)
    4- Furniture and Fixtures (SIC 2511-2599)

 What does an industrial stormwater permit require?
 Common requirements for coverage under an industrial stormwater permit include development of a
 written stormwater pollution prevention plan (SWPPP), implementation of control measures, and sub-
 mittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP
 is a written assessment of potential sources of pollutants in stormwater runoff and control measures
 that will be implemented at your facility to minimize the discharge of these pollutants in runoff from
 the site. These control measures include site-specific best management practices (BMPs), maintenance
 plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be
 implemented by the facility and updated as necessary, with a copy of the SWPPP kept on-site. The indus-
 trial stormwater permit also requires collection of visual, analytical, and/or compliance monitoring data
 to determine the effectiveness of implemented BMPs. For more information on EPA's industrial storm-
 water permit and links to State stormwater permits, go to and click
 on "Industrial Activity."

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities
  What pollutants are associated with my facilities activities?
  Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
  wood and metal furniture and fixtures will vary. There are a number of factors that influence to what
  extent industrial activities and significant materials can affect water quality.
     4  Geographic location
     4  Topography
     4  Hydrogeology
     4  Extent of impervious surfaces (e.g., concrete or asphalt)
     4  Type of ground cover (e.g., vegetation, crushed stone, or dirt)
     4  Outdoor activities (e.g., material storage, loading/unloading, vehicle  maintenance)
     4  Size of the operation
     4  Type, duration, and intensity of precipitation events

  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at wood
  and metal furniture and fixture manufacturing facilities. There are two primary types of furniture
  and fixture manufacturing facilities.  The distinction  is based on the primary raw material, wood, or
  metal. The manufacturing processes  and significant  materials to produce wood and metal furniture or
  fixtures are not similar. However, these manufacturing activities and wood resources are not typically
  exposed to precipitation.
  Table 1. Common Activities, Pollutant Sources,
  Fixture Manufacturing Facilities
and Pollutants at Wood and Metal Furniture and
Wood drying


Other activities
Pollutant Source
Saw dust
Sizing operations
Painting operations
Gluing operations
Used rags
Processing materials unloading
Waste material transportation
Treatment facilities
Open dumps
Air emission control cleaning
Total suspended solids (TSS), pH, cadmium, arsenic
TSS, chemical oxygen demand (COD), biochemical oxygen
demand (BOD5), pH
Lead, cadmium, COD
Solvents, COD, oil and grease
Solvents, COD, oil and grease
Diesel fuel, gasoline, oil and grease, TSS
Solvents, COD, oil and grease
TSS, BOD5, oil and grease, COD
TSS, pH, cadmium, lead, copper, zinc
  What BMPs can be used to minimize contact between stormwater
  and potential pollutants at my facility?
  A variety of BMP options may be applicable to eliminate or minimize the presence of pollutants in
  stormwater discharges from wood and metal furniture and fixture manufacturing facilities. You will
  likely need to implement a combination or suite of BMPs to address stormwater runoff at your facility.
  Your first consideration should be for pollution prevention BMPs, which are designed to prevent
  or minimize pollutants from entering stormwater runoff and/or reduce the volume of stormwater
  requiring management. Prevention BMPs can include regular cleanup, collection and containment of

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities

  debris in storage areas, and other housekeeping practices, spill control, and employee training. It may
  also be necessary to implement treatment BMPs, which are engineered structures intended to treat
  stormwater runoff and/or mitigate the effects of increased stormwater runoff peak rate, volume, and
  velocity. Treatment BMPs are generally more expensive to install and maintain and include oil-water
  separators, wet ponds, and proprietary filter devices.

  BMPs must be selected and implemented to address the following:

  Good Housekeeping Practices
  Good housekeeping is a practical, cost-effective way to maintain a clean and orderly facility to
  prevent potential pollution sources from coming into contact with stormwater. It includes establishing
  protocols to reduce the possibility of mishandling materials or equipment and training employees
  in good housekeeping techniques. Common areas where good housekeeping practices should be
  followed include trash containers and adjacent areas, material storage areas, vehicle and equipment
  maintenance areas, and loading docks. Good housekeeping practices must include a schedule for
  regular pickup and disposal of garbage and waste materials and routine inspections of drums, tanks,
  and containers for leaks and structural conditions. Practices also include containing and covering
  garbage, waste materials, and debris. Involving employees in routine monitoring of housekeeping
  practices has  proven to be an effective means of ensuring the continued implementation of these

  Minimizing Exposure
  Where feasible, minimizing exposure of potential pollutant sources to precipitation is an important
  control option. Minimizing exposure prevents pollutants,  including debris, from coming into contact
  with precipitation and can reduce the need for BMPs to treat contaminated stormwater runoff.  It can
  also prevent debris from being picked up by stormwater and carried into drains and surface waters.
  Examples of BMPs for exposure minimization include covering materials or activities with temporary
  structures (e.g., tarps) when wet weather is expected or moving materials or activities to existing
  or new permanent structures (e.g., buildings, silos, sheds). Even the simple practice of keeping a
  dumpster lid  closed can be a very effective pollution prevention measure.

  Erosion and Sediment Control
  BMPs must be selected and implemented to limit erosion on areas of your site that, due to
  topography, activities, soils, cover, materials, or other factors are likely to experience erosion. Erosion
  control BMPs such  as seeding, mulching, and sodding prevent soil from becoming dislodged and
  should be considered first. Sediment control BMPs such as silt fences, sediment ponds, and stabilized
  entrances trap sediment after it has eroded. Sediment control  BMPs should be used to back-up
  erosion control BMPs.

  Management of Runoff
  Your SWPPP must contain a narrative evaluation of the appropriateness of stormwater management
  practices that divert, infiltrate, reuse, or otherwise manage stormwater runoff so as to reduce the
  discharge of pollutants. Appropriate measures are highly site-specific, but may include, among others,
  vegetative swales,  collection and reuse of stormwater, inlet controls, snow management, infiltration
  devices, and wet retention measures.

  A combination of preventive and treatment BMPs will yield the most effective stormwater
  management for minimizing the offsite discharge of pollutants via stormwater runoff. Though not
  specifically outlined in this fact sheet, BMPs must also address preventive maintenance records or
  logbooks, regular facility inspections, spill prevention and response, and employee training.

  All BMPs require regular maintenance to function as intended. Some management measures have
  simple maintenance requirements, others are quite  involved. You must regularly inspect all BMPs to

  EPA-833-F-06-038                                                                            3

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities

  ensure they are operating properly, including during runoff events. As soon as a problem is found,
  action to resolve it should be initiated immediately.
  Implement BMPs, such as those listed below in Table 2 for the control of pollutants at wood and
  metal furniture and  fixture manufacturing facilities, to minimize and prevent the discharge of
  pollutants in stormwater. Identifying weaknesses in current facility practices will aid the permittee
  in determining appropriate BMPs that will achieve a reduction in pollutant loadings. BMPs listed
  in Table 2 are broadly applicable to wood and metal furniture and fixture manufacturing facilities;
  however, this is not a complete list and you are recommended to consult with regulatory agencies or
  a stormwater engineer/consultant to identify appropriate BMPs for your facility.
  Table 2. BMPs for Potential Pollutant Sources at Wood and Metal Furniture and Fixture
  Manufacturing Facilities
   Pollutant Source
   Outdoor unloading
   and loading
Q  Confine loading/unloading activities to a designated area outside drainage pathways and
   away from surface waters.
FJ  Perform all loading/unloading activities in a covered or enclosed area.
FJ  Close storm drains during loading/unloading activities in surrounding areas.
FJ  Avoid loading/unloading materials in the rain.
FJ  Inspect all containers prior to loading/unloading of any raw or spent materials.
FJ  Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
Q  Use dry cleanup methods instead of washing the areas down.
Q  Regularly sweep area to minimize debris on the ground.
Q  Provide dust control if necessary. When controlling dust, sweep and/or apply water or
   materials that will not impact surface or ground water.
FJ  Develop and implement spill prevention, containment, and countermeasure (SPCC) plans.
FJ  Train employees in spill prevention, control, cleanup, and proper materials management
   Outdoor material
FJ  Covering storage areas with roofs or tarps.
FJ  Confine storage of raw materials, parts, and equipment to designated areas away from high
   traffic, outside drainage pathways and away from surface waters.
Q  Provide secondary containment around chemical storage areas.
Q  If containment structures have drains, ensure that the drains have valves, and that valves
   are maintained in the closed position. Institute protocols for checking/testing stormwater in
   containment areas prior to discharge.
FJ  Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
FJ  Direct stomrwater runoff to an on-site retention pond.
FJ  Ensure that all containers are properly sealed and valves closed.
FJ  Conduct container integrity testing and provide leak detection.
FJ  Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings,  hoses, and
   valves) for failures or leaks  and perform preventive maintenance.
Q  Plainly label  all containers.
Q  Maintain an inventory of fluids to identify leakage.
Q  Wash and rinse containers  indoors before storing them outdoors.
Q  Train employees on proper spill prevention and response techniques.
FJ  Train employees on proper waste control and disposal.

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities
  Table 2. BMPs for Potential Pollutant Sources at Wood and Metal Furniture and Fixture
  Manufacturing Facilities (continued)
   Pollutant Source
   Coal pile management
FJ  Confine storage to areas outside of drainage pathways and away from surface waters.
FJ  Divert stormwater around storage areas with vegetated swales, and/or berms.
Q  Practice good housekeeping measures such as frequent removal of dust and debris. Cleanup
   methods may include mobile sweepers, scrapers, or scoops.
Q  Use properly designed basins for collection, containment, and recycling of pile spraying
Q  Use control measures such as berms, silt fences or waddles to control sediment from leaving
   storage area.
Q  Train employees in good housekeeping measures.
   Waste management
Q  Store waste in enclosed and/or covered areas.
FJ  Store wastes in covered, leak proof containers (e.g., dumpsters, drums).
FJ  Cover the dumpsters or move them indoors.
Q  Use linked dumpsters that do not leak.
Q  Provide a lining for the dumpsters.
FJ  Direct runoff to on-site retention pond.
FJ  Ensure hazardous and solid waste disposal practices are performed in accordance with
   applicable federal, state, and local  requirements.
Q  Ship all wastes to offsite licensed landfills or treatment facilities.
   Sawdust and
   particulate emission
Q  Clean around vents and stacks.
Q  Place tubs around vents and stacks to collect particulates.
FJ  Inspect air emission control systems regularly and repair or replace when necessary.
   Vehicle and Equipment
Good Housekeeping
FJ  Eliminate floor drains that are connected to the storm or sanitary sewer; if necessary, install
   a sump that is pumped regularly. Collected wastes should be properly treated or disposed of
   by a licensed waste disposal company.
FJ  Do  all cleaning at a centralized station so the solvents stay in one area.
FJ  If parts are dipped in liquid, remove them slowly to avoid spills.
Q  Use drip pans, drain boards, and drying racks to direct drips back into a fluid holding tank
   for  reuse.
Q  Drain all parts of fluids prior to disposal. Oil filters can be crushed and recycled.
Q  Promptly transfer used fluids to the proper container; do not leave full drip pans or other
   open containers around  the shop.  Empty and clean drip pans and containers.
FJ  Clean up leaks, drips,  and other spills without using large amounts of water. Use absorbents
   for  dry cleanup whenever possible.
FJ  Prohibit the practice of hosing down an area where the practice would result in the
   discharge of pollutants to a stormwater system.
FJ  Do  not pour liquid waste into floor drains,  sinks, outdoor storm drain inlets, or other storm
   drains or sewer connections.
FJ  Maintain an organized inventory of materials.
Q  Eliminate or reduce the number and amount of hazardous materials and waste  by
   substituting nonhazardous or less hazardous materials.
Q  Label and track the recycling of waste material (e.g., used oil, spent solvents,  batteries).

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Wood and Metal Furniture and Fixture
  Manufacturing Facilities (continued)
   Pollutant Source
   Vehicle and Equipment
Good Housekeeping (continued)
Q  Store batteries and other significant materials inside.
FJ  Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers in
   compliance with RCRA regulations.
Minimizing Exposure
Q  Perform all cleaning operations indoors or under covering when possible. Conduct the
   cleaning operations in an area with a concrete floor with no floor drainage other than to
   sanitary sewers or treatment facilities.
FJ  Park vehicles and equipment indoors or under a roof whenever possible and maintain proper
   control of oil leaks/spills.
Q  Check vehicles closely for leaks and use pans to collect fluid when leaks occur.
Q  Surround any work areas with a berm and grade them lower than the surrounding parking
   lot, in order to prevent runoff from flowing into dirt lots or storm drains.
Q  Provide a roof over all work areas.
FJ  Roof, pave, mound, or berm outside vehicle storage areas.
Management of Runoff
Q  Use berms,  curbs, or grassed swales other diversion measures to ensure that stormwater
   runoff from other parts of the facility does not flow over the maintenance area.
Q  Collect the stormwater runoff from the cleaning area and provide treatment or recycling.
Q  Discharge vehicle wash or rinse water to the sanitary sewer (if allowed by sewer authority),
   wastewater treatment, a land application site, or recycle on-site. DO NOT discharge
   washwater to a storm drain or to surface water.
Inspections and Training
Q  Inspect the  maintenance area regularly to ensure BMPs are implemented.
Q  Train  employees on waste control and disposal procedures.
Q  Seal floor drains if possible.  If not, ensure that work area drains are connected to the sanitary
   sewer not the storm sewer.
Q  Inspect the  bay where the condensed  steam and pressure wash overspray will  be collected
   and treated for discharge.
  What if activities and materials at my facility are not exposed to
  The industrial stormwater program requires permit coverage for a number of specified types of
  industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
  and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
  permit coverage.
  If you are regulated under the industrial permitting program, you must either obtain permit coverage
  or submit a no exposure certification form, if available. Check with your permitting authority for
  additional information as not every permitting authority program provides no exposure exemptions.

Sector W: Wood and Metal Furniture and
Fixture Manufacturing Facilities

  Where do I get more information?
  For additional information on the industrial stormwater program see

  A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
  be found at

  Information contained in this Fact Sheet was compiled from EPA's past and current Multi-Sector
  General Permits and from the following sources:

    4 Pacific Northwest Pollution Prevention Resource Center (PPRC). 1998. Wood Furniture
      Manufacturing - Compliance and Pollution Prevention Workbook.

    4 U.S. EPA, Office of Science and Technology. 1999. Preliminary Data Summary of Urban
      Stormwater Best Management Practices. EPA-821-R-99-012

    4 U.S. EPA, Office of Wastewater Management. NPDES Stormwater Multi-Sector General Permit for
      Industrial Activities (MSGP).