Practical Guide to
En vifonm en tal
Management for
Small Business
&EPA
Small
Business
Division
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Acknowledgements
This document was prepared under the direction of the U. S. Environmental Protection Agency's
(EPA) Small Business Division. The EPA Small Business Division wishes to acknowledge the
valuable review and comments received from EPA, state Small Business Assistance Program repre-
sentatives, Small Business Ombudsmen, National Compliance Advisory Panel members, trade
associations, small business owners, and others. Your suggestions and assistance were greatly
appreciated.
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Contents
I. Introduction 3
II. Responsible Environmental Basics—"Have to's" 6
III. Saving Money Through Sound Environmental Management 22
IV. Keeping the Program Alive 30
V. Taking it Outside Your Facility 36
VI. Summary 39
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/. Introduction
In a nutshell...
Do you as a small business owner feel like environmental management equals crisis management? Ever
wonder how to get control of all the environmental issues at your business once and for all without
sinking too much time and money into it? Don t know where to start? This Guide will help you get a
handle on these questions and maximize the cost savings and other benefits associated with good
environmental management. Following the Guide's step-by-step process, you will learn what good
environmental management is and how environmental management duties can slowly be pulled into
everyday activities without disruption. The end result will be that you can feel confident that your
company is in compliance with environmental regulations, your employees are saving time and money,
and you are better able to chart your company's future. So, go ahead and plant the seed to cultivate a
reliable, responsible, and efficient environmental management program for your business!
What is this Guide about?
The Practical Guide to Environmental Management
for Small business is your Guide to getting orga-
nized and making the most of the valuable time
you and your employees spend on environmental
affairs. It will help you design a management
plan that addresses all of the environmental
concerns of your business. The Guide will also
help you save money and make your business
look good in the eyes of your customers and
your community.
As the top person at your business, you have
to make the overall decisions and provide the
driving force for improving environmental
management. But, as a small business, it is likely
to take a team effort to make much progress,
and you will probably have to delegate some day
to day environmental activities to others. That is
why the Guide is written in plain language. It can
be easily understood by everyone at your busi-
ness.
As you work through the Guide, you will find
some ideas that you can use right away to
produce immediate
results. Even
more important,
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/. Introduction
by going through the Guide step-by-step, you
will gradually be able to create an effective
system to manage your environmental responsi-
bilities and make it much easier and less time
consuming to meet regulatory requirements—
one that will improve as time goes on.
Here is a quick preview of each
Guide Section.
Section II covers the basics
your business must have in
place to meet the require-
ments of environmental
regulations and to keep
employees, the commu-
nity, and the environment
safe. (Don't get discour-
aged: the following Sections
will show you how to make
these tasks more manageable as
time goes on.)
Once you have the basics in place, you can
begin to take advantage of the business benefits
of environmental management by working
through Section III. This Section shows you
how to use information you developed while
working through Section II to find ways to save
money by conserving water and energy and
reducing waste.
Section IV is about taking your early efforts
and getting them organized by writing a policy,
streamlining who does what, and measuring
progress. This enhances your business by making
sure that environmental efforts support your
business strategy, that responsibilities are
handled in a productive way, and that you are
moving forward—not spinning your wheels.
Section V explains why it is valuable to share
your environmental efforts with those outside
your business. It provides suggestions for
showing off your environmental successes to
customers and your community and
for partnering with suppliers and
_ others to improve your
^^^H^^ business' environmental
s-^ "JPfc performance.
¥
* Section VI looks at an
approach called an envi-
ronmental management
system (EMS) which is
what all the other Sections of
the Guide lead up to. For those
of you who like to read the back of
the book first, you might want to glance at
Section VI to get a better idea of where the
Guide is headed.
The steps outlined in the Guide can be fit
into the time you and your employees have
available and the workflow of your business. It
could take a month to work through the Guide
if you can devote some sizeable chunks of time
to it, or more than a year if time is more re-
stricted, but the end result will be equally sound.
The important thing is to devote regular atten-
tion to it while not detracting from your critical
business functions.
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/. Introduction
The Guide will help you develop a sound
approach to environmental management.
However, it is not a manual on environmental
laws and regulations. It will not tell you the
details of what you need to do to comply with
specific regulations. However, the Guide does
tell you who you can rely on for help with
understanding environmental regulations, and
how this important step fits into the overall
environmental management strategy.
Here's a vision of what you can achieve by
working through this Guide: You will understand
all the ways your business affects the environ-
ment. Your employees will be prepared to handle
spills, they will know how to keep safe, and your
business will fulfill the requirements of environ-
mental regulations. You will find ways to save
money, increase productivity, and maybe even
lessen regulatory requirements. Environmental
management responsibilities will be efficiently
organized and delegated within your business,
and good practices will make compliance easier.
By being better organized and taking a strategic
approach to environmental management, you
and your staff will spend less time on it, yet your
business will continue to improve its environ-
mental performance. Your environmental
management program will be so good that you
will be able to show it off to customers and your
community.
The Guide is designed to go hand in hand
with the U.S. Environmental Protection Agency
(EPA) Workbook, Documenting your Environmental
Management flan—A Workbook for Small business.
The Guide provides an explanation of the steps
to take to improve your business' environmental
management activities. The Workbook gives you
a place to keep and organize all of the informa-
tion you compile while working through the
document. If you would like to obtain a copy of
the Workbook, call EPA's Small Business Divi-
sion at 800-368-5888 or download it from
www.epa.gov/ems/or wwwsmallbiz-
enviroweb.org
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//. Responsible Environmental Basics—"Have to's"
In a nutshell...
Now that you 've planted the seed, you need to take care of the seedling. This Section of the Guide
explains how to put in place the critical functions a business must have to keep employees safe, prevent
and be prepared for spills, and comply with regulations. It is vital to get these functions under control
first because failing to do so poses a high legal and financial risk to your business. By working through
this Section with your employees, they will develop good habits that will make regulatory compliance
part of the daily routine and save time down the road. The ideas in this Section will get you organized
and help you make sure you 've got the basics covered using a logical and systematic approach: First
you will learn how to develop a process map to quickly get a handle on how your business affects the
environment. In turn, this will help you determine what environmental regulations may apply to your
business. Then, with this background, you can put in place the essential activities of sound environmen-
tal management—being prepared for spills, labeling, housekeeping, training, recordkeeping, and being
ready for a regulatory inspection. These activities will tie together to provide a safeguard against
unexpected and costly environmental problems at your business. They will also provide a solid founda-
tion that you can build on as you work through later Sections of the Guide to attain real cost savings
and increased productivity for your business.
How can I understand how my
business is affecting the
environment?
You know how when you open the box of a
new electronic gizmo like a computer or DVD
player, there is usually a handy picture laying on
top showing you how to connect all the parts?
This part of the Guide explains how
to create a picture of your company's
processes that is just as handy. This
picture, called a process map, will
show what comes in and what goes
out of the process. The process map
is a great tool for environmental
management because it will help you
see how your business affects the
environment. This will help you
figure out what regulations might apply and at
what points in the process you need to keep
required records. Because it shows the flow of
chemical products through your business, it
allows you to identify the areas where spills are
more likely to happen, where housekeeping may
be a big concern, and what kinds of labels are
needed. You can make sure you are providing
training that fits each employee's
responsibilities by looking at which
steps in the process map they are
involved with.
Getting started is easy. Look over
the example in Figure 1 to get an
idea of what your picture can look
like and fill in the blanks. Begin with
the basics: the raw materials, the
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II. Responsible Environmental Basics—"Have to's'
Figure 1: Generalized Process Flow Diagram
Generalized Process Map
Inputs
What? How Much?
What Cost?
What? How Much?
What Cost?
What? How Much?
What Cost?
Examples of Inputs:
Raw Materials, Energy, Process
Water, Labor.
Process Step 1
Purpose? Who is responsible?
Process Step 2
Purpose? Who is responsible?
Process Step 3
Purpose? Who is responsible?
End
Product
What? How Much?
What Cost?
Outputs
What? How Much?
What Cost?
What? How Much?
What Cost?
Examples of outputs:
Wastewater, Solid Waste,
Waste Energy, Waste
Chemicals, Air Emissions.
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II. Responsible Environmental Basics—"Have to's'
process, and the product. Good start, but it isn't
the complete picture. The process probably
requires additions other than just the raw
materials. Do you use a tool or dispenser to
introduce a raw material to the process? Do the
raw materials feed through some type of ma-
chine? If so, there are elements or processes
required to make it work—probably a power
source, possibly oil, filters, or parts that are
replaced when they are used up. As you examine
all the steps in the process and what makes each
of them work, you can add more detail to your
process map. At first, this diagram will qualify
rather than quantify the flow of materials—just
what is involved in the process, not how much.
You can plug in numbers later when your
company wants to look at process changes and
you need to measure results. When you look at
the process as a complete cycle, the pieces start
to fall into place. Raw materials are just one of
the resources utilized. For example, when you
consider that a specific tool is used and look at
the source of its power, it points out another
input for the diagram. Then, you can pinpoint
output details because all the inputs have to leave
the process in some way, shape, or form.
Once you have it, you can get lots of mileage
out of your process map as a business manage-
ment tool. It helps you think about aspects of
your process that may have escaped notice in the
past. As you work through later Sections of the
Guide, the process map will help you understand
how to improve the process because it helps you
see clearly the inputs and outputs—and associ-
ated costs—of each step. Opportunities to
reduce waste or conserve energy will be more
obvious. You might notice that you have a
"byproduct," something that leaves your process
as a waste but can be used to benefit someone
else's process. They may even be willing to pay
you for it. The process map is also a great
planning tool. As you look for areas to improve,
the visual diagram will make it easier for you to
explain your process, where it is now, and where
you want to go with it. It can also be a great way
to explain a job position to a new employee.
How can I get a handle on
environmental laws
and regulations?
If you feel uncertain
about what environmental
laws and regulations apply
to your business and what
exactly to do about them,
you are not alone. Many
small business owners,
because of their extremely limited time, have
difficulty with this. This part explains why it is
vital to your business to take on the task of
understanding your environmental legal obliga-
tions. It provides an overview of environmental
laws and explains how to use your process map
to get an idea of which areas apply to your
business. Then, it tells you how you can get
competent help to quickly understand the details
of what is required of your business.
If you are not careful at the beginning to
determine all of the environmental requirements
8
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II. Responsible Environmental Basics—"Have to's'
your business must live up to, then your environ-
mental management program will be incomplete
and maybe even flawed from the get go. Take
extra care with this step and seek outside help.
By all means, don't throw up your hands and give
up—the possibility of a penalty for breaking
environmental laws—even once, even by acci-
dent—is way too big of a risk to take for your
small business and the people who work there!
What if I find my business is
not in compliance?
While determining what laws and regulations
apply to your business, you might discover that
you have not been meeting requirements that
you should have been in the past. If this hap-
pens, the Small Business Policy can help. This
policy states that if you are working with your
state's Small Business Assistance Program to fix
a problem, you will be given at least a 90 day
window of opportunity to correct the problem
without the regulatory agency stepping in. Since
this policy has not been adopted by all states,
and some states have modified the policy when
they adopted it, ask your Small Business Assis-
tance Program representative for details about
the policy that is in effect in your state.
A second option is to follow EPA Self-Audit
Policy. Under this policy, you can disclose any
violations you discover to EPA, and your
business will have 60 days to correct the viola-
tions after discovery. If your business discloses
violations under this policy, EPA cannot assess
financial penalties, except that they may assess
economic based penalties — the amount of
money your institution saved while not meeting
requirements. Before entering into a disclosure
under EPA Self-Audit Policy, consult with your
Small Business Assistance Program representa-
tive for advice.
Why comply with
environmental regulations?
The most obvious reason is to avoid penalties
associated with non-compliance—fines for
violations can be in the thousands—a severe
blow to a small business (not to mention the
black mark of being labeled a violator). How
does this happen? Certain agencies at the
federal, state, and local
levels are there to see that
businesses follow environ-
mental regulations. To make
this determination, they can
send inspectors to any business to see first hand
if it is playing by the rules. Of course, when they
find problems, your business will be required to
fix them. The agency will send an official letter
with the list of the problems or violations. They
will spell out what they expect you to do about
each violation and a due date that it must be
completed by. Depending on the violations, your
business may be required to pay monetary fines.
The regulator can even close down your business
temporarily until problems are fixed. It is
possible that the responsible person at your
company who has completely failed to take
notice of or severely disregarded the regulations
may be criminally prosecuted and may even
Why Comply?
^ Monetary
fines
^ Your business
could be
closed down
until the
problems are
fixed
^ Criminal
prosecution or
jail time
^ Reinspection
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II. Responsible Environmental Basics—"Have to's'
serve jail time. Often, regulatory agency staff will
do a follow up inspection to make sure the
problems have really been fixed.
If just dealing with the inspection wasn't
enough, your problems can make the news. You
may have a difficult time getting your local
newspaper to mention the food drive your
business sponsors, but it's front page news when
your business is fined for environmental viola-
tions or has an accidental spill. The regulatory
agencies keep records of all violations and they
are public documents. Anyone can ask to see
them—they are allowed to under the "Freedom
of Information Act." People are expressing
more interest these days in knowing what the
companies in their community are doing. EPA's
website is experiencing 40 million hits per
month. Real estate search engines can find
environmental problems in areas surrounding a
property. Not only can a negative image hurt
sales in your local market, it can also hinder any
expansion activities you may plan. This is
because some expansions require an environ-
mental permit before you can proceed. When a
company is applying for a new permit, there is a
public comment period and often a public
hearing. If your company has a bad reputation
for environmental harm, members of your
community are likely to oppose the permit,
causing a delay. If the public is really opposed,
the permit may not be issued at all, jeopardizing
your expansion plans.
Compliance with environmental regulations
will help retain the value of your property. Any
negative environmental impact can decrease your
property value. Before loaning money, banks
usually require buyers to pay for a professional
review of previous property uses to see if the
property may have been contaminated in some
way. Because of this, if you ever need to change
locations or use your property for collateral, it
will become important to be able to show that
your activities have not caused contamination.
Good documentation that your company is in
compliance with environmental regulations can
protect you from having to pay for past contami-
nation to your site. Likewise compliance with
regulations can lower the cost of liability insur-
ance, because insurance companies will have less
concern about the future costs of a clean-up or
the risk of harm to the health of your employees
and community.
Why can't I wait until someone
tells me what to do?
There are a lot of environmental laws out
there and not all of them matter to your busi-
ness. Why should you weed through all of that
now instead of catching up on work that should
have been done yesterday? Why not wait until an
inspector shows up, takes a tour, and creates a
list of burning issues—signed, sealed, and
delivered? After all, the bureaucrats created
regulations that no one else can understand—let
them tell you what you are supposed to be doing
about the whole mess. Well, sorry to say, this is
not the easy way out.
First, not understanding what regulations
10
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II. Responsible Environmental Basics—"Have to's'
apply to your business is not an acceptable
excuse for failing to meet the requirements. Just
as you can be ticketed for breaking a traffic law
without being aware of it or penalized for a
mistake in a tax return or failure to pay enough,
ignorance of the rules does not protect you
from enforcement, even criminal enforcement.
Second, although an inspection will provide
you with a handy list of things that you need to
do, dropping everything to meet the imposed
deadlines can cost more than would have been
invested to get into compliance in the first place.
You will not have the luxury of time to look for
the least expensive and disruptive way to work
within the rules.
What regulations might impact
me?
'There are so many environmental laws and
regulations that they fill many books. When
you're already swamped with day to day business,
how can you find out which regulations are
important without wasting too much time? A
good place to start is to pull out your process
map and think about how your business
activities could affect the environment. You
bring in raw materials and after some work is
done, they leave as a product. Or, maybe you
use raw materials to perform a service
that fixes, improves, or cleans some-
thing for your customer. But, what else
is going on? Is the air and water leaving
your property the same as when it came
in? If your process has leftovers that
may be contaminated by chemicals—even in tiny
amounts—they could be regulated. Where do
they go? To a storm drain or sanitary sewer? To
the dumpster? Perhaps you keep materials on
your property that could cause a spill if their
containers leaked. As you think about these
questions, this is a good time to add to your
process map any new inputs or outputs you have
thought of. Now you are ready to take a look at
the table at the back of the Guide called "Major
Categories of Environmental Regulations."
Although it doesn't cover every last environmen-
tal regulation, and provides only a general
picture, it will give you a good idea of common
regulations that you should be concerned about
as well as ones that are not likely to apply.
How can I get more information
about regulations that may
apply to my business?
This Guide would be too long and compli-
cated if it gave you detailed information on each
regulation, and it would go out of date quickly.
Besides, the table in the back of the Guide
covers federal regulations only. You also
need to look at your state's require-
ments, and maybe even those
of your city or county.
Fortunately, you can call your
state's Small Business Assis-
tance Program to help you.
Just a phone call away is a
person who's not a regulator or
an inspector but has the
11
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II. Responsible Environmental Basics—"Have to's'
Fines can add up
to large sums. A
kitchen and bath
cabinet company
with 50 employ-
ees was fined
$25,000 for
neglecting to file
an annual report
under EPCRA.
The fine was
based on $5000
per report times
5 years. The
regulation cited
allows for fines
upto$25,OOO
per violation,
which would
have added up
to $125,000. But,
the 'low'penalty
was allowed
because it was a
small business
using small
amounts of
chemicals.
experience and know-how to help you cut
through the red tape and quickly figure out what
regulations apply to your business. After all, you
call a tax auditor to be sure you have filed your
taxes properly, don't you? In the same way, you
may need an expert to help you take care of all
the nitty gritty details of environmental compli-
ance. If you need assistance finding the phone
number and contact person for the Small
Business Assistance Program in your state, call
EPAs Small Business Division at 800-368-5888
or go to www.smallbiz-enviroweb.org/.
Consultation with your Small Business
Assistance Program is free of charge. Also, if
your business seeks help from your Small
Business Assistance Program, the Clean Air Act
Compliance Assistance Enforcement Policy can
give you some leeway to correct any problems
that you find without triggering enforcement.
Some states have similar policies or agreements.
As you work with your Small Business
Assistance Program contact, ask him
or her to help you write down the
actions you need to take to comply
with each regulation that applies to
your company. These actions might
include training, labeling,
recordkeeping, filing reports, and
others. Once you have a good
handle on what regulations apply to
your business and what specific
actions you need to take to comply,
you can go about getting to it. But,
don't forget that regulations are
notorious for changing often. You also need to
find a way to stay on top of this so you don't get
out of compliance by accident. One way is to
attend an update conference on the regulations
that apply to your business once a year or so. Or,
you could just put a tickler on your calendar to
call the Small Business Assistance Program on a
regular basis and ask them to help you stay in the
loop.
What are the basics of good
environmental management?
Now that you understand the ways your
business can affect the environment and what
environmental regulations your business has to
comply with, you are ready to put in place the
basics of good environmental management:
preventing and being prepared for spills, making
sure all chemical materials have proper labels,
practicing good housekeeping, training employ-
ees in their environmental responsibili-
ties, keeping good records, and
being prepared for a regulatory
inspection. This part begins with
spill preparedness because it needs
to be among your highest priorities as
a small business owner. Having a spill
can be a nightmare, especially if it gets off
of your property and contaminates a water-
way or groundwater. A spill can injure your
employees or make them sick. It can lead to
fires and other property damage. It can
become a source of bad press and jeopar-
dize your relationship with the community.
Having a high profile spill is a sure way
12
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II. Responsible Environmental Basics—"Have to's'
to get an inspector to show
up at your business. And,
on top of all that, even a
small spill can cost thou-
sands to clean up.
Working on spill
preparedness naturally leads to working on some
of the other basics. Having proper labels on
containers makes it much easier to handle a spill
because you know what you are dealing with.
Practicing good housekeeping helps keep spills
from happening. Since a spill situation can be
dangerous, it is sensible to make sure everyone is
trained so they know how to keep safe and what
to do the moment a spill happens. Having good
recordkeeping in place helps ensure that the
chemical incident response plan is readily
available as well as the response call list. If a spill
does trigger a regulatory inspection, you will be
able to handle it better if you have a game plan
and employees know what is expected of them.
This illustrates how the basics of good environ-
mental management inter-relate, so that doing a
good job in one area has a positive effect on
performance in the other areas.
Prevent and Be Prepared for Spills. A
common cause of spills is the container: either it
is so old and decrepit that it springs a leak, or
someone knocks it over or drops it. There are
several easy ways to prevent this. Make sure all
employees who work with chemicals know these
tips:
• Take a close look at the chemicals in your
work area every week or so. If you notice
any containers in bad condition, get rid of
them (using proper disposal methods) or
transfer their contents to a new container.
Check to see that containers have good caps
that are tightly closed.
• Put containers holding hazardous chemicals
or wastes into other containers, trays, or drip
pans to catch and contain any chemical that
spills or leaks out.
• When you move a chemical container from
one place to another, place small containers
in a bucket or pail. Place larger containers in
a tub with hand grips or onto a cart with
sides on it that will prevent any spill from
flowing off.
• When transferring a chemical from its
original container, be sure the new container
will safely hold the chemical you are pouring
into it: Is it made of a material that won't
react with or dissolve in the chemical? Does
it have a tight fitting cap? Be careful not to
overfill the new container.
Another good thing to do is to locate all the
drains on your property, both indoors and
outdoors, and determine where they go to. If
your building is old, you may be surprised to find
that the drain you were sure led to the sanitary
sewer and your local wastewater treatment plant
actually connects to the storm sewer system that
drains directly to a lake or river.
After you go to all this
trouble, mark your drains
accordingly.
Consider placing
easy-to-use drain
13
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II. Responsible Environmental Basics—"Have to's'
Document any
training even if it
is an informal
tailgate session.
Keep a record of
who was trained,
the topic, the
date, how long it
was, and
whether it was
classroom, one-
on-one, or on-
the-Job. If train-
ing involves a
new task, offer
to help the
employee the
first time they
undertake the
task, or team
him or her up
with an em-
ployee experi-
enced in the
task. This
counts as train-
ing too.
covers and spill supplies close by drains to close
them off from a spill if you have time and it is
safe to do so.
If you don't have a chemical incident re-
sponse plan, make it a high priority to develop
one. Chances are you have to have some type of
incident response plan anyway to comply with
regulations. This doesn't mean your employees
have to know how to clean up a spill by them-
selves. In fact, they should not clean up chemical
spills at all, except for tiny ones, unless they have
had extensive training. But, anyone in your
business who works with chemicals should know
how to keep themselves and their coworkers safe
if there is a spill and who to call for help. Take
some time to ask about the capabilities of your
city or county emergency services. Do they have
a hazardous materials response team (often
called a hazmat team)? If so, do they have the
necessary equipment and training to clean up the
types of spills that could happen at your place?
If you call them in, how much will it cost?
Answer these questions before you have a spill in
progress and things are going to go a lot more
smoothly.
Train employees. Too often, the environ-
mental management program hides in
files and reports and never gets out
to where the rubber meets the
road. You can have the greatest
ideas in the world to protect the
environment, and even some
that will save money to boot,
but nothing will come of them
if employees don't know about
14
them. This sounds obvious until you remember
that at most small businesses everyone is short
on time. Because of this, it is not unusual that
what needs to be done never gets communicated
to who needs to do it. A well thought out
training program is like sunlight to your seedling
environmental management program. It ener-
gizes employees because training sheds light on
what they need to be doing.
Here are some tips for setting up and manag-
ing your training program:
• As you get your training up and running, set
priorities—(1) train those who handle
chemicals to use them safely and on what to
do if there is a spill or release, (2) make sure
you have training programs as required by
regulations (contact your Small Business
Assistance Program if you don't know), (3)
train them on additional good practices.
• Use your process maps to discover whose
jobs involve tasks that could affect the
environment.
• Develop a list of training topics that make
sense for each job, beginning with training
required by regulations. You can use a matrix
to help with this (Figure 2). These tools can
help you set up training efficiently so each
employee gets the training he or she
needs, but does not sit through
training they don't need (a good
way to make them mad at you and
lose interest).
• If your business already has
a strong employee safety
program, build your environ-
mental training into the existing
-------
II. Responsible Environmental Basics—"Have to's'
Figure 2: Sample Employee Training Matrix
Employee's Name: John Doe
Employment Date: March 21, 2000
Termination Date:
Job Title: Press Operator
Note: OJT refers to On the Job Training.
Required Training:
Hazardous Waste—initial and annual.
Incident Response—initial, annual drill, incident
critiques, and when plan changes.
DOT—initial Awareness, initial Function Specific,
three-year refresher.
Storm Water—per permit, annual.
Air—per permit, initial and when permit changes
affect press operation.
Hazardous Waste
Incident Response
Plan
DOTHazmat
Storm Water
Air Permit
3/30/00
3/30/00
Awareness: 3/30/00
Function Specific:
4/12/00
3/30/00
3/30/00
Annual Refresher: 3/15/01
Update (OJT):
Drill: 1/10/01
Incident Critique: 2/23/01
Plan Update: 3/15/01
Update (OJT): 3/11/01
Update (OJT): 2/29/01
safety training to be more efficient with
employees' time and to help them better
understand the big picture. For example, if
you are already doing OSHA Right-to-Know
(Hazard Communication Standard) training,
which is about how to keep safe when using
chemicals, it is a simple thing to add a short
segment on how to properly handle and
dispose of wastes associated with the use of
that chemical.
Make sure those in your business who are
doing training are available for follow up
questions and know ahead of time who to
call if someone asks a question they don't
know the answer to. (Your Small Business
Assistance Program contact can help here
too.)
Label Hazardous Materials and Wastes
Properly. Have you ever looked at a glass jar of
clear liquid in your maintenance cabinet trying to
remember what it is? You think on it and narrow
15
-------
II. Responsible Environmental Basics—"Have to's"
it down to one of two
things: a xylene-based paint
thinner or a paint stripper
containing methylene chloride.
This is a serious problem
because these products have
very different hazards. The
paint thinner is flammable while the stripper
is not. The stripper is a lot more toxic than the
thinner. You can't even dispose of it properly
because they each have a different hazardous
waste code. To prevent this headache, when you
look over your chemicals to check for leaks and
bad containers, check the labels too. If any are
falling off or fading, write the label information
on a fresh sticker and attach it to the container.
When transferring chemicals from the original
container to another one, label the new container
right away so you won't forget what it is. When
deciding on a label for a waste container, be
specific. If not, too soon you will have a mixture
of wastes that will be hard to classify, unsafe to
handle because you don't know what's in it, and
more costly to ship out.
When deciding on a label for a waste con-
tainer, it makes a big difference whether or not it
is a "hazardous waste" as defined by regulations.
Hazardous wastes have particular requirements,
including labeling. You should still label wastes
that are not hazardous so you don't get them
mixed up with hazardous wastes and because
many non-hazardous wastes still pose hazards to
your employees. Here are some examples of
good labels for waste containers that might be
found in your small business:
Waste Parts
Cleaner
(contains
methylene
chloride)
Waste
(contains
methylene
chloride)
Waste Paint
Thinner
(contains
xylene)
Bath
(contains
sulfuric acid)
Important Note: The above labels meet
certain hazardous waste requirements only.
There may be additional labeling requirements
depending on the regulations that apply to your
business. If you are not sure what labels are
required, consult with your Small Business
Assistance Program contact.
Maintain Good Housekeeping. Here are
some signs that you need to devote more time to
housekeeping:
• You find yourself ordering a chemical
product that you already have because your
shelves were so cluttered when you looked
for it you couldn't see it was there.
• You pick up a spray paint can out of the
storage cabinet only to discover that it is
empty.
• You open the shop door and knock over a
can of paint that was sitting just inside.
Here are some goals to strive for:
• You open any storage cabinet and can tell at
16
-------
II. Responsible Environmental Basics—"Have to's'
a glance what products are there and
whether any containers have leaked or
spilled.
• There is a list nearby to check off chemicals
that need reordering.
• Chemical containers are situated safely—that
is, away from the edges of shelves, away
from high traffic areas, and out of the way
of swinging doors.
• Empty containers are marked as such and
properly disposed of right away, or at least
staged at a labeled bin or shelf, so they don't
get confused with products still in use.
• You cannot find a container without a label
anywhere in your business.
• At the end of a shift, your employees tightly
close any chemical containers they are using
and return them to their designated storage
space.
• You have supplies and personal protective
equipment (also called PPE, e.g., safety
goggles and protective gloves) for safely
cleaning up small spills in each work space in
a location that is easy to get to and well
marked, and employees are trained on when
and how to use them.
If you think your housekeeping is in pretty
good shape, invite your local fire inspector in for
a look. He or she will probably give you a few
more ideas. Getting your housekeeping in order
is like weeding—it's a pain in the neck but it has
to be done so you can see whether anything
worthwhile is under all the clutter.
Keep records of your efforts and suc-
cesses. Good records tell you at a glance what's
going on and what needs to be done on a regular
basis (like annual training or weekly inspections).
They put you in a better position to pass a
regulatory inspection. Most inspectors start with
a close look at your environmental records.
Records in good shape start you off on a good
note. It pays to be clear on what files you must
have to be in compliance and get them organized
first. After that, you can decide what information
has additional value to you. Some records are
essential to protect you from legal and financial
troubles down the road. Others can give you
valuable data on business performance, or come
in handy when you want to show your customers
and neighbors that your business is "green."
The Sample Master File List in Figure 3 gives
you a simple system to organize your environ-
mental management files and records. It covers
the most common environmental filing and
recordkeeping requirements, the ones that apply
to most small businesses, so you can use it as a
starting point. However, be sure to go back and
look at the records and documents that you are
required to maintain by the particular regulations
that apply to your business to make sure nothing
is missing. Consult your Small Business Assis-
tance Program contact again if you are not sure.
Table 2 summarizes the information in the
Master File List, explains why each file needs to
be maintained, and provides guidelines for how
long files and records need to be kept.
17
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II. Responsible Environmental Basics—"Have to's'
While thinking about files, here is an impor-
tant point. Make sure that all critical communica-
tions with regulators are documented. Either ask
the regulator to send you something in writing
(e.g., letter, regulation, interpretation) or write
down your understanding of what was said in a
letter, send it to the regulator, and keep a copy in
your file. Also keep a copy of all important
correspondence, such as permit applications,
required reports, or written responses to regula-
tory inspection citations, and send the original
certified mail with return receipt.
Be Prepared for a Regulatory Inspection.
Maybe you think it can't happen to you because
your business is too small. But, if you do get
inspected—even just once—it will pay to be
prepared. Knowing what to expect will help you
be more confident and less stressed during an
inspection.
Before an inspection takes place, decide who
can best answer questions about your business'
compliance with environmental regulations while
also having a good grasp of its operations.
Designate a primary contact and a back-up
person. Both should have access to the files,
records, and locations within the business that an
inspector may want to look at.
Let's say you, as the business owner, are the
primary contact. Tell front office staff that if an
inspector drops by, they should welcome him or
her and call or page you or your back-up. Once
you get the call, get there as soon as possible.
When you first meet the inspector, it is appropri-
ate to ask for some identification and for
information about the kinds of issues he or she
is interested in. The inspector will usually look at
records first and then ask for a tour of your
operations. Be sure to provide appropriate
personal protective equipment (safety glasses are
usually a minimum), then take the inspector to
any place in your facility they request. Take
thorough notes during the inspection. If the
inspector takes a sample (such as a wastewater
sample) ask him or her to split the sample with
you so you can have your own analysis done later
if you choose to. Take photos of whatever the
inspector photographs. If you can, direct
employees to immediately correct any problems
brought up by the inspector, as long as you
clearly understand what needs to be done.
At the end of the inspection, if you are
comfortable doing so, ask the inspector what her
or his impression was to get a sense of where
you stand. After the inspector leaves it may take
weeks or even months for you to receive a
follow up letter from the regulatory agency
stating the results. But, don't consider the matter
closed until you receive a letter that says so. If
you are served with a Notice of Violation or
other citation as a result of the inspection don't
panic. Ask your contact at the Small Business
Assistance Program to help you respond. They
can help you understand what corrective actions
you must take and how soon. They may be able
to serve as a go between and advocate for you.
Finally, try to keep a positive outlook. Going
through an inspection can be a stressful and
disruptive experience, but you will get through it.
Afterwards you will know better how your
environmental management program is doing.
18
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II. Responsible Environmental Basics—"Have to's'
Figure 3: Master File List
General Environmental Management Files
Facility ID numberfs]—In many states, the regulatory agency assigns an ID number to your facility that applies agency-wide.
Keep this on file so you can find it when talking to regulators, or when visiting the regulatory agency to look at files or records
they have about your facility.
Spill Response—Keep copies of all your spill response plans and associated documents here. At the top of each plan, keep a
current call list for your on-site emergency coordinators and off-site responders (e.g., city hazmat team). If these contacts are
the same for all plans, place the call list in a separate, well marked file folder at the front of this part of files. Do the same for
listing phone numbers you would use to report a spill to regulatory agencies (e.g., state spill response hotline, State Emer-
gency Response Board, National Response Center). Helpful categories could include:
• Incident response call list and decision tree
• Spill reporting call list
• Hazardous waste spill response plan
SPCCplan
• Storm water spill preparedness plan
Within each plan file include:
• Copy of plan
• Summary of annual plan exercises
• Documentation and critique of incidents that triggered the plan
Interaction with Regulators—Keep a record of all your interactions with regulators here, except for information directly related
to a specific environmental permit, which should be kept in the permit file. This includes copies of any letters you send to
regulators and brief notes of any conversations you have with them—not just the stuff they send to you. If you act based on
their answer to one of your questions and someone later disagrees, it will help to be able to show who gave you that
information and when. If there isn't a lot of information, you may be able to keep it all in one file. If not, consider breaking it up
into files for each agency (e.g., EPA, your state environmental regulatory agency, municipal sanitary sewer authority, local
solid waste authority) or by areas (e.g., air, water, waste, emergency response). It's best to keep these documents in order by
date so you can easily lay your hands on the information when you need it. The information in these files should include:
• Regulatory inspections (active and closed, filed by agency)
• Reports of spills or releases
• Other correspondence with regulatory agencies
Training Records—While many different environmental regulations require training, most companies find it easiest to organize
them according to employee. For each person, place the matrix of the training they need to meet their job responsibilities (as
explained in the previous Section) in the front of their training folder. Behind this, keep the employee's training certificate and
an agenda or topics list for each training session. Place this information in chronological order, and use the matrix to quickly
pull training records needed during an inspection. Some regulations (such as hazardous waste) require that you write out
each employee's duties in that area. If possible, append these to the employee's position description in their personnel file so
it is clear that he or she is working within the scope of their job when doing hazardous waste or other environmental duties.
Use red file
folders or file
tabs for your
emergency
contact files so
you can get your
hands on them
quickly during a
spill or emer-
gency.
Write down
contact informa-
tion for regula-
tors you commu-
nicate with often
on the inside of
the file folder for
easy access.
If your company
has a spread-
sheet or data-
base computer
program, you
can keep each
employee's
training matrix
electronically,
and print a hard
copy to put in
the file.
••••••••••••i
19
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In the language
of environmental
management,
the temt "me-
dia" refers to
how pollutants
can get into the
environment
such as waste,
water, or air.
II. Responsible Environmental Basics—"Have to's"
Figure 3: Master File List (cont'd.)
Media-specific Environmental Management Files
Waste Management—Keep all information associated with management of your business' waste streams in this file.
Suggested categories include:
• EPA Generator ID number(s)
• Current hazardous waste permit and associated documents and correspondence (if applicable)
• Records of waste determination (information you used to tell whether a waste is hazardous or not; keep them
even if the waste is not hazardous)
• Hazardous waste shipment paperwork
• Special waste shipment paperwork, including, but not limited to:
• Universal waste batteries
• Universal waste lamps
• Universal waste mercury switches
• Used oil
PCB and non-PCB Ballast recycling
• Solid waste tipping records
• Inspection logs
Air Management
• Current permits for major or minor sources and associated documents and correspondence
• Emission calculations for Potential to Emit (PTE)
• Annual air toxics inventory
• Inspection records and chemical usage records as required by permit conditions (e.g., VOC records, pressure
drop inspections, operating hours).
Wastewater Management
• Correspondence with local wastewater treatment plant authority
• Copy of current sanitary sewer ordinance
• Pre-treatment permit (if applicable) and associated documents and correspondence
Storm Water Management
• Inventory of storm water drainage and outfalls from your property (include map)
• Storm water pollution prevention plan
• Maintenance plan for storm water infrastructure
• Storm water permit (if applicable) and associated documents and correspondence
• Storm water annual reports and sampling results (if applicable)
20
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II. Responsible Environmental Basics—"Have to's'
Table 1: Summary of Environmental Files
What to Include
Facility ID number(s)
Spill Response
Interaction with
Regulators
Training Records
Why?
:' L2 GMP3
Records Retention Recommendations
Waste Management
Air Management
Wastewater Management
Storm Water Management
•S Keep active facility numbers up front, keep inactive facility numbers in the back
of the file.
v' Keep current plans at the front of the file. Keep summaries of drills and exercises
for three years. Move dated plans, closed incident reports, and critiques to back
of the file after three years and retain indefinitely.
•S Keep active inspection documents and notes on interpretations or advice from
regulators up front. Keep closed inspection files for three years, then you can
shred them. Keep regulatory notes that are no longer in effect at the back of the
file as a record of past practices.
v' Keep at the front training records and environmental position descriptions for
employees throughout their employment. (Hazardous waste training records
must be retained for three years, even if the employee has left.) Move training
records of employees who have left the company to the back and keep them in
case you need to account for your past practices.
S Keep up front active EPA ID numbers, permits, and waste determinations. Move
inactive EPA ID numbers, expired permits and the original permit application,
and waste determinations for wastes you no longer generate to the back of the
file. Keep hazardous waste/universal waste shipping records, and activity reports
on file for three years (required), then move them to the back of the file. Keep
inspection logs for three years, then shred. Keep solid waste tipping records up
front for one year, then move them to the back of the file and keep them.
•S Keep active permits up front. Move expired permits, original permit applications,
any calculations or data that you used in the permit process or to prove xemption
to the back. Keep up front annual air emissions reports and monitoring results for
the past three years, then move them to the back of the file.
v' Keep active permits and the current sanitary sewer ordinance up front. Move
expired permits, the original permit application, and expired ordinances to the
back. Keep up front annual reports and results of required monitoring for three
years, then move them to the back.
S Keep up front active permits and storm water pollution prevention plans. Move
expired permits and plans to the back. Keep up front annual reports and
monitoring results for the past three years, then move them to the back.
1 Compliance—Means you need to keep this file to meet recordkeeping requirements of environmental regulations.
2 Liability—Keep this file because it contains information that could help stay out of financial and legal trouble from future environ-
mental claims.
3 Good Management Practice—Keep this on file because it provides information that helps you keep track of your environmental
program, or saves you and your staff time later.
21
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///. Saving Money Through Sound Environmental Management
Greenhouse
gases such as
carbon dioxide
(CO.), sulfur
dioxide (SO.),
and nitrous oxide
(N2O) are respon-
sible for global
climate change,
acid rain and
smog.
In a nutshell...
Your tree is maturing and requires less attention to flourish. You are starting to see the return on your
efforts as it provides shade for your yard. After working through Section II, you are beginning to
develop a sound environmental management program and no longer feel like you are in crisis manage-
ment mode. You can talk knowledgably about the regulatory requirements and what methods you are
using to meet them. Now that you have the basics in place, you can turn some of your attention to the
fun stuff: looking for opportunities to make your business more profitable and productive as well as
more friendly toward the environment. This Section includes pointers for cutting back on your energy,
water, and waste disposal costs. After you have worked at this for a while, you may even find that your
regulatory requirements have been reduced by changing, scaling back, or eliminating a process. All of
this will be good preparation for working though Section IV which is about streamlining environmental
management and ensuring that the program will continuously improve over the long run.
How can I use the process map
to save money?
To be useful for working through this Section
of the Guide, you may need to add some details
to the process map that you put together at the
beginning of Section II. If you haven't already
done so, look at the inputs and outputs of each
step in the process, and figure out quantities and
costs associated with them. You may need to
make some estimates if you don't keep detailed
records, and that's OK. You are looking for a
ballpark idea of the magnitude of expenses.
Once you identify your big cost centers, you can
make better decisions about where to focus your
efforts to reduce costs. To see where this is
going, take a look at figure 1 on page 9. The idea
here is to plug the leaks to cut back on waste
energy, wastewater, or waste that is created in the
process. You also want to find ways to make the
process more efficient so you can cut back on
the inputs without decreasing the quality or rate
of production of the end product.
How can I conserve energy?
Here are three reasons to work on energy
conservation:
• First, saving energy in your business trans-
lates into cost savings.
• Second, using less electricity means less coal
and less natural gas are burned, which
reduces greenhouse gas emissions and other
forms of air pollution and conserves
resources for future generations.
• Third, there is free assistance available to
help your business explore even some of the
more involved options so why not take
advantage of them?
Let us first start with
no cost and very low cost
suggestions. Most of these involve changes in
employee activities and some readily made
equipment changes:
• Turn off lights or office equipment at night
and on weekends or take advantage of
22
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///. Saving Money Through Sound Environmental Management
natural daylight for lighting needs.
• Disconnect unnecessary equipment com-
pletely.
• Turn up or turn back the thermostat during
unoccupied times or consider buying a
programmable thermostat.
• Caulk and weather-strip windows and doors.
• Install blinds or shades to keep out summer
sun to lower air-conditioning costs.
• Purchase fans to keep warm air from
accumulating at the ceiling during winter.
• Insulate hot water holding tanks and hot and
cold pipes and improve insulation of the
climate controlled portions of your facility.
• Replace light bulbs with more efficient ones.
You can order inexpensive sub-compact
fluorescent lamps through a U.S. Depart-
ment of Energy (DOE) program. These last
eight to ten times as long as a regular bulb
and use one quarter to one third of the
energy.
• Place your lights on motion detectors or
install timers on lights and electric equip-
ment to keep them on only when in use.
• It may be worthwhile to replace lighting
fixtures instead of just the bulbs. The new
fixtures can allow you to utilize a smaller
bulb and get the same amount of light, or
reuse the ballast portion of the light.
Call your local utility company to see if
they still have a program to evaluate your
building for energy efficiency. (Many
have dropped their programs since
deregulation.) If the service is
available, the utility will provide you
with specific options for making your busi-
ness more energy efficient, usually for free. If
your local utility company does not provide
this service, check with your state's energy
program to see if they do, or know who does.
There are Industrial Assessment Centers
throughout the country that perform process
audits to reduce energy use, improve effi-
ciency, or reduce waste. (To find the Industrial
Assessment Center in your area see
www.oit.doe.gov/iac/)
Consider Participating in the Energy Star®
Program. Energy Star® is the trade mark EPA
uses to signify energy-efficient products. This
voluntary program is a partnership between
EPA, the U.S. Department of Energy (DOE),
product manufacturers, local utility compa-
nies, and retailers. The agencies set energy
efficiency criteria for specific consumer and
commercial products. Products meeting or
exceeding the energy efficiency criteria
established by the agencies are awarded the
Energy Star®label. These include items like
computers, monitors, fax machines, printers
and copiers. Energy Star® also has a small
business partnership program.
There are some real possibilities for cost
savings over time by replacing major equip-
ment within your facility. Not only will
there be savings on operational costs
because of increased efficiency, it
can also avoid maintenance
problems that take up time and
budget, and justify replacing
23
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///. Saving Money Through Sound Environmental Management
equipment that is out of date for reasons other
than just efficiency. One example is that tradi-
tional systems often have wasted energy and
money by running motors continuously at full
capacity, regardless of the end-use need. Fortu-
nately, motors can now be equipped with
variable speed drives to allow the motor to
closely match its power output with the energy
necessary for the task—eliminating waste and
saving money.
It is possible to make necessary upgrades with
no up-front capital and pay for them later
through the energy savings that result. Best of
all these savings can be guaranteed through the
energy performance contracting and assistance
provided by your state energy office in coopera-
tion with the Energy Services Coalition (ESC).
This works by entering into an agreement with a
Twenty thousand dollars can buy a lot of bread. That is
what a fast food franchise owner is saving by taking
advantage of energy-efficient technologies at his restau-
rant. What is his recipe for success? He upgraded his
store's lighting from 40-watt T-12 lamps and magnetic
ballasts to T-8 lamps and electronic ballasts. In addition to
his 50-percent energy savings, he now has brighter lighting
to make the food look more appetizing. He replaced his old
air-conditioning units with high-efficiency models and
added ceiling fans to circulate the store's air. He can now
set the store's thermostats 3 to 5 degrees higher in the
summer without affecting comfort. With these upgrades,
he will pay back his investment in three years. (Source:
EPA Smallbiz Success Stories)
private Energy Service Company (ESCO). The
energy service company identifies and evaluates
energy-saving opportunities and recommends
some improvements to be paid for through
savings. The savings must meet or exceed annual
payments to cover all project costs over the
contract period, usually seven to ten years, or the
energy service company pays the difference. To
ensure savings the energy service company
offers staff training and long term maintenance
services. Check with the National Association of
Energy Service Companies at www.naesco.org or
call them at 202-822-0950 to find a company
near you. Your state energy office can also
provide you with information, local case studies,
and resources to get you started.
Alternative energy sources merit consider-
ation too. At University of Texas Medical
Branch, alternative energy uses include the
installation of a photovoltaic system in a parking
garage. UTMB parking garages are required to
have lighting 24 hours a day, 7 days a week to
provide safe parking. Photovoltaic panels are
currently being installed with grant money from
the Texas Natural Resource Conservation
Commission. In addition, solar water heating is
becoming a very popular way of saving energy in
facilities with large water heating needs.
How can I conserve water?
Think about it: most business activities are
using part of a limited supply of water that is
good enough to drink. Only a tiny fraction of
the planet's water is drinkable. Ninety-seven
24
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///. Saving Money Through Sound Environmental Management
percent is sea water, which is expen-
sive and difficult to desalinate. About
two percent is caught in polar ice
caps. That leaves just one percent to
sustain life. Much of the world's
population gets their drinking water
from natural underground storage
tanks called aquifers. Humankind is rapidly using
up those reserves, digging ever-deeper wells and
lowering water levels in every continent. Also,
your business pays for using this resource. This
may not seem like a large part of your overhead.
That is, until you realize that you pay for it twice:
coming to the tap and going to the sewer. Take a
look at your combined water-sewer bill. If you
want to save some money while reducing the
impact of your business on your community's
water supply, consider some of the ideas below
as a starting point for your water conservation
efforts.
Find out how your company uses water. You
may have water guzzling processes that can be
changed or updated. Some water cooled equip-
ment can be replaced with air cooled equipment.
Are you spending more for the water to run a
process than you would spend to buy the goods
or services directly? If the water use in the
process can't be eliminated completely, perhaps
the water can be reused. For example, can your
business reuse process water to wash equipment
instead of sending it to the sewer? Since few
people would ignore ways to reduce chemical
use, doesn't it make sense to look at reduction in
water use as well? Rinsewaters can be used for
lower priority cleaning applications just as you
For More Information...
Energy Star® program: www.epa.gov/smallUz/or 888-STAR-YES.
Federal Energy Management Program: 8OO-363-3732.
Putting Energy Into Profits—Energy Star® Guide for Small Businesses is
available through both of the above agencies.
For info on motor selection:
www. eren. doe.gov/femp/procurement/pdfs/motor.pilf
The Department of Energy's Industrial Best Practices:
www.oit.doe.gov/bestpractlces/
State renewable energy assistance programs:
www.energy.ca.gov/reports/SOO-99-008.PDF
might use a slightly contaminated solvent for
another use before you dispose of it. And just as
used solvents can be reclaimed through distilla-
tion, water can be reclaimed through ultrafiltra-
tion. Furthermore, water recycled through
ultrafiltration or reverse osmosis systems can be
of better quality than supply water.
Keeping your plumbing fixtures in good
working order or upgrading fixtures can save
both water and money. Below are several ideas
and suggestions for you to try:
• An easy way to test for leaks in the toilet is
to put food dye in the toilet tank. Let it sit
for an hour or two without flushing. If you
see dye in the toilet bowl, you have a leak.
Check to make sure the overflow tube is not
flowing continually.
• Consider an inspection program for leaks.
• Repair dripping faucets by replacing washers.
• It may be worthwhile to replace plumbing
fixtures with more water efficient options.
25
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///. Saving Money Through Sound Environmental Management
Did you know
how quickly a
small water leak
can add up?
Toilet leaks can
waste more than
SO gallons of
water a day,
18,250 per year.
One drip per
second from a
leaky faucet
equates to 2,700
gallons of water
peryear.
' Faucet aerators with flow restrictors are
available to reduce water use.
• Some heating and cooling equipment models
reuse or recycle water.
• Automatic shut offs on water supplies such
as sinks and hose nozzles will keep them
from being left on.
• High pressure/low volume cleaning nozzles
on spray washers also use less water.
• Cover liquid holding areas when not in use
to reduce evaporation.
If you have grounds or greenspace, look at
outdoor water uses, such as landscaping.
Remember that established plants and lawns
need less water than new ones, and many native
plant species do with less water than imports.
Here are some additional ideas:
• Adding mulch can further reduce your water
needs.
• Set sprinkler patterns to avoid watering
structures and concreted areas and install
moisture-detection devices on automatic
outdoor sprinklers so that they will not
activate when it is raining.
• Water lawns early in the
morning when tempera-
ture and wind speed are
lowest to reduce evapo-
ration.
• Upgrade to an irrigation system that relies
on data on natural water loss through solar
radiation, temperature, wind velocity, soil
conditions and humidity to avoid over
watering by replacing only the water lost.
Small adjustments in your process can help
you to save money on your water and sewer bills.
Keep track of these expenses so that you can
gauge progress and quickly spot changes. Check
your meter for increased use that can signal a
problem. It is possible through continued
improvements that your company could reach a
point where there is "zero discharge" from your
processes through water recycling and reuse.
Other companies have achieved this level of
efficiency motivated either by a desire to reduce
cost associated with water consumption or to
eliminate the need to permit wastewater dis-
charge or to pay to dispose of wastewater. If
possible, talk with other companies about
methods they have used to save water. Your
water utility company may also be a source of
information on conservation methods.
How can I reduce waste
management costs?
Waste disposal can drive up unit costs on your
production lines. Here are some tips for getting
them under control:
One strategy is to make sure you are manag-
ing your wastes efficiently. When you hire a
hazardous waste contractor, ask them to help
you find ways to cut down on costs. While it
might seem that it is not in your contractor's best
interest to do this, the hazardous waste market
has gotten so competitive that contractors are
looking for ways to add value to their service and
set themselves apart from the competition.
Things you should consult with your contractor
about: Would accumulating your waste in a
container of a different size or type make it less
26
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///. Saving Money Through Sound Environmental Management
costly for the contractor to handle? Could you
save money by sending your hazardous waste
solvents for use as fuel for cement kilns? Maybe
there is a component in your waste that makes it
hard to manage and drives up its disposal cost.
Look for an opportunity to keep this item out of
the waste either by collecting it separately or
finding a replacement for it in your process.
Another approach is to look for ways to
reduce the amount of wastes your business
creates. A simple example is to reuse corrugated
boxes two or three times before you
send them off for recycling. Since
new boxes are expensive,
savings can add up fast. Let's
use the example of a spray
painting operation to illustrate
several more waste recycling and
pollution prevention ideas. Begin
with the inventory of paints you keep on hand.
Do you sometimes have paint that you can't use
up because their shelf life has expired? Or excess
paint that you have no use for anymore and have
to be disposed? If so, take a look at your pur-
chasing practices. Many vendors will work with
you on the concept of "just in time and just the
right amount." This means that they will deliver
your raw material more frequently in amounts
that nearly match your process needs. This may
be a little more costly than ordering bulk quanti-
ties up front, but you may be surprised: with
today's shipping options, many suppliers have
the ability for quick delivery at only a little
additional cost. Once you take into account all
the costs of handling paint purchased in bulk
(managing the material in storage, dispensing it,
disposing of excess or expired material) you may
find that you will come out ahead by opting for
"just in time" delivery.
After you look at how paint is delivered to
your process, take a look at the process itself. Sit
down with the workers who are most familiar
with the process and figure out exactly how
wastes are created in the spray
painting operation. Perhaps you are
using fresh mineral spirits each time
you clean the paint guns. What if
you could keep some mineral spirits
in a container to be reused the next
time you clean the guns? It's likely
that you use several rinses to get the guns clean
and that the mineral spirits used in the final pass
isn't very dirty. This could be reused in the initial
rinse the next cleaning and brand new mineral
spirits saved for the final rinses only. Every bit
of chemical that is reused is saving that much
new material and reducing the waste created by
that amount too. So, you save money on both
ends of the process.
Another strategy is to find a different material
to use to clean the paint guns so that a hazard-
ous waste would not be generated at all. There
are new clean-up products available that are not
combustible and aren't hazardous wastes once
they are used up. Of course, it would be prudent
to do some trials on a limited scale so you can
make sure the switch is going to work just as well
and be cost effective. Beyond paint operations,
there are similar green products available for
parts washing and stripping operations, to name
a couple. Some of these products have been on
27
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///. Saving Money Through Sound Environmental Management
the market for more than a decade, so
they have the bugs worked out of
them. In addition to saving money and
reducing the amount of hazardous
waste your business generates, many
of these greener products are also
safer for employees to use.
Another thing you might try is to get better
equipment. Perhaps you can upgrade your spray
paint equipment to a gun that has a smaller
reservoir but delivers the paint just as effectively.
Use plastic liners to eliminate cleaning the gun
reservoirs. Also, a newer HVLP gun is likely to
be more efficient by having higher deposit
efficiency and less overspray, thus saving money
Creative Solutions...
A trophy company owner had a dilemma—finding an inex-
pensive shipping solution for the large-sized trophies. The
large, odd-sized boxes he needed were more expensive
than normal shipping boxes. Through the Minnesota Materi-
als Exchange program, the business owner was put in
touch with a chemical company that was willing to part
with a supply of boxes that were the exact size he
needed—for free! Since then, the trophy company has
found other boxes and bubble wrap for packing trophies
through the program. Using the Materials Exchange Pro-
gram his company saves about $4,5OO per year.
For other case studies see:
State of Texas: http://p2.utep.edu/success/index.cfm
State of Minnesota: http://www.moea.state.mn.us/
p2week99/stories. cfm
on paint purchases. An enclosed paint
gun cleaning system that recycles
cleaning fluid will also save money by
losing less product to evaporation and
re-using product. These process
changes will save on waste disposal
costs as well as product purchases.
They will greatly reduce air emissions, perhaps to
levels that do not require an environmental
permit. If you have been operating under an air
permit, you know how costly it is to keep up, so
being able to drop the permit will save time and
money too.
How do I predict savings from
proposed projects?
This part of the Guide has emphasized
projects that are likely to have a financial pay-
back. It is understandable that you, as the top
person at your business, will want to know how
much and how soon the return will be for the
effort and funding invested in the project. But,
after you have sharpened your pencil, what
exactly do you include in a cost work up?
The question you need to answer is, "What is
the up front cost of the change you are consid-
ering, and how long will it take for enough
savings to accumulate to offset this up front
cost?" This is the "return on investment," and
usually, if it will take more than two years for
benefits to outweigh the initial outlay, it may be
difficult to convince you and your staff to do the
project unless there are other really good reasons
to do it, such as improved employee safety. With
28
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///. Saving Money Through Sound Environmental Management
this in mind, here are some cost categories to
consider as you work up your analysis.
Initial start up costs. In addition to the cost
of purchasing, will the change require remodel-
ing or modifications to meet building codes?
Changeover costs. When changing from the
old process to the new process, what will happen
to excess raw materials that can no longer be
used? Will employees need training before they
can begin using the new process? Will you need a
trial period to work out any bugs?
With the up front costs nailed down, compare
the old process and the new process head to
head.
Operating costs. These can include electric-
ity, water use, and ventilation systems. Also look
at whether the new process will be more or less
labor intensive. Will the new process be more
productive, for example, higher units of output
per hour or lower amount of raw materials per
unit?
Environmental management and compli-
ance costs. What are the waste management
costs? Will compliance be made easier by the
new process? For example, will it eliminate a
required report to regulators? Will it put you in a
hazardous waste generator category with reduced
requirements? Will you be able to discontinue an
environmental permit? If so, try to estimate the
time company employees put into these efforts
to come up with an estimate of dollars saved.
For More Information About Pollution Prevention...
Environmental Protection Agency
Pollution Prevention Information Clearinghouse:
www. epa.gov/opptintr/library/libppic. htm
Envirofacts: www.epa.gov/enviro/indexjava.html
Environmentally Preferable Purchasing web site: www.epa.gov/oppintr/epp
Region 1: www.epa.gov/region1/compliance/assist/p2page.html
Region 2: www.epa.gov/r02earth/p2/p2home.htm
Region 3: www.epa.gov/reg3p2p2/
Region 4: www.epa.gov/region4/air/polprev.htm
Region 5: www.epa.gov/reg5rcra/wptdiv/p2pages/index.html
Region 8: www.epa.gov/region08/conservation_recycling/p2home/
p2home.html
Region 9: www.epa.gov/region09/crossjfir/p2/index.html
Region 10: yosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrec
Other
Pacific Northwest National Laboratory P2 website: www.pnl.gov/p2/
Kentucky Pollution Prevention Center: www.kppc.org/
Avoided costs. In addition to avoided waste
disposal costs, consider whether the new process
requires less raw material inputs, thus saving
costs in purchasing them. Will the new process
eliminate spills and their associated costs? Will
there be less personal protective equipment and
safety training required?
It may not be a formal and totally complete
analysis, but if you think through all of the
above categories you will have a much clearer
picture when you get done of whether your idea
is as valuable as you first thought.
29
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IV. Keeping the Program Alive
In a nutshell...
Now that your tree is fully mature, you want to make sure it will stay healthy over the long run. Could it
become susceptible to disease or get blown down in a storm? To this point, you have put in place the
essential functions of environmental management; you 've taken some opportunities to save money. But,
you worry about losing the momentum. You want to bring your environmental management program up
to a level that no matter what changes occur at your business, it will reliably steer your business
activities in a direction that keeps employees safe, avoids bad effects on the environment, complies with
regulations, and saves money. This Section of the Guide helps you accomplish that. It will help you get
employees more thoroughly involved in environmental management. It explains how a company's
environmental policy can act as a tap root, feeding environmental concerns into all decision making
branches. While it may seem like you have to devote more time at first, you will be streamlining and
integrating environmental responsibilities—thinning them out and making them easier and less time
consuming for each employee. Then you can apply methods to gauge progress over time, set goals, and
form a simple environmental management plan to guide your program towards improvement. Once this
is done, you will be able to have complete confidence in the long term vitality of your environmental
program. Then, you will be ready to make people outside your company aware of your business'
exemplary performance in environmental management by working through Section V.
How do we involve our
employees in environmental
management activities?
By now you have taken some steps to put a
basic environmental management program in
place and find that it makes good sense. You, as
the business owner, continue to offer visible
support for environmental management so the
program is taken seriously. But, do you wonder
how you are ever going to keep it going while
still meeting everyday business demands? It's
time to enlist some help. Environmental efforts
within your company will be more successful if
employees are directly involved. Employees are a
great source of knowledge on environmental
issues related to their work areas and the effec-
tiveness of current procedures. Consider setting
up an Environmental Management Team and
making a company environmental policy. The
team can then use the policy to make the
company's environmental efforts more efficient
and to get more employees actively involved in
them.
The team approach will help to fit another
activity into an already busy schedule and the
discussion it brings about will create a more
complete picture of where you currently stand
and where you go from here. If you can't guide
the Environmental Management Team all the
30
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IV. Keeping the Program Alive
time, appoint a team leader to encourage com-
munication between employees, supervisors, and
company leadership. For this to work, the team
leader needs some authority to keep things
moving. The team should include representatives
from throughout the company. For example, at a
small company, a team could include supervisors
from each process line as well as people respon-
sible for human resources, sales, and plant
operations. In a very small company, the team
leader and the business owner may be the same
person, and the team may consist of the entire
staff. Small companies can have a real advantage
over larger companies. Communication is easier,
staff is used to having multiple roles, and
processes are well understood by everyone.
The first task is to write a company environ-
mental policy. You may want to do this and pass
it down to the team, or you can ask the team to
do it for your review and approval. A company
environmental policy is the shared starting point
for people to understand the basic environmen-
tal beliefs and commitments of the company's
leaders. It states how environmental concerns
are considered in the company's decision making
and how these concerns fit into its day to day
activities. The policy should reflect your commit-
ment to the environmental program. It should
be short, to the point, and well
communicated throughout
the company so that
employees understand and
remember the policy. All
the other steps for improv-
ing the environmental
Ways to Keep Employees Involved
1. Post the Environmental Policy at prominent
locations throughout your business.
2. Set up a suggestion box for environmental
improvements. Recognize or give awards to
employees that make suggestions that get
incorporated into environmental management
procedures.
3. Inform employees through a company newsletter
or bulletin board and provide them updates
on the company's progress in fulfilling its
Environmental Policy.
management program are geared towards
meeting the environmental beliefs stated in the
policy.
How do we go about getting
things written down and why
should we spend time on this?
With the policy in hand, the team can begin to
organize and write down the activities that make
up your environmental management program.
To do this, bring together and examine all parts
of the environmental management program
your company developed by working through
Section II of the Guide. This written program
will support your policy and later form the basis
for setting goals and making an environmental
management plan. Your written program should
31
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IV. Keeping the Program Alive
assign roles and responsibilities for
accomplishing the activities that you
have identified. Break these down
into small manageable jobs that
are clearly defined so that
everyone knows what their job is
and nothing gets missed. The
benefit of doing this is that when you
add up the duties of all individuals it will provide
complete coverage of your company's environ-
mental responsibilities and commitments, but no
one person will have too much to do.
Another good reason to spend time on a
written program is that the team will see where
there is duplication of effort that can be stream-
lined. For example, your team may discover that
employees are being pulled out of their work for
training several times per year. What if your
company set aside time for training covering all
requirements on one day each year? You can also
streamline training by covering more than one
regulation under a given topic—such as training
on labeling requirements that covers require-
ments of both the Occupational Safety and
Health Administration (OSHA) and EPA, as well
as any local requirements such as those of your
municipal fire department.
Another area that can often be streamlined is
spill preparedness. Some small businesses may
have more than one spill response plan—one to
cover storm water regulations, one to cover
hazardous waste spills, and one to cover petro-
leum product spills. For a small company where
these plans are not too complicated, covering all
the requirements in one plan will reduce
the amount of effort it takes to keep it
up to date. It makes the plan more
effective too because employees
•\ don't have to learn a different set
J* of procedures for each plan, and
try to remember during a spill
situation which plan applies to it.
With a good overview of the environmental
management program, the team can begin to
look at more detailed procedures that need to be
consistent with the written program and the
environmental policy. Ask employees to write
down what they do during normal daily activities.
Getting this written down makes sense so that
nothing gets forgotten and procedures are easy
to communicate. Written procedures make cross
training easier, ensuring that someone will be
available to perform a critical function if the
regular employee is away. They can make turn-
over easier because the person hiring will have a
better idea of what each job entails.
Once they are written down, the team can
evaluate procedures so that each employee's
activities include good environmental manage-
ment practices. Without good environmental
management practices, employees may get the
impression that anything other than steps
absolutely crucial to making the product are
"extras." They have to rely on word of mouth
for information, and the answer depends on
who they ask. With no good environmental
management practices, they are more likely to
take shortcuts when pressed for time that are not
32
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IV. Keeping the Program Alive
safe or good for the environment Your com-
pany can reinforce the importance of good
environmental management practices by making
them part of job performance evaluations.
Supervisors can use the good environmental
practices in written procedures to explain to new
employees how the company environmental
policy relates to their job.
When evaluating environmental management
practices, you should see if best environmental
management practices have been identified for
your business sector by environmental regulatory
agencies or your trade or industry association.
For example, EPA Small Business Division has
compiled best environmental management
practices for certain sectors in its publication
called Plugging into Best Environmental Management
Practices. To find out what sectors are included
and, if they pertain to your business, obtain a
copy, call EPA's Small Business Division at 800-
368-5888.
How does this fit in with my
company's safety or quality
management program/
While the focus here is environmental
management, don't overlook the opportunity to
integrate with other business management
systems such as process quality, production
control, or safety management. They offer many
opportunities to complement your environmen-
tal management efforts and vice versa. If you are
already doing job hazard assessments to develop
safety procedures, it is a simple extra step to
address environmental hazards at the same time.
Material safety data sheets that you must have
for your safety program and product specifica-
tion or quality verification sheets that you
maintain for your quality program offer a wealth
of information about environmental issues. If
your business has an electronic business manage-
ment system, this puts information at your
fingertips such as rates of raw material use,
product outputs, and cost data—a great resource
for environmental performance improvement.
Is this working—are we getting
the results we wanted? '
After your environmental management
program has been in place a while, you might be
wondering how you can tell how things are
going. Are you making progress on getting into
compliance? Are all your shops and operations
getting the information they need to keep
moving ahead?
Audits are a great way to gather information
on how well your environmental management
efforts are working. These can be done internally
under the oversight of the Environmental
Management Team or
your business can get
outside help. By
involving employees in
environmental audits,
you will give them a
first hand look at what
they are doing right
and what still needs
33
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IV. Keeping the Program Alive
improvement If getting into
compliance is a big priority, then it is
wise to get some assistance from
outside your company. Fortunately,
there are many outside resources you
can draw on. A number of compliance
assistance organizations make audit
checklists freely available that cover
specific regulations. A representative from your
state Small Business Assistance Program can
come do a compliance audit for you. This has
the added weight of an outside expert without
the headaches that you would get from a true
regulatory inspection. Since a compliance audit
conducted by an outside organization feels a lot
like a regulatory inspection to your employees, it
is also good practice. After each audit, organize
findings and follow up actions by work area to
make it easier to pass them on to those respon-
sible. In addition, the auditor should provide a
summary of larger tasks that need to be done
company-wide.
On Setting Targets
Let's say your goal is to reduce hazardous waste.
You could look for a percentage reduction in the
amount of all hazardous waste generated. But, this
won't be meaningful if your waste generation is
linked to production and your production doubles in
the coming year. What if you look for a percentage
reduction in hazardous waste per unit of product
produced? This is a measure you can use to set a
meaningful target—say, a ten percent reduction in
hazardous waste per unit produced.
Your audits help you gauge
which areas you are making
progress in and which areas are
lagging. Once you have audit results,
it is a good time to set some goals
yand targets. After all, there is a lot of
truth to the old adage, "What gets
measured gets done." Get the Envi-
ronmental Management Team together, go over
the audit results with them, and ask them for
their impressions of how things are going. This
is a great time to go over other information that
tells you how you are doing: How many spills did
you have last year? Are the consumption of
chemical raw materials and the amount of waste
generated per unit of product produced increas-
ing or decreasing? Do problems in a particular
area signal that procedures need to be updated?
Are new employees getting trained soon after
they come on board?
As a group, decide on a few goals. Be sure
that these goals are realistic and fit into previ-
ously established organizational goals. With all
the other demands on small businesses, setting
expectations that are exceedingly difficult to
meet would sure put the chill on the progress
you've made so far. After the group agrees on a
goal, then they need to decide how to measure in
the future whether or not you are making
progress toward your goal and by how much you
want to improve. This is your target.
One last bit of advice on goals and targets.
Don't set too many of them in a given year, or
you will wind up with a mini-bureaucracy of
34
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IV. Keeping the Program Alive
your own. Remember, the beauty of this tool is
that you can get back together next year, look at
your results to see whether your company met its
goal and then regroup. You can choose a
different approach if the first one you tried isn't
as useful as you hoped. You can add new
goals—perhaps in an entirely different area or
production line. Once you have the system set
up to measure performance, keeping it going will
be a lot less time intensive than the initial
investment to get it up and running. It is a good
idea to take your time to select goals that have a
lot of mileage and find the right measures for
them. In just a few years, you will be able to
demonstrate in hard numbers the value of your
environmental management program, and, well,
that's just good business.
You may not realize it, but you have just laid
the groundwork for an effective annual plan for
your environmental management program. Take
your company policy; add a summary of audit
results, accomplishments, and setbacks for the
past year. Then, review the thinking used to
analyze problems, set criteria, select goals for the
coming year, and update the list of goals and
targets. Now you have an environmental man-
agement plan. Of course, this is a simplified
planning approach—but once you have the
process established, you can build on it. When-
ever the plan changes enlist the Environmental
Management Team to communicate the changes.
Employees want to know why it is important to
accomplish a particular environmental task and
what part they are to play in achieving selected
goals.
OK, now you have your written environmen-
tal management program, you have a plan for
what you want to improve and how you are
going to measure improvements. By now,
employee environmental management responsi-
bilities are so well defined and accepted that they
are second nature—just like filing a timesheet, or
starting up their line at the beginning of a shift.
There's only one last thing your company needs
to do to make your environmental management
program complete. Make sure top management
at your company checks in on a regular basis.
As the small business owner, you may need to
periodically do your own assessment of how the
environmental management program is working.
Revisit the environmental policy and make your
own evaluation of whether it is still in synch
with company goals. Finally, pull this together
into a written review to give the Environmental
Management Team feedback on what needs to
be changed, if anything.
What exactly Is an environmental management plan?
An environmental management plan describes the
actions an organization is taking to determine how it
affects the environment, complies with regulations,
keeps track of environmental management activities,
and meets environmental goals and targets. It also
documents key elements of environmental manage-
ment. It is the compass for your environmental
management program because it tells you what
direction you are going in.
35
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V. Taking it Outside Your Facility
In a nutshell...
The environmental management program you have cultivated is providing value to your customers and
your community. This Section of the Guide explores the value of paying attention to relationships
beyond the walls of your small business to show off and improve your environmental management
activities. It suggests ways to make neighbors, the surrounding community, customers, suppliers, and
others aware of your environmental management achievements and how to team up with them to
improve environmental performance.
How do I communicate our
environmental management
efforts to those outside of our
business?
There are people outside your business who
are either interested in your efforts or can help
you with them. Now that your company has
invested effort to develop a good environmental
management program it's time you got a pat on
the back for it. One relationship that you are
already very interested in is the one you have
with your customers. After all, that's what keeps
the money coming in and the wheels turning.
But, the relationships your business develops
with community officials, suppliers,
and the regulatory community are
also important to your business.
That is where you get informa-
tion and the support to make
your program more effective.
The opinions of your neigh-
bors and the community around
you are important to the success
of your business. How do you tell
these people that you are taking steps to be
environmentally friendly? First, you can post a
copy of your company environmental policy so
that it is visible to anyone who visits your
business. Look for a way to make them a partner
in your efforts such as having them return your
package for a refill. This gives them yet another
reason to come see you. Another idea is to
sponsor an education day for a local school
biology, ecology, or environmental science class
to tour your facility. Every parent that asks
"What did you do in school today?" will get to
hear a little about your company. You can also
post information or make information available
on the latest improvement you made at your
business that made a positive
impact on the environment.
Place this information in your
front office to help waiting
visitors pass the time.
Companies who don't see
their end users in person can
add information about positive
environmental achievements
directly to the product packag-
36
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V. Taking it Outside Your Facility
ing. You can modify your packaging to show use
of a post consumer recyclable product or the
potential for recycling after use. These steps may
help catch the eye of new customers as well. You
can create a refill version of your product that
eliminates the large packaging completely. This
may attract the customer who is conscious about
the amount of waste they generate or it may just
be more convenient to carry or store. You can
also pursue obtaining environmentally friendly
designations for your products such as "Energy
Star®" or "Grown in accordance with the
Californian Organic Foods Act." Consumers in
many markets have proven that they are inter-
ested in buying environmentally superior prod-
ucts. People will invest extra money in energy
efficient products if they know that these
products will pay for the difference in future
savings. The market for organically grown
produce continues to increase even though the
prices for these items are substantially greater
than their less environmentally sound competi-
tors. There are organizations and web sites that
spread the word about green products. Your
business may be able to obtain a listing on these
sources if your product is produced in an
environmentally friendly manner.
How can the activities of our
suppliers complement our
efforts towards environmental
management?
Your suppliers can be an extension of your
successful program. Once you communicate to
your suppliers and vendors that you favor raw
materials and services that result in improved
environmental performance, they can assist you
with your needs. They can reformulate your raw
materials to meet your waste reduction goals and
help you find better substitute products. They
can offer "just in time" delivery, allowing you to
keep less hazardous chemicals on-site at any
given time, and possibly to use smaller contain-
ers. Some suppliers will allow you to return
unused product to be beneficially reused or
recycled in their process. You can encourage
them to incorporate recycled materials in their
products and packaging, or to modify the
quantity of product or the product container to
best fit your needs. You can talk with them about
the option of returning their packaging for a
refill. Many companies have discovered that it
saves them money to pick up the empty contain-
ers when they deliver fresh product, rather than
to constantly replace them.
When you consider a new product:
• Ask manufacturers for substantive data on
their green products compared with conven-
tional products.
• Obtain customer references to verify
product performance.
• Request a guarantee policy and special prices
to test green products on a trial basis.
• Determine whether another organization
has certified that the product is environmen-
tally preferable.
37
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V. Taking it Outside Your Facility
Of course you want
to make sure that the
greener products
perform to acceptable
standards, are com-
petitively priced, and
o not offset environ-
mental gains in other areas,
such as a cleaning product that requires more
water. There are resources that can help you
more quickly identify environmentally superior
products, or get a sense of what's available in the
market. EPA's Comprehensive Procurement
Guidelines at www.epa.gov/cpg/ provide
recommended specifications for recycled content
for a variety of products. Another resource is the
Green Seal program at www.greenseal.org
What's the key to improving
my image in the greater
community?
There are many organizations in place to
assist small businesses. Taking advantage of
these services is viewed positively by regulatory
agencies and can offer many benefits. A great
strategy is to become active in the trade or
industry association for your type of business.
Through this relationship, you will get valuable
information about new regulations, and have a
much greater voice on Capitol Hill by joining
with others. These can connect businesses for
peer exchange or business-to-business
mentoring. In addition to being a great resource
on questions about upcoming and existing
regulations, your state's Small Business Assis-
tance Program staff can help you identify what
trade and industry associations are out there and
help you develop a strategy to get your message
out to the community. The Regulatory Flexibility
Act requires that the impact of new regulations
on small businesses be studied before they go
into effect. Staying in the loop will allow you to
put your two cents in before another rule is
added to the books. The Small Business Assis-
tance Program staff can also tell you about other
services you might want to take advantage of,
such as agencies that help you find pollution
prevention ideas that save your business money.
You might also want to become involved in your
state's Compliance Advisory Panel, a group of
small business owners appointed in some states
to advise the Small Business Assistance Program
on how it can better serve small businesses.
There is also a National Compliance Advisory
Panel that advises EPA.
Consider having a representative from your
business get involved in local boards or commit-
tees such as the Local Emergency Planning
Committee. Often the Chamber of Commerce
will have an environmental affairs group. The
regulatory agency may have an industry feedback
group of some type.
Their meetings give
you an opportunity
to obtain informa-
tion about new
developments and
to ask questions and
share concerns in a
relaxed atmosphere.
38
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VI. Summary
In a nutshell...
Because you have invested effort regularly over many months or even years, your environmental
management program has grown strong. Like a healthy tree, it provides protection for you and your
neighbors. You have set up an approach to environmental management that naturally leads to ongoing
improvement. You may not realize it, but you have put in place an environmental management system.
If you want to, you can even seek outside recognition or official verification of your environmental
management system. This Section of the Guide explains the components of an environmental manage-
ment system and how you can determine whether you have all the components in place. It also describes
what kinds of official recognition you can seek for your environmental management system, and what to
consider when deciding whether seeking recognition is a good idea for your business.
What is an environmental
management system?
An environmental management system (EMS)
is an organizational approach to environmental
management that incorporates quality improve-
ment principles (sometimes referred to as "Plan-
Do-Check-Act") to develop, achieve, review, and
maintain an environmental policy. The compo-
nents of an environmental management system
were outlined in 1995 in a standard developed by
the International Organization for Standardiza-
tion called ISO 14001. Since then, many ap-
proaches to environmental management systems
have been developed, but nearly all have similar
components:
Environmental Policy. This is the statement
by top management of their intentions and
principles in relation to environmental perfor-
mance. It is at the heart of the environmental
management system and provides the framework
for planning and action the organization takes
through the environmental management system.
Environmental Planning. The steps in
formal environmental planning include figuring
out all the ways the business impacts the envi-
ronment (called "environmental aspects"),
identifying the legal and other requirements that
the business must comply with, setting goals and
targets to improve environmental performance,
and putting in place a written program to achieve
39
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VI. Summary
your goals. The plan also documents key ele-
ments of environmental management including
the environmental policy, responsibilities,
environmental manual, applicable standard
operating procedures and best management
practices, recordkeeping, document control,
reports, communication, training, monitoring,
and corrective action.
Implementation and Operation. This part
of the environmental management system
defines the structure and assigns responsibility
for environmental management. It lays out
training needs and how they will be met. It sets
up communication channels to make sure that
everyone within your business is aware of the
environmental management system and that
persons outside the company can provide input.
It puts in place an information management
system that includes document control. It
outlines procedures for control of operations
that impact or have potential to impact the
environment and sets up an emergency pre-
paredness and response program.
Checking and Corrective Action. This
includes the methods for monitoring processes
and measuring their impact on the environment.
It identifies what actions the business takes to
correct problems that come up and to prevent
them from happening again. It defines who is
responsible for taking action if there is non-
conformance. It defines what environmental
records must be kept and for how long. It also
explains the audit program used to check on
how well the business is meeting its environmen-
tal management goals.
Management Review. This is a process in
which the business owner and other key people
review the environmental management system to
determine if it is still suitable and effective, and
whether the business is doing what it has
committed to do.
How does what I've done so far
relate to an environmental
management system?
Although the description of an environmental
management system may be daunting, how to
put it in place has already been described in
earlier Sections of the Guide, as shown by Table
2. You can see that if you continue to make
steady progress on the recommendations in
Sections II through V of the Guide, you will
have nearly all the components of an environ-
mental management system. Even if you don't
have all of the elements in place yet, keeping
them in mind helps you get a vision of the full
potential of your environmental management
program as it keeps improving over time.
How do you know when you have assembled
all the components of an environmental man-
agement system? You can find this out yourself
by comparing what you've got in place at your
business against the ISO 14001 standard or
another widely accepted benchmark. This is
referred to as doing a "gap analysis." If your gap
analysis finds that you have all the components
of the environmental management system in
place, then you need to look at whether your
environmental management system is perform-
40
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VI. Summary
ing the way you want it to. Is your business'
performance consistent with your environmental
policy? Are you making forward progress on
environmental objectives and targets? This is
referred to as doing an audit of your environ-
mental management system, or an "EMS audit."
(This is the last piece you need to put in place to
have all the components of an environmental
management system.) Let's say that your gap
analysis shows that you have all the components
of an environmental management system in
place, and your EMS audit shows that your
environmental management system is perform-
ing as it was intended to. If so, then, congratula-
tions! You have put in place an environmental
management system.
To demonstrate that your business has met all
of the criteria for an environmental management
system, you can also seek verification or certifi-
cation from an outside party. For example, some
states have programs (often called "environmen-
tal leadership programs") that give recognition,
awards, or other perks to businesses that demon-
strate they have an effective environmental
management system in place. EPA also has a
program, called National Performance Track,
that recognizes and encourages top environmen-
tal performers—those who go beyond compli-
ance with regulations to attain levels of perfor-
mance that benefit people, communities, and the
environment. (See www.epa.gov/
performancetrack/index.htm.) You can obtain
the most official type of approval by hiring an
outside auditor to come in and look at your
environmental management system to confirm
that it has all of the elements required by ISO
14001 and is functioning properly. If it passes
the audit, your company will be "ISO 14001
certified." This certification carries with it a
distinction similar to being "ISO 9001 certified"
for quality management.
Why would I want to have an
environmental management
system?
After working through previous Guide
Sections, you already know many of the benefits
of having an environmental management
system. It has helped you cut costs. It gives you a
comfort level that you have covered your bases
as far as meeting regulatory requirements, and
that there will be no unpleasant surprises. It
makes it easier for you to answer inquiries from
employees, neighbors, community leaders, and
regulators about your business' environmental
performance. It demonstrates your business'
commitment to being a good neighbor and puts
information at your fingertips about your
business' track record and current environmental
efforts.
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VI. Summary
Table 2: Correlation Between Environmental Management System (EMS) Components and Guide Sections
EMS Component
Environmental Policy
Environmental Planning
^ Identify environmental aspects
Guide Section(s) and Part(s)
IV. How do we involve our employees in environmental management activities?
How can I understand how my business is affecting the environment?
Identify legal and other requirements
How can I get a handle on environmental laws and regulations?
Set objectives and targets
Is this working—are we getting the results we wanted?
^ Written plan
Implementation and Operation
E- Structure and responsibility
IV. Is this working—are we getting the results we wanted?
IV How do we go about getting things written down and why should we spend time on this?
Training
IV
What are the basics of good environmental management?
How do we go about getting things written down and why should we spend time on this?
Communication
11. What are the basics of good environmental management?
IV How do we involve our employees in environmental management activities?
V How do I communicate our environmental management efforts to those outside of our business?
What's the key to improving my image in the greater community?
Documentation and document control
IV
What are the basics of good environmental management?
How do we go about getting things written down and why should we spend time on this?
Operational control
IV
All Parts.
How can I use the process map to save money?
How do I predict savings from proposed projects?
All Parts.
^ Emergency preparedness and response
Monitoring and Measurement
^ Monitoring and measurement
IV
What are the basics of good environmental management?
How do we go about getting things written down and why should we spend time on this?
III. How can I use the process map to save money?
How do I predict savings fromproposed projects?
IV Is this working—are we getting the results we wanted?
Non-conformance and corrective and
preventive action
II. What are the basics of good environmental management?
IV Is this working—are we getting the results we wanted?
Records
II. What are the basics of good environmental management?
IV How do we go about getting things written down and why should we spend time on this?
^ EMS audits
Management Review
IV Is this working—are we getting the results we wanted?
IV Is this working—are we getting the results we wanted?
42
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VI. Summary
So why would you want to obtain outside
recognition or certification for your environmen-
tal management system? Obtaining recognition
from a state environmental leadership program
or EPA's National Performance Track may
impress some of your customers and distinguish
you from your competitors. ISO certification is
expensive, so it may not be worthwhile for a
small business to do. But, if one of your major
customers requires it, as some of the major
automobile manufacturers have of their suppli-
ers, it may be worth the money. Also, the rigor
of the ISO certification process provides a
structure and focus that prevents environmental
management efforts from backsliding over time.
Why are trade organizations and
regulatory agencies supporting
environmental management
systems?
Many businesses have demonstrated that
through their environmental management system
they can make great improvements in their
environmental performance while saving money
and increasing productivity. As a result, trade
associations and other business organizations
support environmental
management systems
because they make good
business sense. Also, if
the majority of compa-
nies in a business sector
adopt environmental
management systems
and show greatly
improved environmental performance, this
enhances the long term viability of the business
sector, and gives it a fresh marketing angle.
Regulatory agencies support environmental
management systems because they are aware that
the traditional "command and control" system
of environmental regulation is limited in its
potential to have major positive impacts on the
environment over the long term. They are more
open to working with industries and trade
organizations on more flexible and perfor-
mance-based approaches to improving environ-
mental performance than traditional compliance
methods. When making agreements to allow
such flexibility, regulatory agencies often require
businesses to put an environmental management
system in place to show accountability for their
actions in the absence of certain elements of the
traditional compliance framework. This allows
regulatory agencies to make forward progress
towards streamlining regulations while account-
ing to the public that the new systems are
working. Regulatory agencies have also incorpo-
rated the environmental management system
approach into their enforcement activities. It is
very common for regulators to require a violator
to put an environmental management system in
place as part of the settlement agreement.
How can I get help with putting
an environmental management
system in place and getting
recognition for it?
Your Small Business Assistance Program can
43
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VI. Summary
give you assistance with environmental manage-
ment systems. (Again, to get contact information
for your state, visit www.smallbiz-enviroweb.org/
or call EPA's Small Business Division at 800-368-
5888.) They can also help you make application
to EPA's National Performance Track program,
make you aware of other recognition programs
that your business may qualify for, or put you in
touch with reputable third party auditors if you
wish to seek ISO 14001 certification. EPA's
Small Business Division can also provide
assistance and refer you to other contacts and
resources. Finally, if you want to learn more
about environmental management systems, there
is a wealth of resources available at EPA's
website, www.epa.gov/ems/. At that website,
you might be especially interested in the case
study for Federal Foam, a small business in
Wisconsin that decided to seek ISO 14001
certification. Another good resource is the
companion publication to this one, Documenting
Your Environmental Management flan—A Workbook
for Small Business, which includes worksheets for
achieving the steps outlined in this Guide. It is
available through EPA's Small Business Division
and atwww.epa.gov/ems/. EPA's Small Business
Division is also collecting best management
practices for selected business sectors. If your
business sector is included, you may want to take
a look at these.
What's the bottom line here?
This Guide has given you tools to develop a
complete environmental management system,
geared to your business' available time and
resources. No matter how long it takes, if you
follow the recommendations in Guide Sections
II through V, you will have a solid compliance
program, an environmental policy to focus your
efforts, programs and procedures that are
written down and kept up to date, and clearly
defined roles that are understood by each
employee. You set goals and targets for each year
and have a plan to move your business in the
direction of improvement. You work at this over
time because it makes good business sense,
increases your business' productivity, and brings
you peace of mind. If you have gotten this far,
your business has all the components of an
environmental management system and is in a
good position to seek
outside verification.
But, in the end,
whether or not it
will be valuable or
cost effective to
seek outside verification
of your environmental
management system is up
to you.
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Table 3: Major Categories of Environmental Regulations
Type of Impact
Wastes containing chemicals even in tiny
amounts.
Examples: Parts washing fluids, paint
thinners, acids, caustics, toxic chemicals like
pesticides or chlorinated solvents, and
wastes that have toxic metals in them like
lead, cadmium, or chromium.
Applicable Law(s)
Overview of Regulations1
Resource Conservation Tells you what a hazardous waste is and sets requirements for taking care of it on-site, moving it from one
and Recovery Act (RCRA) place to another, and where and how it may be treated or disposed. Regulation includes special provisions
of 1976 and subsequent fo make recycling easier for universal wastes: mercury-containing lamps, batteries, mercury switches, and
amendments recalled pesticides.
Thresholds: Applies to any amount of hazardous waste.
Requires Permit? Yes, for certain hazardous waste activities.
Regulatory Reports? Yes, annually, for some, but not all, generators, and any business that must have a permit. May
also require notification of the regulatory agency of hazardous waste activities depending on the amount of waste
generated.
Important Considerations: The law requires your business to determine whether any of its wastes are
legally classified as hazardous. Make sure this is done properly to avoid severe financial and liability risk if
wastes are illegally disposed (even by accident).
Waste disposal liability.
Example: The company that took your waste
ten years ago went bankrupt, leaving a
contaminated landfill. Now you may be
required to share in the cost for the site's
clean-up.
Air pollutants released from business
operations.
Examples: Boilers and furnaces, paint and
dye application, parts cleaning, sand blasting
or other dusty operations.
Comprehensive
Environmental Response,
Compensation, and Liability
Act (CERCLA)
Clean Air Act (CAA) and its
amendments
Contaminated water from business
operations or propery.
Examples: Process water going off your
property through a drain. Storm water that
runs off your property through a storm drain
or another waterway.
Clean Water Act (CWA)
and its amendments
Maintains "Superfund" to pay for clean up of hazardous waste sites up front. Later, the Environmental Protection
Agency (EPA) can recover costs from each "Responsible Party (RP)." Those who once owned the site, presently
own the site, or sent waste to the site can be an RP.
Thresholds: Anyone who owned or contributed waste to a site can be an RP.
Requires Permit? No.
Regulatory Reports? No, but lots of other paperwork.
Important Considerations: If you ever receive a letter that suggests your business may be an RP, get a good
environmental attorney before you reply.
Sets up a system of controls to be sure that pollutants coming from a business' operations or heating plant do not
hurt the overall air quality in the region. It regulates numerous pollutants. Of particular concern to small businesses
are volatile organic compounds (VOCs), nitrous oxides (NOx), and hazardous air pollutants (HAPs), though
additional ones may apply.
Thresholds: Numerous thresholds for specific air contaminants, usually given in tons or pounds per year. These
thresholds are based on your business' potential to emit (PTE), assuming 24 hour production at peak rates, as well
as its actual emissions, so your business could be covered even if its actual emissions are low.
Requires Permit? Yes, depending on what contaminants are emitted and the amount of actual and potential
emissions.
Regulatory Reports? Yes, annually, if your business is subject to a permit. Daily monitoring and quarterly reporting
may also be required depending on the type of operation.
Important Considerations: A business may require a permit based on its potential to emit, even if its actual
emissions do not exceed thresholds. Also, you may have to obtain a permit before you can begin
construction of operations that will increase air emissions.
Sets up a system of controls to be sure that contaminated water coming from cities, businesses, and farms does not
hurt waterways such as wetlands, ponds, streams, and lakes, or harm groundwater quality. Industrial wastewater
cannot be discharged into a septic system. If you put anything but sanitary waste down the drain, you must abide by
the local sanitary sewer ordinance.
Thresholds: Vary for each contaminant based on where it is going and what authority has control. It can be very
small, such as a couple parts per million.
Requires Permit? Yes, if your business dumps contaminated water into a waterway, onto the ground, or into the
street, a storm drain, or a ditch, you may have to obtain a permit, even if you treat the wastewater first. Some local
authorities also require a permit for discharges to the sanitary sewer. Under storm water regulations, even if you are
not required to have a storm water permit, you still may have to file a "no exposure certification."
Regulatory Reports? Yes, if your business is covered by the permit requirements. Monitoring may also be required.
Businesses required to have a storm water permit will also have to submit a storm water pollution prevention plan.
45
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Table 3: Major Categories of Environmental Regulations (cont'd.)
Type of Impact
Chemical spills to air, water, or land.
Examples: A chemical leaks into a storm
drain and contaminates a stream. A valve on
your refrigeration unit fails, releasing
ammonia gas to the air.
Applicable Law(s)
Comprehensive
Environmental Response,
Compensation, and
Liability Act (CERCLA)
Emergency Release
Notification under the
Emergency Planning and
Community Right-to-Know
Act (EPCRA)
Overview of Regulations1
Makes possible a national emergency response program for certain spills and accidental releases. If your
business releases certain chemicals, called "hazardous substances," you must notify the National Response
Center.
Thresholds: Amount of a substance released is more than or equal to its listed "Reportable Quantity," or "RQ."
These amounts vary by substance and can be as small as one pound.
Requires Permit? No.
Regulatory Reports? Yes, in follow up to reported releases.
Requires you to notify state and local emergency planning commissions immediately if your business has an
unplanned release of certain chemicals. In addition to the CERCLA hazardous substances mentioned just above,
it covers "extremely hazardous substances" that are listed in regulations put in place to carry out the Emergency
Planning and Community Right-to-KnowAct.
Thresholds: Amount of a substance released is more than or equal to its "Reportable Quantity" (RQ).
Requires Permit? No.
Regulatory Reports? Yes, in follow up to reported releases.
Emergency planning for chemicals stored
and used at your business site.
Example: Your business has hazardous
chemicals on-site that could pose a danger
to the local community if they spilled, were
released, or involved in a fire.
Telling the community and local
responders about chemicals stored and
used at your business site.
Example: Your business has hazardous
chemicals on-site that could pose a danger
to the local community if they spilled, were
released, or involved in a fire.
Telling the community and regulators
about chemicals released into the
environment as part of your normal
business operations.
Example: Your business has hazardous
chemicals on-site that could pose a danger
to the local community if they spilled, were
released, or involved in a fire.
Emergency Planning
under EPCRA
Hazardous Chemical
Reporting: Community
Right-to-Know under
EPCRA
Toxic Chemical Release
Reporting: Community
Right-to-Know under
EPCRA
Puts in place coordination and planning so that state and local government agencies can prepare for and respond
to hazardous chemical spills. If your business is covered by these requirements, you must notify state and local
planning commissions and assist these agencies with maintaining the local emergency plan, including providing
pertinent information.
Thresholds: If the amount of a listed substance kept on-site at your business is more than or equal to the listed
Threshold Planning Quantity (TPQ). then you must participate in local emergency planning as described above.
TPQ's vary by substance and can be as little as one pound.
Requires Permit? No.
Regulatory Reports? Notification of any changes at your facility that affect emergency planning.
Provides a way for the pubic to access information about hazardous chemicals that community businesses use,
store, or release to the environment. Requires you to submit copies of Material Safety Data Sheets for certain
hazardous chemicals you keep and use at your business, and to report how much of each you have.
Thresholds: For listed substance, the TPQ or 500 pounds, whichever is less; for all other OSHA hazardous
chemicals, 10,000 pounds.
Requires Permit? No.
Regulatory Reports? Yes, an annual chemical inventory report, called a "Tier 1" or "Tier 2" report is required.
Which report your business will have to file depends on local and state requirements.
For certain hazardous chemicals used by certain industries (as determined by SIC code), requires you to measure
or estimate the amount that came on your site during the year and what happened to it; such as, how much went
into your wastestream. You are exempt if your business does not have 10 or more full-time employees. This
information is made available to the public, such as on EPAs EnviroFacts web site.
Thresholds: You manufacture or process 25,000 pounds or otherwise use 10,000 pounds of a listed hazardous
substance at your site in a year. (Certain chemicals of special concern have lower thresholds, like mercury at 10
pounds, lead at 100 pounds, and polycyclic aromatic compounds at 100 pounds.)
Requires Permit? No.
Regulatory Reports? Yes, an annual Toxic Release Inventory (TRI) that identifies the amounts of toxic chemicals,
covered by the requirement, your business releases to the environment.
-------
Table 3: Major Categories of Environmental Regulations (cont'd.)
Type of Impact
Managing Chemical Risks.
Example: You have a process within your
business operations that could release a
dangerous amount of toxic chemicals to the
air if it malfunctioned.
Pesticides.
Examples: Your staff apply weed killers on
outdoor property, use pesticides to control
rodents or insects, or you hire a pesticide
applicator to do this.
Polychlorinated Biphenyls (PCBs).
Example: You have equipment that uses a
PCB-containing transformer as a
component; you have to replace PCB-
containing electrical ballasts in your lighting
fixtures.
Storage, management, and disposal of
petroleum products.
Examples: Your business has one or more
storage tanks for petroleum products such
as gasoline, diesel fuel, or heating oil. You
business drains used oil from motor
vehicles. Your business has potential to spill
petroleum products into a waterway.
Applicable Law(s)
Chemical Accident
Prevention under the
Clean Air Act
Federal Insecticide,
Fungicide and
RodenticideAct(FIFRA)
Polychlorinated Biphenyls
(PCBs) under the Toxic
Substances Control Act
(TSCA)
Underground storage
tank and used oil
regulations of RCRA.
EPAs Oil Pollution
Prevention Regulation,
part of CWA.
Overview of Regulations1
Requires you to evaluate certain processes of your business operations to determine if it could pose a danger to
your neighbors through an accidental chemical release. If so, you must undertake planning to prevent malfunctions
from occurring and to reduce the harm from a chemical release if it does occur.
Thresholds: The amount of a chemical in a process is equal to or more than its listed threshold.
Requires Permit? No.
Regulatory Report? Yes, requires initial submission of Risk Management Plan and registration form which
documents that your business has completed the hazard assessment, analysis, and planning necessary to prevent
and respond to accidental chemical releases from any process covered by the regulation. Also, requires updates
according to a schedule given in the regulation.
Governs the use and disposal of all pesticides to prevent harm to people and the environment. Requires that you
be sure that people using certain pesticides at your business are certified, and, if you are an agricultural business,
that you put in place an extensive Worker Protection program for employees who work with pesticides. (There are
many additional requirements if your business manufactures pesticides or creates plants that are genetically pest
resistant.)
Thresholds: Applies to any amount of restricted use pesticide, and certain other pesticides.
Requires Permit? Requires certification of persons who apply certain pesticides.
Regulatory Report? No.
Requires identification and extensive recordkeeping for PCB-containing items. Sets requirements for taking care of
these items on-site, moving them from one place to another, and where and how they may be treated or disposed.
Thresholds: Applies to certain PCB-containing material (depends on whether PCB concentration of the source of
contamination was 50 ppm or greater).
Requires Permit? Yes, if your business treats or disposes of PCB-containing wastes.
Regulatory Report? Yes, requires submission of annual report if you use or store greater than 45 kg at one time.
Reporting requirements are identified in 40 CFR 761.180.
Applies to petroleum products stored and used such as vehicle fuel, heating oil, and motor oil. Underground
petroleum storage tanks must meet performance standards, the purpose of which is to prevent leaks into soil or
groundwater. (Underground storage tank systems containing other hazardous chemicals may also be regulated.)
Requires additional controls and management practices to detect, prevent, and respond to petroleum leaks or spills.
If your property becomes contaminated by a petroleum spill, there are specific clean up requirements that apply.
Thresholds: Your business is required to develop a Spill Prevention Control and Countermeasure Plan if your
business has a total on-site storage capacity of more than 1,320 gallons of petroleum products in aboveground
tanks and containers (containers less than 55 gallons in capacity are exempt) or has underground petroleum
storage capacity of greater than 42,000 gallons (completely buried tanks regulated under 40 CFR Parts 280 and
281 are exempt), and can reasonably be expected to discharge oil in harmful quantities into waters of the United
States.
Requires Permit? No.
Regulatory Report? Yes, in follow up to reportable releases.
47
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United States
Environmental Protection Agency
(1801)
Washington, DC 20460
Official Business
Penalty for Private Use $300
EPA233-K-02-001
September 2002
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