United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention
-------
Integrated
Environmental Management Systems
Implementation Guide
Design for the Environment Program
Economics, Exposure, and Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
For further information about DfE's Integrated Environmental Management Systems
Programs, please contact:
The Design for the Environment Program
Economics, Exposure, and Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue N.W. (MC 7406)
Washington, D.C. 20460
202-260-1678
www. epa. gov/dfe
To order additional copies of this Guide, please contact EPA's Pollution Prevention
Information Clearinghouse (PPIC) by phone (202-260-1023) or e-mail (ppic@epa.gov).
You may also download this Guide from the Design for the Environment website
(www.epa.gov/dfe).
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Acknowledgments
This Guide is part of an effort to show how Design for the Environment (DfE) technical
work can be used to support development of an Environmental Management System
(EMS). This Guide is based primarily on EMS reference documents acknowledged in
the references section, and on DfE guidance documents such as the Cleaner Technologies
Substitutes Assessment Methodology. The Guide was prepared by Abt Associates Inc.,
Cambridge, MA, with Jean E. (Libby) Parker as lead author. The Abt Associates project
team included Cheryl Keenan, Dennis Chang, Susan Altman, and Jonathan Greene.
The EPA Project Manager was Karen Chu, with the Design for the Environment Program
in the Economics, Exposure and Toxics Division, Office of Pollution Prevention and
Toxics. Bill Hanson is Director of the Design for the Environment Program. Important
contributions were made by Carol Hetfield, Heather Tansey, Ted Cochin, and Jenny
Fisher, EPA.
The Guide was developed in close collaboration with the Eastern Research Group, Inc.
(ERG), Lexington, MA. The ERG project team included Jeff Cantin, Dave Galbraith, and
Owen Davis. We would also like to acknowledge the important contributions of the
University of Tennessee's Knoxville Center for Clean Products and Clean Technologies
and Tellus Institute. The University of Tennessee project team included Lori Kincaid,
Mary Swanson, and Kerry Kelly. Karen Shapiro at Tellus Institute helped develop the
cost comparison section and provided Appendix F. EPA's Pollution Prevention
Division's Environmental Accounting Project provided funding to Tellus for this
contribution.
Valuable insights also were provided by Marci Kinter and Dan Marx of the
Screenprinting & Graphic Imaging Association International (SGIA), Fairfax, VA, and
by Foster Knight and Bob Ferrone of The Lexington Group, Lexington, MA. Useful
comments were received from William T. Engel, Jr. of the Strategic Environmental
Management Institute at the University of Florida's Center for Training, Research and
Education for Environmental Occupations (UF/TREEO), Gainesville, FL.
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Contents
Foreword i
DfE Program Principles iii
Figure A: DfE Substitutes Tree iv
Figure B: Pollution Prevention Hierarchy iv
How to Use This Guide v
Figure C: IEMS Process viii
Figure D. Road Map between ISO 14001 and IEMS ix
MODULE 1: LAYING THE GROUNDWORK page 1
Figure 1-a. The Continuous Improvement Cycle page 2
Figure 1-b. Functions to Include in Your IEMS Team page 7
Figure 1-c. Examples of Environmental Aspects and Associated Impacts page 12
Figure 1-d. How an Activity Becomes an Impact page 12
Figure 1-e. Generic Process Map for Business Activities page 14
Figure 1-f. Product X—Extended Responsibility page 15
Figure 1-g. Input-Output Diagram for a Step in a Manufacturing Operation page 16
Figure 1-h. Input-Output Diagram for a Copier page 16
Figure 1-i. Input-Output Diagram for Cleaning a Printing Press page 17
Figure 1-j. Inputs and Outputs of a Company's Products and Services page 18
MODULE 2: CREATING AN ENVIRONMENTAL POLICY page 23
MODULE 3: DETERMINING SIGNIFICANT ENVIRONMENTAL ASPECTS AND SETTING
OBJECTIVES page 35
Figure 3-a: Ranking Symbols page 38
Figure 3-b: Information on an MSDS page 41
Figure 3-c: Screen Printing Exposure Pathways page 46
Figure 3-d: Dry Cleaning Exposure Pathways page 47
MODULE 4: EVALUATING ALTERNATIVES page 62
MODULE 5: SETTING TARGETS AND MEASURING SUCCESS page 88
Figure 5-a. Root Cause Diagram page 92
MODULE 6: DEVELOPING OPERATIONAL CONTROLS page 94
MODULE 7: IMPLEMENTING YOUR IEMS page 106
Figure 7-a. Sample Environmental Management Project Plan page 107
Figure 7-b. Sample Environmental Management Project Plan page 108
MODULE 8: BUILDING ORGANIZATIONAL SUPPORT page 113
Figure 8-a. Documentation Levels page 119
Figure 8-b. Levels of stakeholder interest page 125
MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT page 132
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APPENDICES
APPENDIX A: GLOSSARY 142
APPENDIX B: SAMPLE QUESTIONS TO ASK YOUR SUPPLIER 146
APPENDIX C: EXAMPLE PERFORMANCE EVALUATION WORKSHEETS 148
APPENDIX D: EXAMPLE ALTERNATIVES EVALUATION WORKSHEET 153
APPENDIX E: ALTERNATIVES EVALUATION SAMPLE WORKSHEETS 160
APPENDIX F: HOW TO EVALUATE COSTS AND SAVINGS OF ALTERNATIVES 182
APPENDIX G: REFERENCES AND RESOURCES 195
APPENDIX H: BLANK WORKSHEETS 202
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Foreword
EPA's Design for the Environment (DfE) Program has over eight years of experience
building voluntary partnerships with industry, public interest groups, universities,
research institutions, and other government agencies to develop cleaner, safer alternatives
to existing products and processes and to manage change in the systems businesses use to
address environmental concerns. The DfE Program has developed technical
methodologies that provide businesses with environmental, economic, and performance
information on traditional and alternative manufacturing methods and technologies.
These approaches help businesses integrate environmental concerns into their daily
business activities so they can reduce cross media impacts, use energy and other
resources efficiently, better manage the risk associated with using hazardous chemicals,
practice product and process responsibility, and integrate environmental and worker
safety and health requirements. In addition, DfE has gained valuable experience in
communicating with a wide variety of people with varying degrees of technical
knowledge, and in establishing and maintaining diverse stakeholder groups. The DfE
Program is offering this experience to support the development of Integrated
Environmental Management Systems in companies
Tip
Words or phrases in bold "type are defined in the Glossary (Appendix A).
Tip
The IEMS process described in this Guide will help you develop a results-oriented EMS, but it may
not include all steps or core elements necessary for ISO certification.
An Environmental Management System (EMS) is a set of management tools and
principles designed to guide the allocation of resources, assignment of responsibilities
and ongoing evaluation of practices, procedures, and processes that a company needs to
integrate environmental concerns into its daily business practices. The EMS developed
and outlined by the International Standards Organization (ISO) in their standard
ISO14001 is one such example. The ISO 14001 EMS provides a widely recognized set
of principles and standards for integrating environmental management into quality
control and other business activities. Although the principles discussed in this document
can apply to any EMS based on a plan-do-check-act approach, this document uses
ISO 14001 as a starting point. In addition to administrative procedures, steps to
implement an EMS involve some technical work, such as identifying and prioritizing
environmental concerns, evaluating options for addressing those concerns, and measuring
the success of implementing those options. The ISO 14001 standard does not specify how
to carry out the technical work.
-------
Tip
An Environmental Management System provides a systematic way to review and improve operations
for better environmental performance and improved profitability, by setting up procedures that
ensure the work gets done. An EMS requires both administrative and technical work.
The DfE Program's approach to creating an EMS provides the DfE Program's technical
methods to carry out the technical work of developing the EMS. The technical methods
to integrate cleaner technology business methods with the management methods required
for an EMS are presented in the DfE Program's Integrated Environmental Management
System (IEMS). This approach emphasizes reducing risk to humans and the
environment, pollution prevention, and wise resource management. The DfE Program
principles follow this section. Those elements of the EMS that require strictly
management or administrative expertise will be presented so as to demonstrate how the
management and technical elements fit together. More detail on the management
elements will be found in other referenced sources. This Guide takes you and your
company through the IEMS creation process, step by step.
Tip
- There are many types of organizations that could make use of this Guide.
> A company could use it to develop an IEMS.
- A trade association could customize it and develop a sector-based approach to provide
training for their members.
> A large company could use it to green their supply chain and their customer chain.
> Federal facilities can use it to fulfill requirements in the Executive Order: Greening of the
Government Through Leadership in Environmental Management.
> Other government facilities could use it to comply with environmental regulations and to be
more environmentally proactive.
In January 1999, the DfE Program teamed with the Screenprinting and Graphic Imaging
Association International (SGIA) to conduct a pilot project with seven screenprinting
companies who wanted to develop lEMSs. The pilot project was designed to enable both
the DfE Program and SGIA to further develop these training materials. This Guide has
undergone major revisions, and the Company Manual Template was developed in
response to lessons learned during the pilot project.
n
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DfE Program Principles
A goal of the DfE Program is to create healthier environments for workers, communities,
and the ecosystem. The DfE Program accomplishes this goal by promoting system
change in the way a company manages environmental concerns. The DfE Program
principles and approaches are useful in meeting regulatory requirements and augmenting
environmental protection beyond compliance. Using the DfE Program's approach can
help a company integrate environmental protection by:
> managing the risk associated with using regulated and unregulated hazardous
chemicals,
»• considering cross-media impacts of activities and products,
»• using energy and other resources efficiently,
> practicing extended product and process responsibility, and
> integrating environmental and health & safety requirements.
Approach
The DfE approach to creating an IEMS has six main steps:
Identify and compare alternatives to evaluate trade-offs and information gaps.
Use the DfE Substitutes Tree outline (see Figure A) to evaluate alternatives.
Use the Pollution Prevention Hierarchy (Figure B) to evaluate and rank
approaches.
Integrate environmental considerations into daily business decision making that
includes performance and cost to provide environmental solutions that promote
competitiveness.
Recognize need for a commitment to continuous improvement.
Work in partnership with stakeholders; engage participation and support of
employees; encourage open communication.
in
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Figure A: DfE Substitutes Tree
Alternatives to Accomplish Function
Alternative Chemicals
Options
r O p t i o n 1
Environ-
mental
Issue
Describe
Function
kO p t i o n 2 ^S,,
• Alternative Processes ^Options
Alternative Technologies
Alternative Work Practices
Evaluation
Evaluate
Environmental
Effects,
Performance,
Costs
Figure B: Pollution Prevention Hierarchy
SOURCE REDUCTION
Substitutes
Process Change
Management Work Practices
Recycle/Reuse
Control
Technology
IV
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How to Use This Guide
This Guide has been designed to help companies integrate environmental concerns into
business decision making using the DfE Program's Integrated Environmental
Management System (IEMS). This Guide follows the guidelines of ISO 14001, an
international standard for EMSs, and it is designed to help businesses set up and
implement a simple, straightforward EMS. This Guide does not intend to give guidance
forISO14001 certification.
This Guide is laid out in nine modules designed to be completed through group
discussions with your IEMS team members and other managers and employees as
appropriate. Most modules can be completed in several hours, but some may take longer.
Sessions may be held once a week, once every other week, or once a month until the job
is done. Use whatever time these modules require for your company. It is more
important to complete each module than to finish in any particular time frame. Most
companies find that it takes about a year to work through the EMS development process.
And it generally takes up to three years for the EMS to be fully understood and
implemented. Developing a company IEMS is a commitment to change, and change
takes time.
Tip
Every choice you and your employees make can affect the environment. Involving everyone helps
produce cost-effective long-term results.
Best results will be achieved by involving everyone in the company in some way. There
are two benefits to involving all employees: first, they will be more likely to take
ownership of managing environmental concerns; second, they often have valuable insight
into how improvements can be made.
Tip
You should not try to perfect each step on your first attempt. Many of the steps will need to be
revisited as you proceed with developing the IEMS.
You should consider regular sessions as suits your schedule to complete the work in each
module. You will need to appoint a responsible person and a committee to head the
development of your IEMS. The committee members could also meet regularly with
other employees to provide progress reports and solicit input. The importance of regular
communication and involvement cannot be overemphasized. Getting people to think
about environmental concerns in their daily work is as important a process as any step in
setting up your IEMS.
v
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Tip
A companion document, A Company Manual Template, contains sample procedures and formats to
help you document important components of your IEMS. Refer to this Guide frequently as you
develop your IEMS. This document is available on the DfF website (www.epa.gov/dfe). See
Appendix G for details about the Template.
Some of these modules will have to be revisited during the process. For example, it is
useful to develop a communication plan in the beginning, but you will need to add to it as
environmental concerns are identified and as other parts of the IEMS are developed.
Some modules may not be completed at the outset, but may be revised as needed
throughout the process.
Finally, you don't need to do everything at once. This Guide will help you identify
possible projects and then help you prioritize these projects, given your resources and
time. You may, for example, want to start out by developing the IEMS for only one part
of your company or operation. You can expand later as your resources permit. It's
important to start small with projects that will achieve success, so that you and your
employees gain experience with the process and build confidence in your ability to make
changes.
What are the Steps in Developing an IEMS?
Each module in this Guide explains a step in the IEMS development process. The
modules contain worksheets to assist you in completing this work. Figure C is a flow
chart showing the steps in the process. Figure D is a "roadmap" showing how the IEMS
modules relate to the components of the ISO 14001 standard. The Appendices contain a
Glossary, example questions to ask your suppliers about chemical risk, an alternatives
evaluation worksheet and performance evaluation worksheet from the DfE Printing
Project, resources for more information, and blank forms that correspond to the
worksheets in each module. In addition to the Appendices, more tools and guidance can
be found on the DfE's website at www.epa.gov/dfe. In particular, there is a more
extensive Risk Guide and Cleaner Technology Substitutes Assessment Guide.
Module 1: Laying the Groundwork
This module provides a general discussion of what an IEMS contains. It will help you
build understanding of and support for your IEMS among your company's managers and
employees, about what an IEMS is and why the company is developing one. This
module also will help you understand how your company currently impacts the
environment by identifying environmental impacts of your company's products,
processes and services.
VI
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Module 2: Creating an Environmental Policy
An early step in the process of developing a IEMS is reviewing your company's current
methods for managing environmental concerns. Next you will write your company's
environmental policy statement and decide on the scope of your IEMS. The
environmental policy will be based on what is important to your company. This module
contains some sample principles and policy statements.
Module 3: Determining Significant Environmental Aspects and Setting
Objectives
You will need to determine which environmental aspects are significant, and prioritize
them to determine what you want to address first. This module provides a method to
estimate environmental risk to help you prioritize environmental aspects. The module
then helps you to translate those priorities into objectives to reduce environmental
impact.
Tip
Environmental aspects are elements of your business, such as air pollutants or hazardous waste,
that can have negative impacts on people and/or the environment.
VII
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Figure C: IEMS Process
Lay the Groundwork
Develop Process
Map and
Identify Aspects
Create Environmental
Policy Statement
GapsAnalysis
Review
and
Update
Determine Significant Aspects
Consider Environmental Risk
Set Objectives,
Determine Actions
Improve Current Activity
Change Current Activity
Evaluate Alternatives
Operational Controls
Set Targets and Project Measurement
Criteria
Implement the System
Establish
Environmental
Management Project
Continuous
Improvement^ - -
Establish Continuing Improvement
Establish
Program
Measurement
Criteria
Vlll
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Figure D: Road Map Between ISO 14001 and IEMS Approach
ISO14001 EMS COMPONENTS
Commitment and Policy
Planning
Implementation
Evaluation
Review
IEMS GUIDE MODULES
Module
Module
Module
Module
Setting
Module
Module
Module
Module
Module
Module
Module
Module
1: Laying the Groundwork
2: Creating an Environmental Policy
1: Laying the Groundwork
3: Determining Significant Environmental Aspects and
Objectives
4: Evaluating Alternatives
5: Setting Targets and Measuring Success
6: Developing Operational Controls
7: Implementing Your IEMS
8: Building Organizational Support
5: Setting Targets and Measuring Success
8: Building Organizational Support
9: Establishing Continuing Improvement
Module 4: Evaluating Alternatives
Before deciding how you will meet your objectives, it is important to consider a wide
array of approaches. This module shows how the IEMS methodology considers a
hierarchy of alternatives, which include substitutes, pollution prevention, and wise
resource management.
Module 5: Setting Targets and Measuring Success
For those significant environmental aspects where you have set an objective, you will
need to develop specific targets that describe how you will achieve your goal and you
need to develop ways of measuring that achievement.
Module 6: Developing Operational Controls
For some environmental aspects, you will need to write procedures to ensure that
activities are performed in a way that reduces environmental impact. This module lays
out how to develop operational controls, measure for success of those controls, and
provide corrective action when necessary.
Module 7: Implementing Your IEMS
Effective implementation is essential to getting your IEMS off to a good start. This
module helps you plan the IEMS development process and set up environmental
management projects for your objectives.
IX
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Module 8: Building Organizational Support
The long-term success of your IEMS will depend on solid organizational support. Such
support includes developing documentation, meeting training needs, and implementing
effective communication and stakeholder involvement processes.
Module 9: Establishing Continuing Improvement
To ensure success and continuing improvement, regular reviews of your overall IEMS
are needed. These reviews include progress made in communication, documentation and
developing stakeholders as well as the specific environmental targets. The reviews
provide critical information to ensure continuing improvement.
How much work each of the steps entails depends entirely on the scope of work that you
decide to undertake. It is not necessary for your IEMS to include all your operations,
especially for your first effort. As you gain experience in managing environmental
concerns along with your daily operations, you will develop your IEMS further.
x
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Module 1: Laying the Groundwork
This module contains an overview of Environmental Management Systems, suggestions
for how to build internal support for your IEMS, ideas for developing your IEMS
management team, and a process for understanding how your company impacts the
environment.
Overview of Environmental Management Systems
An Environmental Management System (EMS) provides a systematic way to review
and improve operations for better environmental performance. An EMS can help a
company better meet its compliance requirements. It can also help a company use
materials more efficiently and streamline operations, thereby reducing costs and
becoming more competitive.
Tip
An EMS is a framework for managing those significant environmental aspects you can control or
influence.
A commonly used framework for an EMS is the one developed by the International
Organization for Standardization (ISO) for the ISO 14001 standard. Although the EMS
described in this Guide is based on the ISO 14001 approach, the process outlined in this
Guide may not provide for meeting all the requirements of ISO 14001 certification. The
purpose of this Guide is not to give advice towards certification. It is to demonstrate a
technical means of integrating environmental concerns into company management so that
businesses can become more effective in reducing their impact on the environment.
Tip
Words in bold type can be found in the Glossary (Appendix A).
In addition, other guides on the market provide useful approaches. Developing an IEMS
based on this Guide does not imply endorsement by the U.S. EPA.
Tip
For more information on ISO 14001 EMS, check Appendix G (References and Resources).
The five main stages of an EMS, as defined by the ISO 14001 standard, are as follows.
> Commitment and policy — top management commits to environmental
improvement and establishes a company environmental policy.
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Planning — the company conducts a review of its operations, identifies legal
requirements and environmental concerns, establishes objectives, evaluates
alternatives, sets targets, and devises a plan for meeting those targets.
Implementation — the company follows through with the plan by establishing
responsibilities, training, communication, documentation, operating control
procedures, and an emergency plan to ensure that environmental targets are met.
Evaluation — the company monitors its operations to evaluate whether the targets
are being met, and, if not, takes corrective action.
Review — the EMS is modified to optimize its effectiveness. The review stage
creates a loop of continuous improvement for the company (Figure 1-a).
Tip
Continuously identifying and reducing risk leads to improved competitiveness and environmental
performance.
Figure 1-a. The Continuous Improvement Cycle
>
>
/Commitment^
^v and Policy )
Continuous
Improvement
( Evaluation j ~* MmplementationJ
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The advantage of adopting the DfE Program approach is that it enables your company to
consider and plan for managing the environmental risk of your company's products,
processes and services. The method outlined in this Guide will help your company
compare alternatives to identify the least cost, best performing and lowest environmental
impact option. This approach will help your company do the following:
»• practice pollution prevention,
> use resources efficiently,
»• avoid shifting problems from one waste stream to another,
»• understand the risks associated with using both regulated and unregulated
chemicals,
> integrate management of worker safety and health requirements with management
of environmental concerns,
»• practice extended product and process responsibility, and
> manage system change in addressing environmental concerns.
Screenprinters from the SGIA/EPA /EMS Pilot Project have this to say about what
they learned:
"That you can have a system to achieve environmental improvement. Never gave it much thought
before."
"Changed from being reactive to environmental regulations to being more proactive."
"The benefits of having documented operational controls."
"General environmental awareness building across the board; and that you can be bottom-line oriented
and environmentally conscious at the same time."
"That the ultimate benefit is improving the environment and improving the bottom line at the same time."
Thus, by using the approach provided in this Guide, you can develop a IEMS that helps
you continuously identify and reduce risks to people and the environment. This Guide
provides methods to help you consider risk reduction when answering the following
questions.
> How does your company impact the environment?
> Which of these environmental impacts are significant?
> How can your company improve its environmental performance?
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Building Support for Your EMS
Both management and employees need to understand not only what a IEMS is, but also
why they would want one. This step is designed to get people to think about and discuss
the ways in which a IEMS would benefit your company. Even though you may already
have management support, it is still important to get employee buy-in to this process.
Through years of working with companies, the DIE Program has learned the importance of building
support from participants through open and frequent discussion about mutual concerns.
Set up times to discuss your company's need for a IEMS with key managers and
employees. Recording the discussions provides important documentation, which can be
used to communicate the benefits of your IEMS to others. One way to record the
discussion is to assign someone the task of writing the group's comments on a flip chart,
so that everyone can see them for discussion. The following set of general questions will
lead you through the discussion.
Discussion Questions
1. Which environmental and worker safety laws and regulations is your company
required to follow?
2. How does your company define environmental performance?
3. Does lack of time or resources prevent your organization from taking charge of its
environmental obligations? Are there individuals appointed to be responsible for
this function?
4. What is your company's environmental policy?
5. Does your organization know how its environmental objectives relate to its
business objectives?1
To build support, consider the benefits a IEMS might provide for your company. A more
systematic approach to meeting your environmental and business goals might contribute
to the following in your company:
> improved environmental performance
> improved worker health and safety
> improved competitiveness
1 Adapted from: Environmental Management Systems: An Implementation
Guide for Small and Medium-Sized Organizations. Ann Arbor, MI: NSF
International, November 1996, p. 3.
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> improved compliance and reduced liability
> fewer accidents
> lower insurance premiums
> improved public image
> enhanced customer trust
> better access to capital
> improved internal communication
> improved company morale
»• reduced operating costs
Tip
To help get facility-wide buy-in to the IEMS process, find the workers who are most enthusiastic
with the process and recruit them to spread the word among their peers. Commitment from top
management is essential, but you also need promoters at all levels of your company.
It will be helpful at this point to create a worksheet comparing the expected costs and
benefits of developing a IEMS. Worksheet 1-1 provides some general categories of costs
and benefits. When making your comparison, provide specific examples from the
discussion.
Assigning Responsible Persons
Designate, as soon as possible, the Management Representative, the IEMS Coordinator,
and a Committee who will be responsible for promoting and developing your IEMS. If
you have a very small company, these may all be the same person! However, it is still
important to designate who will be responsible for various activities. Worksheet 1-2
provides a means to document the responsible persons. This worksheet can be placed in
your Company IEMS Manual (see the Company Manual Template}.
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Worksheet 1-1: Costs and Benefits of Developing and Implementing an IEMS2
Costs
«• Staff/employee time for:
collecting information
reading and understanding this Guide
preparing worksheets
facilitating IEMS sessions
participating in IEMS development
> Possible consulting assistance
> Training of personnel in new procedures
> Technical resources to analyze environmental
impacts and improvement options
«• Resources required to make changes
Contact Person:
Benefits
«• Improved environmental performance
> Expected increased efficiency /reduced cost of
materials
> New customers/markets
> Enhanced employee morale
> Expected savings in compliance and overall
compliance monitoring and assessment, and
record-keeping requirements due to changes in
materials used
> Reduced waste disposal/treatment costs
> Fewer regulatory requirements
Date completed:
Worksheet 1-2: IEMS Responsibilities
IEMS Function
Management Representative
IEMS Coordinator
IEMS Committee
Contact Person:
Person
Regular Position
Date Completed:
Corresponds to RESP-01 in the Company Manual Template.
In addition, Figure 1-b shows the job functions and skills that would make a strong
contribution to your IEMS team. Small companies might not have a person for each
function identified on the table. The list is provided to identify skills that would be
useful, not to suggest that a company would need all of these on a team.
2Ibid, p. 5.
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Figure 1-b. Functions to Include in Your I EMS Team
Company Function
Production
Maintenance
Facilities
Engineering
Storage/Inventory
Shipping,
Receiving,
Transportation,
Logistics
Product Design
Quality
Human Resources
EH&S
Purchasing
Sales/Marketing
Public Relations
Accounting/
Finance
Expertise Brought to Project Team
Management of environmental aspects of production
Management of environmental aspects of equipment
maintenance
Management of environmental aspects of new
construction and installation/ modification of
equipment
Management of environmental aspects of raw
material and product storage and in-facility
transportation
Management of environmental aspects of shipping,
receiving, and transportation
System for examining environmental aspects of new
designs
Quality management system, including document
control procedures
Training on environmental issues
Inclusion of environmental incentives in performance
measurement system
System for complying with environmental regulations
Management of environmental records
System for procurement (including screening of
suppliers, material composition of components)
Environment-related commitments to customers
System for communicating with public on
environmental issues
System for tracking environmental costs of
operations
Planning the Process
To effectively implement your IEMS, you will need to set up a plan for getting the work
done. This plan will be unique to your company. You will identify the steps to take, in
the appropriate order; the decisions that will need to be made; and the resources and
schedules for accomplishing the tasks. Start out by considering the following points as
you plan for your IEMS development:
Determine what level of management involvement is required and what decisions
will be needed from both middle and senior management.
Set a deadline for developing your IEMS and establish a schedule. (See worksheet
at the end of this module.)
Estimate a budget.
Determine how you will document your IEMS.
7
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If you have never developed an IEMS before, estimating resources and time can be
difficult. You will need to create a schedule and estimate resources for completing your
IEMS. As you begin to work on each module, you may want to identify intermediate
steps for which you will set target completion dates. At some points, you may need to
alter the overall schedule. Worksheet 1-3 will assist you in developing and tracking this
plan. As you go through each module, revisit this worksheet and list who is participating
in each task and your estimated budget and schedule. Also, Worksheet 1 -4 will help you
identify and document the persons responsible for different parts of the IEMS and the
resources needed to support their effort. You may not be able to completely fill out these
budget and resource worksheets at the beginning of this process. In addition, the items in
the worksheet blocks may change as you work your way through the IEMS process.
These worksheets only present ideas to get you started.
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Worksheet 1-3: IEMS Development Schedule and Resources Worksheet
Module
Laying the Groundwork: Identifying
Environmental Aspects
Intermediate steps: (As appropriate)
Making the Commitment: Creating a Policy
Statement and Determining the Scope
Intermediate steps: (As appropriate)
Determining Significant Environmental
Aspects and Setting Objectives
Intermediate steps: (As appropriate)
Setting Targets and Measuring Success
Intermediate steps: (As appropriate)
Developing Operational Controls
Intermediate steps: (As appropriate)
Evaluating Alternatives
Intermediate steps: (As appropriate)
Implementing Your IEMS
Intermediate steps: (As appropriate)
Setting Up Environmental Management
Projects
Intermediate steps: (As appropriate)
Establishing Continuing Improvement
Intermediate steps: (As appropriate)
Participants
Budget
Target Completion
Contact Person: Date Completed:
-------
Worksheet 1-4: Persons Responsible for IEMS Development
Roles
"Management representative" having
responsibility for implementing the IEMS
(in small businesses, this could be the
owner).
IEMS Coordinator
IEMS Team Participants
Identifying and determining significance
of environmental aspects.
Identifying and determining applicability
of legal and other requirements.
Competency-based training.
Operational controls.
Emergency preparedness and
response.
Monitoring and measurement of "key
characteristics" of operations and
activities that can have significant
environmental impacts (i.e., the
"significant environmental aspects.").
Periodic evaluations of environmental
compliance.
Handling and investigating non-
conformance with the EMS.
Records management.
Internal EMS audits.
Individual(s)
Responsible
Contact Person:
% of Time
Designated
Budget
Date Completed:
Note: Most of these blocks will be filled in as development of the IEMS progresses. This worksheet will
help track progress and serve to remind the team and management of necessary assignments.
Gathering Information and Identifying Environmental Aspects: Understanding
Your Company's Possible Impacts
The work in this step mostly involves gathering and organizing information about your
company's activities. Information gathering involves four activities:
> map your company's activities and processes,
»• identify inputs and outputs for each activity and process step,
10
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> identify the environmental aspects associated with each input and output, and
> identify regulatory and other requirements.
Each DIE project begins with a simple mapping exercise to identify possible environmental concerns.
Informed participants then select a priority concern that becomes the focus of the DIE project.
The process of identifying environmental aspects is best undertaken through group
discussion with all levels of production employees, office staff, and managers. This helps
to gain insight through different perspectives, and it engages everyone in the process of
understanding the environmental component of your daily activities.
An environmental aspect is an element of your company's activities, products, or
services that can affect the environment.
Tip
An environmental aspect is any element of your company's activities, products, and services that has
the potential to affect the environment.
Environmental impacts are the changes to the environment whether adverse or beneficial
that result from your company's activities, products or services. Most elements of your
business operations will have environmental aspects, intended or unintended.
For example, an unintended aspect of using a cleaning solvent may be that there are
volatile (airborne) emissions produced during use. The "impact" of these emissions may
be hazardous exposure to workers or the community or a contribution to smog formation.
Another example is the business activity of making paper copies. The toner cartridges
contain chemicals that could interact with the environment if they are not disposed of
properly. The used toner cartridges with chemical waste would be an environmental
aspect. The release of these chemicals into a land fill would be an environmental impact.
Figure 1 -c lists examples of environmental aspects and their potential impacts, and Figure
1-d graphically shows the relationship between activities, aspects, and impacts.
11
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Figure 1-c. Examples of Environmental Aspects and Associated Impacts
Environmental Aspects
Metals discharged to
POTW
VOC emissions
Scrap generation
Solid waste generation
Fresh water use
Electricity use
Exposure to chemicals
during business activities
Potential IMPACTS of Each Aspect
Contamination of aquatic habitat and drinking
water supply
Contribution to smog; worker or community
exposure to volatile organic compounds
(VOCs)
Degradation of land, habitat, water supply
Habitat destruction, drinking water
contamination from landfills, wasted land
resources
Depletion of natural resources
Contribution to global warming; degradation of
air quality by electric generating plants
Harm to health of workers, neighbors, wildlife or
plant life
Figure 1-d. How an Activity Becomes an Impact
Activity
Using a paper copier
Environmental
Aspect
Used toner cartridges
Environmental
Impact
Discarding toner
cartridges in trash
can release
chemicals to landfills
Step 1: Develop a Process Map of Your Company's Activities and
Processes
The first step in identifying environmental aspects of your business is to develop a map
of your company's processes, products and services. First, categorize your business
activities into areas or steps in the process, so that you can review them one by one.
Some typical areas to consider might include:
> Receiving Raw Materials
> Storing Raw Materials
12
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> Manufacturing Process, Step 1
> Manufacturing Process, Step 2
»• Manufacturing Process, Step 3
»• Packaging
> Process Clean-up
> Waste Disposal
» Office
> Building Maintenance
»• Shipping Product
»• Transportation (including employee, sales, and management staff, parking)
> Optional: map customer and supplier activities and processes that directly relate to
your company's activities, products and processes
Internet Help
Visit the DfF website for more tools related to process mapping.
www.epa.gov/dfe
Tip
These technical sections are best developed through group discussions. There is no "right" way to
build these lists. The process, however, must make sense to you and be documented so that you can
review it or change it later.
Use this list of areas to develop a process map describing the order in which activities
take place in your company. Some areas may need their own map; others could be parts
of a larger map. Figure 1-e shows a generic process map of a manufacturing company
that might help you to set up your own map. Worksheets EA-01 a and EA-Olb in the
Company Manual Template also provide a way to document your company's operations.
13
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Figure 1-e. Generic Process Map for Business Activities
Office Operations
Word Processing
Copying
Drafting
Producing Your Product
Receiving
Raw
Material
»
Storing
Raw
Material
*
Manufacturing
Process,
Stepl
Manufacturing
Process,
Step 2
Manufacturing
Process,
Step 3
Building Maintenance
Lighting
Cleaning
Heating and Air Conditioning
Auxiliary Services (e.g., boilers,
compressors, electrical transformers)
Products
Product X
Product Y
Product Z
Services
Service A
Service B
Service C
14
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You will notice that two areas of activities, office operations and building maintenance,
have boxes that are separate rather than being part of a sequence. This is because the
activities identified under these areas are not related sequentially. Under the area
"Producing Your Product," the activities are connected in steps required to produce a
product or service. This order will be important to understand later if you decide to work
on an aspect that is part of a sequence of steps.
Tip
Appendix H contains full-page versions of the blank worksheets.
In addition to the process steps laid out in your map, you should consider the
environmental aspects of your products and services. For example, does your product or
its packaging have potential impacts on the environment? If so, there may be
opportunities to form partnerships with customers to work on making changes that reduce
the impact. As shown in Figure 1-f, many companies are extending their responsibility to
consider the upstream impacts of their materials choices and the downstream impacts of
consumer use and disposal of products.
Figure 1-f. Product X—Extended Responsibility
•! P|ant Bl •!
Step 2: Identify the Inputs and Outputs of Each Activity
The next step in identifying environmental aspects is to identify the inputs and outputs of
each box in the process map you developed in Step 1. Among those inputs and outputs
will be some that have environmental effects. Figure 1-g shows a generic step in a
manufacturing process. Figure 1-h illustrates this concept with an example of a business
activity (paper copying) that is an office activity rather than part of an operational
sequence. The second example, shown in Figure 1-i, shows the process step of press
cleaning in printing operations at ABC company. Figure 1-j shows graphically the
general inputs and outputs of a company's products and services.
15
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Figure 1-g. Input-Output Diagram for a Step in a Manufacturing Operation
Additional inputs (e.g., energy)
I
Product
Input
MAKE
PRODUCT
Product
Output
Non-product outputs (e.g., wastes)
Figure 1-h. Input-Output Diagram for a Copier
Original
Document
Toner Paper Energy
v v
COPY
DOCUMENT
T T T
Spent Waste Noise
toner paper
cartridges from
mis-copies
16
Copy of
Document
-------
Figure 1-i. Input-Output Diagram for Cleaning a Printing Press
Press
Cleaner
Clean Shop
Towels
Inked
Press
CLEAN
PRESS
Clean
Press
Soiled Waste
Shop Chemicals
Towels
17
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Figure 1-j. Inputs and Outputs of a Company's Products and Services
Energy Materials
*
Chemicals -^
Packaging -^
PRODUCT
t
Waste
Use and
fc disposal
by
consumer
Energy
Materials
Activities
SERVICE
Use by
consumer
Waste
Step 3: Identify Environmental Aspects of Each Activity
Next you will identify environmental aspects associated with each input and output.
Using your process map developed in Step 2, identify the environmental aspect of each
input and output. Keep the following key points in mind when identifying the
environmental aspect of a particular activity.
Can it interact (beneficially or harmfully) with anything in the environment?
Can it be toxic or hazardous to humans or anything in the environment?
Does it use natural resources?
How is it disposed of?
If a product, how will it be used and disposed of by the consumer?
Use Worksheet 1 -5 to help you list each process step and its associated environmental
aspect. Appendix H contains a blank copy for your use.
18
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Worksheet 1-5:* Identifying Environmental Aspects
Input/Output
Environmental Aspect
(Quantify if available)
Environmental Impact
Office Activities
Paper (In)
Energy & fuel (In)
Toner (In)
Documents (In)
Waste paper (Out)
Used Toner (Out)
Odors (Out)
Use of paper
Use of energy
Harmful chemicals
Solid waste
Solid waste
Solid and chemical waste
Production of odors
Use of natural resources
Use of natural resources; air quality
degradation
Health and environmental effects**
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Indoor air quality
Manufacturing Process
Press cleaner (acetone,
toluene, MEK, isopropyl
alcohol blend) (In)
Wipers (In)
Energy & fuel (In)
Soiled wipers (Out)
Waste chemicals (Out)
Air releases of press
cleaner (Out)
Chemicals that are toxic to humans
or the environment
Materials that are toxic to humans or
the environment
Use of energy
Production of hazardous waste, solid
waste
Production of hazardous waste, solid
waste
Production of air pollutants
Health and environmental effects*
Health and environmental effects*
Use of natural resources; air quality
degradation
Degradation of land, habitat, drinking
water*
Degradation of land, habitat, drinking
water*
Degradation of air quality*
Products and Services
Product X:
Chemicals
Materials
Packaging
Waste
Energy use
Service X:
Chemicals used
Waste products
Energy use
Chemicals that are toxic to humans
or the environment
Materials that are toxic to humans or
the environment
Production of hazardous waste, solid
waste
Production of hazardous waste, solid
waste
Use of energy
Chemicals that are toxic to humans
or the environment
Production of hazardous waste, solid
waste
Use of energy
Contact Person:
Health and environmental effects*
Health and environmental effects*
Degradation of land, habitat, drinking
water
Degradation of land, habitat, drinking
water
Use of natural resources; air quality
degradation
Health and environmental effects*
Degradation of land, habitat, drinking
water
Use of natural resources; air quality
degradation
Date Completed:
*Use the blank form
Manual Template. *
in Appendix H for your data, then use the information to fill in EA-02 in the Company
* See Module 3 for information on chemical effects.
19
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Step 4: Identify your legal and other requirements
The last step in identifying environmental aspects is to identify
environmental legislative and regulatory requirements that pertain to your business
activities, products, and services. Regulated concerns that apply to your business should
be included in your system of environmental programs because your IEMS will integrate
all of your company's efforts to manage environmental concerns.
Tip
It is helpful to begin identifying regulatory requirements by making a list of those regulations that
you know affect your company. Searching for additional information can take time. Any newfound
regulatory requirements can be added into your IEMS at a later date.
State and local legal requirements, in addition to federal, need to be considered. Often
states administer federal environmental and occupational safety and health regulatory
programs and may have stricter and/or different requirements than federal regulations.
You can obtain information on regulatory requirements from a variety of sources. State
or city departments of environmental protection might be able to assist you in finding this
kind of information. For example, state technical assistance programs are often excellent
resources and often can provide one-on-one consultation. In addition, public information
offices of both the Environmental Protection Agency (EPA) and the Occupational Health
and Safety Administration (OSHA) of the Department of Labor (DOL) can help provide
publications that explain regulations pertinent to your company's activities. Publications
by the DfE Program at EPA and EPA's Office of Enforcement and Compliance
Assurance (OECA) also identify federal regulations affecting certain industries.
Appendix G gives full citations of the DfE publications, addresses for some resources,
and describes how to obtain them. You can also visit the DfE Web site at
www.epa.gov/dfe. Regulatory information is also available at the websites of many
agencies.
Tip
Even regulations that may not directly apply to your business may contain important information
about the environmental impacts associated with your type of business.
Worksheet 1-6 will help you organize your search of regulations that affect your
business. In many cases, very small businesses are exempt from some regulations. Still,
the problems addressed by the regulations may affect your business and may be concerns
you would want to address in your IEMS. Thus, it is worthwhile to familiarize yourself
with regulations, just to identify concerns and determine whether any of them apply to
your operations. Use Worksheet 1-6 to keep track of regulations that apply to your
business.
20
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Worksheet 1-6*: Regulations
Regulatory
Agencies
Regulations
That Apply
to My
Business
Sector
Contact Person:
Business
Operations
Potentially
Affected
Date Completed:
Does it Apply to
My Business?
"Corresponds to Table LR-01 in Company Manual Template.
In addition to regulations, industry codes of practice and other non regulatory guidelines
can help point to environmental aspects of your business activities. Your trade
association also may be able to help identify useful publications.
The following case study shows how "Company A" set up a process for creating an
environmental management system and some of the benefits of doing so.
21
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Case Study: Company A
EMS Development
Company A is a 20-person manufacturer of large custom metal machine
parts for industrial customers. To initiate its EMS, the company
formed a small EMS implementation team that includes the managers of
quality, purchasing, and human resources and is led by the owner's
son. This team developed the environmental policy for review and
approval by the owner, and, equally important, set up a structure for
involving all employees in the EMS process. Employees receive general
environmental awareness training during some of the company-wide
Friday meetings, and have been involved in identifying environmental
problems and solutions in their areas of responsibility.
Company A's comprehensive approach to environmental management yielded
immediate results. After identifying oil usage as a significant
environmental aspect, a team of workers and managers identified faulty
gaskets as the primary cause of oil leaking from the machines. By
replacing these gaskets, the company cut its oil use by 50%. This
change, as well as more general improvements in work environment and
worker safety, caused the local environmental enforcement agency to
reclassify Company A as a non-hazardous waste generator (it had been
classified as a hazardous waste generator). The company also reports
significant improvements in the environmental awareness of management
and workers; though less tangible, this change in attitude may prove
equally significant over the long run.
22
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Module 2: Creating an Environmental Policy
This module will help you review your company's current methods for managing
environmental concerns, develop an environmental policy for your company, and
determine the scope of your IEMS. Sample environmental policy statements are
presented at the end of the module.
Tip
Your discussion should be comprehensive and detailed enough to give you some idea of what will
need to be done to develop an IEMS for your company.
Understand How Your Company Currently Manages Environmental Concerns
This step is designed to help you review how your company currently handles
environmental and human health concerns and compares current practice with where you
would like to be. In some references, this is called a "gaps analysis" because it is
designed to uncover ways to improve your management of these concerns. This step is
best developed through discussions with groups of employees representing different
functions in your company, especially line managers and line workers. You'll need to
involve people that have the day-to-day working knowledge of your company's
operations. It is important for everyone to understand what the IEMS involves and why it
is being implemented. In this way, they can then explore alternatives to your current
practices, so as to improve both environmental management and cost savings for your
company. It will be helpful to keep a list of answers for future reference.
Principles that can be a part of your environmental policy include a commitment to risk reduction, pollution
prevention, and wise resource management. You can best follow these principles by committing to consider an
array of alternatives before determining a course of action.
Tip
The environmental policy is the foundation of the company's IEMS. Through it, top management
should communicate goals such as preventing pollution and minimizing risk to workers and the
environment.
Discussion Questions
*1 . Does your company have an Environmental, Health & Safety Policy?
> Is this policy written down?
> Where is it located?
> How many employees know about this policy?
> How did they learn of it? Is it included in a training or orientation program?
23
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> Do employees have the opportunity to make suggestions regarding environmental
concerns?
»• What points are included in this policy?
Tip
Remember to consider worker health and safety, as well as people outside your plant, when
evaluating known health concerns.
2. Does your company have specific environmental or health & safety goals?
> Are these documented?
»• How are these communicated to employees?
> Is there a way of tracking whether goals are met?
> Are there penalties within the company for not achieving the objectives?
> Is there a way to change these goals when changes in processes, production, or
activities occur? How are these changes communicated?
Tip
The EPA National Enforcement Investigations Center (NEIC) has recognized the way in which an
EMS improves a company's compliance record by providing a guidance document for developing a
"compliance-focused" EMS. (See Appendix & for more information.)
3. Does your company have a process to identify all environmental, health & safety
regulatory requirements?
> Has your company conducted compliance audits?
> Has your company received any fines or penalties requiring corrective action?
»• Has your company experienced difficulties in complying with regulations?
> Are some regulations difficult/costly to meet?
»• Does your company know whom to contact at local, state, and federal regulatory
agencies in the event of environmental accidents or compliance concerns?
»• Does your company have a mechanism for staying up to date on changing
regulations?
4. How does your company evaluate risk to human health & safety and the
environment caused by your business operations? How is this information
incorporated into planning for business activities/production?
5. Is there a process within the company to review any changes in products or
processes with an eye toward environmental concerns?
6. Are there policies and procedures regarding procurement and contracting that
consider environmental concerns?
24
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Tip
Reviewing -these questions in six months and, again, in one year provides a good way to track
progress in developing your IEMS.
"7. What training is offered at your company that would support environmental
objectives?
> Do employees receive environmental, health & safety training? What percent of
employees? Which ones?
»• How is that training documented? Where are the records kept?
»• Is there provision for regular training on environmental, health & safety
requirements?
S. Does your company have a procedure for responding to suggestions regarding
environmental concerns that it may receive from customers, neighbors, or
employees?
> Is there a process for soliciting and recording any "suggestions"? Where are these
records kept?
»• Is there a process for following up on any of these suggestions to be sure that
appropriate action was taken?
Tip
As you discuss these questions, it will be beneficial to write down the answers for reference as you
proceed with the following modules.
9. How does your company keep track of its documents?
> Is there a filing system?
> How many people are familiar with the system?
> How many people have access to it?
> How could someone find information relating to environmental, health & safety
concerns? Are there Material Safety Data Sheets (MSDS) available? Does your
company have documented standard operating procedures for plant operations,
emergencies, or document control?
> How are decisions made about when to dispose of documents?
Tip
You should review this policy statement as you complete the modules following this one to
determine whether changes need to be made.
*1 O. How does your company identify potential accidents or emergency situations?
> Are emergency procedures documented?
> How do employees find out about them? Is there regular training?
> Are these procedures periodically tested, evaluated, and revised as needed?
25
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»• Have there been failures in response to accidents or emergency situations?
> Is there a communications plan in place in the event of emergencies?
*1 *1 . Does your company have a way of measuring the environmental effects of any of
its operations?
> Are there records kept?
> How long?
> Are these records reviewed regularly with an eye to whether performance has
improved or worsened?
*1 2. How does your company track its environmental costs?
> Does your company track environmental costs such as on- and off-site waste
handling and treatment?
»• Does your company track regulatory compliance costs such as labor costs for
labeling, manifesting waste and/or permitting, and record keeping?
> When purchasing materials and supplies, does your company consider things like
handling costs, OSHA training, and shelf life?
> Are the above costs allocated to overhead accounts or traced to products or
activities?
Internet Help
Visit the DfF website for more tools related to gaps analysis:
www/epa.go v/dfe
Environmental Policy Statements
An environmental policy is your declaration of commitment to the environment and
worker health and safety. This policy serves as the foundation for your IEMS, and
provides a unifying vision of environmental principles that will guide the actions of
employees and management. This policy statement serves as the framework for setting
environmental objectives and targets, and will be brought to life in your plans and
business activities. Consider the scope of your environmental policy statement for that
will also determine the scope of your IEMS.
26
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Refine Your List of Issues
Review the environmental aspects identified in Module 1. Make a list of general
environmental concerns that could be addressed in your company's environmental policy
statement.
Set Your Boundaries
Think also about the scope of your policy. Decide whether it will include activities
beyond internal operations, such as supplier environmental performance or customer
product use. Remember to consider the company's property beyond plant walls up to the
"fenceline." Consider how to include contractors working at your site, and consider
companies you use for outsourcing. You will want to drop issues from your list that do
not fall within the boundaries set for your policy statement. As you begin your IEMS,
you may want to define your boundaries within the company. As you gain experience,
you may choose to expand the scope of your IEMS to include environmental issues
important to your customers and suppliers.
Draft Your Environmental Policy Statement In General Terms
Address your list of specific issues in general terms in your policy statement. For
example, if chemicals in your water or air are a concern because they potentially impact
the community, you could express a commitment to review and, where feasible, make
changes in the chemicals used by your company, or make sure you are managing them
appropriately. Or, if solid waste in landfills is a concern in your area or to your company,
you could express a commitment to reduce the solid waste your company produces.
Next, think about how to put commitments into action. For example, your commitment
to reduce solid waste may be achieved through a pollution prevention program and/or a
program to design products or services that result in minimal waste generated by the
consumer. Also, these programs may be implemented one at a time over a several-year
period, as part of your commitment to continuing improvement.
Sample Policy Commitments
It is important to think through which commitments your company will be capable of
addressing. Do not include commitments in your policy that the company will not be
able to carry out. The following is a checklist of commitments or principles that you may
wish to consider including in your policy statement:
> Comply with applicable environmental or worker safety laws/regulations.
> Work to achieve pollution prevention.
> Prevent accidents.
27
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Identify opportunities for risk reduction associated with the processes and
chemicals used in your plant, the supplies procured, the products produced, and
the disposal of waste products.
Consider the life cycle (from raw materials extraction and processing to use and
eventual disposal) of products produced, including packaging, so as to affect how
suppliers and end users impact the environment through your products.
Continue improvement in your use of cleaner technologies and processes, and in
the safer use of chemicals.
Practice wise resource management, including conservation of limited resources
and reuse and recycling of materials.
Consider which goals of industry or your trade association could be adopted for
your environmental policy statement.
Resource
Review the Company Manual Template for examples of how to document your policy.
Make sure top management commits to the environmental policy statement. If possible,
the company president should sign and date it. The final environmental policy statement
should be posted or distributed to employees and other interested parties.
Examples
The following are sample environmental policy statements that in some way incorporate
most of the principles listed above.
28
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YOUR COMPANY (ABC)
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
This is a sample policy. Adapt for your company.
ABC Company is committed to managing health, safety and environmental
(HS&E) matters as an integral part of our business. In particular, it
is our policy to assure the HS&E integrity of our processes and
facilities at all times and at all places. We will do so by adhering
to the following principles:
COMPLIANCE
We will comply with applicable laws and regulations and will implement
programs and procedures to assure compliance. Compliance with HS&E
standards will be a key ingredient in the training, performance
reviews, and incentives of all employees.
RISK REDUCTION, PREVENTION, RESOURCE MANAGEMENT
We will seek opportunities, beyond regulatory compliance requirements,
for reducing risk to human health and the environment, and we will
establish and meet our own HS&E quality standards where appropriate.
We will employ management systems and procedures specifically designed
to prevent activities and / or conditions that pose a threat to human
health, safety, or the environment. We will look for ways to minimize
risk and protect our employees and the communities in which we operate
by employing clean technology, including safe technologies and
operating procedures, as well as being prepared for emergencies.
We will strive to minimize releases to the air, land, or water through
use of cleaner technologies and the safer use of chemicals. We will
minimize the amount and toxicity of waste generated and will ensure
the safe treatment and disposal of waste.
We will manage scarce resources, such as water, energy, land, forests,
in an environmentally sensitive manner.
COMMUNICATION
We will communicate our commitment to HS&E quality and to our
company's environmental performance to our employees, vendors, and
customers. We will solicit their input in meeting our HS&E goals and
in turn will offer assistance to meet their goals.
CONTINUOUS IMPROVEMENT
We will measure our progress as best we can. We will review our
progress at least on an annual basis. We will continuously seek
opportunities to improve our adherence to these principles and to
improving our environmental performance, and we will periodically
report progress to our stakeholders.
{Signature} President Date
Adapted from: Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations. Ann Arbor, MI: NSF International, November 1996,
p.3.
29
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SAMPLE POLICY
This is the environmental policy of a small environmental services company specializing in wastewater
treatment and laboratory analysis of effluent. The policy should be signed by the company's President.
We supply quality products and services. This requires the commitment
of everyone working in this institution to pursue our activities
safely, protecting our health and preserving the environment.
To realize this vision we will:
• Establish and review periodically our environmental goals within a
program of continual improvement.
• Comply with legal requirements pertinent to our industry and with
the requirements of other initiatives we enter into in accordance
with our commitment to offer quality products and services.
• Conduct laboratory analyses and supply environmental services
without risk to workers' health.
• Operate the laboratory with a minimum of waste, in current and
future operations.
• Pursue our work with a minimum of disturbance to our neighbors and
the community.
• Maintain our vehicles in optimal condition to minimize their
consumption of fuel and their emissions to the atmosphere.
• Manage our chemical products safely, principally to prevent spills
in their storage and transport.
This policy and any subsequent modifications should be familiar to all
employees and available to the public. Implementation of this policy
is a primary objective of the President and the responsibility of all
employees.
{Signature} President Date
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CASE STUDY: COPY PLUS SERVICES
Sam Worth, owner of a copy center business, was attending a conference
on issues affecting small businesses. The conference was the first of
this type that Sam had attended. His business, Copy Plus Services,
has five centers located in the western suburbs of Chicago. Each
center provides a full range of copy services including fax, binding,
computer usage, video conferencing, and blueprint service. The
centers are run 24 hours a day and seven days a week. Sam grew the
business from a simple copy center located in Elgin, Illinois, five
years ago and is planning to go national with the business.
During one of the small group sessions, Sam and five other attendees
were discussing how their businesses affected the environment. One of
the presentations had mentioned a new standard — IS014001
Environmental Management Systems — which applies to service businesses
as well as manufacturers. None of the people in Sam's small group was
familiar with the standard. They decided to share with one another
what they'd been doing in their businesses to protect the environment
and then review the ISO 14001 standard.
Naturally Sam's five copy centers recycled waste paper. However,
beyond that Sam had never thought of other environmentally conscious
programs that they could implement. He was a bit embarrassed that he
had not really given it much thought. He has had complaints of odors
bothering the people in stores adjacent to his centers. In an attempt
to appear as if he had given it some thought, Sam told the group that
he had a good quality program which he thought addressed environmental
issues, and that one of his centers had received an ISO 9001 quality
award for doing quality work.
For the most part, the other members of the group had also not given
environmental programs much thought. They didn't have any specific
issues confronting them and were somewhat concerned about embarking on
a program for which they could not see any beneficial return and that
might be a big cost to the business. Since they had never dealt with
the EPA, they were leery of the possibility that EPA might come into
their business if they participated in the ISO 14001 program.
31
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One of the group members said that, from what she had read on
environmental programs in Business Week, there were benefits to be
derived by undertaking such a program. Since these programs had to be
integrated into the overall business plan, it seemed important that
top management provide the leadership in incorporating environmental
stewardship. She cited some examples of this from case studies she
had read, as well as from her personal experience. One of the
examples was an ice cream business in Chicago, which increased its
overall productivity by focusing on energy efficiency. In addition,
an international clothing distributor used the environment as a major
selling point for its product.
After Sam returned home from the conference, he sat down and thought
about what had been discussed in the small group session. He wanted
to start an environmental program in his business but was not quite
sure how to proceed. He decided to draft an environmental policy for
his Copy Plus Service before going to bed, and present it to his staff
at their weekly meeting the following Tuesday.
At the meeting Tuesday, Sam presented his environmental policy to his
staff. Sam's staff was composed of the managers of the five centers,
a finance manager, and himself. The reaction from the group was
split. Two of the managers felt that, other than recycling the paper,
there wasn't anything of significance that they could do within their
business. The other three seemed to think that this was something
worth pursuing. The finance manger was on the fence. While she
acknowledged that there might be some ideas for them to pursue, she
was concerned that it would add cost to the business. The copy
business was a low-margin business and competition was increasing.
Tip
Sam may have had a better response if the managers had all participated in developing the policy
together.
32
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Although Sam knew that everyone wasn't equally committed, they all
agreed to pursue the idea further. The finance manager and the two
managers who were enthusiastic would review Sam's environmental policy
to determine whether it was appropriate for the business. If so, they
would help figure out how it could be incorporated into the business.
Sam suggested that they might want to talk with someone else in the
copy business to see what they are doing about environmental programs.
The finance manager said that she knew someone from The Body Shop,
also in the mall, who had worked on a committee to develop their
environmental program. They all agreed that the friend should be
invited to join them for a meeting as an outside observer and advisor.
When the three managers met, Laura Witherspoon from The Body Shop, a
neighboring store in one of the malls, was able to attend. She agreed
to provide her perspective and ideas in establishing an environmental
management system. The first order of business was for them to
explain their operation to her.
Tip
So far Sam has only involved managers. He should now include employees from all levels of the
company.
33
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Copy Center Operations
Each copy center produces a million copies per year using premium
grade paper. Of that output, 70% is single-sided copies. Each copy
center also does a significant amount of blueprint business. There are
fifteen employees per center. Each center's energy bill is $50,000
per month. The majority of the work is done during 9 AM to 6 PM
business hours. They recycle approximately 100,000 pieces of paper
per year in each center. Each center uses 400 toner cartridges and
two gallons of ammonia per month. Supplies are stored on shelves in a
back room and chemicals are stored either in metal cabinets or next to
the machines (for easy access). Copy Plus Center customers come both
through newspaper advertising and pamphlets, and through their Web
site .
Equipment: The copy machines and computers are three to five years
old. They are typically left on 24 hours a day. The managers are
not sure if any of the chemical products used in the copy and
blueprint equipment have an impact on the environment.
Location: The Copy Plus centers are in shopping malls and
residential areas. Businesses in the area such as restaurants have
expressed concern over the odors coming from the centers.
Delivery Service: Each center has vans providing customer pickup and
delivery. In addition, the vehicles are used to pick up supplies
for the centers.
Cleaning Service: Each center contracts with a cleaning service that
cleans the facilities. A waste disposal company handles the waste,
and recycling is subcontracted.
Training: Employee training focuses on running the equipment and
administrative procedures, including paper recycling.
Considering this information, Laura suggested that they approach
environmental management system implementation not just from the
standpoint of the copy center operation but from a total systems
approach. Laura presented a simple input/output model to begin the
process of understanding the environmental aspects of the business.
The three managers immediately recognized the possibility and benefits
of this approach. They asked Laura if she would be willing to prepare
a rough plan that described this approach in more detail, and outlined
a typical copy center environmental management system. Laura agreed
because she remembered how difficult it was to get the synergy in her
own organization. She felt that she could assist them with this.
34
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Module 3: Determining Significant Environmental
Aspects and Setting Objectives
From your work in Module 1, you have probably identified a number of "environmental
aspects" associated with your company's activities. This module will help you prioritize
those aspects. It will also help you determine which one(s) you will want to work on
first. Do not expect to work on all the environmental aspects identified. "Continuous
improvement" implies that this is an on-going process where you address some concerns
now and others in the future.
Your operations may have many environmental aspects, but they may not all be
significant. First, by ranking each aspect against a set of environmental criteria (e.g.,
toxicity, wasted materials), you can determine which are most significant. Next, to select
which significant environmental aspects (SEAs) you will work on, rank each aspect
against practical criteria (e.g., technical and economic feasibility) and benefits criteria
(e.g., improved health). For those aspects you select, you will set objectives in terms of
the improvements you hope to make.
DIE projects emphasize integrating evaluation of both risk and resource conservation into performance
and cost evaluations.
Determining which aspects are significant includes making subjective decisions. For this
reason, you will improve results by having a team of people who represent different job
categories. They can provide a cross-section of operational experience when you work
on this module.
Create a Working List of Environmental Aspects
When you developed a list of environmental aspects using the process map of your
company's activities, you may have identified a large number of environmental aspects.
This is not surprising, since virtually all of your business activities could interact with the
environment in some way. In order to identify which environmental aspects are
significant, we will review environmental risk information. However, ranking your
environmental aspects using environmental risk information can be a labor-intensive
process. Therefore, you may want to create a smaller list of environmental aspects to
rank using risk information.
35
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In describing the approach used to identify and prioritize SEAs, one screenprinter
stated that his company:
"Brought in a cross- section of staff and conducted facilitated brainstorming. They then captured the
information in a matrix to help prioritize aspects."
Another said his company used "common sense." He said,
"A quick walk around any print shop will produce at least enough SEAs to get an IEMS project under
way."
First, create a list of selection criteria that suit your company. Below is a list of examples
to help you get started:
> Which aspects might affect your company's ability to comply with regulations and
other requirements?Are there pollution prevention opportunities?
> Are there potential cost savings or business opportunities (e.g., potential customers
who require their suppliers to haveEMSs)?
> Are there concerns that might be shared by customers or suppliers?
> Is there "low-hanging fruit" that might provide early successes which can serve
both to educate employees and to build confidence in the IEMS?
> Are there opportunities to integrate environmental with worker health and safety
requirements?
> Are there community concerns regarding your company's activities?
> Are there unregulated hazardous chemicals that could be managed better or
substituted?
> Are some of your "solutions" to environmental concerns or regulations shifting
waste from one media (air, water, land) to another?
> Could resources be used more efficiently, e.g., energy, water, materials?
You may want to use all or some of these, and you may think of others specifically
related to your company's circumstances. Create a list of criteria and use that to select a
group of environmental aspects to rank.
Tip
Remember: "aspect" refers to the potential for environmental impact. A significant aspect would
have the potential for large impact, either because impact is likely to occur under current operating
conditions, or because there is potential for serious impact. Even aspects that are well-controlled
should be considered for their potential for impact should controls fail.
There are several ways to make this selection. One way is for the IEMS team to review
the list of environmental aspects and vote on their top concerns. Set a target number to
rank, say ten, and let the top ten environmental aspects be your working list.
36
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When you have a reduced list of environmental aspects (e.g., ten), you are ready to rank
them using environmental risk information to determine which are significant
environmental aspects.
Using Environmental Risk Information to Rank Your Environmental Aspects
Although you will not attempt a formal risk assessment for your IEMS, this module will
help you apply your working knowledge and judgment about the chemicals and materials
your company uses, and the way in which they are used, to select environmental goals to
help create healthier working conditions, communities, and environments. This section
presents a brief introduction to the concept of risk and to ranking symbols. Then it
presents methods to gather chemical and material effects information and rank aspects
according to effects; a method for making judgments about exposure to chemicals and
materials and rank aspects according to exposure; a method for laying out risk as well as
other environmental concerns and ranking aspects considering these factors. In addition,
methods for ranking environmental aspects as projects in terms of cost and expected
improvements are presented as a way to prioritize projects that your company will
undertake to get started on your IEMS.
Risk
Risk assessment, in brief, is a process that integrates the work of several sciences to
determine the kind and degree of environmental and human health impacts potentially
produced by exposure to a chemical or material.
Risk is composed of two parts: toxicity (hazard or "effects") and exposure. Toxicity is
the ability to cause harm to the health of humans, wildlife, or vegetation, as well as the
type and seriousness of that effect. You will collect the information needed to form a
judgment about effects in Worksheet 3 -1. You will review the chemical effects
information for each aspect and give a rank based on your judgment of the seriousness of
the effects of this chemical or substance.
Tip
Visit the DfE website for more tools related to risk.
www. epa. gov/dfe
Exposure is the amount of material with which workers, the community, or the
environment come into contact. The amount is determined by both severity and time of
contact. Severity refers to the amount of material that one can come into contact with at
any one time. The time of contact depends on the number of times that contact occurs in
a given period (the frequency of contact) and the duration of the contact. You will collect
the information needed to form a judgment about exposure in Worksheet 3-2.
37
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Contact with humans and animal or plant life is characterized as occurring along
pathways. These pathways describe the routes along which the substance must travel,
before it enters an animal or plant, and how the substance is taken up by the living
organism. Several pathways for human exposure include:
> breathing the material (inhalation pathway),
»• touching the material (skin or dermal pathway), and
> ingesting (eating or drinking) the material (oral pathway).
Using Ranking Symbols
One way to rank environmental aspects is to use symbols representing a range of high
(H) to low (L). Whatever ranking you use (Figure 3-a shows an example), phrase the
meaning consistently across all ranking categories; this is most straightforward if you
think of "high" as meaning a project you would ultimately like to undertake and "low" as
one having lesser priority. Thus, when considering environmental effects, a chemical
receiving a "low" rank would be one with low impact or good environmental
performance.
Figure 3-a: Ranking Symbols
Symbol
H
M-H
M
M-L
L
Meaning
High
Moderately High
Moderate
Moderately Low
Low
IEMS Meaning
Most environmental impact
More environmental impact
Medium environmental impact
Lower environmental impact
Lowest environmental impact
Identify and Rank Potential Human Health and Environmental Effects of
Chemicals and Materials
To rank the environmental aspects associated with chemicals and materials used in your
business operations, you will need to find information on the human health and
environmental effects associated with those chemicals. Without this information, you
cannot identify the potential impact of each chemical on the environment. Unfortunately,
there is no single and comprehensive source of information for most chemicals.
Information that will help you understand the effects associated with the chemicals you
use may be located in several different sources.
38
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Tip
See Appendix B for a list of sample questions to ask your suppliers.
By taking the time and effort to find information about the chemicals you use, you will be
able to understand the potential effects of the chemicals on humans and on the
environment. You will also know how to use them in a way to minimize or avoid harmful
effects. You can decide whether you want to continue using your current chemicals, or
find alternatives that would mitigate any potential harmful impact.
Sources of information about chemicals include:
> Manufacturer's Safety Data Sheets (MSDSs). These are supplied by the
manufacturer according to OSHA regulation. You should receive a MSDS with
any chemicals you purchase. They should be kept in a location that is available for
review.
> Your suppliers. Ask them for hazard and exposure information on any products
you purchase. Ask them to supply the environmental information that is not on
the MSDS.
»• Your trade association.
> EPA or state environmental agency.
> Online sources in various websites, e.g. various EPA programs. (EPA's DfE
Program website contains a Risk Guide with additional information.)
Tip
Remember, any chemical strong enough to take the place of human labor or to make human labor
easier is strong enough to have some kind of environmental risk associated with it. The challenge is
how to best manage that risk.
Organize the information you have into a format that will enable you to make
comparisons between aspects. You may find that sometimes there exists very little
information for a particular chemical. That discovery in itself is useful. By using this
format and showing where information gaps occur, you will know that whatever decision
you make now about using a specific chemical may change if information becomes
available at a later date. Although you may want to use the chemical now, you may need
to make adjustments later when more information becomes available. Worksheet 3-1
will help you organize your information on the chemicals you use in your business
activities. The column headings list the categories and specific information needed. The
final column asks for your judgment about the ranking of the environmental concerns
associated with the chemical or material under consideration.
39
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Figure 3-b lists the kinds of information OSHA requires on an MSDS. Most of the kinds
of data listed below can be used to fill in the columns on Worksheet 3 -1. Much of the
environmental information will have to be found elsewhere.
In addition to carcinogenicity information and qualitative descriptors of health hazards
(e.g., sensitizer, causes dizziness, etc.), MSDSs sometimes include quantitative toxicity
values, which are important for assessing chemicals hazards. These include lethal dose
(LD) and lethal concentration (LC) measures, which are typically from laboratory studies
done on small mammals such as rats, mice, or rabbits. These measures are used to give
guidance as to the dose required to kill a human. This is important information; however,
interpreting its meaning is difficult. In general, if you are comparing several chemicals
that have LD or LC measures, the lower measure is the most potent (it means that it takes
less to be lethal). Therefore, you would have to be more careful using the chemicals with
the lower LD or LC measures, as compared to those having higher measures. Be sure to
record any quantitative toxicity values found on an MSDS, as well as the more qualitative
information.
40
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Figure 3-b: Information on an MSDS
As defined by the Occupational Safety & Health Administration (OSHA)
(29 CFR 1910.1200), an MSDS is written or printed material concerning
a hazardous material which contains the following:
* The identity of the hazardous material (except as provided for
materials that are trade secrets).
* The physical and chemical characteristics of the hazardous
chemical (such as vapor pressure, flash point).
* The physical hazards of the hazardous chemical, including the
potential for fire, explosion, and reactivity.
* The health hazards of the hazardous chemical, including signs and
symptoms of exposure, and any medical conditions which are
generally recognized as being aggravated by exposure to the
chemical.
* The primary route(s) of entry.
> The OSHA PEL (Permissible Exposure Level), the ACGIH (American
Conference of Governmental Industrial Hygienists) Threshold Limit
Value, and any other exposure limit used or recommended by the
chemical manufacturer, importer, or employer preparing the MSDS,
where available.
* Whether the hazardous chemical is listed in the National
Toxicology Program (NTP) Annual Report on Carcinogens (latest
edition) or has been identified as a potential carcinogen in the
International Agency for Research on Cancer (IARC) Monographs
(latest editions) or by OSHA.
* Any generally applicable precautions for safe handling and use
which are known to the chemical manufacturer, importer, or
employer preparing the MSDS, including appropriate hygienic
practices, protective measures during repair and maintenance of
contaminated equipment, and procedures for clean-up of spills and
leaks .
* Any generally applicable control measures which are known to the
chemical manufacturer, importer or employer preparing the MSDS,
such as appropriate engineering controls, work practices, or
personal protective equipment.
* Emergency and first aid procedures.
* The date of preparation of the MSDS or the last change to it.
* The name, address, and telephone number of the chemical
manufacturer, importer, employer or other responsible party
preparing or distributing the MSDS, who can provide additional
information on the hazardous chemical and appropriate emergency
procedures, if necessary.
41
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Worksheet 3-1: a Health, Safety and Environmental Potential Effects Information
Operation
Manu-
facture
Stepl
Environ-
mental
Aspect
Chemical 1
Informa-
tion
Sources'3
MSDS,
trade
association
Regulatory Data:b
Carcinogen?
OSHA Permissible
Exposure Limit (PEL)?
Toxic release Inventory
(TRI)?
yes
10 ppm
no
no
Contact Person:
Human Health Effects by
Pathways
Acute and Chronic c
Inhalation
Chronic:
cancer
Acute:
dizziness
Dermal
Chronic:
sensitizer
Oral
acute:
LC50 of
100
ppm
Effects on Wildlife
and Other
Environmental Effects d
Air
ozone
depletion
Water
Acute:
kills fish
Land
kills
worms
Worker
Safety
flammable
Rank
Human
Environ-
ment
Date Completed:
a Corresponds to Table EA-03 in Company Manual Template.
b Most information for this column can be found on the MSDS.
c Partial information for these columns might come from the MSDS, but other resources may be needed. In particular, acute effects are usually
reported on MSDS sheets. Chronic effects are sometimes on MSDS sheets, but often will have to be found elsewhere. LC refers to lethal
concentration. Inhalation LC50 is the concentration of a chemical in air that causes death in 50 percent of the test organisms at the end of the
specified exposure period. LD refers to lethal dose. LD50 is the dose of a chemical taken by mouth, absorbed by the skin, or injected that is
estimated to cause death in 50 percent of the test animals. Lethal dose data are expressed in terms of amount of chemical divided by the body
weight, e.g., mg/kg.
d MSDSs usually do not include environmental effects.
Note: This worksheet provides an example of the kinds of information found on an MSDS, but it is not a part of the press cleaning example. For
more information on risk-related data, including methods for interpreting quantitative toxicity values, refer to the Risk Guide provided on the DfE
Program website.
42
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Rank Exposure to Chemicals and Materials
In determining exposure, the amount of material as well as the frequency and duration of
contact must be considered. An important element in exposure is contact. If there is no
possibility of contact occurring, then there may be no exposure and therefore no risk. In
some cases, as when a toxic substance such as lead is embedded in a product such that no
contact occurs during use of that product, the toxic substance may still leach out of that
product if it is disposed of in a landfill. The possibility of contact throughout the use and
disposal of a product should therefore be considered. If, however, a toxic substance is
contained such that neither humans nor the environment would come into contact with it,
then exposure would be low. In ranking such a chemical use the rank given to the
"Workers, " "Community," and "Environment" would be "Low" (L). In ranking
exposure, it is, therefore, necessary to consider how contact might occur and whether, in
fact, it does.
Severity (Quantity)
Determining the quantity of chemical or material that humans or the environment are
exposed to can be difficult, especially if the substance becomes diluted in air as vapor or
dust or in water. Potential exposure is affected by both the amount of a chemical product
used and the concentration of the subject chemical in the product. First, determine the
quantity used per time period (shift, week, month, year). If the chemical of interest is
part of a product, then apply the percentage that the chemical constitutes in the product to
the total usage of the product to determine the quantity used of that chemical. For
example, a product may be a single, pure chemical (such as a solvent), or it may be a
dilute water-based mixture, with the active ingredients being only a small percentage of
the total amount. The higher the concentration, the higher the potential exposure to that
ingredient. See the Exposure section of the Risk Guide on the DfE website for more
information on evaluating the exposure amount and ingredient concentrations.
Tip
See 'the Exposure section of the Risk Guide on the DfE website for more information on evaluating
the exposure amount and ingredient concentrations.
Exposure Time
In addition to quantity, the duration of contact determines the exposure to a chemical or
material. How often is the chemical or material used and for how long? The time period
used should be related to that used for quantity. For example, if you measure quantity per
month, then the time periods should show how many times (frequency) and for how long
(duration) it is used per month. Use whatever time frame works with your business
operation, but be consistent.
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Personal Protective Equipment
The use of personal protective equipment (e.g., gloves, eye protectors, breathing masks)
can greatly alter exposure to a chemical or substance, for the personal protective
equipment provides a barrier that prevents or reduces contact. Even though personal
protective equipment is used, some exposure may occur because people are not perfect in
their adherence to instructions and because equipment fails. Consider the possibility of
failure when making judgments about exposure to chemicals and materials.
Pathways
Substances can come into contact with living organisms through air, water, land, and
other solids. For example, chemicals and substances can be inhaled from the air in the
form of dust, vapors, and mists. Humans can ingest chemicals and substances in liquids
or food. Substances can get into liquids or food by falling into them from the air, or by
food coming into contact with chemicals on surfaces or hands. Finally, touching the
chemical or substance can occur when dust, mists, or vapors contact bare skin or when
unprotected hands touch contaminated surfaces. Animal and plant life can take up
chemicals and substances from the environment in much the same way. Figures 3-c and
3-d show some typical exposure pathways for chemicals used in business operations.
When ranking aspects, determine how contact might occur; then decide how severe that
contact actually is and how much time is involved (the frequency and duration of
contact). (For consistency in comparisons between criteria, apply the same time period to
every aspect in your ranking exercise.)
Worksheet 3 -2 will help you think about the exposure for each chemical you consider.
This chart can be filled in for each chemical or material and represents your best
judgment about exposure. The rank for each can then be placed in the last column. The
rank represents your judgment.
44
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Worksheet 3-2: Exposure to Chemicals and Materials
Operation
press
cleaning
Aspect
acetone,
toluene,
MEK,
isopropyl
alcohol
blend
air
releases
Quantity*
Used per
time period
24 oz. per
day
Exposure Time
Duration**
10 min.
Contact Person:
Frequency
5 times per
day
Personal
Protective
Equipment
(PPE)
gloves
Pathway
Human:
Inhalation,
Dermal, Oral
inhalation
Environme
nt:
air, water,
land
air,
water
Rank Exposed Groups
Workers
H w/o PPE
Commun-
ity
L
Environ-
ment
M-L
Date Completed:
If ingredient in chemical product, use quantity of chemical not product, i.e., apply the percentage that the ingredient makes up of the product.
**How many minutes or hours per day is the chemical or material used?
Note: For more information about evaluating exposure, refer to the exposure section of the Risk Guide on the DfE Program website.
45
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Figure 3-c: Screen Printing Exposure Pathways
46
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Figure 3-d: Dry Cleaning Exposure Pathways
..
_L T5
47
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Ranking Your Significant Environmental Aspects
Now you will put the Effects information together with the Exposure information and
consider some additional information. The following paragraphs explain how to use
Worksheet 3-3 to rank significant environmental aspects.
Regulatory Concerns
For each aspect, refer to the regulations associated with it that were identified in Module
1 and decide how important these are to your company. For example, an aspect might be
regulated, but your company might be small enough that it was exempt from the
regulation. The regulatory concern for your company might therefore be considered low
(i.e., not important enough for a project). On the other hand, your company might have
an environmental aspect to which a regulation applies. If you can stay in compliance
easily, you might also rank the regulatory concern low. Or, if the cost of compliance is
large or you have experienced difficulties in meeting compliance, you may rank this high
(meaning that it may be a good candidate for a project). You do not need at this point to
define your aspect in terms of an environmental concern. That will show up as you rank
the remaining columns for this aspect.
Chemical and Material Risk
Place both the ranking for effects and the ranking for exposure from Tables 3-1 and 3-2
in the columns. The effects rank for humans would be placed in both the worker and
community columns.
Worker Safety
Look at the information in Worksheet 3-1 under worker safety and apply a judgment of
ranking. Enter this rank in the worker safety column.
Other Community Issues
There are a variety of community concerns that might affect your designation of a
particular activity as a significant aspect. These are issues other than pollution. Some
examples are the noise level or odor produced by your plant; increased traffic caused by
your business; and increased light needed for your operations. You may come up with
others specific to your operation and your community. Worksheet 3-3 provides a place to
document and rank these issues. Place the rank from this worksheet in Worksheet 3 -5.
48
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Worksheet 3-3: Community Issues
Operation
Aspect
Community Issues (List)
Rank
Contact Person: Date:
Tip
Remember: The ranks have no intrinsic meaning. They are merely a shorthand for expressing your
judgment about priorities.
Natural Resources
This criterion should be used to identify the use of water, energy, and other
environmental resources, such as forests or land. The rank that you give to a particular
aspect under this criterion is highly subject to the specific circumstances and values of
your company and community. For example, a high rate of water use would be of higher
concern in a desert region than in a region where water is more plentiful. This column
allows you to consider what resource issues you might associate with a particular aspect.
The rank you give is based on your judgment related to your own specific circumstances.
Other natural resource issues include generation of solid waste and its contribution to
landfills in your area. Worksheet 3 -4 provides a place to document and rank these natural
resource concerns. Place the rank from this worksheet in Worksheet 3 -5.
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Worksheet 3-4: Natural Resources Use
Operation
Aspect
Natural Resources
Used
Rank
Contact Person: Date:
Tip
If you are pursuing ISO 14000 certification, you will have to address each significant aspect. You
may want to consider reducing the number of significant aspects to two or three in the beginning
and add more as your company grows in experience with the IEMS process.
Overall Ranking and Significance
Review the columns for each aspect and make a judgment as to whether each aspect
should be determined H, H-M, M, M-L, L in rank. After all the aspects have been given
an overall rank, determine which of them you believe are significant for your company.
Place a yes (Y) or no (N) in the final column.
Ranking Environmental Aspects: Examples
The following example shows you how to rank the aspects identified in Module 1 using
the criteria in Worksheets 3-5a and 3-5b. Examples of both small and large projects are
included. It is important that you think through even solutions that seem obvious,
because sometimes you might find a better solution. Refer to Figure 1 -h and Worksheet
1 -5 to refresh your memory on this example.
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Example 1: Toner Cartridges
In this example, a copy machine is used to make paper copies as part of day-to-day
business activities. The inputs are toner, paper, and electricity (energy) to run the
copies. Outputs include spent toner cartridges, waste paper from poor quality copies,
noise, and usable copies. There are no restrictions on use of the copier. Spent toner
cartridges are simply discarded with the office trash.
Let's consider the use of toner in copying. Unused toner is considered as an input, while
used toner is considered as an output. The same product generates different concerns at
different stages of its use. Let's look at the criteria for each in Worksheet 3 -5a. The
worksheet shows the aspects identified in Figure 1 -h. Only the two toner input and
output aspects are scored for this example, for illustration. However, in a real exercise,
all the aspects would be scored.
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Worksheet 3-5a:a Criteria to Determine Significant Aspects: Toner Cartridge Exampleb
Operation
Copying
Aspect13
Paper Use
Toner (Input)
Documents
Waste Paper
Used toner
(Out)
Odors
Regulatory
Concerns
M
M-H
Chemical and Material Risk
Worker
Eff/Expc
L/L
L/L
Community
Eff/Expc
L/L
L/L
Contact Person:
Environ-
ment
Eff/Expc
L/L
H/H
Worker
Safety
L
L
Other
Community
Issues: d
Natural
Resources:6
L
M-H
Overall
Ranking
M-L
M-H
Date Completed:
Significant?
Y/N
N
Y
a Corresponds to SEA-01 in Company Manual Template.
b Include each input and output of a process step.
c Effects/Exposure
d Noise, Traffic, Light, Odor.
e Include such items as Resource Use, Solid Waste, Energy Use
Ranking Notes for this Example:
Regulatory concerns may be present due to the chemicals used inside the cartridge or due to solid or hazardous waste regulations.
Effects of Chemicals and Materials inside the toner cartridge are probably of concern. You would have identified these in Module 1. However,
since the cartridges are not opened either during input or output use, there would be no exposure. Frequency of impact, therefore, would be low.
Workers: Worker health and safety would be of low or no concern if the toner is used only in the cartridges.
Community: The community's health and safety would be of low or no concern if the toner is used only in the
Environment might be high if you do not currently recycle your cartridges. Chemicals can spill out of the cartridges if they are placed in a landfill.
Natural Resource Use would be low for water, but might be a concern for land if you do not recycle the used cartridge.
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How to Obtain Overall Rank: this can be done in two ways.
1. Look across the columns and assign a total that in your judgement best reflects the
individual ranks in each column.
2. Assign a number from 1 -5 to each rank such that H = 5 and L = 1. Sum these
across the columns and then divide by the number of columns used to get an
average rank for that row. For toner input the total would be 11 (counting each
risk column as 2 because they have two scores and disregarding other community
issues because it was not applicable). Divide by 9 (the number of columns used).
The average rank would be 1.2, which corresponds with M-L. Place M-L in the
Total column.
Meaning of Environmental Aspects Rank: The total rank for toner used as an input is
M-L and for used toner as an output is M-H. These ranks tell you that toner cartridges as
waste outputs of your copying generate more concern than they do as new inputs. Your
main concern would be to reduce any potential impact of the used toner cartridges. You
could reduce potential impact in at least three ways:
»• ensure that the cartridges are not opened either before or after use, to avoid
exposure to the chemicals;
> ensure that the cartridges are recycled according to the distributor's instructions, so
that there is neither concern for ecological exposure to the chemicals in landfills,
nor a contribution to the solid waste going into landfills; and
»• reduce the number of waste toner cartridges by cutting down on unnecessary
copying.
Example 2: Chemical Use and Waste
A second example will provide more points to consider in developing objectives.
Consider the chemical inputs and the chemical waste outputs of a "Press Cleaning"
example. In this example, a printer uses a chemical press cleaner (solvent mixture) to
manually clean the press after each print run. An uncovered bucket of cleaner is kept at
press-side along with a bin of clean, cloth wipers and an uncovered container of soiled
wipers. To clean the press, the printer scrapes excess ink from the press for reuse, dips
one or more wipers in the press cleaner and wipes the press; wipes the press with one or
more clean, dry wipers; and places soiled wipers in an open bin. Soiled wipers are
transferred to a closed storage container at the end of the shift. Most of the resulting
ink/solvent mixture is contained on the wipers, but excess is captured in drums and
disposed of as a hazardous waste. Soiled wipers are sent to the laundry weekly.
Tip
Refer to Figure 1-i and Worksheet 1-5 to refresh your memory on this example.
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Thus, the inputs are the press cleaner and clean wipers. Outputs are reusable ink, soiled
wipers, and waste ink/solvent mixture. The environmental aspects include the waste
ink/solvent mixture and air and water emissions of press cleaner. Air emissions of press
cleaner occur both in the print shop (from the uncovered bucket of cleaner, the cleaning
operation itself, and the storage container of soiled wipers), and at the laundry (from the
soiled wipers). We will score the two aspects of chemicals used in press cleaning and
waste from those chemicals.
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Worksheet 3-5b:a Criteria to Determine Significant Aspects: Chemical Use and Waste Example13
Operation
Press
Cleaning
(in)
(out)
Aspect13
Stepl
Toxic chemical
constituents
Wipers
Enerqy
Water
Waste chemicals
Soiled Wipers
Waste Water
Air Releases #1
Product for next
step
Regulatory
Concerns
M-H
M-H
Chemical and Material Risk
Worker
Eff/Expc
M/M-H
M/M-H
Community
Eff/Expc
M/M-L
M/H
Contact Person:
Environ-
ment
Eff/Expc
M/M-L
M/H
Worker
Safety
M-L
M-L
Other
Community
Issues:
n/a
n/a
Natural
Resources6
M-H
M-H
Overall
Ranking
M
M-H
Date Completed:
Significant?
Y/N
a Corresponds to SEA-01 in Company Manual Template.
b Include each input and output of a process step.
c effects/exposure
d Include noise, traffic, light, odor.
e Include such items as resource use, solid waste, energy use.
Ranking Notes:
Regulatory Concerns: check the lists of regulations and standards to see if they apply to any of the chemicals you have identified as inputs. For
outputs from your manufacturing process, find out whether the regulations for solid and hazardous waste make mention of these chemicals.
Consider whether new chemical products are formed and become wastes during the process of step 1. If so, don't forget to check for these
chemicals as well as the input chemicals. Chemical and Material Risk: Assign the ranks from your Effects and Exposure Worksheets. Safety
might include reference to a flammable chemical. Hence the rank of M-L. Natural Resource Use may be important for both input and output
chemicals. Also, consider the quantity of water used as an input or to take care of waste.
55
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Tip
You do not have to evaluate alternatives for all significant environmental aspects. Therefore, it is
important to consider the "do-ability" of each project and to determine what improvements might
be achieved by each project before deciding which ones to undertake.
Meaning of Rank
The total for input chemicals is M and M-H for output (waste). If you compare all the
ranks, it would seem that the waste chemicals in this example, using assumed criteria,
constitutes a more significant concern than do the other activities.
Tip
Remember: If your company is considering ISO certification, you will have to demonstrate action on
every SEA.
Grouping Environmental Aspects
In reviewing your company's list of environmental aspects you may discover that some
aspects occur in more than one process step. Energy use is a good example. It might be
effective in some circumstances to combine all the process steps having energy aspects,
and develop a facility-wide strategy and program for achieving improvement.
Understand, however, that the energy aspect should be ranked in each process step to
determine its relative importance in that step. For example, energy use in office work
might be a different priority than energy use in a manufacturing step. In addition,
standards and procedures developed to reduce energy use would be different for each
process step. Consequently, although you might achieve certain efficiencies through a
facility-wide effort, your actual environmental improvement will be attained through
objectives set for each process step.
Consider "Practical" Criteria Also
In order to determine which significant environmental aspects will become projects, it is
important to consider the economic and technical feasibility and the time frame for your
company. It is also important to consider what improvements could be expected from
each project. Selecting high-priority projects is desirable from an environmental
perspective, but there is value in undertaking some short term, "easier to implement"
projects which may not be ranked high in environmental risk. The easier projects provide
a useful learning experience, boost confidence as people see results, and focus attention
on environmental goals.
In the examples above, deciding to reduce the volume of copying and to recycle toner
cartridges used in your office copier is a relatively short-term, low-cost environmental
project to set in place as shown in Worksheet 3 -6. Determining how to deal with
chemical waste products could be a longer process: the obvious solution may not be the
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best, and a project that appears difficult and long-term may turn out to have a simple
solution. The many alternative approaches to dealing with waste products can range from
chemical substitutions to changing the nature of the wastes, changing work practices to
reduce the volume of the waste, and changing disposal methods. Your final
environmental program might include changes in each of these phases. In the example,
although ink wastes may have the highest environmental risk rank, addressing those
problems could be longer-term and more costly. On the other hand, doing so might yield
greater cost savings than the quicker, cheaper toner cartridge example.
You need not rank your practical criteria; you can consider them by simply describing
the practical considerations for each potential project. Worksheet 3 -6 helps you lay out
the considerations for each significant environmental aspect. At this point the worksheet
provides you with a "first cut" qualitative judgment, to help choose aspects for further
work. Aspects not selected at this time may be suitable for future projects.
Worksheet 3-6: Criteria to Select Environmental Projects
Project to
Address
Aspect
Toner (In)
Used Toner
(Out)
Press cleaner
(In)
Waste Ink (Out)
Soiled Wipers
(Out)
Time Frame
N/A
Short (1 month)
Longer
evaluation
Longer
evaluation
Cost
N/A
Negligible; time to
write procedure
Employee time
Employee time,
process change
Contact Person:
Technical Feasibility
N/A
Easy
Needs help from
suppliers, etc.
Needs help from
suppliers, etc.
Total Feasibility
N/A
Excellent
More difficult
More difficult
Date Completed:
Tip
Considering the benefits does not mean undertaking an analysis of potential outcomes. It means
identifying the kinds of improvements that might be achieved by implementing a particular project
and then deciding what value (priority) that improvement has for your company.
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Finally, compare in general the expected improvements to be gained by working on each
aspect. Like any undertaking in a business operation, you should be able to describe
what you expect to get before you undertake the project! First, develop a list of benefits
criteria. These might include such things as:
»• Reduced human health impacts
> Reduced environmental impacts
> Cost savings
> Improved community relations
> Improved employee morale
> Customer benefit
Again, these particular criteria might not fit your company. Make a list of criteria
identifying kinds of improvements that could be derived from undertaking environmental
projects. These expected improvements need not be ranked; simply describe the potential
for each criterion to be achieved. Worksheet 3 -7 illustrates the two examples.
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Worksheet 3-7: Potential Improvements
Aspect
Toner (In)
Used Toner
(Out)
Press Cleaner
(In)
Waste Ink
(Out)
Press Cleaner
(In)
Soiled Wipers
(Out)
Human Health1
Little effect
Some effect
through waste
Improve worker
health
Improve
community;
reduce presence
of hazardous
materials
Environment
Little
Some effect in
waste
Some improve,
air
Improve effect on
landfill,
groundwater,
habitat
Cost Savings
Low
Some
Some through
efficiency
Some through
efficiency and
reduced waste fees
Community
Relations
N/A
Good; shows effort
Good
Excellent PR
Contact Person:
Morale
N/A
Good learning
tool
Good; workers
happy
Good; workers
happy
Expected
Improvements
N/A
Some
Good
Excellent
Date Completed:
1 Workers, Community, Global
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Overall Summary of Ranking
Worksheet 3-8 illustrates how to put together the results from ranking the significant
environmental aspects with the results from the economic, technical and improvements
worksheets so that you can determine which will make the best projects for your
company at this time. Projects not chosen now can be developed later. The example
illustrates that while chemical waste may present one of the most involved projects in
terms of feasibility, it may also provide the greatest improvements. The final decision
rests with your company and should reflect both your values and your needs. You may
want to undertake both a short-term and a long-term project.
Tip
It is important to recognize that the tables are merely a tool to help you summarize your judgment
and organize your thoughts. The ranks placed in the tables do not have any intrinsic value but are
used for purposes of comparing the results to each other.
Worksheet 3-8: Overall Ranking Summary
Process Step
Aspect
Toner (In)
Used Toner
Chemicals
Chemical Waste
Aspect Total
M-L
M-H
M
H
Feasibility
Total
N/A
H
M-L
M-L
Contact Person:
Benefits Total
N/A
M
M-H
H
Significant
Y/N
N
Y
Date Completed:
Setting Objectives
The point of the priority setting exercises, of course, is to reduce your company's impact
on the environment. The process outlined in this Guide describes two approaches:
making your current activities and processes the best they can be and making significant
changes in the products your company uses or produces, and in the processes or activities
of your company. If you intend to seek ISO 14000 certification, you will need to take
action on each SEA identified. If you are not seeking certification, you can be more
flexible in undertaking projects. Module 4 describes the process of evaluating alternatives
for those SEAs you believe will require changes. Module 6 describes the process of
developing operational controls for the SEAs that will not involve significant changes at
this time. (You may decide to evaluate alternatives and make changes in these later.)
At this point, general objectives can be developed for each SEA identified. These
objectives should be consistent with your company's environmental policy and also with
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your company's compliance requirements. Using the examples ranked on the worksheets
above, a company could specify its objectives as follows:
»• Reduce the waste from used toner cartridges.
»• Reduce the environmental impact of press cleaning.
These objectives state the desired outcome in terms of the desired improvement in
environmental impact, not in terms of the specifics of how it might be accomplished. For
example, the objective of reducing waste from toner cartridges is open as to how that
might be accomplished. One could reduce the use of toner cartridges, ensure that the
recycling program is adhered to, or stop using copiers and printers that have toner
cartridges in favor of another technology. Likewise, reducing impact from the press
cleaning process can be accomplished in different ways.
In looking at these two objectives, one might note that the toner cartridge objective might
be met by writing and posting a procedure that ensures recycling of the cartridges and by
making sure that people who change the toner cartridges have sufficient training in this
procedure. On the other hand determining how to reduce the impact of chemical wastes
may involve some greater changes that would be provided by operational controls and
training alone. In this case, an alternatives evaluation would be necessary. After an
alternative is identified, of course, operational controls and training would be needed for
the new product, process or activity.
It is important to take on what you can finish. In the beginning, tackle the SEAs that you
can handle, what is environmentally important, and whatever is urgent. Your company
can start on any remaining SEAs when you have completed the first ones.
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Module 4: Evaluating Alternatives
In this module we explore ways to evaluate alternatives for environmental aspects that
you want to change. In Module 6 we will review how to write and implement operational
controls for significant aspects where you are not evaluating alternatives. As examples of
alternatives evaluations, we will show one project having a quick, low-cost solution and
one requiring greater analysis and longer-term implementation: the examples of toner
cartridges and press cleaning chemicals. The objectives from the end of Module 3 were
as follows:
> Reduce the waste from used toner cartridges.
> Reduce the environmental impact of chemical wastes from press cleaning. The
environmental aspect is vapors released to air during the press cleaning process
and at the industrial laundry where used press wipers are sent. Identification of
this significant aspect occurred when the laundry called the company and said they
had received complaints from the local regulatory agency regarding solvent traced
to the printer's press cleaning wipers. The information for this example comes
from the DfE Program Lithography Case Study 1. (See DfE Program website for
Case Study.)
The DfE Program emphasizes the importance of evaluating an array of alternatives before determining
appropriate action. The best solution may not be the most obvious and risk reduction, like pollution
prevention, may save you money.
This module will help you determine how to work toward the objectives you selected in
Module 3. In some cases, this might not be a difficult process. In others, however, the
solution might not be obvious. For example, you may have identified the waste from the
use of a chemical as a significant aspect and determined that alternative practices exist.
You may have then set an objective of reducing the environmental impact from that
chemical as it is used in your business processes. One alternative way to achieve that objective
would be to target that chemical for replacement, but that may not be the best solution for your
company. It is important, therefore, to consider other options for managing the environmental
impact of that chemical as it is used by your company, as well as the option of replacement. This
module will walk you through a process of evaluating options for substitution. It will also help
you develop achievable targets having both environmental and economic advantages.
Screen printers in the SGIA /EMS Pilot Project had this to say about the DfE
method:
"The DfE method forces one to evaluate all aspects-health, safety, regulatory, environmental. The
method helps you to make informed decisions.
"The process standardizes methods used to assess risk and resource efficiency. It makes it easier to
compare "apples to apples." While some matters are still judgement calls, having a frame of reference to
work within ensures that the standards used to make those calls are constant and logical."
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Step 1: Define the Baseline
The baseline is your current chemical, activity or technology that is the source of the
environmental aspect. The process map you developed in Module 1 is a convenient tool
for defining boundaries of the baseline.
Usually it is fairly straightforward to determine at what point in the overall process the
baseline begins and ends. The definition can make a big difference, however, in the
scope of an alternatives evaluation and in the variety of alternatives examined. In our
press cleaning example above, the baseline could be defined in different ways, depending
on exactly how the environmental aspect is specified. If one identifies the
environmental aspect as vapors contaminating the work area, then the baseline would be
use of the product producing the vapors and whatever ventilation hoods or personal
protective equipment are used. If, however, the environmental aspect is identified as the
regulated chemical discharges from the laundry when washing the press wipers, then the
baseline becomes the chemical product used to clean presses and the work practices that
leave large quantities of the solvent in the press wipers when they are sent to the laundry.
In the first case, alternatives might include different chemical cleaning products and also
different kinds of ventilation equipment and personal protective equipment. In the
second case, alternatives would include products, work practices and methods of
reducing solvent left in used wipers. Be sure to capture all you need when you define
your baseline.
Internet Help
Visit the DfF website for more tools related to evaluating alternatives.
www.epa.gov/dfe
Step 2: Identify the Function
Next, define the function of the activity with which the significant environmental aspect
is associated. Defining the function helps to broaden your perspective in developing
alternatives because it allows you to step back from that specific part of the process and
think holistically about how things might be done differently. Looking at earlier parts of
the process will inform you about potential alternative practices. Defining the function
often opens up opportunities that may be missed by focusing only on the process step.
Here are two examples:
Example 1
Aspect identified: Waste from toner cartridges used in copier.
Baseline: Day-to-day copying activities in an office environment with no restrictions on
use of the copier. Spent toner cartridges are discarded with office trash.
Function of toner cartridges: to deliver the chemicals to make clear copies.
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Example 2
Aspect identified: air and water emissions from solvent used for press cleaning.
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone,
toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the
press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals
and soiled wipers are kept in uncovered containers during the work day and closed
containers after work hours. Waste ink/solvent mixture is collected in drums and
disposed of as hazardous waste. Wipers are collected and sent to laundry.
Function of press wash: to ensure good quality printing by thoroughly cleaning the
press during and after the printing process.
Step 3: Develop a List of Alternatives
The important question to ask is how this function could be accomplished in other ways
that might prove to be environmentally preferable, while still meeting cost and
performance concerns. Different levels and kinds of alternatives should be considered.
For example:
> Substitute products
> Reduce product use, through technology changes and improved work practices
> Improve treatment technologies
> Improve disposal technologies
Example 1: List the alternatives for reducing the waste from used toner
cartridges
> First, are there substitute products that could be used in place of toner cartridges?
Probably not, given current technology and the fact that the toner cartridge
specifications are required by the make and model of the printer.
»• Is there a way to reduce the use of the toner cartridges, thereby reducing the waste
product? By defining copier needs, the quantity of copying could possibly be
reduced by encouraging the use of electronic transfer of information within the
company, in place of distributing paper copies.
> Improved treatment technologies — does not apply for this example.
> Improved disposal technologies. The disposal alternatives include throwing in the
trash or recycling.
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Example 2: List the alternatives to the current press wash process
»• Substitution: First ask the question, is there any way to achieve the required
product quality with the use of less or no press cleaning solution? You may
consider substitutions in another part of the process, such as the type of ink, so that
less or different press cleaning solution could be used. Or, you could also consider
substituting the press wash solution for a less volatile cleaner.3 Such substitution
may require other process changes to work. You could also consider using
disposable cleaning wipers, which would eliminate the releases and exposures at
the laundry. In doing so, however, you may create a problem of hazardous waste
at the landfill, thereby merely transferring the problem from one location to
another rather than solving it.
»• Reducing use of the product: reduction in use of the press wash solution might be
brought about by scheduling jobs to require less cleaning (e.g., heavy coverage
jobs after light coverage; dark colors after light colors), or by implementing
inventory control procedures that discourage operators from using more wash than
necessary (e.g., by limiting the amount of wash kept at press-side). In addition, a
study could be made to determine what methods are used by press operators who
use the least solvent. Their methods could be used to train others.
> Responsible recycling/reuse: Possibly the waste press wash solution could be
reused one or more times; if not on the press, then in other clean-up applications.
> Improved treatment technologies: Soiled wipers can be run through a centrifuge to
capture excess solvent prior to being sent to the laundry, but fire regulations
should be consulted to ensure this doesn't impose a fire hazard.
> Improved disposal technologies: What are alternatives for disposal? Sending the
wipers to the laundry; extracting waste solvent from the wipers and reusing the
solvent for other cleaning jobs, then sending it to be burned as a fuel; using
disposable wipers and throwing them in the trash.
Tip
Think broadly when developing alternatives. Sometimes an alternative that is upstream or
downstream from your process will produce better results than will a change of chemicals or
another in-process change.
Worksheet 4-1 will help you organize the functions and alternatives for your evaluation.
Create your own worksheet from the significant environmental objectives you selected in
Module 3. Some of these boxes can be filled out by brainstorming within the team
working on the IEMS, but some will require further work before they can be completed.
Some additional sources of information include chemical product suppliers, machinery
manufacturers and suppliers, workers on the line, trade associations, technical magazines
associated with your business, or other businesses like yours. You may be surprised at
how much information you will uncover. One way to proceed might be to assign each
3 "Volatile" means that the substance evaporates easily.
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member of the team one area of information to collect, and then have them use it to fill in
the chart at the next team meeting. It's important to collect as many ideas as possible and
then narrow down your list of alternatives to evaluate. By keeping your mind open in
your initial brainstorming you may uncover worthwhile alternatives that are not obvious.
Worksheet 4-1:* Potential Alternatives
Significant Environmental Aspect: Waste toner cartridges
Baseline: Spent toner cartridges are discarded in trash.
Function: Provide ink for duplicating
Products
Technologies
Work Practices
Recycling/
Reuse
Treatment
Disposal
Current Practices
Toner Cartridges
Paper
Unlimited copier use
Discard in trash
N/A
See Recycling/Reuse
Above
Contact Person:
Potential Alternatives
N/A
More electronic media use would reduce need for toner
cartridges
More careful about use of printing could reduce quantity of
toner needed
Follow manufacturer's directions to recycle
N/A
See Recycling/Reuse Above
Date Completed:
Document these results in Section AE of the Company Manual Template.
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Worksheet 4-1 :* Potential Alternatives
Significant Environmental Aspect: Press washing
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene,
methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no
restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers
are kept in uncovered containers during the work day and closed containers during after hours.
Waste ink/solvent mixture is collected in drums and disposed of as hazardous waste. Wipers
are collected and sent to laundry.
Function: Provide crisp print quality by effectively cleaning press.
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Current Practices
Prod. A (current)
Current blankets,
Cloth wipers,
Current ink
Work Practice A
Leave solvent in
wipers
Leave solvent in
wipers
Laundry
Contact Person:
Potential Alternatives
Prod. B
Prod. C
(Special formulation)
Different blankets;
Disposable wipers;
Different ink
Work Practice B
Work Practice C
Reuse of solvent for other clean up.
Extraction of solvent from wipers
Trash
Drain
Hazardous Waste
Date Completed:
* Document these results in Section AE of the Company Manual Template.
Step 4: Set the Scope of the Evaluation
You have now reached a critical decision point in your evaluation of alternatives. You
must decide how detailed an evaluation is feasible. Keep in mind the cost of performance
testing as you choose alternatives to evaluate.
When you have selected alternatives to evaluate, place these alternatives in the
appropriate parts of your process map developed in Module 1. If necessary, create new
segments of the process map so that you can show how the alternative fits into your
process.
The following worksheets show the kinds of information that should be collected for each
set of alternatives to yield a decision about which option would be the most feasible, both
technically and economically, for your company to reduce its environmental impact.
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These tables will also give you the information needed to frame specific measurable
targets for your environmental programs.
Each alternative requires developing several kinds of information:
> health,
»• safety,
> environmental effects,
»• performance capabilities,
»• cost,
> effects on resource use, and
> regulatory concerns.
This information will help you integrate human health and environmental concerns into
your usual decision-making criteria of performance and cost. The following worksheets
are designed to help you organize this information in a way that makes comparisons
easier. The following sections take you step by step through the evaluation process.
Example 1
To develop alternatives on copier toner cartridges, your company would conduct
brainstorming sessions about the options for more use of electronic media within your
office and otherwise reducing the need to use the copier in your office activities.
Developing ways to cut down on copying can extend the life of toner cartridges and
reduce the volume requiring disposal. Steps that seem appropriate and desirable can be
recorded and incorporated into your targets. You could establish a dual goal of reducing
the volume of copying and 100% recycling of toner cartridges. Module 6 explains how
to develop operational controls to ensure reduced environmental impact. Module 7
explains how you can make your goals into an "environmental project."
Most of the alternatives for Example 1 do not require substantial changes and would be
implemented by designing guidelines for use and maintenance of the copier, i.e.,
operational controls. While these alternatives could be evaluated using the steps below,
we will not include this example in the sample worksheets. Example 2 provides a more
thorough example of the evaluation process, and we will focus on that.
Example 2
To develop alternatives to reduce air and water emissions caused by press washing, a full
evaluation would require research for each of the alternatives identified. (You may view
such an extensive analysis on the DfE Website. See Appendix G.) You may not have the
resources to do a full evaluation at this time, but you can research any of the alternatives
you choose. The point of identifying a range of alternatives is to let you choose the
options to evaluate with full knowledge of the range available to you, rather than in
response to preconceptions. For example, you could choose to evaluate one set of
alternatives now and another set at a later date as part of a continuing effort.
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Step 5: Evaluate Potential Human Health and Environmental Effects of
Alternatives 4
Worksheet 4-2 through 4-6 shows the kind of information needed to evaluate the
environmental effects of alternative products. Refer to Module 3 for explanation of the
elements. Worksheets 4-2 through 4-6 correspond to worksheets 3-1 through 3-5 in
Module 3.
Tip
The worksheets presented in this section are designed to be "one-size-fits-all." Unfortunately, not
all evaluations will be the "same size." Adapt these worksheets to suit the needs of your evaluation.
1 All information in worksheets is created for purposes of illustration and does not represent real data.
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Worksheet 4-2:a Alternatives Evaluation: Health, Safety and Environmental Potential Effects Information
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to
wipe down the press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered containers during
the work day and closed containers during after hours. Waste ink/solvent mixture is collected in drums and disposed of as hazardous waste. Wipers are collected
and sent to laundry.
Significant Environmental Aspect: Press cleaning
Alternative
Products
Baseline: Blend
A
acetone 25%
toluene 25%
Infor-mation
Sources
MSDS
Regulatory Data: b
Carcinogen?
OSHA Exposure limit?
Volatile Organic
Compound (VOC)?
Toxics Release Inventory
(TRI)?
Greater than 50% VOC —
all chemicals in blend
OSHA PEL, 8H TWA: 1000
ppm, burn in chemical
incinerator, EPAFIFRA
pesticide, Calif Prop 65
Repro Haz
Burn in incinerator, OSHA
PEL 8H TWA 200 ppm,
SARA 31 3 reporting, Calif
Prop 65 developmental
toxicity
Human Health Effects by Pathways
Acute and Chronic0
Inhalation
irritant, liver,
kidney,
toxic, liver, kidney
destructive to
tissues, lung
irritation, chest
pain, edema,
possibly fatal,
abortion, changes
in bone marrow
Dermal
irritant, eye
damage
toxic, extremely
irritating
Oral
toxic
Com-ments
Effects
may be
increasec
by
alcohol
consumpt
ion
Effects on Wildlife
and Other
Environmental
Effects d
Air
may contribute
to smog
may contribute
to smog
Water
?
?
Land
?
?
Worker Safety6
highly flammable,
vapor may flash
back, explosive,
combustive, may
produce carbon
monoxide or
carbon dioxide
Highly flammable,
combustive,
protect from
moisture
Rank
Human f
H
H
Env
?
?
70
-------
MEK25%
isopropyl
alcohol 25%
Special blend
B: vegetable
ester
Technologies
Work Practices
Recycling/
Reuse
Treatment
Centrifuge usec
to extract
solvent from
wipers,
using Blend A
Disposal
DfE Litho-
graphy
Project
DfE
Lithograph
y Project,
Case
Study 1
burn in chemical incinerator,
EPA FIFRA pesticide, OSHA
PEL8HTWA200ppm,
TSCASarule, SARA 31 3
reporting
may be disposal regulations
Less than 30% vocs
No regulations
Possible regulation about
using centrifuge, all other
regulations applying to
Blend A above
Contact Person:
irritant respiratory
system, central
nervous system
depression,
nausea, dizziness
headache, gastro-
intestinal, narcotic
effect
irritant nose &
throat, central
nervous system
depression,
vomiting,
headache, coma,
death
Low
Same as Blend A
irritant eyes, skin,
dermatitis
irritant eye,
corneal burns,
dermatitis
Low
Same as Blend A
large amounts:
headache,
nausea,
vomiting,
unconsciousnes
s, death
Low
Same as Blend
A
Same as
Blend A
may contribute
to smog
may contribute
to smog
?
Same as Blend
A
?
?
no aquatic
toxicity
Same as
Blend A
?
?
?
Same as
Blend A
Highly flammable,
combust ive,
protect from
moisture
Flammable,
reactive, may
produce carbon
monoxide and
carbon dioxide
No concerns
Same as Blend A,
also will need an
explosion proof
centrifuge
M-H
H
L
H
?
?
L
H
Date Completed:
a See Section AE of the Company Manual Template.
b Most Information for this column can be found on the MSDS.
c Partial information for these columns might come from the MSDS, but other resources may be needed. In particular, acute effects are usually reported on MSDS sheets. Chronic effects are
sometimes on MSDS sheets, but often will have to be found elsewhere.
d MSDSs usually do not include environmental effects.
e There may be information on the MSDS that would be useful for preparing your emergency preparedness plan.
f This rank is based on the potential effects of the chemical and not on the dose required to obtain those effects. For example, a person can drinka certain amount of Scotch. Drinking a large
quantity of Scotch, however, can be lethal. Therefore dose does make a difference ultimately in making a judgment. However, one can still make a qualitative ranking about whether Scotch,
cola, water, milk or juice have beneficial or negative impacts. For more discussion of the role of "dose" see the Hazard Guide on the DfE web site.
Note: For more information on risk related data, including methods for interpreting quantitative toxicity values, refer to the risk Guide provided on the DfE Program website. The data on this table
were constructed for purposes of illustration and do not represent real data.
71
-------
Worksheet 4-3:a Alternatives Evaluation: Exposure to Chemicals and Materials
/lanual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down
he press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered containers during the work
lay and closed containers during after hours. Waste ink/solvent mixture is collected in drums and disposed of as hazardous waste. Wipers are collected and sent
o laundry.
Significant Environmental Aspect: Press cleaning
Alternative
Products
iaseline:
ilend A
acetone
'oluene
/1EK
sopropyl
Icohol
ilend B:
egetable ester
Quantity Used per
Time Period
24 oz. Per day for
cleaning press
same
same
same
1 2 oz per day for
cleaning press
Exposure Time
Duration**
10 minfor
cleaning;
all day for wipers
in open bins
same
same
same
10 min for
cleaning;
all day for wipers
in open bins
Frequency
5 times per day for
cleaning
same
same
same
5 times per day for
cleaning
Personal Protective
Equipment (PPE)
Face shield, chemical
safety goggles, chemical
gloves, mechanical
exhaust, NIOSH-OSHA
respirator
Above, plus chemical
fume hood
Same as acetone
Half mask respirator,
gloves, local exhaust,
safety goggles, rubber
apron, boots, impervious
clothing
None
Pathway
Human: Inhalation,
Dermal, Oral
All for workers,
inhalation for
community
All for workers,
inhalation for
community
All for workers,
inhalation for
community
All for workers,
inhalation for
community
all
Environment: air,
water, land
Air, water
Air, water
Air, water
water
Rank Exposed Groups
Workers
H w/o PPE
M w/o PPE
(less due to
less volume
used and less
volatile mix)
Community
H (laundry
releases)
M
Environment
M
L
72
-------
'echnologies
Vork Practices
Jecycling/
Jeuse
'reatment
lentrifuge
assuming
ilend A)
)isposal
8 oz recovered per
day- reduce
environmental
releases by 1/3
10 min while
putting wipers in
centrifuge
1 time per day
Gloves
lontact Person:
Inhalation, dermal
N/a
M w/o PPE
M (possibly some
fumes from
venting centrifuge]
L
Date:
ngredient in chemical product, use quantity of chemical not product, i.e., apply the percentage that the ingredient makes up of the product.
ow many minutes or hours per day is the chemical or material used?
=: All data are for purposes of illustration and do not represent real data.
73
-------
Worksheet: 4-4: Alternatives Evaluation: Community Issues
Significant Environmental Aspect: Press Cleaning
Alternative
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Community Issues (List)
no additional issues
Contact Person:
Rank
Date:
Worksheet: 4-5: Alternatives Evaluation: Natural Resource Use
Significant Environmental Aspect: Press Cleaning
Alternative
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Natural Resources Used (List)
no additional issues
Contact Person:
Rank
Date:
74
-------
Worksheet 4-6:a Alternatives Evaluation: Criteria to Determine Environmental Impact
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth
wipers to wipe down the press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered
containers during the work day and closed containers during after hours. Waste ink/solvent mixture is collected in drums and disposed of as hazardous
waste. Wipers are collected and sent to laundry.
Significant Environmental Aspect: Press Cleaning
Alternative
Products:
Blend A (Baseline)
Blend B
Technologies
Work Practices
Recycling/Reuse
Treatment: Centrifuge
Disposal
Regulatory
Concerns
H
L
M
Chemical and Material Risk
Worker
Eff/Expb
H/H
L/M
H/M
Community
Eff/Expb
H/H
L/M
H/M
Contact Person:
Environment
Eff/Expb
?/M
L/L
?/L
Worker
Safety
H
L
H
Other
Community
lssues:c
n/a
n/a
n/a
Natural
Resourcesd
n/a
n/a
n/a
Overall
Ranking
H
L
M-L
Date Completed:
Preferred
Alternative?
Y/N
yes
yes
Corresponds to SEA-01 in Company Manual Template.
Effects/exposure
Noise, traffic, light, odor.
Include such items as resource use, solid waste, energy use.
75
-------
Step 6: Evaluate the Performance of Alternatives
Evaluating the performance of your alternative chemical products requires several steps,
as described below. Performance evaluations can be expensive to perform. Consider the
cost of the evaluation when deciding how many and what kind of alternatives to test.
Tip
Cost data for your cost evaluation should be collected during the performance evaluation There
may be more uncertainty in the cost data if you wait to develop it until after the performance
evaluation. See Step 8 for information on what kind of data will be needed for your cost evaluation.
Describe the baseline. The baseline is the standard chemical, activity, or technology that
is currently used. The baseline also includes the boundaries of the baseline, its process
steps and how they are performed. This ensures that (1) a similar process is used to
evaluate the performance of the baseline and alternatives where possible, or (2) when a
different process is used due to the nature of the alternative (e.g. technology), differences
will be noted and understood. The alternatives will then be compared to this baseline.
Example: The baseline for press washing is manual cleaning of press using a chemical
press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl alcohol)
and cloth wipers to wipe down the press, with no restrictions on the amount of cleaner or
number of wipers used. Chemicals and soiled wipers are kept in uncovered containers
during the work day and closed containers during after hours. Waste ink/solvent mixture
is collected in drums and disposed of as hazardous waste. Wipers are collected and sent
to laundry.
Tip
See Appendix C for sample performance evaluation worksheets from the [)fE Printing Project.
Identify the most important performance traits for the selected process area Some
sample performance traits include the following: how well does it work, how long does it
take, how easy is it to use, and how easy is it to install?
Example: The most important performance traits for press wash are that it work quickly
to cut ink, require minimal wiping to remove any oily residue, dry quickly, and not
adversely affect print quality.
Determine how the alternatives will be compared with the baseline. One example of
a quantitative comparison is measuring the time it takes to complete a task. One example
of a qualitative comparison is using a scale, such as ++ representing "much more
favorable than the baseline."
16
-------
Example: We will use a comparison scale from -2 to +2, where -2 represented "much less
favorable than the baseline," +2 represented "much more favorable," and a 0 represented
"no difference with the baseline."
Select the operating conditions for testing the baseline and alternatives and conduct
the evaluation. The operating conditions should be realistic and consistent for the
baseline and alternatives. If you cannot test an alternative at your facility (e.g., new
equipment), have the supplier provide off-site service or performance test data.
Conditions should be as similar as possible for each test, or the results will not be
comparable. Examine work practices as well to ensure similar application from test to
test. Other elements that may affect testing include room temperature and humidity.
Make a list of what things might affect your test results and try to make sure that they are
similar for each test.
Example: Evaluate the baseline and alternatives using the same size printing run, the
most commonly used ink formulation, the same application procedures, and the same
printed image.
An evaluation example is shown in Worksheet 4-7.
77
-------
Worksheet 4-7:* Performance Comparison of Alternatives
Significant Environmental Aspect: press cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl
ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no restrictions on the
amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept in uncovered
containers during the work day and closed containers during after hours. Waste ink/solvent mixture is
collected in drums and disposed of as hazardous waste. Wipers are collected and sent to laundry.
Function: ensure crisp print quality by effectively cleaning press
Blend A (baseline)
Product B
Technologies
Work Practices
Recycle/ Reuse
Treatment:
Centrifuge to
recover Blend A
Disposal
How well it works
0
0
(Did not show much
difference from
baseline)
+
(demonstrates that
worked well, but is not
comparable to products
above)
Time
0
0
"+"
Contact person:
Ease of use
0
0
"+"
Overall Performance
Evaluation
0
0
"+"
works well to recover
solvent
Date Completed:
*Document these results in Section AE of the Company Manual Template.
Step 7: Evaluate what regulations may be triggered by using each alternative
For each alternative being considered, make sure you understand the applicable
regulations. This may influence your choice of alternatives. Identify what management
controls might be required by these regulations. Also consider what additional cost might
be attributed to the regulation. Some of the costs associated with using a product or
process may be attributable to a regulation triggered by using that product or process.
These would be the regulatory cost and should be included on Worksheets 4-8 and 4-9.
78
-------
Worksheet 4-8:* Regulatory Comparison of Alternatives
Alternative
Product
Blend A
Blend B
Technologies
Work Practices
Recycle/ Reuse
Treatment
Centrifuge
Disposal
Applicable
Regulations
same as
Worksheet 4-2
none
possible local fire
regulations
Required Controls
same as
Worksheet 4-3
none
May not be allowed
Contact Person:
Regulatory Cost
Items 1
SARA reporting, PPE,
Chemical fume
hoods, fire controls
none
Overall
Regulatory
Concerns
Evaluation
H
L
H
Date Completed:
*Document results in Section AE of the Company Manual Template.
1 Include: paperwork triggered, reporting requirements, cost of controls, personal protective equipment and any
other costs that may be attributed to regulations associated with using that product or process. It is not
necessary to quantify on this table. See Step 8 and Appendix F for more ideas.
Step 8: Evaluate the cost of the baseline and alternatives
Determine the cost of each alternative, including: raw materials, labor, disposal costs, (all
from Step 6) and regulatory costs (from Step 7). Include all the cost categories in the
baseline and the alternatives. It's important to document all costs, even those that are the
same for the baseline and for the alternatives. Documenting all costs gives you a
reference later to answer questions and to support further evaluations. Figure 4-a shows
possible costs associated with regulations that may be hidden in overhead in your
company's accounting system. Be sure to include these hidden costs when completing
the worksheets.
See Appendix F for more discussion of environmental cost accounting.
79
-------
Figure 4-a. Examples of Environmental Costs Incurred by Firms'
Regulatory Upfront Voluntary
(Beyond Compliance)
« Notification Site studies » Community relations,'
» Reporting Site preparation outreach
* Monitoring/testing Permitting * Monitoring/testing
• Studie&'mcideling R&O » Training
« Remediation Engineering and * Audits
• Recordteeping procurernert . Qualifying suppliers
* Plans • Installation • Reports (e.g., annual
. Trainfng ' ~ 7. ~ ~ ~~ ~ ~ ~ environmental reports)
C~onv&nt tofiar Costs
* [nspief.ions •MM"'*"""'"' Minna „ Insurance
. Manifesting Capital equipment . Planning
« Labeling Materials . Feasibility slucfies
* Preparedness Labor „ Remediation
, Protective equipmenf Supplies . Recycling
« Medical surveillance Utilities , Environmental studies
. Environmental Structures . R&D
insurance ^ ^Salvage value . Habitat and weHand
« Financial assurance Back-End protection
* Pollution contra) • Landscaping
« Spill response » Closure/ « Other environmental
* Stormwaler decommissioning projecls
management Disposal of inventory . Financial support to
* Waste manageinenl Post-dosurecane environmental groups
* Tanes/fees Site survey andtor researchers
^•^^S^^^g^W??!^^^^
Future compliance costs Remediation • Legal expenses
Penalties/fines Property damage » Natural resource
Response to future Personal injury damages
releases damage • Economic loss
darnaggs
__««y<
gy
Corporate image • Fieiationship wtth • Relationship witrt
Relationship with professional staff lenders
cuslomera . Relationship with * Relationship wilh
Relations hips with workers host co m m u n ities
investors « Relationship with » Relationship with
Relationship with insurers suppliera regulators
Taken from "An Introduction to Environmental Accounting as a Business Management Tool: Key Concepts and
Terms," EPA 742-R-95-001.
Evaluating the cost of the baseline and alternatives requires several steps, as described
below.
Annual operating costs
Collect annual operating costs for your baseline and alternative. Use Worksheet 4-9a to
help you collect cost information. Review Worksheets 4-2 and 4-8 to assist you in
evaluating environmental costs. Be as thorough as possible when considering costs, but
don't worry about how you classify costs. For example, you may wish to consider
personal protective equipment as a regulatory compliance cost, especially if its use is
required by regulations. Alternatively, you may wish to classify all protective equipment
as "materials." Use Worksheet 4-9a to record operating costs.
80
-------
Worksheet 4-9a: Annual Operating Costs
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl
alcohol) and cloth wipers to wipe down the press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals
and soiled wipers are kept in uncovered containers during the work day and closed containers during after hours. Waste ink/solvent
mixture is collected in drums and disposed of as hazardous waste. Wipers are collected and sent to laundry.
Alternative
Products
Blend A: Baseline
Blend B
Technologies
Work Practices
Recycle/
Reuse
Treatment:
Centrifuge
Disposal
Materials
$24,320
$6,320
n/a
Direct
Labor
$2,075
$2,500
$420
Utilities
n/a
$200
Waste
Management
$7,000
$0
$6,200
Contact person:
Regulatory
Compliance
$2,100
$0
$2,100
Insurance
$0
$0
$200
Future Liability
possible medical
suits
$0
Total
Operating
Costs
$35,495
$8,820
$9,120
Date:
81
-------
Potential Annual Revenue Effects
Environmental projects may save you money not only by reducing your costs, but
also by generating revenues. For example, an alternative may increase your
product throughput because the activity takes less time to complete, or product
quality may be improved enabling you to sell more of your product. The
alternative may also let you recover materials previously disposed of, and generate
revenues through sales of the reclaimed material (such as recovering metal scrap
which can be sold to scrap dealers). These annual revenue effects should be
considered using Worksheet 4-9b. If these potential revenues are difficult to
quantify, you can consider them qualitatively in your evaluation by making a note
in the last column of Worksheet 4-9d. In general, a reduction in materials needed
would show up on Worksheet 4-9a: Annual Operating Costs. In this example, the
reduction in press cleaning solvent needed due to switching to a less volatile blend
(much less lost through evaporation during use) does show up in the first column
of Worksheet 9-a. The revenue effects shown in Worksheet 4-9b are caused by
reusing the solvent recaptured by the centrifuge for other cleaning operations (not
press cleaning). In other words, the centrifuge saves on the purchase of other
kinds of cleaning solvents than the ones being considered for press cleaning.
82
-------
Worksheet 4-9b: Potential Annual Revenue Effects
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone,
toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the
press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals
and soiled wipers are kept in uncovered containers during the work day and closed
containers during after hours. Waste ink/solvent mixture is collected in drums and
disposed of as hazardous waste. Wipers are collected and sent to laundry.
Alternative
Products:
Blend A or B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Product
Throughput
none
0
Product
Quality
none
0
Reuse of or
Sales of
Recovered
Materials
none
$34,000
Total Revenue
Effects
0
$34,000
Contact Person:
Date:
Initial Investment Costs
Collect initial investment costs for each alternative. If any of your alternatives will
require an investment in new equipment, you will need to consider these costs.
These not only include capital costs, but also other one-time costs accompanying
your investment, such as installation costs or new equipment training. Use
Worksheet 4-9c to help you collect these costs.
83
-------
Worksheet 4-9c: Initial Investment Costs*
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene, methyl ethyl ketone, and isopropyl
alcohol) and cloth wipers to wipe down the press, with no restrictions on the amount of cleaner or number of wipers used. Chemicals and
soiled wipers are kept in uncovered containers during the work day and closed containers during after hours. Waste ink/solvent mixture is
collected in drums and disposed of as hazardous waste. Wipers are collected and sent to laundry.
Alternative
Products
Blend A or B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Purchased
Equipment
none
$15,000
Utility Systems/
Connection
none
0
Planning/
Engineering
none
$2,000
Site
Preparation
none
$500
Contact Person:
Construction/
Installation
none
0
Start-up/
Training
none
$200
Permitting
none
Depends on
local
regulations
Other**
none
0
Total Inv.
Costs
none
$17,700
Date:
*Typically there are no investment costs for your "business as usual" baseline.
**"Other" costs potentially include land or building purchases, contingency to cover unforeseen expenses, and investment in initial inventory (also
known as working capital). For further description of these costs, see Appendix F
84
-------
Tip
Remember that your accountant can assist you in making these calculations.
If a change in your processes or activities will affect your costs and savings over
many years, the analysis should look at long term costs and savings. A critical
component of assessing a project where costs and savings may occur over several
years is incorporating the notion that the value of money changes over time -
commonly called the "time value of money." Most businesses prefer to have
money sooner rather than later. If you have money today, you have the
opportunity to use it now to grow your business. See Appendix F for more
information on how to obtain the net present value of your initial investments, if
you wish to make that calculation.
Cost Comparison
Use Worksheet 4-9d to list and rank the results of each cost table.
Worksheet 4-9d: Cost Comparison of Alternatives
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of
acetone, toluene, methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to
wipe down the press, with no restrictions on the amount of cleaner or number of
wipers used. Chemicals and soiled wipers are kept in uncovered containers during
the work day and closed containers during after hours. Waste ink/solvent mixture
is collected in drums and disposed of as hazardous waste. Wipers are collected
and sent to laundry.
Alternative
Products
Blend A
Blend B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Total
Operating
Costs
$35,495
$8,820
$9,120
Total
Investment
Costs
$0
$17,700
Contact Person:
Annual
Revenue
Effects
$0
$34,000
Rank
H
L
L
Date:
Document results in Section AE of the Company Manual Template.
85
-------
Step 9: Evaluate Results
Use Worksheet 4-10 to compare performance, regulatory considerations, cost, and
environmental effects for alternatives.
Worksheet 4-10:* Evaluation of Alternatives
Significant Environmental Aspect: Press Cleaning
Baseline: Manual cleaning of press using a chemical press cleaner (a blend of acetone, toluene,
methyl ethyl ketone, and isopropyl alcohol) and cloth wipers to wipe down the press, with no
restrictions on the amount of cleaner or number of wipers used. Chemicals and soiled wipers are kept
in uncovered containers during the work day and closed containers during after hours. Waste
ink/solvent mixture is collected in drums and disposed of as hazardous waste. Wipers are collected
and sent to laundry.
Alternative
Chemical
Product A
(current
baseline)
Product B
Technologies
Work Practices
Recycle/Reuse
Treatment:
Centrifuge
Disposal
Performance
Rank1
0
0
"+"
Contact Person:
Regulatory
Considerations
Rank2
H
L
H
Cost Rank3
H
L
L
Environmental
Effects4
H
L
M-L
Overall
Evaluation5
Poor due to
effects
Good due to
effects &
cost
Good due to
effects &
savings
Date Completed:
*Document results in Section AE of the Company Manual Template.
1 Take from Worksheet 4-7 Performance Comparison of Alternatives.
2 Take from Worksheet 4-8 Regulatory Comparison of Alternatives.
3 Take from Worksheet 4-9d Cost Comparison of Alternatives.
4 Take from Worksheet 4-4: Criteria to Determine Environmental Impact.
5 Rank the desirability of each alternative. This is a judgment call.
Note: For more information on the methodology for comparing alternatives, refer to both the DfE
Website and the Cleaner Technologies Substitutes Assessment, A Methodology Resource Guide,
DfE, U.S. EPA 744-R 95-002, Dec. 1996.
86
-------
Interpretation of Results
Performance
The rank of "0" for product A reflects that it is the baseline. The rank of "0" for
product B indicates that it's performance is very similar to the baseline. The +
shown for the centrifuge shows that it performs well, but is not directly
comparable to the products above.
Regulatory Considerations
Ranks show that product A has many regulations associated with the chemicals it
contains, but product B chemicals have little or not regulations. The centrifuge is
rated high because some states have regulations that may prohibit the use of
centrifuges for recovering solvent from wipers. Also, the explosive nature of
Product A ingredients would affect the type of centrifuge used. If product B were
used with the centrifuge, the regulatory concern might not apply.
Cost
The rankings show the high cost associated with using product A compared to the
low cost of using product B. In addition, the low cost rank for the centrifuge
reflects the cost savings affected by re-using reclaimed solvent.
Environmental Effects
The high rank for product A reflects the serious impact of the chemicals contained
in it, while the low score for product B reflects the low impact of that product's
chemicals. The M-L rank for the centrifuge reflects the reduction in use of solvent
with some continuing exposure to the solvent for workers who transfer the wipers
from bins to the centrifuge. There would also be some community exposure from
venting the centrifuge out doors. In addition, it reflects the concern with the
possibility of explosion of the centrifuge while extracting these solvents.
Conclusion
From both a cost and environmental perspective, switching to product B and using
the centrifuge would make sense.
Remember, like all other aspects of your IEMS, evaluating SEAs and alternatives
is an ongoing process. What you cannot accomplish this year, you can plan on
doing next year. Take it step by step to avoid being overwhelmed.
87
-------
Module 5: Setting Targets And Measuring
Success
Tip
State your target in terms of the environmental improvement to be achieved, rather than
the means of achieving it. For example, "reduce air releases of X" rather than "substitute
X." The desired improvement may continue for a long time, but the means may change with
circumstances.
For each objective you set for your significant environmental aspects in Module 3,
you will set a corresponding target. A target is a detailed performance
requirement. Using the Module 4 press cleaning example, assume that the
alternatives evaluation showed that the Company could reduce air and water
releases both in the plant and at the laundry by substituting Product B, and that this
shows an acceptable level of performance and cost. The environmental target then
could be stated as follows:
Reduce air releases of regulated chemicals in press cleaner by 80% in the
plant, and reduce the volume of regulated chemicals on used wipers by 40%
by the end of a 12-month period through product B substitution and
improvements in work practices.
Tip
Be sure to consider what operational controls may be needed for any new processes. Refer
to Module 6 for help.
The evaluation showed you what is possible in terms of reducing air and water
releases, and also showed you the best means to accomplish that objective. When
you frame your target consider how you will measure the results. You will need to
establish ways of measuring your progress in meeting the targets, in order to both
evaluate your process and document success. Time frame is also important. How
long will it take you to implement the program, which includes training people,
acquiring new product, phasing out old product, acquiring equipment, defining
new work procedures for several steps of the production process, and establishing
operational controls for changed processes?
Measuring Results
Some say that "an EMS without an effective monitoring and measurement
program is like driving at night without the headlights on - you know that you are
moving but you can't tell where you are going!"5
Environmental Management System: An Implementation Guide for Small and Medium-Sized
Organizations, NSF International, Ann Arbor, Michigan, November 1996, p.49.
88
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For each target, identify a measurement for success, e.g. volume of waste or
energy used or percent of cartridges recycled (see Worksheet 5-1). These
measurements, also called performance indicators, should be:
simple and understandable,
objective,
verifiable,
linked to production, and
relevant to your objectives.
Tip
Measuring and evaluating environmental performance is an ongoing process.
Below are some sample performance indicators:
»• tons of SO2 released per unit of electricity produced,
»• pounds of hazardous substance "X" emitted per unit of product, or per
dollars of sales, and
»• percentage reduction in the discharge of a material in a given year versus
that in a base year.
Measure changes in the aspect (e.g., reduced waste) with respect to production or
sales rather than by itself in order to evaluate environmental improvement.
Changes in the aspect can be caused by changes in the sales volume with no real
environmental improvement. Each measure should be an indicator of where
problems may be occurring in the process. Worksheet 5-1 is designed to assist you
in tracking your measurement indicators.
Worksheet 5-1: Environmental Performance Measurement Indicators
Aspect
Waste
Toner
Cartridge
Objective
Recycle
cartridges
Indicator
Number bought
/ number
recycled
Date
Checked
monthly
Contact Person:
Who Checked
Office
manager
Result
1 missing
Corrective
Action
Discuss
problem with
copier
maintenance
person
Date Completed:
89
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In the toner cartridge example, the performance indicators might be the number of
toner cartridges used and the number sent for recycling. In the case of the air
emissions from the press cleaning, measurements could include:
> amount of press cleaner used per 1,000 images printed,
> amount of press cleaner saved over a selected time period,
»• amount of press cleaner used at each press per 1,000 images printed,
> amount of fluid collected from wipes before sending them to the laundry,
and
> levels of solvent in water reported by POTW associated with laundering
this company's press wipes.
You may be able to think of more. It is important to recognize that each
"indicator" measures something different. The first one measures "input" with
respect to "output." This ratio is important because changes in use of press
cleaner can be caused by fewer print runs, as well as more efficient use of the
cleaner during the production process.
Experience has shown the importance of setting up measurement criteria to assess how things
are going.
To be sure that you are measuring success rather than simply reduced production,
be sure to include output in your measurement criteria. You may also need to
include more than one kind of measurement to understand the results and be able
to evaluate the process.
The second measurement allows you to compare a current time period with
previous time periods with respect to press cleaner use, which could help to
indicate efficiencies in use, such as better work practices. Again, this comparison
should not be made without reference to output over the same time period.
Number three also provides a comparison among different work practice methods.
Number four shows how much press cleaner is being reused and the reduction in
burden on the laundry, and number five shows the success in reducing water
releases at the laundry. In a sense, number five is the "acid test" of whether your
goal is being met. Without success here, the achievement of the targets within
your plant would be meaningless because the original problem was the water
releases from the laundry caused by the wipes. Each of the other measurements
shows success in the achievement of targets that are steps toward your final goal.
Also, some of these measures can be used to determine cost savings related to
particular steps and to the overall goal. Most important, each measure is an
important indicator of where problems may be occurring in the process.
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If you use special equipment to measure environmental performance, it is
important that you maintain and calibrate the equipment on a regular schedule.
Again, designate a person to be responsible for this task, provide appropriate
training on maintaining the equipment, and document the calibrations schedule.
Worksheet 5-2 provides a sample log for calibration.
Worksheet 5-2: Calibration Log
Indicator
Measurement
Method
Contact Person:
Equipment
Used
Equipment
calibrated:
date/method
Date Completed:
Determining Causes of Problems
You will need to establish a method to determine the causes of failing to meet a
target. In some cases, the cause might not be difficult to understand. Other times,
however, the cause might not be obvious.
One method is called "root cause analysis." This method can be applied here to
identify causes for not meeting targets. You can also use it to determine the
possible causes of a potential impact. You should determine the root cause of
each of your significant aspects.
Tip
For more information on constructing a "Cause and Effect Diagram/' go to www.sytsma.com/
tqmtools.cause.html
The root cause diagram, shown in Figure 5-a, will help you organize your thinking
when you analyze your company's potential for environmental impact. This
analysis can be done by one person or by a group, with one person writing down
the ideas produced. Each diagonal line represents a main component of the
production process. Your company may have different or additional components
(for example, "disposal") beyond those represented here. Each horizontal line
stemming from the diagonal represents an important element contributing to each
of the main components. For example, elements of work practices might
contribute to the labor component. This diagram is simply a device to help
organize the analysis of the cause of potential environmental impacts. Use it if it
helps, but don't get hung up on trying to make it work.
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Figure 5-a. Root Cause Diagram
\
ell"1
Q8 §.§.
fne = importa
itributing to the
ment
§18
i jj
. poor communication, - E
»• faulty or missing procedures, Q
> equipment malfunction (or lack of maintenance JP
> lack of training =
»• lack of understanding (of requirements), or . ~ -
»• failure to enforce rules.
c E
Be sure that you have considered these possibilities in ^our environmental impact
analysis. c w
CD
92
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Taking corrective action
Once you document a problem with respect to meeting targets, the company must
be committed to resolving it. Take action as quickly as possible. First, make sure
assigned responsibilities for actions and schedules are clear.
Employees in the shop may recognize the need for corrective action and provide
good ideas for solving problems. Find ways to get them involved in the
improvement process. It's important to determine whether a lapse is temporary or
due to some flaw in the procedures or controls. For this reason, communicate any
findings to employees, and provide any follow-up training for changes in the
procedures that may result. The following is a checklist to help complete
corrective action. Have you:
Identified the problem(s)?
Identified the cause(s)?
Come up with a solution for each?
Implemented the solution(s)?
Documented the solution(s)?
Communicated the solution(s)?
Documented the action(s)?
Worksheet 5-3 is a sample Corrective Action Notice that will assist in
documenting the resolution process.
Worksheet 5-3:* Corrective Action Notice
Issue Date:
Solution Due
Date:
Requested by:
Issued to:
Problem Statement:
Most Likely Causes:
Suggested Solutions:
Action Taken:
Measured Results:
Corrective Action Closed by:
Date:
Contact for Notice: Date completed:
'Report results on TCA-01 in the Company Manual Template.
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Module 6: Developing Operational Controls
As mentioned at the end of Module 3, for every environmental aspect your
company determines to be significant (SEA), it is desirable that one of two actions
be taken. Action may include either:
»• Evaluating alternatives to make changes in processes in order to reduce the
potential for impact, or
> Writing operational control procedures for activities or steps in a
production process where the potential impact may be well controlled.
Tip
ISO 14000 requires action to be taken on each SEA. If you are not pursuing ISO
certification at this time, you could focus on selected SEAs.
In writing operational controls for an SEA, determine the environmental
objectives desired, set targets for performance and write operational controls
(procedures) to ensure that the objective will be met. Your company may already
have procedures in place. These should be reviewed to be sure they are consistent
with EMS objectives. This module describes the process for setting objectives,
developing operational controls, and creating the organizational support for
ensuring that those objectives are met.
Tip
Objective: Overall environmental goal, based on the environmental policy, which is quantified
where practicable.
Target: Detailed performance requirement based on an environmental objective.
If you determine that process changes should take place in order to address an
SEA, the IEMS emphasizes the need to evaluate alternatives before setting targets.
Module 4 describes the process for evaluating alternatives.
The following are some examples of the kind of activities that might be improved
with operational controls:
> management/disposal of wastes,
> approvals for using new chemicals,
»• storage & handling of raw materials and chemicals,
»• wastewater treatment,
> building and vehicle maintenance,
> transport,
»• operation and maintenance of equipment,
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management of contractors,
marketing and advertising, and
acquisition or construction of property and facilities.
Experience has demonstrated the importance of written procedures and thorough employee
preparation and involvement.
The process of setting targets and ensuring their success has several steps which
are discussed in more detail below. These include:
> determining the possible causes of potential impact,
> setting measurements for the desired environmental performance,
»• drafting operational controls,
> designating persons responsible for maintaining operational controls and
for reviewing the success of the controls,
»• developing training for persons assigned responsibility,
> taking corrective action when objectives are not met, and
> establishing a DfE environmental review for new processes and products.
1. Determine the possible causes of potential impact
For all of your significant environmental aspects, you should determine the cause
of the impact. In some cases, the cause might seem obvious. However, sometimes
the root cause of the problem is not the most obvious cause. Use the "root cause"
analysis described in Module 5 to help your EMS team get to the cause of the
impact prior to developing your operational controls.
2. Set targets and measurements for environmental performance
As discussed in Module 5, you need to set a target for each objective and establish
measurements for environmental performance indicators. The targets should
reflect correction of the root cause identified above. Measurement indicators
should document changes in the causes identified above. Using the indicators, you
can determine if your operational controls are helping you meet your objectives.
3. Draft operational controls
Next, for each significant aspect which you have decided to address with
procedures, draft operational controls. (For some aspects, you may choose to
make process changes instead, as explained in Module 4.) Review each of the
causes identified in your root cause analysis that would contribute to the
95
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environmental impact of a significant aspect. Address the causes by drafting
operational controls.
Tip
DfE Partner Jeff Adrian of the John Roberts Company has provided operational control
examples. See the Case Study at the end of this module.
Operational controls may already exist for some of the activities associated with a
significant aspect. Identify which aspects have written procedures that describe
operational controls, and which aspects will need to have procedures developed.
In some cases the procedures that you have in place to comply with environmental
and health and safety regulations may be useful to meet your IEMS objectives.
Worksheet 6-1 below will help you track which aspects will require procedures to
be developed.
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Worksheet 6-1:* Operational Control Procedures
Significant
Environ-
mental
Aspect
Waste Toner
Cartridges
Indicator(s)
Number of
Toner
Cartridges
recycled
compared to
number
purchased
Associated
Job
Functions
Copy machine
maintenance
Existing Operational
Control Procedures
none
Operational Control
Procedure
Development/
Modification Needed
yes /new
Contact Person:
Responsible
for
Developing
Office manager
Responsible
for Checking
Office manager
Location
Posted
Over copy
machine
Date Completed:
"Corresponds to OC-01 in the Company Manual Template.
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It is important to involve the people who will implement the procedures in drafting
them. You can accomplish this in several ways:
»• Meet with workers and have them describe current procedures. Discuss the
environmental objective desired, and how to write operational controls
(procedures) to ensure that the objectives will be met.
> Or, have someone (possibly an intern) interview the workers to establish
current (undocumented) procedures; then draft (or revise) operational
controls. Have the workers and a manager review the draft.
»• Keep the written operational controls simple and concise. They should
include the appropriate actions, precautions, and notifications required.
Focus on activities that may lead to significant impacts and avoid getting
overwhelmed by trying to control every activity and process.
4. Designate responsibility for maintaining and reviewing controls
Designate those people responsible both for maintaining the controls and for
reviewing them to ensure that procedures are followed and deviations corrected.
Generally, the workers responsible for the significant aspect under consideration
will be responsible for implementing the operational controls. The immediate line
manager would most likely be responsible for regular review of the controls. It is
helpful to list those people responsible for each set of procedures. Worksheet 6-2
will help with documenting responsibilities.
Worksheet 6-2: Operational Control Responsibilities
Significant Aspect
Waste toner cartridges
Procedures (list)
-save package from
new toner cartridge
-place waste cartridge
in package
-follow supplier
instructions for return
of used toner
cartridges
Contact Person:
Responsible for
maintaining controls
Copier maintenance
person
Date Completed:
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5. Develop training
Tip
The training described here relates to operational controls. More information on training
for environmental awareness and regulatory training can be found in Module 8.
Achieving success in meeting environmental objectives for each significant aspect
depends upon making sure that each person responsible for maintaining or
reviewing controls has received adequate training. After operational controls are
drafted, develop a training program that ensures everyone understands both the
controls and their own role in ensuring that they are followed. Training can
include on-the-job training. Worksheet 6-3 identifies some of the decisions to be
made when setting up a training plan. This worksheet helps you identify, plan for,
and track the training needs of your employees. Include this training with any
general environmental training to create an integrated training plan for your IEMS.
See the John Roberts case study at the end of this module for an example of
training materials one printing facility prepared to support an operational control.
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Worksheet 6-3: Training Plan for Operational Controls
Aspect
Waste Toner
Cartridges
Procedures
For Recycling
Person
Responsible
for Carrying
Out
Copier
Maintenance
Person
Training
Needs
Recycle
Procedure
How to
Train
Office
Manager
Explain
When/ Length
When assigned
copier
maintenance
duties/ 20 min
Contact Person:
Budget
N/A
Completion
Date
Within one
week of taking
job
responsibility
Person
Responsible
for training
Office
Manager
Date Completed:
100
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6. Take corrective action when objectives are not met
Tip
If the problem cannot be resolved, review Module 4 to determine a need for evaluating
alternatives.
Take action to correct failures in operational controls as quickly as possible to
meet environmental objectives. Use the process in Module 5, to take appropriate
corrective action when your operational controls are not helping you meet your
objectives.
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CASE STUDY FROM THE JOHN ROBERTS COMPANY
Example of an Operational Control For Cleaning Press
Blankets
Steps
1. On the first turn of the cylinder, use a solvent saturated
shop towel pad (as is the current practice) to loosen and
remove most of the ink from the blanket's surface.
2. With a second shop towel pad that has been first dipped into
water and then wrung out, remove the balance of the ink from
the blanket's surface on the second turn of the cylinder.
3. Start the press as before.
Critical points
By not using water on the first turn of the cylinder, the full
strength of the Press Wash is available to move the ink. So, do
not blend down Press Wash with water.
It is not necessary that the blanket be absolutely dry after the
second turn of the cylinder. Rather, a slight film of water
(think of how the sidewall of your car's tires look after just
washing the car) will not be problem on startup of the press.
The first few sheets will very easily carry this moisture off.
By using a second pass with a water wipe, clays, starch and paper
dust are better removed. A water wipe should be easier to slide
across the blanket than a drywipe.
Care does need to be taken in just one respect, and that is in
the area of the blanket cylinder's grippers. Excess Press Wash
or moisture there has the potential of being spun off the
cylinder onto the stock if not removed.
Towel usage
When the solvent shop towel pad is dirty, discard it in the
safety cans as before.
The water wipe shop towel pad now becomes the solvent shop towel
pad and a new pad (from clean shop towels) is made up for the
water wipe step.
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CASE STUDY FROM THE JOHN ROBERTS COMPANY
Example of Training for Operational Controls
As part of training, the Director of Environment and Safety
distributed additional materials to all employees involved with
press blanket cleaning. Because this operational procedure
documents a new and standardized method, there were many
questions from employees. The director prepared additional
written information, including: 1) a background sheet telling
employees why this procedure was important, and 2) a Q&A list
addressing issues that had come up in training.
These materials and the associated training were done to ensure
that employees knew why the procedure was needed and what part
they were to play in consistently implementing it.
Training for Press/Blanket Washing
New Procedures Background
Background
As some of you may already know, the elimination of Blanket Wash
2215 is necessitated by the tightening of environmental
regulation.
Blanket Wash 2215 is a blend of solvents that includes the
chemical 1,1,1 Trichlorethane (TCA), a chemical that has been
banned internationally by the Montreal Protocol..
The reason for this is that TCA is an upper level ozone depleter,
destroying the ozone layer that shields us from the harmful
effects of the sun's ultraviolet radiation.
While still being manufactured today, TCA is being taxed at ever
higher rates until it will no longer be manufactured in 1995.
Additionally, because Blanket Wash 2215 evaporates readily to the
atmosphere, the other chemicals in the blend contribute volatile
organic compounds (VOC's), which when combined with nitrogen
oxides (from the burning of fossil fuels) and sunlight, leads to
the formation of smog in the lower levels of our atmosphere.
The replacement for Blanket Wash 2215 will be the use of the much
less volatile, and thus less harmful, Press Wash.
Because Press Wash solvent works at a different rate that the
discontinued Blanket Wash 2215, a new cleaning procedure will
have to be followed.
This new procedure, though somewhat different than today's
method, will work nicely to clean press blankets.
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CASE STUDY FROM THE JOHN ROBERTS COMPANY
Training for Press/Blanket Washing Questions
You May Have
If we can still buy solvent blends that contain some 1,1,1
Trichlorethane (TCA) , why do we need to make the change now?
Well, there are several reasons. First, there are some health
concerns with TCA, so we want to eliminate any exposure as much
as we possibly can. Second, in an effort to discourage the use
of TCA now, the government is increasing taxes on this chemical
(and other targeted chemicals), making the product unduly costly.
Third, this is a reportable usage chemical, which requires that
we complete Form R (a complicated procedure) that is also public
information. It is better that we have no reportable chemical
usage because if we do, then we are also brought into the
regulatory loop on many other time consuming and costly programs.
Fourth, John Roberts has made a commitment to reduce its total
emissions as part of the Minnesota Toxic Pollution Prevention
Plan and we will be accountable for reaching these goals. Fifth,
as a responsible member of the community (in which many of us
live as well as work), it is the right thing to do for the
betterment of our environment.
Will this new procedure slow down my work and reduce my
productivity? Will I be penalized because of this?
Unquestionably, this new procedure will slow things down
slightly, but not by much. Even with the older Blanket Wash,
pressmen would often use two turns of the cylinder to complete
the cleanup of the blanket. Understanding that the blanket does
not need to be completely dry will save otherwise wasted time.
So the only remaining time element is the need to switch to a
water wipe shop towel pad and the time to take care to wipe the
blanket ends, especially the cylinder gap. Management's
commitment to environmental responsibility supports your efforts.
What if I find I need more shop towels? Won't this new procedure
use a lot more shop towels?
If it turns out that you need more shop towels, they are
available (we ordered extra last week and have them in stock).
Testing that we have already done has shown that towel rotation
(where the water wipe pad becomes the new solvent wipe pad and
clean towels are then used for the new water wipe pad) works very
well.
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Can I use a sponge instead of a shop towel pad for the second
(water) wipe?
Yes, it's possible to use a sponge instead of a padded shop towel
for the water wipe. But if you do choose to use a sponge, you
will have to use less wiping pressure or you will squeeze the
water out of the sponge onto the blanket leaving the blanket too
wet. Try it and see if you like it. You may find a shop towel
water wipe easier to control.
Can I mix water with the Press Wash and do it all at one time?
Why might this not be a good procedure?
Yes, again it's possible to do this, but it's not recommended.
Here's why. When you add water to Press Wash, you dilute the
Press wash's ability to cut the ink in the first place. This may
mean more work and slower cleaning. Also, Press Wash contains
surfactants that make it able to mix with water, and it is these
surfactants that tend to remain on the "clean" blanket that cause
problems with both the ink roller train and the water fountain
systems. It's good to remove surfactants as completely as
possible, and this is best done with a separate water wipe.
Can I just use a dry shop towel pad to wipe the blanket
completely dry instead of a second water wipe? Would I be better
off?
Well, for the reasons listed above, it's not recommended to use a
dry shop towel second wipe. Aside from the fact that some feel a
dry shop towel is harder to move across the blanket (it tends to
drag), how would you clean the blanket of water solubles such as
starches, clays and paper dust? The only reason I can think of
to completely dry the blanket would be to ease your fear of
"throwing"solvent drops on the work after startup. This is
addressed by taking a little care on the second (water) wipe,
especially at the ends of the blanket in the cylinder gap.
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Module 7: Implementing Your IEMS
You will ensure the success of your IEMS by developing the capabilities and
support mechanisms to achieve your environmental policy, objectives, and targets.
This module will cover planning for and setting up environmental management
projects for each objective. In addition, this module covers tools that will help you
keep your IEMS on track: a new product review process, a regulatory compliance
tracking system, a pollution prevention tracking log, and an Emergency
Preparedness and response plan development process.
Setting Up Environmental Management Projects
This section will help you set up environmental management projects developed to
achieve each objective and target selected in previous modules.
The three main elements in developing an environmental management project are:
> identifying the person responsible for achieving the environmental
objectives and targets in each relevant function and level;
> establishing the means or action plan for achieving targets and objectives;
and
> implementing timetables.
An outline for such a program might include:
> objective,
»• target,
»• person(s) responsible,
> budget,
> date of expected completion,
»• date of actual completion, and
»• performance indicators for measurement.
Let's continue working with the two examples from Module 3:
»• Recycle used toner cartridges.
> Reduce the environmental impact of chemical wastes from cleaning a
printing press. Remember, the environmental aspect is the air releases
during the press cleaning process and the water releases at the commercial
laundry where the used press wipes were sent.
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Figures 7-a and 7-b show example projects for the above two sample objectives
and targets.
Figure 7-a. Sample Environmental Management Project Plan
Environmental Management Project Plan
SEA: Waste from Copy Toners
Date
Environmental Objective: Reduce the waste from used copy toner
cartridges
Performance Indicator Measurement: Number of cartridges purchased
vs number mailed and number remaining in stock in one-year
period.
Target: 100% recycling of used toner cartridges in conformance
with manufacturer instructions.
Action Plan: Train persons in charge of replacing toner
cartridges. Create a check list for dates cartridges mailed for
recycling.
Responsibility: Office Manager
Budget: One hour training
Schedule: One month
Review: Monthly by company manager.
Corresponds to OTP-02 of the Company Manual Template.
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Figure 7b. Sample Environmental Management Project Plan
Environmental Management Project Plan
SEA: Chemical Wastes from Press Cleaning
Date
Environmental Objective: Reduce the Environmental Impact of
Chemical Wastes from Press Cleaning
Performance Indicator Measurement: Amount of fluid reused;
reduction in vapors measured at laundry provided by laundry.
Target 1: Reduce air releases of cleaning fluid by 80% in plant
by end of 12-month period
Action Plan 1: Substitute Product B cleaning fluid, train
printers in new product use
Responsibility: Printing Press Manager
Budget: Cost of new fluid
Schedule: Six months
Review: Monthly by company manager.
Action Plan 2: Substitute best work practice, train printers in
best work practice
Responsibility: Printing Press Manager
Budget: Time for training and evaluation of results
Schedule: One year
Review: Monthly by company manager.
Performance Measurement: Amount of Product B substituted for
current product in one-year period and reduction in total product
used over one-year period.
Target 2: Reduce releases to the water at laundry by 40% after
12-month period.
Action Plan: Remove excess fluid from wipes prior to sending to
laundry; reuse recovered fluid
Responsibility: Shop manager
Budget: Cost of centrifuge, time to process wipes
Schedule: 12 months
Review: Monthly by company manager.
Corresponds to OTP-02 of the Company Manual Template.
Resource
The results of your environmental projects plan can be documented on OTP-02 in the
Company Manual Template.
As you can see from Figure 7-b, more than one target can be used to accomplish
an objective, and more than one action plan to accomplish a target. You need to
outline the steps necessary to achieve each target and make sure that the
responsibility for completion is assigned, the time frame specified, and a budget
given to ensure completion. Appendix H contains a blank worksheet to assist you
in planning your environmental projects.
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Review New Products, Processes, and Activities
Tip
Conduct an Environmental Review when buying a new product, making a new product, changing
an existing process, developing a new process, or undertaking new or changed activities.
Change is an important part of business survival for most companies. Products,
technologies, ways of doing things are updated regularly. To avoid creating new
"significant environmental aspects" that must be addressed later, it is helpful to
integrate new processes, products, and activities into the environmental
management program that you are developing for the rest of your company. You
can do so by setting up a procedure for reviewing new processes, products, or
activities while they are in the planning stage. One way to accomplish this is to
create a sign-off form to be circulated among the people responsible for or
affected by the new process or product, including those responsible for the area of
the company where the new process or activity will be implemented. Worksheet
7-1 is an example of such a sign-off form. The worksheet is a model that should
be modified to reflect your company's activities and environmental policy.
Worksheet 7-1 : Environmental Review of New Processes, Products and
Activities
Area of Company
New Process,
Product, or
Activity
Environmental
Review by
Manager/Date
Environmental
Effects
Pollution
Prevention
Opportunities
Contact for form: Date Completed:
Compliance Tracking
If your company does not already have a method in place for tracking regulatory
compliance activities, this IEMS Program provides the opportunity for developing
one. A tracking system will help you integrate this aspect of environmental
control into your IEMS Program, future planning, and your annual management
review. Worksheet 7-2 provides an illustration.
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Tip
Investigate the legal requirements that may be associated with documenting your company's
compliance before you design the worksheet that you will use. Worksheet 7-2 is an example
of components that are useful, but regulations differ by locality. One source to review
would be EPA's Small Business Compliance Policy.
Worksheet 7-2:* Compliance Tracking Log
Person
Responsible
Regulation
Compliance
Check Date
Results and
Root Cause
Corrective
Action/Date
Compliance
Verified/ Date
Contact Person: Date Completed:
*Document results on CA-01 in the Company Manual Template.
Root cause analysis and the corrective action notices described above are useful in
examining failures in compliance and ensuring that corrective action occurs.
Pollution Prevention: Ideas and Tracking
Pollution prevention is another environmental management tool that is important
to integrate with your company's business activities. Pollution prevention means
reducing or eliminating waste at the source. The focus is more on waste than on
environmental risk. There is a hierarchy of solutions for pollution prevention:
1. absource reduction,
2. abreuse/recycle, and
3. abtreatment.
Before deciding on major changes, an evaluation of alternatives, as described in
Module 4, should be completed. There are, however, many different ways in
which your company could successfully implement pollution prevention activities,
especially if employees are encouraged to think about how to implement pollution
prevention in their work practices. Some examples would include reuse and
recycle of office paper, turning off lights/equipment when not in use, and keeping
the lid on solvent containers.
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You may develop specific programs that incorporate pollution prevention, such as
the toner cartridges example above, and you may also want to encourage pollution
prevention practices across the company. Measuring pollution prevention
achievements is different from, and often more difficult than, measuring
environmental achievements in general. Simply measuring the reduction in a
waste stream might mean only that the waste has been transferred to another
medium, not reduced. It is therefore important to measure the reduction at the
source of waste generation. It may also be important to measure the activities that
your company directs towards pollution prevention. The following are existing
sources of information that your company may have that would help you track
pollution prevention:
Permit applications
TRI reports
Purchasing records
Utility bills
Hazardous waste manifests
Material Safety Data Sheets
In addition, administrative procedures can be set in place that support pollution
prevention activities. Below is a checklist to help you consider opportunities for
your company:
Establish procedures in each company area for identifying pollution
prevention opportunities.
Have a chemical or raw material inventory system in place.
Assess how many objectives have been met through pollution prevention.
Worksheet 7-3 provides a tracking log for pollution prevention in your company.
Worksheet 7-3: Pollution Prevention Tracking Log
Area of
Company
Pollution
Prevention
Activity
Date Started
Results
Measurement
Method
Person
Responsible
Contact: Date Completed:
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Emergency Preparedness and Response
It is important to include environmental concerns in your emergency preparedness
and response plans and training. The following steps will help you integrate plans
for reducing the potential environmental impact of accidents, spills or other
emergency situations.
> Appoint a person responsible for integrating environmental concerns. This
can be the person already responsible for Emergency Preparedness and
Response or someone from the IEMS team who will work with that person.
> Identify the potential environmental impacts of potential emergency
scenarios.
> Develop response procedures to minimize these impacts and integrate them
into the emergency preparedness and response plans.
»• Conduct training for employees affected by these new procedures.
Worksheet 7-4 will help you identify your needs so that you can develop a plan.
Worksheet 7-4: Environmental Emergency Preparedness and Res
Potential Emergency
Scenario
Potential
Environmental Impact
Action
Required
Procedures
Needed
Donse
Training Needed
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Module 8: Building Organizational Support
Effective organizational support is important to achieving long term success for
your IEMS. This module will cover training, documentation, stakeholders and
communication.
Training to Get the Job Done
It's very important that people receive the training needed to get work done in a
way that is consistent with your objectives. Training is needed both in technical
work and for general awareness on the part of all employees. The following are
some examples of areas where training is needed:
»• legal requirements,
> ability to recognize new problems,
> technical work needed to solve problems,
»• procedures to implement operational controls,
»• any new procedures or needs related to significant environmental aspects,
and
> awareness of the company's environmental policy and the IEMS and its
objectives
Tip
Don't overlook the need for on-going training when experiencing employee turn-over. Be
sure that new employees are trained soon after they arrive.
In addition to environmental or worker health and safety training that your
company may currently carry out, you will have specific training requirements
associated with significant environmental aspect operational controls, as your
IEMS develops. Module 6 addressed the training for that phase of your IEMS.
Training plans developed during completion of that module should be integrated
with the training identified in this module.
Go through the Action Steps listed below and use Worksheet 8-1 to help you
identify, plan for and track the training needed to assist in developing and putting
your IEMS in place. You will probably be able to identify some general training
needs now, but will need to return to this module to add specific technical training
needs that may be identified as you proceed with the IEMS.
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Action Steps
*1 . Identify all job functions that affect the environment. Small companies
may wish to identify individuals. Identify who is responsible for employee
health and safety.
2. Identify the training and type of training these people currently receive that
relates to environmental, including health and safety, concerns.
3. Determine if IEMS education could be included in this training or whether
there should be special IEMS training, at least in the beginning.
4. Identify training materials or programs available outside your company.
Some places to check include:
> Trade Associations
> Small Business Association
> EPA materials
»• State Department of Environmental Protection
> Suppliers
> Certified Contractors
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Worksheet 8-1: Training Plan
Jobs Affecting
Environment
Sample: Staff EH&S Person
Production Employees
Training Needs
Environmental Policy
Emergency Preparedness
& Response
How to Train
Staff Training
Session
Contact Person:
When/ Length
Once/ Two hrs.
Budget
9
Completion
Date
9
Who is
Responsible
9
Date Completed:
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Resource
Review the Company Manual Template for sample documentation to help you develop your
own IEMS Manual.
Documenting Your Work
When undertaking a new activity like IEMS development, documenting
discussions, plans, targets, and programs is crucial. Documentation ensures that
no information is lost, and lets you track your performance. Much of this
documentation will become the content for your company's IEMS Manual. The
companion document to this guide, the Company Manual Template, provides a
template for your own documentation development. Documentation is important
to the success of your IEMS for several reasons:
Experience has proven the value of documenting meetings, decisions, and study results, and of
making that documentation accessible to those who need it.
> Word-of-mouth information is rarely communicated consistently, whereas
written information is more likely to be constant from person to person and
over time.
»• Creating documentation helps you assess the progress of your IEMS. Some
inconsistencies show up only as you commit your ideas to paper, and
having a record allows you to check on progress and evaluate results.
> Documentation is vital to maintaining consistency in an IEMS over time
and from department to department. In most companies, change is a fact of
life: new products are developed, the company grows, employees change
positions or leave the company. Accurate documentation will make it
much easier to maintain an effective and flexible IEMS during these
changes.
What is Documentation?
The term "documentation" has many different interpretations. The term can refer
to any or all of the following:
> instructions for doing something;
> records of what was done;
> policies developed;
»• printed matter that is given or sent to clients, regulatory agencies,
customers, and the public; and
> any electronic copy of the items above.
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Tip
documentation is usually the single most overlooked administrative procedure in most
companies, but it can play a vital role in EMS development, determining what you need
from your documents, both for future reference and to teach procedures to others, will
help you understand the overall needs that you want your IEMS process to meet.
How a company interprets "documentation" will depend on its particular
experience. For example, documentation could include environmental impact
statements, process manuals, or even the local newspaper that reports your
company's activities. Other examples might include environmental training
records and OSHA manuals. All of the work completed to develop your IEMS
also provides documentation.
How to Develop Your Documentation
Tip
Remember that you will not finish most of the modules in this Guide the first time through.
You will probably overlook items that will be useful for your IEMS documentation during
your first search. Simply add items as you think of them later in the process. Whoever is
in charge of documentation will therefore need to plan for later additions.
The basic steps in preparing IEMS documentation include:
Step 1: Determine how EMS documentation can be integrated into existing (documents.
Before you dive into your documentation, learn how deep the water is. Find out
what documentation already exists, what its purpose is, and whether it works. The
goal of this search is to locate materials you can use to begin your EMS
implementation and documentation. Many companies use the same format for all
their documents. An example of existing documentation might be a quality plan
or tracking reports.
Step 2: Tailor the documentation to your organization's individual needs.
You will probably have to compromise in producing documentation that meets
your needs while also meeting your budget. Here are some questions to help you
determine what fits your needs:
»• How can you extend those documents that already exist rather than creating
new ones?
> Does your business operate in a single location or many? This will affect
who creates some of the documents and where they are located. It may also
affect how many versions of a document might be necessary to cover
different circumstances.
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> What is your current computer capability? Many companies use an
electronic system to maintain documents.
»• What security precautions do you need? As a computer system becomes
larger and can be accessed by more people, electronic information can more
likely be edited and destroyed. Security, or at least restrictions on who can
change data, can be a critical issue for many companies.
Step 3: Determine a format for all documents.
Before developing your IEMS documents, plan the format (document and page
appearance) for the documents to be created. If a company standard exists, use it.
If not, the need for IEMS documentation provides an opportunity to create a
standard company format. Consider whether pages are single- or double-sided and
why; choose margins, header, footer, typefaces, text, headings, etc. Include plans
for bulleted and numbered lists, tables, and even paragraph spacing. Once you
have a consistent format for documents, anyone who writes one will use the
established electronic format and fill in the necessary text. All documents will
look like part of an organized, integrated system. Most important, documents will
be it easier to read and understand!
Step 4: Prototype each document
Prototyping means visualizing what you will need in the document and creating an
outline for it before you actually have information to fill in. This practice is useful
not only for document preparation, but for the IEMS process as a whole. As you
visualize what you will need in the document, you will gain understanding about
what you will need from the process of developing your IEMS. It's a way of
"outlining" your IEMS process as well as designing documents.
Who should do the prototyping? The best people to do this are the people who
will use the document. Involving them in the process gives document users the
power to develop documents they will actually use - effective documents.
The following questions will help your "prototypers" design documents. Consider
these questions for each document you identify as necessary for your company.
> What is the document's purpose?
> Who will use it, and how will they use it?
> How long should the document be?
> What must be included in the document? Which information is most
critical?
»• Is it process-focused? Process focus rather than regulation- or program-
focus helps people who use the documents to better understand how their
jobs fit into the rest of the company functions.
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> How is the information best arranged? Will the user read sequentially or
randomly?
Example: A Tiered Documentation System
The tiered documentation system consists of four "levels" of documents. The
system can be shown as a pyramid with the environmental management system
manual at the top and records at the bottom (see Figure 8-a).
Figure 8-a. Documentation Levels
Procedures
and References
Operating and Work Instructions
Forms and Records
\
The pyramid shape illustrates a hierarchy in which the amount of detail, degree of
specificity, and number of pages all increase as you progress from the top to the
bottom of the figure.
Creating an Outline for the Process
It will be helpful at this point to develop some idea of what your IEMS
documentation will look like, and thereby determine the work needed to fill it in.
Doing so will help to plan the development of your IEMS. Create an outline for
the process of developing your IEMS and your Company Manual or other form of
documentation that suits your company. What and how much documentation you
include depends upon your company's needs. The following outlines a sample
Company Manual:
1. Environmental Policy
2. Environmental Action Responsibilities Assignments
3. Environmental Documents and Their Location
4. Identification of Environmental Aspects
5. Identification of Legal Requirements
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6. Identification of Significant Environmental Aspects
7. Development of Objectives, Targets, and Action Plans
8. Conducting an Alternatives Evaluation
9. Development of Operational Controls
10. Environmental Training (Awareness and Task-Specific)
11. Emergency Preparedness
12. Review of New Products and Processes
13. Documentation and Document Control
14. Communication with External Stakeholders
15. Conducting a Compliance Assessment
16. Conducting an Internal Assessment
17. Taking Corrective Action
18. Management Review
Resource
Take a look at the accompanying Company Manual Template for sample procedures and
formats to help you document important components of your IEMS.
The actual content of your outline will be filled in as you proceed to develop your
IEMS.
Document Control
Documents must be easy to find and kept up to date. Consider the following
points regarding your document control. Two worksheets follow this section.
Worksheet 8-2 will help you develop documents and Worksheet 8-3 will help you
manage your documents once they have been created.
Sound document management ensures that:
they can be located;
they are periodically reviewed, revised as necessary, and approved for
adequacy by authorized personnel;
the current versions of relevant documents are available at all locations
where operations essential to the effective functioning of the system are
performed;
obsolete documents are promptly removed from all points of issue and
points of use, or are otherwise assured against unintended use; and
any obsolete documents retained for legal and/or knowledge preservation
purposes are suitably identified.
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Worksheet 8-2: Documentation
List Existing
Documents
List Documents
to be Created
Determine
Format: Who/
Date Completed
/
/
/
/
/
/
/
/
Develop Prototype
(Content): Who/
Date Completed
/
/
/
/
/
/
/
/
Assign
Writing:
Who/ Date
/
/
/
/
/
/
/
/
Review Writing/
Compare to
Prototype
Who/ Date
/
/
/
/
/
/
/
/
Added to
Document
List/ Date
/
/
/
/
/
/
/
/
Who Has
Access
Where
Located
Contact Person: Date Completed:
Corresponds to CS-2 of the Company Manual Template.
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Worksheet 8-3: Document Control
Document
Who Will Use It
Permanent Location
Periodic Review
Schedule/ Who
/
/
/
/
/
When Can Be
Destroyed
Contact Person: Date Completed:
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Working with Stakeholders
The DfE Program has found that including a variety of stakeholders in a project provides proven
benefits. DfE stakeholders include: industry, government, labor, environmental groups, and
others. Their inclusion ensures both a mix of viewpoints and a wealth of different experience and
training that contribute to a project. This level and breadth of stakeholders may not be available to
a small company, but opening your I EMS planning process to a variety of stakeholders will
improve results.
Stakeholders are anyone who has a stake in your company's environmental
performance. Stakeholders can play an important role in helping your company
develop an IEMS. Employees have strong stakeholder interest in your company
and can provide strong support for IEMS development. Customers, suppliers, and
neighbors can provide useful input. In addition, establishing partnerships with
trade associations, suppliers, professional associations, and community colleges
can be very helpful in developing parts of your IEMS. This section addresses the
kind of stakeholders you may wish to include in the process and the potential
benefits of including stakeholders. While involvement of employees is critical to
the success of your IEMS, how far you proceed with including additional
stakeholders is your decision.
Stakeholder Roles
Consider why you would want to include internal and external stakeholders and
what roles they can play. Before engaging stakeholders, be clear on what you
expect their role to be. What do you want from them? What do you intend to tell
them? Consider the following:
> Internal stakeholder (e.g., employee) participation can facilitate
implementation of environmental projects as employees "take ownership"
of the IEMS process and the process changes it may bring;
> Different stakeholders bring useful perspectives to identifying
environmental issues, often identifying issues that might otherwise have
been overlooked;
> Participation by all types of stakeholders can add credibility, transparency
and value to your IEMS;
> Involving external stakeholders can help them understand your business
operating constraints;
> Sometimes being an environmental leader can gain customer recognition
and loyalty, and involving customers in your IEMS helps them recognize
your leadership.
> Forming partnerships with customers and suppliers can help to identify
shared concerns and ways to cooperate to resolve them. There may be
ways that your company can help your customers meet their environmental
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management needs. Forming partnerships with suppliers can help your
company obtain important information and may help you meet your IEMS
goals.
Tip
Working together with your customers to identify common needs in managing environmental
concerns can help to build long term relationships.
Identifying Stakeholders
Almost every organization will have a wide array of internal and external groups
that may be interested in and helpful partners to that organization. These groups
will not be homogenous. Each will have its own priorities and perspectives, and
each will have something different to contribute in support of your IEMS.
The following list provides types of stakeholders:
Internal Stakeholders
> Employees
> Shareholders
> Customers
»• Suppliers
> Investors & Insurers
»• Trading Partners
External Stakeholders
> Neighbors
> Community
> Organizations
> Environmental Groups
> Larger Companies
> The Media
> The Public
> Local Government
Tip
Remember, your stakeholders' concerns may be very different from what you expect, and
even less difficult to resolve than you may think. The only way to find out is to talk with
them.
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You may want to start with those stakeholders who have expressed interest in your
operations. If you wish additional input, you can contact the following sources in
your effort to locate suitable stakeholders:
> ask your organization's own employees, including plant/site managers and
public relations personnel;
»• contact local officials for suggestions;
> contact a local planning agency for suggestions;
»• contact local schools, community colleges, or universities; or
»• contact a national advocacy group to elicit suggestions as to which local or
national groups may be interested/suitable.
How to Work With Your Stakeholders
The next stage of the process is to establish dialogue with stakeholders. You may
view this as an opportunity to further refine your understanding of the various
interests of the groups.
Develop stakeholder participation in stages and learn as you go. You might think
about the different kinds of stakeholders as forming ever broader circles around
your business (see Figure 8-b). Begin with the innermost circle and work
outward.
Figure 8-b. Levels of Stakeholder Interest
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Communications
When working with either internal or external stakeholders, including your IEMS
team, effective communication will facilitate a smooth implementation of your
IEMS. You will want to follow these effective rules of communication:
Tip
It's important to revisit the communication plan at various stages of your IEMS
development to add any additional communication needs for each piece of your IEMS.
Begin early in the process.
Let people know what you are doing. In most cases, you will need the cooperation
of several people within your company to gather information and develop an
IEMS that will work. In small and large organizations alike, early
communication will pay off in greater acceptance of the resulting system.
Set your communication objectives.
Decide what you want to achieve in your communication. Setting this goal will
help you get the right message across without overwhelming people with too much
information, spending too much time, or missing the mark. It is helpful to create
an IEMS communication policy for your company. The policy should outline
what kinds of information will be communicated to external stakeholders, and how
the company will document and respond to communications from external
stakeholders. In addition, the policy should discuss how the company will report
environmental health and safety (EH&S) incidents, such as spills, accidents and
"near misses". The policy should include who reports what, to whom, and when.
Tip
Create and maintain a list of everyone you can think of who would be interested in your
company's environmental activities. Include how you could reach them. You can then make a
decision about where to begin. You could start with staff and later add other audiences if
that suits your capabilities and needs. It is helpful to make your communication list as
complete as possible to start with but pare it down to start out. Begin small, and then you
can use the list to expand when ready.
Communicate regularly and integrate IEMS communication.
To build support for the IEMS, try to communicate on a regular basis. Some
simple means of regular communication can usually be accomplished without
straining resources - for example, a bulletin board posting, email messages, or
articles in the organization newsletter. Don't forget to consider direct word-of-
mouth communication, particularly in smaller organizations. Talking directly with
key individuals at intervals may be the best mechanism for ensuring good
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communication. Use existing channels of communication to get the message out
on your IEMS activities.
Consider various methods of communication when informing stakeholders about
your company and what you are doing, or plan to do, to protect the environment.
Methods may include:
discussion in company meetings;
company website;
scheduling tours of your facility;
producing a fact sheet about your company's activities, the EMS program,
and why and how your company would like to include stakeholders;
establishing a phone line to answer questions, record concerns, etc.;
going to local schools, community colleges, universities, or civic
organizations, such as the Rotary, that may provide a focal point of interest
about your company; and
> holding public meetings when you feel it is appropriate.
Ensure that stakeholder dialogue is a two-way process.
The stakeholders will want to know that their comments and concerns are being
listened to and taken into account. You need to convey that your organization is
genuinely and actively including them.
Worksheet 8-4 will help you develop criteria.
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Worksheet 8-4:* Working with Stakeholders
Your Stakeholders
(Example) Employees
(Example) Neighbors
Customers
Potential
Environmental
Interest
What you want
to tell them:
Environmental
policy
Environmental
policy and IEMS
plans
Environmental
policy and IEMS
plans
Contact Person:
What you want
them to tell
you:
How to get it
done
Their
environmental
concerns
Their
environmental
concerns
How to
communicate
with/tell them:
Memo, bulletin
board, meetings,
suggestion box,
intranet
Meetings, open
house, flyers,
suggestion box, web
site
Above, plus inserts
in direct mail
advertising, or
billing, web site
When
Person
Responsible
Date Completed:
*Report results on CS-01 in Company Manual Template.
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Tip
Make use of current technology. A company website can be used to communicate your
company's environmental policy and other important elements of your IEMS. It can also be
used to solicit comments and suggestions from stakeholders.
To complete this worksheet, think about ways to use your current means of
communication to begin your dialogue. Consider which methods will work to
convey your message to each group, and which will work to obtain the
information you want to get from each group. The means that you choose may be
different for each stakeholder group.
In addition to communicating with your stakeholders, it is important to track their
communication to your company and the response made to that communication.
A procedure for documenting and responding to stakeholder communication
should be established and a person appointed to be responsible for carrying it out.
Worksheet 8-5 will assist you in setting up and documenting each communication.
The following Case Study shows how "Company B" set up a process to train and
then use its internal stakeholders to identify environmental concerns and some of
the benefits achieved.
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Worksheet 8-5: Stakeholder Communication Record
Date Communication Received:
Type of Communication:
Received From:
Address/Telephone Number/E-Mail:
Content of Communication
(attach copy if possible):
Will ABC Company Respond?
Date of Response:
Person Responding:
Nature of Response
(attach copy if possible):
Are Internal Actions Necessary?
(If Yes, fill out a Corrective Action
Form.)
Contact Person:
Y N
Y N
Date Completed:
Corresponds to CS-02 of the Company Manual Template.
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Case Study: Company B — Working With Stakeholders
Company B is a 30-person company that manufactures sangria and
chile salsa. With strong senior management backing and support
from a local consultant, Company B focused initially on building
environmental consciousness among its employees. To all of its
workers and managers the company offered general environmental
awareness training as well as more specific training on how to
identify specific environmental issues. Employees then split
into 10 teams, each charged with identifying the environmental
issues associated with a specific area of operation, from the
acquisition of raw materials through to product delivery. Based
on the work of these teams, Company B developed a list of its
most important environmental issues and concrete objectives and
plans for improvement.
The key to Company B's success lay in using participatory teams
to define new environmental problems and develop solutions. For
example, the company identified waste of raw materials as an
environmental issue, and teams from several areas found ways of
reducing waste. Company B now requires its suppliers to use
stronger containers to avoid materials spoilage. More
significantly, the team from the mixing area realized that by
using a spray nozzle to clean out left-over orange juice
concentrate (a key ingredient in sangria) from large supply
containers, it can recover an additional 3,000 pounds of
concentrate (6% of its total consumption, valued at $4,200) per
year. Company B gained an even greater economic benefit by
revising its process for cleaning and sanitizing its stainless
steel tanks, reducing use of an iodine-based cleaning fluid by
11,000 liters per year, or 90%, at an estimated yearly savings of
$7,000.
Other benefits the company has realized include improved
compliance, a safer work environment, and reduced emissions from
its transport vehicles thanks to improved maintenance. The
environmental awareness of all employees has increased
significantly, with some workers extending their new-found
environmental consciousness to their homes. The company has also
publicized its participation in the EMS project to the local
community in an effort to improve its community relations and to
help improve the environmental awareness of the community.
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Module 9: Establishing Continuing Improvement
Now it's time to step back and look at the total picture. Your IEMS constitutes an
overarching "Environmental Management Program" made up all of the elements
we have covered above and a few additional elements that we will cover in this
module. The framework of your IEMS Program at this point includes:
> Company Environmental Policy
> Environmental Aspects Review Process
> Objectives, Targets and Environmental Management Programs
> Measuring Environment Performance and Taking Corrective Action
»• Operational Controls
> Documentation Plan
> Stakeholder Strategy
> Communication Plan
Resource
Review the Company Manual Template for sample procedures and formats to help you
document important components of your IEMS.
The final steps in developing your EMS include:
> determining program measurement criteria,
> setting up an internal assessment process, and
»• establishing a management review process.
Principles emphasize the importance of continuing improvement. Environmental improvement
requires work in steps. It will not be achieved overnight, but must be viewed as a long-term,
evolving process.
Step 1: Determine program measurement criteria
Determining measurement criteria, also called environmental performance
indicators, will help you evaluate the success of your overall IEMS program. The
purpose of these indicators is different from the specific measurement criteria you
developed for evaluating progress toward individual objectives. These
performance indicators focus on how well the overall system for improving
environmental management is functioning. Select performance indicators that will
help you and your employees decide whether success has been achieved or
whether improvement in procedures needs to be made. It is easier for
management and staff to understand how things are going if they have benchmarks
as guidelines.
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You will need performance indicators that describe how well your environmental
policy is being implemented. In addition, you will need performance indicators
for all of the various components of your IEMS. The measurement criteria
selected for each component of your IEMS will probably be different. For
example, how will you measure the success of communication, documentation,
stakeholder outreach, or training programs?
One approach is to measure the activities, for example, number of meetings held
with stakeholders, number of documents created, number of employees trained, or
number of hours of training. Activity, however, does not always mean results.
Consider the objective of each IEMS component and define a way to measure
results so that you would feel satisfied that the objectives are achieved. To
measure results effectively, your methods should be:
> simple
> flexible
»• consistent
> ongoing
> usable (i.e., results communicated)
»• accurate (i.e., reliable data produced)
Worksheet 9-1 will help you organize your thoughts.
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Worksheet 9-1: IEMS Program Measurement Criteria
Company Name
~~~~~~-----~->______^ Measurement
~~~~~~— — -^___Elements
IEMS Components ~~~~~~— -— -_
Environmental Policy
Communication Plan
Stakeholders Input
Environmental or IEMS Training
Review of Aspects
Operational Controls
Environmental Review of New
Processes and Activities
Setting Objectives & Targets
Environmental Management
Project 1
Environmental Management
Project 2
Documentation
Regulatory Compliance
Pollution Prevention
Other
Objectives of
Component
Activity
Measures
Results
Indicators
Review
Period
Contact person for form: Date Completed:
Here are some examples of IEMS results measurements for various program
components that can be tracked over time:
number of significant environmental aspects included in environmental
projects plan
number of environmental objectives and targets met
pounds of hazardous waste generated per unit of production
employee sick leave absences related to work environment
percentage of employees completing environmental training
average time for resolving corrective action
energy or water use per unit of production
percentage of solid waste recycled/reused
number of complaints from community; number of responses to complaints
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> number of pollution prevention ideas generated from employees
> resources used per unit of product or service
»• pollution (by type) generated per unit of product or service
»• per cent of products for which life cycle assessment has been conducted
> number of products which have a recycling program
> number of instances of non-compliance
It is the results shown by these environmental performance indicators that will
become the basis for your plans for next year and for establishing continuous
improvement.
Step 2: Set up an internal assessment process
To make sure that your IEMS is achieving the general goals outlined in your
Environmental Policy, you will need to establish procedures for an assessment
process and assign people to be responsible for accomplishing the assessments on
a regular basis. In general, assessments are conducted through interviews,
examination of documents, observation of activities, and review of results of
measurements. Assessments should be conducted regularly, for example, on every
quarter. The purpose of the assessment is to develop information for management
review and to take corrective action where needed. The assessment procedures
should describe:
»• the activities and areas to be considered in assessments,
> the frequency of assessment,
> the responsibilities associated with managing and conducting assessments,
> the communication of assessment findings,
> assessor competence, and
»• how assessments will be conducted.
Assessments may be performed by personnel from within the organization or by
external persons selected by the organization. In either case, the persons
conducting the assessment should be in a position to do so impartially and
objectively. Use Worksheet 9-1 along with Worksheet 9-2 and 9-3 to help you set
up your assessment process. The Worksheet 9-2 specifies some of the factors that
will be examined during the assessment and Worksheet 9-3 will help you track
correction of non-conformities.
These forms alone will not be enough to conduct assessments. First, the
categories should match what is appropriate for your company. Second, each
category will probably require subheadings to fully describe what you need to
check about each category to be assessed. These worksheets are more of a
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summary log with suggestions about what you might want to include. Although
every part of your IEMS program should be assessed regularly, all parts need not
be assessed at the same time, nor on the same schedule. Make this IEMS work to
help you ensure that your IEMS program is doing what you want it to do.
Worksheet 9-2: Internal Assessment Checklist
Internal Assessment Team:
Date of Internal Assessment: Signed:
IEMS Procedures:
Check each item assessed, including auditing of records, where applicable (codes in parentheses refer
to the Worksheet number ("WS") in this Guide, followed by the document number in the Company
Manual Template):
Environmental policy (Module 2)
Environmental objectives (progress; implementation of action plans)
_ IEMS responsibilities (WS 7-2, RESP-01)
Identification of Environmental Aspects (WS 1-5, P-EA)
Identification of Legal Requirements (WS 1-6, P-LR)
Identification of Significant Environmental Aspects (WS 3-3, WS 3-6, P-SEA)
Development of Objectives, Targets, and Action Plans (WS 5-1, P-OTP)
Conducting an Alternatives Evaluation (WS 4-1 to 4-6, P-AE)
Development of Operational Controls (WS 6-1 to 6-3, P-OC)
Environmental Training (Awareness and Task-Specific) (WS 8-1, P-ET)
Emergency Preparedness (WS 7-5, P-EP)
Review of New Products and Processes (WS 7-3, P-NPP)
_ Documentation (WS 8-2, WS 8-3, P-D)
Conducting a Compliance Assessment (WS 5-4, P-CA)
Conducting an Internal Assessment (WS 9-2, WS 9-3, P-IA)
Taking Corrective Action (WS 5-3, P-TCA)
Management Review (WS 9-4, P-MR)
IEMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person: Date Completed:
Corresponds to LA-01 of the Company Manual Template.
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Worksheet 9-3: Internal Assessment Record
Internal Assessment Team:
Date of Internal Assessment: Signed:
Major Non-Conformities Observed
1.
2.
Minor Non-Conformities Observed
1.
2.
3.
Is ABC Company making progress in meeting its I EMS objectives?
Is ABC Company adhering to the commitments in its environmental policy?
Suggestions for Improving IEMS:
Contact Person: Date Completed:
Corresponds to IA-02 of the Company Manual Template.
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Review your company's environmental aspects and objectives
Tip
Regularly revisiting your environmental aspects and objectives is an essential step in
developing an EMS that achieves the goal of continuous environmental improvements.
As part of your internal assessment, it is critical that you regularly review your
company's environmental aspects and objectives. Over time, you will probably
add to the list of environmental aspects and you may need to re-rank the aspects as
your activities change and as new information becomes available. Here are some
things to check:
> New process review— have any changes introduced new environmental
aspects?
> Worksheets from the most recent environmental aspect identification and
ranking exercises — is there new information on chemical effects? If so,
update your worksheets.
> Communication received from stakeholders — do any comments suggest a
need for re-ranking your aspects?
> Environmental objectives and targets — what new ones will your company
set for this time period?
»• Pollution prevention program — has information become available from
this effort that would add aspects or objectives?
> Assessment program — have your assessments turned up information on
where your IEMS and environmental programs could be improved? Would
this information be useful in your aspect identification process or in
redesigning your objectives?
The regular review of aspects can be used to change the priorities you set last time,
or it can be used to examine a part of your company's activities that you set aside
last time. The regular review can be part of a planned "phasing in" process,
wherein different parts of your company's operations are reviewed until all your
company's activities are included in your IEMS. The regular review of aspects is
the foundation for your company's continuing improvement.
Step 3: Establish a senior management review process
To maintain continual improvement, suitability, and effectiveness of your
environmental management system, and thereby its performance, your
organization's senior management should review and evaluate the environmental
management system at defined intervals, such as quarterly. The scope of the
review should be comprehensive, though not all elements of an environmental
management system need to be reviewed at once, and the review process may take
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place over a period of time. The worksheets in Steps 1 and 2 provide information
for the management review. Review of the policy, objectives, and procedures
should be carried out by the level of management that defined them. Following is
a checklist of some of the things that should be included in the management
review:
»• results from assessment,
> the extent to which objectives and targets have been met,
> the continuing suitability of the environmental management system in
relation to changing conditions and information, and
> concerns amongst relevant interested parties.
Questions for management to consider include:
Is our environmental policy still relevant to what we do?
Are roles and responsibilities clear and do they make sense?
Are we applying resources appropriately?
Are we meeting our regulatory obligations?
Are the procedures clear and adequate? Do we need others? Should we
eliminate some?
What effects have changes in materials, products, or services had on our
IEMS and its effectiveness?
How effective are our measurement and assessment systems?
Can we set new measurable performance objectives?
What effects have changes in materials, products, or services had on our
IEMS and its effectiveness?
> Do changes in laws or regulations require us to change some of our
approaches?
> What stakeholder concerns have been raised since our last review?
> Is there a better way? What else can we do to improve?
Create a continual improvement plan and check progress. Document observations,
conclusions, and recommendations for necessary action. Assign action items for
follow-up, and schedule the next regular review. Worksheet 9-4 will provide a
place to record management review information.
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Worksheet 9-4: Management Review Record
Date of review meeting:
Persons present at meeting:
Conclusions:
Actions to be taken/Person(s) responsible:
Signed:_
Management Representative Plant Manager
Worksheet 9-4 corresponds to MR-01 in the Company Manual Template.
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Congratulations!
This completes your IEMS. Hopefully, the management system accompanied
by the annual process of review and renewed objectives will bring its own
rewards in greater productivity, reduced costs and healthier environments!
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Appendix A: Glossary
alternatives evaluation - A systematic evaluation of alternative ways to
accomplish a task that reviews the cost, performance, and environmental impact of
each alternative under consideration. Ideally, the range of evaluation would
include alternative chemicals, products, processes, technology, work procedures,
and disposal methods.
ancillary material - Material input that is used by the unit process producing the
product, but is not used directly in the formation of the product.
aspect, environmental - Element of an organization's activities, products, and
services that can interact with the environment.
assessment - An estimate or determination of the significance, importance, or
value of something.
certification - Procedure by which a third party gives written assurance that a
product, process, or service conforms to specified requirements.
compliance - An affirmative indication or judgment that the supplier of a product
or service has met the requirements of the relevant specifications, contract, or
regulation; also the state of meeting the requirements.
continual improvement - Process of enhancing the environmental management
system to achieve improvements in overall environmental performance , in line
with the organization's environmental policy. Note - The process need not take
place in all areas of activity simultaneously.
corrective action - An action taken to eliminate the causes of an existing
nonconformity, defect, or other undesirable situation in order to prevent
recurrence.
effects - Refers to changes, actual or potential, caused by a chemical, activity, or
process as it comes into contact with humans or the environment.
environment - Surroundings in which an organization operates, including air,
water, land, natural resources, flora, fauna, humans, and their interrelation.
environmental assessment - A systematic, documented, periodic and objective
review by company management of facility operations and practices related to
meeting environmental requirements. The assessment is a systematic, documented
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verification process of objectively obtaining and evaluating evidence to determine
whether specified environmental activities, events, conditions, management
systems, or information about these matters conform with selected criteria, and
communicating the results of this process to management.
environmental management system (EMS) - Organizational structure,
responsibilities, practices, procedures, processes, and resources for developing,
implementing, achieving, reviewing, and maintaining the environmental policy.
environmental objective - Overall environmental goal, arising from the
environmental policy, that an organization sets itself to achieve, and that is
quantified where practicable.
environmental performance - The measurable results of the environmental
management system, related to an organization's control of its environmental
aspects, based on its environmental policy, objectives, and targets.
environmental performance evaluation - Process to measure, analyze, assess,
report, and communicate an organization's environmental performance against
criteria set by management.
environmental performance indicator- A specific datum selected, such as
volume of a chemical used, which will provide measurable information regarding
progress toward meeting a specific environmental goal.
environmental policy - Statement by the organization of its intentions and
principles in relation to its overall environmental performance, which provides a
framework for action and for the setting of its environmental objectives and
targets.
environmental target- Detailed performance requirement, quantified wherever
practicable, applicable to the organization or parts thereof, that arises from the
environmental objectives and that needs to be set and met in order to achieve those
objectives.
function - Performance characteristic.
hazard - The ability to cause damage.
impact, environmental - Any change to the environment, whether adverse or
beneficial, wholly or partially resulting from an organization's activities, products,
or services.
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inputs and outputs - Material or energy that crosses a unit process boundary.
Example — Materials may include raw materials, products, emissions, and waste.
interested party - Individual or group concerned with or affected by the
environmental performance of an organization.
life cycle - Consecutive and inter-linked stages of a product system, from raw
material acquisition or generation of natural resources to the final disposal.
life-cycle assessment (LCA) - Compilation and evaluation, according to a
systematic set of procedures, of the inputs and outputs of materials and energy and
the potential environmental impacts of a product system throughout its life cycle.
life-cycle characterization - Element of the life-cycle impact assessment phase in
which the potential impacts associated with the inventory data in each of the
selected categories are analyzed.
media - The means or substance through which something is transmitted, e.g., air,
water, or soil.
objective, environmental - Overall environmental goal, arising from the
environmental policy, that an organization sets itself to achieve, and that is
quantified where practicable.
pollution prevention - Pollution prevention means reducing pollution or waste at
the beginning of a process. The underlying theory to this approach is that if you
don't generate waste in the first place, there is nothing to treat or dispose of.
prevention of pollution - Use of processes, practices, materials, or products that
avoid, reduce, or control pollution, which may include recycling, treatment,
process changes, control mechanisms, efficient use of resources, and materials
substitutions.
procedure - A specified way to perform an activity.
process - A set of interrelated resources and activities that transform inputs into
outputs.
product - Any good or service.
risk - This is the probability that something undesirable will happen from
exposure to a hazard.
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risk assessment - Risk assessment is the process of gathering data and making
assumptions to estimate short- and long-term harmful effects on human health or
the environment from exposure to hazards associated with the use of a particular
product or technology.
root cause - A fundamental deficiency that results in a nonconformance and must
be corrected to prevent recurrence of the same or similar nonconformance.
stakeholders - Those groups and organizations having an interest or stake in a
company's EMS program (e.g., regulators, shareholders, customers, suppliers,
special interest groups, residents, competitors, investors, bankers, media, lawyers,
insurance companies, trade groups, unions, ecosystems, cultural heritage, and
geology).
substitutes - A chemical, product, process, or technology, which may be
substituted for another to perform the same function or achieve the same end
result.
target, environmental - Detailed performance requirement, quantified wherever
practicable, applicable to the organization or parts thereof, that arises from the
environmental objectives and that needs to be set and met in order to achieve those
objectives.
volatile - Ability to evaporate easily.
waste - Any output from the product system that is disposed of.
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Appendix B: Sample Questions To Ask Your
Supplier
(From Solutions for Lithographic Printers, Question 8.)
This appendix contains questions focused on getting information on chemical
hazards of products used in press wash. Modify the questions to suit the chemical
products that your company uses. The entire document can be found on the DfE
website under industry projects.
What questions should I ask my blanket wash supplier?
Your supplier can be a valuable source of information for evaluating both the
wash you use now and any substitute wash. Ask your supplier the questions listed
below to gain important health and environmental information about the blanket
wash you are currently using or a substitute blanket wash you may consider
testing.
1. What chemicals are in the blanket wash?
> Send me a copy of the MSDS.
> What chemicals are in this wash that are not listed on the MSDS?
2. Which regulations might be triggered when using this product?
> Are there any HAPs (Hazardous Air Pollutants under the Clean Air
Act) in this wash?
»• How do you suggest I comply with the applicable regulations?
3. What is the volatile organic compound (VOC) content and vapor
pressure of the wash?
Tip
The lower the VOC content, the better. The lower the vapor pressure, the better.
4. What health risks are associated with the use of the blanket wash?
> What types of short-term symptoms, such as dizziness, headache or
nausea, might I experience by using these products on a daily basis?
»• Does this product contain any chemicals with adverse long-term
health effects?
> When using this product on a daily basis, what type of ventilation do
I need?
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5. Do I need to be concerned if workers get this wash on their hands or
skin?
6. What are the best ways to use the wash to minimize both the health
risk and waste generated?
7. Do I need to change the way I currently use blanket wash to make this
product work best?
8. What is the proper method for disposing of the used blanket wash and
wipers?
> Will my used wipers or used blanket wash be considered hazardous
waste under RCRA?
> Once the wash is mixed with other chemicals, such as inks or
fountain solutions, what is the proper disposal method?
9. Do I need to take any special precautions when laundering used
wipers?
10. Do any of the chemicals in this product present a risk to aquatic
species?
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Appendix C: Example Performance Evaluation
Worksheets
This appendix contains two worksheets designed for evaluating the
performance of ink remover and emulsion and haze remover for
screenprinting. These worksheets can be adapted for other performance
evaluations. These worksheets also can be found on the DfE website, as
Appendices I and J in the Cleaner Technology Substitutes Assessment for the
DfE Screenprinting Project.
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INK REMOVER EVALUATION SHEET
Facility name and location:
Evaluation #
Date:
Time:
Ink Remover employee's name:
Fill in the blank or circle the appropriate characteristic. Make any
notes or comments in the space to the right.
Screen Condition
Screen identification and history
Screen size
Screen condition and threads per
inch
Mesh
(Record mesh material type and type
of mesh treatment, (e.g., abraded,
calendared, etc.) if any)
Number of impressions of the
screen's last run
Ink type
Ink color
• Enter the identification marking (tracking) code for the screen:
• Estimate how much ink was left on the screen?
inches x inches
• Note screen condition including any rips, holes, corrosion:
• Record the screen mesh size: threads/inch
• Mesh type:
• Mesh treatment:
• Circle one:
Solvent-based, UV, Water-based
• Specify manufacturer and series #:
• Circle one:
Blue, Black, Other (specify):
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INK REMOVER EVALUATION SHEET
Evaluation #
Emulsion type
% Ink Coverage
Drying Time
• Circle one:
Capillary film, Direct photo, Dual cure, Other (specify):
• Specify manufacturer and series #:
• Check one:
0 - 25%.. .0 25 - 50%.. .a 50 - 75%...a 75 - 100%.. .Q
Time between end of press run and start of ink removal with product
(hours or mins.; specify units)
Performance
Ink Remover Dilution
Quantity of Ink Remover Used
Time (enter time from application of
ink remover until screen is ready for
the next step)
Physical effort required
(circle rating and comment)
How many wipes did you use?
Was a pressure washer used?
Examine screen after ink removal.
(enter ratio) or "none"
oz.
Note: Do not include screen positioning or clean up time.
mins.
Low, Moderate, High
(check one) Yes No
Did the ink remover effectively and easily remove the ink? (Also
any side effects of the product on the screen)
note
Comments or suggestions - Record any comments and note anything unusual about the reclamation on a
separate sheet of paper, (e.g., did you have to reapply the product? why was the screen hard to clean?)
150
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INK REMOVER EVALUATION SHEET
#
Facility name and location:
Evaluation
Date:
Time:
Screen Reclamation employee's name:
Fill in the blank or circle the appropriate characteristic. Make any notes or
comments in the space to the right.
Screen Tracking
Screen identification
• Enter the identification marking (tracking) code for the screen:
Performance
Drying Time
(Specify units; hours or
mins.)
Time from ink removal completed to start of emulsion removal:
1 Time from emulsion removal completed to start of haze removal:
Dilution
Emulsion Remover
1 Haze Remover
(ratio) or none
(ratio) or none
Quantity of Product Used
Enter # of ounces used:
• Emulsion Remover
Enter # of ounces used:
• Haze Remover
ounces
ounces
Product Use Time (enter
time from application of
product until screen is ready
for the next step)
Emulsion Remover
1 Haze Remover
mins.
mins.
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INK REMOVER EVALUATION SHEET
Evaluation #
Was a pressure washer
used?
For emulsion removal? (check one) Yes
For haze removal? (check one) Yes _
No_
No
Physical effort required
(circle one for each step and
describe the level of effort)
• Emulsion Remover:
circle one: Low, Med, High; Describe if the stencil dissolved easily or
slowly, and if a great deal or very little scrubbing took place:
• Haze Remover:
circle one: Low, Med, High; Describe the effort required for haze
removal:
Examine screen after
emulsion removal.
• Is there any ink haze or stencil stain on the mesh? If so, describe:
• If any emulsion is still present, describe the residue left on the screen in
detail:
Examine screen after
reclamation is complete.
Can the screen be reused for all jobs? check one: Yes
No
If "No", describe why the screen cannot be reused: (e.g., Is there is a ghost
image? Can the screen be used for reverse printing? Can it be used for close
tolerance work? Can transparent inks be used with it?)
Examine the substrate
image after the screen is
reused. Comment on the
print image quality.
Comments - Record any comments and note anything unusual about the reclamation on a separate sheet.
(e.g., did you have to reapply the product? why was this screen more difficult to clean?)
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Appendix D: Example Alternatives Evaluation
Worksheet
This study presents a worksheet that can be adapted to evaluate sets of
alternatives.
From "A Worksheet to Help You Choose a Better Wash," Case Study #4 from the
DfE Lithographic Printing Project.
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LlTHOORAFHY PROJECT BuiLETIN 4
A Cooperative Project
between the
U.S. Environmental
Protection Agency
and the
Printing Trade
Associations
Nationwide
U.S.EPA*
This Bulletin highlights
How to Find a Better
Blanket Wash for
Your Company
1 fl Dssaiftioii cl fee Dfenl
Cost Categories
A Worksheet to Help YOU
choose a Better Wash
There are many factors to consider when choosing n blanket wash or other press chemical
thai is best for your shop, VerhRps the most obvious are purchase price and performance.
Bui there are other, less obvious factors that arc just its important. How flammable is the wash?
Is it a regulated material? How hazardous Ls it to worker health or to the environment? liven
if it is cheaper to buy, a wash that is more ha/ardous, or one that is regulated, may have large
hidden costs that make it more expensive in the end.
The worksheet contained in this bulletin identifies many of these costs, both obvious and HOE
so obvious. Use it lo compare your blanket wash options - it may help you find % blanket wash
that is heller ft>r your shop.
The Worksheet: How Does it Work?
'[lie worksheet can help you compare tf.st blanket washes to your normal wash. Complete
the worksheet after you (or your press operators) know how well the test wash works
(this may take a week or two of use). When you answer the questions and add up the
scores, the worksheet will tell you If the test wash may be a better choice for your shop,
Ail information needed for the worksheet is available from:
• the press operators in your shop who have been using the test wash
< the Material Safety Data Sheet (MSDS) that comes with the blanket wash
• your blanket wash supplier
if the Final Worksheet Score Is...
Greater than M>«*«>
Less than zero
Equal to zero*
Then...
The test wash may be a better choice than
your normal blanket wash
The test wash may not be a better choice
for your facility than your normal blanket wash
The test wash is approximately the
same as your normal wash
' If the test wash appears to be approximately the same as your normal wash overall, look at saoh
individual category, Which is most important to you? Different scores in that category may still
help you decide which blanket wash is best for your shop,
154
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Could a substitute blanket wash be a better choice for your facility?
Use the scorecard below to figure out whether a substitute blanket wash may be a better choice for your facility
Atld the scores to see if the substitute wash is better, worse, or the same as your current wash.
Test Wash:
.......... •
Supplier Name and Phone:
! !> B Compare the test wash to the blanket wash you normally use for the following questions and enter the score of your '
answer In the column on the right:
Compared to yournnrraa! Mantel wash,
-2
Scores
-10
1
Enter
Score
2 Below
1 ' Is the price per gallon of the test blanket wash; , Much more More Same Less Much lass '
21 Is the amount of test wash used to clean each blanket: Much more More Same Less Much less :
U;s j Is the time required to clean n blanket with the test wash: , Much more More Same Let* Much less i
['J j What does the press operator think of the test blanket wash? I* it Much worse Worse Same Better Much better '
Consult MS!>S form* and contact the blanket wash supplier to answer questions 5-9: '
j & Do«s the te«t wash contain hazardous chemicals as defined by Federal/State environmental regulations fit OSHA? V»s * -2 No • 2
Compared to pur normal Mantel wash,
Scores
-2
B
fc[h the vapor pressure of the lest wash; ... ................... , ..... Muchhiflhar Higher Same Lower Much Lower
'^ I Is the percentage VOCs of the test wash: ....... , ........ ; , ........ Much higher Higher Same Lower ' Much lower
[^ Is the flosh point of the test wash: ..... ,,.,., ..................... Much lower Lower Sama Higher Much higher
I -! How does tlwi test wash compare on any other factors: ... ..... ; ..... Much worse Worse Same Better Much better
Add all nine scores on this worksheet to get the total score for this test blanket wash. Tfltu! ,
Remember, when adding negative numbers -2 *• 2 ~ B,
What does the score mean?
A score greater titan zero means the test wash may he a better choice than your facility's regular wash,
a score of zero indicates that the test wash is approximately the same, and a score of less than zero
indicates that the test wash may not he a better choice for your facility.
HnforthaMfomtS
155
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W orksheet
Questions
What Do They Mean?
prtee; Compared to your normal blanket wash, Is the price per gallon of the
test blanket wash much more, more, the same, less, or much less?
The must obvious difference between two blanket washes is the cosi to buy them. Compare
She cost per gallon of your normal wash to the test wash. Answer "much more"
if the test wash costs twice as much as your normal wash or "much less" if it Is half (he
price or less, factor in dilution ratios far those washes that art- .shipped us eo»cenui;Ues.
Amount ys0d par cleanings Compared to your normal blanket wash. Is the amount
of test wash used to clean each blanket much more, more, the same, less, or much less?
The more wush yon use each time you dean a blanket, the more it costs yon, Ask press
operators how much of the icst wash is needed to clean the hlankei compared to the amount
of normal wash. Answer "much more." If it takes twice its much test wash or "much low*" if It
takes Jess than half as much to clean Hte blanket,
Tim® to ci©ar% a blankets Compared to your normal blanket wash, \s the time
required to clean a blanket with the test wash much more, more, the same, less, or
much less?
Press* downtime costs money, if the test wash tykes twice as long to dean the blanket, answer
"much more". Answer "much less" if I he lest wash takes only half as long us your normal wash,
operator opinions Compared to your normal blanket wash What does the press
operator think of the test wash? Is it much worse, worse, the same, better, or much better?
Ask press operators to compute the lest wash to the normal wash on odor, hhmkct swell, the
lime required for the press to come b^ek to color; the effort required to use the washes, arid
any other factors they think ate important, Combine these into an overall score for this ques-
tion,
Use the
Worksheet to
Choose a Better
Roller Wash Too!
Hcaxsretails csheiiYiicail^; Does the test wash contain hazardous chemicals as defined by
environmental laws or the Occupational Safety and Health Act fOSHAJi'
O>macr the supplier or manufacturer for this information. A variety of environmental regula-
tions apply to hazardous mnmeM;ti law (such its RCUA,("AA, €EH~
CIA, or HPCUA - Section 2, etc,) or unties' OSHA. Never mix hEiyjirdous and non-hazardous
wastes. The hazardous chemicals In a blaisket wash, m clelliied by OSUA, ait1 itMiHlly listed Ui
Sectj<»n 2 of die MSDS form. !! this st*ciion .says "none", ycntr test wash prob.'ihJy does noi con-
tain (XSBA hiE^uxkn^s cJiemiculs, Ikil beware. The M.SD& lists OStiA l\$iznnJuiis dictiijcals only.
The bttiukct witsli may siill contain chehiicals defined as hszatxtous by oihcr Ciivironmeiiial reg~
ukttions. If this section is blank, ask your supplier. .See Qijestiaits to Ask Wltesi To^i
Youf BlanJfcct Wash Su|5pIIer for more infrHTtmtion,
156
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If the test wash vapor pressure (in imnHi]) is
Mote than ten times higher
Bsfwern ten times mt 1.5 times higher
Between 1.6 limes and ten tines lower
More than ten times lower
Evaporation: Compared to your normal blanket wash, Is the
vapor pressure of the test wash much higher, highar, the same,
lower, or much lower?
See MSOS Section ^ - Physical and Chemical Characteristics - for
vapor pressure information. Vapor pressure is a measurement of
how quickly a chemical evaporates. The higher the vapor pres-
sure of 3 blanket wash, the- quicker H evaporates If a blanket
wash has hazardous Ingredients, (hey can evaporate into the air in
your shop, enter the tungs of your workers, ami poHute the sur-
roumling environment, if the vapor pressure of your test vswh is
less than the wash you are currently using, is: may evaporate less in your shop. Vapor
pressure is usually expressed in mniMg. Gill your supplier if ihe vapor pressures of the
washes are expressed in different units. 10 nimHg is usually a regulatory cut-off, but the
lower
-------
IWt isfceMs
In kssp fes*S
wncb aiai i^n Afisr Lryi--?.;
ik. ?84S W*
-t;r=5~r!S Ibsr, tttf
cost. If a test wash scores
significantly better than
your normal wash, this
means the test wash might
be a better choice, but
does not guarantee it.
The Hidden Costs of Your Blanket Wash
The environmental, health, iintl safety costs of blanket washes are often hidden.
If your lest wash is tess harmful to your workers or (he environment, or is less
flammable than your current blanket wash, you may save money by using it even
if it costs more per gallon. Potential savings include:
* Decreased regulatory costs {such as i$|»s»l costs, control
equipment, permitting, peraiiflinp fees, training, fines)
••* Improved worker and safely
•-> insurance! costs (such as workers compensation, fire, and liability)
-«• Oilier decreased costs (such its energy)
Choosing a Better Wash—An Example
By testing ;< variety of washes you may be able to find one thai is cheaper to use and belter
for the environment. During the Dffi Lithography Project (set- page 6 for more information),
a vegetable ester wash was found that worketl well and cost less than a petroleum-based wash.
Cost per wash was calculated based on price per gallon, time required to wash a blanket, number
of towels, and amount used. Results showed the vegetable ester wash was cheaper to use
per blanket than the petroleum-based wash at one facility, but was more expensive at another
facility. While savings may he even greater when factors such as (hose on the worksheet are also
considered, these mixed results show how important it is to evaluate products in your own facility.
Use the Worksheet to Choose
Other Chemicals for Your Shop
The nine worksheet questions can be easily adapted to compare other
chemicals, such as roller washes, you test in your shop. These nine questions
are important to consider when making any chemical decisions for your facility.
Design far tin Envkmnt • •
158
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What You Can Do To
Compare Blanket Washes
follow, the checklist .
tn'lf»n> when testing
different blanket washes:
Test Blanket Wash for a Set
Amount of Time:
a Discuss blanket wash .
tests with press operators
o Sat a trial period of one
or two weeks with press
operators
n Record major observations
during test period
Collect Information from:
n Press Operators
n Material Safety Data
Sheets
>* Vapor pressure
information from
MSDS Section 3
=•*• Rash point
information from
MSDS Section 4
r> Blanket Wash Supplier
>* Percentage VOC
content
••!> Is blanket wash
considered hazardous
under environmental
regulations or OSHA?
Complete Worksheet:
n Enter each score in work-
sheet column
n Add scores for final result
Complete Evaluation:
n Does the final result
indicate potential
improvement?
o Are there other benefits or
costs of the test wash that
are not on the worksheet?
Don't Give Up
Keep in mind that the process of choosing a belter blanket wash will require some
experimentation and an open rninit. Not every blanket wash will work well. ;st yout shop
right away, but some .may work better as press operators become more comfortable with
them. For this reason, allow A set period of lime for trying a blanket wash, and stick u> iL
For more ideas on cost &ivi&g ways to reduce pollution and waste at your facitky, see other
Design for the Hm'itxmmtnt (DIB) Bulletins for the lithographic industry.
to Ask You Call Your
To complete the worksheet you wii! need to ask your supplier some important questions;
(Some blanket wash manufacturers may supply this information on the MSDS, but they
are not required to do so,!
I Does the blanket wash contain chemicals deemed hazardous
under any environmental statute or OSHA?
| What is the percent Volatile Organic Compound
{VOC} content
-------
Appendix E: Alternatives Evaluation Sample
Worksheets
This appendix presents an alternatives evaluation conducted by a small company.
The Significant Environmental Aspect (SEA) they identified was chemical hazard
to workers from a solvent.
160
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SCREEN ROOM COST IMPROVEMENT PLAN
Summary: A significant cost savings opportunity exists in our
Screen Room operations by changing the method we use chemicals
and also the vendor. Estimated yearly savings are $40,000. This is
attain by replacing the i&mrj ^ "Cleaner" and B«wd ©
Cleaner*' with Btttftd C. 'ttMnbr and replacing the fcw^ B
"Stencil Remover" with "Stencil Remover". The biggest
$ impact is the difference in price and yield of gflgmi C"Stencil
Remover". The price is $45/gal. compared to $85/gal. and the yield
is estimated to be twice as much. The increase in yield is a direct
result of not using the - fcrwrsd ^ "Cleaner".
r is non-hazardous. It contains no
cyclohexanone, xylene or glycol ether. The flash point is 122F.
ftmnd K Cleaner is considered a hazardous chemical. It
contains cyslohexanone and ethylbenzene, which the state of
California has determined to cause cancer. The flash point is 50F.
It has been an ongoing goal to eliminate the need of f5r®ty(| ^
"Cleaner" because of safety concerns. This proposal accomplishes
this and attains a significant cost saving.
COST SAVINGS DETAILS - Sheet Fed Operation
There are several steps performed in the Screen Room that use the
above chemicals as well as others. The following will be a
comparison of present methods to the proposed methods
highlighting usage, time required in the process, and noting
potential savings in chemical and labor costs.
161
-------
All Savings are based on 50 screens/day cycling through the
Screen Room:
Initial Screen Cleaning after removing from printing press:
Present Method
I. Spray 2 oz. Of S«wd Q Oloww onto the ink
side of screen
H. Squeegee off ink into small bucket below screen
in. Repeat steps 1 and 2
IV, Wipe with cloth rag saturated with 3 oz. of Brftdi A
"Cleaner", Repeats this operation an average of 3 times
V. Wipes with dry rag
VI. Total time; an average 5.5 minutes (This depends on
UY or Solvent ink used or whether black ink was used)
Proposed Method
I. Spray 1 oz, of ^rani O- Ckwmv" onto the ink
side of screen
n. Squeegee off ink into unall bucket below screen
HI, Repeat steps 1 arid 2
IV. Spray 1 oz. of 6ro«do de»mr, , °fl cjotn raS
wipe clean
V, Total time: an average of 4 minutes
Cost Comparison
I. Cost Elements:
1. BrtUM} 6 Gleourw - $800/5 5gals. or
.114/02.
2. j&wwyl* Cleanly - $590/55gals. or
.084/oz.
3. irvM C Cleaner , - $735/55gals. or
,104/oz.
162
-------
II. Present Method:
1. 4 oz. of. Bcwvi 8 awee - $ ,456
2. 9oz, of Brtind A CAeoww - J56
'Total Chemical Cost -$1.21
III. Proposed Method:
1, 3 02. of t Bratsft o Ckww , - $ .315
Total Chemical Cost - $ .315
IV, Yearly Chemical Savings:
50 X 250 X
- $.11,188
V. Yearly Labor
50 X 250 work X
1.5 minute / 60min./hour
X$10/hour = $3425
Reclaiming Process for Screens. Of the 50 cycle
through the Screen Room, only 30 (est.) go this
additional step to remove the emulsion.
Present Method
I. Spray 5 oz. of' Brftc>A (> ft-udw^t I on both
IL Power Rinse -1
DL Spray both with. ft firoiiAci z. '-9Goz.
IV. Power rinse with water - 1
V, Brush with BrotU C- fioitct%5 - both sldes-1.4oz.
VT. 10 minutes queue time so # V will work
VH. Power rinse with water -1 side
VIII. Move to Rinse
IX. Total time: an average of 8 minutes
163
-------
Proposed Method
I. Spray 5 oz. of BncM c^Prddw4-1 on both sides
H. Power rinse w/water - 1 side
HI. Spray with Brand o ft-cdM £. - 1 side-45oz.
IV, Power rinse w/water — 1 side
V. A) 25 % of screens; Brush with fim^d C- Proto^
-both sides-1.4oz,
B) 75% of screens: Wipe with cloth rag saturated with
6rAod G fajdaft ^-2 sides-2oz<: Go to step VII!**
VI 25% of screens; 10 minute queue time so #VA will
work
VIL 25% of screens; Power rinse w/ water - 1 side
VIII, Move to Rinse tank
IX. Total time; an average 6 minutes
**This is possible because of the elimination of • Brdni\ ^.
K Cleaner" which locks the image into the mesh.
BewnA C- "PryawYoV 3 will only be needed on dark colors,
part, black.**
Cost Comparison
I Cost Elements;
1. Bmnd Cx^toavtd 3. - $1,045/5Sgals. Or
.148/oz. ~
2. -SranA e> frtJAvidr ^ • $85/gaL (4 gals. Are
mixed with 51 gals. Of water) or ,012/oz. of blen
3, 8rA«i 0- ttx^ttfcfc-z. - $45/gal. (2 gals. Are
mixed with 53gals. Of water) or ,006/oz. of blend
4, E»n,\^ t m^wcf 3 -$I75/5gals. Or.273/oz
5. SrcuM Of rodftV ^ - $42/5gals. (1 quart is mixed
with 5 gals. Of water) or .003/oz. of blend
II. Present Method;
1. 5 oz, of Brand C-^ Pn^wcV d - $ .740
2, 90 oz. of 8rw\ ft Product x -1.126
164
-------
3. 1.4 oz, of tBrflwl o fta^ti- ^ - . 388
Total Chemical Cost $2.25
II. Proposed Method:
i. 5oz, of«»a\Ad'DjWi^?'''i - $.740
2. 45 oz. of BrwMl C- RtscM z .270
3. 25% of screens: 1.4 oz. of
Brfti^ O ftoUct-3 -388
75% of screens: 2 oz, of
eronlG ftutod-H- .022.
Total Chemical Cost $1,40 to $1.03
III. Yearly Chemical Savings:
12,5 screens/day(25% of total) X 250
workdays/year X $.85 savings/screen + 38.5
screens/day(7S% of total) X 250 workdays/year
X $1.22 savings/screen = $14,398
IV. Yearly Labor Savings:
30 screens/day X 250 workdays/year X 2 minutes
savings/screen / 60min./hour X $iO/hour= $2.500
YEARLY SAVINGS IN SCREEN OPERATIONS:
CHEMICAL SAVINGS = 325,586
LABOR SAVINGS « 5,625
TOTAL $31,211
165
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DESIGN ART
Collect
Customer Specs/
Develop Preliminary
Layout
Customer
Approval
Final Layout
Digital Output
to Film
RECEIVE MATERIALS
Inspect Shipments
Material
Handling and
Preparation
166
-------
PREPARE EMULSION AND SCREEN
Stretch Mesh
and
Attach to Frame,
Apply Emulsion
or capillary film
to mesh and dry.
Expose Negative
I
Wash to reveal
image and dry
ri.
Block out
and Pinhole
INK PREPARATION
Work Order
from
Account
Managemen
167
-------
PRINT
Register Press
for
Production Run
I
PRINT
168
-------
INPUT/OUTPUT SUMMARY
NC Process Flow Maps
RECEIVE MATERIALS
I Store Shipment
Inputs
a Energy
a Building Space
Q Safe Storage
Q Recordkceping
Outputs
a Leaking Containers
a Waste Products
Q Spills 0?)
II Inventory Control
Inputs
a Energy
a Kecordkecprng
Outputs
a Expired Products
U Waste Products
IjjIJtfateria.l Handling & Preparation
Inputs
Q Energy
o Recordkeeping
Outputs
Q Empty containers
169
-------
DESIGN ART
UCJoltcct
Inputs
a Bncrgy
Q Paperwork
Outputs
a Unusable Artwork
Q Waste Packaging Materials
Inputs
Q Energy
O Paperwork
a Proofing Materials
Outputs
a Spent Printer Toner (cartridge)
a Paper
a Unusable Artwork
a Waste Packaging
, Approval
Inputs
O Energy
a Paperwork
Inputs
Q Energy
Q Paperwork
V Digital Oufimt
Inputs
Q Energy
Q Paperwork
Q Film Stock
U Imaging Device
u Imaging Material
Outputs
u Spent Imaging Materials
O Waste Film
170
-------
PREPARE EMULSION AND SCREEN
I Strctcfr McHh & Attach to Frame
Inputs
U Frame
D Mesh
o Adhesive
Q Energy
o Paperwork
Outputs
Q Minimal Air Emissions
Q Waste Adhesive
P Waste Mesh
D Waste Frame (potential)
Q Used Razorblades
II Appiv Emulsion or CapHIary Film to Mesh and Drv
Inputs
D Energy
D Paperwork
0 Activator
D Film or Emulsion
a Water
Outputs
a Expired Emulsion
Q Waste Emulsion
Q Waste Activator
III
Inputs
Q Energy
Q Paperwork
o Film Positive (or negative)
D UV Bulbs
Outputs
Q UV Bulbs
a Film
IV Waah to JRpvoaJ Image & Dry
Input*
u Energy
a Water
a Light Bulbs
Outputs
u Waste Water
a Used Light Bulbs
171
-------
PREPARE EMULSION AND SCREEN (cont'd)
V BlockoutA
Inputs
p lincrgy
o Paperwork
a Bfockcml
a Water
a Tape
Outputs
G Waste Waler
a Waste Olockout
u Waste lilockout Applicator
a Expired Materials
172
-------
INK PREPARATION
/ Color Match Approval
Inputs
p Unergy
o Paperwork
o Jnk
O Substrate
Q Con miners
u Solvents
Q Additives
o Mesh
o UV Bulbs
Outputs
o Wasu>lt)k
o Mixing Sticks
o Empty Containers
u Color Proofing
O Substrate
u Used Shop Ilags
Q Waste Mesh (potential)
o Waslo Frame (potential)
Jl 'Mix Ink
Inputs
a Energy
a Paperwork
o Containers
a Substrate
O Solvents
o Ink
o Ink Additives
Outputs
o Waste Ink
o Waste Ink Additives
o limply Containers
Q Substrate
0 Mixing Sticks
U Used Shop Rags
173
-------
PRINT
I...l*rcj!l.Sct-iiB
Inputs
D Lmcrgy
a Paperwork
Outputs
a Used Shop Rags
^^
Inputs
Q Shop Hags
O Additives
D Solvents
o Paperwork
D Energy
O Substrate
U Ink
Outputs
a Used Shop Towels
D Tape
O Setup Paper
Q Waste Substrate
a Waste Ink
J1I Print
Inputs
D Energy
p Shop Rags
Q J'aperwork
a Solvents
a Additives
Q Substrate
Q Ink
Q Coatings
u Adhesivcs
Outputs
O Ueod Shop Rags
O Waste Jnks
o Waste Solvent
Q Spills (possible}
u Used Ink Containers
u Tape
174
-------
SCREEN RECLAIMING
I Appty Ink Remover
Inputs
D Solvent
a Shop Rags
Q Squeegee
D Ink Remover
D Storage Container
Outputs
U Used Shop Rags
D Waste Ink
D Spills (possible)
Inputs
D Energy
0 Water
Outpwte
D Waste Water
HI Jtcnioyc Km utsion or Capillary Jiilm
Inputs
Q Energy
D Shop Rags
D Water
o Stencil Remover
Q Scrubbers
Outputs
D Waster Waier
D Tape
D Used Shop Rags
Q Spills (possible)
IV Rinse
Inputs
a Energy
Q Waier
Outputs
Q Waste Water
Inputs
u
Q Water
Q Haxe Remover
a Scrubbers
Q Shop Rag$
175
-------
SCREEN RECLAIMING (cont'd)
Outpul*
Q Waster Water
Q Used Shop Rags
Q Spills (possible)
VIRingc .
Inputs
Q Kncrgy
u Water
Outputs
a Waste Water
VII Drv
Inputs
D Bncrgy
176
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FINISHING, PACKAGING, & SHIPPING
I
Inputs
D Paperwork
u Knergy
u Pinshing Materials
u Finish ing Tools
Q Tape
Outputs
u Waste Material
P Trim m ings
u Adhesive
a Spcnl Finishing Materials
a Spent Finishing Tools
Jl Packaging Activities.
Inputs
o Knergy
D Paperwork
Q Pallets
o Boxes
Q Packing Materials
O«tpn
-------
SIGNIFICANT ENVIRONMENTAL ASPECTS (SEAs)
1} Reduce VOCs
2) Contain lead con tarn inaiion (water table)
3) Employee health and safety
178
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Worksheet 8-1: Functions and Alternatives
Aspect
e*S*l*w»
R*tt+»b«
Alternative Product*
•Scr-eM-n clato***/
|V\V- ir-e*vxov*»-
•^tXtAVk.
rxuw/^ifcre*,
teiW C-, qeinffcr
^rttrd D G\eaney
Alternative
Technologies
OV-BV
fVrto> iOl^JZ^s
UJ«.sUav
Alternative Work
Practices
Recycling/
Reuse
Treatment
Disposal
Date Completed: Contact Person:
Worksheet 8-2: Alternative Products Environmental Effects Comparison
Chemical Product
Baseline
'Srarvic Cipher
Brand D cieaiw
Known Effects1
^•*-vnc-c.y
f4» F, P.
c?dor
SK,n
irr»4^hw^i
Management of Effects2
3f'ov<-*>
^\OV«*^
**tatM.t,f ^-v-s
glovj^C,
ex-Kausf fsct^.
Cost of
Mgmt1
5«.ryut
s^^vm.
Resource
use
rVA
K)A
NA
Effects
Score
Notes:
1 Return to the "Environmental Concerns Worksheet" in Module 5 for the "known effects."
2 List protection required for each effect.
} Identify cost items.
179
-------
Worksheet 8-3: Performance Comparison of Alternatives
how well does K work how long does It take how easy Is It to use total
cWarw
Better
Brand
\s
Worksheet 8-4: Regulatory Comparison of Alternatives
Regulations Requlrad
Controls Required
(Itet)
Cost of Regulations
Total
6mr«1 A
Br-Ocrvl
180
-------
Worksheet 8-5: Cost Comparison of Alternatives
raw
material
labor
dtopoaal
touicoct
aavlnga '
Mteoat
*»«/•>
Worksheet 8-6: Alternative Products Evaluation Worksheet
Chemical Product
tondA-
frWo
&«wdp
Performance
—
•/-
••f
Regulations
^
•f-
f-
Coat
r-
+ *-
i~-
Effects1 Score
—
-f
4- f-
Overall
Score1
Date Completed: Contact Person:
' Take score from Environmental Effects Comparison Table above (last column).
2 Score on a scale of low to high to reflect the desirability of each product. This is a judgment call.
181
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Appendix F: How To Evaluate Costs And Savings
Of Alternatives
This appendix presents a rudimentary introduction to project financial analysis -
whole textbooks have been written on this subject! While you may not quite need
that level of detail for assessing your baseline and alternatives, a list of other
resources is included in Appendix G (References and Resources). Your accountant
can assist you in your analysis as well.
There are many factors to consider when evaluating alternatives. Will the
alternatives perform as well? What are the environmental effects of alternatives?
How much will each alternative cost? Module 4 describes ways to evaluate
alternatives for environmental aspects that you want to change. This Appendix
further describes one of those steps - Step 8: Evaluate the cost of the baseline and
alternatives - and provides an example and guidance on where in your business to
find cost data necessary for this evaluation step.
Many costs, especially environmental costs (waste hauling or disposal costs, for
example) are often "hidden" in overhead accounts. These costs are usually
unintentionally omitted from a financial analysis. If an alternative will reduce the
amount of waste generated, for example, thereby reducing waste disposal costs,
this savings may be omitted from a conventional analysis. Other costs and savings
may not be included in a financial analysis because they are "less tangible," or
difficult to quantify. Table F. 1 gives examples of some of these costs. When
evaluating alternatives, it is important to fully assess potential costs and benefits of
the alternative, as well as your baseline costs, to provide a complete picture of the
relative costs and savings.
Table F.1: Examples of Potentially Hidden and Less Tangible Costs
Potentially Hidden Costs
Up-front: site preparation, permitting, installation
Back-end: site closure, disposal of inventory,
post-closure care
Regulatory: training, monitoring, recordkeeping
Less Tangible Costs
Liability: Superfund, personal injury,
property damage
Future regulatory compliance costs
Employee safety and health
compensation
Organizational image
Evaluating the cost of the baseline and alternatives requires several steps as
described below. A description of these steps is followed by an example.
Step 1: Map baseline and alternatives. Module 1 describes how to develop a
map of your company's processes, products, and services. This map is important
182
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to understanding the activities occurring in your facility that cost you money. To
also understand the potential costs and savings of alternatives, it is important to
develop process maps for alternatives if the alternative will vary your current
processes. For example, Figure F.I shows a metal finisher's baseline cleaning
process using a solvent, which is collected and shipped off-site for proper disposal.
One alternative examined by the metal finisher was installing a distillation system
that could recover 95% of the spent solvent. Figure F.2 shows the process map
with the distillation system - spent solvent is collected, recycled on-site, and re-
used in the cleaning process. The map helps you visualize the differences
between the baseline and alternative, and can help guide you in collecting cost
data.
Note: Remember to include
potentially hidden and less
tangible costs.
Step 2: Collect annual operating costs for
baseline and alternatives. Using the process
maps from Step 1 you can now begin collecting
annual operating costs for both your baseline
and alternatives. Use Worksheet 4-5a to help you collect cost information. Table
F.2 lists examples of some of these costs that may be relevant to your baseline and
alternatives. Costs that are the same for the baseline and the alternative can be
omitted from the analysis. In the solvent cleaning example, labor time and energy
required for cleaning remains the same for both the baseline process and the
solvent recycling alternative. Therefore, these costs can be excluded from the
analysis.
Be as thorough as possible when considering costs, but don't worry about how you
classify costs. For example, you may wish to consider personal protective
equipment as a regulatory compliance cost, especially if its use is required by
regulations. Alternatively, you may wish to classify all protective equipment as
"materials."
183
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Figure F.1 Current Cleaning Process
Solvent-
Energy-
Product
Input
Cleaning
Spent
Solvent
Product
Output
Figure F.2 Alternative Cleaning Process
Make-up
Solvent
Energy-
Product
Input
-Recovered Solvent-
Cleaning
Product
Output
-Spent Solvent-
Distillation
184
-------
Note: Remember that
changes in one process may
affect costs in other
processes. You should
Environmental projects may save you money
not only by reducing your costs, but also by
generating revenues. For example, an alternative
may increase your product throughput because
the activity takes less time to complete, or
product quality may be improved enabling you to sell more of your product. The
alternative may also let you recover materials previously disposed of, and generate
revenues through sales of the reclaimed material (such as recovering metal scrap
which can be sold to scrap dealers). These annual revenue effects should be
considered using Worksheet 4-5b to assist you. Quantify these revenue effects if
possible, and add them to the total operating costs in Worksheet 4-5d. If these
potential revenues are difficult to quantify, you can consider them qualitatively in
your evaluation by making a note in the last column of Worksheet 4-5d.
By convention, costs (or outflows) are usually denoted by a negative (-) sign while
an inflow (or revenue) is denoted by a plus (+) sign. Make sure to keep these
signs correct when adding revenues to costs. For example, if the annual operating
cost of your alternative is -$20,000, but the alternative will generate an additional
$10,000 in revenues, your total annual operating cost would be -$10,000.
185
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Table F.2 Annual Operating Costs
Materials (Purchase, delivery, storage)
Raw materials
Solvents
Catalysts
Personal protective equipment
Maintenance supplies
Direct labor (Wages, benefits)
Operating
Supervision
Inspection
Utilities
Electricity
Steam
Water
Fuel
Waste management (Labor, materials)
On-site handling
Treatment
Storage
Hauling
Disposal
Regulatory compliance (Labor, materials)
Labeling
Manifesting
Record keeping
Permitting
Reporting
Protective equipment
Insurance
Commercial general liability
Workers' compensation
Health insurance
Pollution liability
Future liability
Fines/penalties
Legal costs
Business shutdown
Personal injury
Property/natural resource damage
Remediation
Step 3: Collect initial investment costs for each alternative. If any of your
alternatives will require an investment in new equipment, you will need to
consider these costs. These not only include capital costs, but also other one-time
costs accompanying your investment, such as installation costs or new equipment
training. Use Worksheet 4-5c to help you collect these costs. Table F.3 lists
examples of these costs that may be relevant to your alternatives.
Step 4: Calculate net present value for the baseline and alternatives. The
next step enables you to compare the baseline and alternatives to determine which
options appear to be most financially attractive. Because a change in your
processes or activities may affect your costs and savings over many years, the
analysis should look at long term costs and savings. For example, if you are
considering installing new equipment that will last
for 10 years, your analysis should include the costs and savings that will accrue to
you over the 10 year period. This is especially important for environmental
projects which often times reap benefits over the long term.
186
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Table F.3 Initial Investment Costs
Purchased equipment (Purchase, tax, delivery)
Process equipment
Storage and materials handling equipment
Safety/protective equipment
Monitoring/control equipment
Laboratory/analytical equipment
Waste handling/treatment equipment
Initial spare parts
Utility systems/connection
Electricity
Water
Steam
Fuel
HVAC
Plant air
Inert gas
Sewerage
Refrigeration
Plumbing
Planning/engineering (Labor, materials)
Consultant/contractor fees
In-house planning/engineering
Procurement
Vendor fees
Site preparation (Labor, materials)
Consultant/contractor fees
In-house
Demolition & clearing
Equipment rental
Equipment/rubbish disposal
Disposal
Grading/landscaping
Vendor fees
Construction/installation
Consultant/contractor fees
In-house
Equipment rental
Vendor fees
Start-up/training (Labor, materials)
Consultant/contractor fees
In-house
Safety/environmental training
Trials/manufacturing variances
Vendor fees
Permitting
Consultant/contractor fees
In-house
Permit fees
Vendor fees
Other
Buildings
Land
Contingency
Working capital (cash, inventory)
187
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A critical component of assessing a project where costs and savings may occur
over several years is incorporating the notion that the value of money changes
over time - commonly called the "time value of money." Most businesses prefer
to have money sooner rather than later. If you have money today, you have the
opportunity to use it now to grow your business, for example. Put another way,
there is a cost if you receive the money tomorrow instead of today. For example if
you receive $1,000 today and put it in the bank receiving 10% interest, at the end
of the first year you would have $ 1 , 1 00. This is clearly preferable to receiving
$1,000 a year from now. Thus, because $1 today is not equal to $1 tomorrow, you
need to adjust the value of future dollars to reflect their diminished value to you
today.
The mechanism for making this adjustment is called a discount rate. A discount
rate is a percentage that is applied to future costs or revenues to determine its
present value. Typically, for business decisions, the discount rate chosen
represents the business 's cost of capital plus some level of desired return on an
investment plus an additional margin to account for uncertainty. Your accountant
will be able to assist you in selecting an appropriate discount rate for your
analysis.
To calculate the present value (PV) of a cost or savings in the future, use the
following equation:
(1 + r)
where FV = the future value of a cash flow (i.e., a cost or cash outflow, or a
revenue or cash inflow) received in year t, and
r = the discount rate.
For example, the present value of a $1,000 revenue you expect to receive over the
next four years would be:
$1000 $1000 $1000 $1000
PV=~, - T-1 + -T - r-2+? - r-3 + ? - ^4 Of.
(1 + 0.10) (1+0.10) (1 + 0.10) (1+0.10)
188
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Year
1
2
3
4
Total
Future
Value
$1000
$1000
$1000
$1000
Present Value
$ 909
$ 826
$ 751
$ 683
$3169
The net present value (NPV) can then be calculated as follows:
and
where XPV is the sum of the present values of the cash inflow or outflows
I = the initial investment cost.
In our above example, if the initial investment cost is $1000, then the NPV equals
$2169 ($3169 - $1000). If your alternative won't require an initial investment -
for example, you are substituting a toxic chemical with a less hazardous chemical,
but there are no changes in your equipment, then NPV is equal to the sum of the
present values ($3169 in the above example).
Note: In financial analyses, a cost
(or outflow) is usually denoted by a
negative (-) sign while an inflow (or
revenue) is denoted by a plus (+)
NPV can be calculated using a financial
calculator, spreadsheet software like
Excel, or using project profitability
analysis software such as P2/FINANCE
(see the resources list at the end of this
Appendix).
Step 5: Assess the costs and savings. The last step is to evaluate your baseline
and alternatives from a cost and savings perspective. The difference between the
alternative and baseline is entered in Worksheet 4-6. A positive number indicates
that the alternative saves money, while a negative number indicates that the
alternative is more expensive than the baseline. The alternative with the greatest
NPV is the most profitable one.
Note: Remember that your accountant can assist you in these calculations.
189
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Example: Baseline vs. Alternative Cleaning Processes
As described above, as part of its EMS, a metal finisher examined methods for
reducing solvent use in cleaning. Recovering solvent via a distillation system was
one alternative identified. The cost and savings analysis of the baseline versus
alternative follows.
Step 1: Map baseline and alternatives. These processes are mapped in Figures
F.I andF.2.
Step 2: Collect annual operating costs for baseline and alternatives. The
current annual costs for the baseline are shown in Table F.4. These costs are
readily available from purchase orders. Because labor and electricity costs for the
cleaning operation remains the same for the baseline and alternative, these costs
are omitted from our analysis.
Table F.4 Annual Operating Costs -- Baseline
Annual Operating Costs
MATERIALS
Solvent
WASTE MANAGEMENT
Solvent disposal
$/year
11,631
19,041
Annual operating costs for the alternative are shown in Table F.5. Material costs
include make-up solvent (because 95% of the solvent is recovered from
distillation, make-up solvent must be added) as well as oil and filters for the
distillation system. Electricity costs are for operating the distillation system only
(electricity use for cleaning is the same for both the baseline and alternative).
These costs are available from the equipment vendor.
Table F.5 Annual Operating Costs - Cleaning with Solvent Recovery
Annual Operating Costs
MATERIALS
Chemicals
Oil
Filters
WASTE MANAGEMENT
Disposal
UTILITIES
Electricity
$/year
6692
375
2284
439
241
190
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These operating costs are entered into Worksheet 4-5a. Note that there are no
potential annual revenue effects for the alternative project so Worksheet 4-5b is
not included.
Step 3: Collect initial investment costs for each alternatives. The initial
investment costs for the distillation system, provided by the equipment vendor,
appear in Table F.6. These costs are then entered in Worksheet 4-5c.
Table F.6 Initial Investment Costs for the Distillation System
Investment Costs
PURCHASED EQUIPMENT
Distillation system
START-UP/TRAINING
Start-up & Training
Cost in $
26,200
750
191
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Worksheet 4-5a - Annual Operating Costs
Alternative
A (Baseline)
B
Materials
11,631
9,351
Direct
labor
Utilities
0
241
Waste
management
19,041
439
Regulatory
compliance
Insurance
Future
liability
Total
Operating
Cost
30,672
10,031
Worksheet 4-5c - Initial Investment Costs
Alternative
A (Baseline)
B
Purchased
equipment
—
26,200
Utility systems/
connection
—
Planning/
engineering
—
Site
preparation
—
Construction/
Installation
—
Start-up/
training
—
750
Permitting
—
Other
—
Total Inv.
Costs
—
26,950
Worksheet 4-5d - Cost Comparison of Alternatives
Alternative
A (Baseline)
B
Total Operating Costs
(Present Value)
-233,293
-76,296
Total Investment Costs
(Present Value)
N/A
-26,950
NPV
-233,293
-49,346
Annual Revenue
Effects (qualitative
Worksheet 4-6 - Evaluation of Alternatives
Alternative
A (Baseline)
B
Environmental
Effects
Performance
Regulatory
Considerations
NPV (Alternative -
Baseline)
—
$183,947
Overall Evaluation
192
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Step 4: Calculate net present value for the baseline and alternatives. Next, the net
present value for the baseline and alternative is calculated using the company's discount
rate of 10%. Because the lifetime of the distillation system is 15 years, operating costs are
assessed over 15 years. These costs are entered in Worksheet 4-5d. Remember that cash
outflows (such as investments or operating costs) are entered using a negative (-) sign
while inflows (revenues) are denoted by a plus (+) sign.
Step 5: Assess the costs and savings. Worksheet 4-5d shows that the NPV for the
baseline is -$233,293 while the NPV of the alternative is -$49,346. The difference
between the alternative and baseline (alternative minus baseline) is entered in Worksheet
4-6. A positive number indicates that the alternative saves money, while a negative
number indicates that the alternative is more expensive than the baseline. Worksheet 4-6
shows that the distillation system will save the metal finisher $183,947 over 15 years.
Getting Started - Where to Find Cost Data
You now have the tools to evaluate the cost and savings of your alternatives. However,
you may not be sure where to find the data necessary for conducting this analysis. To
assist you, Table F.7 lists costs and sources for these data in your business. Note that when
collecting similar cost data for your alternatives, suppliers and vendors are frequently a
good information source.
Future assessments can benefit from improving your business' current cost tracking
system. While at first glance this may seem intimidating, you can begin to incorporate
these costs into your accounting framework one step at a time. Begin by tracking a few
costs on a routine basis, selecting the most significant costs first. You may want to begin
by examining the costs associated with environmental issues to gain a better awareness of
how they affect your business' bottom line. Use this awareness to focus your efforts on
specific cost areas that appear to have the most importance to your business. As your
level of knowledge increases, you can expand your cost tracking system to include other
cost data. Eventually you will have a system that meets your needs and provides you with
extensive crucial business information.
193
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Table F.7 Where to Find Costs
Cost Category
Process Chemicals
Ancillary Chemicals
Storage Space
Waste Treatment
Testing
Disposal
Training
Personal Protective
Equipment
Insurance
Production
Taxes/Fees
Environmental
Compliance
Maintenance Labor
Maintenance Materials
Water Usage
Electricity Usage
Steam Usage
Data Elements
Usage Rates
Unit Costs
Usage Rates
Unit Costs
Total Square Footage
Cost/Sq. Ft.
Flow Rates
Total Chemical Costs
Number of Tests/Year
Cost per Test
Type and Quantity
Disposed
Unit Costs of Each
Number of People
Number of Trainings
Length of Training
Hourly Labor Rates
Type and Quantity Used
Cost per Item
Type and Coverage
Premium
Machine Down Time
Machine Rates
Labor Rates
Sewer Use Tax
Chemical Use Tax
Water Use Tax
Volume of Weight of
Each Taxed Item
Hours of Labor for All
Compliance Tasks
Hours of Labor
Tasks Performed
Amount of Materials
Costs of Materials
Annual Usage Rate
Cost/Gal, or Cu. Ft.
Annual Usage Rate
Cost/kWh
Cost of Production
Fraction of Total
Used by Process
Where Found
Production Records
Purchase Orders
Prod. Specifications
Purchase Orders
Actual Measurement
Rental Contract
WWT Log Sheets
Purchase Orders
Environmental Files
Invoices
Manifests
Invoices
Training Records
Wage Rate Sheet
Stock Room or
Inventory
Capital Budgets
Invoices
Prod. Records
Operating Budget
Personnel Records
Water Bills
Environmental Records
Water Bills
Water, Chemical
Usage Records
Estimates, Salaries, or
Environmental
Management
Records
Maintenance Log
Maintenance Log
Purchase Orders
Flow Meters or Logs
Town Water Bills
Equipment Specs.
Utility Bills
Fuel Bills, Boiler
Maintenance Logs,
Count of Processes
Using Steam
Who to Ask
Foreman
Billing Dept.
Product Engineers
Billing Dept.
Maintenance or
Engineering
Billing Dept.
WWT Operator
Purchasing Dept.
Environmental Manager
Accounts Payable
Environmental Manager
Accounts Payable
Environmental Manager
or Contractor
Personnel Dept.
Environmental Manager
Purchasing Dept.
CFO, Accountant
Accounts Payable
Production Manager
Finance Dept.
Personnel Dept.
Accounts Payable
Environmental Manager
Local POTW
Production Manager,
Purchasing
Environmental Manager
Maintenance Dept.
Shop Foreman
Maintenance Dept.
Purchasing Dept.
Production Manager
Accounts Payable
Production Manager
Accounts Payable
Accounts Payable
Maintenance Dept.
Plant Walk-Through
Source: Appendix C of Total Cost Assessment for Environmental Engineers and Managers (John Wiley
&Sons, 1998).
194
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Appendix G: References And Resources
General Resources
The ISO 14000 Handbook, edited by Joseph Cascio, Chairman, US Technical Advisory
Group to ISO/TC 207, CEEM Information Services, Fairfax, Virginia, 1996.
Environmental Management Systems: An Implementation Guide for Small and Medium-
Sized Organizations, NSF International, Ann Arbor, Michigan, November 1996.
Developed with funding through a cooperative agreement with the U. S. EPA, Office of
Wastewater Management and Office of Enforcement and Compliance Assurance.
EPA Position Statement on Environmental Management. Federal Register: March 12,
1998 (Volume 63, Number 48), pp. 12094-12097.
Design for the Environment, Building Partnerships for Environmental Improvement,
Design for the Environment, U. S. EPA, EPA/600/K-95/002, September 1995.
Federal Environmental Regulations Potentially Affecting the Commercial Printing
Industry, Design for the Environment, U. S. EPA, EPA744B-94-001, March 1994.
"Compliance-Focused Environmental Management System — Enforcement Agreement
Guidance," EPA-330/9-97-002R, U. S. EPA, Office of Criminal Enforcement, Forensics
and Training, August 1997, Revised January 2000.
"Improving Environmental Performance and Compliance: Ten Elements of Effective
Compliance Systems." Enforcement Cooperative Program of the Commission for
Environmental Cooperation, June 2000. (www.cec.org)
Government Printing Office (GPO)
The GPO website provides links to the full text of the Code of Federal Regulations (CFR),
Federal Register notices for the past several years, and other resources.
Website: www.access.gpo.gov/nara/
The Clean Air Technology Center (CATC)
A source of general information on air emissions-related technology.
Telephone: 919-541-0800
Website: www.epa.gov/tnn/catc
195
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The RCRA, Superfund & EPCRA Hotline offers information and publications that are
relevant to RCRA.
Telephone: 800-424-9346
Website: www.epa.gov/epaoswer/hotline
The Office of Water
The Office of Water, especially the Office of Wastewater Management, can be contacted
for information on Clean Water Act provisions that relate to the printing industry.
Telephone: 202-260-5700
Website: www/epa/gov/OW
The Safe Drinking Water Hotline can provide information on issues related to the Safe
Drinking Water Act.
Telephone: 800-426-4791
Website: www.epa.gov/OGWDW/
The Superfund Website provides general information on CERCLA.
Website: www/epa.gov/superfund
The Chemical Emergency Preparedness and Prevention Office website offers information
on the emergency response aspects of EPCRA, which are administered under the
Chemical Emergency Preparedness and Prevention Office.
Website: www/epa.gov/swercepp/
The Toxics Release Inventory website provides information on the Toxics Release
Inventory reporting requirements, which are implemented by the Office of Pollution
Prevention and Toxics.
Website: www.epa.gov/opptintr/tri/index.html
The Occupational Safety and Health Administration (OSHA) website provides
information on the Occupational Safety and Health Act, OSHA regulations, standards,
interpretations, and other information.
Website: www.osha.gov/
Technical Resources
Cleaner Technologies Substitutes Assessment, A Methodology & Resource Guide, Design
for the Environment, U. S. EPA, EPA744-R 95-002, December 1996.
Cleaner Technologies Substitutes Assessment, Industry: Screen Printing; Use Cluster:
Screen Reclamation, Design for the Environment, U. S. EPA, EPA744-R-94-005,
September 1994.
196
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Information on developing a Cause and Effect (Fishbone) Diagram is available at:
www.sytsma.com/tqmtools/cause.html
Cost Resources
Journal Articles/Publications
Aldrich, James. R., 2000. "P2 and the Bottom Line - Choosing Variables: What Factors
Should You Include when Analyzing the Value of a P2 Project?" Pollution Prevention
Review. John Wiley & Sons, Inc. Summer.
Aldrich, James. R., 1999. "P2 and the Bottom Line - Net Present Value," Pollution
Prevention Review. John Wiley & Sons, Inc. Summer.
Aldrich, James. R., 1999. "P2 and the Bottom Line - Internal Rate of Return," Pollution
Prevention Review. John Wiley & Sons, Inc. Spring.
Aldrich, James. R., 1998. "P2 and the Bottom Line - Depicting Financial Impacts Over
Time," Pollution Prevention Review. John Wiley & Sons, Inc. Autumn.
Aldrich, James. R., 1998. "P2 and the Bottom Line - The Time Value of Money,"
Pollution Prevention Review. John Wiley & Sons, Inc. Summer.
Kennedy, Mitchel, 1998. "Critical Issues of Total Cost Assessment: Gathering
Environmental Cost Data for P2," Pollution Prevention Review. John Wiley & Sons, Inc.
Spring.
Pojasek, Robert B., 1998. "Practical Pollution Prevention - Activity-Based Costing for
EHS Improvement," Pollution Prevention Review. John Wiley & Sons, Inc. Winter.
Pojasek, Robert B., 1997. "Understanding a Process with Process Mapping," Pollution
Prevention Review. John Wiley & Sons, Inc. Summer.
U.S. EPA, 1995. An Introduction to Environmental Accounting as a Business
Management Tool: Key Concepts and Terms (EPA 742-R-95-001).
White, Allen L., Becker, M., and Savage, D., 1993. "Environmentally Smart Accounting:
Using Total Cost Assessment to Advance Pollution Prevention," Pollution Prevention
Review. John Wiley & Sons, Inc. Summer.
197
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Software Tools
P2/FINANCE (Pollution Prevention/Financial Analysis Cost Evaluation System) This
software provides spreadsheets (Microsoft Excel) for evaluating the profitability of
pollution prevention and other types of projects. It can be downloaded free of charge from
EPA's web site: www.epa.gov/opptintr/acctg
E2/FINANCE (Energy and Environment /Financial Analysis Cost Evaluation System)
This software is useful for evaluating the profitability of energy efficiency, pollution
prevention and other types of projects. It can be downloaded free of charge from Tellus
Institute's web site: www.tellus.org
Web Sites
The US EPA Environmental Accounting Project web site (www.epa.gov/opptintr/acctg)
contains case studies and other documents.
Other Resources
Design for the Environment Printing Project, Lithography Case Study 1, Managing
Solvents and Wipes. U. S. EPA, EPA 744-K-93/001, October 1995.
Designing Solutions for Screen Printers, An Evaluation of Screen Reclamation Systems,
Design for the Environment, U. S. EPA, EPA744-F-96-010, September 1996.
Solutions for Lithographic Printers, An Evaluation of Substitute Blanket Washes, Design
for the Environment, U. S. EPA, EPA744-F-96-009, September 1997.
EMS Gap Analysis, The Lexington Group, Environmental Management Consultants, Inc.,
©1997.
For a full list of DfE Program publications, contact EPA's Pollution Prevention
Information Center, 1200 Pennsylvania Ave., N.W. (7409), Washington, DC 20460.
Phone: 202/260-1023; Fax: 202/260-4659
E-mail: ppic@epa.gov
http: //www. epa. gov/opptintr/library/ppicdist. html
DfE website: http://www.epa.gov/dfe
The John Roberts Company
9687 East River Road
Minneapolis, MN 55433
(612)755-0394
198
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Ecological Benefits Assessment Model (EBAM)
What does EBAM do?
> Estimates the ecological benefits of risk management alternatives in economic
terms.
> Estimates the dollar value of the ecological benefits of risk management
alternatives on recreational fishing.
> Estimates the dollar value of environmental damages.
Technical Contact:
Lynne Blake-Hedges
U.S. Environmental Protection Agency
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-7241
E-mail: blake-hedges.lynne@epa.gov
Chemical Screening Tool for Exposure and Environmental Release
(ChemSTEER)
What does ChemSTEER do?
> Estimates occupational inhalation and dermal exposures during chemical
manufacturing, processing, and use activities.
> Estimates chemical releases to air, water, and land that are associated with
chemical manufacturing, processing, and use.
For more information about the tool, contact:
Scott Prothero
U.S. Environmental Protection Agency
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-1566
E-mail: prothero.scott@epa.gov
199
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Use Cluster Scoring System
What does the UCSS do?
»• The Use Cluster Scoring System (UCSS) is a computer-based, risk-screening
system with information about nearly 3,200 chemicals in the 380 clusters — or
families — into which these chemicals are grouped. For example, instead of
considering a single chemical that happens to be a paint stripper, the cluster of
chemicals that perform as paint strippers is considered.
> The UCSS accesses hazard and exposure data that are extracted from the Toxics
Release Inventory (TRI), the Integrated risk Information System (IRIS), and other
readily accessible risk assessment related databases.
> The UCSS then uses a simple system to score and rank chemicals and their
respective clusters. The program was developed to identify clusters of chemicals of
potential concern to EPA.
For additional information about the Use Cluster Scoring System, contact:
Frankly n Hall
U.S. Environmental Protection Agency
OPPT, Economics, Exposure & Technology Division
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-9596
E-mail: hall.franklyn@epa.gov
Graphical Exposure Modeling System (GEMS)
What does GEMS do?
> GEMS will connect outdoor air, surface water, soil, groundwater, and multimedia
models with some of the environmental and population data needed to run the
models.
> GEMS will estimate environmental concentrations in a variety of environmental
media.
> GEMS will have graphics capabilities for displaying data and environmental
modeling results.
For more information about the model, contact:
Lynn Delphire
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Phone: 202-260-3928
E-mail: delphire.lynn@epamail.gov
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Exposure, Fate Assessment Screening Tool (E-FAST)
What does E-FAST do?
> Provides screening-level estimates of the concentrations of chemicals released to
air, surface water, landfills, and from consumer products.
> Estimates potential inhalation and ingestion dose rates resulting from these
releases.
> Modeled results, estimates of concentrations and doses, are designed to be
conservative.
For more information about the model, contact:
Tom Brennan
U.S. Environmental Protection Agency
401 M Street, S.W. (7406)
Washington, D.C. 20460
Phone: 202-260-3920
E-mail: brennan.thomas@epamail.gov
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Appendix H: Blank Worksheets
This appendix contains blank copies of all the worksheets presented in the Implementation
Guide, for your use. The worksheets are identified by the same numbers used in the
Guide. For example, Worksheet 6-1 would be the first worksheet found in Module 6.
202
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Worksheet 1-1: Costs and Benefits of Developing and Implementing an IEMS
Costs
Contact Person:
Benefits
Date completed:
203
-------
Worksheet 1-2: IEMS Responsibilities
IEMS Function
Person
Regular Position
Management Representative
IEMS Coordinator
IEMS Committee
Contact Person:
Date Completed:
Corresponds to RESP-01 of the Company Manual Template.
204
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Worksheet 1-3: IEMS Development Schedule and Resources Worksheet
Module
Making the Commitment: Creating a Policy Statement and
Determining the Scope
Intermediate steps: (As appropriate)
Planning the Process: Decision Points, Leadership &
Participants, Schedule & Plan
Intermediate steps: (As appropriate)
Determining Significant Aspects: Prioritizing Concerns and
Setting Objectives
Intermediate steps: (As appropriate)
Developing Operational Controls
Intermediate steps: (As appropriate)
Participants
Budget
Target Completion
205
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Making Improvements: Evaluating Alternatives and Setting
Targets
Intermediate steps: (As appropriate)
Implementation: Building Organizational Support for Your IEMS
Intermediate steps: (As appropriate)
Setting Up Environmental Management Projects; Measuring
and Achieving Success
Intermediate steps: (As appropriate)
Establishing Continuing Improvement
Intermediate steps: (As appropriate)
Contact Person:
Date Completed:
206
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Worksheet 1-4: Persons Responsible for IEMS Development
Roles
"Management representative" having responsibility for implementing the
EMS (in small businesses, this could be the owner).
IEMS Coordinator
IEMS Team Participants
Identifying and determining significance of environmental aspects.
Identifying and determining applicability of legal and other requirements.
Competency-based training.
Operational controls.
Emergency preparedness and response.
Monitoring and measurement of "key characteristics" of operations and
activities that can have significant environmental impacts (i.e., the
"significant environmental aspects.").
Periodic evaluations of environmental compliance.
Handling and investigating non-conformance with the EMS.
Records management.
Internal EMS audits.
Individual(s)
Responsible
Contact Person:
% of Time
Designated
Budget
Date Completed:
Note: Most of these blocks will be filled in as development of the IEMS progresses. This worksheet will help track progress and serve to remind
the team and management of necessary assignments.
207
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Worksheet 1-5:* Identifying Environmental Aspects
Input/Output
Environmental Aspect
(quantify if available)
Environmental Impact
Office Activities
Manufacturing Process
Building Maintenance
Products and Services
Contact Person:
Date Completed:
Use the information you have included here to fill in EA-02 in the the Company Manual Template.
208
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Worksheet: 1-6* Regulations
Regulatory Agencies
Regulations That
Apply to My Business
Sector
Business Operations
Potentially Affected
Does it Apply to My
Business?
Contact Person:
Date Completed:
"Corresponds to Table LR-01 in the Company Manual Template
209
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Worksheet 3-1: a Health, Safety and Environmental Potential Effects Information
Operation
Environ-
mental
Aspect
Informa-
tion
Sources
Regulatory Data: D
Carcinogen?
OSHA Permissible
Exposure Limit (PEL)?
Volatile Organic
Compound (VOC)?
Toxics Release
Inventory (TRI)?
Contact Person:
Human Health Effects by Pathways
Acute and Chronic c
Inhalation
Dermal
Oral
Effects on wildlife
and Other
environmental effects d
Air
Water
Land
Worker
Safety
Rank
Human
Env.
Date Completed:
a Corresponds to Table EA-03 in Company Manual Template.
b Most information for this column can be found on the MSDS.
c Partial information for these columns might come from the MSDS, but other resources may be needed. In particular, acute effects are usually reported on MSDS sheets.
Chronic effects are sometimes on MSDS sheets, but often will have to be found elsewhere. LC refers to lethal concentration. Inhalation LC50 is the concentration of a
chemical in air that causes death in 50 percent of the test organisms at the end of the specified exposure period. LD refers to lethal dose. LD50 is the dose of a chemical
taken by mouth, absorbed by the skin, or injected that is estimated to cause death in 50 percent of the test animals. Lethal dose data are expressed in terms of amount of
chemical divided by the body weight, e.g., mg/kg.
d MSDSs usually do not include environmental effects.
Note: For more information on risk-related data, including methods for interpreting quantitative toxicity values, refer to the Risk Guide provided on the DfE Program website.
210
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Worksheet 3-2: Exposure to Chemicals and Materials
Operation
Aspect
Quantity*
Used per
time period
Exposure Time
Duration**
Contact Person:
Frequency
Personal
Protective
Equipment
(PPE)
Pathway
Human:
Inhalation,
Dermal,
Oral
Environment:
air, water,
land
Rank Exposed Groups
Workers
Community
Environment
Date Completed:
If ingredient in chemical product, use quantity of chemical not product, i.e., apply the percentage that the ingredient makes up of the product.
**How many hours per day is the chemical or material used?
Note: For more information about evaluating exposure, refer to the exposure section of the Risk Guide on the DfE Program website.
211
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Worksheet 3-3: Community Issues
Operation
Aspect
Community Issues (List)
Rank
Contact Person: Date:
212
-------
Worksheet 3-4: Natural Resources Use
Operation
Aspect
Natural Resources Used
Rank
Contact Person: Date:
213
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Worksheet 3-5:a Criteria to Determine Significant Aspects'3
Operation
Aspect13
Regulatory
Concerns
Chemical and Material Risk
Worker
Eff/Expc
Community
Eff/Expc
Contact Person:
Environment
Eff/Expc
Worker
Safety
Other
Community
Issues: d
Natural
Resources:6
Overall
Ranking
Date Completed:
Significant?
Y/N
Corresponds to SEA-01 in the Company Manual Template.
b Include each input and output of a process step.
c Effects/Exposure
d Noise, traffic, light, odor.
e Include such items as Resource Use, Solid Waste, Energy Use
214
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Worksheet 3-6: Criteria to Select Environmental Projects
Project to Address
Aspect
Time Frame
Cost
Contact Person:
Technical
Feasibility
Total Feasibility
Date Completed:
215
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Worksheet 3-7: Potential Improvements
Aspect*
Human Health1
Environment
Cost Savings
Community
Relations
Contact Person:
Morale
Expected
Improvements
Date Completed:
Workers, Community, Global
216
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Worksheet 3-8: Overall Ranking Summary
Process Step
Aspect
Aspect Total
Feasibility Total
Contact Person:
Benefits Total
Significant
Y/N
Date Completed:
217
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Worksheet 4-1:* Potential Alternatives
Significant Environmental Aspect:
Baseline:
Products
Technologies
Work Practices
Recycling/
Reuse
Treatment
Disposal
Baseline
Contact Person:
Potential Alternatives
Date Completed:
Document these results in Section AE of the Company Manual Template.
218
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Worksheet 4-2: a Alternatives Evaluation: Health, Safety and Environmental Potential Effects Information
Baseline:
Significant Environmental Aspect:
Alternative
Information
Sources
Regulatory Data: "
Carcinogen?
OSHA Exposure limit?
Volatile Organic
Compound (VOC)?
Toxics Release
Inventory (TRI)?
Human Health Effects by
Pathways
Acute and Chronic0
Inhalation
Dermal
Oral
Comments
Effects on Wildlife
and Other
Environmental
Effects d
Air
Water
Land
Worker
Safety e
Rank
Human f
Env
219
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Contact Person:
Date Completed:
a See Section AE of the Company Manual Template.
b Most Information for this cofumn can be found on the MSDS.
c Partial information for these columns might come from the MSDS, but other resources may be needed. In particular, acute effects are usually reported
on MSDS sheets. Chronic effects are sometimes on MSDS sheets, but often will have to be found elsewhere.
d MSDSs usually do not include environmental effects.
e There may be information on the MSDS that would be useful for preparing your emergency preparedness plan.
f This rank is based on the potential effects of the chemical and not on the dose required to obtain those effects. For example, a person can drink a
certain amount of Scotch. Drinking a large quantity of Scotch, however, can be lethal. Therefore dose does make a difference ultimately in making_a
judgment, htowever, one can still make a qualitative ranking about whether Scotch, cola, water, milk or juice have beneficial or negative impacts. For
more discussion of the role of "dose" see the Hazard Guide on the DfE web site.
Note: For more information on risk related data, including methods for interpreting quantitative toxicity values, refer to the risk Guide provided on the DfE
Program website. The data on this table were constructed for purposes of illustration and do not represent real data.
220
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Worksheet 4-3 :a Alternatives Evaluation: Exposure to Chemicals and Materials
Baseline:
Significant Environmental Aspect:
Alternative
Products
Quantity Used
per Time Perioc
Exposure Time
Duration**
Frequency
Personal Protective
Equipment (PPE)
Contact Person:
Pathway
Human:
Inhalation,
Dermal, Oral
Environment:
air, water, land
Rank Exposed Groups
Workers
Communitv
Environment
Date:
* If ingredient in chemical product, use quantity of chemical not product, i.e., apply the percentage that the ingredient makes up of the product.
** How many minutes or hours per day is the chemical or material used?
Note: All data are for purposes of illustration and do not represent real data.
221
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Worksheet: 4-4: Alternatives Evaluation: Community Issues
Significant Environmental Aspect:
Alternative
Community Issues (List)
Contact Person:
Rank
Date:
222
-------
Worksheet: 4-5: Alternatives Evaluation: Natural Resource Use
Significant Environmental Aspect:
Alternative
Natural Resources Used (List)
Contact Person:
Rank
Date:
223
-------
Worksheet 4-6:a Alternatives Evaluation: Criteria to Determine Environmental Impact
Baseline:
Significant Environmental Aspect:
Alternative
Regulatory
Concerns
Chemical and Material Risk
Worker
Eff/Expb
Community
Eff/Expb
Contact Person:
Environment
Eff/Expb
Worker
Safety
Other
Community
Issues:0
Natural
Resources'1
Overall
Ranking
Date Completed:
Preferred
Alternative?
Y/N
a Corresponds to SEA-01 in Company Manual Template.
b Effects/exposure .
c Noise, traffic, light, odor.
d Include such items as resource use, solid waste, energy use.
224
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Worksheet 4-7:* Performance Comparison of Alternatives
Significant Environmental Aspect:
Baseline:
Function:
Alternative
How well it works
Time
Contact person:
Ease of use
Overall Performance
Evaluation
Date Completed:
'Document results in Section AE of the Company Manual Template.
225
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Worksheet 4-8:* Regulatory Comparison of Alternatives
Alternative
Applicable Regulations
Required Controls
Contact Person:
Regulatory Cost
Overall Regulatory
Concerns Evaluation
Date Completed:
*See Section AE of the Company Manual Template.
Note: Under "Cost of Regulations" include: paperwork triggered, reporting requirements, cost of controls, personal protective equipment, and any
other costs that may be attributed to regulations associated with using that product or process.
226
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Worksheet 4-9a: Annual Operating Costs
Significant Environmental Aspect:
Baseline:
Alternative
Materials
Direct Labor
Utilities
Waste
Management
Contact person:
Regulatory
Compliance
Insurance
Future
Liability
Total
Operating
Costs
Date:
227
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Worksheet 4-9b: Potential Annual Revenue Effects
Significant Environmental Aspect:
Baseline:
Alternative
Product
Throughput
Contact Person:
Product Quality
Reuse of or
Sales of
Recovered
Materials
Date:
Total Revenue
Effects
228
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Worksheet 4-9c: Initial Investment Costs*
Significant Environmental Aspect:
Baseline:
Alternative
Purchased
Equipment
Utility Systems/
Connection
Planning/
Engineering
Site
Preparation
Construction/
Installation
Start-up/
Training
Permitting
Other**
Total Inv.
Costs
Contact Person:
Date:
229
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Worksheet 4-9d: Cost Comparison of Alternatives
Significant Environmental Aspect:
Baseline:
Alternative
Total Operating
Costs
Total
Investment
Costs
Contact Person:
Annual
Revenue
Effects
Rank
Date:
Document results in Section AE of the Company Manual Template.
230
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Worksheet 4-10:* Evaluation of Alternatives
Significant Environmental Aspect:
Baseline:
Alternative
Products
Technologies
Work Practices
Recycle/Reuse
Treatment
Disposal
Performance
Rank1
Contact Person:
Regulatory
Rank2
Cost Rank3
Environ-
mental
Effects4
Overall
Evaluation5
Date Completed:
*See Section AE of the Company Manual Template.
1 Take from Worksheet 4-7, Performance Comparison.
2 Take from Worksheet 4-8, Regulatory Cost Comparison.
3 Take from Worksheet 4-9d, Cost Comparison.
4 Take from Worksheet 4-4, Criteria to Determine Environmental Impact.
5 Rank on a scale of low to high to reflect the desirability of each product. This is a judgment call.
Note: For more information on the methodology for comparing alternatives, refer to both the DfE website
and the Cleaner Technologies Substitutes Assessment, A Methodology Resource Guide, DfE, U.S. EPA
744-R 95-002, Dec. 1996.
231
-------
a. Roof Cause Diagram CD
0
m C
ii £
^ «
c a
E
LLJ _
232
-------
Worksheet 5-1: Environmental Performance Measurement Indicators
Aspect
Objective
Indicator
Date
Checked
Contact Person:
Who Checked
Result
Corrective Action
Date Completed:
233
-------
Worksheet 5-2: Calibration Log
Indicator
Measurement Method
Contact Person:
Equipment Used
Equipment calibrated:
date/method
Date Completed:
234
-------
Worksheet 5-3:* Corrective Action Notice
Issue Date:
Solution Due Date:
Requested by:
Issued to:
Problem Statement:
Most Likely Causes:
Suggested Solutions:
Action Taken:
Measured Results:
Corrective Action Closed by:
Date:
Contact for Notice: Date completed:
'Report results on TCA-01 in the Company Manual Template.
235
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Worksheet 6-1:* Operational Control Procedures
Significant
Environ-
mental Aspect
Indicator(s)
Associated
Job
Functions
Existing
Operational
Control
Procedures
Operational Control
Procedure
Development/
Modification Needed
Contact Person:
Responsible for
developing
Responsible
for checking
Location
Posted
Date Completed:
"Corresponds to OC-01 in the Company Manual Template.
236
-------
Worksheet 6-2: Operational Control Responsibilities
Significant Aspect
Procedures (list)
Contact Person:
Responsible for
maintaining
controls
Date Completed:
237
-------
Worksheet 6-3: Training Plan for Operational Controls
Aspect
Procedures
Person
Responsible
for Carrying
Out
Training
Needs
How to Train
When/
Length
Contact Person:
Budget
Completion
Date
Person
Responsible
for training
Date Completed:
238
-------
Worksheet 7-1 : Environmental Review of New Processes, Products and Activities
Area of Company
New Process, Product,
or Activity
Environmental
Review by
Manager/Date
Environmental Effects
Pollution Prevention
Opportunities
Contact for form: Date Completed:
239
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Worksheet 7-2:* Compliance Tracking Log
Person
Responsible
Regulation
Compliance
Check Date
Results and Root Cause
Corrective
Action/
Date
Compliance
Verified/ Date
Contact Person: Date Completed:
'Document results on CA-01 in the Company Manual Template.
240
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Worksheet 7-3: Pollution Prevention Tracking Log
Area of
Company
Pollution Prevention
Activity
Date Started
Results
Measurement
Method
Person
Responsible
Contact: Date Completed:
241
-------
Worksheet 7-4: Environmental Emergency Preparedness and Res
Potential Emergency
Scenario
Potential Environmental
Impact
Action Required
ponse
Procedures Needed
Training Needed
242
-------
Worksheet 8-1: Training Plan
Jobs Affecting
Environment
Training Needs
How to Train
Contact Person:
When/ Length
Budget
Completion
Date
Who is
Responsible
Date Completed:
243
-------
Worksheet 8-2: Documentation
List Existing
Documents
List Documents to
be Created
Determine Format:
Who/
Date Completed
/
/
/
/
/
/
/
/
/
Develop Prototype
(Content): Who/
Date Completed
/
/
/
/
/
/
/
/
/
Assign
Writing:
Who/ Date
/
/
/
/
/
/
/
/
/
Review Writing/
Compare to
Prototype
Who/ Date
/
/
/
/
/
/
/
/
/
Added to
Document
List/ Date
/
/
/
/
/
/
/
/
/
Who Has
Access
Where
Located
Contact Person: Date Completed:
Corresponds to CS-2 of the Company Manual Template.
244
-------
Worksheet 8-3: Document Control
Document
Who Will Use It
Permanent Location
Periodic Review
Schedule/ Who
/
/
/
/
/
/
/
/
/
When Can Be Destroyed
Contact Person: Date Completed:
245
-------
Worksheet 8-4:* Working with Stakeholders
Your
Stakeholders
Potential
Environmental
Interest
What You Want to Tell Them
Contact Person:
What You Want Them to Tell
You
How to
Communicate
With/ tell Them
When
Person
Responsible
Date Completed:
*Report results on CS-01 in the Company Manual Template.
246
-------
Worksheet 8-5: Stakeholder Communication Record
Date Communication Received:
Type of Communication:
Received From:
Address/Telephone Number/E-Mail:
Content of Communication
(attach copy if possible):
Will ABC Company Respond?
Date of Response:
Person Responding:
Nature of Response
(attach copy if possible):
Are Internal Actions Necessary?
(If Yes, fill out a Corrective Action
Form.)
Contact Person:
Y N
Y N
Date Completed:
Corresponds to CS-02 of the Company Manual Template.
247
-------
Worksheet 9-1: IEMS Program Measurement Criteria
Company Name
~~~~ Measurement
~~~~~~--------____Bements
IEMS Components
Environmental Policy
Communication Plan
Stakeholders Input
Environmental or IEMS Training
Review of Aspects
Operational Controls
Environmental Review of New
Processes and Activities
Setting Objectives & Targets
Environmental Management
Project 1
Environmental Management
Project 2
Documentation
Regulatory Compliance
Pollution Prevention
Other
Objectives of
Component
Activity
Measures
Results
Indicators
Review
Period
Contact person for form: Date Completed:
248
-------
Worksheet 9-2: Internal Assessment Checklist
Internal Assessment Team:
Date of Internal Assessment: Signed:
IEMS Procedures:
Check each item assessed, including auditing of records, where applicable (codes in parentheses refer
to the Worksheet number ("WS") in this Guide, followed by the document number in the Company
Manual Template):
Environmental policy (Module 2)
Environmental objectives (progress; implementation of action plans)
_ IEMS responsibilities (WS 7-2, RESP-01)
Identification of Environmental Aspects (WS 1-5, P-EA)
Identification of Legal Requirements (WS 1-6, P-LR)
Identification of Significant Environmental Aspects (WS 3-3, WS 3-6, P-SEA)
Development of Objectives, Targets, and Action Plans (WS 5-1, P-OTP)
Conducting an Alternatives Evaluation (WS 4-1 to 4-6, P-AE)
Development of Operational Controls (WS 6-1 to 6-3, P-OC)
Environmental Training (Awareness and Task-Specific) (WS 8-1, P-ET)
Emergency Preparedness (WS 7-5, P-EP)
Review of New Products and Processes (WS 7-3, P-NPP)
_ Documentation (WS 8-2, WS 8-3, P-D)
Conducting a Compliance Assessment (WS 5-4, P-CA)
Conducting an Internal Assessment (WS 9-2, WS 9-3, P-IA)
Taking Corrective Action (WS 5-3, P-TCA)
Management Review (WS 9-4, P-MR)
IEMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person: Date Completed:
Corresponds to LA-01 of the Company Manual Template.
249
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Worksheet 9-3: Internal Assessment Record
Internal Assessment Team:
Date of Internal Assessment: Signed:
Major Non-Conformities Observed
1.
2.
Minor Non-Conformities Observed
1.
2.
3.
Is ABC Company making progress in meeting its I EMS objectives?
Is ABC Company adhering to the commitments in its environmental policy?
Suggestions for Improving IEMS:
Contact Person: Date Completed:
Corresponds to IA-02 of the Company Manual Template.
250
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Worksheet 9-4: Management Review Record
Date of review meeting:
Persons present at meeting:
Conclusions:
Actions to be taken/Person(s) responsible:
Signed:_
Management Representative Plant Manager
Worksheet 9-4 corresponds to MR-01 in the Company Manual Template.
251
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Green Zia Environmental
Excellence Program
Green Zia Environmental Excellence
Program
New Mexico Environment Departemnt
PO Box 26110
Santa Fe, NM 87502
505-827-0677
pat_gallagher@nmenv. state, nm. us
Dry Cleaning
Guidance for improved environmental
performance and pollution prevention in
your dry cleaning business
-------
Acknowledgements
The material in this workbook is based on the Systems Approach to
Pollution Prevention, developed by Dr. Robert Pojasek of Pojasek and
Associates, and the Nothing to Waste Manual developed by US
Environmental Protection Agency Region 1. Process maps were developed
by Ms. Alicia Hale of Los Alamos National Laboratory. Special thanks to
Comet Cleaners of Albuquerque for their participation in this program.
This manual is printed on recycled paper. The manual printing and
distribution is supported through funding provided by the US Environmental
Protection Agency. Special thanks to Rob Lawrence, Eli Martinez and Joy
Campbell of the US Environmental Protection Agency for their help in
funding this project and in supporting pollution prevention in New Mexico.
-------
Table of Contents
Introduction to Green Zia Program Pagel
Green Zia Tools for Dry Cleaners Page 5
Process Maps for Dry Cleaners Tab 1
Dry Cleaning Regulatory Guidance, Pollution Prevention Ideas
and Other Resources Tab 2
-------
Ill
-------
The Green Zia
Environmental Excellence
Program
Guidance materials for dry cleaning
Introduction
This packet contains information on how to establish a pollution prevention program
specific for a dry cleaning operation. The packet also contains waste management and
regulatory guidance materials to help assure that you are in compliance with
environmental, health, and safety regulations. Used together, this information can help
you establish a pollution prevention program that will help you be in compliance and
reduce waste. Use of the tools from start to finish also helps you qualify for the Green
Zia Environmental Excellence Program.
The Green Zia Environmental Excellence Program is a voluntary program based on
quality management principles that is designed to help New Mexico businesses achieve
environmental excellence through pollution prevention programs.. This program is
administered by a partnership of state, local, and federal agencies, academia, private
industry, and environmental advocacy groups. This packet has been specifically
developed for a dry cleaning operation and is designed to meet the needs of a small
business.
The basic logic of the Green Zia Environmental Excellence Program is that:
• waste or pollution is the result of inefficiency;
• reducing waste increases profits;
• waste that is not created cannot pollute.
This guidance has been developed to aid in your company's understanding of best
management practices to help your company comply with environmental health and
safety regulations and to reduce waste and associated liabilities.
It is important to remember that environmental health and safety regulations are triggered
by the use of equipment and chemicals. Better use of chemicals, use of safer chemicals,
and efficient operation of machinery can help reduce your regulatory burden—if you
aren't using hazardous materials, then you have fewer regulations to be concerned with!
-------
This program is based on first understanding work processes and materials use and then
improving work practices to reduce cost, waste, and regulatory concerns.
Working through the Green Zia Environmental Excellence Program will result in a
system that helps address environmental issues in cost effective ways, based on sound
business practices. The system provides a framework for continuous improvement over
time and contributes to a thorough understanding of environmental issues in your
business.
What is Pollution Prevention?
Simply put, pollution prevention means not creating a waste in the first place. Pollution
prevention is achieved through the efficient use of resources including raw materials,
energy, water, and even time and distance. The goal is to produce a product or deliver a
service as efficiently as possible with the least amount of wasted materials and the least
possible environmental impact.
The bottom line is that pollution prevention or improved efficiency can help businesses
save money and help protect the environment at the same time.
What is Environmental Excellence?
Environmental excellence means moving beyond compliance with environmental, health,
and safety regulations by establishing an environmental management system that
incorporates pollution prevention into core business practices.
A prevention-based environmental management system will:
• help a business identify all the environmental compliance, health and safety concerns,
and costs associated with a waste generating process; and
• use prevention approaches to reduce or eliminate the waste and reduce the associated
costs.
In the Green Zia Environmental Excellence Program, attention is focused on the process
that generates the waste, not the waste. Identifying and implementing process
improvements will reduce waste and costs. This is a major shift from the traditional,
reactionary approach that concentrates only on managing wastes or pollutants already
created to an anticipatory approach that concentrates on prevention of wastes or
pollutants to improve environmental and economic performance. This prevention-first
environmental management system will identify cost effective ways to achieve "beyond
compliance" status, creating a win-win situation between economics and environment.
-------
The Green Zia Tools:
The Green Zia Program provides tools to establish a basic prevention-based
environmental management system. Management and employees walk through the tools
as a team to gain a complete understanding of their operation. Examples have been
worked out for the dry cleaning business. We encourage you to customize the examples
to your own operations. The packet includes a series of process maps for all areas of the
dry cleaning operation. Tools 2-6 are also explained and illustrated to help you develop
your program. Use of these tools on a regular basis will help your company qualify for
the Green Zia Environmental Excellence Program.
Green Zia tools:
Knowledge of
Process
Full Cost
Accounting
Pinpointing
Problems
Creative Problem
Solving
Prioritization of
Options
Ensuring Success
Tool 1: Process Mapping: Illustrates the work steps clothing and materials
pass through as they are transformed into your final product. Maps allow for
the identification of all inputs and outputs such as water, chemicals,
electricity, or other materials from a process, helping you to understand
wastes and their sources. Maps also help you understand regulated activities.
Tool 2: Activity-Based Costing: Identifies the true costs of wastes or losses
and helps participants identify areas to target for pollution prevention by
assigning dollar values to these wastes and losses.
Tool 3: Root Cause Analysis: Creates a cause and effect diagram to
highlight why and where the losses occur in the process. Understanding why
and where the loss occurs will help participants focus on specific areas for
improvement.
Tool 4: Brainwriting: Addresses problems by generating as many
alternatives as possible to minimize loss.
Tool 5: Bubble-up-bubble-down: Ranks alternatives to determine the
optimal solution. Factors such as cost, ease of implementation, and
effectiveness are considered in evaluating and ranking the alternatives.
Tool 6: Action Plan: Details each step that needs to be taken to implement
the alternative and reduce or eliminate the loss from the process.
-------
-------
Tool#l: Process Mapping
To begin incorporating pollution prevention into your business,
you must first get a full understanding of where wastes are being
generated. This tutorial will discuss the advantages of using
process maps to logically evaluate each step of your process.
Warm-up Exercise
Maps have been used throughout the
ages for many purposes from helping
sailors navigate the seas to providing a
safe route for climbers hiking to the
tallest peaks. You have probably drawn
maps to your home or office so that
someone could visit. It is important that
the information on this map is complete
and accurate or, as you may have found,
your guest will get lost!
Take a minute now and think of a coffee shop or restaurant nearby that everyone in the
group knows. Draw a map from the building you are currently in to this establishment -
include traffic lights, landmarks, and any other important features along the way. Now
compare maps with the other members of your group. Are they the same? If a person
not familiar with the area were to use your map, would they have found their way?
-------
Introduction
Are you aware of the amount of waste that your business generates? Could this waste be
turned into profit? By considering methods of reducing wastes, recycling used and
unused raw materials, and reusing lost material, you could not only help the environment
but also reduce your raw material and waste disposal costs.
This section discusses process mapping, a method of analyzing a process in order to
catalogue all the materials used and lost in the process. With process mapping, you will
systematically identify the series of steps materials pass through as they are transformed
into the final product. Evaluating your process in this manner will allow you to recognize
the opportunities to prevent losses and possibly streamline operations. Each loss
identified during the process mapping is an opportunity to prevent that loss.
A series of process maps have been developed for dry cleaning operations and are
included in this packet. You should customize these maps for your operation, since no
two businesses are exactly alike. These maps become a reference for you to use for your
pollution prevention program and can be updated to reflect changes as you improve your
operations. These maps are also great for training new employees and for other problem
solving needs.
Large businesses and manufacturers use these tools to understand and improve their
manufacturing processes. Small businesses can benefit by using these tools as well!
It is helpful to also prepare a narrative to go along with your process maps to explain the
process in detail. We recommend that you include regulatory activities in the narratives
as part of your environmental management system. Narratives are also included in this
packet; please revise to reflect your business operations.
Create a team of employees to complete this exercise. During this exercise you will:
• Examine and revise the process maps and narratives in the packet to accurately reflect
your operation
• Fully understand the functionality of each step of a process
• Identify the inputs and outputs/losses within the process
• Communicate findings in a clear and concise manner to members of the team.
-------
Example of a process map for dry cleaning:
compresse
so
V
D
r
i
f
buttons
spin diskfilte
Proces
dair
detergent
vent energy
ill-
»s Map 2.3: Dry-to-dry machines with a refrigerated
condenser
r i
ry to dry machine with
efrigerated condenser
2.3.1
r
* i
water
vapors from
door opening
1
dam
rs clol
r
aged
hes
r
solve
refrigers
nt vaf
ted cc
waste so vent (to s
filters or distil lati
and return to w
tank)
energy
hangers
chemicals g,oves ,
i.l i
Final inspection and spotting Sort and hang clothes for
2.3.2 2.3.3 operation
ors (to
ndenser) chemical sludge
pln d!jk clothes rerun in dry to dry
.rking machine
Please review the process maps in the back of this booklet and make changes to reflect
your operation.
Once you have reviewed and revised the process maps to your
operation, move to the next section...Activity-Based Costing!
-------
-------
Tool #2: Activity-Based
Costing
Every waste or environmental loss costs you money. By determining which
activities cause waste, you can focus your pollution prevention efforts to
minimize the cost to your business and to protect the environment. This
tutorial will introduce you to a method of evaluating your waste.
Warm-up Exercise
Your daughter approaches you one evening and says
that she is planning to buy a car. With the $400 she has
left over each month, after paying all of her bills, she
is sure she will be able to afford the $220 monthly car
payment.
What are the other costs of operating and maintaining
a car that she is forgetting? Consider not only the
annual costs, such as insurance, but also the
intermittent (once in a while) costs. Can she really afford this car?
-------
Introduction
Once you have determined the losses in your processes through your process maps, you
can discover how these losses are affecting your "bottom line". How much does it cost
you to discard 10% of your raw materials, or 2% of your finished products? Which
activities have losses that most hurt the profitability of your company? This tool will
help you look at the cost of the losses in your business and see how much these losses are
costing you. The results may surprise you!
Which losses should you care about? The Pareto Principle suggests that 80% of the
problems in a business come from 20% of machines, raw materials, or operators. (The
same is true for any facet of a business; for example, 80% of sales come from 20% of
your customers, etc.) Once you have assigned costs to your activities, you can figure out
which 20% of your activities are contributing to 80% of your costs. The Pareto Principle
is very important in activity-based costing as it is used to focus on the most important
areas for improvement in your pollution prevention program. Use of the Pareto Principle
for the activity-based costing section will help you quickly identify areas of your business
on which to focus your prevention efforts.
New Terms
Activity based costing (ABC) - An accounting method used to assign the cost of your
losses to the activities that generate these losses. By assigning costs to activities, you will
discover the activities should be targeted for prevention.
Environmental costs -The costs associated with the losses in your process.
Pareto principle - A principle that suggests that 80% of anything can be attributed to 20%
of the factors involved. For example, 80% of your environmental costs can be attributed
to 20% of your activities.
Intermittent operations - Operations that occur once in a while.
10
-------
Activity Based Costing
1. Make a list of all the activities in your operation. Be sure to include the activities
from your process map as well as any intermittent operations (such as cleaning or
maintaining equipment.).
Regular activities:
• Spotting
• Weighing and sorting loads
• Dry cleaning
• Placing clothes on hangers
• Pressing
• Wrapping
Intermittent activities:
• Leak detection, record-keeping
• Mucking out sludge
• Replacing cartridge or spin disk filters
• Fixing leaks
• Recycling solvent
• Managing evaporator water
• Equipment maintenance (boiler, compressor, cleaning equipment)
2. List all of the losses in your operation. Look on your process map and add any others
that you think of.
3. Reviewing your process maps, identify the operations in your plant that generate most
of your waste or pollution problems. For example, does solvent use cause most of
your environmental problems? Does boiler use and maintenance result in your
biggest problem? Does the 80/20 Rule apply? Focus your efforts for now on the
areas of your operations that you do the most or that create the biggest environmental
problem for you.
4. Use process maps to review material use and losses for your selected process or
operation. You will use these maps as a guide to assign costs to these losses.
5. Identify which major costs or general ledger costs apply to the material use and losses
on the process maps (utilities, chemical purchase costs, waste disposal costs, costs
that are easy to get information on and that you typically consider when looking at
your processes). Enter into Table 1. (See example provided)
6. Identify which other activities are related to the use of these materials that are not in
the major costs (protective equipment such as gloves, monitoring, record keeping,
11
-------
maintenance, compressors to run equipment, permits, fees to the state or city, storage
space for chemicals, the cost of spill clean-up and reporting, etc.). These activities
are not usually considered when thinking about the cost of a process, yet the costs
associated with them can be significant.
7. Write the activities in the first column of Table 2. Along the top list all the costs or
services required for these activities. Add or delete categories as appropriate for your
business. Put an "x" for every cell that applies.
8. Count the total number of "x's" in Table 2. Then circle the x's that represent what
you estimate to be about the top 20% of the most expensive activities in your
operation. Again, you are using the 80/20 rule: 20 percent of your activities will
probably add up to about 80% of your total costs.
9. Then estimate only the cost of each of these top activities that you circled and write
them in a new table. Cost estimates are allowable as you are using this method to
prioritize your most expensive activities. You can refine costs once you have chosen
a project to work on. (In the example, the top 20% of the cost categories chosen have
the estimate beside them.) Add these numbers into Table 1 under the appropriate
waste stream in the "Hidden costs" line.
10. Add the ledger costs and the hidden costs together to discover the true costs.
11 .Create a Pareto Chart. Create a chart showing all these costs graphically. On the x
axis (vertical), place costs in dollars, on the y axis (horizontal), show the true costs of
the wastes. This chart will help graphically show how all the costs stack up against
each other. Does the 80/20 Rule apply here? Use this chart to identify the most
expensive processes. This can be used to identify the first area for improvement.
Which waste stream do you think you should focus on from this Pareto chart?
12
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Activity-Based Costing Example
compresse
so
v
D
r
ir
v
buttons
v
spin disk filte
Proce;
d air
detergent
vent energy
ill.
>s Map 2.3: Dry-to-dry machines with a refrigerated
condenser
1 \
ry to dry machine wi
sfrigerated condense
2.3.1
t j
water
vapors from
door opening
\
dam
rs clot
F
aged
hes
th
*r
u
sove
refrigerE
ntvar.
ted cc
waste solvent (to s
filters or distillatic
and return to we
tank)
energy
hangers
chemicals g,oves ,
* ,- 1 1
Final inspection and spottin ) Sort and hang clothes for
2.3.2 2.3.3 operation
ors(to
ndenser) chemical sludge
j^'j* clothes rerun in dry to dry
rking mac lne
Activities
Materials and Losses
Dry Cleaning
Final Spotting
Sort and Hang
Buttons/damaged clothes (upset
customers/replacement costs)
* Detergent
*New solvent
Lint
* Solvent sludge
Water from clothes
* Fugitive vapors
Vapors through condenser and maintenance
* Filters
Energy
Boiler/Compressor
* Spotting Chemicals/Chemical sludge
Protective Gloves
Hangers
(*) indicates most important waste streams and
materials
13
-------
-------
Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs/Loss
es
Labor
Raw
material
Disposal
fees
Other
ledger
costs
Hidden
Costs
Total
%of Total
Fugitive
Vapors
$2,000
($1,240)
$3,240
.121
Solvent
Sludge
$2,500
($4,550)
$7,050
.264
Detergent
$500
($150)
$650
.024
Solvent
Use
$5,000
($3,650)
$8,650
.324
Filters
$2,000
$850
($2,000)
$4,850
.18
Spotting
chemicals
$1,500
$100
$150
($500)
$2,250
.084
Total
$4,000
$7,850
$2,600
$150
$12,090
$26,690
1.0
Table 2. Hidden Cost Analysis (per year)
Fugitive Vapors
Activities/Cost
Factors
Monitoring
Reporting
Repairs
Materials
X ($200)
X
X
Space
Utilities
Services
X
Total hidden costs for vapors
Labor
X($1040)
X
X
($1,240)
Solvent sludge
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
X
X
X
X
X
X
X
X
Total hidden costs for sludges
X ($2,050)
X
X
X($ 1,000)
X ($1,500)
($4,550)
Detergent
Storage
X
X($150)
Total hidden costs for detergent
X
($150)
Solvent Use
Recordkeeping
Permit fees
Permit
Storage
Spill/clean-up
X
X
X
X
X
X
X ($3,000)
X
Total hidden costs for new solvent
X
X ($650)
X
($3,650)
Filters
Disposal
Repairs
X
X
X
X
Total hidden costs for filters
X (1,500)
X ($500)
($2,000)
Spotting chemicals
Handling/
disposal
X
Total hidden costs for spotting chemicals
X ($500)
($500)
14
-------
Environmental Costs
$10,000
« $8,000
(A
8 $6,000
I $4,000
< $2,000
Solvent
Use
Solvent
Sludges
Filters
Fug.
Vapors
Spotting Detergent
Chemicals
Losses
Pareto Chart for Dry Cleaning
The Pareto Chart illustrates costs relative to each other and helps choose areas to target
for pollution prevention activities. In this example, solvent use, the most expensive loss,
will be the focus of the pollution prevention efforts in the following sections. The
example provided is not based on an actual case study, but is provided to illustrate use of
the tool.
Now that you have completed the process mapping and activity-based costing, you have a
sense of the relative environmental costs of your operations. Since solvent use is the
target, we will use the following problem-solving and decision-making tools to find a
way to reduce solvent use, increase efficiency and save money.
Most of your work is done. These two tools can be revised as needed. Use
these maps and information annually (or more often) to keep improving your
operation on an ongoing basis. Now that you have identified your most
expensive wastes, you can now move towards solving problems and
eliminating waste: the next tool is Root Cause Analysis!
15
-------
Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs/Losses
Labor
Raw
material
Disposal
fees
Other ledger
costs
Hidden
Costs
Total
%of Total
Total
16
-------
Table 2. Hidden Cost Analysis (per year)
Activities/Cost
Factors
Materials
Space
Utilities
Services
Labor
Waste Stream
Monitoring
Reporting
Repairs
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Repairs
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Repairs
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
17
-------
18
-------
Tool #3: Root Cause
Analysis
Now that you have recognized the activities in your process that are
expensive to your business, you can begin to focus your efforts on pollution
prevention. This tool presents a method of detecting the underlying reason
for an environmental loss so that the loss can be prevented.
Warm-up Exercise
t:
MACHINES
broken alarm clock
Think of all of the times that you have been late for work and
list the different reasons for your delay. Maybe your alarm
clock did not go off, or perhaps your child was sick and you
needed to arrange for a sitter. Did you spend too much time
reading the newspaper or did you need to run to the store to
pick up milk?
Arrange all these reasons in the categories listed below, or
create an additional category. Some of the items on your list
may be entered more than once.
Now consider the last time you were late for work. Why were
you late? Circle the reason.
PEOPLE
sick child
METHODS
reading the newspaper
MATERIALS
out of milk
19
-------
Introduction
In the last tool you determined the key losses responsible for the greatest amount of
environmental costs. In order to try to prevent a loss, you must first understand why it is
occurring. The underlying reason for a loss is also known as its "root cause". The root
cause will answer the question: What ultimately caused the loss? Determining the root
cause of an environmental loss is very similar to determining the root cause of being late
for work
A cause and effect diagram is one method of determining the root cause for a loss. This
tool provides a visual description of all possible causes for a specific loss. Once all the
possible causes are depicted on the diagram, the most plausible cause or causes are
identified. It is imperative that all persons involved in determining the root cause are in
agreement. The next step is to write a "Dear Abby" letter summarizing the cause or
causes for a loss will ensure that all participants see the problem in the same way.
During this exercise you will:
• Construct a cause and effect diagram with all potential causes for a loss
• Discuss the most probable cause or causes
• Write a Dear Abby letter describing the reason for the loss.
Root Cause Analysis
After participating in process mapping and activity based costing exercises, it was
determined that the largest loss, solvent use, accounts for approximately 80% of all
environmental costs in the dry cleaning operation. The next step is to discover the root
cause of this loss.
To determine the root cause of a loss, you must ask: "Why is the loss occurring?" One
way of gathering information concerning the generation of a loss is called a cause and
effect diagram, or fish bone diagram, since it resembles a fish bone. Major categories of
possible causes for the loss are first defined and entered on the diagram as an offshoot
from a main horizontal line. Next, all possible causes of the waste are assigned to a
category and entered on the diagram. Once all the causes are defined, an agreement is
made as to the most plausible reason for the loss.
Divide the causes into four major categories— Methods, Machines, Materials, and People-
- and then write down all the possible reasons why solvents could be lost from the
process and assign them to a category. Begin the diagram and then write down some of
the things that immediately come to mind. An example has been provided in Figure 2.
20
-------
Several things may come to mind. Clothes must be sorted by color and type. Poor
sorting may lead to color bleeding, damaged clothing, and loss of solvent due to color
bleeding. Improperly weighed loads may result in inefficient solvent use. Workplace
conditions such as a dirty, disorganized work area may lead to solvent spills and
contamination. The machines are expensive and require proper operation and
maintenance. Filters must be changed regularly, the distillation and recycling unit must
be operating properly, and the machine must be set for the proper loads. The solvent
quality and detergent additives must be monitored. Also, training and a good work
attitude are critical to efficient operations. All of these ideas should be entered under one
of the four categories in the fishbone diagram: Machines, Methods, Materials and People
as in the example in Figure 2.
Now that all the possible causes of solvent being lost during the dry cleaning process are
categorized, it is time to determine the most probable cause. Go back to the diagram and
circle the most probable causes. One of these should be the root cause. Then, working
with employees as a team, discuss which one of these major causes is the root cause. To
come to clear understanding of the root cause, we suggest that the team write a short
"Dear Abby" letter describing the interpretation of the problem to ensure that each person
sees the problem the same way. Once the letter is in place, the group becomes Abby and
seeks to solve the problem, (see Figure 3)
Another method for determining the root cause of a problem is the "5 whys."
By asking the question "why?" five times, you may get to the root cause of a problem.
An example of how the five whys works is as follows.
The Five Whys:
1. Why has the machine stopped, forcing an interruption in production?
A circuit breaker tripped due to an overload.
2. Why was there an overload?
There was not enough lubrication for the bearings.
3. Why was there too little lubrication for the bearings?
The pump was not pumping enough lubrication.
4. Why was there not enough lubricant being pumped?
The pump shaft was vibrating because of abrasion.
5. Why was there abrasion?
There was no filter, which allowed chips of metal to get into the pump.
The solution is then to place a filter on the pump to capture metal chips.
21
-------
Both tools can be used to find the root cause of the problem. For most problems to be
permanently solved the root cause must be addressed. The fishbone diagram is a good
visual tool that helps you understand all the areas that contribute to a problem.
Understanding all the contributing factors will help facilitate problem solving. The Five
Whys will also help you move past dealing with the symptoms of the problem to solving
the real problem.
Examples of the fishbone diagram and a Dear Abby letter as well as a blank fishbone
diagram are included for your use.
The next tutorial will present brainwriting - a method
to generate ideas.
22
-------
Figure 1: Dry Cleaning Process - Process Map
Process Map 2.3: Dry-to-dry machines with a refrigerated
condenser
compressed air
1
de
solvent
- I I
tergent
energy
I -
' 1
r
Dry to dry machine with
refrigerated condenser
2.3.1
l
r
buttons
1
I
int ,,
vapor
solve
efrigers
nt va|
ated ct
ener
chemicals
i ,
gy
,
gloves
, J
1
Final inspection and spotting
operation
2.3.2
I
ors (to
mdenser) chemical sludge
• r waste solvent (to spin d sk
filters or d stillat on unit
5 from and return tn wnrkinn
door opening
. f
spin d sk filters
damaged
clothes
tank)
Sort and hang clothes for
pressers
2.3.3
— ^.To pressin
operation
F
clothes rerun in dry to dry
machine
23
-------
Figure 2: Cause and Effect Diagram
Methods
sorting
Clothing type
improper weighin
Loads
composition
solvent
it 7
/ /
quality /
Materials
disorganized, dirty,
dusty
Workplace
Conditions
poor lighting
Machines
Distillation unit Poor
maintenance
type
dry \
cleaning a^
system 4
poor maintenance
not efficient
filters
type
detergent additives
~^r
\ Awareness
wrong quantity
bad /
attitude
not
sufficient
Training do weekly leak
^____ detection
Regulations
People maintain inventory logs
24
-------
Figure 3: Dear Abby Letter
Dear Abby,
We run a small dry cleaning operation. Use of solvent is our most expensive business
issue. Solvents are highly regulated and we must comply with lots of regulations from air
quality and hazardous waste to health and safety. Some dry cleaning plants have had to
pay lots of money for clean-up of contaminated sites which has put them out of business.
These are issues that we wish to take seriously.
Our group did root cause analysis and we believe that our biggest problem is employee
awareness. Employees affect solvent use from loading the machines and maintaining the
equipment to keeping the operation clean and making sure we are in compliance with
regulations. However, as you know, our employees have a billion things to do every day
and they often don't stick around for enough time to get proper training.
Can you help us?
Signed,
Cleaning up in Farmington
25
-------
Root cause analysis: Fishbone Diagram
Methods
Machines
Materials
People
26
-------
Tool #4: Brainwriting
To address an opportunity effectively, it is important to recognize all
alternatives. Very rarely is there one "right" way of preventing pollution.
Instead, there are many different potential solutions. This tutorial presents a
technique of listing many different alternatives for an opportunity.
Warm-up Exercise
You know the old adage "two heads are better than one." This is
especially true when trying to come up with new ideas. When you
generate ideas in a group you will notice that each member of the
group brings their unique set of experiences and strengths to the
table.
Try the following exercise with your group. Look at the picture below (turn it on it's side
and upside-down). What does it remind you of? Write down all the images that come to
mind—even images that seem crazy should be included. Now go around the room, each
person sharing one image with the group. One person should volunteer to keep a list of
all the images. Repeat this step until every member of the group is out of images. How
many images did the group come up with? How does this compare with the number of
images you generated alone ?
27
-------
Introduction
In the last tool you evaluated all the probable causes of a loss and determined the
underlying reason, or root cause. Once the root cause has been identified, you may be
tempted to jump to a premature solution. When you address a loss without considering all
the alternatives of prevention you may be overlooking the most appropriate option(s).
Looking for alternatives for pollution prevention by addressing its root cause is the next
step towards addressing an opportunity. There are several tools available to help groups
develop alternatives. You already explored one tool during the warm-up exercise. In this
exercise you will explore another method—brainwriting. Brainwriting requires maximum
interaction and creativity between group members. All possible alternatives, regardless of
how far-fetched they appear, are considered by the group. Alternatives raised by the
group may seem contradictory, or they may build on one another to make them better. A
comprehensive list of alternatives can then be compiled.
During this exercise you will:
• Conduct a brainwriting session
• Develop a list of all possible alternatives for an opportunity for improvement
Brainwriting
You have completed your process map to see how you can optimize your processes and
reduce losses, (see Figure 1) In the example provided, Activity-Based Costing helped to
identify that 80% of the environmental costs associated with dry cleaning were due to
solvent use. Not only are solvents expensive, they are considered a hazardous waste and a
hazardous air pollutant and they must be handled very carefully. Spills must be avoided
to eliminate employee exposures and site contamination.
Root cause analysis determined that the greatest losses occurred due to employee
handling practices. Employees control the dry cleaning processes from the beginning to
the end and also must deal with environmental, health, and safety compliance issues.
The next step is to develop as many alternatives to solve the problem as possible. This is
done through the process of brainwriting. Through brainwriting, staff works together to
generate as many alternatives as possible regardless of how crazy they seem. In fact, to
make it more interesting you can give a prize to the person that comes up with the
craziest idea.
Make copies of the blank brainwriting sheet included at the end of this chapter. Make
enough sheets so that each person on the brainwriting team has one per person with one
28
-------
blank sheet in the middle of the table. Place these sheets in the center of the table. Each
person should take a sheet and write two alternatives on it and then place the sheet back
in the center. Then take another sheet of paper and write two more alternatives on it.
Every time someone picks up a sheet of paper, encourage them to read what others have
written and try to make improvements to the alternatives listed. Someone could even say
they think someone's idea is completely out in left field, if they try to make it better. Keep
repeating this process until everyone runs out of ideas.
Now list all the alternatives that were discovered.
The alternatives on each sheet of paper should be read aloud and discussed. Many of the
ideas may be the same and some may have small variations. The group should debate the
small variations and eliminated the impossible alternatives. One comprehensive list
should be developed—with each idea only written once, although all variations of the
same idea should be included.
Examples of brainwriting are provided below.
The next tutorial will present bubble-up, bubble-down—a
method for selecting the best option to prevent loss.
29
-------
Figure 1: Dry Cleaning Process Map
Process Map 2.3: Dry-to-dry machines with a refrigerated
condenser
compressed air
l
de
solvent
- 1 J
tergent
energy
I ,
' 1
Dry to dry machine with
refrigerated condenser
l
F
buttons
i
I
int v
vapor
2.3.1
v
from
door opening
1
>in dsk filters
solvent vap
efrigerated cc
energy
,
chemicals g,oves ,
1 V
1 1
Final inspection and spotting
operation
2.3.2
ors (to
ndenser) chemical sludge
Sort and hang clothes for
pressers
2.3.3
— ^.To pressing
operation
F
waste so vent (to spin disk , .. •_,,._,
filters or d stillation unit clothes reru"ln dr* to dr*
and return to workina macnme
'
damaged
clothes
tank)
30
-------
Figure 2: Sample of brainwriting
1.
Use non-toxic solvent to eliminate all
environmental problems.
2.
Train people to maintain filtration
system and distillation systems better.
3.
Employees could run really dirty
clothes through the dirtiest solvent, and
then clean again in regular solvent.
4.
Investigate wet cleaning systems.
5.
Start a "clean shop" program to train
employees to keep work areas clean to
prevent spills and waste.
6. Begin an employee incentive
program to reward best operating
practices for operating dry cleaning
machine and reducing clothing damage
problems.
7.
Start a energy conservation program
and focus on boiler and presses.
8.
Spot fairly clean clothes, run through
an air tumbler, then press... some things
may not need full cleaning
9.
Pay employees small bonus for keeping
good environmental records including
hazardous waste and air quality
records.
10.
Test solvent to see if we are replacing
too soon.
31
-------
Figure 3: List of alternatives
1. Use non-toxic solvent to eliminate all environmental problems.
2. Train people to maintain filtration and distillation systems better.
3. Employees could run really dirty clothes through the dirtiest solvent, and then clean
again in regular solvent.
4. Investigate wet cleaning systems.
5. Start a "clean shop" program to train employees to keep work areas clean to prevent
spills and waste.
6. Begin an employee incentive program to reward best operating practices for operating
dry cleaning machine and reducing clothing damage problems.
7. Start an energy conservation program and focus on boiler and presses.
8. Spot fairly clean clothes, run through an air tumbler, then press...some things may
not need full cleaning.
9. Pay employees small bonus for keeping good environmental records including
hazardous waste and air quality records.
10. Test solvent to see if we are replacing too soon.
11. Create an employee problem-solving team to deal with waste of all kinds on a regular
basis.
12. Train workers on pollution prevention and ways to reduce and reclaim spills.
13. Provide incentives for employees who reduce losses.
14. Start a customer information program to inform them of our environmental program.
15. Invest in better equipment.
32
-------
Figure 4: Brainwriting Sheet
1. 2.
3. 4.
6.
8.
10.
33
-------
34
-------
Tool #5: Bubble-Up, Bubble-Down
You have now generated a list of alternatives for preventing an environmental loss
in your business. But how do you choose the best alternative? This tutorial
presents one method of prioritizing alternatives to ensure that the most appropriate
alternative is selected.
Warm-up Exercise
Most of us use lists from time to time to make sure that we don't
forget to do the things that we need to get done. Without a shopping
list, for example, we may return from the store without milk, the
reason why we went in the first place. Certain limitations, like time
or money, may cause us to drop things off our list. We often need to
prioritize and make sure that the most important things get done.
Make a list of the things that you need to get done tomorrow (try to
list at least ten things). List these items in the order that they come
to mind. Now prioritize this list by putting the most important items
on the top of the list and the least important items on the bottom. You should now have a "rank
ordered" list. If you only have time to complete one of the items on your list, which would it be?
The item on the top of the list should have been your most important item.
35
-------
Introduction
A comprehensive list of pollution prevention alternatives was developed in the last tool using a
technique called brainwriting. The alternatives generated during this tutorial can range from
operational changes, such as employee training and improvements in operations, to technology
changes, such as changing a solvent. The next step is to choose one alternative that is capable of
being worked with successfully. Additionally, it is important to select the optimal solution for
your business. To accomplish this, you must consider the feasibility of each alternative. Such
factors as effectiveness, implementability, cost, and potential ramifications of each alternative
should be discussed. Personal preferences and biased information should not enter into the
decision-making process.
There are several tools available to aid a group in selecting an alternative while avoiding bias.
These tools allow a group to rank and prioritize alternatives using a systematic approach. When
all the alternatives are listed, suggestions are made by the group to improve even the worst
alternatives. At this point, many of the alternatives may be eliminated; every realistic alternative
remains on the list. These remaining alternatives can then be sorted based on the factors
presented above and any other factors that may affect a particular business. The method of
selection presented in the exercise is the bubble-up, bubble-down. This tool uses a forced pair
comparison to rank alternatives. Using this method you will be able to find the most effective
solution to the selected loss.
During this exercise you will:
• Evaluate all alternatives.
• Use the bubble-up, bubble-down method to reach a decision on the best alternative.
Bubble-Up, Bubble-Down
Take the list of alternatives and compare the first two alternatives. Decide which of the two is the
best and move this alternative to the top of the list. Go to the next, or third alternative and
compare it to the second. If it is better than the second, move it up and compare it to the first, if
not, leave it in the third position. Continue this process until all the alternatives are rank ordered.
This process should go fairly quickly. Make sure you listen to everyone's opinions and
objections. Again, factors to consider are cost, effectiveness, and the ability to implement the
alternative.
Bubble-up, Bubble-down should generate much discussion among employees on the best
solutions. These discussions will help to increase buy-in to the alternatives. As a rule,
employees never resist their own ideas.
36
-------
An example of how the Bubble-Up Bubble-Down method was applied to the list of alternatives
generated in the last tool is listed below.
Typically, the three or four alternatives that "bubbled-up" to the top of the list are the easiest and
cheapest to implement, the "low-hanging fruit". The alternatives in the middle may require more
research or study to see if they are feasible. The ideas at the bottom of the list may require major
equipment changes or capital investments. It is important to keep the entire list on file as part of
your continuous environmental improvement program.
The next step is to develop an action plan. Action planning
is essential to assure that ideas are implemented!
37
-------
Figure 1: List of alternatives, prioritized using Bubble Up, Bubble Down
1. Begin an employee incentive program to reward best operating practices for operating dry
cleaning machine and reducing clothing damage problems. Provide incentives for employees
who reduce losses.
2. Create an employee problem-solving team to deal with waste of all kinds on a regular basis.
3. Train people to maintain filtration and distillation systems better.
4. Train workers on pollution prevention and ways to reduce and reclaim spills.
5. Pay employees small bonus for keeping good environmental records including hazardous
waste and air quality records.
6. Start a "clean shop" program to train employees to keep work areas clean to prevent spills
and waste.
7. Start a customer information program to inform them of our environmental program.
8. Test solvent to see if we are replacing too soon.
9. Start an energy conservation program and focus on boiler and presses.
10. Spot fairly clean clothes, run through an air tumbler, then press... some things may not need
full cleaning.
11. Use non-toxic solvent to eliminate all environmental problems.
12. Investigate wet cleaning systems.
13. Invest in better equipment.
14. Employees could run really dirty clothes through the dirtiest solvent, and then clean again in
regular solvent.
38
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Tool #6: Action Planning
Being able to successfully manage a project is important when trying to
accomplish a task, especially when you are under a deadline. You need to set up a
schedule, ensure that you have the necessary resources, and assign the right
person to each part of the job. In this tutorial you will create an "action plan" for
the implementation of an alternative to prevent pollution.
Warm-up Exercise
Your group has been assigned the task of making chocolate
chip cookies. The cookies need to be ready in one hour and
the cooking time is twelve minutes. Pick a person to manage
this project. The manager must then assign the ten tasks
listed below to individuals in the group.
You will need to know how much time is required for each
task, what tasks need to be accomplished before others, what
resources (i.e. bowls, flour etc.) are required, and what the most efficient way of organizing
these tasks (and remember the clock is ticking). Create a schedule.
Making chocolate-chip cookies:
Mix dry ingredients
Mix wet ingredients
Put the batter on the pan and put pan into the oven
Combining wet and dry ingredients
Turn on the oven
Taste cookies
Wash tools and utensils
Grease pan
Take cookies out of the oven
39
-------
Developing an Action Plan
Before you begin to implement your alternative you should complete this questionnaire. It will
ensure that you are being thorough in your planning and thay you have considered all the
important issues that may arise, such as the resources that are needed and the problems that may
occur, (see Figure 2)
Things to consider in developing an action plan are resources needed, both financial and human
resources; the need for pilot testing or bench scale testing; and information sources from the
outside such as trade associations, vendors, suppliers, and the Environment Department. Other
issues such as employee support and maintaining product or service quality should be
considered. A list of questions that should be considered during action planning is as follows:
Action Planning Questionnaire
1. What is the overall objective and ideal situation?
2. What steps are needed to get there from here?
3. What actions need to be done?
4. Who will be responsible for each action?
5. What is the best sequence of action?
6. How long will each step take and when should it be done?
7. How can we be sure that earlier steps will be done in time for later steps that depend on
them?
8. What training is required to ensure that all staff has sufficient know-how to execute each
step in the plan?
9. What standards do you want to set?
10. What volume or quality is desirable?
11. What resources are needed and how will you get them?
12. How will you measure results?
13. How will you follow up each step and who will do it?
14. What checkpoints and milestones should be established?
15. What are the make/break vital steps and how can you ensure they succeed?
16. What could go wrong and how will you get around it?
17. Who will this plan affect and how will it affect them?
18. How can the plan be adjusted without jeopardizing its results for the best response and
impact?
19. How will you communicate the plant to generate support?
Now put all of this information in an Action Plan Form. Most of the information that you need
should come from your answers to the questionnaire. The specific task, or step, to be
accomplished is written in the first column under "Action." In the following column list the
person who is responsible for completing this task. A performance standard should then be
40
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provided. This standard is a way of establishing how well a task needs to be performed. Under
"monitoring technique" enter a measurable goal or target used to track the plan's implementation.
A firm deadline should then be set, and finally, indicate the resources that are needed to perform
each task. This form will help you organize your thoughts, keep track of all the actions that need
to be completed, and ensure that the proper quality is being maintained.
Use the form provided to track implementation of the project and to measure its success.
sample action planning form is included at the end of this section.
Action Plan Form for Employee Incentive Program
A
Overall Target: Employee Incentive Program
Action
1. Develop
Program
incentives
2.Design a
program for
review and
giving
incentives
3 . Meet with
employees
4. Set up
improvement/s
uggestion box,
system
5. Review
Team
6. Incentives
awarded
Responsible
person
Carol
Marcy
Carol, Mark and
Marge
Carol
Carol and Mark
Marge
Performance
standard
List of incentives
Approved
program by
Marge
Highly interactive
meeting
System in place,
all employees are
aware, easy to use
Review team
reviews
suggestions
monthly
Ideas
implemented,
paying off in $$,
improvements
Monitoring
technique
Discuss ideas
with Marge the
owner
Marge
approves,
allocates
funding.
Question
employees
before and after
Number of ideas
submitted
Marge evaluates
work
Check on
progress,
success
Completion
deadline
Jan 15
Feb 1
Feb 15
March 1
March 7
Junel
Resources
needed
Team of Carol
and Mark
Action #1
complete
Firm date for
meeting;
meeting room
Box, access to
company
computer,
review team
Ideas
accepted/imple
mented
Cash bonuses,
days off, etc
Congratulations!!! You have completed the Pollution Prevention Training. Now it is time to put
these tools to work and remember that pollution prevention is an ongoing process. If you
continue to implement pollution prevention in your business, you will increase the efficiency of
your process while helping the environment. Simply revisiting your process maps and Pareto
Chart once a year and using the tools to continue to make improvements will make a big
difference in your operation. Ongoing use of these tools will help you to participate in the Green
Zia Environmental Excellence Program.
41
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Here are a few suggestions to make pollution prevention
continue to work for you:
• Return to the Nothing to Waste activities and concepts as
you make business decisions.
• Schedule regular pollution prevention reviews of your
business.
Remember: Pollution Prevention saves resources,
saves money, and prevents accidents!
42
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Overall Target
Action
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Responsible
person
Performance
Standard
Monitoring
Technique
Completion
Deadline
Resources
Needed
43
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Process Maps for Dry
Cleaners
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Dry Cleaning Overview Process Map
Receive Clothing
1
Clean Clothing
2
Pressing Operations
3
Storage and Retrieval
4
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Process Map 1.0: Receiving/Processing Clothing
tags
staples
I Pins I
I T i
Clothing received
at counter
1.1
Clothing moved to
cleaning area
1.2
Clothing sorted by
color and type
1.3
Clothing weighed
for loading in
machine
1.4
torn tags
waste pins/
articles left in^ staples
pockets
unidentified
clothing
dropped
clothing
clothing with
lost tags
dropped
clothing
clothing with
lost tags
Process Map 1.0: Clothing Receipt and Preparation
1.1 Clothing Received at Counter
As clothes are received at the counter, employee staple or pin identification tags to the individual pieces of
clothing. Customers may also leave articles in pockets that must be thrown away or retained for the customer once
the clothes are cleaned. This step generates wastes such as torn tags, pins and staples and various other wastes
from the customer's clothing. Also, clothing not properly identified may wind up as lost or unclaimed clothing.
1.2 Clothing Moved to Cleaning Area
Clothes are moved to the cleaning area and are inspected for stains.
1.3 Clothing Sorted by Color and Type
Once the clothing is in the cleaning area, employees sort it by color and type. The employee also decides which
washing method should be used for each garment. Delicate garments are sometimes segregated and hand washed.
1.4 Clothing Weighed for Loading in Machine
Employees weigh the clothing before loading it into the machine. Machine is set based on weight of load.
Properly weighted loads may increase solvent cleaning efficiency.
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Process Map 2.3: Dry-to-dry machines with a refrigerated
condenser
compr
1
1
button
spin disk
essed air
de
solvent
• I J
Dry to d
refriger;
1
^ int ,,
water
s
vapors
door o|
filters
erqent
energy
1 v <-
y machine with
2.3.1
so vent vap
refrigerated cc
^ r waste solvent (to s
filters or distillatic
Trom and return to wo
enin9 tank)
damaged
clothes
energy
hangers
chemicals gloves I
i . 1 I
Final inspection and spotting Sort and hang clothes for
232 233 operation
)rs(to
idenser) chemical sludge
)in 'S clothes rerun in dry to dry
rKing machine
Process Map 2.0: Process Map for Dry to Dry Cleaning Machine with Built-in Refrigerated Condenser
2.3.1 Dry to Dry Machine with Built-in Refrigerated Condensers
In this process, the washer and dryer are integrated into one unit. The clothes are washed with a mixture of solvent
(Perchloroethylene) and detergent. This process also uses energy. The cleaning process generates a waste which is
comprised of a mixture of solvent, water, and detergent. Water is the byproduct of air humidity and residual sweat trapped in
the garment. Used solvent is recycled through a closed loop distillation unit where it is reclaimed and recycled back into the
cleaning process. During cleaning, some solvent vapors are lost to the atmosphere as employees open the machine door.
Also, lint uild up around the machine door loosens the seal and results in some solvent vapor leaks. Clothing may also be
damaged during this process due to shrinkage or color transfer. Other wastes include lost buttons and lint. Button losses
require matching of replacement buttons, sewing and perhaps special purchases of new buttons. Lint is managed as a
hazardous waste. Water is separated and is sent though an evaporator. Environmental compliance issues relative to this
process, if it is Perchloroethylene-based, include leak detection, recordkeeping, notification requirements, solvent purchase
recordkeeping requirements to meet air quality standards, and OSHA exposure requirements; hazardous waste compliance
issues may apply to spent filters, lint, evaporator water, and sludges for recyciling or distaillation unit. As a general rule, any
material that comes into contact with Perchloroethylene may be a regulated hazardous waste. A general rule also is that any
water or material that has come into contact with Perchloroethylene should never be poured down a drain.
2.3.2 Inspection/Final Spotting Operation
Once the clothes are dry, they are taken out of the dryer and inspected. Clothes that are not sufficiently cleaned are spotted
and cleaned again. The spotting operation includes removing stains and dirty areas by using chemicals, steam, and
scrubbing. In this process, employees use several kinds of spotting chemicals because different stains require different
chemicals. For example, certain cleaning products are used for water soluble stains such as grass stains while other
cleaning chemicals are required for non-water soluble stains such as ink. Garments are placed on the spotting table that is
equipped with a vacuum device. Employees place the spotting chemicals on the stain while the vacuum sucks the chemicals
into a canister. During this procedure, employees use chemicals, soaps, detergents, commercial spotting agents, energy,
and protective gloves. This process generates small amounts of chemical sludge waste.
2.3.3 Sort and Hang Clothes for Pressers
Clothing is placed on hangers and sent to the pressing area. Some solvent vapors may be released to the atmosphere from
offgassing from the clothing.
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Process Map 3.0: Dry Cleaning Pressing Operation
energy
hangers
plastic wrap
Move clothes to
pressing area
3.1
pped clothes or clothes
Pressing operation
3.2
steam
f
Wrapping
operation
3.3
y bent hange
torn/
broken buttons
plastic
Ancillary Operation: Boilers
water
energy I chemicals
Process Map 3.0 : Pressing Operation
3.1 Move Clothes to Pressing Area
Employees prepare and move the clothes to the pressing area. Losses associated with this process include dropped clothing and
clothing with lost tags.
3.2 Pressing Operation
Clothing is pressed either on tables or on pressing forms. Wastes or losses include energy and water from steam and broken
buttons or damaged clothing from pressing. Energy losses may occur around leaks in compressor or steam lines.
3.3 Wrapping Operation
Employees prepare the clothing for the customers by hanging the clothes on hangers, batching the clothes by customer order,
wrapping them in plastic wrap, and twisting the tops of the plastic wraps with twist ties. Wastes includes torn plastic, bent hangers,
dropped clothing or clothing accidentally placed into the wrong order.
Support Process for Pressing Operation : Boiler Maintenance
Boiler maintenance includes maintenance and chemicals. Boilers also use a significant amount of energy.
-------
Process Map 4.0: Clothing Storage and Retrieval
storage space energ
1
Clothing to storage
4.1
Clothing Retrieval
4.2
1
r
U
clothing with
lost tags
clothing
never
claimed
Clothing not
clean enough
for customer
Process Map 4.0 : Clothing Storage and Retrieval
4.1 Clothing Storage
During this process, clothes are moved to the storage area. Losses may include energy and floor space
which is required to maintain the storage area. Additional losses include clothing that is never retrieved,
clothing that is not picked up promptly by the customer, or clothing that has lost its identification tags.
4.2 Clothing Retrieval
Clothing is retrieved at the counter. Losses may include customer dissatisfaction with cleaning quality. The
customer may also find the clothing not clean enough and request that the dry cleaner repeat the process.
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Intermittent Process Summary Map
Solvent Recycling
Personal protection gear
energy
Waste solvent
filters
Personal protection gear
filtered solvent
Filtration
1.1
Distillation
1.2
spent
protective
spent filter
cartridges
hazardous
sludges
spills
spent
protective
hazardous
rags for spill/
equipment
clean-up
hazardous rags for
spill/equipment
clean-up
Solvent loading and distribution
energy (for pumping)
personal protective
equipment
spills
spill clean-up spent personal
materials protective
equipment
Carbon Absorption
carbon filters
solvent laden air
I energy
hot air or
steam
vapors from leaks
spent filters
vapors from leaks
Refrigerated
Condenser
solvent laden
air from dry
cleaning energy refrigerant
machine
Refrigerated
condenser
2.3 (A)
vapors
from leaks
bad parts
Evaporator
water from
cleaning fi|ters
No narratives are provided for these process maps.
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Dry Cleaning Regulatory
Guidance., Pollution
Prevention Ideas and Other
Resources
-------
Dry Cleaning Industry:
Pollution Prevention Fact Sheet
Eliminate - reduce - reuse - recycle - exchange
The Dry Cleaning Industry is faced with a challenge of overcoming pollution in the
workplace. Most of the environmental concern centers around the atmospheric
escape of the primary solvent used in the clothes washing cycle. Since 1995 when
the manufacture of chlorofluorocarbons (CFC-113) and trichloroethane (TCA) were
banned, the solvent of choice has become perchloroethylene (PCE or Perc), with
approximately 93% of U.S. dry cleaners using it
Perc is a toxic chemical that is a suspected carcinogen and can harm the central
nervous system, lungs, liver, and kidneys. Environmentally, Perc is non-
biodegradable and can react with sunlight to form carbon tetrachloride, a powerful
ozone-depleting chemical.
Petroleum-based solvents are an alternative to Perc. However, due to their high
flammability, they combust more easily in heated applications and are subsequently
prohibited in most states. New petroleum-based solvents, mainly azeotropic blends
of glycol ethers, are entering the solvent market. Though some of these new solvents
are biodegradable and less toxic to human health, many contain volatile organic
compounds (VOC's)
| EQUIPMENT |
As information concerning the risks involved in using various dry cleaning solvents
has been made available over the past five decades, various alterations have been
made to the standard machine, resulting in six generations of machines currently in
use:
• First generation machines, called transfer machines, consisted of a separate
washer and dryer that allowed evaporated solvent to leak into the air during
transfer.
-------
• Second generation machines, or "dry to dry" machines, allowed both cycles to
occur in the same machine, eliminating the transfer step and thus preventing
the leakage of solvent.
• Third generation machines, or closed-loop machines, incorporated either a
refrigerated condenser or a carbon absorber, both of which are designed to
filter used solvent from the air stream.
• Fourth generation machines included a secondary internal vapor recovery
device to further decontaminate the machine's waste stream.
• Fifth generation machines add an automatic still clean out, eliminating the
need for human contact with toxic still sludge.
• Sixth generation machines contain a monitoring computer to control Perc
concentrations in the machine and work area.
Although each new generation improved the quality of the machines, each also
brought new environmental concerns to the table. For example, first generation
machines leaked so much solvent into the air that the National Emission Standards for
Hazardous Air Pollutants (NESHAP) has banned the manufacture of new transfer
machines.
Second generation machines require more maintenance and are less flexible, which
increase costs to the operator. They are also still potentially dangerous because
they exhaust their air into the environment.
However, greater automation and better technology often leads to higher
maintenance costs and more frequent malfunctions. While the final three
generations each improved waste disposal, they also became more expensive and
harder to maintain.
Many lower generation machines can be retrofitted with additional containment,
filtering, or condensing equipment to increase solvent efficiency and containment to
that of higher generation levels.
-------
Process
The following are practical solutions to help dry cleaning establishments reduce
human health risk and environmental contamination. These suggestions have been
successfully implemented by establishments throughout the industry.
• Use closed containers for collection and storage of recovered or new solvent.
• Clean drying sensors and filters weekly.
• Replace all valve seals and door gaskets regularly.
• Check and repair hoses and exhaust ducts.
• Experiment with optimizing solvent distillation, condensation, or filtering
equipment.
• Experiment with exhaust parameters, such as exhaust or air exchange velocity.
• Replace machine with dry to dry, close-loop machine with internal
refrigerated condensing and carbon absorbing capabilities.
• Upgrade machines with added refrigerated condenser, secondary carbon
absorber for solvent vapor containment, and a spill container.
• Replace dry cleaning process with wet cleaning process (see below).
• Replace Perc or petroleum-based solvent machine with a liquid carbon
dioxide machine.
Make sure washer and dryer are in close proximity and properly enclosed.
Install distillation equipment with closed containment still bottoms for safer
removal and disposal of still sludge.
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Replace cartridge filters with spin disk filters which can be cleaned without
opening.
Use a carbon absorber that is regenerated with hot air stripping rather than steam
stripping, minimizing water waste.
Incorporate a door fan local exhaust system to capture solvent vapors during
opening of machine door.
Use double carbon waste water treatment devices to clean up Perc-soiled waste
streams, recycling treated waste water to the process boiler.
New Technologies on the Market
Two new systems are now available for the dry cleaning industry. The first system
includes a detergent that enhances the dissolution ability of liquid carbon dioxide and
the second system replaces dry cleaning with wet cleaning, a technology which
supplements a standard water solvent with fiber protective additives.
The major drawback of each of these technologies is the cost of undertaking new
equipment. Also, even with special dryers that check the temperature through
humidity level selection, wet cleaning systems are not able to clean 100% of fabrics
and may cause shrinkage. Wet cleaning operations include three major processes,
which creates a labor-intensive operation.
Pollution Prevention
and YOU
The Green Zia Program of New Mexico encourages all businesses to get involved
with a program to eliminate waste. It is better to eliminate waste then to recycle,
treat, or reduce waste. It is up to even the small businesses to work together and
make our environment safer. When implementing a pollution prevention program,
remember these principles:
• Build quality into the workplace. Commit to keeping your workplace safe for
workers and the environment.
• Eliminate errors. Take control of the workplace.
-------
Implement your idea now. If a solution has better than a 50-50 chance of
succeeding, start right away. Compliance with environmental issues can be
costly, especially for small businesses, and a pollution prevention plan can save
money.
Strive for continuous environmental improvement. Any operation that
generates waste can move beyond compliance and incorporate pollution
prevention into core business practices.
Work as a team. Involve employees in brainstorming sessions to get different
views of the problem.
Find the root of the problem to find a great solution.
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Dry Cleaning Regulatory
Guidance Materials
-------
EVERYTHING YOU WANTED TO KNOW ABOUT DRY CLEANER REGULATIONS BUT
WERE AFRAID TO ASK
Dry Cleaners in New Mexico
The dry cleaning industry, due to its use of perchloroethylene, is controlled by state
and federal regulations dealing primarily with air emissions, hazardous waste
management, wastewater, and employee health and safety. Table II-1 on pages II-2
and II-3 in the "Plain English Guide For Perc Dry Cleaners" (EPA 305-B-96-002)
gives a good overall review of regulatory requirements and recommendations. The
following information will be given to provide corrections, additions, or clarifications
to the EPA document.
Perchloroethylene (also referred to as PCE, PERC, tetrachloroethene, and
tetrachloroethylene) is the main product used by dry cleaners. You may come across
different regulatory documents that use PERC or PCE when referring to
perchloroethylene. For clarity, we will only use the term PERC in this document.
Even though it is not stated in the EPA document, the controls discussed are based on
the maximum achievable control technology (MACT) for major dry cleaners and
generally available control technologies (GACT) for non-major dry cleaners as
specified in section 112 of the Clean Air Act.
Air Emissions:
Dry cleaners are classified as small area, large area, or major based on the yearly
amount of PERC purchased on a rolling average. Table II-2 located on page II-7 has a
chart you can use to determine your classification. Page II-8 has examples of how you
calculate a rolling average. Figure II-5 on page 11-35 contains a sample log sheet for
PERC purchases. It is important to monitor your purchases, especially if you are close
to being reclassified as a larger facility. Generally speaking, the larger the facility the
greater the regulatory requirements. If a facility purchases more than 1,470 gallons of
PERC in a one-year period of time, they will be required to apply for a Title V
operating permit. At present, if a facility is required to obtain a Title V permit they
will be required to maintain the record-keeping at that level even if their usage goes
down. However, if, for example, you are classified by EPA as a large area dry cleaner
and your rolling average for a 12-month period went below 140 gallons per year for 2
consecutive years, you can request to be reclassified by the EPA.
The regulatory requirements established by EPA are called the National Emission
Standards for Hazardous Air Pollutants (NESHAP). A common requirement for all
facilities in compliance with NESHAP regardless of classification is that they must
meet good housekeeping, monitoring, record keeping, reporting, and leak
detection/repair requirements. See attached table labeled "EPA Air Requirements for
Dry Cleaners" for an overall view. The requirements for the PCE NESHAP are
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divided in 4 categories: emissions control equipment, emissions equipment
monitoring, fugitive emissions control, and record keeping and reporting.
Emission Control Equipment:
Emission controls that are required are based on the type of machines and the date
that they were installed. Table II-2 contains information on which controls are
required for your facility. Keep in mind that there are no regulatory requirements on
the manufacturer of dry cleaning equipment. The responsibility of regulatory
compliance is yours. You should only purchase equipment capable of complying with
the regulations.
Emission Control Monitoring:
Those facilities using carbon absorbers as the main PERC vapor recovery system
must be aware that if the unit cannot be repaired it must be replaced with a
refrigerated condenser. The carbon absorber requires a sampling port in the exhaust
stack to measure its efficiency. Page 11-21 explains how a sampling port can be
installed. Information on testing can be found on pages 11-33, 34, & 35. Since carbon
absorbers vent their exhaust into the air, it is advisable that they be replaced with a
refrigerated condenser to recover more PERC and reduce air emissions.
Refrigerated condensers require monitoring of temperature differences. Page 11-32
has information on how this is accomplished. You need to be aware that the
refrigerant in your condenser may need to be replaced in the future as refrigerants,
such as R-22, are phased out. Such units will generally need to be retrofitted or
replaced. Check with the manufacturer of your equipment.
Fugitive Emissions Control:
To reduce the amount of PERC emissions to the air, all PERC dry cleaners must
conduct a leak detection and repair program on a regular basis. Pages 11-30 and 11-32
list the requirements. Figure 11-2 on page 11-31 is a sample of a "Monthly Machine
Maintenance and Perchloroethylene Log" that can assist you.
Record Keeping and Reporting:
NESHAP requires you to fill out three reports at the start of your operation and send
them to the EPA Region VI contact listed at the end of this document. The reports are
an "Initial Notification Report", a "Pollution Prevention Compliance Report", and if
an emission control device is installed, a "Control Requirements Compliance Report".
Copies of the forms are located in Appendix B. A copy of these three reports should
be kept at the facility.
-------
All dry cleaners are required to keep a logbook in order to demonstrate compliance
with EPA air regulations. The information should be complete for the past 5 years of
operation and should contain the following:
• Receipts of PERC purchases
• Monthly totals of PERC purchases
• Calculations performed on the first of each month to determine a rolling average
• Dates on which dry cleaning machines were inspected for leaks
• Locations of any detected leaks and a record of repair activities
• Results of temperature monitoring of refrigerated condensers
• Results of carbon absorber outlet concentrations
In addition to maintaining the facility log, copies of the design specification and
operating manuals must be kept on site for each dry cleaning system and emission
control device at the facility. Figure 11-2 on page 11-31 contains a sample log for
maintenance record keeping. Figure II-5 on page 11-35 contains a sample log for
PERC purchases.
Hazardous Waste
Just like under Air Regulations, a facility is classified as either a Conditionally
Exempt Small Quantity Generator (CESQG), a Small Quantity Generator (SQG), or a
Large Quantity Generator (LCG) based on the amount of hazardous waste they
generate on a monthly basis. Table II-4 on page II-l 1 has a chart that can be used to
determine into which category your facility falls. There are different regulatory
requirements for each category. Table II-5 on page 11-12 is a summary of the
regulatory requirements for each category. Unlike the categories under the Air
Regulations, a facility can move from one category to another on a monthly basis.
Any waste that is contaminated with PERC, such as the button trap, lint screen, still
bottom residue, spent filter cartridges, filter muck, process water, carbon filters,
and/or cooked powder residue is considered a hazardous waste as well as any unused
PERC that is to be disposed.
Instructions on how to properly count the quantity of hazardous waste you generate
can be found on page II-9. This is important since it will affect which category you
are in for a particular month. This will also affect the quantity and time frames that
you are allowed to store your hazardous waste, whether or not you need to manifest
your waste, as well as requirements for reporting, level of personnel training and
container maintenance. Figure II-6 on page 11-41 contains a copy of a Uniform
Hazardous Waste Manifest.
Page 11-13 states that all SQGs and LQGs are required to send their hazardous waste
to an RCRA-permitted facility. Unless subject to stricter state requirements, CESQGs
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may send their hazardous waste to a state approved solid waste facility (municipal
landfill) or to a RCRA permitted facility. At present, the New Mexico Solid Waste
Regulations allow hazardous waste from a CESQG to be disposed at a municipal
landfill as long the waste can pass the paint filter test (no free liquids).
It is important to be aware that the facility generating the hazardous waste is
ultimately responsible for ensuring the hauler and the facility excepting the waste are
RCRA permitted. If a CESQG is able to dispose of their waste at a municipal landfill
then the hauler must be registered by the New Mexico Solid Waste Bureau.
It is also important to remember that all hazardous waste must be kept in a leak-proof,
tightly covered container. The only exception is the small hole allowed in a separator
water collection bucket. See the paragraphs below dealing with waste water. On page
11-37 it states, "keep tanks covered or provide at least 2 feet of freeboard (space at the
top of the tank) in uncovered tanks." This statement is not true in New Mexico. Any
tank that contains PERC or PERC contaminated waste MUST be a closed container.
All facilities should have a contingency/emergency plan in place at their facility.
Only LQGs are required to have a written plan approved by the New Mexico
Hazardous Waste Bureau. Pages 11-27, 28, &29 contain information to help establish
a proper plan. It is very important that the facility have a person assigned to be the
emergency coordinator. This person will be responsible for ensuring that emergency
procedures are carried out in the event of an emergency. The New Mexico
Environment Department has a 24-hour emergency reporting number that you can
call in case there is an incident dealing with hazardous materials. The number is 505-
827-9329.
Staff should be properly trained in the use of the equipment and dealing with
emergencies. Hazardous Operator Training (hazwoper), however, is not required for
dry cleaners.
All SQGs and LQGs are required to obtain an EPA Identification Number. Figure II-1
on page 11-24 shows a copy of the form to use. CESQGs are not required to have EPA
ID numbers; however, you need to keep in mind that it is possible for a facility to
change status on a monthly basis. Therefore, if you are presently a CESQG and if you
ever generate more than 220 pounds of hazardous waste in any particular month, your
status would change to a SQG for that month. Since it costs nothing to get an EPA ID
number, you should apply for one.
Wastewater:
Any water, regardless of how it became contaminated, that contains more than 0.7
ppm (parts per million) of PERC is considered hazardous waste and must be dealt
with according to RCRA regulations. Placing PERC-contaminated wastewater
-------
directly onto or into the ground (e.g. septic systems, underground injection well, etc.)
is prohibited.
One is also discouraged from disposing of PERC-contaminated waste water into the
sewer system. Even though a waste water treatment plant may accept PERC-
contaminated waste water, it does not relieve a facility of being responsible for
contaminating ground water with PERC if there is a leak in the sewer pipes. It is also
in the best interest of the facility to make sure that any cracks in their floors are sealed
in case any PERC gets on the floor due to leaks or spillage. Should the ground water
be contaminated by any means and the source of PERC is traced back to your facility,
you could be responsible for its clean up and may also receive a significant fine. The
cost of clean up would be far greater than the costs associated with proper handling of
your waste water.
Separator water, which typically contains 150 ppm of PERC, is by definition a
hazardous material. There are two options available to deal with this waste water:
Option 1: Store and dispose of the separator water as you would any other hazardous
waste. If you are collecting your separator water by letting your separator tank
overflow drip into a bucket, the bucket must be kept covered to minimize
evaporation. A small hole in the cover to allow entry of the hose from the separator
water tank is acceptable. The bucket must not be allowed to overflow.
Option 2: You may evaporate your separator water if it has first been treated to
reduce its PERC concentration to below 0.7 ppm. EPA has allowed a dry cleaner to
treat its separator water on site without the need of a RCRA permit using either a
mister or evaporator. Misters are usually used by smaller facilities whereas an
evaporator is used by larger facilities. Treatment can be accomplished by passing the
separator water through two granular activated carbon units in series prior to
evaporation. The activated carbon units must be operated and maintained so that the
separator water never exceeds 0.7 ppm PERC concentration.
Treated water can now be allowed to evaporate in the air or be used as boiler water
for example. However, you should not dispose of this treated water in the sewer.
Should there be a problem with the sewer pipes leaking, continuous disposal down
the sewer could conceivably increase the concentration in ground water above the
0.7ppm level.
Underground Storage Tanks
The only time a dry cleaner needs to be concerned with underground storage tank
(UST) regulations is if they store their PERC in an UST. However, if the UST
containing the PERC is connected directly to their machine, it is considered part of
the operation and is not regulated by the Environment Department. This does not
relieve you of responsibility should the tank leak and contaminate ground water.
-------
OSHA
The Occupational Health and Safety Bureau has a consultation program in place to
assist facilities to be in compliance with OSHA regulations. A copy of "Frequently
Asked Questions" about the program is included with this document. Also attached is
a copy of a "Check List for Dry Cleaning Exposure to Perchloroethylene (PERC)"as
well as a poster that you are encouraged to display at your facility.
CONTACTS:
EPA
Regional Small Business
Assistance Contact
Javier Balli
US EPA Region VI (AIR)
1445 Ross Avenue, (6PD-S)
Dallas, TX 75202-2733
214-665-7261
FAX: 214-665-6762
E-mail: balli.Javier@epa.gov
Regional Small Business
Liaison
David Gray
Small Business Liaison
US EPA Region VI (6XA)
1445 Ross Avenue, Suite 1200
Dallas TX 75202-2733
214-665-2200
FAX: 214-665-2118
E-mail: gray.david@epa.gov
Regional Dry Cleaning Air
Coordinators
Loretta Finklin
US EPA Region VI (6EN-AA)
1445 Ross Avenue
Dallas TX 75202-2733
214-665-7293
E-mail:
Loretta.finklin@epamail.epa.gov
City of Albuquerque
John Liberatore
EHD/APCD
P.O. Box 1293
Albuquerque, NM 87103
505-768-1964
FAX: 505-768-2617
E-mail: jliberatore@CABQ.gov
Bob Hogrefe
Southside Water Reclamation
Plant
4210 Second Street, SW
Albuquerque, NM 87185
Ph:873-7030
Fx:873-7087
Rhogrefe@cabq.gov
STATE AGENCIES:
Green Zia Environmental
Excellence Program
Pat Gallagher
NM Environment Department
Office of the Secretary
PO Box 26110
Santa Fe, NM 87502
505-827-0677
FAX: 505-827-2836
E-mail:
pat_Gallagher@nmenv. state.nm.
us
-------
Air Quality Bureau
Steve Dubyk
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2859
FAX: 505-827-0045
E-mail:
steve_dubyk@nmenv. state.nm.us
Hazardous Waste Bureau
Debby Brinkerhoff
NM Environment Department
2044 Galisteo
P.O. Box 26110
Santa Fe, NM 87502
505-827-1511
FAX: 505-827-1833
E-mail:
debby_brinkerhoff@nmenv. state.
nm.us
Occupational Health & Safety
Bureau
Debra McElroy
525 Camino de los Marquez,
Suite 3
P.O. Box 26110
Santa Fe, NM 87502
505-827-4230
FAX: 505-827-4422
E-mail:
debra_mcelroy@nmenv.state.nm.
us
Ground Water Quality Bureau
Industrial Waste Team Leader
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2900
FAX: 505-827-2965
Solid Waste Bureau
Phillip Westen
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-0559
FAX: 505-827-2902
E-mail:
phillip_westen@nmenv. state.nm.
us
Underground Storage Tank
Bureau
Joyce Shearer, Ph.D.
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-476-3779
FAX: 505-827-0310
E-mail:
joyce_shearer@nmenv.state.nm.
us
-------
State of New Mexico Wastewater Treatment Facility Contacts
POTW FACILITY
ALAMOGORDO, CITY OF
ALBUQUERQUE, CITY OF
ANTHONY W&SD
ARTESIA, CITY OF
AZTEC, CITY OF
BELEN, CITY OF
BERNALILLO, TOWN OF
BLOOMFIELD, CITY OF
CANNON AIR FORCE BASE
CAPITAN, VILLAGE OF
CARLSBAD, CITY OF
CARRIZOZO, TOWN OF
CHAMA, VILLAGE OF
CIMARRON, VILLAGE OF
CLAYTON, TOWN OF
CLOUDCROFT, VILLAGE OF
CLOVIS, CITY OF
CONCHAS STATE PARK
CUBA, VILLAGE OF
DEMING, CITY OF
DEPARTMENT OF ENERGY, LANL AND U OF CA
DES MOINES, VILLAGE OF
DEXTER, TOWN OF
EAGLE NEST, VILLAGE OF
ECO Resources #3
ECO Resources # 2
ESPANOLA, CITY OF
ESTANCIA, TOWN OF
EUNICE, CITY OF
FARMINGTON,CITYOF
FORT SUMNER, VILLAGE OF
GALLUP, CITY OF
GRANTS, CITY OF
HAGERMAN, TOWN OF
HATCH, VILLAGE OF
HOBBS, CITY OF
PHONE NO.
(505)439-5643
(505) 437-4530
(505)873-7040
(505)882-3922
(505)746-2122
(505)334-8664
(505)864-6081
(505)867-2307
(505)632-8474
(505)354-2247
(505)887-5412
(505)354-2247
(505)756-2184
(505)376-2232
(505)682-241 1
(505)769-7865
(505)868-2900
(505)289-3864
(505)546-8848
(505)665-7855
(505)734-5482
(505)891-1223
(505)891-1223
(505)753-4740
(505)384-2302
(505)394-2576
(505)599-1315
(505)355-2401
(505)863-1210
(505)287-7927
(505)752-3201
(505)267-3021
(505)397-9315
CONTACT PERSON
Jose Miramontes
Charles Bowman, WW Utilities
Div. Director
Pat Banegas
Ernest Thompson, Mayor
Gary Spickelmier
Robert Rimorin
NickTobey
Casimiro Ruybalid
Lynn Steinle
Terry Cox
Gilbert Ybarbo
Steve Sale
Tony Gonzales, Mayor
Lino Paiz
David Venable, Mayor
Robert Challender
Leo Wilson
Faustino Gallegos
Louis Jenkins, Public Works
Director
Charles Barnett
Joe Alvarez
Donald Thymes
Donald Thymes
Frank Naranjo
Willie Luster
Tom Wethington, WW Director
John McMillan, Mayor
Ray Espinoza
Willie Alire, City Manger
Robert Romero
Clifford Browning
James Tulk
-------
HOLLOMAN AIR FORCE BASE
JAL, CITY OF
JEMEZ SPRINGS, CITY OF
KIRTLAND AIR FORCE BASE HQ AFSWC/CC
LACUNA, PUEBLO OF
LAS CRUCES, CITY OF
LAS VEGAS, CITY OF
LOGAN, VILLAGE OF
LORDSBURG, CITY OF
LOS ALAMOS, BAYO PLANT
LOS LUNAS, VILLAGE OF
LOVING, VILLAGE OF
LOVINGTON, CITY OF
MAGDALENA, VILLAGE OF
MAXWELL, VILLAGE OF
MELROSE, VILLAGE OF
MORA MUTUAL DOMESTIC WATER & SEWER. WKS.
MORIARTY, CITY OF
MOUNTAINAIR, TOWN OF
ORGAN WATER AND SEWER ASSOCIATION
PECOS, VILLAGE OF
PORTALES, CITY OF
QUESTA, VILLAGE OF
RAMAH DOMESTIC UTILITIES
RATON, CITY OF
RED RIVER, TOWN OF
RESERVE, VILLAGE OF
ROSWELL, CITY OF
ROY, VILLAGE OF
RUIDOSO-RUIDOSO DOWNS REGIONAL WWTP
SAN JON, VILLAGE OF
SANTA FE, CITY OF
SANTA ROSA, CITY OF
SANTA TERESA SERVICES COMPANY
SILVER CITY, TOWN OF
SOCORRO, CITY OF
SPRINGER, TOWN OF
SUNLAND PARK, CITY OF
TAOS, TOWN OF
(505)479-7080
(505)395-2222
(505)829-3540
(505)528-3599
(505)454-1401
(505)487-2239
(505)524-8273
(505)662-8147
(505)865-9689
(505)396-2884
(505)854-2261
(505)375-2752
(505)253-4274
(505)387-5401
(505)832-6257
(505)847-2321
(503)825-5423
(505)757-6591
(505)359-3152
(505)586-0694
(505)722-4366
(505)445-2292
(505)754-2277
(505)533-6581
(505)624-6700
(505)485-2204
(505)258-4014
(505)576-2922
(505)984-6509
(505)472-3331
(505)589-0906
(505)388-4981
(505)835-0240
(505)589-1979
(505)758-8401
Meryle F. Stueve, TSgt, USAF
Fred Seifts
David Sanchez, Mayor
Frank Analla
Gilbert Morales
Andrew R. Jaramillo
Julian Cordova
Alex De La Garza
Paul Pizzoli, Utilities Director
Louis Huning, Mayor
Bob Carter
Vida M. Trujillo
Leroy Quintana, Mayor
Bobby Bennett, Mayor
Manuel B. Alcon President
Rosendo Saiz
Debra Kelly
Charles Jefferson
Joseph Cyde Baca, Mayor
Thomas Howell
Mike Cordova
Ron Morsbach
Mike Baca
Jake Pierce, City Administrator
Lonnie Graham
Roger Cooper, PE, Dir of Public
Works
Alex Deschamps
Gary Jackson, Village Manager
Chris Molyneaux
Qustandi Kassisieh
Gerald Anaya,Water & Sewer
Superintendent
Charles Crowder
Stan Snider
Pat Salome, City Clerk
Mark Boling
Mark Swan, Supervisor
-------
TATUM, TOWN OF
TEXICO, TOWN OF
THOREAU WATER AND SANITATION
TRUTH OR CONSEQUENCES, CITY OF
TUCUMCARI, CITY OF
TULAROSA, VILLAGE OF
TWINING, W&SD
VAUGHN, TOWN OF
WAGON MOUND, VILLAGE OF
(505)392-7412
(505)482-3314
(505)862-7136
(505)894-7331
(505)461-3451
(505)585-2771
(505)776-8845
(505)392-1266
(505)666-2408
F. L. (Roy) Miller
Mathew Meeks
Vidal Brown
Quentin Drunzer, City Manager
Bernadette Moya, City Manager
Margaret Gonzales, Village Clerk
Joe Harvey
F.L. Miller- Con. Engineer
Alfred Romero Mayor
-------
Online Resources:
International Fabricare: www.fabriclink.com
US EPA: Design for the Environment: www.epa.gov/opprintr/dfe
Additional Sources of Information:
Document No. Name of Document:
EPA 744-K-98-002 Design for the Environment: Frequently Asked Questions
about Drycleaning
EPA 305-B-96-001 Multimedia Inspection Guidance for Dry Cleaning Facilities
24
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EPA Air Requirements for Dry Cleaners
Equipment Requirements
Requirements
Surround all Existing Transfer
Machines with a room
enclosure vented by a Carbon
Absorber
Installation of main Perc
Vapor Recovery System*
Installation of additional
Carbon Absorber for Residual
Perc Recovery System
Small Area Source
Not required
Required for New
machines at start-up
Not required
Large Area Source
Not required
Required for New machines
at start-up and Existing
machines by 9/23/96
Not required
Major Source
Required by 9/23/96
Required for New
machines at start-up and
Existing machines by
9/23/96
Required for New
machines at start-up and
Existing machines by
9/23/96
Emissions Equipment Monitoring
Requirement
Monitoring of Refrigerated Condensers
Monitoring of Carbon Absorbers
All Sources
Weekly monitoring required
Weekly monitoring required
Fugitive Emissions Control
Requirement
Leak detection
program
Simple leak repairs
Leak repairs
requiring parts
ordering
Disposal of
cartridge filters
General operation
of dry cleaning
machines
Keep machine doors
closed except when
transferring
garments
Store perc and perc
waste in tightly
sealed containers
Small Area Source Large Area
Biweekly inspection Weekly inspf
Repair within 24 hours.
Source Major Source
action Weekly inspection
Order parts within 2 days. Install parts within 5 days of receipt.
Drain for at least 24 hours.
As per manufacture's specifications and
recommendations .
Required
Required
Reporting
Requirements
Initial Compliance Report
Additional Compliance Reports
All Sources
Required upon start-up.
Required 30 days after any change in facility status including
ownership, address, equipment, or size category.
a change in
25
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Record Keeping-Must be kept for 5 years.
Requirement
Perc Purchase Log
Leak Inspection Log
Maintenance Log
Small Area Source
Large Area Source
Major Source
Record purchases from receipts for entire facility and calculate on the first of every
month. Keep all receipts. Maintain a 12 month running total.**
Biweekly inspection and
record**
Weekly inspection and
record**
Weekly inspection and
record**
Record all repairs needed, parts ordered and installed. Also record tests of exhaust from
the carbon absorber and temperature of the refrigerated condenser, if required for your
facility.**
* Perc Vapor Recovery Systems must be either Existing Carbon Absorbers installed before
September 22,1993 or Refrigerated Condensers.
**An example is provided in Appendix B.
26
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OSHA Check list for Dry Cleaning Exposure to Perchloroethylene (PERC)
PERC is the most commonly used dry cleaning solvent. It can enter the body by breathing it
and through the skin. Symptoms associated with exposure including damage to the liver and
kidneys, memory loss, confusion, dizziness, headache, drowsiness, and eye and throat
irritation. Repeated skin exposures may cause dermatitis. PERC is also thought to cause
cancer in humans.
General measures for controlling PERC
To reduce the exposure to PERC, a comprehensive control approach should be followed.
This includes the use of engineering measures, work practices, and personal protection
equipment. Engineering controls are the most preferred and effective means of controlling
exposure. Substitution with another less toxic solvent is an effective means of eliminating
exposure to PERC.
Can PERC be replaced with another solvent?
Are the dry cleaning machines isolated from other work areas?
Do employees unload the machines after the clothing is dried?
Are vapor recovery systems leak free?
Are the machines free from liquid PERC leaks?
Are the machines free from gaseous PERC leaks?
Are the employees wearing personal protective equipment?
Are the machines ventilated to capture PERC when the doors are
open?
Does the shop have fresh air supply to dilute the amount of PERC in
the air?
Do the doors lock so they can't be opened while the machine is
operating?
Are full drying times maintained?
Control of PERC using Machine Design
Machine design can reduce or eliminate employee exposure to PERC as well as reduce
the amount of PERC released into the atmosphere. Machines that are self-contained
with vapor capturing systems do not allow PERC to be released into the work place.
Examine your machines to determine the following. The optimum type machine is a dry-
to-dry machine with a refrigerated condenser and carbon adsorber.
27
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Do you use a dry-to-dry machine?
Is this machine vented?
Is this machine non-vented with a secondary vapor control?
Does the machine have a drum monitor to indicate levels o PERC?
Does the machine have a refrigerated condenser?
Does the machine have a carbon adsorber?
Does the machine have a door lock mechanism that prevents the
loading or unloading of the machine before the end of the cycle?
Is the machine automatically filled with PERC so that employees don't
have contact?
Is the PERC system completely enclosed?
Controlling PERC hazards by material substitution
By substituting another solvent for PERC, the exposure is not only reduced, it is
eliminated. Currently, two potential alternatives to PERC are on the market. They are
Wet-cleaning and Petroleum-Based dry-cleaning. Modern wet cleaning is a method to
clean by water immersion of garments usually cleaned in solvents. Petroleum-based
dry-cleaning has been used in garment cleaning for many years. These alternatives
have different physical properties from PERC that affect there cleaning performance as
well as their health and safety hazards.
Can PERC be substituted with another product?
Is the substitution less toxic than PERC?
Is PERC less flammable than the substitution product?
28
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Controlling PERC hazards by ventilation
An effective means of controlling PERC exposure is through ventilation controls. These
controls can be part of the machine design, a local exhaust system, or general
ventilation. It is important to remember that ventilation controls do not eliminate the
PERC vapors but instead, capture or dilute the vapors before they reach the workers
breathing zone.
Does the machine have built-in ventilation controls?
Can the machine be retrofitted with ventilation controls?
Can a capture type hood be placed over the dryer door?
If the machine has a capture type hood, does it have a velocity of 100
feet per minute?
Does the exhaust from the machine exit at least five feet above the
roof to prevent reentry into the building?
Can cross drafts that interfere with the local exhaust ventilation be
eliminated?
When using general ventilation for dilution, does the air change every
five minutes?
Do supply and exhaust systems move the air from a clean area to a
less clean area?
Does the shop have an adequate supply of fresh air?
Other hazards in your dry-cleaning shop
Within the dry-cleaning shop, employees are exposed to numerous hazards. As the
employer, you should identify and eliminate these hazards. One method of doing this is
by conducting a hazard assessment. When conducting a hazard assessment, look at
each process and identify actions that could result in an injury or exposure to chemicals.
Common hazards to address are unguarded machines, bad electrical cords or outlets,
exposure to chemicals, and lack of the appropriate personal protective equipment.
Below is a checklist with the corresponding OSHA standards; this is not an exhaustive
list. If you have further questions regarding health and safety in your shop, please
contact our office at 505-827-4230.
29
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Is your process free from high levels of noise?
Are employees wearing gloves, face shields, or other
personal protection equipment?
If employees conduct maintenance and repair on machines,
do you have a lock out/tag out program?
Do you have fire extinguishers and are employees trained
in the use?
Are machines guarded so that employees cannot get
caught, pinched, or pulled into them?
Are all belts, pulleys, and chains guarded?
Are all electrical cords, wires, connectors, and electrical
boxes maintained so that employees cannot come into
contact with electricity?
Have you made a list of all hazardous chemicals in the work
place? This includes the pre-spotting agents and any other
chemicals used.
Have employees been trained in the use of these
chemicals?
Do you have material safety data sheets, or MSDS, for
each chemical on the premises?
Have you written a hazard communication program for
employees who use chemicals?
Note: If any of the above questions that are answered with "Yes", then the condition is probably adequate. If
any of the above questions are answered "NO", then re-evaluate the situation, as a violation of the standards
may exist. For assistance contact:
NEW MEXICO OCCUPATIONAL HEALTH & SAFETY BUREAU
CONSULTATION PROGRAM
505-827-4230
The Consultation Program provides safety and industrial hygiene surveys of workplaces, along with
evaluation of, and assistance with the establishment of safety and health programs. The program is
administered by the State but is operated separately from the Enforcement Program. The services are
primarily targeted to smaller businesses, both public and private. The goal is to reduce workplace injuries
and illnesses by helping businesses identify workplace hazards and find effective, economical solutions for
eliminating or controlling them. The service is free and there are no penalties or fines, even if problems are
found. Participation in this voluntary program has helped many New Mexico Businesses lower their costs
associated with worker's compensation claims and increase their efficiency and productivity.
30
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OSHA CONSULTATION/TECHNICAL SERVICES
FREQUENTLY ASKED QUESTIONS
What is the Consultation Service all about?
The Consultation program provides safety and industrial hygiene surveys of workplaces,
along with evaluation of, and assistance with establishment of safety and health programs.
Although the service was established by the same Act that created the Occupational
Safety and Health Administration, and the associated enforcement/compliance agencies
on the federal and state level, the Consultation Service does not issue fines or penalties.
Since the same regulations are covered, the service allows the employer to benefit from
the professional assistance, without fines being imposed.
What does your service cost and who is eligible?
The Occupational Health & Safety Bureau (OHSB) offers consultation services free of
charge to New Mexico employers with 250 or less employees on location or 500 statewide.
Limited services are available to larger companies. Consultation is offered only at the
request of an employer.
What types of places do you visit?
The extent of the OSHA Act is to protect employees in all places of work. These include
machine shops, hospitals, offices, chemical manufacturing plants etc. The consultation
program is designed to assist employers (especially small employers) in complying with
the requirements of OSHA regulations. We therefore, visit any place of employment that
has employees.
Where does the Consultation Service get its funding?
The program receives funding from both the federal and the state government.
How long does the consultation process take?
Depending on the size of the company and the scope of the visit, a consultation may take
anywhere from one or two hours to a full day. If exposure monitoring is requested or
recommended, another day is often scheduled.
What kinds of things do you look at?
In order to evaluate the systems in place, sufficient information from the employer may be
needed. This would include assessing existing safety and health programs, the OSHA 200
logs, accident investigation reports, and a walk-through of the facility to identify potential
injury and illness hazards in the workplace.
Do we have to let you in all areas?
You, the employer makes that determination. If you requested a comprehensive survey,
the consultant will look at all areas.
31
-------
Can it be arranged for both the safety and the industrial hygiene visits to be
conducted on the same day?
Visits are scheduled based on the caseload of the consultants. Where the caseloads
permit such an arrangement can be made.
Do I (the employer) have to fix everything you find?
The employer is obligated to correct all serious hazards found by the consultant, within a
reasonable time frame. Time extensions are granted for abatement of hazards when
needed, if the employer is providing interim protection for employees.
How are hazards classified as "serious" & "other than serious"?
A serious violation results where there is substantial probability that death or serious
physical harm could result. An other than serious violation is a hazard that has a direct
relationship to job safety and health, but probably would not cause death or serious
physical harm.
How much will it cost to correct/fix the hazards identified?
Usually, it is not prohibitively costly to correct hazards identified by our consultants.
However, where cost becomes an overriding consideration or where the employer can
show that engineering controls are not feasible the employer may seek a variance from
OHSB. In this case the employer must show that a combination of work practices,
administrative controls, and personal protective equipment will provide equal or better
protection for the employees.
Do you come back to verify hazard correction?
For regular consultation visits, a statement of assurance of correction for each hazard is
usually acceptable. For special program consultations (SHARP) a follow-up visit is usually
conducted to verify correction of hazards.
How do we request an extension of time on corrections?
All extensions have to be requested in writing. The letter should include the reason for the
extension, what has been done to date to correct hazards; and if corrections have not been
made, the employer must state what interim measures have been taken to protect the
employees.
What is the SHARP Program all about?
SHARP or Safety and Health Achievement Recognition Program is one of our special
programs for companies wishing to go the extra mile to establish a fully functional overall
safety and health program, in addition to the correction of hazards. SHARP is primarily a
recognition program for exemplary companies, but an added incentive for SHARP
participants is a one-year exemption from OHSB's general schedule inspections.
Does Sharp keep OHSB enforcement out in all cases?
No, At SHARP sites, OHSB will continue to make inspections in the following
situations:
32
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imminent danger;
fatality/catastrophe;
formal complaints;
referral from other government agencies; or
follow-up on previously cited violations.
Where can I get information on establishing written programs (i.e. blood borne
pathogen, hazard communication, confined space, etc?
Many of the safety and health programs are available through the New Mexico
Occupational Health & Safety Consultation Program. They are available upon request.
How do we know which elements of the safety and health program requirements
need to be fixed, if it doesn't show up on your report to us?
It is addressed in the safety & health program management section of the report the
employer receives. These issues are also discussed by the consultant with the employer.
Is it necessary to have a written certification of hazard assessment at work sites that
do not require (PPE) Personal Protective Equipment for any task?
Yes, according to 1910.132(d)(2), the employer shall verify that the required workplace
hazard assessment has been performed through a written certification that identifies the
workplace evaluated.
Can you come to our company and conduct a class or safety meeting?
Onsite training and education by consultants will be based on available resources and the
employers request. The training and education will be tailored to the nature of the hazards
or potential hazards in each specific workplace. Training in specific areas is also available
through private consultants and the New Mexico Workers Compensation Administration or
your insurer.
Can the consultant come back for specific things such as checking new equipment
or processes that we bring on line?
Yes, Visits for specific purposes can be requested, in addition to regular consultation visits.
May I call your office anytime to ask questions?
Consultants are available to answer questions between 7-5pm Monday-Friday
Can anyone gain access to my report?
No, our files are confidential and are destroyed after 3 years.
Will a consultation visit lead to an inspection by OSHA compliance? Will your
findings be passed on them?
All information is kept confidential. OHSB compliance inspectors cannot discover where
we have been and then inspect those companies. The only time enforcement is contacted,
is if a company neglects to correct serious hazards beyond time extensions. Then we are
obligated to refer those items to enforcement, but only after we have made every attempt
to work with the company.
33
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What determines when a compliance inspection is going to occur? How do they
decide whom they are going to visit?
Factors that may trigger a compliance inspections include:
formal complaints by employees or their authorized agents;
fatalities;
catastrophe or major incidents;
history of the company (previous OSHA activity);
referral by other governmental agencies;
general schedule inspections; or
special emphasis programs
Have you been or will you go to my competitor?
Our service extends to all eligible companies who request it. All information is kept
confidential; therefore, no hazards, or processes that may be a trade secret, seen in your
facility will be discussed in another place of business.
Where can I get a copy of the regulations?
The Government Printing Office (GPO) processes all sales and distribution of the CFR.
For payment by credit card, call (202) 512-1800, M-F, Sam to 4 pm or fax your order to
(202) 512-2250, 24 hours a day. For payment by check, write to the Superintendent of
Documents, Attn: New Orders, PO Box 371954, Pittsburgh, PA 15250-7954. Regulations
and other material are available on the Internet at www.osha.gov.
General Health and Safety Issues
YES NO
D D Do the employees wear respirators?
If so,
D D Does the company have a written respiratory protection program?
D D Are employees trained to properly wear, clean/maintain, and know in what
situations the respirators are needed?
If not,
D D Is the indoor air quality such that they are not needed?
D D Is there a written Hazard Communication Program?
D D Are MSD sheets available for all the hazardous chemicals in the workplace and are
they updated regularly?
D D Have employees received Hazard Communication training?
D D Are there elevated storage/equipment lofts or platforms present?
If so,
34
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D D Are signs showing the weight capacity present?
D D If the floors are more than 4 feet above a lower floor, are guardrails present?
D D Are all exits marked with signs?
D D Are exit doors free to access and are routes to these exits kept free of
obstructions?
D D Is there a procedure in place for obtaining medical treatment for injured
employees?
D D Are there first aid supplies readily available?
D D Are there fire extinguishers on site?
D D Are they charged and ready for use?
D D Are employees required to use these extinguishers?
If yes,
D D Is the path unobstructed?
YES NO
D D Are they subjected to an annual inspection?
D D Are employees trained to use them?
If not,
D D Is there a written policy that requires employee evacuation?
D D Does the company have an emergency action plan and fire prevention plan?
D D Has the electrical system throughout the facility been assessed for situations where
an employee may come into contact with an electrical current, or the electrical
system is such that a fire hazard exists (i.e. bare conductors, faulty equipment,
exposed electrical equipment where a flammable/explosive environment may
exist)?
D D Does the employer (if 10+ employees are employed) record occupational injuries
and illnesses on the OSHA-200 log?
Note: If any of the above questions that are answered with "Yes", then the condition is probably adequate. If
any of the above questions are answered "NO", then re-evaluate the situation, as a violation of the standards
may exist. For assistance contact:
NEW MEXICO OCCUPATIONAL HEALTH & SAFETY BUREAU
CONSULTATION PROGRAM 505-827-4230
35
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Auto Repair Shop Safety Checklist
Yes No
Walking Working Surfaces
D D Are all aisles and walkways 22" or wider?
D D Are permanent aisles marked and maintained free of obstructions?
D D Are spills and slick areas cleaned up?
Hand Tools
D D Are tools clean and in good condition?
D D Are chisels and punches without mushroomed heads?
D D Are wood hammer handles without cracks or splits?
Power Tools
D D Are right angle grinders equipped with half moon guards?
D D Is hearing protection worn when using impact tools?
D D Are electric tools double insulated or grounded?
D D Are bench grinder tools rests (1/4") and top tongue guards (1/8") adjusted?
Machinery
D D Are all guards in place?
D D Is machinery used according to manufacturers instructions?
D D Does air compressor have Lock-out/Tag-out procedure? Locks and Tags?
D D Are car hoists and lifts inspected annually by experts?
D D Are overhead hoists and engine hoists inspected (internally) annually?
D D Are air nozzles restricted to 30 psi or less?
Flammables
D D Are flammables (<25 gallons) stored in approved cabinets?
D D Are fire extinguishers available for types of flammables?
D D Are spray paint operations performed inside spray booth or area?
D D Are torches more than 20 feet from other flammables?
D D Are torches more than 20 feet from other spare bottles, including empties?
36
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Yes No
Personal Protective Equipment
D D Is hearing protection provided and are employees trained on use and limitations?
D D Is a Chemical Hazard Communication Program in place?
D D Is personal protective equipment used?
D D Is a written Personal Protective Equipment program in place?
Electrical
D D Are all cords in good condition?
D D Is strain relief provided for cord connections to tools or junction boxes?
D D Is conduit used for permanent wiring?
D D Are all outlets grounded?
D D Are all areas within 6 feet of wet or potentially wet surfaces protected by GFCI?
Safety and Health Program (recommended)
D D Is a Job Hazard Analysis written for hazardous jobs?
D D Is training provided for Job Hazard Analysis tasks?
D D Are safe behaviors observations conducted?
D D Is there management commitment to the safety program?
D D Are employees involved in a safety program?
D D Is the safety program evaluated periodically?
Note: If any of the above questions that are answered with "Yes", then the condition is probably adequate. If
any of the above questions are answered "NO", then re-evaluate the situation, as a violation of the standards
may exist. For assistance contact:
NEW MEXICO OCCUPATIONAL HEALTH & SAFETY BUREAU
CONSULTATION PROGRAM
505-827-4230
The Consultation Program provides safety and industrial hygiene surveys of workplaces, along with
evaluation of, and assistance with the establishment of safety and health programs. The program is
administered by the State but is operated separately from the Enforcement Program. The services are
primarily targeted to smaller businesses, both public and private. The goal is to reduce workplace injuries
and illnesses by helping businesses identify workplace hazards and find effective, economical solutions for
eliminating or controlling them. The service is free and there are no penalties or fines, even if problems are
found. Participation in this voluntary program has helped many New Mexico Businesses lower their costs
associated with worker's compensation claims and increase their efficiency and productivity.
37
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Second Edition
Environmental Management Systems:
An Implementation Guide for
Small and Medium-Sized Organizations
Environmental
Policy
Management
Review
Continual
Improvement
Planning
Checking /
Corrective Action
Implementation,
-------
Second Edition
Environmental Management Systems:
An Implementation Guide for Small and Medium-Sized Organizations
Written by:
Philip J. Stapleton, Principal
Margaret A. Glover, Principal
Glover-Stapleton Associates, Inc.
3 Bunkers Court
Grasonville, MD 21638
410-827-7232
and
S. Petie Davis, Project Manager
NSF ISR
789 N. Dixboro Road
Ann Arbor, Ml 48158
1-888-NSF-9000
Copyright © NSF 2001
All rights reserved
This work has been copyrighted by NSF to preserve all rights under U.S. Copyright law and
Copyright laws of Foreign Nations. It is not the intent of NSF to limit by this Copyright the fair
use of these materials. Fair use shall not include the preparation of derivative works.
Published by NSF International: E-mail: information@nsf-isr.org Web: www.nsf-isr.org
©2001 NSF I
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Acknowledgments
When the first edition of this Guide was published in November 1996, the use of environmental
management systems (EMS) was a relatively new, but rapidly expanding phenomenon. Considerable
experience in EMS design and implementation has been gained since the first edition of this Guide was
published. The authors' primary goal in preparing this second edition of the Guide was to take
advantage of the many new developments in the EMS field as well as the insights and experiences of
many organizations that have implemented EMS over the past few years.
The second edition was prepared by NSF International with funding through a cooperative agreement
with the U.S. Environmental Protection Agency's Office of Wastewater Management; Office of
Enforcement and Compliance Assistance; Office of Pesticides, Prevention and Toxic Substances; and
Office of Policy Economics - Innovation.
In preparing the second edition, the authors solicited input from a variety of organizations that used the
Guide in EMS planning and implementation activities. Feedback from the user community was very
helpful in framing the changes that are reflected in this second edition. In particular, the authors would
like to thank the following individuals for sharing experiences and insights on their use of the first edition
of the Guide.
• Sue Mills, Champion International,
• Charles Tellas, Milan Screw Products, Inc.,
• Ronda Moore, Zexel Corporation
• Susan Briggs, Brookhaven National Laboratory
NSF International also would like to acknowledge the following individuals for their many contributions
to the first edition of this Guide:
• Jeffrey R. Adrian, The John Roberts Company
• Lemuel D. Amen, Washtenaw County Department of Environment & Infrastructure Services
• Stephen P. Ashkin, Rochester Midland
• Christine A. Branson, Industrial Technology Institute
• Ken Burzelius, Midwest Assistance Programs, LeSueur County
• Marci Carter, Iowa Waste Reduction Center, University of Northern Iowa
• John Dombrowski, U. S. Environmental Protection Agency (Office of Compliance)
• David Fiedler, Michigan Department of Environmental Quality (Environmental Assistance Div.)
• Wendy Miller, U. S. Environmental Protection Agency (Office of Compliance)
• Charles Tellas, Milan Screw Products, Inc.
• Bryant Winterholer, K. J. Quinn & Co., Inc.
Finally, the authors of this Guide would like to thank Jim Home of the U. S. Environmental Protection
Agency (Office of Wastewater Management) for his significant contributions to the development of this
Guide.
©2001 NSF
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Second Edition
Environmental Management Systems:
An Implementation Guide for Small and Medium-Sized Organizations
CONTENTS
Introduction to Second Edition 1
Section 1: Why Your Organization Should Have an EMS 4
Section 2: Key EMS Concepts 8
Section 3: READY! (Initial EMS Planning) 10
Section 4: SET! (Key Elements of an EMS) 14
Environmental Policy 16
Identifying Environmental Aspects 20
Legal and Other Requirements 25
Objectives and Targets 28
Environmental Management Program(s) 32
Structure and Responsibility 35
Training, Awareness and Competency 39
Com munications 43
EMS Documentation 47
Document Control 50
Operational Control 53
Emergency Preparedness and Response 57
Monitoring and Measurement 60
Nonconformance and Corrective / Preventive Action 65
Records 69
EMS Auditing 71
Management Review 75
Section 5: GO! (Roadmap for EMS Development) 78
Creating Your EMS: Step by Step 80
Appendix A: TOOLKIT 88
Sample Environmental Policies 89
Environmental Impact Identification and Evaluation: Techniques and Data Sources...96
Sample Procedure: Instructions for Environmental Aspects Identification Form 98
©2001NSF ii
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Sample Procedure: Instructions for Environmental Aspects Identification Form 103
Environmental Aspects Identification 106
Sample Environmental Aspect Evaluation and Scoring Tools 108
Resources for Tracking Environmental Laws and Regulations 111
Sample Process Tool: Setting Objectives & Targets 113
Sample Procedure: Setting Objectives & Targets 117
Sample Tools: Environmental Management Program 120
Sample Responsibility Matrix 123
Sample Environmental Training Log 125
Sample Procedure: Communications with External Parties 127
Sample Document Index 130
Outline of Sample EMS Manual and Other EMS Documents 132
Sample Records Management Form (supplied courtesy of 134
General Oil Company) 134
Sample Procedure: Corrective and Preventive Action 136
(includes tracking log) 136
Sample Environmental Records Organizer 141
Sample Procedure: EMS Audits 143
Sample EMS Audit Forms 149
Sample EMS Audit Questions 152
Sample Procedure: Management Review 157
Appendix B: EPA's Performance Track and Other Government EMS Initiatives 159
Appendix C: Information on Process Mapping and Design for Environment 169
Appendix D: Registration of Environmental Management Systems 178
Appendix E: Integration of Environmental Management Systems and Quality
Management Systems 182
Appendix F: Additional Sources of Information and Contacts 186
Glossary of Acronyms 195
Bibliography 196
©2001 NSF
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Introduction to Second Edition
The first edition of this Guide was published in November 1996. Like its predecessor, this second
edition is designed to explain environmental management system (EMS) concepts and to support and
facilitate the development of EMS among small and medium-sized organizations. Implementation of an
EMS is a voluntary approach to improving environmental performance. Over the past several years,
many public and private sector organizations have implemented EMS and their numbers grow daily.
These organizations report a number of important EMS benefits, as described in this Guide.
Many changes were made in this edition of the Guide to improve its usefulness and to reflect EMS
experience gained over the last four years The changes were based on feedback solicited from
selected users of the first edition of the Guide, lessons learned and implementation examples from the
NSF/EPA projects, the Multi-State Working Group, Guide users, and Technical Committee 207-Small
and Medium-Sized Enterprise efforts. In particular, the authors have provided additional information on
certain EMS elements that many organizations have found to be particularly challenging - including
environmental aspects, communications and operational controls, among others. Sections 3 through 5
have been reconfigured into a new "Ready-Set-Go" format. The new Section 5 (GO!) has been added
to provide a "roadmap" or logical sequence for implementing the key elements of an EMS. In addition,
pollution prevention success stories and examples of EMS implementation practices from public sector
and service based-organizations have been added to help demonstrate the value of EMS.
This Guide is designed primarily for use by EMS implementers — the people in a small or medium-
sized organization that lead the EMS development effort. The heart of the Guide is found in Section 4,
"Key Elements of an EMS." For each of the key EMS elements, this section describes the importance of
the element, how to get started on implementation, and other key suggestions. In this edition,
worksheets have been added to help users "capture their learning" as they progress from one EMS
element to the next. Readers of the Guide can use these worksheets to summarize and evaluate their
existing management processes, to initiate needed improvements and to help maintain implementation
momentum.
The Guide continues to use the ISO 14001 standard as one important EMS model. ISO 14001,
published in November 1996, is the most widely accepted international standard for EMS. EPA, as part
of its effort to promote the use of EMS's that can help organizations improve environmental performance
(including compliance) and make greater use of pollution prevention approaches, is implementing
several EMS initiatives that might be useful to some organizations. These include the National
Environmental Performance Track, the EMS Initiative for Local Governments and the Design for
Environment EMS Guide. Information on the National Environmental Performance Track program and
other Federal and state-level EMS initiatives can be found in Appendix B and other relevant sections of
this Guide.
While this Guide is intended primarily for organizations outside the Federal government, some Federal
agencies are developing EMS's at their facilities. These agencies may wish to use this Guide to support
their EMS efforts.
This Guide is not intended for use by registrars (or others) for registration purposes, nor is it intended to
provide specific interpretations of the ISO 14001 Standard.
©2001 NSF
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How this Guide is Organized
Section 1:
Why Your Organization
Should Have an EMS
Section 2:
Key EMS Concepts
Section 3:
Initial EMS Planning
Section 4:
Key Elements
of an EMS
Section 5:
Roadmap for
EMS Development
Appendices
Describes the many benefits of an EMS and how such a system can
help your organization to compete and prosper in today's global
marketplace.
Summarizes overall management systems concepts. This section
explains what a management system is and what must be in place for
a successful EMS.
Describes the initial process for planning an EMS and recommends
some steps in the overall EMS planning effort.
Provides detailed guidance on how each element of your EMS could
be designed and implemented. Discusses each of the key elements of
an EMS and suggests how to put them in place.
Describes a sequence of events or "roadmap" for implementing the
key elements of an EMS and explains why the implementation of
certain elements might precede others.
Describe sources of EMS information and related EPA and state
programs. Also describe the process for registering an EMS and
selecting and working with a registrar. The Tool Kit (Appendix A)
provides sample EMS policies, procedures and other tools that your
organization can tailor to fit its EMS needs. The sample procedures
are adapted from actual EMS procedures used by organizations that
have implemented EMS.
Use of Icons
A variety of icons are used in this Guide to highlight key concepts and suggestions for the reader. The
most frequently used icons include:
4^%
^f (" y|^ The light bulb is used to highlight EMS examples and experiences from various
\^~ organizations.
The hand is used to point out hints for implementing EMS elements.
The key is used to indicate keys to successful EMS implementation, as identified by
various organizations.
©2001 NSF
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The speech balloon is used to indicate quotes from representatives of organizations that
have implemented an EMS, as well as definitions from various sources (such as ISO
14001).
The Tool Box icon is used to highlight references to useful examples and other tools
that are found in Appendix A (the Tool Kit).
The Links icon is used to summarize critical linkages among EMS elements.
©2001 NSF
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Section 1: Why Your Organization Should Have an EMS
A systematic approach to achieve your environmental and other organizational goals
Key EMS Benefits
improved
environmental
performance
reduced liability
competitive advantage
improved compliance
reduced costs
fewer accidents
employee involvement
improved public image
enhanced customer
trust
more favorable credit
terms
meet customer
requirements
Does your organization need an EMS? Well, ask
yourself the following questions:
"We view the
establishment of an
EMS as a process
that forces us to
better organize our
priorities and
projects and to
identify problems
and exposures
before they occur."
- K.J. Quinn &Co.,
a small specialty
chemical company
Is your organization required to comply
environmental laws and regulations?
with
• Are you looking for ways to improve your
environmental performance?
• Is the state of your organization's environmental
affairs a significant liability?
• Does a lack of time or resources prevent your
organization from managing its environmental
obligations effectively?
• Is the relationship between your organization's
environmental goals and other goals unclear?
If you answered YES to one or more of the above
questions, an EMS can help your organization —
and so will this Guide!
As one of your organization's leaders, you probably
know that interest in environmental protection and
sustainable development is growing each year. You
might hear about these issues from customers, the
public or others. Like many, your organization may
be increasingly challenged to demonstrate its
commitment to the environment. Implementing an
EMS can help you meet this challenge in several
important ways.
First, an effective EMS makes good sense, whether
your organization is in the public or private sector.
By helping to identify the causes of environmental
problems and then eliminate them, an EMS can help
you save money. Think of it this way:
> Is it better to make a product (or provide a
service) right the first time or to fix it later?
> Is it cheaper to prevent a spill in the first place or
to clean it up afterwards?
> Is it more cost-effective to prevent pollution or to
manage it after it has been generated?
©2001 NSF
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"We found that an
EMS could improve
employee retention,
new hire selection,
working conditions,
and the perceptions
of our customers,
suppliers, lenders,
neighbors, and
regulators."
Milan Screw Products,
a 32-person manufacturer
of precision fittings
Some reasons that
municipalities have
implemented an EMS:
0 Improved compliance
performance
0 Enhanced
management
confidence
0 Increased efficiency
0 Public image concerns
0 Growth management
0 Desire to be seen as
leaders and innovators
Second, an EMS can be an investment in long-
term viability of your organization. An EMS can
help you to be more effective in achieving
environmental goals. And, by helping businesses to
keep existing customers and attract new ones, an
EMS adds value.
Here's some good news: Much of what you need for
an EMS may already be in place! The management
system framework described in this Guide includes
many elements that are common to managing many
organizational processes, such as quality, health &
safety, finance, or human resources. As you review
this Guide, you will probably find that your
organization has many EMS processes in place,
even though they may have been designed for other
purposes. Integrating environmental management
with other key organizational processes can improve
financial, quality and environmental performance.
The key to effective environmental management is
the use of a systematic approach to planning,
controlling, measuring and improving an
organization's environmental performance.
Potentially significant environmental improvements
(and cost savings) can be achieved by assessing and
improving your organization's management
processes. Many environmental "problems" can be
solved without installing expensive pollution control
equipment.
Of course, there is some work involved in planning,
implementing and maintaining an EMS. But many
organizations have found that the development of an
EMS can be a vehicle for positive change. Many
organizations have seen that the benefits of an EMS
far outweigh the potential costs. And while these
EMS concepts certainly apply to the private sector, a
number of public sector organizations (including
municipalities) have found that they can benefit from
an EMS.
In the Total Quality Management (TQM) world, they
say that "quality is free" — as long as you are willing
to make the investments that will let you reap the
rewards. The same holds true for environmental
management.
Want to know more about EMS costs and benefits?
Then read on ...
©2001 NSF
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EPA encourages the use
of EMS that improve
compliance, pollution
prevention and other
forms of environmental
performance. The
Agency is assessing how
EMS can be used to
strengthen environmental
programs and policies.
"We needed a system
to manage things that
came up in a consistent
way. Our area is
growing and an EMS
will help us handle
development issues
such as controlling soil
erosion and preserving
the natural features of
the area. An EMS is a
way to control
environmental
problems in a rapidly
growing community."
Steve Daut, Council Trustee
Village of Chelsea, Michigan
Frequently Asked Questions about EMS
1. We already have a compliance program - why do
we need an EMS?
An EMS can help you to comply with regulations more
consistently and effectively. It also can help you identify
and capitalize on environmental opportunities that go
beyond compliance.
2. How big does an organization need to be to
successfully implement an EMS?
EMS have been implemented by organizations ranging in
size from a couple of dozen employees to many thousands
of employees. The elements of an EMS (as described in
this Guide) are flexible by design to accommodate a wide
range of organizational types and sizes.
3. Will an EMS help us to prevent pollution?
A commitment to preventing pollution is a cornerstone of an
effective EMS and should be reflected in an organization's
policy, objectives and other EMS elements. Examples
throughout this Guide show how organizations have used
an EMS to prevent pollution.
4. To implement an EMS, do we have to start from
scratch?
Much of what you have in place now for environmental
management probably can be incorporated into the EMS.
There is no need to "start over".
5. How will an EMS affect my existing compliance
obligations?
An EMS will not result in more or less stringent legal
compliance obligations. But an EMS should improve your
efforts to comply with legal obligations, and, in some cases,
may lead to more flexible compliance requirements. (See
discussion of Performance Track in Appendix B.)
6. Do we need to be in 100% compliance in order to
have an EMS?
No. The concept of continual improvement assumes that
no organization is perfect. While an EMS should help your
organization to improve compliance and other measures of
performance, this does not mean that problems will never
occur. However, an effective EMS should help you find and
fix these problems and prevent their recurrence.
©2001 NSF
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EMS Costs and Benefits
POTENTIAL COSTS
Internal
• Staff (manager) time
• Other employee time
(Note: Internal labor costs represent the
bulk of the EMS resources expended
by most organizations)
External
• Potential consulting assistance
• Outside training of personnel
POTENTIAL BENEFITS
Improved environmental performance
Enhanced compliance
Prevention of pollution/resource conservation
New customers / markets
Increased efficiency / reduced costs
Enhanced employee morale
Enhanced image with public, regulators, lenders,
investors
Employee awareness of environmental issues and
responsibilities
If your organization already has or is
considering a quality management system
(based on ISO 9001, for example), you will
find significant synergy between what you
need for quality management and for
environmental management (see below).
Some Common Aspects of Quality and Environmental Management Systems
QMS
Quality Policy
Adequate Resources
Responsibilities and Authorities
Training
System Documentation
Process Controls
Document Control
System Audits
Management Review
EMS
Environmental Policy
Adequate Resources
Responsibilities and Authorities
Training
System Documentation
Operational Controls
Document Control
System Audits
Management Review
One final note: Small and medium-sized
organizations often have certain advantages
over larger organizations in ensuring effective
environmental management. In smaller
organizations, lines of communication are
generally shorter, organizational structures are
less complex, people often perform multiple
functions, processes are generally well
understood, and access to management is
simpler. These can be real advantages for
effective environmental management.
Are you interested in learning more about how
an EMS can help your organization? If so, let's
look at some key management systems concepts
and how they are applied in the environmental
area.
©2001 NSF
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Section 2: Key EMS Concepts
The focus on quality principles
An EMS is:
A continual cycle of planning,
implementing, reviewing and
improving the processes and
actions that an organization
undertakes to meet its
environmental obligations.
You have probably heard of Total Quality Management
(TQM). Your organization may apply TQM principles to
some of its operations and activities.
An effective EMS is built on TQM concepts. To improve
environmental management, your organization needs to
focus not only on what things happen but also on why
they happen. Over time, the systematic identification
and correction of system deficiencies leads to better
environmental (and overall organizational) performance.
Most EMS models (including the ISO 14001 standard,
which is described later) are built on the "Plan, Do,
Check, Act" model introduced by Shewart and Deming.
This model endorses the concept of continual
improvement.
Continual
Improvement:
Enhancing your EMS
to better your overall
environmental
performance
Figure 1
An effective EMS doesn't just
happen. An effective EMS
needs ongoing and visible
management support
Top management" is the
person or group with
executive responsibility for the
organization"
In the EMS model described in this Guide, the "Plan, Do,
Check, Act" steps have been expanded into seventeen
elements that are linked together. These EMS
elements and their linkages are discussed in Section 4.
Some of the keys to a successful EMS include:
Top Management Commitment
Applying TQM principles to the environmental area and
providing adequate resources are the job of top
management. To initiate and sustain the EMS effort,
top management must communicate to all employees
the importance of:
• making the environment an organizational priority
(thinking of effective environmental management as
fundamental to the organization's survival)
• integrating environmental management
throughout the organization
(thinking about the environment as part of
product/service and process development and
delivery, among other activities)
©2001 NSF
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Flexible & Simple =
Adaptable &
Understandable
Some organizations have
found that an effective EMS
allows them to design pollution
and other environmental
impacts out of their products,
services and operations. This
can save money and reduce
liability.
Employee involvement is
crucial. An effective
implementation team is
pivotal to the success of
many organizations.
An EMS should integrate
]^- environmental
^ management into day-to-
day operations as well as
strategic decisions. It can
make the environment the
responsibiity of every
employee.
• looking at problems as opportunities
(identifying problems, determining root causes
preventing problem recurrence)
and
Focus on Continual Improvement
No organization is perfect. The concept of continual
improvement recognizes that problems will occur. A
committed organization learns from its mistakes and
prevents similar problems from recurring.
Flexibility
An effective EMS must be dynamic to allow your
organization to adapt to a quickly changing
environment. For this reason, you should keep your
EMS flexible and simple. This also helps make your
EMS understandable for the people who must
implement it — your organization's managers and
other employees.
Compatibility with Organizational Culture
The EMS approach and an organization's culture
should be compatible. For some organizations, this
involves a choice: (1) tailoring the EMS to the culture,
or (2) changing the culture to be compatible with the
EMS approach. Bear in mind that changing an
organization's culture can be a long-term process.
Keeping this compatibility issue in mind will help you
ensure that the EMS meets your organization's
needs.
Employee Awareness and Involvement
As you design and implement an EMS, roadblocks
may be encountered. Some people may view an
EMS as bureaucracy or extra expense. There also
may be resistance to change or fear of new
responsibilities. To overcome potential roadblocks,
make sure that everyone understands why the
organization needs an effective EMS, what their role
is and how an EMS will help to control environmental
impacts in a cost-effective manner. Employee
involvement helps to demonstrate the organization's
commitment to the environment and helps to ensure
that the EMS is realistic, practical and adds value.
Building or improving an EMS (with the help of this
Guide) provides an opportunity to assess how your
organization manages environmental obligations and
to find better (and more cost-effective) solutions.
While you will probably identify some areas where
your current EMS can be improved, this does not
mean that you should change things that are working
well! By reviewing what your organization does and
how well it works, you can ensure that your EMS will
be viable and effective, both now and in the future.
Don't get discouraged if your system has some bugs
at first — the focus is on continual improvement!
©2001 NSF
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V
Section 3: READY! (Initial EMS Planning)
Putting the theory of EMS into practice
Building an EMS might sound like an overwhelming task
for a smaller organization, but it need not be. Since time
and other resources are limited in any organization, it is
important that you use resources wisely. One way to do
this is by preparing and following a simple, effective plan.
Fortunately, you can build on the experiences of other
organizations that have already implemented an EMS.
Examples are provided throughout this Guide.
Milan Screw Products found
that the use of a cross-
functional team (the
environmental task group)
was the key to progress in
evaluating and implementing
their EMS. Participation of
line managers and
employees is essential in
successfully implementing
an EMS.
Appendix F has
information on EMS
resources
K.J.Quinn & Company found
that it could perform an initial
assessment of its
environmental programs in
20-25 hours
Preliminary Review Tools:
See the "NSF ISO 14001
Self Assessment Tool"
(at www.nsf-isr.org) or
"Incorporating Design for
Environment into your Gap
Analysis"
(at www.epa.gov/dfe)
Figure 2 illustrates the initial steps in the EMS planning
process. The importance of careful planning cannot be
overemphasized. Taking the time to figure out what you
need to do, how you will do it, and who must be involved
will pay big dividends down the road.
Experience shows that using a team approach to
planning and building an EMS is an excellent way to
promote commitment and ensure that your objectives,
procedures and other system elements are realistic,
achievable, and cost-effective. Ideas for using a team
and involving employees are discussed in this section.
A few hints to keep in mind as you build your EMS:
• Help is available — don't hesitate to use it.
(See Appendix F for information on resources.)
• Pace yourself. Move quickly enough that employees
stay interested and engaged, but not so fast that
those involved are overloaded or that the effort
becomes superficial.
Don't re-invent the wheel - existinc
practices should help you to meet EMS
management
requirements.
Consultants can help you evaluate your EMS and
suggest approaches used successfully elsewhere.
Explore ways to hold consulting costs down. You
may be able to join forces with other organizations to
hire a consultant or sponsor a training course.
Some Thoughts on Using Consultants
Assess your own in-house resources first.
Ensure both parties understand the scope
of work.
Get references and check them. Look for
consultants with experience in small
organizations and your specific industry.
Use consultants to gain insights on approaches
used by other organizations.
An EMS developed by consultants "in isolation"
will not work. Your own people need to be
involved in the EMS development process.
©2001 NSF
10
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FIGURE 2: INITIAL EMS PLANNING STEPS
Define Organization's Goals
Secure
Management
Commitment
Select
EMS
Champion
Hold
Kick-off
Meeting
Conduct
Preliminary
Review
Secure
Resources,
Assistance
Initiate
Employee
Involvement
READY!
Build
Implementation
Team
Develop
Project
Plan,
Schedule
Monitor &
Communicate
Progress
©2001 NSF
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Laying the Groundwork for an EMS: Key Steps
Define
Organization's
Goals for EMS
Secure Top
Management
Commitment
Select
EMS
Champion
Build
Implementation
Team
Hold
Kick-Off
Meeting
more...
A first step in EMS planning is to decide why you are
pursuing the development of an EMS. Are you
trying to improve your environmental performance (for
example, compliance with regulations or prevent
pollution)? Are you trying to promote involvement
throughout the organization? Write your goals down
and refer back to them frequently as you move
forward. As you design and implement the EMS, ask:
How is this task going to help us achieve our goals?
This also is a good time to define the project scope or
"fenceline" (i.e., what is the "organization" that the
EMS will cover? One location? Multiple locations?
Should we "pilot" the EMS at one location then
implement the system at other locations later?).
One of the most critical steps in the planning process is
gaining top management's commitment to support
EMS development and implementation. Management
must first understand the benefits of an EMS and what
it will take to put an EMS in place. Explain the
strengths and limitations of your current approach and
how those limitations can affect the organization's
financial and other performance. Management also
has a role in ensuring that the goals for the EMS (see
above) are clear and consistent with other
organizational goals. Management's commitment
should be communicated across the organization.
Not all small- or medium-sized organizations have the
luxury of choosing among multiple candidates, but your
choice of project champion is critical. The champion
should have the necessary authority, an understanding
of the organization, and project management skills.
The champion should be a "systems thinker" (ISO
9000 experience can be a plus, but is not necessary),
should have the time to commit to the EMS-building
process and must have top management support.
A team with representatives from key management
functions (such as engineering, finance, human
resources, production and/or service) can identify and
assess issues, opportunities, and existing processes.
Consider including contractors, suppliers or other
external parties as part of the project team, where
appropriate. The team will need to meet regularly,
especially in the early stages of the project. A cross-
functional team can help to ensure that procedures are
practical and effective and can build commitment to
and "ownership" of the EMS.
Once the team has been selected, hold a kick-off
meeting to discuss the organization's objectives in
implementing an EMS, the steps that need to be taken
initially, and the roles of team members, among other
topics. If possible, get top management to describe its
mitment to the EMS at this meeting. The kick-off
©2001 NSF
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Conduct
Preliminary
Review
Prepare
Budget and
Schedule
Secure
Resources,
Monitor and
Communicate
Advertise your successes to
keep management and
employees aware of your
EMS efforts. Document
benefits, no matter how
small they may seem at the
time. As this list grows, so
will EMS support.
Creating Your Own EMS (cont'd.)
meeting also is a good opportunity to provide some
EMS training for team members. Follow-up this
meeting with a communication to all employees.
The next step is for the team to conduct a preliminary
review of your current compliance and other
environmental programs/systems and to compare
these against the criteria for your EMS (such as ISO
14001). Evaluate your organization's structure,
procedures, policies, environmental impacts, training
programs and other factors. Determine which parts of
your current EMS are in good shape and which need
additional work. See the "NSF ISO 14001 Self-
Assessment Tool" (www.nsf-isr.org) or "Incorporating
Design for the Environment into Your Gap Analysis"
(www.epa.gov/dfe) for gap analysis tools.
Based on the results of the preliminary review, prepare
a project plan and budget. The plan should describe
in detail what key actions are needed, who will be
responsible, what resources are needed, and when the
work will be completed. Keep the plan flexible, but set
some stretch goals. Think about how you will maintain
project focus and momentum over time. Look for
potential "early successes" that can help to build
momentum and reinforce the benefits of the EMS.
The plan and budget should be reviewed and
approved by top management. In some cases, there
may be outside funding or other types of
assistance that you can use (from a trade association,
a state technical assistance office, etc.). See
Appendix F for more ideas on possible sources of help.
Employees are a great source of knowledge on
environmental and health & safety issues related to
their work areas as well as on the effectiveness of
current processes and procedures. They can help the
project team in drafting procedures. Ownership of the
EMS will be greatly enhanced by meaningful employee
involvement in the EMS development process.
As you build the EMS, be sure to regularly monitor
your progress against the project plan and
communicate this progress within the organization.
Be sure to communicate the accomplishments that
have been made and describe what happens next.
Build on small successes. Be sure to keep top
management informed and engaged, especially if
additional resources might be required.
©2001 NSF
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Section 4: SET! (Key Elements of an EMS)
What does an EMS consist of? How are the elements linked together?
As mentioned earlier, your EMS should be built on the "Plan, Do, Check, Act" model to ensure that
environmental matters are systematically identified, controlled, and monitored. Using this approach
will help to ensure that performance of your EMS improves over time and that you meet your goals for
implementing an EMS in the first place.
This section describes seventeen EMS elements that are common to most EMS models. This section
also notes the key linkages among these elements. While there are several good EMS models
available, this Guide generally uses the ISO 14001 Standard as a starting point for describing EMS
elements. This has been done for several reasons:
ISO 14001 is a widely accepted international standard for EMS that focuses on
continual improvement;
Companies may be asked to demonstrate conformance with ISO 14001 as a
condition of doing business in some markets; and
• The Standard is consistent with the key elements found in many EMS models,
including the European Union's Eco-Management and Audit Scheme, EPA's
Performance Track and the Code of Environmental Management Principles for
Federal Agencies, among others.
Figure 3: EMS Model
Management
Review
Environmental
Policy
Checking /
Corrective Action
Monitoring & Measurement
Nonconformance & Corrective &
Preventive Action
• Records
• EMS Audits
Continual
Improvement!
Planning
Environmental Aspects
Legal & Other Requirements
• Objectives & Targets
Environmental Management,
Program
©2001 NSF
Implementation
Structure & Responsibility
Training, Awareness, Competence
• Communication
• EMS Documentation
• Document Control
• Operational Control
Emergency Preparedness /
Response
-------
Key Elements of an EMS: A Snapshot
• Environmental policy — Develop a statement of your organization's commitment to the
environment. Use this policy as a framework for planning and action.
• Environmental aspects — Identify environmental attributes of your products, activities
and services. Determine those that could have significant impacts on the
environment.
• Legal and other requirements — Identify and ensure access to relevant laws and
regulations, as well as other requirements to which your organization adheres.
• Objectives and targets — Establish environmental goals for your organization, in line
with your policy, environmental impacts, the views of interested parties and other
factors.
• Environmental management program — Plan actions necessary to achieve your
objectives and targets.
• Structure and responsibility — Establish roles and responsibilities for environmental
management and provide appropriate resources.
• Training, awareness and competence — Ensure that your employees are trained and
capable of carrying out their environmental responsibilities.
• Communication — Establish processes for internal and external communications on
environmental management issues.
• EMS documentation — Maintain information on your EMS and related documents.
• Document control — Ensure effective management of procedures and other system
documents.
• Operational control — Identify, plan and manage your operations and activities in line
with your policy, objectives and targets.
• Emergency preparedness and response — Identify potential emergencies and develop
procedures for preventing and responding to them.
• Monitoring and measurement — Monitor key activities and track performance.
Conduct periodic assessments of compliance with legal requirements.
• Nonconformance and corrective and preventive action — Identify and correct problems
and prevent their recurrence.
• Records — Maintain and manage records of EMS performance.
• EMS audit — Periodically verify that your EMS is operating as intended.
• Management review — Periodically review your EMS with an eye to continual
improvement.
©2001 NSF 15
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Environmental Policy
Communicating your environmental vision
Key Policy Commitments: *
0 Continual improvement
0 Pollution prevention
0 Compliance with
relevant laws and
reaulations
Sample environmental
policies are provided in the
Tool Kit (see Appendix A).
An environmental policy is top management's
declaration of its commitment to the environment. This
policy should serve as the foundation for your EMS
and provide a unifying vision of environmental concern
by the entire organization. Given its importance, your
policy should be more than just flowery prose.
Since it serves as the framework for setting
environmental objectives and targets, the policy should
be brought to life in your plans and deeds. Everyone
in the organization should understand the policy and
what is expected of them in order to achieve the
organization's objectives and targets.
Your policy should reflect three key commitments (see
box), including a commitment to continual
improvement. While this does not mean that you must
improve in all areas at once, the policy should drive your
organization's efforts to continually improve
environmental management (and the improved
performance that results from these efforts).
Continual Improvement:
"Process of enhancing the
environmental management
system to achieve
improvements in overall
environmental performance
in line with the organization's
environmental policy."
ISO U001
Hints:
• Your organization probably has some type of
environmental policy now, even if it's not written
down. For example, your organization probably is
committed to complying with the law and avoiding
major environmental problems, at a minimum.
Document existing commitments and goals as a
starting point.
• The policy should relate to your products and
services, as well as supporting activities. Consider
the results of your preliminary review (see Section
3) and your analysis of the environmental aspects
of your products, services and activities before
finalizing the policy. These two steps can provide
insight as to how your organization interacts with the
environment and how well it is meeting its
challenges. For example, information obtained
during the preliminary review might help you define
specific policy commitments.
• Keep your policy simple and understandable. Ask
yourself: What are we trying to achieve? How can we
best communicate this to the rest of the organization?
One test to use: Could our employees describe the
intent of our policy in twenty words or less?
©2001 NSF
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Environmental
Policy
^
c
o
M
P
L
1
A
N
C
1 E 1
1
M
P
R
O
V
E
M
E
N
T
i j
P
R
E
V
E
N
T
1
O
( N ,
Figure 4:
Three Pillars of an
Environmental Policy
Environmental Aspects
Objectives & Targets
Training & Awareness
Communication
Management Review
The environmental policy should be explicit enough
to be audited. If you choose to use phrases such as
"We are committed to excellence and leadership in
protecting the environment", consider how you would
demonstrate that such a commitment is being met.
The environmental policy can be a stand-alone
document or it can be integrated with your health &
safety, quality, or other organizational policies.
Consider who should be involved in developing the
policy and the best process for writing it. Input from a
range of people within your organization should
increase commitment and ownership.
Make sure that your employees understand the
policy. Options for communicating your policy
internally include posting it around work sites (e.g., in
lunchrooms), using paycheck stuffers, incorporating
the policy into training classes and materials, and
referring to the policy at staff or all-hands meetings.
Test awareness and understanding from time to time
by asking employees what the policy means to them
and how it affects their work.
The policy also should be communicated externally.
Some options for external communications include
placing the policy on business cards, in newspaper
advertisements and in annual reports, among other
options. You might choose to communicate the policy
proactively or in response to external requests (or
both). This decision should be factored into your
overall strategy for external communication (see later
discussion under "Communications").
Consider how you would demonstrate that you are
living by the commitments laid out in the policy. This
is a good test of whether or not the policy is a "living
document".
For EPA's Performance Track program, an organization's policy must
include:
compliance with legal requirements and voluntary commitments;
pollution prevention (see Figure 5);
continuous improvement in environmental performance, including
areas not subject to regulation, and
sharing information on environmental performance and their operation
of the EMS with the community.
For more information see Appendix B.
©2001 NSF
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Commitments to Compliance with Legal Requirements and Pollution Prevention
Compliance with legal requirements is a critical consideration in EMS development and
implementation. EMS implementation requires an organization, among other things, to:
• develop and communicate an environmental policy that includes a commitment to compliance;
• develop and implement a procedure to identify, analyze and have access to environmental
laws and regulations;
• set objectives and targets in line with its environmental policy, which includes a commitment to
compliance;
• establish management programs to achieve its objectives;
• train employees and communicate relevant EMS requirements to them;
• establish and implement operational control procedures;
• establish and implement a procedure for periodically evaluating compliance; and
• establish and implement a procedure to carry out corrective and preventive actions.
While the requirements noted above relate directly to an organization's management of legal
requirements, each of the seventeen EMS elements described in this Guide can contribute to
enhanced compliance (including communication, documentation and document control, records
management, EMS audits, and management review). An EMS that includes the elements described
in this Guide will help your organization improve or maintain its compliance performance and facilitate
the establishment of objectives and targets that go "beyond compliance."
Figure 5
Prevention of Pollution Hierarchy
Source Reduction
In-Process Recycling
Other Recycling
Treatment &
Recovery
EMS design and implementation also
should take into account the Pollution
Prevention (P2) hierarchy. In
evaluating P2 opportunities,
organizations should start at the top of
the pyramid (i.e., source reduction)
and work their way down as needed to
define the most appropriate methods
for preventing pollution. Examples
and best practices of P2 in operation
are provided throughout this Guide.
©2001 NSF
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Capture the Learning: Environmental Policy Worksheet
Do we have an existing policy?
If yes, how was the policy developed?
When was the policy last reviewed?
Does the policy reflect the three key
commitments (commitments to
compliance, prevention of pollution and
continual improvement?)
What other commitments does or
should our policy contain?
How does our policy take into account
the environmental attributes of our
products, activities and services?
How would we demonstrate
conformance to our policy?
How is the policy communicated to
our employees? Do our employees
understand the critical elements of our
policy? How do we know?
What feedback have we received on
the policy (from employees, contractors
or other interested parties)?
What happens when we receive
feedback on the policy?
How do we make our policy available
to external parties? Is this process
effective?
Our next step on environmental
policy is to ...
©2001 NSF
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Identifying Environmental Aspects
How an organization interfaces with the environment
/Environmental Aspect:
"Element of an
organization's
activities, products, or
services that can
interact with the
environment."
ISO 14001
Environmental Impact :'
"Any change to the
environment, whether
adverse or beneficial,
wholly or partially
resulting from an
organization's activities,
products, or services."
efme
environmental
aspects
Decide if under
your control and
influence
dentify relate
environmental
impacts
ecide if th
impacts are
significant
To plan for and control its environmental impacts, an
organization must know what these impacts are. But
knowing what the impacts are is only part of the challenge
— you also should know where these impacts come
from. Stated another way, how does your organization
(i.e., your products, services and activities) interact with the
environment?
If your organization has undertaken pollution prevention
projects, you are probably familiar with this concept — that
is, you must know how and where a waste is generated in
order to minimize or eliminate it. And like pollution
prevention, the identification and management of
environmental aspects can (1) have positive impacts on the
bottom line and (2) provide significant environmental
improvements.
So, an EMS should include a procedure to identify and
assess environmental aspects that the organization:
• can control, and
• over which it can have an influence.
Your organization is not expected to manage issues
outside its sphere of influence or control. For example,
while your organization probably has control over how
much electricity it buys from a supplier, it likely does not
control or influence the way in which that electricity is
generated. Similarly, if your organization manufactures a
product that is subsequently incorporated into another
product (for example, a bumper that becomes part of an
automobile), your organization does not control the
environmental aspects of that "finished" product (the
automobile). Thus, your focus should be on the
environmental aspects of your products or services.
The relationship between aspects and impacts is often one
of cause and effect. The term "aspects" (see definition
above) is neutral, so keep in mind that your environmental
aspects can be either positive (such as making a product
out of recycled materials) or negative (such as discharging
toxic materials to a stream). Aspects may result from past
activities, such as spills.
Once you have identified the environmental aspects of your
products, activities, and services, you should determine
which aspects could have significant impacts on the
environment. Aspects that have one or more significant
impact should be considered significant environmental
aspects. These significant aspects should be considered
when you establish environmental objectives, define
operational controls and consider other actions, as
discussed later.
©2001 NSF
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A multi-step process can be used to make this evaluation.
Keep the resulting information up-to-date, so that potential
aspects of new products, services, and activities are
factored into your objectives and controls.
' US Postal Service Assesses \
Its Environmental Aspects
The US Postal Service examined
environmental aspects related to the
vehicles it operates, the chemicals it
uses to maintain equipment, the solid
wastes it generates, and the products
(stamps) that it sells.
"Products" are tangible
results of a process that
transforms inputs into
outputs (for example, cars
or computers). "Services"
also result from processes,
but are intangible in that you
cannot "hold" them (such as
dry cleaning or equipment
maintenance at a customer
site). "Activities" may relate
directly or indirectly to the
provision of products or
services to customers (such
as purchasing or product
design).
V
Milan Screw Products set up
an internal task group to
identify environmental
aspects. As part of this
process, external
stakeholders were identified
and interviewed to
understand their
environmental concerns.
These stakeholder concerns
were added to the list of
environmental aspects.
Hints:
• In identifying aspects and impacts, look beyond
activities covered by laws and regulations. But
because many of your aspects/impacts may be
addressed by legal requirements, your compliance
program might yield some valuable information. Permits,
audit reports, and monitoring records can be useful
inputs. Beyond regulated aspects, consider land,
energy, and natural resource use, for example.
• Once you have identified environmental aspects and
related significant impacts, use this information in setting
your objectives and targets. This does not mean that
you need to address all of your impacts at once.
There may be good reasons (such as cost, availability of
technology or scientific uncertainty) for addressing some
impacts now while deferring action on others. Keep in
mind that managing environmental aspects can have
positive impacts on the organization.
• Remember to look at services as well as products.
While the need to examine on-site operations might be
obvious, you also should consider the potential impacts
of what you might do "off-site" (such as servicing
equipment at customer sites). Similarly, the
environmental aspects of the products, vendors, and
contractors you use may be less obvious, but should still
be considered.
• Identifying significant environmental aspects is one of
the most critical steps in EMS implementation. It can be
one of the most challenging - as well as one of the
most rewarding. Decisions you make in this step can
affect many other system elements (such as, setting
objectives and targets, establishing operational controls
and defining monitoring needs). Careful planning of this
activity will pay dividends in later steps.
Getting Started
• To understand your environmental aspects, it helps to
understand the processes by which you generate
products and services. Flow charting your major
processes can help you understand the process inputs
and outputs as well as how materials are used. A sample
flow chart is provided in the Tool Kit (see Appendix C).
You might also want to consider the views of interested
parties (e.g., neighbors, civic groups, regulators, etc.) in
this process. Some organizations have found external
parties to be a good resource in identifying environmental
aspects.
©2001 NSF
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In evaluating your
environmental
aspects and impacts,
consider both normal
and abnormal (such
as start-up and
shutdown) operating
conditions.
Use visual tools. As a
starting point, some
organizations prepare
maps of their site and
building(s), along with
surrounding land uses.
The implementation
team uses these maps
to "audit" the site and
identify potential
environmental aspects.
Objectives & Targets
Training & Awareness
Communications
Operational Controls
Monitoring & Measurement
You can use many sources of information to help you
identify and assess your environmental aspects. For
starters, look at your permits, the regulations that apply
to your operations, EPCRA reports, Material Safety
Data Sheets and monitoring records. Trade
associations, regulatory agencies, customers and
suppliers also might provide useful information to
support the assessment
Your team should define the criteria that will be used to
determine significance. Such criteria often include the
types of impact; the magnitude, frequency and duration
of the impact; regulatory status, and other factors.
Consider the questions on the following page for
identifying and characterizing aspects and impacts.
Various approaches exist for evaluating environmental
aspects and impacts. Select one that can be readily
adapted for your use and that makes sense for your
organization. Examples of approaches for evaluating
environmental aspects and impacts can be found in the
Tool Kit (see Appendix A).
Once you've found a process that works for your
organization, describe the process in the form of a
written procedure. A sample procedure for performing
the assessment is provided in the Tool Kit.
You can start out with a simple process for identifying
aspects and impacts, then refine the process in the
future as needed. You also can identify and consider
more obvious environmental impacts or "low hanging
fruit" first, then enhance the assessment process to
consider more complex environmental impacts later. As
with any element of the EMS, there is virtue in
considering how your process for identifying aspects
and impacts might be improved over time. Ask yourself:
Is there additional information we should consider in this
process? Do we have the right people involved? Are
we using the results in a meaningful way?
Use the worksheet at the end of this section to capture
some of your ideas. Using this worksheet will give you
a "jump start" on implementing this EMS element.
©2001 NSF
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Identifying Aspects and Impacts: Some Questions to Consider:
Identifying Aspects
Which operations and activities interface with
the environment in a way that could result (or
has resulted) in environmental impacts?
What materials, energy sources and other
resources do we use in our work?
Do we have emissions to the air, water or
land?
Do we generate wastes, scrap or off-spec
materials? If so, does the treatment of
disposal of these materials have potential
environmental impacts?
Which characteristics or attributes of our
products or services could result in impact the
environment (through their intended use, end-
of-life management, etc.)?
Does our land or infrastructure (e.g.,
buildings) interact with the environment?
Which activities (for example, chemical
storage) might lead to accidental releases?
Evaluating Impacts
Are the impacts actual or potential?
Are the impacts beneficial or damaging to the
environment?
What is the magnitude or degree of these
impacts?
What is the freguency or likelihood of these
impacts?
What is the duration and geographic area of
these impacts?
Which parts of the environment might be
affected (e.g., air, water, land, flora, fauna)?
Is the impact regulated in some manner?
Have our interested parties expressed
concerns about these impacts?
The Link Between Aspects and Impacts (some examples from a real company)
Aspects
Emissions of volatile organic
compounds
Discharges to stream
Spills and leaks
Electricity use
Use of recycled paper
Potential Impacts
Increase in ground level ozone
Degradation of aquatic habitat and drinking
water supply
Soil and groundwater contamination
Air pollution, global warming
Conservation of natural resources
Air Emissions
• Solid and Hazardous Wastes
• Contamination of Land
Some Potential Environmental Aspect Categories:
• Water Discharges
• Energy Use
• Local Issues
(e.g. noise, odor, dust, traffic, etc.)
Raw Material and Resource Use
(water, energy, etc.)
Hazardous Material Storage and Handling
©2001 NSF
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Capture the Learning: Environmental Aspects Worksheet
Do we have an existing process for
identifying aspects and/or impacts?
If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
Should any outside parties be
involved?
When is the best time for us to
implement this process? Can it be
linked to an existing organizational
process (such as our budget, annual
planning or auditing cycles?)
What are some obvious
environmental aspects of our:
^ Operations and activities?
^ Products?
^ Services?
What sources of information can we
use to identify environmental aspects?
What sources of information can be
used to determine the environmental
impacts of these aspects?
What significance criteria might make
sense for our organization?
How will we keep this information up-
to-date?
Our next step on environmental
aspects is to ...
©2001 NSF
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United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2261A)
EPA315-B-97-001
March 1997
Implementation Guide
For The Code of
Environmental Management
Principles for Federal Agencies
(CEMP)
-------
CHAPTER 1: INTRODUCTION
What is the Code of Environmental Management Principles (CEMP)?
The Code of Environmental Management Principles for Federal Agencies (CEMP), developed by the
Environmental Protection Agency (EPA) in response Executive Order 12856, is a collection of five broad
principles and underlying performance objectives that provide a basis for Federal agencies to move toward
responsible environmental management. Adherence to the five principles will help ensure environmental
performance that is proactive, flexible, cost-
effective, integrated, and sustainable. ^^^^^^^^^^^^^^^^^^^^^^^^^™
CEMP focuses federal agencies on the necessity of
state-of-the-art environmental management for
reaching the highest levels of environmental
performance. State-of-the-art should be defined as
those environmental management programs or
systems that ensure environmental performance be
considered as world-class or best-in-class by peers
and stakeholders. EPA has patterned the CEMP on
the common critical elements of a comprehensive
management system tailored to the environmental
activities of an organization (an Environmental
Management System).
Executive Order 12856, "Federal Compliance with
Right-to-Know Laws and Pollution Prevention
Requirements," which was signed on August 3,
1993, requires EPA to "establish a 'Federal
Government Environmental Challenge Program',"
one component of which is to "challenge Federal
agencies...to agree to a code of environmental
principles to be developed by EPA, in cooperation
with other agencies, that emphasizes pollution
prevention, sustainable development and state-of-
the-art environmental management programs..."
EPA has been working to develop the CEMP
through the Interagency Pollution Prevention Task
Force, which was created by the Executive Order,
early in calendar year 1995. Sixteen Federal
agencies participated in the development of the
CEMP.
THE PRINCIPLES
1. MANAGEMENT COMMITMENT:
The agency makes a written top-management
commitment to improved environmental
performance by establishing policies which
emphasize pollution prevention and the need to
ensure compliance with environmental requirements.
2. COMPLIANCE ASSURANCE AND
POLLUTION PREVENTION:
The agency implements proactive programs that
aggressively identify and address potential
compliance problem areas and utilize pollution
prevention approaches to correct deficiencies and
improve environmental performance.
3. ENABLING SYSTEMS:
The agency develops and implements the necessary
measures to enable personnel to perform their
functions consistent with regulatory requirements,
agency environmental policies, and its overall
4. PERFORMANCE AND ACCOUNTABILITY:
The agency develops measures to address employee
environmental performance, and ensure full
accountability of environmental functions.
5. MEASUREMENT AND IMPROVEMENT:
The agency develops and implements a program to
assess progress toward meeting its environmental
goals and uses the results to improve environmental
performance.
The CEMP is not a regulation, it is a voluntary
component of a program established to encourage federal agencies to enhance their environmental
performance through the creative use of management tools. As such, the goal is to move agencies "beyond
Code of Environmental Management Principles
Implementation Guide
-------
compliance" and the traditional short-term focus on regulatory requirements to a broader, more inclusive view
of the interrelated nature of their environmental activities.
Unfortunately, federal agencies often lack the resources to develop a complete environmental management
program, especially when their primary missions are not directly related to environmental protection or
management. They are often forced to take a "finger in the dike" approach that focuses on compliance,
addressing situations as they occur, instead of planning their activities to prevent such situations. They may
even be successful, until they run out of fingers. Thus, short-term success is no indicator of the long-term
stability of the system and may even lead to complacency. Agencies that are able to better understand their
"dike" (how it was built, why it was built the way it was, and how the demands on it are changing over time)
will be in a better position to identify weak points and predict the next "high tide," managing their resources
for prevention, not just response. Of course, regulatory compliance is still required, but the CEMP, properly
implemented, will provide agencies with a tool to improve overall performance while maintaining compliance
as a performance baseline.
What is an Environmental Management System (EMS)?
The International Organization for Standardization (ISO) defines environmental management systems as
"that part of the overall management system which includes organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for developing, implementing, achieving,
reviewing and maintaining the environmental policy." In other words, an EMS focuses on environmental
management practices, rather than the activities themselves, such as air monitoring or drum handling. The
EMS provides the structure by which the specific activities can be carried out efficiently and in a manner
consistent with key organizational goals, but does not specify levels of performance (e.g., the EMS will
ensure that proper procedures are in place and that operator training exists but won't specify methods or
frequency of sampling). The EMS allows an organization the flexibility to adapt the system to its needs and
priorities, rather than forcing a "one size fits all" mentality.
The EMS approach has its genesis in the same movement that created the "quality management" systems
traditionally applied to manufacturing, such as Total Quality Management (TQM). The Global
Environmental Management Initiative (GEMI) patterned its Total Quality Environmental Management
(TQEM) philosophy on TQM, employing many of the same diagnostic tools for environmental applications.
The more general EMS approach
incorporates the "plan-do-check-act"
cycle and the emphasis on continuous
improvement found in TQM and other
quality management schemes. [See
Figure 1] A number of organizations
and countries (e.g., ISO, Britain,
Canada) have developed standards to
Environmental Processes in a
Management System
encourage implementation of the EMS
approach.
Is the CEMP an EMS Standard?
Organization and Resources
Figure 1
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The CEMP is a set of principles - not a standard - that will help an organization improve its environmental
performance and level of environmental protection. In developing the CEMP, EPA examined a number of
EMS standards to identify common elements and areas that needed to be addressed. The CEMP reflects its
EMS origins in its structure and format; however, it is not a standard. A technical standard for a product
describes characteristics related to its performance, such as size, strength, durability, and materials of
construction. Similarly, a technical management standard describes the characteristics desirable for a
management approach to a particular subject area, such as quality or the environment. Just as conforming to
a technical product standard allows a manufacturer to advertise that its product meets agreed-upon
specifications for performance, an organization conforming to a technical management specification standard
(such as ISO 14001) can claim that its management practices are aligned with consensus "best practices." In
addition to the possibility of improving performance through improved management, one of the primary
motivations for adopting such standards is the potential for commercial advantage resulting from independent
certification of conformance to the standard (and potential for
disadvantage from failure to conform).
BASIC EMS ELEMENTS
Environmental Policy
Planning
Implementation and Operation
Checking and Corrective Action
Management Review
Although these terms refer specifically
to the ISO 14001 EMS Standard, they
are common elements of other EMS
Standards and reflected in the CEMP.
Rather than focus on strict evaluations of conformance, EPA
would like to emphasize the aspects of improved management
(leading to improved performance) and continuous improvement.
In addition to a statement of expectation for each broad principle,
the CEMP stresses the important indicators supporting each
principle (the "Performance Objectives"), so that agencies can
understand their intrinsic and systemic value and better judge
agency progress. This Guide expands upon that informative
discussion. The CEMP also differs from most EMS standards in
its emphasis on regulatory compliance and the fact that it is
targeted toward Federal agencies (essentially removing the appeal
of commercial advantage). For these reasons, EPA believes that
it would be inappropriate for it to "endorse" a particular EMS
standard at
this time, although EPA has participated strongly in
the ISO process and exchanges information with other
countries that have developed such standards.
On September 3, 1996, Steve Herman, the EPA
Assistant Administrator for Enforcement and
Compliance Assurance, signed a letter transmitting the
CEMP to the Federal agency executives who had
signed the Charter for the Interagency Pollution
Prevention Task Force in September 1995, requesting
written commitment to the Principles contained in the
CEMP. In this letter, EPA also asked each agency to
provide a written statement declaring their support for
the CEMP principles at the agency level along with a
description of their plans for implementation of the
CEMP at the facility level. The CEMP was published
in a Federal Register notice on October 16, 1996 (61
FR 54063). The information in this document is
provided as a guide to assist agencies in formulating
CEMP BACKGROUND SOURCES
1. ISO 14001 EMS Standard (draft)
2. NSF-110 EMS Standard (draft)
3. CMA Responsible Care Program
4. CSA-2750 EMS Standard (draft)
5. DOE Environmental Management
Assessment Protocols
6. U.S. Sentencing Commission
Guidelines
7. Canadian Code of Environmental
Stewardship
8. EPA Environmental Leadership
Program (proposed)
9. GEMI TQEM matenals
10. Wever, "Utilizing a Self Assessment
Matrix for Implementing TQEM"
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their responses to EPA and their approaches to implementation of the CEMP.
Although this document presents specific actions that could be taken in implementing the principles, they are
offered only as suggested steps that have proven useful to other organizations in implementing similar
programs. Agencies are encouraged to consider other steps that might be more appropriate for their
circumstances, or to adopt an EMS standard as the vehicle for implementing the CEMP. An agency that
implements an EMS (such as ISO 14001) will have addressed the major elements of the CEMP, so long as its
system includes an explicit compliance assurance component.
The term "agency" is used throughout the CEMP to represent the participation of individual federal
government bodies. Many Cabinet-level "agencies" have multiple levels of organization and contain
independently operating bodies (known variously as bureaus, departments, administrations, services, major
commands, etc.) with distinct mission and function responsibilities. Therefore, while it is expected that a
"parent agency" would subscribe to the CEMP, each parent agency will have to determine the most
appropriate level(s) of explicit CEMP implementation for its situation. Regardless of the level of
implementation chosen for the organization, it is important that the parent agency or department demonstrate
a commitment to these principles.
Before an agency can fully implement the CEMP, it should conduct an initial review or "gap analysis" to
evaluate its current program and specific needs. Although the gap analysis is very important, it can be
counter-productive for an agency to focus narrowly on what it is not doing. It is also important to understand
what it is already doing, and evaluate ways to improve and build on existing programs and activities. Some
agencies may find that they are already performing many of the suggested activities. This is good; there is no
need to rebuild a program from scratch. In fact, EPA believes that many agencies do have programs that
address the principles of the CEMP, but those programs may not be seen as connected parts of a system and
may be operated in isolation or by multiple contractors. Looking outside the environmental arena can provide
inspiration. Agencies may be tempted to say "Yes, we do that, but it's not environmental, it's part of our
quality (or some other) system." If it already helps manage important agency activities, it can probably help
environmental management as well. The full impact of the CEMP/EMS approach will be realized in tying
these programs and activities together to improve efficiency, which is also likely to improve performance and
cost-effectiveness.
PLUGGING THE GAPS
A gap analysis is designed to answer the following
questions:
• How well are the organization and its
environmental programs performing?
• What standards of environmental performance
does the organization hope to achieve?
• What are the gaps between objectives and
performance?
• What existing programs and activities can serve
as the best foundation for improved
environmental performance?
Building on existing programs becomes even more
important when agencies are faced with diminishing
resources and being asked to "do more with less."
Through careful analysis, agencies will probably
find ways to address the principles at little or no
cost. For example, developing a policy statement
on environmental protection does not require large
investments in personnel or equipment, yet it can
carry agency-wide visibility and impact.
Ultimately, agencies that are able to invest in the
implementation of the principles are likely to realize
a high return on that investment through an
improved "risk profile" at their facilities, resulting
in a lowering of costs associated with regulatory
compliance, health and safety, incident response,
and cleanup of contaminated sites. Non-monetary
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benefits, such as improved public opinion and employee satisfaction, can also be achieved.
How Does the CEMP Tie Into Other EPA Programs?
EPA has several programs that are designed to encourage creative approaches to environmental protection.
Most notable among these are Project XL and the Environmental Leadership Program (ELP), both of which
encourage Federal agency participation (McClellan AFB in Sacramento and Puget Sound Naval Shipyard in
Bremerton, Washington participated in the pilot phase of the ELP). The ELP has established the full-scale
implementation of an EMS as one of its criteria for participation, and evaluated the CEMP and ISO 14001 as
background material in developing this criterion. Project XL also has the use of innovative regulatory
management programs as a required element. One major difference between the two programs is that the
ELP seeks to identify more efficient operations within the existing regulatory structure, while Project XL will
allow some relief from regulatory requirements //the ultimate performance exceeds that achievable with full
compliance.
In addition, EPA's National Enforcement Investigation Center (NEIC) has begun to require EMS elements in
consent decrees with several private companies. This approach is intended to ensure that companies with
WHY DOES THE CEMP EMPHASIZE COMPLIANCE?
A basic EMS describes the managerial framework within which
environmental activities are carried out, rather than the activities
themselves The philosophy behind the EMS approach is that the way in
which a site is managed (rather than a strict focus on outcomes) does
make a difference. Most existing environmental regulations do not
address this management implementation aspect.
While EPA agrees with this approach, it does not wish to lose sight of
the fact that compliance with regulations is of paramount importance, as
well as a primary mission of the Agency. Implementation of regulatory
requirements has driven most of the improved environmental
performance over the past quarter-century, and the regulatory structure
continues to ensure the basic level of protection for workers, the public,
and the environment. A properly implemented EMS can provide more
consistent levels of compliance and higher levels of environmental
performance, depending upon the objectives and targets selected.
Organizations should not take the view that a few regulatory lapses are
of secondary importance to implementing the EMS. Indeed, low or
inconsistent levels of compliance can be indicative that the EMS is not
working. EPA approves of EMS implementation as a means to identify
weaknesses in an organization's approach to compliance and to examine
its internal compliance assurance process. The EMS should not become
such a weakness itself.
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prior instances of non-compliance address the root causes of those situations. [See Related Boxes]
What You Will Find in This Document
MANUAL ELEMENTS REQUIRED FOR A
COMPLIANCE-FOCUSED ENVIRONMENTAL MANAGEMENT SYSTEM
IN A SETTLEMENT AGREEMENT
1. Management Policies and Procedures
a. Organization's Environmental Policy - Must clearly communicate management commitment to
environmental performance, including compliance with applicable federal, state, and local
environmental statutes and regulations, including permits (i.e., "environmental requirements").
b. Site-specific Environmental Policies and Standards
• Body of general policies, rules, and procedures for environmental principles and practices.
• Includes process for developing, approving, and communicating standard operating practices for
activities having potentially adverse environmental or regulatory compliance impacts.
• Clearly identifies organizational responsibilities for maintaining regulatory compliance, including
required reporting to regulatory agencies.
• Includes ongoing means of communicating environmental issues and information to all
organization personnel, on-site service providers, and contractors, and receiving and addressing
their concerns.
• Describes and establishes processes to ensure sustained interaction with regulatory agencies, and
within the organization (e.g., between the various divisions, contractors, and the Environmental
Control Department) regarding environmental issues and regulatory compliance.
2. Organization, Personnel, and Oversight of EMS
a. Describes, organizationally, how the EMS is implemented and maintained.
b. Includes organization charts that identify units and individuals having environmental performance and
regulatory compliance responsibilities.
c. Identifies duties, responsibilities, and authorities of key environmental program personnel in
implementing and sustaining the EMS (e.g., could include position descriptions and performance
standards for all environmental department personnel, and excerpts from others having specific
environmental program and regulatory compliance responsibilities).
3. Accountability and Responsibility
a. Specifies accountability and responsibilities of organization's management, on-site service providers,
and contractors for environmental protection practices, compliance, required reporting to regulatory
agencies, and corrective actions implemented in their area(s) of responsibility. Also specifies
potential consequences of departure from specified operating procedures, including responsibilities
(personal and organizational) for civil/administrative penalties imposed as a result of noncompliance.
Chapter 2 summarizes federal agency responses to the CEMP, as received by EPA. Each of Chapters 3-7 is
dedicated to one of the principles. The principle and its supporting Performance Objectives, which provide
more information on the tools and mechanisms by which the principle is fulfilled, are described in detail and
several possible actions that can help an agency meet the principle are provided. These actions are provided
as guidelines to assist agencies in understanding the scope of the principles, and as a suggested basis for
planning. Agencies are not required to pursue all of these actions, nor are they limited to them. It should be
understood that, as is implicit in the EMS approach, implementation of the principles will not be as effective
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if they are administered as though they are discrete pieces of a larger program. In fact, they are so tightly
interconnected that the entire program can succeed only if the elements are fully integrated. Although clear
managerial responsibility must be assigned for each component, the system as a whole depends ultimately on
communication among the various program elements.
Similarly, activities described in the context of one of the principles are often carried throughout other
principles. For example, benchmarking should be done not only in connection with daily operations, but also
in terms of information management, pollution prevention initiatives, safety and emergency response,
training, and so on. Audits will target not only what is commonly thought of as "environmental compliance,"
but also safety, emergency response, and documentation procedures. Training and information management
are integral to the successful operation of any organization.
EMS MANUAL ELEMENTS (cont.)
4. Environmental Requirements
a. Describes process for identifying, understanding, and communicating environmental requirements to
affected organization personnel, on-site service providers, and contractors, and ensuring that facility
activities conform to those requirements. Specifies procedures for identifying and obtaining
information about changes and proposed changes in environmental requirements, and incorporating
those changes into the EMS.
5. Assessment, Prevention, and Control
a. Identifies an ongoing process for assessing operations, for the purposes of preventing and controlling
releases, environmental protection, and maintaining compliance with statutory and regulatory
requirements. This shall include monitoring and measurements, as appropriate, to ensure sustained
compliance. It shall also include identifying operations and waste streams where equipment
malfunctions and deterioration, operator errors, and discharges or emissions may be causing, or may
lead to, releases of hazardous waste or hazardous constituents to the environment, or a threat to
human health or the environment. Finally, process shall include performing root cause analysis of
identified problems to prevent recurring issues.
b. Describes process for identifying activities that could cause adverse environmental impacts and/or
regulatory noncompliance, and where documented standard operating practices need to be developed
[see element l.(b)].
c. Describes a system for conducting and documenting routine, objective, self-inspections by department
supervision and trained staff, especially at locations identified by the process described in (a) above.
d. Describes process for ensuring input of environmental concerns and requirements in planning; design;
and operation of ongoing; new; and/or changing buildings, processes, maintenance activities, and
products.
6. Environmental Incident and Noncompliance Investigations
a. Describes standard procedures and requirements for incident and noncompliance reporting,
investigation; and development, tracking, and effectiveness verification of corrective and preventive
actions. The procedures shall specify testing of such procedures, where practicable.
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The last chapter in this document contains a "Self-Assessment Matrix," which describes stages that an
organization may go through in implementing the principles. The Matrix shows five levels for each of the
Performance Objectives that support the principles, with a brief description of a typical organization's
accomplishments at that level. Agencies can use the Matrix and the accompanying text in the chapter to
relate the suggested activities to the levels in the Matrix. There is no real significance to the numbering of the
levels. No scoring system is implied, although agencies are free to track their own progress in such a manner,
EMS MANUAL ELEMENTS (cont.)
7. Environmental Training, Awareness, and Competence
a. Identifies specific education and training required for organization personnel, as well as process for
documenting training provided.
b. Describes program to ensure that organization employees are aware of its environmental policies and
procedures, environmental requirements, and their roles and responsibilities within the environmental
management system.
c. Describes program for ensuring that personnel responsible for meeting and sustaining compliance
with environmental requirements are competent on the basis of appropriate education, training, and/or
experience.
8. Planning for Environmental Matters
a. Describes how environmental planning will be integrated into other plans developed by
organizational subunits, as appropriate (e.g., capital improvements, training, maintenance).
b. Requires establishing written goals, objectives, and action plans by at least each operating
organizational subunit, as appropriate, including those for contractor operations conducted at the
facility, and how specified actions will be tracked and progress reported.
9. Maintenance of Records and Documentation
a. Identifies the types of records developed in support of the EMS (including audits and reviews), who
maintains them and where, and protocols for responding to inquiries and requests for release of
information. Specifies the data management systems for any internal waste tracking, environmental
data, and hazardous waste determinations.
10. Pollution Prevention Program
a. Describes an internal program for reducing, recycling, reusing, and minimizing waste and emissions,
including procedures to encourage material substitutions. Also includes mechanisms for identifying
candidate materials to be addressed by program and tracking progress.
11. Continuing Program Evaluation
a. Describes program for periodic, at least annually, evaluation of the EMS, including incorporating the
results of the assessment into program improvements, revisions to the manual, and communicating
findings and action plans to affected employees, on-site service providers, and contractors.
12. Public Involvement/Community Outreach
a. Describes a program for ongoing community education and involvement in the environmental aspects
of the organization's operations and general environmental awareness.
if they so desire. Agencies are also free to modify the Matrix to make it a more useful tool.
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EPA does not expect the CEMP to be implemented "overnight." EPA fully realizes that some agencies,
bureaus, and departments may require years to implement the CEMP. Awareness and understanding are the
necessary first steps. The CEMP, like EMS standards, includes ongoing review and a commitment to
continuous improvement, so in one sense implementation will never be "finished."
EPA's Federal Facilities Enforcement Office (FFEO) is available to provide technical assistance to agencies
implementing the CEMP. EPA is also collaborating with the Department of Energy in preparing a primer on
environmental management systems for federal facilities. The Primer addresses specific aspects of
environmental management (e.g., pollution prevention and audits) and discusses ways to integrate and make
them more powerful within the context of an EMS. FFEO is leading EPA's efforts on the Primer.
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CHAPTER 2: FEDERAL AGENCY RESPONSES TO THE CEMP
CEMP Development Process
On August 3, 1993, President Clinton signed Executive Order No. 12856, which pledges the federal
government to implement pollution prevention measures, and publicly report and reduce the generation of
toxic and hazardous chemicals and associated emissions. Section 4-405 of Executive Order 12856 requires
the Administrator of the Environmental Protection Agency (EPA), in cooperation with federal agencies, to
establish a Federal Government Environmental Challenge Program. As required under the Executive Order,
the Challenge program consists of three components to challenge Federal agencies to: 1) agree to a code of
environmental principles emphasizing pollution prevention, sustainable development, and "state of the art"
environmental management programs; 2) submit applications to EPA for individual Federal facilities for
recognition as "Model Installations"; and 3) encourage individual Federal employees to demonstrate
outstanding leadership in pollution prevention.
On September 12, 1995, senior agency representatives signed the Charter for the Interagency Pollution
Prevention Task Force committing the federal government to achieve, among other items, environmental
excellence through various activities including: a) active agency and facility participation in the Federal
Government Environmental Challenge Program and, b) participation in the establishment of an agency Code
of Environmental Management Principles (CEMP). In June 1995, a subcommittee of federal agency
representatives was formed by the Task Force to work directly with EPA in the development of the CEMP.
Through this process, several drafts of the CEMP were forwarded to federal agencies by the subcommittee
for formal review and comment. The version of the CEMP published on October 16, 1996 (61 FR 54062)
represents the final version as approved by the subcommittee and incorporates comments from members of
the Interagency Task Force.
As stated in Chapter 1, EPA formally transmitted the CEMP to the federal agency executives who had signed
the Charter for the Interagency Executive Order 12856 Pollution Prevention Task Force on September 3,
1996. In the letter accompanying the CEMP, Steve Herman, the EPA Assistant Administrator for
Enforcement and Compliance Assurance, requested written agency commitment to the Principles contained in
the CEMP and a description of their plans for implementation of the CEMP at the facility level. EPA sought
endorsement of the CEMP Principles on an agency wide basis, with flexibility as to how the Principles
themselves are implemented at the facility level. For example, agencies could choose to directly implement
the CEMP Principles at the facility level or use another alternative environmental management system (e.g.,
ISO 14001). This flexible approach was in recognition that of the fact that individual federal facilities and
installations may already have environmental management systems in place or are considering adoption of the
ISO 14001 Environmental Management Standard.
Responses From Federal Agencies and Departments
As previously stated, in September 1996 EPA requested federal agencies to provide a brief written statement
declaring the agency's support for the CEMP Principles along with a concise explanation of how the agency
plans to implement the CEMP at the facility level. Responses endorsing the CEMP on an agency-wide basis
have been received from the 16 agencies that participated in the development of the CEMP. A table
summarizing the responses is provided in Table 1 and the copies of each agency response are contained in
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Appendix 1.
Three of the responses were detailed in nature. The Postal Service, the Department of Defense (DoD), and
the Central Intelligence Agency (CIA) addressed each of the five CEMP principles as well as the objectives of
the principles, explained how the agency planned to implement the CEMP at the facility level, and described
how the agency's management system will meet the CEMP.
The Postal Service's head of Environmental Management Policy endorsed the CEMP, described its
management commitment, submitted a copy of its Policy for Environmental Protection which contains seven
guiding principles, and stated that the Postal Service is also evaluating the use of ISO 14001 as a
management system to meet the CEMP. The Postal Service described its compliance program, discussed its
Environmental Strategic Plan, and submitted its most recent annual status report which tracks the status of
the current 105 Tactical Action Plans intended to achieve compliance and leadership. The Postal Service
described its enabling systems and submitted a copy of its environmental target areas (e.g., leadership targets
and compliance targets) which provide focus and direction for developing and implementing plans at the
Area, District and Plant Levels. The Postal Service described its performance and accountability program,
and how it continuously monitors progress and updates the Tactical Actions in its Environmental Strategic
Plan to reflect many new ideas, target areas and programs. Since Postal Service employees are accountable
for environmental objectives through the Policy for Environmental Protection, the Policy was integrated into
personnel evaluations to reinforce personnel accountability. The Postal Service also discussed its
measurement and improvement strategy, and its utilization of a concept known as Environment Information
Services and Support to gather, analyze and distribute data and information through the Postal Routed
Network to Postal environmental professionals and personnel throughout the U.S.
DoD endorsed the CEMP at the Deputy Under Secretary level, and provided the only response which
addressed all of the objectives of each CEMP principle. DoD discussed its management commitment, and
described its Environmental Security Directive which establishes environmental protection goals and
develops supporting strategies that fully complement accomplishment of DoD's overall mission. DoD also
stated that the Department is using ISO 14001 in the development of its current strategic plan and is
evaluating adoption of ISO 14001 as a management system for the entire Environmental Security program.
DoD described its compliance program in the context of its Environmental Security Directive and supporting
instructions, and described its requirement that each installation conduct a self audit for environmental
performance at least annually. DoD described its enabling systems in the context of the Environmental
Security Directive which establishes environmental goals, supporting strategies, budget priorities and
measures of merit that support overall organizational objectives. DoD also described its extensive
environmental training program which includes military recruit training, technical training programs,
professional (officers) military education programs as well as insertion of environmental requirements into
the education programs for non environmental professionals whose actions could affect the environment.
DoD described its performance and accountability program, and how the Environmental Security Directive
establishes goals for compliance, pollution prevention and conservation, and requires periodic reporting on
progress towards meeting these goals through measures of merit. DoD personnel regulations require that
major job components be identified in job descriptions, and that evaluation criteria for the major job
components be prepared in employee's annual work plans. Thus, persons with environmental responsibilities
are evaluated on the performance of those responsibilities and outstanding performance by installations and
individuals is recognized via an awards program. DoD also discussed its measurement and improvement
strategy which includes implementation of an automated data management system, annual assessments of
progress towards achieving the goals established by the Environmental Security Directive, and
evaluation/benchmarking of environmental operations in other government and non-government organization
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which have environmental challenges similar to DoD and CEMP. DoD efforts to improve environmental
performance include establishment of hazardous materials pharmacies at installations and ships to provide
central control of purchasing, storing, distributing and disposing of hazardous materials, resulting in reduced
purchases, disposals, and potential for violations.
The CIA's chief of Environmental Safety endorsed the CEMP, and described its management commitment in
the context of establishment of a formal environmental program in FY 1992. The program is designed to
gain compliance with environmental regulations and initiate remediation of potential cleanup sites, and has
been funded on a multiyear basis and administered by the newly formed Environmental Safety Group. Most
recently, the CIA issued an Agency Notice establishing the CIA Pollution Prevention Policy and Goals, with a
target of fifty percent reduction in the use of toxic chemicals and a reduction in the use of extremely
hazardous substances. The CIA described its proactive compliance program which consists of annual
compliance inspections of all CIA sites, compliance audits at some sites, and provision of expert consultation
and assistance to field sites to address specific issues. The CIA described its enabling personnel including
funding for environmental compliance training programs for specialists, site managers, and selected
component personnel, and regular briefings of senior managers on the progress of the program. The CIA has
also established a Lotus Notes electronic bulletin board database which provides means to disseminate
regulatory updates to field personnel, functions as an inquiry and response forum, and serves as a general
discussion media for promoting environmental issues and policies. The CIA described its performance and
accountability program, and how all major field sites are staffed with a full-time Environmental Safety
Officer (ESO) who implements the environmental program under the direction of the site manager. The
ESOs are responsible for coordinating the environmental program among the various tenants located at a site,
and have their performance evaluations prepared annually by the site manager and forwarded to the CIA
environmental program office for review, accountability. The CIA also discussed its measurement and
improvement strategy, including annual programmatic appraisals to assess the status of the CIA
environmental program, periodic review by the CIA IG to ensure programmatic compliance with
environmental laws and regulations, and prioritization of centrally funded resources to address deficiencies
identified by the reviews/appraisals. Annual environmental conferences are also held to assemble field ESOs
to review the status of site and CIA programs, and to discuss goals and opportunities for improvement in
areas such as pollution prevention, affirmative procurement, waste reduction and recycling.
The remaining 13 responses endorsed the CEMP but were more general in nature. EPA is in the process of
following up with these agencies to obtain more specific information about how the agencies plan to
implement the CEMP at the facility level. The responses from the Department of Commerce (DoC),
Department of Energy (DoE), Department of Interior (Dol), Department of Justice (DoJ), Environmental
Protection Agency (EPA), and the National Aeronautics and Space Administration (NASA) addressed the
five CEMP principles in varying levels of detail. DoE, DoJ, EPA and NASA explained in general terms how
they plan to implement the CEMP at the facility level. DoC, DoE, DoJ and EPA generally described how
their agency's management system will meet the CEMP. DoE, Dol, and NASA indicated that their agency's
are evaluating the use of ISO 14001 as a management system to meet the CEMP. The responses from the
Department of Health and Human Services (HHS), Department of Transportation (DoTransp.), Department
of Treasury (DoTreas.), General Services Administration (GSA), Department of Agriculture (USDA),
Veterans Administration (VA), and Tennessee Valley Authority (TVA) addressed the CEMP principles and
how the agency's plan to implement the CEMP at the facility level in a very general way. GSA and TVA
briefly describe how their agency's management system will meet the CEMP, and DoTreas., indicated that it
is evaluating the use of ISO 14001 as a management system to meet the CEMP.
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Table 1.
Summary of Agency Responses to Code of Environmental Management Principles (CEMP)
Agency
CIA
USDA
DoC
DoD
DoE
Dol
DoJ
DoTransp.
DoTreas.
EPA
GSA
HHS
NASA
Postal Service
TVA
VA
CEMP
endorsed on
agency wide
basis
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explains plan
to implement
CEMP at
facility level
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Partial
Describes how
alternative
system (e.g.,
ISO 14001)
will meet
CEMP
Yes
Partial
Yes and
evaluating ISO
14001
Partial and
evaluating ISO
14001
Evaluating ISO
14001
Partial
Evaluating ISO
14001
Partial
Partial
Evaluating ISO
14001
Yes and
evaluating ISO
14001
Partial
Addresses each
CEMP
principle
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Addresses the
objectives of
each CEMP
principle
Partial
Yes
Partial
Partial
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CHAPTER 3: MANAGEMENT COMMITMENT (PRINCIPLE 1)
The agency makes a written top-management commitment to improved environmental performance
by establishing policies which emphasize pollution prevention and the need to ensure compliance with
environmental requirements.
The first Principle stresses the importance of upper-level management in setting the agenda for the agency's
commitment to environmental management. Although it is possible for organizations to adopt ideas that
originate at the grassroots level, it is more likely that such ideas will be dismissed unless they have a
champion with sufficient organizational clout to advance them. Agencies can advance the cause of
environmental management by setting policies, ensuring that the environmental system is integrated
throughout the agency, and setting a clear example of long-term commitment by articulating support for
strategies that enhance environmental stewardship and sustainable development.
PERFORMANCE OBJECTIVES:
1.1 OBTAIN MANAGEMENT SUPPORT
The agency ensures support for the environmental program by management at all levels and assigns
responsibility for carrying out the activities of the program.
Management sets the priorities, assigns key personnel, and allocates funding for agency activities. In
order to obtain management approval and support, the environmental management program must be seen
as vital to the functioning of the organization and as a positive benefit, whether it be in financial terms or
in measures such as regulatory compliance status, production efficiency, or worker protection. If
management commitment is seen as lacking, environmental concerns will not receive the priority they
deserve.
Organizations that consistently demonstrate management support for pollution prevention and
environmental compliance generally perform at the highest levels and will be looked upon as leaders that
can mentor other organizations wishing to upgrade their environmental performance.
1.1.1 Policy Development
The agency establishes an environmental
policy followed by an environmental
program that complements its overall
mission strategy.
Management must take the lead in
developing organizational goals and
instilling the attitude that all organization
members are responsible for implementing
and improving environmental management
measures, as well as develop criteria for
POSTAL SERVICE POLICY
"The United States Postal Service is committed to
provide employees and customers with a safe and
healthy environment. Environmental protection is
the responsible thing to do and makes for sound
business practices.
"In performing its mission...the Postal Service will
conduct its activities in a manner protecting human
health and the environment."
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POSTAL SERVICE GUIDING PRINCIPLES
evaluating how well overall goals are met. The environmental policy will be the statement that
establishes commitments, goals, priorities, and
attitudes. It incorporates the organization's
mission (purpose), vision (what it plans to
become), and core values (principles by which
it operates). The environmental policy also
addresses the requirements and concerns of
stakeholders and how the environmental policy
relates to other organizational policies.
1. Meet or exceed all applicable environmental laws
and regulations in a cost-effective manner;
2. Incorporate environmental considerations into
business planning processes;
3. Foster the sustainable use of natural resources by
promoting pollution prevention, reducing waste,
recycling, and reusing materials;
4. Expect every employee to take ownership and
responsibility for environmental objectives;
5. Work with customers to address mutual
environmental concerns;
6. Measure progress in protecting the environment;
7. Encourage suppliers, vendors, and contractors to
comply with similar environmental protection
policies.
Appropriate steps to address policy
development could include:
• Develop overall organizational goals and
priorities;
• Prepare Mission and Vision statements
emphasizing commitment;
• Communicate with stakeholders, including
regulatory agencies, to identify needs,
expectations, and concerns.
1.1.2 System Integration
The agency integrates the environmental management system throughout its operations, including
its funding and staffing requirements, and reaches out to other organizations.
Management should institutionalize the environmental program within organizational units at all
levels and should take steps to measure the organization's performance by incorporating specific
environmental performance criteria into managerial and employee performance evaluations, as
appropriate.
Organizations that fulfill this principle demonstrate consistent high-level management commitment,
integrate an environmental viewpoint into planning and decision-making activities, and ensure the
availability of adequate personnel and fiscal resources to meet organizational goals. This involves
incorporating environmental performance into decision-making processes along with factors such as
cost, efficiency, and productivity.
As one of the main determiners of success or failure, management cannot afford to be isolated from
the strategies and activities associated with an organization-wide environmental management
program. All levels of management must be responsive to the demands of the program, encourage
initiatives to expand its effectiveness, and take proactive steps to integrate program requirements
into existing activities across the organization. Management should also seek a leadership role for
the organization in order to serve as an example to others wishing to emulate its success.
Management backing should also provide organization members with an indication of the
organization's place in the global community.
Appropriate steps to address program integration could include:
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Identify environmental liabilities and risks;
Conduct an organizational review to assist in integrating the environmental program into all
planning, organizing, implementing, and measuring processes;
Assign specific management responsibilities;
Encourage teaming across all divisions within the agency to improve communication and
teamwork;
Include environmental performance in the evaluation criteria for organizational units, managers,
and employees, as appropriate;
Coordinate and review budget requirements to ensure adequate funding to achieve goals;
Review responsibilities to ensure adequate staffing at all levels;
Assume a leadership role through involvement in outreach activities, such as professional
organizations, conferences, information exchanges, local government, and public information
sessions;
Provide awareness training to all levels of management and workers.
1.2 ENVIRONMENTAL STEWARDSHIP AND SUSTAINABLE DEVELOPMENT
The agency strives to facilitate a culture of environmental stewardship and sustainable development.
"Environmental Stewardship" refers to the concept
that society should recognize the impacts of its
activities on environmental conditions and should
adopt practices that eliminate or reduce negative
environmental impacts. Every aspect of an
organization's operations, including strategic
planning, procurement, waste reduction, waste
management, water and energy usage, responses to
existing environmental problems, and land
management, must be conducted in such a way as to
limit or eliminate adverse impacts on the
environment. Government agencies, whose
national policies affect a range of complex
management decisions and who have been entrusted
with the management of the nation's immense and
diverse land and water resources, must provide an
example to others in implementing programs of
environmental stewardship.
The President's Council on Sustainable
Development was established on June 29, 1993 by
Executive Order 12852. The Council has adopted
the definition of sustainable development as:
"meeting the needs of the present without
compromising the ability of future generations to
meet their own needs." The concept was developed
to provide insight into the way in which natural
resources and systems (rainforests, atmospheric
ECOSYSTEM MANAGEMENT
Ecosystem management is a relatively recent
development that has been adopted by several
federal agencies. The concept of ecosystem
management is a response to the recognition of
the inadequacy of the traditional resource-
management approach, which focused on
individual resources, such as water, land, forest,
wildlife, etc. It has become clear in recent years
that these seemingly separate components are in
fact highly integrated and interdependent.
Therefore, the federal government is attempting
to tailor its management responsibilities to entire
ecosystems, many of which range across
legislatively or administratively defined
boundaries. It is believed that encouraging
consideration of these complex and dynamic
systems as complete entities will provide a more
coherent framework for resource management
and protection, reduce administrative conflict,
and better address declining ecological
conditions. This approach will require
significant interaction and coordination with
state and local authorities and private
landowners.
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conditions, natural water bodies, etc.) are integrated within the environment and how that relationship is
affected by the use of the resources. It is hoped that this understanding will lead to a new level of
consciousness in which use of natural resources is limited to identifiable needs, original conditions are
restored as much as possible, and waste material is managed in an environmentally friendly manner, all of
which will help to ensure the presence of these resources for future generations.
Responsible environmental management should be
INTERAGENCY COOPERATION IN
ECOSYSTEM MANAGEMENT
Fourteen federal agencies came together to sign the
"Memorandum of Understanding to Foster the
Ecosystem Approach" (December 15, 1995). The
MOU defines the Ecosystem Approach as:
• a method for sustaining or restoring ecological
systems;
• goal driven;
• based on a vision of desired future conditions
that integrates ecological, economic, and
social factors;
• applied within a geographic framework
defined primarily by ecological boundaries.
The goal of the Ecosystem Approach is to "restore
and sustain the health, productivity, and biological
diversity of ecosystems and the overall quality of
life through a natural resource management
approach that is fully integrated with social and
economic goals."
The signatories agree that federal agencies should
• provide leadership in and cooperate with
activities that foster the Ecosystem Approach;
• ensure that they utilize their authorities in a
way that facilitates the Ecosystem Approach;
• administer their programs in a manner that is
sensitive to the needs and rights of
landowners, local communities, and the
public;
• work with landowners, local communities, and
the public to achieve common goals.
one of the main pillars of the organization, not an
ancillary concern or afterthought. Personnel at all
levels need to be "on the same page" when it comes to
environmental issues. In order to generate this level
of awareness, personnel need to have some
understanding of environmental issues, how they are
related to the organization's activities, and the
consequences of inaction or negative action. Where
possible, the organization should attempt to
supplement information on specific regulatory,
compliance, or management concerns by providing a
global perspective in its presentation of
environmental issues that encompasses concepts such
as sustainable development and ecosystem
management. The organization's culture should be
extended to draw in the surrounding community, in
which personnel are likely to reside.
An organization's commitment to environmental
stewardship and sustainable development would be
demonstrated through implementation of several of
the CEMP Principles and their respective
Performance Objectives. For example, by
implementing pollution prevention and resource
conservation measures (see Principle 2, Performance
Objective 2.3), the agency can reduce its negative
environmental impacts resulting directly from its
facilities. In addition, by including the concepts of
environmental protection and sustainability in its
policies, the agency can help develop the culture of
environmental stewardship and sustainable
development not only within the agency but also to
those parts of society that are affected by the agency's
activities.
Appropriate steps in creating a culture of
environmental stewardship could include:
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Provide orientation describing the program
for all personnel;
Encourage each organizational group to
prepare an environmental action plan,
which will describe the steps the group will
implement to improve environmental
performance and what will be achieved;
Introduce the concepts of life-cycle analysis
and design for the environment to the
agency, focusing on groups with
responsibilities in potentially affected areas
(e.g., procurement or engineering);
Provide outside speakers describing issues
of environmental concern and how they
relate to the agency;
Provide in-house "brown bag" speakers
from various aspects of the agency describing their responsibilities;
Create newsletters and other promotional items describing the progress of the program and how it
benefits the agency;
Encourage organizational sponsorship of outside activities with environmental content, such as
"Clean up days" or school visits;
Promote "Open House" days for the local community;
Participate in local government hearings and other activities;
Implement a program that demonstrates commitment to sustainable development and renewable
resources by planting trees or other such activity;
Incorporate evaluations of environmental implications of proposed activities into decision-making
processes.
ECOSYSTEM CASE STUDIES
The Interagency Ecosystem Management Task Force
has conducted case studies in seven areas facing
extreme environmental stress:
Anacostia River watershed;
Coastal Louisiana;
Great Lakes basin;
Pacific Northwest forests;
Prince William Sound;
South Florida; and
Southern Appalachians.
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CHAPTER 4: COMPLIANCE ASSURANCE AND POLLUTION
PREVENTION (PRINCIPLE 2)
The agency implements proactive programs that aggressively identify and address potential
compliance problem areas and utilize pollution prevention approaches to correct deficiencies and
improve environmental performance.
The second Principle addresses what might be considered the core of environmental management. Whatever
an agency's approach to environmental management, it must always meet the obligation of compliance with
regulations. The CEMP is intended to help agencies more easily meet this obligation and expand their vision
"beyond compliance." Aggressive pollution prevention strategies will also be central to maintaining
compliance, improving environmental performance, reducing risks, and cutting costs. Preparation for
emergency situations can also help avoid breakdowns in compliance and pollution control.
PERFORMANCE OBJECTIVES:
2.1 COMPLIANCE ASSURANCE
The agency institutes support
programs to ensure compliance
with environmental regulations
and encourages setting goals
beyond compliance.
Implementation of an
environmental management
program should be a clear signal
that non-compliance with
regulations and established
procedures is unacceptable and
injurious to the operation and
reputation of the organization.
Satisfaction of this performance
objective requires a clear and
distinct compliance management
system as a component of the
agency's overall environmental
management system.
All personnel, beginning with
management, must understand that
the objective of a compliance
program is not to set up obstacles
COMPLIANCE ASSURANCE...
Environmental compliance can be a sensitive subject, and not one
that many organizations eagerly address. Environmental
regulations have been characterized by some as unnecessary,
burdensome, overly costly, stifling of creativity, and ineffective.
Federal facilities, which were not a primary focus of many of the
environmental statutes but have come under their jurisdiction, may
consider these descriptions particularly appropriate.
However, EPA and other regulatory agencies weigh the societal
benefits of regulation against the societal burden of compliance,
taking into account the best available scientific information.
Admittedly, it can be difficult to assign a dollar figure to improved
air or water quality, and many issues are not easily resolved by
science, such as the effects of dioxins on living tissue.
The lack of an underlying regulatory structure can be seen in the
legacy of contamination at CERCLA sites and many Federal
facilities. Compliance with regulations must be a core value of any
organization. Federal agencies, which are endowed with the public
trust, should give no more thought to violating environmental rules
than they would to distributing sensitive information or
disregarding contracting, procurement, and other financial
requirements.
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that prevent meaningful work from being accomplished, but to guide the organization through complex
and often uncertain terrain to the successful
completion of tasks. Early incorporation of a
compliance perspective will prevent unpleasant and
costly surprises later in a project's schedule. The
environmental management program must also
encourage forward-thinking to go beyond simple
compliance, as the organization will be constantly
playing catch-up to meet stricter standards. For
example, the agency should stress the importance of
the environmental compliance performance of its
outside contractors and suppliers, perhaps by
encouraging (and eventually requiring) their
adherence to a specified set of environmental
management principles.
...AND "BEYOND COMPLIANCE"
Supporters of Environmental Management
Systems and other "quality" approaches to
environmental management often speak of the need
to go "beyond compliance." What does this mean?
Are there different levels of compliance, rather
than just "in" or "out of compliance? What can be
found "beyond compliance"?
"Beyond compliance" is recognition that much of
the activity that falls under environmental
programs is driven by regulations. Permits are
requested, forms are filled out, reports are filed, to
comply with regulation. But accepting compliance
as a core value doesn't preclude looking for ways
to make it easier, less costly, and less pervasive.
Although an EMS is a management system, not a
compliance system, the benefit of an EMS is that it
forces a look at all activities that can have an
environmental impact and provides an integrating
structure for supporting activities that are not
strictly environmental in nature, such as training
and documentation. This "holistic" approach
provides a context in which the core of compliance
can incorporate the organization mission and
vision. It encourages participation at all levels to
improve and coordinate management, rather than a
"do this because it's required" directive.
A 1993 survey of six major corporations found that
facilities spent more on compliance than on
pollution prevention, but would rather have the
ratio heavily weighted toward pollution prevention
(Source: Business Roundtable). A "beyond
compliance" approach can help to reallocate
resources to priority areas without sacrificing
compliance. "Beyond compliance" also includes
working with regulators to form mutually
beneficial partnerships, rather than approaching
them as adversaries.
An agency that fully incorporates the tenets of this
principle demonstrates maintainable regulatory
compliance and addresses occasions of non-
compliance swiftly and efficiently. It also has
established a proactive approach to compliance
through tracking and early identification of regulatory
trends and initiatives and maintains effective
communications with both regulatory authorities and
internally to coordinate responses to those initiatives.
It also requires that contractors demonstrate their
commitment to responsible environmental
management and provides guidance to meet specified
standards.
Appropriate steps to ensure compliance could
include:
• Develop an independent compliance group, with
clear assignment of responsibility and
appropriate authority;
• Review organizational activities in the context of
Federal, state, and local regulations;
• Assess compliance status to establish a baseline
(performing compliance audits can help with this
step);
• Establish a compliance management system that
is integrated with the overall environmental
management system;
Track regulatory initiatives to identify future compliance issues;
Hold information sessions to explain the purpose and function of the compliance group;
• Develop guidance for operations to maintain compliance;
• Inform and coordinate with regulatory authorities as necessary;
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• Evaluate the environmental and safety performance of outside contractors;
• Develop a program that encourages employees to report knowledge of environmental violations,
departures from procedure, or criminal conduct, and that maintains employee confidentiality;
• Take immediate action to address conditions identified as giving rise to incidents resulting in non-
compliance;
• Plan, track, schedule, and report on corrective actions;
• Develop procedures to elevate compliance issues to upper management, when necessary.
Appropriate steps to move beyond compliance could include:
• Make pollution prevention the primary approach for addressing environmental issues;
• Implement an effective system to keep environmental recordkeeping up-to-date;
• Utilize quality management tools and procedures to identify potential problems and prevent incidents
resulting in non-compliance;
• Develop regular contacts with regulatory authorities to proactively identify and prepare for future
compliance issues;
• Ensure that information on applicable regulations and permit limitations is communicated and
understood;
• Set performance goals that improve upon compliance standards;
• Introduce risk assessment considerations into compliance situations, where appropriate.
2.2 EMERGENCY PREPAREDNESS
The agency develops and implements a program to address contingency planning and emergency
response situations.
Emergency preparedness is not only required by law, it is good business. Properly maintained facilities
and trained personnel will help to limit property damage, lost-time injuries, and process down time.
Personnel should understand the use of fire extinguishers and other such equipment and know whom to
call, where to go, what to do, and (most importantly) what not to do. Simulated spill-response and other
such exercises are invaluable in limiting damage due to "upset conditions." In addressing the
environmental consequences of spills and other incidents, procedures should incorporate an
understanding of concepts such as ecosystem management that can be applied to limit damage.
The emergency response program will also be the most likely mechanism for integrating the
environmental program with the organization's operational health and safety procedures. Sound worker
safety practices will help to limit situations that could result in environmental damage as well as worker
injuries.
Commitment to this principle is demonstrated by the institution of formal emergency-response
procedures (including appropriate training) and the appropriate links between health and safety programs
(e.g., medical monitoring for federal employees performing hazardous site work).
Appropriate steps in development of an emergency preparedness program could include:
• Develop procedures to address accidents, fires, spills, meteorological, seismological, radiological
Code of Environmental Management Principles 22 Implementation Guide
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incidents, etc.;
Develop a disaster preparedness plan that details procedures to be followed at all of the agency's
facilities;
Identify hazards associated with the activities of the agency and its facilities (e.g., chemicals,
equipment, transportation);
Devise appropriate measures to address and mitigate identified hazards (risk management), and
coordinate these measures with generic procedures;
Implement a preventive maintenance program for all equipment;
Identify an Emergency Management Team (EMT), with clear managerial responsibility;
Provide appropriate training for the EMT and other personnel;
Conduct exercises on a regular basis;
Develop an in-house program that provides medical monitoring for "high-risk" employees and
emergency treatment services as appropriate;
Coordinate with local fire, law enforcement, and medical authorities;
Develop a communication plan that outlines the coordination with local fire, law enforcement, and
medical authorities;
Identify available resources during emergency situations including lines of authority (e.g., emergency
procurement authority) for responding to and mitigating emergency situations.
2.3 POLLUTION
PREVENTION AND
RESOURCE
CONSERVATION
The agency develops a
program to address pollution
prevention and resource
conservation issues.
An organization with a fully-
developed pollution
prevention program ultimately
can save time and money, and
reduce its liability. Use of
environmentally-friendly
materials is also friendly to the
organization's reputation and
reinforces the idea that the
organization is a responsible
citizen. Reducing exposure to
toxics through material
substitution or process
modifications and
improvements also benefits
employee health and can
improve morale. Although
source reduction should be the
POLLUTION PREVENTION TOOLS
As interest in pollution prevention grows, and organizations look to
move beyond the "low-hanging fruit," it becomes increasingly important
to find ways to evaluate the potential benefits of competing approaches.
Two such tools are Life Cycle Analysis (LCA) and Total Cost
Assessment (TCA).
Life Cycle Analysis generally focuses on the environmental aspects of
a specific product (although it could be applied to processes or
services) over its lifetime. LCA looks at each stage from raw material
through production, use, and disposal. Inputs to the analysis include
energy use, waste generation, emissions, and releases from each stage.
Total Cost Assessment focuses on the economics of a given situation,
including costs related to environmental variables. For example, TCA
might compare the cost of retrofitting to address increased emissions
with the cost of additional waste treatment and disposal for two
alternatives.
A number of publications give further detail on LCA and TCA. A
starting point for Federal agencies could be Federal Facility Pollution
Prevention Project Analysis: A Primer for Applying Life Cycle and
Total Cost Assessment Concepts, EPA 300-B-95-008, July 1995.
primary focus of pollution prevention, recycling and reuse programs
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should also be aggressively pursued and promoted.
In order to be fully effective, pollution prevention programs must be integrated throughout the organization's
activities. All personnel should be encouraged to identify additional opportunities for pollution prevention
initiatives. Energy conservation efforts can often
be paired effectively with pollution prevention
concerns, as can parallel programs to identify
conservation opportunities for water and other
resources. The pollution prevention/resource
conservation program can be employed as a strong
indicator of the organization's commitment to
sustainable development. Incorporation of concepts
such as life-cycle analysis and total cost assessment
can help to identify preservation or conservation
NATIONAL PERFORMANCE REVIEW
In 1993, the National Performance Review examined
the Federal role in environmental protection and
degradation. Specifically, the NPR looked at ways to
improve the Federal ability to:
• promote sustainable economic development;
• prevent environmental degradation;
• reduce costs; and
• maintain the long-term health of the nation's
ecological systems.
The NPR made four specific recommendations in
two broad areas (see related boxes).
opportunities.
An organization committed to pollution
prevention has a formal program describing
procedures, strategies, and goals. In connection
with the formal program, the most advanced
organizations have implemented policy that
encourages employees to actively identify and
pursue pollution prevention and resource
conservation measures, and instituted
procedures to incorporate such measures into
the formal program. Resource conservation
practices would address the use by the agency
of energy, water, and transportation resources,
among others. Greater efficiency in using
natural resources will also help to cut pollution
(e.g., lowered emissions from power generation
and vehicles, lessened need for wastewater
treatment) and related costs. Pollution
Code of Environmental Management Principles
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prevention policies and practices should follow the
environmental management hierarchy prescribed
NPR RECOMMENDATIONS
h
Improve Implementation of Environmental
IVjbanaiicmcnt
1.
u
t
i
2o
n
P
r
Improve Federal Decisionmaking Through
Environmental Cost Accounting - use of tools
such as Life Cycle Analysis and Total Cost
Assessment, discussed earlier, is increasing
among Federal agencies. A number of software
packages have also been developed to address
this issue.
Develop Cross-Agency Ecosystem Planning
and Management - the "MOU to Foster the
Ecosystem Approach," described under
Principle 1, demonstrates progress in this area.
ention Act of 1990 [Figure 2]: 1) source
reduction; 2) recycling; 3) treatment; and 4)
disposal.
Section 3-301(b) of Executive Order 12856 requires the head of each federal agency to make a
commitment to utilizing pollution prevention through source reduction, where practicable, as "the
primary means of achieving and maintaining compliance with all applicable federal, state and local
environmental requirements." Making this critical link between pollution prevention and compliance
assurance is the key to achieving and maintaining a "beyond compliance" state. An integrated
environmental management system can help agencies make this link.
It is equally important to understand the link between pollution prevention and resource conservation, and
the cyclical nature of this relationship. For
example, agriculture has been identified as
a principal source of non-point source
water pollution, mainly through run-off Pollution Prevention Act
that increases sedimentation in waterways Environmental Management Hierarchy
and deposits large amounts of pesticides, x~
nitrates, phosphates, and other compounds. \ ^
The soil's productive capability is
diminished and water quality degraded,
with the result that greater amounts of
pesticides and fertilizers are needed to
maintain crop yields, and water supplies
may eventually be unsuitable for irrigation
(e.g., through increased salinity). However,
more strategic approaches to irrigation that
reduce run-off can both reduce water usage
Source Reduction
Recycling/ Reuse
Treatment
^Disposal/
Figure 2
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and preserve water quality, while maintaining greater amounts of productive soil.
Similarly, new techniques are being employed to reduce the impacts of pesticide usage and livestock
management. Integrated pest management approaches that utilize both biological (breeding
pest-resistant strains, selective introduction of pest predators) and strategic planting (crop rotation,
timing of planting, removing land from production for a period) methods can decrease reliance on
chemical pesticides. Prevention of livestock waste material is not a realistic goal, but it can be
appropriately managed to lessen environmental impacts. Another approach is to encourage the growth of
natural vegetation along waterways to act as a natural filter for run-off, to act as a barrier that prevents
livestock from directly contaminating the water, and to help absorb greenhouse gases produced by
livestock and through clearing of land. Resource conservation strategies should be consistent with the
agency's approach to environmental stewardship and sustainable development (see Principle 1).
A number of initiatives over the past several years have boosted federal agency participation in pollution
prevention and resource conservation activities. Many originate from agency missions, such as EPA's
33/50, Energy Star, and Green Lights programs, the Department of Energy's Federal Relighting
Initiative, and the New Technology Demonstration Program, which is sponsored by DOE and the
Department of Defense through the Strategic Environmental Research and Development Program
(SERDP). Others arise from statute or directive, such as Executive Order 12856, which requires federal
agencies to develop facility-wide pollution prevention plans and report releases and transfers of toxic
chemicals to the Toxic Release Inventory (TRI), and Executive Order 12902, which sets targets for
reducing energy use and increasing energy efficiency in federal buildings, encourages use of renewable
energy sources, and requires Federal agencies to evaluate opportunities for water conservation and
develop plans for comprehensive energy and water audits at their facilities.
Appropriate steps in developing a pollution
prevention/resource conservation program
could include:
NPR RECOMMENDATIONS (cont.)
Improve Environmental Performance at Federal
Buildings and Facilities
3. Increase Energy and Water Efficiency - Executive
Order 12902 calls for Federal buildings to use 30%
less energy, become 20% more energy efficient,
increase use of renewable energy sources,
incorporate water conservation goals, and undertake
energy and water audits.
4. Increase Environmentally and Economically
Beneficial Landscaping - the President issued a
"Memorandum on Environmentally Beneficial
Landscaping" (April 26, 1996) directing Federal
agencies to use regionally native plants, minimize
adverse effects on native habitat, use integrated pest
management practices, and use water-efficient
landscaping practices.
Incorporate design for the environment principles into
• Implement a program to identify and
evaluate pollution prevention
opportunities that emphasizes source
reduction as the policy and practice of
first choice;
• Implement a program to identify and
evaluate energy conservation
opportunities;
• Implement a program to identify and
evaluate opportunities to conserve
other resources, such as water;
• Implement an affirmative procurement
program to address use of recycled-
content materials;
• Identify and implement opportunities
to reduce the use of toxic materials;
• Perform life-cycle analyses to assess
overall environmental impacts;
activities, as appropriate;
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Implement a system of product stewardship;
Implement a "Repair or Replace" program to track the condition of capital equipment;
Institute recycling programs for glass, plastic, aluminum, cardboard, paper, and other waste streams;
Encourage reuse of paper and other materials.
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CHAPTER 5: ENABLING SYSTEMS (PRINCIPLE 3)
The agency develops and implements the necessary measures to enable personnel to perform their
functions consistent with regulatory requirements, agency environmental policies, and its overall
mission.
The third Principle concerns the underlying or supporting functions for an environmental management
system. These functions are generic in the sense that they support any type of management system, but are
critical to the system's effectiveness and success. Functions falling under this Principle include training,
operating procedures, technical standards, goal-setting, communication, information management, and
documentation.
PERFORMANCE OBJECTIVES:
3.1 TRAINING
The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
Comprehensive training is crucial to the success of any enterprise. People need to know what they are
expected to do and how they are expected to do it. Organizations that attempt to save time or money by
limiting training often exceed those savings through non-compliance, rework, remediation of
contaminated sites, or lost-time injuries. Trained personnel are better able to understand the processes
for which they are responsible and are therefore more likely to offer suggestions to improve those
processes.
Training for those expected to oversee the environmental management program must receive equal
priority with training for those whose functions are central to the organization's primary mission.
However, training in environmental subjects should not be limited to those directly involved with the
program, but should be extended to all employees as appropriate. For example, an environmental
training program may take a three-phase approach: 1) awareness training to introduce all employees to
the environmental program; 2) mandatory training for personnel directly involved with the program (e.g.,
RCRA 262, 264, 265 and/or OSHA 40-hour training); and 3) skills training for personnel operating
equipment or for other specific tasks. Refresher training offered on a regular basis is also an important
component of any training program.
An organization will be operating at the highest level when it has an established training program that
provides instruction to all employees sufficient to perform the environmental aspects of their jobs, tracks
training status and requirements, and offers refresher training on a periodic basis.
Appropriate steps in development of a training program could include:
• Develop a "Core Curriculum" that is required of all personnel;
• Identify additional job-specific training requirements;
• Determine availability of outside training vs. desirability of "in-house" training;
• Establish an in-house training group to be responsible for tracking the program;
Code of Environmental Management Principles 27 Implementation Guide
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Train the trainers, if necessary;
Establish periodic refresher training (e.g., 8-hour vs. 40-hour OSHA training);
Develop methods to obtain feedback from employees and assess the effectiveness of the training;
Investigate alternative training methods, such as computer-based or video conference training;
Encourage continuing education for employees, such as seminars, trade shows, and college courses.
3.2 STRUCTURAL SUPPORTS
The agency develops and implements procedures, standards, systems, programs, and objectives that
enhance environmental performance and support positive achievement of organizational
environmental and mission goals.
Clear procedures, standards, systems, programs, and short- and long-term objectives must be in place for
the organization to fulfill its vision of environmental responsibility. The commitment to responsible
environmental management should be prominent within the organization's Mission and Vision
statements. The interrelationship and interdependence of environmental concerns with all other activities
needs to be spelled out in such a way as to infuse the organization with environmental consciousness. It
must also be clear how the organization's method of operation will help to support the concept of
environmental stewardship.
A streamlined set of procedures, standards,
systems, programs, and goals that describe and
support the organization's commitment to
responsible environmental management and
further the organization's mission demonstrate
conformance with this principle.
Appropriate steps in developing clear
organizational documentation could include:
• Review organizational documentation for
clarity, conciseness, conflict, and
redundancy;
• Eliminate or revise procedures, standards,
systems, programs, and goals determined
to be barriers to organizational goals;
• Encourage constructive input from all
personnel;
• Pursue integration of the environmental
program throughout the agency;
• Conduct periodic review of procedures, etc.
to ensure currency.
3.3 INFORMATION MANAGEMENT,
COMMUNICATION, DOCUMENTATION
The agency develops and implements systems that encourage efficient management of
Code of Environmental Management Principles 28 Implementation Guide
WEAVING THE WEB INTERNALLY...
Many organizations are using the World Wide Web
(WWW) to disseminate environmental and other
information to the people who carry out their
missions. Most federal agencies have a presence on
the Web, many with very sophisticated links to
information of interest. EPA, for example, uses its
Enviro$en$e pages to describe EPA programs and
policies, provide points of contact, and point to
environmental information provided by other
agencies and the private sector. EPA's Enviro$en$e
is available on the Web at www.epa.gov/envirosense.
Agencies use their Web pages to post bulletins,
notices on meetings, reports on internal task forces,
etc. Some post electronic versions of internal
directives, technical standards, and procedures (e.g.,
audit protocols). In this way, personnel across the
agency can be sure that they have the most current
version of a document, and that it is the same version
used by other agency locations.
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environmentally-related information, communication, and documentation.
Information management, communication, and documentation are necessary elements of an effective
environmental management program. The need for advanced information management capabilities has
grown significantly to keep pace with the volume of available information to be sifted, analyzed, and
integrated. The ability to swiftly and efficiently digest data and respond to rapidly changing conditions
can be key to the continued success of an organization. For example, an integrated information
management system may be used to track process requirements, procedures, measurements, compliance
standards, and compliance status. The effects of process changes can be followed and incidents resulting
in non-compliance quickly rectified. Generation of reports is also greatly simplified, reducing demand on
time, personnel, and financial resources. Many private and public organizations have taken advantage of
the explosion in networking capabilities to make information available through the Internet (particularly
the World Wide Web), organization intranets (internal networks that utilize Internet technologies), and
other commercial group software packages. Figure 3 offers a conceptual depiction of the multiple
sources of environmental information that can be maintained, coordinated, and combined through
sophisticated information management using such technologies.
Information management capabilities include not only hardware and software concerns, but also people
Federal Agency
Environmental Compliance
Management System
hT^n fc—-, .
r EPA 10 \ I \
/ . ^1EPA8 -\
^-LJ.-j I J
Figure 3
Code of Environmental Management Principles
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who are able to understand the information, draw informed conclusions, and make intelligent decisions and
recommendations. Integrating information management capabilities throughout the organization will help to
ensure that no part of the organization is left behind. A drawback to rapid technological advances, such as
those exemplified by the use of the Internet, is that they tend to create "tiers" within organizations. At the top
of the organization are the traditional decision-makers, who obtain the bulk of their information through
briefings, status reports, and assignments to staff that have specific information-gathering functions. These
people will generally continue to receive information through these specialized channels.
The next tier is often the sectional or line managers, who may be
...AND WITH STAKEHOLDERS
Agencies also find the Web helpful in communicating with
stakeholders. As an example, DOE has made available large
amounts of information related to its investigations of Human
Radiation Experimentation (HREX). Electronic public-access
information areas can save agencies the resources that would be
necessary to generate and distribute thousands of pages of text that
must be continually updated. Special care must be taken, however,
to ensure that sensitive information is properly excised before
making it available.
Agencies can also fulfill much of their public assistance
responsibilities electronically. For example, both the DOE
Pollution Prevention Information Clearinghouse (EPIC) and EPA's
Enviro$en$e pages provide the public with information on
pollution prevention, energy efficiency, and other environmental
assistance information through case studies, reports, event
calendars, notices of newly available documents, etc. Under EPA's
Enviro$en$e, the Federal Facilities Environmental Leadership
Exchange (FFLEX) provides pollution prevention strategies and
other information of interest to the public sector. Similarly,
although not environmentally-related, the Internal Revenue Service
offers downloadable tax forms, electronic technical assistance, and
electronic filing. EPA's Enviro$en$e is available on the World
Wide Web at www.epa.gov/envirosense.
responsible for reports or briefings to top
management, but are also responsible
for some level of daily operations.
These people often find that rapid
technological advances can make their
functions more difficult, at least
initially. They find that the people they
are managing are using unfamiliar
technologies in ways they don't
understand, while their "tried and true"
methods of gathering and evaluating
information are being phased out or are
suddenly seen as inadequate. Their
survival may depend on how quickly
they can adapt to the new technology.
The third tier consists of personnel
who are at the "cutting edge" of
technological advances, whether
they are responsible for
development and implementation
or simply use the technology in
their daily activities. The people at
this level will ultimately determine
how widely a technology is
adopted by demonstrating its value
in meeting the needs of the
organization. The lowest tier
generally consists of personnel
who do not have access to the
technology, such as people in
remote field offices or very old
buildings. Their ability to function
may be severely hampered.
Agencies need to be aware of this
"tiering" effect and take steps to
address it in order to maintain
smooth operations to the extent
possible.
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Effective communication allows coordination among the various parts of the organization, ensures that
activities are more clearly focused, enhances consistency, and limits duplication of effort. Complete
documentation and recordkeeping improves regulatory compliance efforts, clarifies responsibilities, and
enhances tracking of processes.
Organizations adopting this principle have developed a sophisticated information gathering and
dissemination system that supports tracking of performance through measurement and reporting. They
also have an effective internal and external communication system that is used to keep the organization
informed regarding issues of environmental concern and to maintain open and regular communication
with regulatory authorities and the public. Those organizations operating at the highest level ensure that
employees have access to necessary information and implement measures to encourage employees to
voice concerns and suggestions.
Appropriate steps in developing information management, communication, and documentation
capabilities could include:
Information Management:
• Assign managerial responsibility for information management;
• Create an in-house group to identify equipment needs, new developments, and trends in information
management;
• Review current capabilities to determine whether they are sufficient to meet expected needs;
• Streamline and integrate existing technology to ensure that all personnel have compatible
capabilities;
• Develop procedures for evaluating new information management projects;
• Assign a "shepherd" (project point of contact) for each new initiative;
• Develop procedures for collection, management, and dissemination of information obtained through
the environmental program (routine reports and audits);
• Establish a Resource Center that includes regulations, guidance documents, and other publications
relating to environmental management;
• Implement the use of electronic networks including on-line databases and libraries (see Figure 3);
• Identify key environmental records and documents to be managed and inventoried;
• Develop procedures to assure validity of environmental data;
• Develop secure procedures for handling, manipulating, and maintaining environmental data;
• Develop methods to employ environmental management system data in strategic decision making.
Communication:
• Develop a clearly delineated organizational structure indicating desired lines of communication;
• Assign each organizational group a "shepherd" within the environmental program to act as the
group's point of contact on the environmental program;
• Develop efficient in-house communication through the use of voice mail, electronic mail, and inter-
office mail;
• Provide regular status updates on organizational activities through the use of newsletters, electronic
bulletin boards, etc.;
• Provide a "shepherd" (project point of contact) for each major initiative;
• Develop a formal system to allow personnel to anonymously communicate (without fear of
retribution) environmental concerns to upper levels of management for resolution;
• Develop a communication network with other organizations (both public and private), as
appropriate;
Code of Environmental Management Principles 31 Implementation Guide
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• Develop a public outreach program that can encourage public participation, where appropriate;
• Develop channels to encourage cooperation, commitment, and solicit employee environmental
concerns;
• Develop a communications network to report environmental performance to stakeholders and that
can address compliance and emergency response situations;
• Ensure that effective working relationships exist between environmental staff of headquarters and
field units as well as between staff and line personnel whose responsibilities directly impact
environmental performance.
Documentation:
• Develop a centralized filing system;
• Develop an appropriate distribution network for documents;
• Develop procedures for completion of all reports;
• Develop quality assurance and security procedures for documentation;
• Maintain documentation on the properties of materials used by the organization, such as Material
Safety Data Sheets (MSDS).
Code of Environmental Management Principles 32 Implementation Guide
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CHAPTER 6: PERFORMANCE AND ACCOUNTABILITY (PRINCIPLE 4)
The agency develops measures to address employee environmental performance, and ensure full
accountability of environmental functions.
The fourth Principle concerns the need to lay out the organizational structure and lines of responsibility for
the environmental system. Without a clear structure showing who's in charge and who's accountable for
getting things done, the system components won't mesh as well as they should and the benefits of the system
will be reduced. Putting expectations into individual performance standards is one way to ensure that people
are aware of their responsibilities.
PERFORMANCE OBJECTIVES:
4.1 RESPONSIBILITY, AUTHORITY AND ACCOUNTABILITY
The agency ensures that personnel are assigned the necessary authority, accountability, and
responsibilities to address environmental performance, and that employee input is solicited.
At all levels, those personnel designated as responsible for completing tasks must also receive the
requisite authority to carry out those tasks, whether it be in requisitioning supplies or identifying the need
for additional personnel. Similarly, employees must be held accountable for their environmental
performance. Employee acceptance of accountability is improved when input is solicited. Encouraging
employees to identify barriers to effective performance and to offer suggestions for improvement
provides a feeling of teamwork and a sense that they control their own destiny, rather than having it
imposed from above.
Appropriate steps in addressing responsibility issues could include:
• Assign specific individuals who are senior management or above at the agency the authority to
ensure compliance with established environmental standards and procedures;
• Issue clear statements defining
responsibilities for personnel and groups
within the agency that are directly involved
in the environmental program (these
statements should tie into the agency's
mission and vision statements that stress
the importance of environmentally
REWARDS.
"Four of 17 [Civilian Federal Agencies] reported the
use of award programs to recognize employee
environmental achievements. Expanding the use of
responsible operation); these Pro^ams 1S needed= and maY be a Relatively
T , ., . , easy way for CFAs to begin to improve their
Issue, as necessary, statements denning the i „
' -" ° performance...
authority for carrying out assigned
EPA EMS Benchmark Report, December 1994
responsibilities;
• Prepare a process for addressing
conflicting spheres of authority;
• Develop a policy detailing the agency's
approach to accountability;
• Develop a program to solicit employee input and address concerns.
Code of Environmental Management Principles 3 3 Implementation Guide
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4.2 PERFORMANCE STANDARDS
The agency ensures that employee performance standards, efficiency ratings, or other accountability
measures, are clearly defined to include environmental issues as appropriate, and that exceptional
performance is recognized and rewarded.
A major barrier to efficient operation is a lack of specificity regarding employee expectations. Therefore,
performance criteria relating to environmental practices should be specifically incorporated into employee
evaluations, and employees should be rewarded for satisfying or exceeding those criteria. Performance
incentives give people the feeling that their contributions are important. Employees who feel valued pay
more attention to their work and perform at a higher level. As noted above, providing employees with
avenues for constructive input, and the expectation that they will provide such input, spreads an attitude
of ownership. In addition, the agency's written policies defining standards and procedures to be followed
by its employees must be consistently enforced through appropriate disciplinary mechanisms.
Organizations that identify specific environmental
performance measures (where appropriate),
evaluate employee performance against those
measures, take appropriate disciplinary action when
agency procedures are violated, and publicly
recognize and reward employees for excellent
environmental performance through a formal
program demonstrate conformance with this
principle.
....AND PITFALLS...
...to be avoided in developing performance incentives
or awards. Some management experts believe that
incentives simply cannot work in any meaningful
way. How can this be true? Some objections are that
incentives:
do not motivate beyond short-term compliance;
don't differ from punitive management;
can harm relationships;
don't address root causes;
impede management's ability to manage;
discourage creativity;
undermine intrinsic motivation.
Agencies developing incentive or awards programs
need to give careful thought to the outcomes they
want to encourage, not just behaviors.
Appropriate steps in developing performance
evaluations could include:
• Identify appropriate organizational
performance goals;
• Develop standards upon which employee
evaluations will be based;
• Publicize and solicit input from the agency;
• Develop procedures for evaluating
performance;
• Prepare a program to reward or recognize
honorees;
• Prepare disciplinary mechanisms to be utilized
when agency policy and procedures are not
followed.
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CHAPTER 7: MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5)
The agency develops and implements a program to assess progress toward meeting its environmental
goals and uses the results to improve environmental performance.
The fifth Principle addresses the "feedback" aspect that is critical to any system and the importance of
collecting internal and external information on system performance. When the agency can judge how well the
system is working, it can also identify steps to improve the system. The measurement-improvement cycle is
continuous for the life of the system.
PERFORMANCE OBJECTIVES:
5.1 EVALUATE PERFORMANCE
The agency develops a program to assess environmental performance and analyze information
resulting from those evaluations to identify areas in which performance is or is likely to become
substandard.
Measurement of performance is necessary to understand how well the organization is meeting its stated
goals. Businesses often measure their performance by such indicators as net profit, sales volume, or
production. Two approaches to performance measurement are discussed below.
5.1.1 Gather and Analyze Data
The agency institutes a systematic program to periodically obtain information on environmental
operations and evaluate environmental performance against legal requirements and stated
objectives, and develops procedures to process the resulting information.
Managers should be expected to provide much of the necessary information on performance through
routine activity reports that include
environmental issues. Performance of
organizations and individuals in
, , , MEASURING PERFORMANCE
comparison to accepted standards can also
be accomplished through periodic
environmental audits or other assessment
activities. Assessments can be performed
by members of the organization or by an
outside group brought in for the specific
purpose of evaluating the organization. In
order to be fully effective, measurable
performance indicators (activities to be
performed or results to be achieved)
against which the organization's
performance can be compared must be identified. However, assessments that concentrate solely on
numerical "accounting" issues will tell only part of the story and may miss vital information.
Code of Environmental Management Principles 3 5 Implementation Guide
When choosing performance indicators, think about
whether they:
Address key organizational goals;
Can show performance trends;
Provide directly usable information;
Are controlled by the group being measured;
Show the way to improve performance.
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Assessments will need to evaluate the effectiveness of the overall management system, even if this
aspect is not directly quantifiable. Various audit protocols have been developed by Federal agencies
and private concerns. EPA is in the process of
revising its Generic Protocols for Conducting
Environmental Audits at Federal Facilities, which
incorporates information from other agencies.
COMPLIANCE VS. CONFORMANCE
Agencies should be aware that their EMS, as well as
their performance, needs to be evaluated. While they
will continue to audit their environmental activities
for compliance with regulations, the EMS must be
audited for conformance with the system as
designed. That is, how well does the system match
with the agency's plan (e.g., in terms of training,
documentation, policy development)? Whether an
EMS Standard like ISO 14001, or an EMS of the
agency's own design, this is a crucial step in
maintaining and improving a fully-functional EMS.
The operation of a fully-functioning system of
regular evaluation of environmental performance
along with standard procedures to analyze and use
information gathered during evaluations signal an
organization's conformance with this principle.
Appropriate steps to address performance
measurement could include:
• Develop, collect data, and report on measurable
performance indicators for each organizational
activity;
Develop an internal environmental audit program;
Identify an independent outside (third party) environmental audit group;
Define the scope, type, and frequency of assessments;
Develop quality assurance objectives, including appropriate levels of review;
Develop procedures for management and use of information obtained from routine reports and
during audits, including analysis of results, reporting, trend analysis, and root-cause analysis;
Develop procedures to convey system measurements into the review and improvement process.
GOVERNMENT PERFORMANCE AND RESULTS ACT OF 1993 (GPRA)
GPRA requires Federal agencies to provide information on their goals and how well they achieve them.
Agencies will have to:
• develop strategic plans prior to fiscal year 1998 that describe goals and objectives, plans to meet them,
necessary resources, and key external factors;
• develop annual plans describing fiscal year performance goals beginning in F Y 1999;
• prepare annual reports comparing performance to goals beginning in March 2000.
Agencies can use the GPRA planning framework to include environmental goals and identify how they will be
met and the resources that will be needed.
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5.1.2 Institute Benchmarking
The agency institutes a formal program to compare its environmental operations with other
organizations and management standards, where appropriate.
"Benchmarking" is a term often used for the comparison of one organization
FEDERAL AGENCY BENCHMARK REPORT
EPA surveyed 17 civilian federal agencies (CFA), 4 defense related agencies (DRA), and
3 corporations (Chevron, Xerox, and 3M) to evaluate their approaches to six Benchmark
Elements:
Organizational Structure;
Management Commitment;
Implementation;
Information Collection/Management/Follow-up;
Internal and External Communication;
Personnel.
EPA selected a total of 31 Key Indicators as representative of the six Elements. While 50
percent or more of the DRAs responded positively to all Key Indicators, CF As did so for
fewer than half the Indicators. Rarely did more than 10 of the 17 CFAs respond positively
to an Indicator. Corporate responses fell much closer to the DRAs.
Source: "Environmental Management System Benchmark Report: A Review of Federal
Agencies and Selected Private Corporations," EPA-300R-94-009, December 1994
against others,
particularly those
that are
considered to be
operating at the
highest level. The
purpose of
Benchmarking is
twofold: first, the
organization is
able to see how it
compares with
those whose
performance it
wishes to
emulate; second,
it allows the
organization to
benefit from the
experience of the
peak-performers,
whether it be in
process or
managerial
practices. The
higher-performing
organization also benefits by passing along innovations or efficiencies, which will enhance its
reputation among its peers. It may also obtain more tangible benefits, such as innovative
technological approaches. Benchmarking
also serves an overall good by fostering a
spirit of cooperation, rather than
competition and secrecy. The Malcolm
Baldrige National Quality Award, for
example, requires its winners to share their
strategies with other organizations seeking
improvements.
Benchmarking offers an attractive path to
improvement of performance through
adoption of practices already proven to be
effective. However, reliance on such
comparisons can be more harmful than
beneficial in certain circumstances. Too
BENCHMARKING TIPS
1. Tie efforts to strategic objectives;
2. Keep teams of manageable size (e.g., 6 to 8);
3. Involve those most affected;
4. Avoid focusing on overly broad issues;
5. Set realistic timetables;
6. Pick benchmarking partners carefully;
7. Follow benchmarking protocol;
8. Focus the data collection process;
9. Focus on process, not on numbers;
10. Identify future recipient of information.
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often, organizations fail to focus their efforts appropriately and attempt to adopt practices that
simply do not fit. The practice of Benchmarking, rather than the improper approach to it, is then
blamed for the poor result and abandoned.
During 1993-94, EPA surveyed 21 federal agencies and three private corporations to determine
whether they display behavior indicative of "best in class" environmental management systems. The
elements used for the "best in class" benchmark were taken from a number of sources, including
management standards. Benchmarking against established management standards, such as the ISO
14000 series or the Responsible Care program developed by the Chemical Manufacturers
Association (CMA), may be useful for those agencies with more mature environmental programs,
particularly if the agencies' activities are such that their counterparts in the private sector would be
difficult to find. However, it should be understood that the greater benefit is likely to result from
direct comparison to an organization that is a recognized environmental leader in its field.
Appropriate steps to address benchmarking could include:
• Evaluate the agency to identify areas in which benchmarking would be most beneficial;
• Begin to develop and implement a program of comparison with other organizations;
• Develop methods to apply results of inter-organizational comparisons and further encourage
comparison with other organizations and networking through professional organizations and
conferences;
• Explore the possibility of mentoring another public or private organization.
5.2 CONTINUOUS IMPROVEMENT
The agency implements an approach toward continuous environmental improvement that includes
preventive and corrective actions as well as searching out new opportunities for programmatic
improvements.
Continuous improvement is approached through the use of performance measurement to determine which
organizational aspects need to have more attention or resources focused upon them. Environmental
excellence should be viewed as a journey, not a destination. There are always constructive steps to be
taken. The development of organizational goals should incorporate the principle of continuous
improvement. The institution of a program to solicit and respond to employee suggestions is an
important step in generating confidence in the
organization's commitment to improvement.
Public and private organizations that are
generally considered by their peers and the
public to be performing at the highest levels
can provide incentive and insight toward
implementation of improvement measures.
Continuous improvement may be demonstrated
through the implementation of lessons learned
and employee involvement programs that
provide the opportunity to learn from past
performance and incorporate constructive
MANAGEMENT REVIEW
An EMS needs periodic management review. This is
different from the conformance review discussed
earlier. Management needs to evaluate the EMS to
see if it needs to be changed to meet an organization's
evolving goals and needs. Of course, the
implemented EMS will have to be evaluated to see if
it conforms to the revised EMS plan.
Code of Environmental Management Principles 3 8 Implementation Guide
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suggestions. In addition, the agency actively seeks comparison with and guidance from other
organizations considered to be performing at the highest level.
Appropriate steps to address continuous improvement could include:
• Develop procedures to address the root cause of current deficiencies and prevent future deficiencies;
• Develop a "lessons learned" program to educate personnel;
• Develop and implement a program of comparison with other organizations;
• Develop a program to apply results of inter-organizational comparisons and continue to conduct
comparisons and/or develop partnerships with other organizations, particularly those considered
"best in class";
Encourage suggestions for improvement from all personnel;
Conduct periodic review of operating procedures;
Review contemporary management philosophies to identify viable approaches;
Provide a mechanism to incorporate identified improvements into the next planning cycle;
Periodically review and report on improvements.
Code of Environmental Management Principles 3 9 Implementation Guide
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CHAPTER 8: CEMP SELF-ASSESSMENT MATRIX
The CEMP Self-Assessment Matrix is a tool to help agencies evaluate their progress in implementing the
CEMP and map their next steps. The Matrix was designed to support the gradual development of an
environmental program that addresses the CEMP principles, and to relate the suggested actions presented in
previous chapters to the stage in the program's evolution when they are most likely to be implemented. The
Matrix is also intended to support several points that are key to development of an environmental
management system, including:
• there is a logical (but not strictly structured) progression of activities in the growth of a program;
• advancing to the next "higher" level builds upon the foundation of more fundamental activities at
"lower" levels;
• integration of the system by addressing all of the principles, and maintaining that integration
throughout the life of the program, is fundamental to its success;
• even after reaching the "highest" level, continual review and improvement is necessary to maintain
that level of performance.
It will be helpful for agencies to keep in mind that they may already have a foundation of system elements
that they can build upon. The results of an agency's "gap analysis" can provide a starting point for
implementation of each principle.
How the CEMP Matrix Works
The CEMP Matrix is laid out to show the implementation of each principle over five levels of development.
There is nothing magical about the use of five levels. The number was chosen as an intermediate point that
communicates the idea of progression without overwhelming the user. Although the levels are numbered, no
"scoring" scheme is implied, although agencies are free to develop such schemes if they believe it would
benefit them. Similar approaches that are intended to be used as scoresheets have been developed by other
organizations. For example, the Council of Great Lakes Industries (CGLI) has developed a matrix that is
intended to take an organization through a "roadmap" to implement Total Quality Environmental
Management. The CGLI uses the seven Malcolm Baldrige Award criteria as its categories, and ranks
progress over ten levels. Like the Baldrige award itself, the seven categories are weighted to indicate their
relative importance.
The Global Environmental Management Initiative has developed two slightly different approaches to
environmental self-assessment. The first is based on the 16 principles found in the International Chamber of
Commerce (ICC) Business Charter for Sustainable Development, which are generally applicable to any
organization. Using this "Environmental Self-Assessment Program," organizations rate their performance for
71 "elements" identified under the 16 principles on a scale of 1 through 4 (or Not Applicable), with 1
corresponding to simple regulatory compliance. Each element is also assigned a weighting factor, which
represents its relative importance to the scoring organization (unlike the CGLI matrix, where a category has
the same weighting factor for all organizations).
The second GEMI approach is for organizations that want to measure their environmental management
systems against the ISO 14001 EMS Standard. The "ISO 14001 Self-Assessment Checklist" covers a total
Code of Environmental Management Principles 40 Implementation Guide
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of 31 questions under the five ISO 14001 EMS elements. By scoring each on a scale of 0 through 2, an
organization should get an idea of how well its EMS conforms to the ISO 14001 Standard. The Checklist can
be used to support a gap analysis or as an indicator that ISO conformance has been achieved. This exercise
would be especially useful for companies that may need to explore ISO certification (and third-party
certification) for business purposes, although Federal agencies may also benefit from comparison to a
recognized international standard. Agencies will also recognize that the questions in the Checklist can help
them implement the CEMP.
For the CEMP Matrix, each block gives an
indication of what the agency will have
accomplished under a particular principle. Some of
these are more concrete than others, while some
may be more subjective and will require
interpretation by the agency. For example, Level 3
under "Policy Development" states that the agency
"develops draft policy and circulates it for review
and comment," which is fairly straightforward.
Level 3 under "Environmental Stewardship" states
that the agency "identifies alternatives to high-
impact activities," which will require agencies to
determine which activities are high-impact and
develop criteria for identifying alternatives.
The Matrix is offered as a potentially useful tool
that gives one approach to implementing the
principles, not as a rigid "one size fits all"
blueprint. Agencies are encouraged to adapt the
Matrix to their own programs, and to make
whatever modifications they deem advisable.
Moving From Level to Level
ICC CHARTER
The International Chamber of Commerce Business
Charter for Sustainable Development Principles for
Environmental Management cover the following
areas:
1.
2
3.
4.
5.
6.
7.
8.
9.
10.
Corporate Priority
Integrated Management
Process of Improvement
Employee Education
Prior Assessment
Products and Services
Customer Advice
Facilities and Operations
Research
Precautionary Approach
11. Contractors and Suppliers
12. Emergency Preparedness
13. Transfer of Technology
14. Contributing to the Common Effort
15. Openness to Concerns
16. Compliance and Reporting
Previous chapters have presented possible steps
that could be taken by agencies implementing the CEMP. To enhance the usefulness of the Matrix, the steps
are repeated here and related to the Matrix level (1 through 5) at which they might be most appropriate.
Again, the Matrix is intended as a guide and therefore these actions are not required, nor is it required that
they be performed in any particular order. Not all levels have actions associated with them, and many of the
activities will be continuing or ongoing through the upper levels of the Matrix, rather than performed on a one
time only basis. However, it will be beneficial to agencies to understand that some activities are very basic
"first steps," while others are likely to require significant groundwork in terms of program maturity if they are
to be properly conducted. Some agencies may find that they are in a position to conduct some "higher-level"
activities before other "lower-level" activities can be completed, or can skip some activities altogether. The
important thing is for agencies to understand their own circumstances and tailor their activities appropriately.
Similarly, it is not necessary for agencies to complete the same level for all principles before moving to the
next level. In fact, this would be counterproductive. An agency may well find that it has reached Level 4 for
one principle before Level 1 is completed for another. It is, however, important that the various parts of the
Code of Environmental Management Principles
41
Implementation Guide
-------
program maintain communication with each other, as is illustrated by the number of candidate actions that
cover similar ground. For example, several of the principles can be partially fulfilled by implementing a
system to obtain employee feedback. Even though this activity cross-cuts the principles, it does not
necessarily appear at the same Matrix level for each.
Finally, the Matrix does not represent a mythical state of perfection that will be impossible for agencies to
attain. Rather, it should be thought of as a means by which agencies can gauge their progress in
implementing the CEMP and, more broadly, in improving their approaches to environmental management by
incorporating those elements considered "state of the art." Improvements in management should be reflected
by improvements in the efficiency, cost-effectiveness, and performance of environmental programs.
Code of Environmental Management Principles 42 Implementation Guide
-------
Appendix 1: Agency Responses
Central Intelligence Agency (CIA)
Department of Agriculture (USDA)
Department of Commerce (DoC)
Department of Energy (DoE)
Department of Interior (Dol)
Department of Justice (DoJ)
Department of Transportation (DoTransp.)
Department of Treasury (DoTreas.)
Environmental Protection Agency (EPA)
General Services Administration (GSA)
Health and Human Services (HHS)
National Aeronautics and Space Administration (NASA)
Postal Service
Tennessee Valley Authority (TVA)
Veterans Administration (VA)
-------
Table 1.
Summary of Agency Responses to Code of Environmental Management Principles (CEMP)
Agency
CIA
USDA
DoC
DoD
DoE
Dol
DoJ
DoTransp.
DoTreas.
EPA
GSA
HHS
NASA
Postal Service
TVA
VA
CEMP
endorsed on
agency wide
basis
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explains plan
to implement
CEMP at
facility level
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Partial
Describes how
alternative
system (e.g.,
ISO 14001)
will meet
CEMP
Yes
Partial
Yes and
evaluating ISO
14001
Partial and
evaluating ISO
14001
Evaluating ISO
14001
Partial
Evaluating ISO
14001
Partial
Partial
Evaluating ISO
14001
Yes and
evaluating ISO
14001
Partial
Addresses each
CEMP
principle
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Addresses the
objectives of
each CEMP
principle
Partial
Yes
Partial
Partial
Code of Environmental Management Principles
13
Implementation Guide
-------
compliance" and the traditional short-term focus on regulatory requirements to a broader, more inclusive view
of the interrelated nature of their environmental activities.
Unfortunately, federal agencies often lack the resources to develop a complete environmental management
program, especially when their primary missions are not directly related to environmental protection or
management. They are often forced to take a "finger in the dike" approach that focuses on compliance,
addressing situations as they occur, instead of planning their activities to prevent such situations. They may
even be successful, until they run out of fingers. Thus, short-term success is no indicator of the long-term
stability of the system and may even lead to complacency. Agencies that are able to better understand their
"dike" (how it was built, why it was built the way it was, and how the demands on it are changing over time)
will be in a better position to identify weak points and predict the next "high tide," managing their resources
for prevention, not just response. Of course, regulatory compliance is still required, but the CEMP, properly
implemented, will provide agencies with a tool to improve overall performance while maintaining compliance
as a performance baseline.
What is an Environmental Management System (EMS)?
The International Organization for Standardization (ISO) defines environmental management systems as
"that part of the overall management system which includes organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for developing, implementing, achieving,
reviewing and maintaining the environmental policy." In other words, an EMS focuses on environmental
management practices, rather than the activities themselves, such as air monitoring or drum handling. The
EMS provides the structure by which the specific activities can be carried out efficiently and in a manner
consistent with key organizational goals, but does not specify levels of performance (e.g., the EMS will
ensure that proper procedures are in place and that operator training exists but won't specify methods or
frequency of sampling). The EMS allows an organization the flexibility to adapt the system to its needs and
priorities, rather than forcing a "one size fits all" mentality.
The EMS approach has its genesis in the same movement that created the "quality management" systems
traditionally applied to manufacturing, such as Total Quality Management (TQM). The Global
Environmental Management Initiative (GEMI) patterned its Total Quality Environmental Management
(TQEM) philosophy on TQM, employing many of the same diagnostic tools for environmental applications.
The more general EMS approach
incorporates the "plan-do-check-act"
cycle and the emphasis on continuous
improvement found in TQM and other
quality management schemes. [See
Figure 1] A number of organizations
and countries (e.g., ISO, Britain,
Canada) have developed standards to
Environmental Processes in a
Management System
encourage implementation of the EMS
approach.
Is the CEMP an EMS Standard?
Organization and Resources
Figure 1
Code of Environmental Management Principles
Implementation Guide
-------
prevention policies and practices should follow the
environmental management hierarchy prescribed
NPR RECOMMENDATIONS
h
Improve Implementation of Environmental
IVjbanaiicmcnt
1.
u
t
i
2o
n
P
r
Improve Federal Decisionmaking Through
Environmental Cost Accounting - use of tools
such as Life Cycle Analysis and Total Cost
Assessment, discussed earlier, is increasing
among Federal agencies. A number of software
packages have also been developed to address
this issue.
Develop Cross-Agency Ecosystem Planning
and Management - the "MOU to Foster the
Ecosystem Approach," described under
Principle 1, demonstrates progress in this area.
ention Act of 1990 [Figure 2]: 1) source
reduction; 2) recycling; 3) treatment; and 4)
disposal.
Section 3-301(b) of Executive Order 12856 requires the head of each federal agency to make a
commitment to utilizing pollution prevention through source reduction, where practicable, as "the
primary means of achieving and maintaining compliance with all applicable federal, state and local
environmental requirements." Making this critical link between pollution prevention and compliance
assurance is the key to achieving and maintaining a "beyond compliance" state. An integrated
environmental management system can help agencies make this link.
It is equally important to understand the link between pollution prevention and resource conservation, and
the cyclical nature of this relationship. For
example, agriculture has been identified as
a principal source of non-point source
water pollution, mainly through run-off Pollution Prevention Act
that increases sedimentation in waterways Environmental Management Hierarchy
and deposits large amounts of pesticides,
nitrates, phosphates, and other compounds.
The soil's productive capability is
diminished and water quality degraded,
with the result that greater amounts of
pesticides and fertilizers are needed to
maintain crop yields, and water supplies
may eventually be unsuitable for irrigation
(e.g., through increased salinity). However,
more strategic approaches to irrigation that
reduce run-off can both reduce water usage
Source Reduction
Recycling/ Reuse
Figure 2
Code of Environmental Management Principles
25
Implementation Guide
-------
environmentally-related information, communication, and documentation.
Information management, communication, and documentation are necessary elements of an effective
environmental management program. The need for advanced information management capabilities has
grown significantly to keep pace with the volume of available information to be sifted, analyzed, and
integrated. The ability to swiftly and efficiently digest data and respond to rapidly changing conditions
can be key to the continued success of an organization. For example, an integrated information
management system may be used to track process requirements, procedures, measurements, compliance
standards, and compliance status. The effects of process changes can be followed and incidents resulting
in non-compliance quickly rectified. Generation of reports is also greatly simplified, reducing demand on
time, personnel, and financial resources. Many private and public organizations have taken advantage of
the explosion in networking capabilities to make information available through the Internet (particularly
the World Wide Web), organization intranets (internal networks that utilize Internet technologies), and
other commercial group software packages. Figure 3 offers a conceptual depiction of the multiple
sources of environmental information that can be maintained, coordinated, and combined through
sophisticated information management using such technologies.
Information management capabilities include not only hardware and software concerns, but also people
Federal Agency
Environmental Compliance
Management System
hT^n fc—-, .
r EPA 10 \ I \
/ . ^1EPA8 -\
^-LJ.-j I J
Figure 3
Code of Environmental Management Principles
29
Implementation Guide
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
LEVEL
1.1 OBTAIN MANAGEMENT SUPPORT
Policy Development
System Integration
1.2
ENVIRONMENTAL
STEWARDSHIP
FINISH
Agency communicates its policy externally, to regulatory
authorities, other agencies, and other stakeholders
Agency decisions consider environmental criteria when
appropriate; program thoroughly integrated
• Assume leadership through outreach
All agency decisions include appropriate environmental
criteria to minimize impact
• Consider environmental impacts
• Participate in hearings and other activities
Agency develops final policy and communicates it internally
Over 50% of agency decisions consider environmental
criteria; program integrated through 75% of agency
• Encourage teaming across divisions
Agency develops procedures to evaluate environmental
impacts of future activities
• Introduce LCA and design for environment concepts
• Provide outside speakers
• Sponsor outside activities
• "Open House" for community
• Demonstrate commitment
Agency develops draft policy and circulates it for review and
comment
Environmental criteria are incorporated into employee
performance standards as appropriate; program integrated
through 50% of agency; criteria for environmental decision-
making developed
• Review responsibilities
Agency identifies alternatives to high-impact activities
• Encourage environmental action plans
• Provide "brown bag" speakers
• Create promotional items
Agency evaluates environmental concerns of key stakeholders
• Develop goals and priorities
• Communicate with stekeholders
Environmental criteria are incorporated into affected
managerial performance standards; program integrated
through 25% of agency, starting with activities most affected
• Conduct organizational review
• Assign management responsibilities
• Include performance criteria
• Coordinate and review budget
Agency implements awareness programs to inform
employees and stakeholders
• Provide orientation
Agency evaluates its mission in environmental terms
• Prepare Mission/Vision statements
START
Environmental program is communicated throughout agency;
environmental groups established and their missions defined
and communicated
• Identify liabilities and risks
• Provide awareness training
Agency evaluates environmental impacts of its activities
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
LEVEL
2.1
COMPLIANCE ASSURANCE
2.2
EMERGENCY PREPAREDNESS
2.3
POLLUTION PREVENTION AND
RESOURCE CONSERVATION
FINISH
It
5
Full agency compliance is sustainable; contractors are
included within the compliance program
• Set "beyond compliance" performance goals
• Evaluate contractor performance
• Introduce risk assessment
All agency personnel are trained in emergency response
procedures; full-scale exercieses are conducted at least
annually
Program maintained throughout the agency; significant
reductions in waste generation achieved
Agency develops proactive and cooperative relations with
regulators; non-compliance situations reduced significantly
• Employee reporting encouraged
• Regular contact with regulators
• Procedures to elevate issues to upper management
• Pollution prevention is primary management approach
Agency implements medical monitoring for environmental
program personnel as appropriate and inspects facilities
periodically
• In-house medical monitoring, where appropriate
Agency encourages reduced use of resources and identifies
indificuals contributing to the success of the program;
process improvements implemented
• Affirmative procurement program
• Life-cycle analysis performed
• Design for environment
• Product stewardship
Agency fully implements compliance program, develops a
program to track relevant legislation and regulations, and sees
improved performance
• Track regulatory initiatives
• Address non-compliance conditions
• Track corrective action progress
• Environmental recordkeeping system
• Identify problems and prevent non-compliance incidents
• Establish compliance management system that is
integrated with EMS
Agency emergency response teams are trained and periodic
drills are conducted
• Emergency Response Team
• Training for Emergency Response Team and other
personnel
• Conduct regular exercises
• Identify emergency resources
Agency develops goals, implements employee suggestion
procedures, and identifies alternatives to major generators
• Toxic materials reductions
• Water conservation program
• "Repair or Replace" program
Agency communicates with regulatory authorities, develops
procedures to address compliance situations, and distributes
them throughout the agency
• Introduce compliance group
• Develop compliance guidance
• Coordinate with regulators
• Communicate information on regulations and permits
Agency develops procedures to address emergency response,
distributes them throughout the agency
Develop response procedures
Disaster preparedness plan
Hazard mitigation measures
Preventive maintenance program
Coordinate with authorities
Develop communication plan
Agency communicates pollution prevention commitment to
all personnel and begins recycling programs (paper,
aluminum, glass)
• Energy conservation program
• Recycling program in place
• Encourage reuse of materials
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
START
Agency compliance group evaluates agency's activities and
compliance history
• Develop compliance group
• Review agency activities
• Assess compliance baseline
Agency emergency response group evaluates its activities and
vulnerability to natural disaster and accidents
• Identify hazards from agency activities and facilities
Agency evaluates its waste generation profile and identifies
major points of generation
• Pollution prevention program that emphasizes source
reduction
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
LEVEL
3.1
TRAINING
3.2
STRUCTURAL SUPPORTS
3.3
INFORMATION MANAGEMENT,
COMMUNICATION, DOCUMENTATION
FINISH
It
5
100% of agency folly trained, refresher training provided,
computer-based and distance learning employed when
appropriate; training program continually evaluated
• Obtain feedback on training
• Investigate alternative training methods
Procedures are fully implemented and reviewed periodically
• Conduct periodic review of procedures to ensure
currency
Agency maintains effective communications, applies
environmental information to decision-making, and
maintains thorough records
• Use EMS data in decision-making
75% of agency fully trained; refresher training developed and
available, where appropriate; continuing education
encouraged
• Establish refresher training
• Encourage continuing education
Agency implements procedures and begins training of all
staff, as appropriate
• Pursue integration of environmental program throughout
agency
Agency develops procedures for use of information, provides
avenues for employee input, and has a well-maintained
records center
Use electronic networks
Assure validity of envtl. data
Secure data-handling procedures
Employee reporting system
Encourage employee input
50% of agency fully trained; system to track fulfillment of
training requirements developed and implemented
• Establish in-house group to track training program
Agency disseminates procedures throughout to raise
awareness of issues; implementing staff is trained
• Encourage input from personnel
Agency communicates with regulators and stakeholders and
develops information gathering, manipulation, and
management procedures
Evaluate new IM projects
Assign POC for new projects
Establish Resource Center
Provide regular status updates
Communicate with other orgs.
Develop public outreach program
Communicate with stakeholders
Develop distribution network
QA and security procedures
Agency training group identifies available outside training
and develops in-house training where necessary; 20% of
agency folly trained
• Identify job-specific requirements
• Evaluate outside vs. in-house training
• Train the trainers as necessary
Agency develops or revises procedures to address activities
identified as having environmental aspects
• Eliminate or revise procedures found to be barriers
Agency develops internal communications and information
management infrastructure, and document control procedures
Ensure compatibility
Develop envtl. IM procedures
Identify key records/documents
Develop in-house communication
Enable working relationships
Report completion procedures
Maintain MSDS. etc.
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
START
Agency training group identifies environmental training needs
and where training is available
• Develop "Core Curriculum"
Agency identifies and evaluates existing procedures and
activities that have environmental aspects
• Review agency documentation
Agency identifies lines of communication, information needs.
documentation procedures
Assign managerial responsibility
Create in-house IM group
Review current capabilities
Define lines of communication
Assign environmental POCs
Develop centralized filing system
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 4: PERFORMANCE AND ACCOUNTABILITY
LEVEL
FINISH
It
5
It
4
It
3
It
2
1
It
START
4.1
RESPONSIBILITY, AUTHORITY AND ACCOUNTABILITY
Assignment of environmental responsibilities is reviewed periodically in light of
performance
Personnel are provided avenues to provide input and employees are held accountable for
environmental performance
• Develop employee input/concerns program
All employees assigned environmental responsibilities are given appropriate authority and
training
• Issue clear statements of environmental responsibility
• Prepare process to address authority conflict
• Develop policy on accountability
Managers assigned environmental responsibilities are given training and authority to meet
those responsibilities
• Issue statements defining authority
Agency identifies personnel with responsibility for environmental performance
• Assign authority to ensure environmental compliance
4.2
EMPLOYEE PERFORMANCE STANDARDS
Agency develops a program to recognize and reward personnel that carry out
environmental responsibilities exceptionally well; appropriate disciplinary mechanisms
also in place
• Prepare program to reward or recognize honorees
• Prepare disciplinary mechanisms to address non-conformance with agency policy or
procedures
Personnel are evaluated based on environmental aspects of their performance standards
• Develop procedures for evaluating performance
Affected employees have environmental responsibilities clearly stated in performance
standards
Managers have environmental responsibilities clearly stated in performance standards
• Develop employee evaluation standards
• Publicize standards and solicit input from agency
Agency identifies personnel with responsibility for environmental performance
• Identify organizational performance goals
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
LEVEL
5.1 EVALUATE PERFORMANCE
Gather/Analyze Data
Institute Benchmarking
5.2
CONTINUOUS IMPROVEMENT
FINISH
It
5
Data-gathering is a continuous process; gaps in performance
are identified and analyses conducted to identify their root
cause(s)
Agency maintains ongoing "benchmarking cycles"; agency
becomes a target for benchmarking by others
• Explore possibility of mentoring other organizations
Agency shows significant improvement in addressing
substandard performance situations and aggressively seeks to
compare its performance to others
• Review other management approaches for applicability
Periodic evaluations of operations and data-gathering
procedures are conducted to assess performance
• Include system measurement in review and improvement
process
Agency identifies and implements improvements based on
evaluation of other organization
• Develop methods to apply results of benchmarking and
pursue further involvement
Agency fully implements periodic reviews of systems and
performance and seeks out additional opportunities for
improvement
• Develop methods to apply results of benchmarking and
pursue further involvement
• Conduct review of procedures
• Review and report improvements
Data-gathering and processing procedures are implemented
throughout the agency
• Identify independent audit group
• Develop procedures to manage and use information from
audits
Agency evaluates performance of target organization through
sharing of information (e.g., site visit) for comparison with its
own
Agency implements employee-involvement measures, such
as newsletters and lessons learned, to solicit input on
improving performance
• Develop lessons learned program
• Encourage employee suggestions
• Work to include improvements in next planning cycle
Agency develops procedures for gathering appropriate data
and communicates them to management
• Define assessment parameters
• Develop QA objectives
Agency identifies other organizations with similar activities
and/or exceptional performance and initiates contact with
them
• Develop program of comparison to other organizations
Agency develops procedures to address preventive and
corrective action situations and communicates them to
management
• Develop procedures to identify root causes
• Develop program of comparison to other organizations
Agency identifies performance indicators, data needs, and
standards of comparison
• Develop and report on performance indicators
• Develop internal audit program
Agency evaluates its activities and sets goals for
environmental performance
• Evaluate most useful benchmarking areas
Agency evaluates performance to identify areas needing
improvement
START
Notes:
-------
This document was prepared by
the Federal Facilities
Enforcement Office (2261-A) in
the Office of Envirocement and
Compliance Assurance.
Consulting assistance and
document design/layout
services were provided under
IAG number DW89936515.
For additional copies of this
document, please contact:
Priscilla Harrington
U.S. EPA (2261-A)
401 M Street, SW
Washington, D.C. 20460
Tel: (202) 564-2461
Fax: (202)501-0069
-------
EPA P2 Web Sites
The U.S. Environmental Protection Agency (EPA) provides a host of information
sources to support an organization's P2 Program. The P2 Guide is not in-
tended to be an exhaustive review of P2 case studies and information. In order to
keep the hard copy Guide to a workable size, these links are designed to help you
find the information that you will need to move forward with your search for P2
alternatives and prepare P2 action plans. Please have your Internet connection
ready as you select the links that are provided below. Each of these Internet sites
will lead you to other sites with more information. The EPA home page
http://www.epa.gov/ also has a search function that can help you find more specific
P2 information.
Back HOME
Back to EPA P2 Info.
Click on the Site Name to View it on the Web WWW
EPA's Pollution
Prevention Home Page
EPA Environmental
Accounting Project
Energy Star Program
National Center for
Environmental
Publications and
Information
EPA Environmentally
Preferable Purchasing
EPA Sustainable Industry
Program
Pollution Prevention
Information
Clearinghouse
WasteWiSe Program
EPA Design for
Environment Program
WAVE Program
Other EPA Voluntary Programs
-------
Other P2 Web Sites
Other U.S. government agencies and the states provide organizations with P2
support and information. A listing of Internet sites that your organization can
use to gather information for its P2 alternative generation and action planning can
be found below. Please have your Internet connection prepared to be activated by
the links provided below. All of these sites will refer you to other sites that can
provide the information that you require. You can also use your favorite browser to
find additional sites for gathering P2 information for your organization.
Click on the site name to view it on the web. WWW
National Pollution
Prevention Roundtable
Small Business
Development Centers
POD Joint Services P2
Library
State P2 Technical
Assistance Providers
P2 Resource Exchange
Community-Based
Approaches
NIST Manufacturing
Extension Partnership
Centers
DOE Energy Efficiency
Air Force P2 Tool Box
Back HOME
Back to EPA P2 Info.
-------
EPA Information on P2
The U.S. Environmental Protection Agency (EPA) provides information and
support to organizations that seek to implement P2 programs. In addition, the
EPA supports other efforts at the regional, state and local levels to provide useful
P2 information. This section of the CD-ROM is designed to help introduce you to
these sources of information. For convenience, this information is provided in two
sections:
• EPA P2 Web Sites
• Other Web P2 Information
You will need to have your Internet connection activated to use these links directly
from the CD-ROM.
-------
United States Office of Enforcement and
Environmental Protection Compliance Assurance
Agency Washington, DC 20460
EPA300-B-94-012
November 1994
EPA Federal Facility Pollution
Prevention Planning Guide
-------
This document was prepared
by the Federal Facilities
Enforcement Office (2261 ) in
the Office of Enforcemeig
and Compliance Assurance':
Consulting assistance and
document design/layout ser-
vices were provided by
Science Applications Inter-
national Corporation (SAIC).
For additional copies of this
document, please contact:
Pollution Prevention
Information Clearinghouse
U.S. EPA (3404)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-1023
Fax: (202) 260-0178
-------
TABLE OF CONTENTS
PAGE.
SECTION I: INTRODUCTION
Background 1
Purpose of This Document 1
Pollution Prevention Defined 2
Executive Orders 3
Federal Laws 5
State Laws 5
Federal Agency Pollution Prevention Policies 6
SECTION II: FACILITY POLLUTION PREVENTION PLAN
DEVELOPMENT STEPS
Introduction 7
Developmentof a Facility Plan for Pollution Prevention 7
Step 1: Develop Goals 7
Step 2: Obtain Management Commitment 8
Step 3: Build abeam 8
Step 4: Develop a Baseline 10
StepS: Conduct Pollution PreventionActivities and
Opportunity Assessments 12
Step6: Develop Criteria and Rank Facility-Wide
Pollution Prevention Activities 13
Step7: Conduct aManagementReview 17
Public Participation 17
Measurements ofProgress 18
Implementation of the Plan 18
SECTION III: TECHNICALASSISTANCEAND LITERATURE
Pollution Prevention Planning Documents 21
Agency Guidance Documents 21
Technical Assistance Programs 22
Federal Facility Pollution Prevention Contacts 23
State Pollution Prevention Programs 24
ANNEX A: EXECUTIVE ORDER 12856
Recycled/Recyclable • PrintedwithVegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer) • PleaseRecydeas Newsprint
-------
SECTION I: INTRODUCTION
"... Federal facilities will set the example for the rest of the country and
become the leader in applying pollution prevention to daily operations,
purchasing decisions and policies... By stopping pollution at its source,
the Federal government can make a significant contribution to protecting
the public health and our environment. " President Clinton
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
BACKGROUND
The Federal government is the Nation's
largest consumer of raw materials, power,
water, and products. The government
consumes these resources in its produc-
tion, maintenance, and operational activi-
ties. In many cases, these activities result
in the generation of harmful liquid, solid,
and gaseous wastes. Such wastes may
have adverse impacts on people and the
environment. In addition, the manage-
ment and disposal of these wastes (as well
as the cleanup of improperly managed
wastes) are costly.
The cost for material use, the manage-
ment of solid and hazardous wastes, the
control of discharges to the air and water,
and the cleanup of improperly managed
materials is rising. Rising costs in the
Federal community translates into costs to
every American. In addition, the require-
ments for the management of hazardous
materials and the release of chemicals to
the environment are becoming more com-
prehensive. The increasing costs and
expanding requirements create incentives
for Federal facilities to reduce the
amounts of hazardous materials used and
wastes generated.
Federal agencies can reduce their envi-
ronmental impacts and the costs associat-
ed with managing these impacts by incor-
porating pollution prevention into their
facilities activities. The Federal govern-
ment is in a unique position to demon-
strate leadership by protecting the envi-
ronment using pollution prevention.
Through its purchasing practices, for
example, the government can demonstrate
the use of less toxic and environmentally
protective products and materials. The
government can also create the demand
for goods and products with recycled con-
tent by establishing minimum recycled
content standards in its procurement con-
tracts. By embracing pollution preven-
tion as the preferred environmental man-
agement technique, the Federal govern-
ment can promote pollution prevention in
all its forms, including source reduction,
recycling, and affirmative procurement.
The Federal government can fundamen-
tally change the way in which the govern-
ment and, in the long-run, the Nation con-
duct business.
PURPOSE OF THIS
DOCUMENT
This document is designed to help
Federal facility environmental coordina-
tors comply with the pollution prevention
planning requirements of Section 3-
302(d) of Executive Order 12856 (see
Annex A), which states that "the head of
each Federal agency shall ensure that
each of its covered facilities develops a
written pollution prevention plan no later
than the end of 1995, which sets forth the
facility's contribution to the goal estab-
lished in set uon 3-302(a) of this order.
Federal agencies shall conduct assess-
ments of their facilities as necessary to
ensure development of such plans and of
the facilities' pollution prevention pro-
grams. " Specifically, the manual will
support facilities in developing written
pollution prevention plans that describe
how facilities will contribute to meeting
the Agency 50 percent reduction goals in
-------
the release of or the transport for disposal
of toxic chemicals as identified under
Section 3-302(a) of Executive Order
12856. This document also provides
guidance for Federal facility environmen-
tal coordinators to meet pollution preven-
tion requirements and goals established in
several other Executive Orders, Federal
laws, State laws, and Federal agency poli-
cies. More importantly, this manual is
intended to describe how you, the envi-
ronmental coordinator, can strengthen the
environmental program at your facility
using pollution prevention approaches.
This guide is intended to introduce you to
multimedia pollution prevention planning
techniques. It is intended to be a quick
reference guide that can assist in first
developing a pollution prevention facility
plan (as required under Executive Order
12856) and, second, initiating a compre-
hensive environmental management pro-
gram. This document is not a compre-
hensive technical guide to pollution pre-
vention facility planning. For additional
planning support, EPA encourages you to
refer to pollution prevention planning
guidance documents that your agency or
EPA has developed (see Section III).
The remainder of Section I provides an
overview of pollution prevention and
related Executive Orders, Federal laws,
State laws, and Federal agency policies
that require pollution prevention activi-
ties. Section H outlines steps for develop-
ing a facility-wide, multimedia pollution
prevention facility plan and building the
plan into a pollution prevention program.
Section III provides a list of pollution pre-
vention guidance documents, technical
assistance programs, and contacts that
might provide further assistance in devel-
oping and implementing your facility's
pollution prevention plan.
POLLUTION PREVENTION
DEFINED
Over the past several years, a new envi-
ronmental protection concept has evolved
that focuses on eliminating or modifying
activities that result in adverse environ-
mental impacts. This concept, known as
pollution prevention, has gained support
throughout the Nation, especially in
Federal agencies, as a means to meet or
exceed environmental goals and stan-
dards.
The Pollution Prevention Act of 1990 and
Executive Order 12856 define pollution
prevention as "... any practice which
reduces the amount of a hazardous sub-
stance, pollutant, or contaminant enter-
ing any waste stream or otherwise
released into the environment (including
fugitive emissions) prior to recycling,
treatment, or disposal; and any practice
which reduces the hazards to public
health and the environment associated
with the release of such substances, pollu-
tants, or contaminants.
Pollution prevention refers to the use of
materials, processes, or practices that
eliminates or reduces the quantity and
toxicity of wastes at the source of genera-
tion. It includes practices that eliminate
the discharge of hazardous or toxic chem-
icals to the environment and that protect
natural resources through conservation
and improved efficiency. Pollution pre-
vention also reduces the use of hazardous
materials, energy, and water.
Pollution prevention is a novel approach
to waste management not only because it
seeks to avoid the generation of waste or
environmental releases, but also because
it stresses the management of all environ-
mental media (i.e., air, land, and water)
together. Within this framework, pollu-
tion prevention aims to eliminate or
reduce waste released to land, air, and
water without simply transferring or dis-
tributing pollutants among these media.
Pollution prevention represents the first
step in a hierarchy of options for manag-
ing waste. This environmental protection
hierarchy lists, in descending order of
preference, source reduction, recycling,
treatment, and disposal as the recom-
mended options for waste management.
Source Reduction
Activities
Process Efficiency Improvements
Perform the same task with
less energy or materials by
designing new systems or
modifying existing ones.
Material Substitution
Replace hazardous chemicals
with less toxic alternatives.
Inventory Control
Prevent product expiration
and damage by improving
inventory management.
Preventive Maintenance Routinely
check for and repair leaks and spills
and maintain equipment in good
working order to extend useful life.
Improved Housekeeping
Keep the facility neat and
organized to reduce chances of
spills and releases of chemicals.
Source Reduction
Environmental Protection
Hierarchy
Section I: Introduction
-------
Source reduction is assigned the highest
priority because it eliminates or reduces
wastes at the source of generation.
Recycling is the next preferable approach
because it involves the reuse or regenera-
tion of materials and wastes into usable
products. Treatment and disposal are
considered last-resort measures.
Key benefits of pollution prevention may
include reductions in reporting require-
ments, compliance costs, and environ-
mental liability. Pollution prevention
may also reduce expenditures for raw
materials, waste disposal, transportation,
handling and storage, training, manage-
ment overhead, and emergency response.
This approach will result in a cleaner
environment, more efficient operations,
and safer working environments.
EXECUTIVE ORDERS
To promote pollution prevention as the
preferred environmental management
technique throughout the Federal govern-
ment, the President has issued numerous
Executive Orders. These orders instruct
Federal agencies to integrate waste reduc-
tion and recycling programs into their
environmental management initiatives.
To do this, the President has identified
specific source reduction and recycling
goals that all Federal agencies and facili-
ties should meet. By requesting Federal
agencies to respond to the goals of the
Executive Orders, the Federal govern-
ment demonstrates its commitment to the
environment and ultimately to each citi-
zen of the United States.
These Executive Orders (discussed on the
following page) translate into various
requirements that you should consider
when developing and implementing your
facility pollution prevention plan. The
general requirements for these Executive
Orders are summarized in the box. You
should check with your headquarters to
obtain information concerning goals,
requirements, assistance programs, and
research efforts specific to your agency.
Facility Requirements Under Pollution Prevention
Executive Orders
Executive Order 12856—Federal
Compliance with Right-to-Know Laws
and Pollution Prevention
Requirements (August 3, 1993)
• Develop a facility-wide pollution pre-
vention plan by December 31,1995,
to reduce releases and transport of
toxic chemicals by 50 percent.
• Ensure that the plan supports
agency-wide reduction strategies
and goals.
• Establish agency plans and goals to
eliminate or reduce unnecessary
acquisition of products containing
hazardous substances or toxic
chemicals.
• Make strategies, plans, and Toxic
Release Inventory (TRI) reports
available to the communities sur-
rounding your facility.
• Comply with EPCRA emergency
planning and response require-
ments.
• Report releases and transfers of
toxic chemicals to the TRI.
Executive Order 12873—Federal
Acquisition, Recycling, and Waste
Prevention (October 20, 1993)
• Establish goals for solid waste pre-
vention and recycling to be achieved
by 1995.
• Procure products that are environ-
mentally preferable or that are made
with recovered materials, and set
annual goals to maximize the num-
ber of recycled products purchased.
Executive Order 12902—Energy
Efficiency and Water Conservation
(March 8, 1994)
• Reduce the overall energy use in
Federal buildings by 30 percent by
2005.
• Increase overall energy efficiency in
industrial facilities by 20 percent by
2005.
• Significantly increase the use of
solar and other renewable energy
sources.
• Minimize the use of petroleum
products at Federal facilities by
switching to less polluting alterna-
tive energy sources.
Executive Order 12843—Procurement
Requirements and Policies for
Federal Agencies for Ozone-Depleting
Substances (April 21, 1993)
.Maximize use of alternatives to
ozone-depleting substances.
.Modify procurement specifications
and practices to substitute non-
ozone-depleting substances,
Executive Order 12844—Federal Use
of Alternative Fueled Vehicles
(April 21, 1993)
• Procure and use alternative fueled
vehicles, where possible, to reduce
toxic and hazardous air pollutants.
• Purchase 50 percent more alterna-
tive fueled vehicles from 1993
through 1995 than currently speci-
fied in the Energy Policy Act of
1992. While your facility may not
be scheduled to purchase such
vehicles, you should investigate and
purchase such vehicles if possible.
Executive Order 12845—Purchasing
Energy Efficient Computer Equipment
(April 21, 1993)
• Meet EPA "Energy Star" energy effi-
ciency requirements in the purchase
of computer equipment.
• Equip existing computer equipment
with energy efficient low-power
stand-by feature.
• Educate staff about the environmen-
tal and economic benefits of energy
efficiency.
Executive Order 12898—Federal
Actions to Address Environmental
Justice
.Encourages Federal facilities to doc-
ument potential environmental im-
pacts in environmental justice areas
and target such impacts for reduc-
tion through pollution prevention.
-------
Executive Order 12856-Federal
Compliance with Right-to-Know
Laws and Pollution Prevention
Requirements
One of the most important milestones in
Federal pollution prevention activities
was the signing of Executive Order 12856
(Federal Compliance with Right-to-Know
Laws and Pollution Prevention Require-
ments) in August 1993. This order is
expected to serve as a central directive to
Federal agencies and facilities on pollu-
tion prevention during the coming years.
Executive Order 12856 calls on Federal
agencies to develop a 50 percent reduc-
tion goal by 1995 for their releases of
toxic chemicals, or pollutants, with the
baseline being no later than 1994.
To accomplish this, Executive Order
12856 requires Federal facilities subject
to the order to develop facility-specific
pollution prevention program plans.
These plans should set goals, identify
activities, and establish a timeline to
reduce and eliminate the acquisition,
manufacture, processing, or use of toxic
chemicals and extremely hazardous sub-
stances at the facility. The plans should
consider all activities and processes that
rely on toxic and extremely hazardous
materials. In addition, the plans should
include any other activities that may
adversely impact the environment. The
plans should consider all environmental
media (i.e., land, air, and water) and iden-
tify specific activities that will result in
reductions of impacts to these media.
Executive Order 12873-Acquisition,
Recycling, and Waste Prevention
Executive Order 12873 directs Federal
agencies and facilities to implement
acquisition programs aimed at encourag-
ing new technologies and building mar-
kets for environmentally preferable and
recycled products. Toward this end, all
agencies are directed to review and revise
their specifications, product descriptions,
and standards to enable procurement and
acquisition personnel to meet the goals set
forth in the Executive Order. Agencies
also must set goals for waste prevention
and the acquisition of recycled products
and report on their progress in meeting
the goals.
Executive Order 12902-Energy
Efficiency and Water Conservation
Under Executive Order 12902, Federal
agencies and facilities are directed to
increase efforts to conserve energy and
water by improving efficiency. Each
agency must undertake a prioritization
survey of all its facilities leading to a 10-
year plan to conduct comprehensive ener-
gy and water audits. In response to this
plan, each Federal facility will be expect-
ed to contribute to its agency-wide con-
servation and reduction goals.
Executive Orders 12S43, 12844,
12845—Ozone-Depleters, Alternative
Fueled Vehicles, Energy Star
Computers
Three other executive orders, signed on
Earth Day 1993, commit the Federal gov-
ernment to accelerated action on several
fronts—phasing out ozone-depleting sub-
stances, purchasing alternative fueled
vehicles, and buying energy-efficient
computers.
Executive Order 12843—Procurement
Requirements and Policies for Federal
Agencies for Ozone-Depleting Substances
Executive Order 12843 directs Federal
agencies to change their procurement
policies to reduce the use of ozone-
depleting substances earlier than the 1995
phase-out deadline called for in the
Montreal Protocol. Federal agencies are
directed to modify specifications and con-
tracts that require the use of ozone-deplet-
ing substances and to substitute non-
ozone-depleting substances to the extent
economically practicable. Through affir-
mative acquisition practices, the Federal
government will provide leadership in the
phase-out of these substances on a world-
wide basis, while contributing positively
to the economic competitiveness on the
world market of U. S. manufacturers of
innovative safe alternatives.
Executive Order 12844 —Federal Use of
Alternative Fueled Vehicles
Executive Order 12844 places the
Federal government in a leadership role
in the use of alternative fueled vehicles,
calling on each agency to adopt aggres-
sive plans to exceed the purchase .
requirements of such vehicles estab-
lished by the Energy Policy Act of
1992. The use of alternative fueled
motor vehicles can reduce air pollution,
stimulate domestic economic activity,
reduce vehicle maintenance costs, and
provide market incentives for the devel-
opment of such vehicles and the fueling
infrastructure needed to support large
numbers of privately owned alternative
fueled vehicles.
Executive Order 12845—Purchasing Energy
Efficient Computer Equipment
The U.S. government became a participant
in the Energy Star Computer program by
agreeing to buy energy-efficient computers,
monitors, and printers to the maximum
extent possible. To the extent possible,
Federal agencies must now purchase only
those computer products that qualify for the
Energy Star logo, as long as they meet other
performance requirements and are available
in a competitive bid.
Executive Order 12898—Federal
Actions to Address Environmental
Justice in Minority Populations and
Low-Income Populations
Section 3-302(c) of Executive Order 12898
requires that "each Federal agency, when-
ever practicable and appropriate, shall col-
lect, maintain and analyze information on
the race, national origin, income level and
other readily accessible and appropriate
information concerning areas surrounding
Federal facilities that are (1) subject to the
reporting requirements under the
Emergency Planning and Community
Right-to-Know Act, 42 U.S.C. section
11001-11050 as mandated in Executive
Order 12856: and (2) expected to have a
substantial environmental, human health, or
economic effect on surrounding popula-
Section 1: Introduction
-------
tions. Such information shall be made
available to the public, unless prohibited
by law." Facilities are encouraged to con-
sider these requirements in developing
facility baselines and pollution prevention
plans. Facilities also are encouraged to
develop and implement pollution preven-
tion alternatives that will reduce the envi-
ronmental impacts to environmental j us-
tice areas where socioeconomic factors
are of concern.
FEDERAL LAWS
For several years, Congress has promoted
pollution prevention by legislating
Federal laws that either directly or indi-
rectly require the implementation of pol-
lution prevention. For example, the
Pollution Prevention Act of 1990 estab-
lished pollution prevention as the pre-
ferred environmental management
approach for all waste generators, includ-
ing Federal facilities. The Federal
Facilities Compliance Act of 1992 indi-
rectly encourages pollution prevention by
waiving sovereign immunity for Federal
facilities concerning hazardous waste
compliance requirements.
The Pollution Prevention Act and the
Federal Facilities Compliance Act strong-
ly demonstrate the Federal government's
desire to protect the environment through
pollution prevention approaches. Each of
these acts is discussed in greater detail in
the following paragraphs.
Pollution Prevention Act of 1990
The Pollution Prevention Act of 1990
clearly establishes pollution prevention as
the Nation's preferred approach to envi-
ronmental protection and waste manage-
ment. Although the Act does not mandate
specific pollution prevention activities, it
does establish pollution prevention as the
national environmental protection policy.
The Act states, "The Congress hereby
declares it to be the national policy of the
United States that pollution should be
prevented or reduced at the source when-
ever feasible; pollution that cannot be
prevented should be recycled in
ronmentallv safe manner whenever feasi -
hie; pollution that cannot be prevented or
recvcled should be treated in an environ-
mentally safe manner whenever feasible;
and disposal or other release into the
environment should be employed only as
a last resort and should be conducted in
an environmentally safe manner. "
Federal Facilities Compliance Act
of 1992
The Federal Facilities Compliance Act
requires all Federal facilities to comply
with all applicable hazardous waste laws
and corresponding Federal, State, and
local regulations. The Act makes Federal
facilities fully responsible for violations
of the Resource Conservation and
Recovery Act (RCRA) resulting from
their management of hazardous wastes.
By making Federal facilities responsible
for RCRA compliance violations, the Act
provides Federal facilities with incentives
to minimize hazardous wastes regulated
under RCRA.
Other Federal Laws
Other Federal environmental laws pro-
mote pollution prevention by creating
requirements that must be met by all
waste generators. Waste generators can
reduce the burden of these regulations by
implementing pollution prevention alter-
natives. Such environmental laws include
the Clean Air Act, Clean Water Act,
RCRA, Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA), and Emergency Planning
and Community Right-to-Know Act
(EPCRA).
STATE LAWS
States have promoted pollution preven-
tion as a means to improve environmental
management approaches since the early
1980s. In general, State pollution preven-
tion programs maintain technical assis-
tance functions that disseminate pollution
prevention information to support indus-
trial facilities in their efforts to reduce
wastes and eliminate environmental
Pollution Prevention
Incentives in Federal
Legislation
Clean Air Act
The 1990 Amendments added pol-
lution prevention as a primary goal
of the Clean Air Act.
Clean Water Act
The overall goal of the Clean Water
Act is to reduce and eventually
eliminate the discharge of pollu-
tants into U.S. waterways.
Resource Conservation
and Recovery Act
The Hazardous and Solid Waste
Amendments (HSWA) of RCRA
established as national policy the
reduction or elimination of haz-
ardous waste generation wherever
possible.
Comprehensive Environmental
Response, Compensation, and
Liability Act
CERCLA indirectly promotes pollu-
tion prevention through its perva-
sive liabilityscheme. Any misman-
agement of hazardous materials
can result in liability and can lead to
enforcement action.
Emergency Planning
and Community
Right-to-Know Act
Waste minimization is an explicit
goal of EPCRA; however, it does
not directly mandate pollution pre-
vention. Instead, EPCRA promotes
pollution prevention through the
reporting and public right-to-know
requirements.
-------
impacts. These technical assistance pro-
grams may also support your Federal
facility.
In addition, many States have modified
their regulatory programs, including per-
mitting, compliance inspections, and
enforcement actions, to incorporate and
promote pollution prevention approaches
as a means to meet environmental quality
goals. Moreover, several States have
enacted legislation or regulations promot-
ing or mandating pollution prevention
facility planning. As such, it is critical
that each Federal facility meet not only
the pollution prevention requirements as
directed under Section 5-505 of Executive
Order 12856 but also the pollution pre-
vention requirements of the State environ-
mental program. In cases where the State
and Federal requirements overlap, the
facility should meet the more stringent of
the two requirements.
The following table lists the States that
have facility planning or other prevention
requirements. Since new projects are
emerging with increasing frequency, it is
critical to periodically check with your
State regulators on developing require-
ments and programs. A list of contacts for
State pollution prevention programs is
provided in Section III.
FEDERAL AGENCY
POLLUTION PREVENTION
POLICIES
Pollution prevention program planning
will be the key to successfully addressing
the requirements and goals established in
the Executive Orders and Federal and
State regulations. To reinforce these goals,
Executive Order 12856 requires each
Federal agency to develop a pollution pre-
vention strategy. EPA prepared the docu-
ment entitled, Pollution Prevention in the
Federal Government: Guide for Develop-
ing Pollu lion Prevention Strategies for
Executive Order 12856 and Beyond, to
assist Federal agencies in developing pol-
lution prevention strategies in accordance
with Section 3-301 of the Executive
Order. Information on obtaining this doc-
ument is given in Section HI. Each
agency's strategy will describe how it will
meet the 50 percent toxic release reduc-
tion goal by December 31, 1999, as out-
lined in Section 3-302 of Executive Order
12856. Your facility-specific prevention
plan, as required under the Executive
Order, will support your agency in meet-
ing its source reduction goals as described
in its pollution prevention strategy.
In response to all of these requirements
and directives, several Federal agencies have
demonstrated their commitment to pollution
prevention by developing pollution preven-
tion policies. These policies direct facilities
to develop facility pollution prevention
plans. As a Federal facility environmental
coordinator, it is your responsibility to ensure
that these policies are implemented. For fuj-
ther information on your agency's pollution
prevention policy, contact your Federal facil-
ity pollution prevention contact. A list of
contacts is provided in Section III.
Summary of State Pollution Prevention Legislation
State
Alaska
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Massachusetts
Michigan
Minnesota
Legislation
Facility
Planning
Prevention
X
X
X
X
X
X
X
X
X
X
X
X
X
Other
Pollution
(Requirements
X
X
X
X
X
X
X
X
X
X
X
X
State
Mississippi
Missouri
New Jersey
New York
North Carolina
Ohio
Oregon
Pennsylvania
Rhode island
South Carolina
Tennessee
Texas
Vermont
Virginia
Washington
Wisconsin
Legislation
Facility
Planning
Prevention
X
X
X
X
X
X
X
X
Other
Pollution
Requirements
X
X
X
X
X
X
X
X
X X
X
Section 1: Introduction
-------
SECTION II: FACILITY POLLUTION
PREVENTION PLAN DEVELOPMENT STEPS
INTRODUCTION
This discussion translates all of the
requirements (summarized in Section I)
into specific activities that will help you
define, develop, and implement a pollu-
tion prevention program at your Federal
facility. Specifically, this section de-
scribes the components of a pollution
prevention facility plan. It provides a
stepwise process for the development
and implementation of a facility-wide,
multimedia pollution prevention plan
that will help you and your facility meet
all of the pollution prevention require-
ments and goals.
Once the plan is completed, you will
have a strategy and a list of action items
for integrating pollution prevention into
your facility's environmental protection
program. A facility pollution prevention
plan can be prepared in many different
ways. The exact approach you take will
depend upon the types of organizational
structures, management styles, and mis-
sions within your facility. The remainder
of this section defines EPA-recommend-
ed steps for developing your facility-
wide pollution prevention plan and dis-
cusses public participation, measurements
of progress, and plan implementation.
DEVELOPMENT OF A
FACILITY PLAN FOR
POLLUTION PREVENTION
tent of the plan and the environmental
issues targeted will depend upon your
goals and facility's requirements from
your headquarters, EPA region, and State
environmental regulators. The greatest
challenge to you will come in applying
the pollution prevention planning ap-
proach to develop a plan that meets the
needs of your facility and its specific
environmental concerns.
This sub-section discusses the seven
steps commonly used to develop a facili-
ty pollution prevention plan.
Step 1: Develop Goals
The first step in preparing a facility pol-
lution prevention plan is to develop
goals. These goals will identify specific
reductions and accomplishments that you
envision for the facility's pollution pre-
vention program. Section 3-302(a) of
Executive Order 12856 requires each
Federal agency to develop "voluntary
goals to reduce the agencv's total releas-
es of toxic chemicals for treatment and
disposal from facilities covered by this
order by 50percent by December 31,
1999. " Specifically, your facility pollu-
Step 7:
Step 6:
Step 5:
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
Before you initiate a facility-
wide, multimedia pollution
prevention program, you P
should define specific
goals, actions to accom-
plish those goals, and
a schedule for these
actions. In short,
you should have
a plan. The
exact con-
Step 1:
Conduct a Management Review
Develop Criteria and Rank
Activities/Opportunities
Conduct P2 Opportunity Assessments
Develop a Baseline
Pollution Prevention
Obtain Management Commitment
Steps
Step 2
Develop Pollution Prevention Goals
Steps for
Developing a
Facility
Pollution
Prevention Plan
-------
tion prevention plan should define how
your facility will contribute to your
agency's overall pollution prevention
reduction goals (see Section 3-302(d) of
Executive Order 12856). Some recom-
mended goals might include the following:
• Reductions in the release and use of
toxic and extremely hazardous chemi-
cals at your facility (see Executive
Order 12856)
• Reductions in the release and use of
other pollutants as identified by your
agency's pollution prevention strategy
• Reductions in the unnecessary pur-
chase of toxic and hazardous chemi-
cals (see Executive Order 12873)
• Affirmative procurement practices to
ensure the purchase of recycled con-
tent materials as directed by EPA (see
Executive Order 12873)
• Increases in the volumes of materials
captured for recycle
• Reductions in the generation of solid
wastes
• Reductions in the consumption of
materials, water, and power (see
Executive Order 12902)
• Reductions in the use and release of
toxic chemicals to environmental jus-
tice areas where socioeconomic fac-
tors are of concern (see Executive
Order 12898).
EPA is currently developing guidance on
specific pollution prevention approaches
that can be used by agencies and facili-
ties in meeting their 50 percent reduction
goals.
By setting goals, you will define the na-
ture of the pollution prevention program
and direct its initial efforts toward a quan-
tifiable objective. As you develop the
facility pollution prevention plan, you
may identify new goals or modify original
goals. Be sure to document and publicize
any major changes to the program goals.
Step 2: Obtain Management
Commitment
The next step is obtaining a commitment
from upper management. When man-
agement is committed to pollution pre-
vention, the development (and imple-
mentation) of the program plan proceeds
more smoothly. As with any new pro-
ject, obtaining management support for
pollution prevention involves providing
managers with the information they need
to make decisions. Managers should
understand the goals of pollution preven-
tion, the reasons for developing a pollu-
tion prevention plan (e.g., the Executive
Orders), and the elements of a pollution
prevention program. Most important,
the facility managers should understand
all of the potential benefits that they will
reap in developing and implementing a
pollution prevention program.
To obtain upper management commit-
ment, you have to sell the concept. To
do that, you have to convince managers
that a pollution prevention facility plan
will help the facility mission by:
• Improving compliance with all
applicable environmental require-
ments, regulations, and Executive
Orders
• Reducing operating costs with re-
spect to waste management and the
purchase of raw materials
• Reducing the facility's chances of
creating environmental contamina-
tion that may result in environmental
liabilities and large-scale cleanup
requirements
• Improving the productivity of staff by
providing a cleaner, healthier work-
ing environment through reduced use
of toxic materials
. Increasing efficiency through innova-
tive pollution prevention techniques
identified and implemented under the
pollution prevention program.
Once upper management agrees to
developing a facility plan, the facility
director should sign a formal policy
statement that expresses approval for the
plan. In addition to the policy statement,
upper management must provide the
authority for the environmental staff to
develop and implement the pollution
prevention plan.
Step 3: Build a Team
A pollution prevention program cannot
succeed without the support of all facility
staff. Therefore, the facility pollution
prevention plan should be developed by
facility staff who are led through the
process by the environmental personnel
responsible for the plan. EPA suggests a "
team approach in which various staff
support the planning and implementation
steps. Realize that various facility staff
should participate in the planning process
because they will ultimately be responsi-
ble for implementing pollution preven-
tion options.
The same staff will not necessarily sup-
port the planning process throughout the
effort. You will need assistance from
staff who understand and operate differ-
ent processes or missions at the facility.
You will draw on different facility per-
sonnel when characterizing their opera-
tions and defining pollution prevention
Obtaining the Right Kind
of Commitment
When briefing management on
the pollution prevention planning
process, be sure you obtain the
following:
.Authority to develop, implement,
and facilitate a facility-wide pollu-
tion prevention program.
• A policy statement that confirms
this authority and emphasizes
management's support for this
effort.
• Resources to initiate the program.
Be careful not to scare away man-
agement with expensive or man-
power intensive programs. Once
you have demonstrated the cost-
effectiveness of pollution preven-
tion, funding for projects will be
easier to obtain.
8
Section II: Facility Pollution Prevention Plan Development Steps
-------
A Successful
Model
Under the Tidewater Interagency
Pollution Prevention Program
(TIPPP) plan, Ft. Eustis Army
Transportation Center, Langley Air
Force Base, NASA Langley
Research Center, and Naval Base
Norfolk in the Tidewater, Virginia,
area have joined together to
address pollution prevention
issues at the community level. The
four facilities worked with EPA and
the Commonwealth of Virginia to
develop a four-facility plan for
cooperative pollution prevention
projects and information sharing.
The plan described base-specific
and TlPPP-wide goals, as well as
efforts and approaches for meeting
pollution prevention targets identi-
fied under the 1990 Chesapeake
Bay Agreement. In addition, each
facility has developed its own pol-
lution prevention plan that is inte-
grated with the TIPPP plan and
focuses on facility-specific issues.
The TIPPP provides a model for
planning across a variety of facili-
ties and issues. In the long-term,
the planning conducted for the
TIPPP allowed the program to
achieve desired goals and to
demonstrate the utility of commu-
nication among facilities within a
geographic region.
Issue the Policy
\.
Create
Incentives
Enlist
Mid-Management
support
Establish an
Oversight Group
Choose Staff for
Baselining and
I Opportunity
Assessment
Activities
Building a Team
options that apply to them. You should
also enlist staff who support the entire
facility, including maintenance engineers,
supply staff, and health/safety personnel.
These staff will be invaluable in defining
facility-wide characteristics and pollution
prevention opportunities.
To ensure that the right staff are available
when needed, EPA suggests a team build-
ing approach that relies on education and
flexibility so that facility staff can partici-
pate when needed. The following types
of activities may support you in building
a personnel pool that you can rely on
throughout the development and imple-
mentation stages.
Issue the Policy Statement
All staff should have access to the pollu-
tion prevention policy. At first, this doc-
ument will serve as the license for the
pollution prevention planning and imple-
mentation process. Everyone should
know that it exists and what is says.
Enlist Middle Management Support
To ensure program success, it is critical
that middle managers understand and
support the initiative. You will have to
convince them that the pollution preven-
tion program will help make their lives
simpler with respect to the environment.
You will be relying on their good will
and access to information so it is critical
to enlist their support. Provide them with
the policy statement, a description of pol-
lution prevention, the benefits of pollu-
tion prevention, and how they can sup-
port the effort.
Establish an Oversight Group
The oversight group is a team of individ-
uals who will help to develop and imple-
ment the program. This team will be
responsible for:
• Developing the facility pollution pre-
vention program plan
• Encouraging staff participation in the
planning and implementation of the
program
• Monitoring the program as it develops
• Acting as advocates for the pollution
prevention program
• Publicizing the program.
Team members should be chosen from
all areas of the facility and should in-
clude both supervisors and shop-level
employees. Although the team may con-
sist of several members, the environmen-
-------
Pollution Prevention Team
Members
• Environmental coordinator
• Facility director
• Senior management
• Public affairs department
• Shop personnel
Developing A Team
Approach
The U.S. Coast Guard at Governor's
Island has several tenant facilities
that were managing environmental
issues independently. Each tenant
command, therefore, was manag-
ing its own wastes. In developing
pollution prevention alternatives,
the different tenant organizations
worked together to develop and
exchange innovative pollution pre-
vention options and approaches.
This team approach resulted in
information sharing and coopera-
tion not only on pollution preven-
tion approaches but also on future
waste management practices.
tal coordinator may be responsible for
leading the oversight group.
Select Stafffor Baselining and
Opportunity Assessment Activities
As you begin to develop a baseline and
conduct opportunity assessments, you
should identify and enlist the help of
staff who work in areas where wastes are
generated. These staff will support you
in defining the operations for the facility
baseline and in developing pollution pre-
vention alternatives. In using this
approach, your baselining and opportuni-
ty assessment team will change as you
move through the facility. Each opera-
tion will have staff who are familiar with
your activities and may be willing to
help once implementation occurs.
Publicize tile Program
You must have cooperation from facility
staff. If they will not participate, you
may never accomplish anything other
than the initial planning effort.
Publicizing the program can be difficult
depending on the size of the facility and
staff attitudes concerning the environ-
ment. To publicize the program, the
oversight group can hold public forums
to discuss the program. You might also
distribute brochures or factsheets to all
staff through the mail or electronic bul-
letins. Starting a new environmental or
pollution prevention newsletter might
help as well. Again, the goal of the pub-
licity program is to clearly demonstrate
management commitment to the pollu-
tion prevention program.
Create Employee incentives
Nothing will encourage facility staff to
participate like financial or recognition
incentives. Employee incentives for par-
ticipating in the pollution prevention pro-
gram definitely capture people's atten-
tion. Many facilities offer bonuses or
other awards to employees who suggest
viable ways to prevent pollution.
Announcing the incentives program in
conjunction with the publicity effort will
spark interest and participation. If your
agency has a suggestion program or other
financial compensation programs, you
might use these to reward good ideas and
participation.
Step 4: Develop a Baseline
Executive Order 12856 (Section 3-304)
requires all Federal facilities to comply
with the Toxic Release Inventory (TRI)
reporting requirements under Section 313
of the Emergency Planning and Com-
munity Right-to-Know Act (EPCRA).
As explained in Section 2-207 of
Executive Order 12856, these additional
toxic pollutants may include "extremely
hazardous chemicals" as defined in
Section 329(3) of EPCRA, hazardous
wastes as defined under the Resource
Conservation and Recovery Act (RCRA)
of 1976 (42 U.S.C. 6901-6986), or haz-
ardous air pollutants under the Clean Air
Act Amendments (42 U.S.C. 7403-7626).
For the purposes of establishing the base-
line (under 3-302(c)), "other chemicals"
are in addition to (not instead of) the
Section 313 (TRI) chemicals. This
means that facilities must not only deter-
mine which TRI chemicals they use and
release at or above the thresholds estab-
lished under EPCRA but also have to
quantify the use and release of other
"extremely hazardous chemicals" in
developing their pollution prevention
plans. Facilities may choose to highlight
this TRI reporting and related reductions
in the individual facility pollution pre-
vention plans required by Section 3-
302(d) of this Executive Order.
The chemical usage and release baseline
required for TRI reporting is the first step
in developing a facility baseline. These
data are the minimum data needed for a
hazardous material usage and release
baseline. Such data, however, will not be
the only useful information for develop-
ing a facility pollution prevention plan
that addresses all environmental issues
and costs.
Developing an environmental baseline
involves building a comprehensive pic-
ture of the materials usage patterns and
environmental impacts associated with
the facility. To develop a complete base-
line, you will have to collect various
information and assimilate it into a uni-
10
Section II: Facility Pollution Prevention Plan Development Steps
-------
fied, multimedia description of your
facility's environmental impacts. The
baseline will define materials usage pat-
terns and the environmental problems
that arise from these usage patterns. To
obtain this information, you will search
and review data with the operations staff
who are tasked to support this effort.
Specifically, each waste generating oper-
ation should have one point of contact
who can provide baseline statistics that
represent that operation.
You can use the information gathered in
several ways to describe the impacts cre-
ated by onsite activities. In many cases,
you may have to calculate or estimate the
exact impacts by using a material balance
calculation. The volumes of chemical
releases are calculated by quantifying the
amounts of materials used and the known
amounts of waste generated. This
method assumes that all material used
will either be used in the product,
become a waste, or be released into the
environment. The mass balance is a sim-
ple way to account for all material that
comes into the facility.
Pollution prevention can begin when
materials enter the facility. Therefore,
the baseline development process begins
with the purchasing and supply depart-
ments. You and your pollution preven-
tion team should determine who is
responsible for purchasing and handling
raw materials. Does one person order
everything in a tightly controlled system,
or can many people order materials for
their sections' needs or their own needs?
How does the supply system track, store,
and distribute the new materials?
Developing a baseline of purchasing
information also involves quantifying the
amounts and costs of the materials pur-
chased and distributed, as well as identi-
fying the locations and processes where
they are being used.
With the materials purchasing, handling,
and usage information collected, one-half
of the puzzle is complete. The other half
focuses on identifying waste generation
and environmental releases from the
facility. What products or services are
being conducted at the facility that con-
sume materials? What wastes and pollu-
tants are being generated by the use of
the materials, what processes are generat-
ing these wastes and pollutants, and what
are the volumes and characteristics of the
wastes being generated? In addition, you
Characterize Material
Purchase and Use
Identify and Quantify
Waste Generation
Assess Environmental
impacts
Characterize
environmental
damage
Associate damages
to activities and
process
Quantify waste
generation and
environmental
release
OmOKUe
standard operating
procedures for
Quantify amounts
ot material
disposed of
without use
The Baseline
Development
Process
Keys to Success in
Developing a Baseline
In developing a baseline, it is cru-
cial to involve all appropriate staff.
The baseline is the foundation of
the pollution prevention program.
Everyone who generates waste or
creates an environmental impact
must be included in the beginning.
Key personnel include:
.Environmental coordinator and the
baseline development team
.Hazardous waste collection site
personnel
. Waste generators
.Purchasing department
. Supply department
• Public works department
.Environmental program staff
. Safety program staff.
Data will be inconsistent or non-
existent. Your most difficult chal-
lenge will be collecting enough
information to prepare the baseline.
To simplify the data collection
process, be sure to:
• Educate staff on what information
is needed and why.
• Carefully document data/informa-
tion and manage it for easy
retrieval.
• Do not be shy; conduct interviews
with facility staff and ask questions.
Oftentimes, staff are the only
source of accurate data and infor-
mation.
* Be resourceful; you and your team's
observations and analysis may be
the only way to evaluate specific
operations.
-------
should understand how wastes are man-
aged following their generation, what
problems are associated with the man-
agement or mismanagement of these
wastes, and how they are disposed of.
You should also identify the costs associ-
ated with waste handling activities and
whose budget pays for these costs.
At this point, the puzzle might appear
finished, but the borders are still missing.
The borders consist of the facility's nat-
ural resources and land use. You and
your team should investigate how facility
activities affect the external environment.
What are the impacts of these activities
on the natural resources and land, not
only on the facility's property but beyond
its borders? Stormwater runoff, ground-
water contamination, and air emissions
are examples of the environmental effects
that might be characterized in your base-
line.
Remember that the reason you are devel-
oping a baseline is to assess pollution
prevention opportunities that might be
taken to reduce environmental impacts,
waste generation, and costs. When you
begin to collect baseline data, you will
observe operations and review data. As
part of this process, you may identify
pollution prevention opportunities. You
should document these opportunities and
incorporate them into your facility pollu-
tion prevention plan.
The baselining effort may require signifi-
cant effort over a long period of time.
The size of your facility, the number of
waste generating processes, and environ-
mental program staffing may make the
baselining task a timely effort. Base-
lining should be a continuous process.
You should develop an initial baseline
within your time and staff constraints and
build it over time. If you must gradually
develop a baseline, start with the process-
es that you know create your most seri-
ous environmental problems and proceed
from there. For example, you can use
your TRI reporting data as your initial
facility baseline. Over time, you can
expand these data to include other chemi-
cals and environmental impacts.
Baselining is a critical effort that should
continue from this point forward. Base-
lining is the process of documenting
environmental impacts, associating them
Material Balance for Defining Usage Patterns
with facility activities, and compiling
records into an accessible information
base. The table on pages 14 and 15 iden-
tifies many types of information that
might be useful in developing your facili-
ty environmental baseline.
Step 5: Conduct Pollution Prevention
Activities and Opportunity
Assessments
Under Section 3-302(d) of Executive
Order 12856, you are required to identify
pollution prevention activities and con-
duct opportunity assessments as part of
your pollution prevention plan, Specific-
ally, Section 3-302(d) states that "Fed-
eral agencies shall conduct assessments
of their facilities as necessary to ensure
development of such plans and of the
facilities 'pollution prevention programs. "
Using the baseline data, you can identify
potential pollution prevention activities
and opportunities. For example, the
baseline may indicate that water usage is
a critical issue for a facility. If water is a
critical issue, what activities can be initi-
ated to reduce usage, waste, and overall
cost? For every issue documented under
the baseline, the team should identify
activities that will promote pollution pre-
vention. In general, these activities will
include the following:
• Additional Analysis—The baseline
may indicate that a process or envi-
ronmental impact is not fully under-
stood and that more complete infor-
mation or data are needed. To fully
characterize the problem, the staff
will have to conduct analyses, analyti-
cal measurements, or studies. Upon
completion of these analyses, the staff
will assess pollution prevention
opportunities.
• Immediate Implementation—The
baseline may provide applications of
existing pollution prevention strate-
gies, techniques, or technologies that
can be implemented immediately to
reduce environmental impacts. In
such cases, the facility may seek to
implement pollution prevention
options immediately.
12
Section II: Facility Pollution Prevention Plan Development Steps
-------
• Pollution Prevention Opportunity
Assessments—The baseline may also
show that processes may be amenable
to pollution prevention options. To
define the best option, the staff should
conduct a thorough pollution preven-
tion opportunity assessment. Execu-
tive Order 12856 requires all Federal
facilities to conduct opportunity
assessments (as needed) to develop
their facility pollution prevention
plan. Several manuals (referenced in
Section III) can be used to conduct
pollution prevention opportunity
assessments. Page 16 provides a gen-
eral summary of the assessment
process.
Focus your initial effort on the pollution
prevention activities that affect processes
responsible for the environmental issues
or impacts of greatest concern. Setting
priorities requires weighing different
objectives, such as toxic use reduction,
cost reduction, or water use minimiza-
tion. Each facility will have its own
objectives depending on its overall pol-
lution prevention goals and site-specific
conditions (see Step 6 below).
Your facility pollution prevention plan
should include a list of all of the pollu-
tion prevention activities and opportuni-
ties identified in this step. The facility
pollution prevention plan will eventually
act as a road map that ties together all of
the additional analyses with the immedi-
ate implementation and opportunity
assessment activities. As activities are
completed or new ones identified
through pollution prevention opportunity
assessments, the list of prevention activi-
ties will change.
Step 6: Develop Criteria and
Rank Facility-Wide Pollution
Prevention Activities
By this time, you have a list that de-
scribes hundreds of pollution prevention
activities. The next step is to develop
priorities and rank the activities. That is,
develop a list of action items that you
The recognized need to prevent pollution
based upon the baseline facility
Planning and Organization
• Organize assessment program team
Assessment
organization and
commitment to
proceed
Assessment Phase
• Collect process and facility data
•Prioritize and select assessment targets
• Select people for assessment teams
. Review data and respect sile
• Generate options
• Screen and select options for further study
Assessment report
of selected options
Final report,
including
recommended
options
Select new
assessment
targets and
reevaluate
previous options
Feasibility Analysis Phase
. Technical evaluation
• Economic evaluation
• Select options for implementation
Implementation
«Justify projects and obtain funding
• Install equipment
• Implement procedure
• Evaluate performance
Successfully implemented
pollution prevention projects
Procedure for Pollution Prevention Opportunity Assessments
and facility staff will undertake to inte-
grate pollution prevention into your
facility's activities. The order in which
you choose to initiate pollution preven-
tion activities and projects depends upon
facility-specific considerations and envi-
ronmental goals. These considerations
will be used to rank all of the pollution
prevention activities identified previous-
ly. The following considerations are
commonly used to rank such activities:
.Environmental Compliance—The
project's impact on improving the
facility's overall environmental com-
pliance status. Section 3-30 l(b) of
Executive Order 12856 places special
emphasis on identifying and imple-
menting pollution prevention projects
that improve compliance.
Mission Impact—The project's
potential impact on the facility's mis-
sion and the ability of the staff to
accomplish their mission.
Environmental Benefits-The pro-
ject's environmental benefits (e.g., air
emission reduction, hazardous waste
minimization).
Ease of Implementation—Complex
changes that require additional staff
effort may not be accepted as easily
as simpler changes.
Cost Savings—The potential cost
savings associated with project im-
plementation. Pollution prevention
techniques that result in improved
efficiency and cost savings are usual-
ly accepted more readily than options
that result in increased costs.
13
-------
Types of Information for Developing an Environmental Baseline
Information Type
Material Usage for Hazardous and
Nonhazardous Materials of Concern
Components of Materials Used at the
Facility
Power Usage and Water Consumption/
Disposal Statistics for Each Activity at
the Facility
Facility Designs
Uses
Identifying and quantifying use of target
materials at the facility
Defining the usage patterns of the activi-
ties resident to the facility
Performing mass balance estimations of
environmental releases facility-wide and
activity-specific
Determining whether or not the facility
meets Toxic Release Inventory reporting
thresholds for chemicals of concern
Developing a list of materials and prod-
ucts used at the facility that must be eval-
uated to identify which contain hazardous
components, including the EPA 17 chemi-
cals of concern
Identifying the use of specific hazardous
components, such as the EPA 17 chemi-
cals of concern or extremely toxic materi-
als
Determining where chemical substitute
analyses may be needed
Documenting how utilities are used to
identify opportunities to reduce usage
Identifying greatest contributors to sew-
ered, aqueous wastes
Verifying the location of storm sewer and
sanitary sewer inlets and outfalls
Verifying the location of and drainage to
all oil/water separators
Understanding the flow of stormwater and
surface water to determine potential
impacts
Locating underground and above ground
storage tanks
Locating washracks and suitable sites for
washing activities
Documenting the sewer system and
design of the wastewater treatment facili-
ties (if present)
Sources
Supply function files and/or data
systems; material purchasing, requisi-.
tion, and manifesting records often
important
Activity requisition records (if kept or
complete)
Warehouse material inventory records
Facility material inventory records
Direct observation of use patterns and
practices through onsite facility
assessments
TRI (Form R) report
Materials Safety Data Sheets (MSDS)
kept at each of the activities and by the
Health and Safety Office; on-line MSDS
systems maybe useful in cases where
materials identified but sheets are not
available
Equipment specifications
Utility usage statistics
Building meters
Onsite observation and estimation of
non-metered uses based on rough
measurement (flow over time)
Engineering facility records and maps
Facility master planning documents
Construction records
Corps of Engineers maps and records
if facility built or modified by the Corps
Onsite characterization of facilities and
processes
14
Section II: Facility Pollution Prevention Plan Development Steps
-------
Types of Information for Developing an Environmental Baseline (continued)
Information Type
Hazardous Materials and Waste Handling
Procedures
Solid Waste Management Procedures
Solid and Hazardous Waste Generation
and Disposal Statistics
Regulatory Operating Parameters
Environmental Impacts
Uses
identifying materials management
practices that result in wastes
Identifying waste management prac-
tices that result in releases of chemi-
cals to the environment
Defining practices that inhibit segrega-
tion and recycling of wastes
Identifying practices that result in com-
pliance problems
Identifying opportunities for recycling
Creating plans for comprehensive recy-
cling projects
Developing the waste generation base-
line that will be used to measure suc-
cess in attaining prevention goals
Developing priorities for conducting
initial facility and process-specific facil-
ity assessments
Quantifying the costs associated with
hazardous waste management to help
create cost justifications for prevention
projects
Quantifying the costs associated with
solid waste generation and disposal to
develop programs that are more cost
effective and comprehensive
Identifying the potential for alternative
waste management practices, including
comporting and waste exchange/sale
Defining release rates of regulated
materials to the air, water, and soils
Identifying wastes associated with
facility activities
Identifying compliance issues that are
often the highest priority considera-
tions for the facility managers and
environmental staff
Providing a summary of environmental
impacts caused by the facility
Identifying and quantifying the impacts
that may arise from land management
activities
Sources
Standard operating procedures for haz-
ardous materials and waste handling and
management activities
Mission statements
Equipment specifications
Spill prevention and management plans
Onsite observation of hazardous material
and waste management practices
Permits
Waste management contracts
Recycling program statements or plans
Onsite observation of solid waste man-
agement practices as implemented by
residents and staff
Facility and process flow diagrams
Waste management contracts and billing
statements
Hazardous materials shipping manifests
Existing hazardous waste tracking sys-
tems
Facility records and files on waste gener-
ation
Facility-wide waste estimation surveys
Supply system records as input to mass
balance estimations
TRI (Form R) reports
Water discharge permits
City sanitary discharge permits
Air permits
Hazardous waste storage permits
Environmental compliance audit reports
Land and facility management plans
Environmental assessments and impact
studies (National Environmental Policy
Act documents)
15
-------
Key Information About Pollution Prevention Opportunity Assessments
Pollution Prevention Opportunity
Assessments
The pollution prevention opportunity
assessment is one of the most important
activities that you will perform in the plan-
ning and implementation of your facility
pollution prevention program. The oppor-
tunity assessment is a tool used to define
the specific characteristics of a single
operation that creates environmental
impacts (e.g., wastes, releases of toxic
chemicals to the environment, power/
water usage, habitat destruction),
Specifically, the pollution prevention
opportunity assessment is a systematic
evaluation of processes and operations to:
.Characterize all aspects of the process
or operation, including process flow,
waste generation patterns, material
and power consumption, costs, man-
power, reliance on toxic chemicals
• Define the impacts that the process
and related wastes have on the air,
water, and land
.Associate impacts and wastes with
specific unit operations
.Assign related costs and liabilities with
specific wastes and management prac-
tices.
This detailed process information is used
to identify, refine, and plan the implemen-
tation of pollution prevention technologies
that will reduce the environmental impacts
associated with the process.
Pollution prevention opportunity assess-
ments are performed after the baselining
activity. An opportunity assessment can
be performed anytime after the baseline is
developed to augment baseline data.
Hence, opportunity assessments can be
performed as part of the planning process
or anytime after the planning process.
EPA recommends that detailed, process-
specific opportunity assessments be per-
formed after completion of the facility pol-
lution prevention program plan so that
environmental staff can develop priorities
in conducting opportunity assessments
for all candidate operations. Complete the
facility plan before initiating the detailed
pollution prevention opportunity assess-
ments.
Common Pollution Prevention
Opportunities
When conducting an opportunity assess-
ment, it is important to consider all types
of activities. While it may be easier to
focus on source reducing technologies,
you may be ignoring inexpensive and easy
fixes that can result in significant reduc-
tions that arise from procedures or policy
modifications. Training and awareness
may also yield significant reductions.
Training an equipment operator to proper-
ly operate a machine or increasing worker
awareness about a particular procedure
may eliminate an environmental or cost
concern. All of the following types of
activities may reduce environmental
impacts:
• Policy changes
• Procedural changes
• Equipment modifications
• Material substitution
• Training
• Efficiency improvements
• Waste stream segregation
• Housekeeping practices
• Inventory control
• Reuse of materials.
A pollution prevention opportunity
assessment should consider any of these
options as a potential approaches to
meeting environmental goals.
Keys to Success in Conducting
Opportunity Assessments
The following approaches will facilitate
your opportunity assessment:
• Solicit assistance and input from staff
who operate the process. They are the
experts.
• Build consensus among staff on the
best pollution prevention options for
their processes. If they do not agree,
they will not implement changes.
• Explain what you are doing. The staff
you are helping with an assessment
will have to implement the opportuni-
ties identified.
• Explain why the assessment is impor-
tant to all staff involved.
• Do not rule out any options until you
have actually considered the merits
and potentials (see Steps 5 and 6).
• Do not rush. If you have to go back for
more information, do so.
• Use information sources, data sys-
tems, and technical assistance services
to generate ideas (see Section III).
The most common problem arises when
process staff do not understand why you
are asking so many questions. You need
their help, so solicit their participation by:
.Explaining what you are doing and why
.Asking for their input
.Building consensus
• Being considerate of their other duties
• Giving examples of how pollution pre-
vention will make their jobs easier.
Rememberjou cannot do this alone. The
staff who generate the waste will ultimately
have to reduce it. They must be involved
from the very beginning. To assist you in
conducting opportunity assessments, EPA
has published several manuals that describe
assessment techniques. Section III provides
references for these documents.
16
Section II: Facility Pollution Prevention Plan Development Steps
-------
Other criteria that you may consider
include the availability of disposal
capacity, community concerns, environ-
mental justice goals, worker safety/expo-
sure, anticipation of future regulations,
and resource consumption.
After you have identified ranking crite-
ria, you should rank all pollution preven-
tion activities identified on a numerical
scale by assigning a value that reflects
how the activity matches each criterion.
The highest ranking activity (i.e., the
opportunity with the highest total score)
should be considered first for implemen-
tation. Often, one criterion is considered
to be more important than the others. In
such a case, a weighting factor can be
used. Further information on ranking
schemes is presented in the guidance
documents listed in Section III.
Example of a Ranking Matrix Used at a U.S.
Postal Service Facility
Criteria Water-Borne High-Volume Low- Gun Washer
Coating Pressure Spray
_
Reduction in Occupational Hazard
Reduction in a RCRA-Regulated Waste
Reduction of a 33/50 Program Chemical
Reduction of Environmental Impact
Capital Cost
Ease of Implementation
TOTAL
_ .
5
5
5
4
3
2
24
Gun
5
5
5
4
4
2
25
Station
5 -
4
4
2
2
3
20
5 = very positive, 4 = positive, 3= neutral, 2= negative, 1 = very negative
Step 7: Conduct a Management
Review
Once the pollution prevention team has
developed a ranked list of pollution pre-
vention activities, you should obtain
upper management and senior staff sup-
port. This is an important opportunity
for upper management to reaffirm its
support for the pollution prevention pro-
gram. To do this, you should convene a
management review committee to
review your facility pollution prevention
plan. The management review commit-
tee should include representatives from
all of the organizations that will be
affected by the pollution prevention
program.
During management review, the pollu-
tion prevention team should present the
ranked list of activities for approval.
You should explain the process used to
develop the list and emphasize the
potential benefits of the effort. Upper
management must understand the rela-
tionship between the pollution preven-
tion program activities and their impacts
on the facility mission and existing envi-
ronmental programs. The end product of
this review should be a coherent, inte-
grated pollution prevention program that
supplements other facility programs
(e.g., health and safety, environmental
compliance, training, and development).
By providing this information, you will
allow upper management to make
informed decisions from a program-wide
perspective about prioritizing pollution
prevention projects, developing an
implementation schedule, and providing
funding. If additional resources are
needed for establishing the pollution pre-
vention program (e.g., staff positions),
they should be requested at this point.
You now have a management-approved
pollution prevention plan for your facili-
ty. The next steps focus on getting your
program started. It is important to real-
ize that the following steps may proceed
simultaneously. In addition, you may
find that the facility pollution prevention
plan changes once you start learning
more and conducting additional assess-
ments. Be flexible and willing to modify
the plan as you proceed.
PUBLIC PARTICIPATION
Executive Order 12856 requires facilities
to provide the public with access to their
pollution prevention plans and pro-
grams. Specifically, the Executive
Order requires facilities to provide pub-
lic access to their facility pollution pre-
vention plans and encourages facilities
to include public participation in the
facility planning process. Under
Section 508 of Executive Order 12856,
Federal facilities should:
• Maintain a copy of their pollution
prevention plans onsite for review by
their host agencies, EPA, and State
regulators.
• Provide their facility pollution pre-
vention plans to EPA or States upon
request but should not submit the
plans directly to EPA.
• Readily allow and encourage public
access to their facility pollution pre-
vention plans and all supporting data.
Under Section 301 of Executive Order
12856, Federal facilities should also
involve the public in developing all
facility pollution prevention plans and
programs. In doing so, Federal facilities
will foster a cooperative environmental
protection approach within their com-
munities.
17
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MEASUREMENTS OF
PROGRESS
Executive Order 12856 requires agencies
and facilities to report on their efforts to
reduce the release of hazardous and
extremely toxic materials to the environ-
ment. Specifically, the Order requires
facilities and agencies to report on their
progress in accomplishing their 50-percent
reduction in the use and release of
extremely toxic (i.e., TRI) chemicals.
Therefore, it is critical that you establish
mechanisms to measure the impacts of
pollution prevention activities on waste
generation and environmental releases of
chemicals. The impacts should be mea-
sured and reported in comparison to the
facility-wide baseline (Step 4).
Measuring progress in achieving pollution
prevention goals is part of an on-going
process that starts with the official ribbon
cutting ceremony. It can be thought of as a
self-auditing process that enables the facili-
ty to measure the program's development
as it grows. By carefully monitoring pro-
gram development, the pollution preven-
tion team can make the necessary adjust-
ments and, thus, be certain that each pollu-
tion prevention dollar is being spent wisely.
Measurement activities occur at two lev-
els—the program level and the project
level. Each level entails a slightly different
approach. Program-level measurement
involves a constant process of evaluation
and feedback that should occur after the
initial program has been established.
Milestones should be built into the project
implementation schedule, which is sub-
mitted during the initial management
review. The evaluation process may
reveal the need for further data collection
or adjustment of the scope of the pro-
gram's goals and objectives. Additional
funding and staff resources may be
required for implementation to proceed
according to schedule.
Measurement at the project level is more
specific. Each project should be evaluated
against the facility baseline data to deter-
mine how successfully it is accomplishing
its intended purpose. For instance, the
environmental coordinator needs to know
if a newly installed piece of equipment has
met expectations that it will reduce waste
generation by a certain percentage and
save on disposal costs. Regardless of
whether the waste volumes turn out to be
lower or higher than expected, the coordi-
nator should have this information. Other
parameters used for evaluating project
success are reductions in the following
areas:
.Environmental compliance violations
. Material losses
.The number of materials purchased
requiring Material Safely Data Sheets
.The number of worker sick days
resulting from occupational exposure.
The pollution prevention team should
develop a project tracking system for
monitoring projects. The complexity of
the system depends on the number and
type of projects being implemented. The
team should work closely with other staff
in the environmental department to avoid
collecting the same data twice. Informa-
tion collected as part of program monitor-
ing may be useful for complying with
environmental reporting requirements.
As a result of the evaluation process, the
pollution prevention team can apply
lessons learned to future projects and pre-
vent the same mistakes from being repeat-
ed. The team should also establish a for-
mal mechanism for reporting the results of
the pollution prevention program to man-
agement, as well as to the facility commu-
nity at large. Keeping management inter-
ested in the program's achievements
encourages continued funding for future
initiatives. Keeping the facility personnel
interested increases cooperation and
enthusiasm.
IMPLEMENTATION OF THE
PLAN
The facility planning requirements under
Executive Order 12856 were established
to encourage Federal facilities to develop
pollution prevention programs. As such,
developing a facility-wide pollution pre-
vention program plan is only a beginning.
The facility pollution prevention plan only
identifies activities that should help to
integrate pollution prevention into your
facility's mission. The real effort begins
once the plan has been finalized. At that
point, you and your co-workers must .
translate the facility pollution prevention
plan into activity. If not, the facility pollu-
tion prevention plan will become just
another study.
To get the program off to a fast start, you
should select a few low-cost, high-profile
pollution prevention projects for immedi-
ate action. To support you in conducting
cost-benefit analyses to justify projects,
EPA developed the Costing and Life Cycle
Analysis for Pollution Prevention Invest-
ments manual. This manual provides
guidelines for conducting financial evalu-
ations of pollution prevention options (see
Section III).
The results of these initial projects can
demonstrate the utility and effectiveness
of pollution prevention in meeting envi-
ronmental quality standards. Moreover,
these initial projects can be used to build
support for the pollution prevention pro-
gram. Once the pollution prevention pro-
gram demonstrates waste reductions and
cost savings, it will gain legitimacy, sup-
port, and interest. Various organizations at
your facility may want to pursue pollution
prevention alternatives once your initial
efforts demonstrate savings and reductions
in waste and pollution.
By developing a pollution prevention
plan, each Federal facility will meet
Executive Order 12856 planning require-
ments. In implementing its plan, each
Federal facility will improve its environ-
mental program and contribute to its
agency-specific reduction goals, also
required under Executive Order 12856.
Ultimately, through its pollution preven-
tion plan, each facility will have the
opportunity and mission to demonstrate
environmental stewardship that will bene-
fit the Federal government and the
nation as a whole.
18
Section II: Facility Pollution Prevention Plan Development Steps
-------
Measuring Progress and Success
Measuring the progress and success of pollution prevention activities is critical at both the programmatic and project levels. By
measuring the progress of each project, the facility can determine the success of the program as a whole. To measure the suc-
cess of projects and the program you should undertake the following initiatives:
• Establish Milestones—The pollution prevention program and each individual project should be designed to accomplish mile-
stones over a measurable amount of time. Milestones for the program maybe conducting opportunity assessments, providing
staff training, and reducing wastes. Milestones for projects might include conducting an opportunity assessment, choosing a
pollution prevention option, purchasing equipment, and reducing environmental releases of toxic chemicals by a known per-
centage overadefined period of time. Every pollution prevention activity should include defined milestones for tracking
progress and success.
• Identify Measurement Criteria—Each pollution prevention project should include measurable variables that define success.
This might include pounds of chemicals eliminated from disposal (assuming the same level of activity) or the percentage of
paper used that contains recycled content. Forevery project, specific target measurements areneeded toobjectively evaluate
the progress or success of the effort.
• Identify Data and Information Requirements—For each measurement criterion, you should define the data needed to adequately
represent thedefined standard, information requirements might include waste generation statistics, chemical release rates,
chemical loss rates, chemical use rates, production rates, costs, power and water usage statistics, and other types of informa-
tion.
• Develop a System to Compile and Track Information and Data—A computer data base or spread sheet system might be useful
in compiling data. If measurement criteria require data manipulations or calculations, a computer spread sheet program will
facilitate tracking. For example, a measurement criterion might be a ratio of waste generated to the level of production or activi-
ty. Therefore, you would collect waste generation and production data amied to calculate a simple ratio. A computerized
system may be helpful (especially if you track numerous projects and criteria).
• Evaluate Data and Information—As you compile data and perform calculations, it is critical to review the projects and pro-
grams. These data will help to define program successes and failures. The data will also help identify additional activities that
will strengthen the pollution prevention projects and the facility-wide program.
Starting a Pollution Prevention Project
Unlike compliance requirements, pollution prevention options involve changing processes and activities that create wastes and
environmental impacts. Therefore, you must have the cooperation of the shop or facility staff. The following considerations
may play a critical role in initiating pollution prevention projects:
• Obtain approval for the pollution prevention project from your management and the management of the affected facility and
involve staff on defining the pollution prevention project. Develop and implement their ideas about the best reduction
approach.
• Enlist operational staff support. The facility staff will determine how well a pollution prevention option works. The staff must
understand and embrace the concept for success.
• Determine whether training is necessary so that the personnel understand the purpose of the project, the goals, and the crite-
ria for success. Staff should clearly understand the direct benefits of the project, such as reduced exposure to toxic chemi-
cals, less paperwork, and a cleaner environment.
• Determine whether policies or standard operating practices need to be modified.
• If a project requires purchasing equipment, network with other Federal facility coordinators or technical assistance programs
to learn what does and does not work. Remember to include installation costs when preparing the request for funding.
• Work with the Public Affairs Office to advertise the project once it is initiated and is reducing pollution. Be sure to recognize
all staff who are contributing to the project.
19
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SECTION III: TECHNICAL ASSISTANCE
AND LITERATURE
As you establish your pollution prevention program plan and implement
pollution prevention projects at your Federal facility, you may want addi-
tional ideas on approaches and solutions to specific problems. To assist
you in your efforts, various Federal agencies have developed guidance doc-
uments on ways to develop and implement pollution prevention programs.
These are identified below. In addition, some Federal and State agencies
provide direct technical assistance on pollution prevention topics and pro-
jects. Contacts for these assistance programs are listed in the pages that
follow,
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
POLLUTION PREVENTION
PLANNING DOCUMENTS
1. Federal Facility Pollution
Prevention: Tools for Compliance
EPA/600-R-94- 154
U.S. Environmental Protection
Agency (EPA)
Office of Research and Development
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
2. Pollution Prevention in the Federal
Government: Guide for Developing
Pollution Prevention Strategies for
Executive Order 12856 and Beyond
EPA/3 OO-B-94-007
U.S. EPA
401 M Street, SW(2261)
Washington, DC 20460
202-260-9801
3. Facility Pollution Prevention Guide
EPA/600-R-92-008
U.S. EPA
Office of Research and
Development
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
4. Costing and Life Cycle Analysis for
Pollution Prevention Investments:
A Practical User 's Guide to
Environmental Project Financial
Analysis at Federal Facilities
U.S. EPA
401 M Street, SW
Washington, DC 20460
202-260-9801
5. Pollution Prevention Directory
EPA/742-B-94-005
U.S. EPA
401 M Street, SW
Washington, DC 20460
202-260-9801
AGENCY GUIDANCE
DOCUMENTS
6. Navy Shore Installation Pollution
Prevention Planning Guide
Dec. # OPNAV-P45- 120-10-94
Office of Chief of Naval Operations
2000 Navy Pentagon
Washington, DC 20350
703-602-5334
7. U.S. Air Force Installation Pollution
Prevention Program Manual
United States Air Force
Air Force Center for Environmental
Excellence (AFCEE)
AFCEE/ESP
8106ChennaultRoad
Building 1161
Brooks AFB, TX 78235-5318
1-800-233-4356
8. Army Pollution Prevention
Plan Manual: A Guide for
Army Installations
Army Environmental Policy Institute
430 10th Street, Suite 5105
Atlanta, GA 30318
404-875-6813
21
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9. Guidance for Preparation of Site
Waste Minimization and
Pollution Prevention Awareness Plans
Department of Energy
1000 Independence Avenue, S W
Washington, DC 20585
301-427-1570
TECHNICAL ASSISTANCE
PROGRAMS
1. Pollution Prevention Information
Clearinghouse (PPIC)
U.S. Environmental Protection Agency
PM 211-A
401 M Street, SW
Washington, DC 20460
202-260-1023
The Pollution Prevention Information
Clearinghouse (PPIC) is dedicated to
reducing or eliminating industrial pollu-
tants through technology transfer, educ-
tion, and public awareness. It is a free,
nonregulatory service of the U.S. EPA
and consists of a repository of pollution
prevention information, a telephone ref-
erence and referral service, and a com-
puterized information exchange system.
2. Pollution Prevention Information
Exchange System (PIES)
EPA Systems Development Center
200 N. Glebe Road
Arlington, VA 22203
703-506-1025 (modem)
PIES is a free, 24-hour electronic net-
work accessible by personal computer
equipped with a modem. PIES consists
of message centers, bulletins, technical
data bases, case studies, and issue-spe-
cific conference listings.
3. Federal Agency Mini-Exchange
(FAME)
EPA Systems Development Center
200 N. Glebe Road
Arlington, VA 22203
703-506-1025 (modem)
FAME is a data base on the Pollution
Prevention Information Exchange System
that provides information on pollution
prevention/recycling efforts at Federal
facilities.
4. Defense Environmental Network and
Information Exchange (DENIX)
DECIM Office
Hoffman 2, Room 12S49
200 Stovall Street
Alexandria, VA 22332
1-800-642-3332
703-325-0002
DENIX is a Department of Defense com-
munications platform for the dissemina-
tion and exchange of environmental
information across all DOD components.
5. PRO-ACT
AFCEE
8106ChennaultRoad
Building 1161
Brooks AFB, TX 78235-5318
1-800-233-4356
210-536-4214
DSN 240-4214
PRO-ACT is an environmental informa-
tion clearinghouse and hotline provided
by the Air Force Center for Environ-
mental Excellence (AFCEE). PRO-ACT
services are provided free of charge to all
Air Force personnel.
6. Center for Environmental Research
Information (CERT)
Dorothy Williams
U.S. Environmental Protection Agency
Center for Environmental Research
Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
CERI serves as the exchange of scientific
and technical environmental information
produced by EPA in brochures, capsule
and summary reports, handbooks,
newsletters, project reports, and manu-
als.
7. Center for Waste Reduction
Technologies (CWRT)
Center for Waste Reduction
Technologies
American Institute of Chemical
Engineers
345 East 47th Street
New York, NY 10017
212-705-7407
CWRT was established in 1989 by the
American Institute of Chemical
Engineers to support industry efforts
in meeting the challenges of waste
reduction through a partnership with
industry, academia, and government.
8. The National Pollution Prevention
Roundtable
David Thomas
218 D Street, SE
Washington, DC 20003
202-543-7272
The Roundtable is a group of pollution
prevention programs at the State and
local level in both the public and acade-
mic sectors. The member programs are
engaged in activities including multi-
audience training and primary to post-
secondary pollution prevention
education.
9. Northeast States Pollution
Prevention Roundtable (NE
Roundtable)
Terri Goldberg, Program Manager
Northeast States Pollution Prevention
Roundtable/Northeast Waste
Management Officials' Association
85 Merrimac Street
Boston, MA 02114
617-367-8558
The NE Roundtable was initiated in 1989
by the Northeast Waste Management
Officials 'Association to assist State
programs, industry, and the public in
implementing effective source reduction
programs.
10. Pacific Northwest Pollution
Prevention Research Center
Madeline Grulich, Director
Pacific Northwest Pollution
Prevention Research Center
411 University Street, Suite 1252
Seattle, WA 98101
206-223-1151
The Pacific Northwest Pollution
Prevention Research Center is a non-
profit public-private partnership dedicat-
ed to the goal offurthering pollution pre-
vention in the Pacific Northwest.
22
Section III: Technical Assistance and Literature
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11 Waste Reduction Institute for
Training and Applications
Research, Inc. (WRITAR)
Terry Foecke
Waste Reduction Institute for
Training and Applications
Research, Inc.
1313 5th Street, SE
Minneapolis, MN 55414-4502
612-379-5995
WRITAR is designed to identify waste
reduction problems, held find their solu-
tions, and facilitate the dissemination of
this information to a variety of public
and private organizations.
12. Waste Reduction Resource Center
for the Southeast (WRRC)
Gary Hunt
Waste Reduction Resource Center for
the Southeast
3825 Barrett Drive
PO Box 27687
Raleigh, NC 27611-6787
WRRC was established to provide multi-
media waste reduction support for the
States of U.S. EPA IV (Alabama, Florida,
Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, and
Tennessee).
FEDERAL FACILITY
POLLUTION PREVENTION
CONTACTS
Department of Agriculture
William Opfer
Environmental Health Engineer
Department of Agriculture
PO Box 96090
Washington, DC 20090-6090
202-205-0906
Central Intelligence Agency
Larry McGinty
Chief, Environmental and Safety
Group/QMS
Central Intelligence Agency
Washington, DC 20505
703-482-4533
Department of Commerce
Jack Murphy
Environmental Compliance Officer
Office of Management Support
U.S. Department of Commerce
Room 6020
14th and Constitution Avenue
Washington, DC 20230
202-482-4115
Department of Defense
Mr. Andrew Perth
ADUSD/PP
Skyline 6, Suite310
5109 Leesburg Pike
Falls Church, VA 22041
703-756-2969
Economic Development
Administration
Dr. Frank Monteferrante
Senior Environmental Specialist
U.S. Department of Commerce
Herbert C. Hoover Building
Room 7019
Washington, DC 20230
202-482-4208
Department of Energy
Susan C. Weber
Waste Minimization Division
Office of Waste Management (EM-334)
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
301-903-1388
Food and Drug Administration
Dr. Naresh K. Chawla
Chief, FDA Safety Office (HFA-205)
Food and Drug Administration
7500 Standish Place
Rockville, MD 20855
301-594-1718
General Services Administration
Karone Peace
Safety and Environmental Division
Environmental Branch (PMS)
General Services Administration,
Room 4340
18th and F Streets, NW
Washington, DC 20450
202-501-3518
Department of the Interior
Connie Kurtz
Environmental Protection Specialist
Division of Hazardous Materials
Management
Department of the Interior, MS 2340-
MIB, Room 2349
Office of Environmental Affairs ,
1849 C Street, NW
Washington, DC 20240
202-208-7554
Department of Justice
Marvin Fink
Safety and Health Manager
Security and Emergency Planning Staff
U.S. Department of Justice, Room 6525
10th and Constitution Avenue, NW
Washington, DC 20530
202-514-5076
National Aeronautics and Space
Administration
Olga Dominguez
Environmental Management Division
National Aeronautics and Space
Administration
NASA Headquarters, Code JE
Washington, DC 20546
202-358-1093
National Oceanic and Atmospheric
Administration
I. Sam Higuchi, Jr.
Senior Environmental Compliance
Officer
National Oceanic and Atmospheric
Administration
SSMC-2/OA3X1 Room 4434
1325 East West Highway
Silver Spnng, MD 20910
301-713-0845
National Security Agency
Barbara Krupiarz
Project Manager, Pollution
Prevention Program
Environmental Service Division
National Security Agency, (APS- 13),
Room AT200
Department of Defense
9800 Savage Road
Fort Meade, MD 20755-6000
410-684-7305
23
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Postal Service
Bernie Denno
Environmental Specialist
U.S. Postal Service, Room 6830
475 L'Enfant Plaza, SW
Washington, DC 20260-2810
202-268-6014
Tennessee Valley Authority
Paul Schmierbach
Environmental Compliance Department
Tennessee Valley Authority
400 Summit Hill Drive
Knoxville, TN 37902
615-632-6644
Department of Transportation
Janet Krause
Environmental Engineer
Office of the Secretary
Department of Transportation
400 7th Street, SW
Washington, DC 20590
202-366-0038
Coast Guard
T. J. Granite, Environmental
Compliance and Restoration Branch
P2 and Recycling Coordinator
U.S. Coast Guard
USCG(G-ECV-IB)
2100 2nd Street, SW
Washington, DC 20593
202-267-1941
Federal Aviation Administration
Tom Halloway
Manager of Hazardous Materials
and Special Projects Staff
Federal Aviation Administration,
AEE-20
800 Independence Avenue, SW
Washington, DC 20591
202-267-8114
Department of the Treasury
William McGovem
Chief, Environmental Compliance
Division
Department of the Treasury
Treasury Annex
1500 Pennsylvania Avenue, NW
Washington, DC 20220
202-622-0043
Department of Veterans Affairs
John Staudt
Chief, Hazardous Materials
Management Division
Department of Veterans Affairs, 138C-4
810 Vermont Avenue, NW
Washington, DC 20420
202-233-7863
STATE POLLUTION
PREVENTION PROGRAMS
ALABAMA
Alabama Waste Reduction and
Technology Transfer (WRATT) Program
Daniel E. Cooper, Chief
Special Projects
Alabama Department of
Environmental Management
1751 Congressman William L.
Dickinson Drive
Montgomery, AL 36130
205-260-2779
ALASKA
Pollution Prevention Office
David Wigglesworth, Chief
Pollution Prevention Office
Alaska Department of Environmental
Conservation
PO Box O
Juneau, Alaska 99811 -1800
907-465-5275
Waste Reduction Assistance Program
(WRAP)
Kristine Benson
Alaska Health Project
1818 West Northern Lights Boulevard
Suite 103
Anchorage, AK 99517
907-276-2864
ARIZONA
Arizona Waste Minimization Program
Sandra Eberhardt, Manager
Pollution Prevention Unit
Arizona Department of
Environmental Quality
3033 North Central Avenue,
Room 558
Phoenix, AZ 85012
602-207-4210
ARKANSAS
Arkansas Pollution Prevention Program
RobertJ. Finn
Hazardous Waste Division
Arkansas Department of Pollution
Prevention and Ecology
PO Box 8913
Little Rock, AR 72219-8913
501-570-2861
CALIFORNIA
Department of Toxic Substances Control
Mr. Kim Wilheim
Department of Toxic Substances Control
Pollution Prevention, Public and
Regulatory Assistance Division
400 P Street
PO Box 806
Sacramento, CA 95812-0806
916-322-3670
Tony Eulo
Local Government Commission
909 12th Street
Suite 205
Sacramento, California 95814
916-448-1198
California Integrated Waste
Management Board
8800 Cal Center Dnve
Sacramento, California 95826
Recycling Hotline: 800-553-2962
General Public Information:
916-255-2289
COLORADO
Pollution Prevention and Waste
Reduction Program
Kate Kramer, Program Manager
Pollution Prevention Waste Reduction
Program
Colorado Department of Health
4300 Cherry Creek Drive South
Denver, CO 80220
303-692-3003
Michael Nemeck
Colorado Public Interest Research Group
(COPIRG)
1724 Gilpin Street
Denver, Colorado 80218
303-355-1861
24
Section III: Technical Assistance and Literature
-------
CONNECTICUT
Connecticut Technical Assistance
Program (CONNTAP)
Andrew Vecchio
Connecticut Technical Assistance
Program (ConnTAP)
Connecticut Hazardous Waste
Management Service
900 Asylum Avenue
Suite 360
Hartford, Connecticut 06105-1904
203-241-0777
Connecticut Department of
Environmental Protection
Liz Napier
Bureau of Waste Management
Connecticut Department of
Environmental Protection
165 Capitol Avenue
Hartford, Connecticut 06106
203-566-5217
DELAWARE
Delaware Pollution Prevention Program
Philip J. Cherry
Andrea K. Farrell
Pollution Prevention Program
Department of Natural Resources and
Environmental Control
PO BOX 1401
Kings Highway
Dover, DE 19903
302-739-5071/3822
Herb Allen
Department of Civil Engineering
University of Delaware
Newark, DE 19716
302-45 1-8522/8449
DISTRICT OF COLUMBIA
Office of Recycling
Evelyn Shields, Recycling Coordinator
D.C. Department of Public Works
65 K Street, NE
Washington, DC 20002
202-727-5887
George Nichols
Department of Environmental Programs
Council of Governments
777 North Capitol Street, NE
Suite 300
Washington, DC 20002-4201
202-962-3355
Kenneth Laden
Environmental Policy Division
D.C. Department of Public Works
2000 14th Street, NW
Washington, DC 20009
202-939-8115
Ms. Ferial Bishop, Administrator
Environmental Regulation
Administration
D.C. Department of Consumer and
Regulatory Affairs
2100 MLK Avenue, SE
Suite 203
Washington, DC 20020
202-404-1136
FLORIDA
Waste Reduction Assistance
Program (WRAP)
Janeth A. Campbell, Director
Waste Reduction Assistance Program
Florida Department of Environmental
Regulation
2600 Blair Stone Road
Tallahassee, Flonda 32399-2400
904-488-0300
GEORGIA
Georgia Multimedia Source Reduction
and Recycling Program
Susan Hendricks, Program Coordinator
Environmental Protection Division
Georgia Department of Natural
Resources
4244 International Parkway, Suite 104
Atlanta, GA 30334
404-362-2537
HAWAII
Hazardous Waste Minimization Program
Jane Dewell
Waste Minimization Coordinator
State of Hawaii Department of Health
Solid and Hazardous Waste Branch
Five Waterfront Plaza, Suite 250
500 Ala Moana Blvd.
Honolulu, HI 96813
808-586-4226
John Harder
Department of Health
Office of Solid Waste
5 Waterfront Place, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813
808-586-4373
IDAHO
Division of Environmental Quality
Joy Palmer
Katie Sewell
Division of Environmental Quality
Idaho Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83720-9000
208-334-5879
ILLINOIS
Illinois Hazardous Waste Research and
Information Center (HWRIC)
Dr. David Thomas, Director
Illinois Hazardous Waste Research
and Information Center
One East Hazelwood Drive
Champaign, IL 61820
217-333-8940
Office of Pollution Prevention
Mike Hayes
Illinois Environmental Protection Agency
Office of Pollution Prevention
2200 Churchill Road
PO Box 19276
Springfield, IL 62794-9276
217-785-0533
INDIANA
Office of Pollution Prevention and
Technical Assistance
Joanne Joice, Director
Charles Sullivan, Environmental
Manager
Office of Pollution Prevention and
Technical Assistance
Indiana Department of Environmental
Management
105 South Meridian Street
PO Box 6015
Indianapolis, IN 46225
317-232-8172
Indiana Pollution Prevention Program
Rick Bossingham, Coordinator
Jeff Burbrink, Agricultural Pollution
Prevention Coordinator
Environmental Management and
Education Program
2129 Civil Engineering Building
Purdue University
West Lafayette, IN 47907-1284
317-494-5038
25
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IOWA
Iowa Waste Reduction Center (IWRC)
John Konefes, Director
Kim Gunderson, Environmental Specialist
Iowa Waste Reduction Center
University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
Waste Management Authority Division
Tom Blewett, Bureau Chief
Scott Cahail, Environmental Specialist
Waste Management Authority Division
Department of Natural Resources
Wallace State Office Building
Des Monies, IA 50319
515-281-8941
KANSAS
State Technical Action Plan (STAP)
Tom Gross, Bureau Chief
State Technical Action Plan
Kansas Department of Health and
Environment
Forbes Field, Building 740
Topeka, KS 66620
913-296-1603
Kansas State University RITTA Program
Lani Himegarner, Program Manager
Engineering Extension Programs
133 Ward Hall
Kansas State University
Manhattan, KS 66506-2508
913-532-6026
KENTUCKY
Kentucky Partners - State Waste
Reduction Center
Joyce St. Clair, Executive Director
Kentucky Partners - State Waste
Reduction Center
Ernst Hall, Room 312
University of Louisville
Louisville, KY 40292
502-588-7260
LOUISIANA
Louisiana Department of
Environmental Quality
Gary Johnson, Waste Minimization
Coordinator
Louisiana Department of
Environmental Quality
P.O. Box 82263
Baton Rouge, LA 70884-2263
504-765-0720
MAINE
Maine Waste Management Agency
Gayle Briggs
Maine Waste Management Agency
State House Station 154
Augusta, ME 04333
207-287-5300
MARYLAND
Waste Management Administration
James Francis
Hazardous Waste Program
Waste Management Administration
Maryland Department of the
Environment
2500 Broening Highway,
Building 40 .
Baltimore, MD 21224
410-631-3344
Maryland Environmental Services
George G. Perdikakis, Director
Maryland Environmental Services
2020 Industrial Drive
Annapolis, MD 21401
301-974-7281
Technical Extension Service
Travis Walton, Director
Technical Extension Service
Engineering Research Center
University of Maryland
College Park, MD 20742
301-454-1941
MASSACHUSETTS
Office of Technical Assistance for
Toxics Use Reduction
Barbara Kelley, Director
Richard Reibstein, Outreach Director
Massachusetts Department of
Environment
Office of Technical Assistance
100 Cambridge Street
Boston, MA 02202
617-727-3260
Toxics Use Reduction Institute
Jack Luskin
Director of Education and Outreach
Toxics Use Reduction Institute
University Avenue
Lowell, MA 01854
508-934-3262
MICHIGAN
Office of Waste Reduction Services
Nan Merrill, Manager
Office of Waste Reduction Services
Environmental Services Division
Michigan Departments of Commerce
and Natural Resources
116 West Allegan Street
PO Box 30004
Lansing, MI 48909-7504
517-335-1178
MINNESOTA
Minnesota Office of Waste Management
Kevin McDonald, Sr., Pollution
Prevention Planner
Minnesota Office of Waste Management
1350 Energy Lane
Suite 201
St. Paul, MN 55108-5272
612-649-5750/5744
Minnesota Pollution Control Agency
(MPCA)
Eric Kilberg, Pollution Prevention
Coordinator
Environmental Assessment Office
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
612-296-8643
Minnesota Technical Assistance
Program (MNTAP)
Cindy McComas, Director
Minnesota Technical Assistance Program
Environmental Health School
of Public Health
University of Minnesota
1313 5th Street, SE, Suite 207
Minneapolis, MN 55414
612-627-455514646
MISSISSIPPI
Mississippi Waste Reduction/Waste
Minimization Program, Mississippi
Technical Assistance Program
(MISSTAP) and Mississippi Solid
Waste Reduction Assistance Program
(MSSWRAP)
Dr. Caroline Hill
Mississippi Technical Assistance
Program and Mississippi Solid Waste
Reduction Assistance
PO Drawer CN
26
Section III: Technical Assistance and Literature
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Mississippi State, MS 39762
601-325-8454
Thomas E. Whitten, Director
Waste Reduction/Waste Minimization
Program
Mississippi Department of
Environmental Quality
POBox 10385
Jackson, MS 39289-0385
601-961-5171
MISSOURI
Waste Management Program (WMP)
Becky Shannon, Pollution Prevention
Coordinator
Hazardous Waste Program
Division of Environmental Quality
Missouri Department of Natural
Resources
205 Jefferson Street
POBox 176
Jefferson City, MO 65102
314-751-3176
Environmental Improvement and
Energy Resources Authority
Steve Mahfood, Director
Tom Welch, Assistant for Planning
and Project Development
Environmental Improvement and
Energy Resources Authority
225 Madison Street
PO Box 744
Jefferson City, MO 65102
314-751-4919
MONTANA
Solid and Hazardous Waste Bureau
Dan Fraser
Water Quality Bureau Chief
Department of Health and
Environmental Sciences
Room A-206
Cogswell Building
Helena, MT 59620
406-444-2406
Jeff Jacobsen
Montana State University Extension
Service
807 Leon Johnson Hall
Bozeman, MT 59717-0312
406-994-5683
NEBRASKA
Hazardous Waste Section
Teri Swarts, Waste Minimization
Coordinator
Hazardous Waste Section
Nebraska Department of Environmental
Control
301 Centennial Mall South
PO Box 98922
Lincoln, NE 68509
402-471-4217
NEVADA
Business Environmental Program
Kevin Dick, Manager
Business Environmental Program
Nevada Small Business Development
Center
University of Nevada - Reno
Reno, NV 89557-0100
702-784-1717
Doug Martin
Bureau of Waste management
Division of Environmental Protection
123 West Nye Lane
Carson City, NV 89710
702-687-5872
Nevada Energy Conservation Program
Curtis Framel, Manager
Nevada Energy Conservation Program
Office of Community Services
Capitol Complex
201 South Fall Street
Carson City, NV 89710
702-885-4420
NEW JERSEY
New Jersey Pollution Prevention
Program
Jean Herb, Director
Office of Pollution Prevention
New Jersey Department of
Environmental Protection
CN-402
401 East State Street
Trenton, NJ 08625
609-777-0518
New Jersey Technical Assistance
Program (NJTAP)
Kevin Gashlin, Director
New Jersey Technical Assistance
Program
New Jersey Institute of Technology
Hazardous Substance Management
Research Center
Center for Environmental and
Engineering Sciences
323 Martin Luther King Boulevard
Newark, NJ 07102
201-596-5864
NEW YORK
Bureau of Pollution Prevention
John lanotti, Director
Bureau of Pollution Prevention
Division of Hazardous Substances
Regulation and the Division of
Solid Waste
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, NY 12233-7253
518-457-7276
NORTH CAROLINA
Pollution Prevention Program
Gary Hunt, Director
Stephanie Richardson, Manager
Pollution Prevention Program
Office of Waste Reduction
North Carolina Department of
Environment, Health, and Natural
Resources
PO Box 27687
Raleigh, NC 27611-7687
919-571-4100
OHIO
Ohio Technology Transfer
Organization (OTTO)
Jeff Shick, State Coordinator
Jackie Rudolf
Ohio Technology Transfer Organization
Ohio Department of Development
77 South High Street, 26th Floor
Columbus, OH 43255-0330
614-644-4286
Ohio Environmental Protection Agency
Roger Hannahs
Michael W. Kelley
Anthony Sasson
Pollution Prevention Section
Division of Hazardous Waste
Management
Ohio Environmental Protection Agency
PO Box 1049
Columbus, OH 43266-0149
614-644-3969
27
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OKLAHOMA
Pollution Prevention Technical
Assistance Program
Chris Varga
Hazardous Waste Management
Service, 0205
Oklahoma State Department of Health
1000 Northeast 10th Street
Oklahoma City,OK 73117-1299
405-271-7047
OREGON
Waste Reduction Assistance Program
(WRAP)
Roy W. Brewer, Manager
David Rozell, Pollution Prevention
Specialist
Phil Berry, Pollution Prevention
Specialist
Hazardous Waste Reduction and
Technical Assistance Program
Hazardous and Solid Waste Division
Oregon Department of Environmental
Quality
811 SW Sixth Avenue
Portland, OR 97204
503-229-6585
PENNSYLVANIA
Department of Environmental Resources
Meredith Hill
Assistant to Deputy Secretary
Office of Air and Waste Management
Pennsylvania Department of
Environmental Resources
PO Box 2063
Hamsburg, PA 17105-2063
717-772-2724
Center for Hazardous Materials Research
Roger Price
Center for Hazardous Materials Research
University of Pittsburgh Applied
Research Center
320 William Pit Way
Pittsburgh, PA 15238
412-826-5320
1-800-334-CHMR
Pennsylvania Technical Assistance
Program (PENNTAP)
Jack Gido, Director
PENNTAP
Penn State University
110 Barbara Building 11
810 North University Drive
University Park, PA 16802
814-865-0427
RHODEISLAND
Hazardous Waste Reduction Program
Richard Enander, Chief
Janet Keller
Office of Environmental Coordination
Rhode Island Department of
Environmental Management
83 Park Street
Providence, RI 02903-1037
401-277-3434
Eugene Pepper, Senior Environmental
Planner
Hazardous Waste Reduction Section
Office of Environmental Coordination
Rhode Island Department of
Environmental Management
83 Park Street
Providence, RI 02903
401-277-3434
SOUTH CAROLINA
Center for Waste Minimization
Ray Guerrein
Center for Waste Minimization
South Carolina Department of
Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
802-734-4715
SOUTH DAKOTA
Waste Management Program
Wayne Houtcooper
Department of Environment and
Natural Resources
Joe Foss Building
523 E. Capitol Avenue
Pierre, SD 57501-3181
605-773-4216
TENNESSEE
Department of Health and Environment
Paul Evan Davis
Bureau of Environment
Tennessee Department of Health and
Environment
14th Floor, L & C Building
401 Church Street
Nashville, TN 37243-0455
615-741-3657
Waste Reduction Assessment and
Technology Transfer Training
Program (WRATT)
George Smelter, Director
Waste Reduction Assistance Program
CamMetcalf(Suite 606)
Center for Industrial Services
University ofTennessee
226 Capitol Boulevard Building
Nashville, TN 37219-1804
615-242-2456
Carroll Dugan, Section Manager
Waste Reduction and Management
Section
Tennessee Valley Authority
Mail Code HB 2G-C
311 Broad Street
Chattanooga, TN 37406
615-751-4574
TEXAS
Center for Hazardous and Toxic
Waste Studies
John R. Bradford, Director
Center for Hazardous and Toxic
Waste Studies
Texas Tech University
PO Box 4679
Lubbock, TX 79409-3121
806-742-1413
UTAH
Department of Environmental Quality
Sonja Wallace, Pollution Prevention
Co-Coordinator
Stephanie Bernkopf, Pollution
Prevention Co-Coordinator
Office of Executive Director
Utah Department of Environmental
Quality
168 North 1950 West Street
Salt Lake City, UT 84114-4810
801-536-4480
VERMONT
Pollution Prevention Program
Gary Gulka
Pollution Prevention Division
Vermont Department of
Environmental Conservation
103 South Main Street
Waterbury, VT 05676
802-244-8702
28
Section III: Technical Assistance and Literature
-------
Paul Maskowitz, Chief
Recycling and Resource
Conservation Section
Vermont Department of Environmental
Conservation
103 South Main Street
Waterbury, VT 05676
802-244-8702
VIRGINIA
Waste Minimization Program
Sharon Kenneally-Baxter, Director
Waste Minimization Program
Virginia Department of Waste
Management
Monroe Building, llth Floor
101N. 14th Street
Richmond, VA 23219
804-371-8716
WASHINGTON
Waste Reduction, Recycling
and Litter Control Program
Stan Springer
Joy St. Germain
Peggy Morgan
Waste Reduction, Recycling and
Litter Control Program
Washington Department of Ecology
Mail Stop PV-11
Olympia, WA 98504-8711
206-438-7541
WEST VIRGINIA
Pollution Prevention and Open Dump
Program (PPOD)
Richard Ferrell, Environmental Analyst
Waste Management Section
West Virginia Division of Natural
Resources
1356 Hansford Street
Charleston, WV 25301
304-558-4000
WISCONSIN
Department of Natural Resources
Lynn Persson, Hazardous Waste
Reduction and Recycling Coordinator
Kate Cooper, Assistance Recycling
Coordinator
Bureau of Solid and Hazardous Waste
Management
Wisconsin Department of Natural
Resources
PO Box 7921 (SW/3)
Madison, WI 53707-7921
608-267-3763
WYOMING
Department of Environmental Quality
David Finley, Manager
Pat Gallagher, Senior
Environmental Analyst
Solid Waste Management Program
Wyoming Department of
Environmental Quality
122 West 25th Street
Herschler Building
Cheyenne, WY 82002
307-777-7752
29
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ANNEX A: EXECUTIVE ORDER 12856
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EXECUTIVE ORDER
Federal Register
Vol. 58, No. 150
Friday, August 6,1993
41981
Presidential Documents
Title 3—
The President
Executive Order 12856 of August 3, 1993
Federal Compliance With Right-to-Know Laws and Pollution
Prevention Requirements
WHEREAS, the Emergency Planning and Community Right-to-Know Act
of 1986 (42 U.S.C. 11001-11050) (EPCRA) established programs to provide the
public with important information on the hazardous and toxic chemicals in their
communities, and established emergency planning and notification requirements
to protect the public in the event of a release of extremely hazardous substances;
WHEREAS, the Federal Government should be a good neighbor to local communi-
ties by becoming a leader in providing information to the public concerning toxic
and hazardous chemicals and extremely hazardous substances at Federal facilities,
and in planning for and preventing harm to the public through the pianned or
unplanned releases of chemicals;
WHEREAS, the Pollution Prevention Act of 1990 (42 U.S.C. 13101-13109) (PPA)
established that it is the national policy of the United States that whenever feasible,
pollution should be prevented or reduced at the source, that pollution that cannot
be prevented should be recycled in an environmentaiiy safe manner; that pollution
that cannot be prevented or recycled should be treated in an environmentaiiy safe
manner; and that disposal or other release into the environment should be em-
ployed only as a last resort and should be conducted in an environmentaiiy safe
manner;
WHEREAS, the PPA required the Administrator of the Environmental Protection
Agency (EPA) to promote source reduction practices in other agencies;
WHEREAS, the Federal Government should become a leader in the field of pollu-
tion prevention through the management of its facilities, its acquisition practices,
and in supporting the development of innovative pollution prevention programs
and technologies;
WHEREAS, the environmental, energy, and economic benefits of energy and wa-
ter use reductions are very significant; the scope of innovative pollution prevention
programs must be broad to adequately address the highest-risk environmental
problems and to take full advantage of technological opportunities in sectors other
than industrial manufacturing; the Energy Policy Act of 1992 (Public Law 102-486
of October 24, 1992) requires the Secretary of Energy to work with other Federal
agencies to significantly reduce the use of energy and reduce the related environ-
mental Impacts by promoting use of energy efficiency and renewable energy tech-
nologies; and
WHEREAS, as the largest single consumer in the Nation, the Federal Government
has the opportunity to realize significant economic as weii as environmental ben-
efits of pollution prevention;
AND IN ORDER TO:
Ensure that all Federal agencies conduct their facility management and acquisition
activities so that, to the maximum extent practicable, the quantity of toxic chemi-
cals entering any wastestream, Including any releases to the environment, is re-
duced as expeditiously as possible through source reduction; that waste that is
generated is recycled to the maximum extent practicable; and that any wastes
remaining are stored, treated or disposed of in a manner protective of public
health and the environment;
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41982 Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
Require Federal agencies to report in a public manner toxic chemicals entering
any wastestream from their facilities, including any releases to the environment,
and to improve local emergency planning, response, and accident notification; and
Help encourage markets for clean technologies and safe alternatives to extremeiy
hazardous substances or toxic chemicals through revisions to specifications and
standards, the acquisition and procurement process, and the testing of innovative
pollution prevention technologies at Federal facilities or in acquisitions;
NOW THEREFORE, by the authority vested in me as President by the Constitu-
tion and the laws of the United Slates of America, including the EPCRA, the PPA,
and section 301 of title 5, United States Code, it is hereby ordered as follows:
Section 1. Applicability.
1-101. As delineated below, the head of each Federal agency is responsible for
ensuring that all necessary actions are taken for the prevention of pollution with
respect to that agency's activities and facilities, and for ensuring that agency's
compliance with pollution prevention and emergency planning and community
right-to-know provisions established pursuant to all implementing regulations is-
sued pursuant to EPCRA and PPA.
1 102. Except as otherwise noted, this order is applicable to all Federal agencies
that either own or operate a "facility" as that term is defined in section 329(4) of
EPCRA, if such facility meets the threshold requirements set forth in EPCRA for
compliance as modified by section 3-304(b) of this order ("covered facilities").
Except as provided in section 1-103 and section 1-104 below, each Federal agency
must apply all of the provisions of this order to each of its covered facilities,
including those facilities which are subject, independent of this order, to the
provisions of EPCRA and PPA (e.g., certain Government-owned/contractor-oper-
ated facilities (GOCO's), for chemicals meeting EPCRA thresholds). This order
does not apply to Federal agency facilities outside the customs territory of the
United States, such as United States diplomatic and consular missions abroad.
1-103. Nothing in this order alters the obligations which GOCO's and Government
corporation facilities have under EPCRA and PPA independent of this order or
subjects such facilities to EPCRA or PPA if they are otherwise excluded. However,
consistent with section 1-104 below, each Federal agency shall include the releases
and transfers from all such facilities when meeting all of the Federal agency's
responsibilities under this order.
1-104. To facilitate compliance with this order, each Federal agency shall provide,
in all future contracts between the agency and its relevant contractors, for the
contractor to supply to the Federal agency all information the Federal agency
deems necessary for it to comply with this order, in addition, to the extent that
compliance with this order is made more difficult due to lack of information from
existing contractors, Federal agencies shall take practical steps to obtain the infor-
mation needed to comply with this order from such contractors.
Sec. 2-2. Definitions.
2-201. All definitions found in EPCRA and PPA and implementing regulations are
incorporated in this order by reference, with the following exception: for the
purposes of this order, the term "person", as defined in section 329(7) of EPCRA,
also includes Federal agencies.
2-202. Federal agency means an Executive agency, as defined in 5 U.S.C. 105. For
the purpose of this order, military departments, as defined in 5 U.S.C 102, are
covered under the auspices of the Department of Defense.
2-203. Pollution Prevention means "source reduction," as defined in the PPA, and
other practices that reduce or eliminate the creation of pollutants through: (a)
increased efficiency in the use of raw materials, energy, water, or other resources;
or (b) protection of natural resources by conservation.
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Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41983
2-204. GOCO means a Government-owned/contractor-operated facility which is
owned by the Federal Government but all or portions of which are operated by
private contractors.
2-205. Administrator means the Administrator of the EPA.
2-206. Toxic Chemical means a substance on the list described in section 313(c) of
EPCRA.
2-207. Toxic Pollutants. For the purposes of section 3-302(a) of this order, the
term "toxic pollutants" shall include, but is not necessarily limited to, those
chemicals at a Federal facility subject to the provisions of section 313 of EPCRA
as of December 1, 1993. Federal agencies also may choose to include releases and
transfers of other chemicals, such as "extremely hazardous chemicals" as de-
fined in section 329(3) of EPCRA, hazardous wastes as defined under the Re-
source Conservation and Recovery Act of 1976 (42 U.S.C 6901-6986) (RCRA), or
hazardous air pollutants under the Clean Air Act Amendments (42 U.S.C. 7403-
7626); however, for the purposes of establishing the agency's baseline under 3-
302(c), such "other chemicals" are in addition to (not instead of) the section 313
chemicals. The term "toxic pollutants" does not include hazardous waste subject
to remedial action generated prior to the date of this order.
Sec 3-3 Implementation.
3-301. Federal Agency Strategy. Within 12 months of the date of this order, the
head of each Federal agency must develop a written pollution prevention strat-
egy to achieve the requirements specified in sections 3-302 through 3-305 of this
order for that agency. A copy thereof shall be provided to the Administrator.
Federal agencies are encouraged to involve the public in developing the required
strategies under this order and in monitoring their subsequent progress in meet-
ing the requirements of this order. The strategy shall include, but shall not be
limited to, the following elements:
(a) A pollution prevention policy statement, developed by each Federal agency,
designating principal responsibilities for development, implementation, and evalu-
ation of the strategy. The statement shall reflect the Federal agency's commit-
ment to incorporate pollution prevention through source reduction in facility
management and acquisition, and it shall identify an individual responsible for
coordinating the Federal agency's efforts in this area.
(b) A commitment to utilize pollution prevention through source reduction,
where practicable, as the primary means of achieving and maintaining compli-
ance with all applicable Federal, State, and local environmental requirements.
3-302. Toxic Chrmical Reduction Goals, (a) The head of each Federal agency
subject to this order shall ensure that the agency develops voluntary goals to
reduce the ageno'-itotal releases of toxic chemicals to the environment and off-
site transfers of>uch toxic chemicals for treatment and disposal from facilities
covered by this order by 50 percent by December 31, 1999. To the maximum
extent practicable, such reductions shall be achieved by implementation of source
reduction practlc*v
(b) The baseline for measuring reductions for purposes of achieving the 50
percent reduction goal for each Federal agency shall be the first year in which
releases of toxic chemicals to the environment and off-site transfers of such
chemicals for treatment and disposal are publicly reported. The baseline amount
as to which the 50 percent reduction goal applies shall be the aggregate amount
of toxic chemicals reported in the baseline year for all of that Federal agency's
facilities meeting the threshold applicability requirements set forth in section 1-
102 of this order. In no event shall the baseline be later than the 1994 reporting
year.
(c) Alternatively, a Federal agency may choose to achieve a 50 percent reduc-
tion goal for toxic pollutants. In such event, the Federal agency shall delineate
the scope of its reduction program in the written pollution prevention strategy
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41984 Federal Register/Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
that is required by section 3-301 of this order. The baseline for measuring reduc-
tions for purposes of achieving the 50 percent reduction requirement for each
Federal agency shall be the first year in which releases of toxic pollutants to the
environment and off-site transfers of such chemicals for treatment and disposal are
publicly reported for each of that Federal agency's facilities encompassed by
section 3-301. In no event shall the baseline year be later than the 1994 reporting
year. The baseline amount as to which the 50 percent reduction goai applies shall
be the aggregate amount of toxic pollutants reported by the agency in the baseline
year. For any toxic pollutants included by the agency in determining its baseline
under this section, in addition to toxic chemicals under EPCRA, the agency shall
report on such toxic pollutants annually under the provisions of section 3-304 of
this order, if practicable, or through an agency report that is made available to the
public.
(d) The head of each Federal agency shall ensure that each of its covered facilities
develops a written pollution prevention plan no later than the end of 1995, which
sets forth the facility 's contribution to the goal established in section 3-302(a) of
this order. Federal agencies shall conduct assessments of their facilities as neces-
sary to ensure development of such plans and of the facilities' pollution prevention
programs.
3-303. Acquisition and Procurement Goals, (a) Each Federal agency shall establish a
plan and goals for eliminating or reducing the unnecessary acquisition by that
agency of products containing extremeiy hazardous substances or toxic chemicals.
Similarly, each Federal agency shall establish a plan and goal for voluntarily
reducing its' own manufacturing, processing, and use of extremely hazardous
substances and toxic chemicals. Priorities shall be developed by Federal agencies,
in coordination with EPA, for implementing this section.
(b) Within 24 months of the date of this order, the Department of Defense (DOD)
and the General Services Administration (GSA), and other agencies, as appropri-
ate, shall review their agency's standardized documents, including specifications
and standards, and identify opportunities to eliminate or reduce the use by their
agency of extremely hazardous substances and toxic chemicals, consistent with the
safety and reliability requirements of their agency mission. The EPA shall assist
agencies in meeting the requirements of this section, including identifying substi-
tutes and setting priorities for these reviews. By 1999, DOD, GSA and other
affected agencies shall make all appropriate revisions to these specifications and
standards.
(c) Any revisions to the Federal Acquisition Regulation (FAR) necessary to
implement this order shall be made within 24 months of the date of this order.
(d) Federal agencies are encouraged to develop and test innovative pollution
prevention technologies at their facilities in order to encourage the development of
strong markets for such technologies. Partnerships should be encouraged between
industry, Federal agencies, Government laboratories, academia, and others to
assess and deploy innovative environmental technologies for domestic use and for
markets abroad.
3-304. Toxics Release Inventory/Pollution Prevention Act Reporting, (a) The head of
each Federal agency shall comply with the provisions set forth in section 313 of
EPCRA, section 6607 of PPA, all implementing regulations, and future amend-
ments to these authorities, in light of applicable guidance as provided by EPA.
(b) The head of each Federal agency shall comply with these provisions without
regard to the Standard industrial Classification (SIC) delineations that apply to
the Federal agency's facilities, and such reports shall be for all releases, transfers,
and wastes at such Federal agency's facility without regard to the SIC code of the
activity leading to the release, transfer, or waste. All other existing statutory or
regulatory imitations or exemptions on the application of EPCRA section 313 shall
apply to the reporting requirements set forth in section 3-304(a) of this order.
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Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41985
(c) The first year of compliance shall be no later than for the 1994 calendar year
with reports due on or before July 1,1995
3-305. Emergency Planning and Community Right-to-Know Reporting Responsibilities.
The head of each Federal agency shall comply with the provisions set forth in sections
301 through 312 of EPCRA, all implementing regulations, and future amendments to
these authorities in light of any applicable guidance as provided by EPA. Effective
dates for compliance shall be: (a) With respect to the provisions of section 302 of
EPCRA emergency planning notification shall be made no later than 7 months after
the date of this order.
(b) With respect to the provisions of section 303 of EPCRA all information neces-
sary for the applicable Local Emergency Planning Committee (LEPC's) to prepare or
revise local Emergency Response Plans shall be provided no later than 1 year after the
date of this order.
(c) To the extent that a facility is required to maintain Material Safety Data Sheets
under any provisions of law or Executive order, information required under section
311 of EPCRA shall be submitted no later than 1 year after the date of this order, and
the first year of compliance with section 312 shall be no later than the 1994 calendar
year, with reports due on or before March 1, 1995.
(d) The provisions of section 304 of EPCRA shall be effective beginning January 1,
1994.
(e) These compliance dates are not intended to delay implementation of earlier
timetables already agreed to by Federal agencies and are inapplicable to the extent
they interfere with those timetables.
Sec. 4-4. Agency Coordination.
4-401. By February 1, 1994, the Administrator shall convene an interagency Task
Force composed of the Administrator, the Secretaries of Commerce, Defense, and
Energy, the Administrator of General Services, the Administrator of the Office of
Procurement Policy in the Office of Management and Budget, and such other agency
officials as deemed appropriate based upon lists of potential participants submitted to
the Administrator pursuant to this section by the agency head. Each agency head may
designate other senior agency officials to act in his/her stead, where appropriate. The
Task Force will assist the agency heads in the implementation of the activities re-
quired under this order.
4-402. Federal agencies subject to the requirements of this order shall submit annual
progress reports to the Administrator beginning on October 1, 1995. These reports all
include a description of the progress that the agency has made in complying with all
aspects of this order, including the pollution reductions requirements. This reporting
requirement shall expire after the report due on October 1, 2001.
4-403. Technical Advice. Upon request and to the extent practicable, the Administra-
tor shall provide technical advice and assistance to Federal agencies in order to foster
full compliance with this order. In addition, to the extent practicable, all Federal
agencies subject to this order shall provide technical assistance, if requested, to
LEPC's in their development of emergency response plans and in fulfillment of their
community right-to-know and risk reduction responsibilities.
4-404. Federal agencies shall place high priority on obtaining funding and resources
needed for implementing all aspects of this order, including the pollution prevention
strategies, plans, and assessments required by this order, by identifying, requesting,
and allocating funds through line-item or direct funding requests. Federal agencies
shall make such requests as required in the Federal Agency Pollution Prevention and
Abatement Planning Process and through agency budget requests as outlined in
Office of Management and Budget (OMB) Circulars A-106 and A-n, respectively.
Federal agencies should apply to the maximum extent practicable, a life cycle analysis
and total cost accounting principles to all projects needed to meet the requirements of
this order.
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41986 Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
4-405. Federal Government Environmental/Challenge Program. The Adminis-
trator shall establish a "Federal Government Environmental Challenge Pro-
gram" to recognize outstanding environmental management performance in
Federal agencies and facilities. The program shall consist of two components
that challenge Federal agencies; (a) to agree to a code of environmental prin-
ciples to be developed by EPA, in cooperation with other agencies, that empha-
sizes pollution prevention, sustainable development and state of-the-art environ-
mental management programs, and (b) to submit applications to EPA for indi-
vidual Federal agency facilities for recognition as "Modei Installations." The
program shall aiso include a means for recognizing individual Federal employ -
ees who demonstrate outstanding leadership in pollution prevention.
Sec 5-5. Compliance.
5-501. By December 31,1993, the head of each Federal agency shall provide the
Administrator with a preliminary list of facilities that potentially meet the
requirements for reporting under the threshold provisions of EPCRA, PPA, and
this order.
5-502. The head of each Federal agency is responsible for ensuring that such
agency take all necessary actions to prevent pollution in accordance with this
order, and for that agency's compliance with the provisions of EPCRA and PPA.
Compliance with EPCRA and PPA means compliance with the same substantive,
procedural, and other statutory and regulatory requirements that would apply
to a private person. Nothing in this order shall be construed as making the
provisions of sections 325 and 326 of EPCRA applicable to any Federal agency
or facility, except to the extent that such Federal agency or facility would
independently be subject to such provisions. EPA shall consult with Federal
agencies, if requested, to determine the applicability of this order to particular
agency facilities.
5-503. Each Federal agency subject to this order shall conduct internal reviews
and audits, and take such other steps, as may be necessary to monitor compli-
ance with sections 3-304 and 3-305 of this order.
5-504. The Administrator, in consultation with the heads of Federal agencies,
may conduct such reviews and inspections as may be necessary to monitor
compliance with sections 3-304 and 3-305 of this order. Except as excluded
under section 6-601 of this order, all Federal agencies are encouraged to cooper-
ate fully with the efforts of the Administrator to ensure compliance with sections
3-304 and 3-305 of this order.
5-505. Federal agencies are further encouraged to comply with all state and local
right-to-know and pollution prevention requirements to the extent that compli-
ance with such laws and requirements is not otherwise already mandated.
5-506. Whenever the Administrator notifies a Federal agency that it is not in
compliance with an applicable provision of this order, the Federal agency shall
achieve compliance as promptly as is practicable.
5-507. The EPA shall report annually to tho President on Federal agency compli-
ance with the provisions of section 3-304 of this order.
5-508. To the extent permitted by law and unless such documentation is withheld
pursuant to section 6-601 of this order, the public shall be afforded ready access
to all strategies, plans, and reports required to be prepared by Federal agencies
under this order by the agency preparing the strategy, plan, or report. When the
reports are submitted to EPA, EPA shall compile the strategies, plans, and
reports and make them publicly available as well. Federal agencies are encour-
aged to provide such strategies, plans, and reports to the State and local authori-
ties where their facilities are located for an additional point of access to the
public.
-------
Federal Register / VoK 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41987
Sec. 6-6. Exemption.
6-601. In the interest of national security, the head of a Federal agency may request
from the President an exemption from complying with the provisions of any or all
aspects of this order for particular Federal agency facilities, provided that the proce-
dures set forth in section 120(j)(l) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9620(])(1)), are
followed. To the maximum extent practicable, and without compromising national
security, all Federal agencies shall strive to comply with the purposes, goals, and
implementation steps set forth in this order.
Sec. 7-7. Genera! Provisions.
7-701. Nothing in this order shall create any right or benefit, substantive or proce-
dural, enforceable by a party against the United States, its agencies or instrumentali-
ties, its officers or employees, or any other person.
[FR Doc/ 93-19069
Filed 8-4-93; 4:37 pm]
Billing code 3195 -01-P
THE WHITE HOUSE,
August 3, 1993.
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Baldrige National Quality Program
^ &
Baldrige National
Quality Program
Criteria for Performance Excellence
-------
The Baldrige Criteria
provide a proven road
map for performance
improvement—one
that will enable
your organization
to be more
successful than
you ever
^^•^^^
imagined.
Vicki Spagnol
Member,
Baldrige Panel of
Judges, 1999-2001
Principal,
Management Insights,
New York, NY
Whether large or small,
in business, education, or health care,
in one locality or with sites worldwide,
your organization can benefit from conducting
a self-assessment using the appropriate Baldrige
Criteria for Performance Excellence (Business,
Education, or Health Care) and taking action
for improvement.
Yet, you might hesitate to take advantage of this
opportunity because you are uncertain how to
get started, and it takes effort to begin.
This booklet is a step-by-step guide for your
leadership team on how to use the Baldrige
process as a tool for conducting a self-assessment
and developing an action plan for your
organization. The Baldrige process provides the
atmosphere for leaders, managers, and all staff
to better recognize successes within your
organization and to implement valuable
improvements where needed.
Read further, and accept the Baldrige challenge
of excellence—to "enable your organization to
be more successful than you ever imagined."
-------
It is never too early to begin using the
Baldrige Criteria for Performance Excellence.
You do not have to wait until you are ready to apply for the Baldrige Award.
Your organization may use the Criteria in the early stages of your journey
toward performance excellence. In fact, most organizations begin by using
the Criteria as a source of information on managing for excellence, building
a common language, and facilitating communication about performance
excellence within their organizations. Some draw on the Criteria to guide
the development of processes focused on performance excellence. Others
use the Criteria for self-assessment and action.
Getting Started 1
-------
Why consider self-assessment?
Organizations cite many reasons for undertaking a self-assessment
and action initiative:
• Customers and/or competitors are driving a need to change.
• Your industry is changing.
• Your organization is among the best, and you want to make sure
you stay that way.
• Business is good, and you want to keep it that way.
• Your leadership team has committed to a self-assessment to enhance
organizational learning.
• Your organization's values are aligned with the Core Values of the Criteria.
• You see a clear connection between your key issues and the
systematic approach embodied in the Criteria for improving
organizational performance practices.
• You could capitalize on one or more of the following benefits of
conducting a self-assessment and implementing action plans
for improvement:
o jump-starting change initiatives
o energizing improvement initiatives
o focusing your organization on common goals
The Baldrige improvement process isn 't another thing to do; it is part of,
and causes you to do, the only things you need to do.
Earl A. Goode, 1994 Baldrige Award Recipient
President, GTE Directories Corporation, D/FW Airport, TX
2 Getting Started
-------
Are you ready for
self-assessment?
Indicators of readiness
include the following:
• Senior leaders are aware of the key issues facing your
organization but need communication and employee
"buy-in" to take action.
• Senior leaders support a self-assessment, action, and
improvement initiative.
• You have talked to the organization's opinion leaders
to identify possible objections to self-assessment and
action, and their feedback increased your interest in
starting the process.
• A champion for self-assessment and action is on your
leadership team.
Getting Started 3
-------
Introduction to Ten Steps for Self-Assessment and Action
Organizations describe different approaches for applying the Baldrige
Criteria in their self-assessment and action exercises. For example, some
engage all staff in the process, some select participants from a cross section
of functions and levels, and some appoint a small group to represent all
of their colleagues. Some use only the Organizational Profile for their
first self-assessment. Some organizations look at all seven Categories
simultaneously, while others focus on specific elements within a single
Category before moving on to assess the other Categories. While there is
merit and demonstrated success associated with all of these different
approaches, this booklet describes one effective approach that has been used
frequently in a variety of small and large organizations.
This ten-step approach will guide you through a process for using the
Baldrige Criteria as a self-assessment and action tool. The first step is to
identify whether the whole organization or a specific part of it will be
assessed. Next, you will select champions for each of the seven Baldrige
Categories. Then you will prepare an Organizational Profile describing your
organization and its challenges. In some cases, the Organizational Profile
may be used by itself for an initial self-assessment; if you identify significant
4 Getting Started
-------
information gaps, you may wish to move from the self-assessment phase
and address these gaps through action planning and implementation.
Otherwise, your Category champions will complete an exercise to become
familiar with the Baldrige self-assessment and action process.
Next, your champions will select Category teams, and together they will
collect information and data for assessing their respective Categories. They
then will create and communicate an action plan for improvement. In the
final step in the process, your senior leaders, champions, and teams will
evaluate what has been done and think about how to improve the process
in the future.
Please note that your organization's experience with and prior use of the
Baldrige Criteria may determine whether you follow all ten steps in a
somewhat formal approach or if your organization would benefit more
from an informal assessment. If you decide on an informal assessment—
which many have found a good way to start—you can complete the
exercise in a one- to two-day meeting.
Are you ready to learn more about applying the ten steps to self-assessment and
action in your organization? Let's begin with Step 1.
Getting Started 5
-------
iOS
Identify the boundaries of the organization
to be assessed.
PURPOSE: This step should ensure that all
appropriate areas are included and that data
and information are consistently collected
from those areas throughout the self-assessment
and action activities. In addition, it should ensure that self-assessment
and action champions and team members are selected who are
representative of these areas.
PROCESS: Determine if the self-assessment and the action planning
and implementation will cover the full organization, a subunit, a
division, or a department. Clarify what is included and what is not
to determine what will be evaluated. Indicate what will be included
in the self-assessment and action plan. An organization chart is a
useful tool for making this determination.
6 Getting Started
-------
t seven champions, one for each
Criteria for Performance Excellence
Category. In the Business Criteria, the
Categories are Leadership, Strategic
Planning, Customer and Market Focus,
Information and Analysis, Human Resource
Focus, Process Management, and Business
Results. Similar Categories are included in
the Education and Health Care Criteria.
PURPOSE: The champions will participate in preparing the
Organizational Profile and responses to Category Item questions.
PROCESS: Select champions with leadership and facilitation skills
who have widespread knowledge of the organization. Champions
with enthusiasm and Criteria knowledge are assets in the
self-assessment, planning, and action processes.
The scope and success of the self-assessment and action process are
proportional to the rank of its champions within the organization's
leadership system. The higher the rank, the more likely the assessment
will lead to significant improvements in organizational performance.
P. George Benson, Member, Baldrige Panel of Judges, 1997-1999
Dean, Terry College of Business, University of Georgia, Athens, GA
Getting Started 7
-------
Decide on the format for and scope of
your self-assessment and action plan.
PURPOSE: This step should clarify expectations
for what is to be accomplished and the
resources needed to complete the task.
Selecting a format to easily communicate
the self-assessment results sets the stage for future steps.
Communicating results of the self-assessment and implementing an
action plan enable the organization to enhance alignment and
better achieve common purposes.
PROCESS: Decide on the scope of the self-assessment and the format
for capturing and communicating the assessment and action. You
may choose to write only an Organizational Profile, as suggested in
Step 4, if you are just getting started. You may decide to use portions
or all of the Criteria for Performance Excellence. Whatever the
scope of the self-assessment, your format may be an oral discussion
and report, a written bulleted report, or a full written application as
used in the Baldrige Award evaluation process.
The format you select should allow all participants to provide their
perspectives about the organization. In an oral discussion, participants
might agree on which questions they can answer now, which questions
they need to gather information to answer, and which questions
require some work to develop answers. If you use a bulleted or full
written report, capture agreed upon information and identify issues
for which there is not yet a consensus response.
8 Getting Started
-------
10S
Senior leaders and champions prepare the
Organizational Profile.
PURPOSE: The Organizational Profile is a
statement of your operating environment and
what is relevant and important to your
organization and its performance. It will help
ensure a common understanding about what is important, the key
influences on how your organization operates, and where your
organization is headed. The Organizational Profile will guide your
self-assessment participants in selecting and sorting the most useful
data and information for the assessment.
Many organizations start with the Organizational Profile and
progress gradually to more detailed levels of self-assessment and
action. Developing the Organizational Profile may help you identify
gaps in information, lack of consensus, and/or inconsistent or
incomplete deployment (communication or implementation
throughout the organization).
PROCESS: Review the questions in the Organizational Profile found
in the back of this booklet. These questions are also included in the
Criteria booklet on the pages entitled "Preface: Organizational
Profile." Prepare a response to the two parts, "Organizational
Description" and "Organizational Challenges." The Organizational
Description addresses your organization's business environment
and your key relationships with customers, suppliers, and other
partners. The Organizational Challenges section calls for a
description of your organization's competitive environment, your
key strategic challenges, and your system for performance
improvement. (Similar points are covered in the Organizational
Profiles for education and health care organizations.)
Step 4 continued on next page
Getting Started 9
-------
Senior leaders and champions prepare the
Organizational Profile.
Depending on the extent of the gaps uncovered, it may be valuable to
move to Step 9, "Develop and implement an action plan for improvement."
Developing an action plan and implementing improvements to close
identified gaps will prepare you to complete a full self-assessment in
the future.
Writing an Organizational Profile is a crucial step in identifying what is
truly important to jour organization. By revealing strengths and key gaps, it
serves as a foundation for learning. In addition, by using teams to prepare
the Organizational Profile, you create opportunities for people across the
organization to communicate with one another, perhaps for the first time. In
effect, you are providing a common language so they can develop a common
understanding of their organization's purpose, activities, and environment.
Christopher S. Forman, Member, Baldrige Panel of Judges, 1997-1999
Chief Executive Officer, Pacific Theatres Corporation, Los Angeles, CA
10 Getting Started
-------
10S
Action;
Practice self-assessment techniques with
your seven Category champions, using
Item 1.1 in the Criteria for Performance
Excellence as a guide.
PURPOSE: Practicing these techniques will
help you learn how to use the Criteria for
self-assessment and action.
PROCESS: Using the Criteria for Performance Excellence, read and
follow the "Criteria Response Guidelines," especially the "Guidelines for
Responding to Approach-Deployment Items." Read the Criteria and the
"Category and Item Descriptions" for Item 1.1. Collect information and
data to outline your key processes in response to Item 1.1 questions.
Based on the information collected by the champions, prepare your
response. Describe approaches, including methods and measures, and
explain how and where the approaches are used in your organization.
Also include how approaches are evaluated and improved. Next, identify
gaps. Gaps may be incomplete responses in which methods, measures,
cycles of improvement, and deployment are unknown or unclear.
To maintain a focus on what is relevant and important, identify
inconsistencies between your Item 1.1 response and what you identified
as important to your organization in the Organizational Profile. Finally,
agree on your organization's key strengths and opportunities for
improvement related to Item 1.1.
Although you might start with an oral discussion or a bulleted report in
your first self-assessment and action plan, in future self-assessments
you can progress to a full written response.
Step 5 continued on next page
Getting Started 11
-------
Practice self-assessment techniques with your seven
Category champions, using Item 1.1 in the Criteria for
Performance Excellence as a guide.
The following is an example of a written response to one of the questions in 1.1:
Linkage to
(Organizational)
Profile
Linkage
to other
Categories .
Each month the Leadership Team (LT) reviews inputs from
each Process Team from the five sites described in the
Organizational Profile. Inputs cover performance to goals,
including results (listed in Category 7) for key organiza-
tional measures as identified in the Strategic Plan
(Category 2). The inputs detail performance as compared
to goals and the rationale for deviation from the planned
progress in excess of 15%. When a unit is not performing to
plan or the process shows a nonconformance, the Process
Teams determine if they can quickly correct the problem
or if an Improvement Team is needed. The LT also assesses
whether goal objectives should be retained or altered. The
LT considers tradeoffs to make the best use of resources..
The data champion performs correlations to establish
cause-effect relationships among the various data and
short- and long-term plans. Based on these analyses, the
LT assigns actions—with specified goals and measures for
progress—to the appropriate Process Team. The LT adjusts
resources as required to accommodate the planned actions.
12 Getting Started
-------
10S
Champions select Category teams.
Champions and teams prepare a response
for their assigned Items.
PURPOSE: Each champion will guide a team
through the next steps of the self-assessment and
action planning process. Using its members' expertise, each team
provides or obtains data and information to respond to the questions in
each Category Item of the Criteria for Performance Excellence.
PROCESS: Advise the champions to select three to five enthusiastic
team members with knowledge of the organization's activities
and/or the Criteria for their Category. Team members may serve as
leaders of and/or participants in the Category teams. Selecting team
members from different levels of the organization to be assessed
adds valuable perspectives and information. Adding members who
are external to the organization to be assessed can provide the
perspective of customer and supplier units.
Provide the champions and team members with copies of this Getting
Started booklet so they may review the self-assessment and action-
planning steps. Also, provide copies of the Criteria for Performance
Excellence (see page 23) so teams can review the full Criteria.
Step 6 continued on next page
Getting Started 13
-------
Action:
Champions select Category teams. Champions and teams
prepare a response for their assigned Items.
Read and follow the "Criteria Response Guidelines," especially the
"Guidelines for Responding to Approach-Deployment Items" for Category
teams 1 through 6 and "Guidelines for Responding to Results Items" for
the Category 7 team. Each team reads the Criteria and the "Category and
Item Descriptions" for its assigned Category. Teams collect information
and data to outline the key processes or results in each Item.
For Categories 1 through 6, describe approaches and explain how
and where the approaches are used in all parts of the organization
being assessed. The Category 7 team works with the other teams to link
results to approaches. Prepare a response to the Criteria based on the
information collected.
When several people are involved in assessing a Category, you learn things
you didn 't know about your own organization. The different perspectives
add power to your self-assessment.
David F. Quattrone, Member, Baldrige Panel of Judges, 1998-2000
Superintendent of Schools, Indian Hill School District, Cincinnati, OH
14 Getting Started
-------
Share responses among teams and finalize
the findings. Identify key strengths and
gaps in Category responses.
PURPOSE: Sharing responses should help you
arrive at a common understanding of what the
organization is doing.
PROCESS: Each team presents its findings to the other teams. Teams
clarify findings and add or delete information based on the broader
expertise among all teams and linkages across Categories and Items.
Together, teams reach consensus on the strengths and gaps in the
organization's approaches; deployment of approaches; sharing,
learning, and improvement processes; and results for each Category.
Teams identify overall themes that cut across Categories.
Sharing findings among teams creates enormous leverage for improvement.
It highlights the systemic nature of the enterprise by surfacing gaps in
alignment and integration of everyone's efforts. Furthermore, it enables
the transfer of knowledge from one process to another while providing a
clear perspective on performance and the extent to which excellence has
been achieved.
Kenneth G. Best, Member, Baldrige Panel of Judges, 1997-1999
Principal, The Best Performance Group, Chesterfield, MO
Getting Started 15
-------
Prioritize your organization's key strengths
and opportunities for improvement.
PURPOSE: Prioritization will help you develop
an action plan that most effectively uses
available resources.
PROCESS: Using the Organizational Profile to maintain a focus on
what is relevant and important, the teams decide on factors for
prioritizing opportunities for improvement, including any resource
constraints. Decision factors could include linkage to strategic
directions, impact throughout the organization, cost, time to
implement, and people available. Using the decision factors, the
teams prioritize opportunities for improvement and identify those
most important to include in the action plan.
16 Getting Started
-------
Develop and implement an action plan
for improvement.
PURPOSE: The outcome of self-assessment is a
road map for improving your organization. An
improvement action plan will include steps for
achieving improved results.
PROCESS: The champions develop an action plan for improvement
that addresses the top priorities and includes some short-term
actions to keep alive the momentum for improvement. The plan
should indicate who is accountable for leading each step, what is
to be accomplished and how, key progress dates, and how progress
will be measured. Senior leaders communicate the plan to the rest
of the organization. Champions obtain feedback on the plan and revise
the plan based on the feedback. Senior leaders deploy the revised plan
to everyone in the organization. Those identified in the plan to lead
action steps then implement the plan and track results. Senior leaders
communicate progress frequently and celebrate successes.
Getting Started 17
-------
10 S
Evaluate and improve your
self-assessment and action process.
PURPOSE: Regularly scheduled self-assessment
and action are key to ongoing improvement.
By improving the self-assessment and action
process, teams can reduce cycle time, gather
more useful information, improve action
plans, and achieve better results.
PROCESS: Senior leaders seek input from champions, teams, and
action plan leaders on what worked well and what could be
improved the next time self-assessment, action planning, and
implementation occur. Use this input to improve the self-assessment
and action process.
Schedule a reassessment. Many organizations conduct self-assessment
and planning and implement key improvements annually or biennially.
Consider conducting a more in-depth assessment. If you used only
the Organizational Profile for your first self-assessment, consider
using the Category Items in the Criteria for Performance Excellence
for your next self-assessment. Once you complete the Category
Items, your next self-assessment could include use of the "Scoring
Guidelines" found in the Criteria to assess your rate of improvement.
Each time you complete a Baldrige self-assessment, your insights
become sharper and more in-depth.
David McClaskey, Member, Baldrige Panel of Judges, 1999-2001
Senior Technical Associate, Eastman Chemical Company, Blountville, TN
18 Getting Started
-------
Now that you are familiar with one approach, you'd like to conduct a
self-assessment and take action for improvement. What steps can you
take to prepare yourself and your organization?
1. Share this starter booklet with others in your organization.
2. Have one or more people from your organization attend the
Baldrige Quest for Excellence Conference and/or the Baldrige
Regional Conferences to learn more about the Baldrige Criteria.
3. Contact your state or local award programs to find out
what resources they can provide.
4. Have someone from your organization apply to become
a Baldrige Examiner or state Examiner and learn from others
within and outside your industry.
More information on these opportunities follows on pages 23 and 24.
Getting Started 19
-------
(The Organizational Profile is taken from the Criteria for Performance
Excellence. Organizational Profiles for education and health care organizations
are found in the Education Criteria and Health Care Criteria, respectively.)
The Organizational Profile is a snapshot of your organization, the key
influences on how you operate, and the key challenges you face. It is the
most appropriate starting point for self-assessment and helps you to identify
potential gaps in key information and focus on key performance
requirements and results.
P.1 Organizational Description
Describe your organization's business environment and your key
relationships with customers, suppliers, and other partners.
Within your response, include answers to the following questions:
a. Organizational Environment
(1) What are your organization's main products and/or services?
Include a description of how they are delivered to customers.
(2) What is your organizational context/culture? Include your
purpose, vision, mission, and values, as appropriate.
(3) What is your employee profile? Include educational levels,
workforce and job diversity, bargaining units, use of contract
employees, and special safety requirements, as appropriate.
(4) What are your major technologies, equipment, and facilities?
(5) What is the regulatory environment under which your
organization operates? Include occupational health and
safety regulations; accreditation requirements; and
environmental, financial, and product regulations.
20 Getting Started
-------
b. Organizational Relationships
(1) What are your key customer groups and/or market segments?
What are their key requirements for your products and services?
Include how these requirements differ among customer groups
and/or market segments, as appropriate.
(2) What are your most important types of suppliers and dealers
and your most important supply chain requirements? What are
your key supplier and customer partnering relationships and
communication mechanisms?
Notes:
N1. Customer group and market segment requirements (P.1b[1])
might include on-time delivery, low defect levels, price
reductions, electronic communication, and after-sales service.
N2. Communication mechanisms (P.1b[2]) should be two-way
and might be in person, electronic, by telephone, and/or written.
For many organizations, these mechanisms might be changing.
P.2 Organizational Challenges
Describe your organization's competitive environment, your key
strategic challenges, and your system for performance improvement.
Within your response, include answers to the following questions:
a. Competitive Environment
(1) What is your competitive position? Include your relative size
and growth in your industry and the numbers and types of
your competitors.
Organizational Profile continued on next page
Getting Started 21
-------
(2) What are the principal factors that determine your success
relative to your competitors? Include any changes taking place
that affect your competitive situation.
b. Strategic Challenges
What are your key strategic challenges? Include operational,
human resource, business, and global challenges, as appropriate.
c. Performance Improvement System
How do you maintain an organizational focus on performance
improvement? Include your approach to systematic evaluation
and improvement of key processes and to fostering organizational
learning and knowledge sharing.
Notes:
N1. Factors (P.2a[2]) might include differentiators such as price
leadership, design services, e-services, geographic proximity, and
warranty and product options.
N2. Challenges (P.2b) might include electronic communication with
businesses and end-use consumers, reduced product introduction
cycle times, mergers and acquisitions, global marketing and competition,
customer retention, staff retention, and value chain integration.
N3. Performance improvement (P.2c) is an assessment dimension
used in the Scoring System to evaluate the maturity of organizational
approaches and deployment (see pages 45-46 in the Criteria for
Performance Excellence). This question is intended to help you set
a context for your approach to performance improvement.
22 Getting Started
-------
Resources on Self-Assessment and Action
The Baldrige National Quality Program (BNQP) provides the resources
listed below.
1. The Criteria for Performance Excellence
(Business, Education, and Health Care)
Single copies of the Criteria booklets are provided free of charge by the
Baldrige National Quality Program upon request. Each booklet
includes Category and Item requirements, Core Values and Concepts,
and a glossary of key terms. The Criteria booklets also can be down-
loaded from the Baldrige National Quality Program Web site at
http://www.quality.nist.gov.
2. E-Baldrige (available spring 2001)
Organizations can use E-Baldrige, a Web-based self-assessment tool that
uses the Organizational Profile,
• to help determine their readiness for a full self-assessment
• to possibly reveal gaps in information and opportunities for improvement
. to compare themselves to others who already have completed the
E-Baldrige challenge
• to assist with developing an action plan for improvement or continue
with a more complete self-assessment
Visit www.quality.nist.gov/eBaldrige/Step_One.htm to take the E-Baldrige
self-assessment challenge.
3. Information on the following:
State and Local Baldrige-Based Award Programs
Many of these programs provide consulting assistance in the area of
self-assessment and action in addition to their award program
functions. Located in nearly every state and in some communities,
these award programs offer networking opportunities, more extensive
award eligibility opportunities than the national Baldrige program
(extending to not-for-profit and for-profit organizations alike), and
multiple application levels that enable recognition of organizations
early in their improvement efforts, as well as those organizations
Getting Started 23
-------
with more mature approaches, deployment, and results. All programs
provide review and feedback.
Baldrige Examiners
Examiners can help you understand the Criteria and how to apply
them in your self-assessment and action efforts. Examiners receive
training each year on the Baldrige Criteria, using a case study learning
methodology. In addition to evaluating Award applications and preparing
feedback reports, Examiners serve as "ambassadors," often speaking
about the Baldrige Criteria, the Award Program, and the value of
self-assessment and action in organizational improvement. You can
apply to be an Examiner. If accepted, you will receive training and
network with others interested and experienced in organizational
self-assessment and action.
Baldrige Award Recipients
The recipients honor their responsibility to serve as performance
improvement advocates, share their strategies, and serve as role
models. Many undertake ongoing self-assessments of their organizations,
using the Baldrige Criteria, and can share their experiences with you.
Upcoming Conferences
The Baldrige National Quality Program annually sponsors the Quest for
Excellence Conference and three Regional Conferences. At these events,
current and past Baldrige Award recipients discuss their role model
approaches for addressing the seven Baldrige Criteria Categories. These
conferences also provide the opportunity to learn about the Award
recipients' self-assessment and action practices.
The Baldrige National Quality Program welcomes your inquiries:
Baldrige National Quality Program
National Institute of Standards and Technology
Administration Building, Room A600
100 Bureau Drive, Stop 1020
Gaithersburg, MD 20899-1020
Phone: (301) 975-2036 Fax: (301) 948-3716
E-mail: nqp@nist.gov Web address: http://www.quality.nist.gov
24 Getting Started
-------
The American Society for Quality (ASQ) provides additional resources
relating to the Baldrige Program and self-assessment and action, including
the following items.
1. Videotapes
Baldrige videotapes featuring Baldrige Award recipients include Quest
for Excellence and Take the Journey! An Invitation to American Small
Business. The Why Apply videotape addresses the benefits of applying
for the Baldrige Award and receiving a feedback report on strengths
and opportunities for improvement. A Uniquely Rewarding Experience
discusses the benefits of being a Baldrige Examiner.
2. Case Studies
Baldrige case studies are used to familiarize Examiners with the
Criteria and the Scoring System. The case studies, when used with
the Criteria, illustrate the responses to the Criteria requirements and
findings of the review process. The case study packet is illustrative of an
application for the Baldrige Award and is useful in understanding the
benefits of the Baldrige process, as well as for self-assessment,
planning, and training.
3. Bulk Orders
Multiple copies of the Criteria for Performance Excellence (Busi-
ness, Education, and Health Care) may be ordered in packets of 10.
To order, contact ASQ:
American Society for Quality
600 North Plankinton Avenue
Milwaukee, Wl 53203
or
P.O. Box 3005
Milwaukee, Wl 53201-3005
Phone: (800) 248-1946 Fax: (414) 272-1734
E-mail: asq@asq.org Web address: http://www.asq.org
Getting Started
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NIST0055
Revised April 2001
Baldrige National Quality Program
National Institute of Standards and Technology
Administration Building, Room A600
100 Bureau Drive, Stop 1020
Gaithersburg, MD 20899-1020
Phone: (301) 975-2036
Fax: (301) 948-3716
E-mail: nqp@nist.gov
Web address: http://www.quality.nist.gov
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