United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
(7406)
EPA744-R-00-011
October 2000
Integrated
Environmental
Management Systems
Implementation Guide
U.S.EPA
Office of
Pollution
Prevention
and Toxics
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Integrated
Environmental Management Systems
Implementation Guide
U.S.EPA
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 Airman, 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 fora Step in a Manufacturing Operation page 16
Figure 1-h. Input-Output Diagram fora 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
ISO 14001 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.
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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 Options
Option 1
Alternative Chemicals {
WOption 2
Alternative Processes °Ption 3
M ^
Environ- Describe
mental Function
Issue
\\
Alternative Technologies
Figure B: Pollution Prevention Hierarchy
SOURCE REDUCTIC
Substitutes
Process Change
Management Work Practice:
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
for ISO 14001 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 bfE website (www.epa.gov/dfe). See
Appendix & 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.
vn
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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 1:
Module 2:
Laying the Groundwork
Creating an Environmental Policy
Module 1: Laying the Groundwork
Module 3: Determining Significant Environmental Aspects and
Setting Objectives
Module 4:
Module 5:
Module 6:
Module 7:
Module 8:
Module 5:
Module 8:
Module 9:
Evaluating Alternatives
Setting Targets and Measuring Success
Developing Operational Controls
Implementing Your IEMS
Building Organizational Support
Setting Targets and Measuring Success
Building Organizational Support
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
Review
Commitment
and Policy
Continuous
Improvement
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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 DfE 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 IEMS Team
Company Function
iProduction
Maintenance
iFacilities
JEngineering
iStorage/lnventory
Management of environmental aspects of raw
material and product storage and in-facility
transportation
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 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
ions
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 DfE 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 DfE 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
Environmental
Aspect
En
I Icinn a rtartar
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 bfE website for more tools related to process mapping.
www. epa.go v/dfe
Tip
These technical sections are best de veloped through group discussions. There is no "righ t" 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-Ola 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
Manufacturing
Process,
Stepl
Manufacturing
Process,
Step 2
Manufacturing
Process,
Step 3
^
r
Process
Clean-Up
fc.
Packaging
Waste
Disposal
— >
Shipping
Building Maintenance
Lighting
Cleaning
Heating and Air Conditioning
Auxiliary Services (e.g., boilers,
compressors, electrical transformers)
Products
Services
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
Your
^ Your k _!
Origin HI Planter User •!DisP°sal
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
Spent Waste Noise
toner paper
cartridges from
mis-copies
16
Copy of
Document
-------
Figure 1-i. Input-Output Diagram for Cleaning a Printing Press
Inked
Press
Press
Cleaner
Clean Shop
Towels
CLEAN
PRESS
Soiled Waste
Shop Chemicals
Towels
Clean
Press
17
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Figure 1-j. Inputs and Outputs of a Company's Products and Services
Energy Materials
Chemicals ^^
Packaging ^^
PRODUCT
Use and
^ disposal
~~^ bv
consumer
Waste
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 in Appendix H for your data, then use the information to fill in EA-02 in the Company
Manual Template. ** 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
If 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 Jbe 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
"I. 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?
S. 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
-------
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?
&. 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.
25
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"I0. 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?
< Have there been failures in response to accidents or emergency situations?
< Is there a communications plan in place in the event of emergencies?
11 _ 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?
"I2. 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 bfE 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
30
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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 — ISO14001
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 be tter response if the managers had allparticipated in de ve lop ing 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.
DfE 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 I EMS 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 have EMSs)?
< 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 bfE 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
Step 1
Environ-
mental
Aspect
Chemical 1
Informa-
tion
Sources'3
MSDS,
trade
association
Regulatory Data: b
Carcinogen?
OSHA Permissible
Exposure Limit (PEL)?
Volatile Organic
Compound (VOC)?
Toxic Release
Inventory (TRI)?
Regulatory Data:6
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.
42
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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.
43
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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.
44
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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.
45
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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:
*lf 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.
46
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Figure 3-c: Screen Printing Exposure Pathways
47
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Figure 3-d: Dry Cleaning Exposure Pathways
48
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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.
49
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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.
judgment about priorities.
They are merely a shorthand for expressing your
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 Example"
Operation
Copying
Aspect"
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/Exp°
L/L
H/H
Worker
Safety
L
L
Other
Community
lssues: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)
Aspect15
Step 1
Toxic chemical
constituents
Wipers
Energy
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.
56
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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
57
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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.
58
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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.
Screenprinters in the SGI A /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 DfE website for more tools related to evaluating alternatives.
www. epa.go v/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
Alternatives4
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.
4 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, EPA FIFRA
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
rritant, liver,
-------
MEK 25%
sopropyl
alcohol 25%
Special blend
B: vegetable
ester
Technologies
Work Practices
Recycling/
Reuse
Treatment
Centrifuge used
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:
rritant respiratory
system, central
nervous system
depression,
nausea, dizziness,
neadache, gastro-
ntestinal, narcotic
effect
rritant nose &
:hroat, central
nervous system
depression,
vomiting,
neadache, coma,
death
Low
Same as Blend A
rritant eyes, skin,
dermatitis
rritant eye,
corneal burns,
dermatitis
_ow
Same as Blend A
large amounts:
headache,
nausea,
vomiting,
unconsciousnes
s, death
Low
Same as Blend
A
Same as
Blend A
may contribute
:o smog
nay contribute
:o smog
?
Same as Blend
A
?
?
no aquatic
loxicity
Same as
Blend A
?
?
?
Same as
Blend A
Highly flammable,
com bust ive,
Drotect from
noisture
rlammable,
•eactive, may
D reduce carbon
nonoxide and
carbon dioxide
Mo 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 exam pie, 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. 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.
73
-------
Worksheet 4-3 :a Alternatives Evaluation: Exposure to Chemicals and Materials
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 dur ng 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
Toluene
MEK
Isopropyl
alcohol
Blend B:
vegetable ester
Quantity Used per
Time Period
24 oz. Per day for
cleaning press
same
same
same
12 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
•espirator
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,
nhalation for
community
All for workers,
nhalation for
community
All for workers,
nhalation for
community
All for workers,
nhalation 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
ess volume
used and less
volatile mix)
Community
H (laundry
•eleases)
M
Environment
M
74
-------
Technologies
Work Practices
Recycling/
Reuse
Treatment
Centrifuge
'assuming
Blend A)
Disposal
8 oz recovered per
day - reduce
environmental
•eleases by 1/3
10 min while
outting wipers in
centrifuge
1 time per day
Gloves
Contact Person:
Inhalation, dermal
N/a
M w/o PPE
M (possibly some
Fumes from
venting centrifuge)
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.
75
-------
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:
76
-------
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
3 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.
77
-------
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 e valuation should be collected during the performance e valuation 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 DfE'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."
78
-------
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.
79
-------
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.
80
-------
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.
81
-------
Figure 4-a. Examples of Environmental Costs Incurred by Firms*
y ^8->y j4CTmi»roa^«!««iam>s»aa!THg^^ «!<4».u jemamm«m!jsew*i*t!*?ffi?<1p!"m!yx!mf
•fOf^i^piMt^^
Regulatory
* Notification
• Reporting
* Manitoring/tesling
• Studies/modeling
* Remediation
» Recordkeeping
* Plans *
- Training
. Manifesting
• Labeling
4 Preparedness
4 Protective equipment
* Medical surveillance
m En¥ironmental
insurance
• Financial assurance
, Pollution control
• Spill response »
« Storm water
management «
* Waste management •
* Taxes/fees *
Upfrant
Site studies
Site preparation
Permitting
R&O
Engineering and
procurement
Installation
Capital equipment
Materials
Labor
Supplies
Utilities
Structures
Salvage value
Back-End
Closure/
decommissioning
Disposal of inventory
Pc«t-ciosurs cane
Site survey
Voluntary
(Beyond Compliance)
» Community relations/
outreach
* Monitoringftesting
» Training
• Audits
• Qualifying suppliers
• Reports (e.g., annual
environ mental reports)
• Planning
* Feasibility studies
• Remediation
. Recycling
* Environmental studies
- R&D
* Habitat and weHand
protection
. Other environmental
projecls
• Financial Support 1c
environmental groups
and/or researchers
» Future compliance costs *
•. Penalties/fines *
» Response to future *
re leas&s
Remediation
Property damage
Personal injury
damage
• Legal expenses
« Natural resource
damages
• Economic loss
damagss
*x,w*nv~it"<} > t — tjurjur- a ' • A^«iS!ii?W^jraS^'fe?Wi^fei"^ElSjKi!a:* -AiSiiissaii&a&tSiaaafSsu
» Corporate image «
» Relationship with
customers .
» Relationships with
investors 4
» Relationship with insurers
OeSgtkinship with
professional staff
Refationshlp wilh
workers
Relationship with
suppliers
« Relationship with
lenders
• Relationship wilh
host communities
* Relationship with
regulate ns
Taken from "An Introduction to Environmental Accounting as a Business Management Tool: Key Concepts and
Terms," EPA742-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.
82
-------
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:
83
-------
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.
84
-------
Worksheet 4-9 b: 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
Contact Person:
Product
Quality
none
0
Reuse of or
Sales of
Recovered
Materials
none
$34,000
Date:
Total Revenue
Effects
0
$34,000
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.
85
-------
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
86
-------
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.
87
-------
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 Rank 3
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.
88
-------
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.
89
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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
5 Environmental Management System: An Implementation Guide for Small and Medium-Sized
Organizations, NSF International, Ann Arbor, Michigan, November 1996, p.49.
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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:
91
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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
\
p T3 O
^ o o
Q 8 b.b.
L/ne = i mporta
ntributing to the
onent
D 03 °
•fci F £=
/v
\
/X,
f
!l
The following are typical, but not necessarily obvious, causes of problems:
< poor communication,
< faulty or missing procedures,
< equipment malfunction (or lack of maintenance),
< lack of training,
< lack of understanding (of requirements), or
< failure to enforce rules.
Be sure that you have considered these possibilities in your environmental impact
analysis.
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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
Issue Date:
Notice
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,
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< operation and maintenance of equipment,
< 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
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causes identified in your root cause analysis that would contribute to the
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:
100
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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:
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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
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given to ensure completion. Appendix H contains a blank worksheet to assist you
in planning your environmental projects.
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
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control into your IEMS Program, future planning, and your annual management
review. Worksheet 7-2 provides an illustration.
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
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Contact:
Date Completed:
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 Response
Potential Emergency
Scenario
Potential
Environmental Impact
Action
Required
Procedures
Needed
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 framing 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
?
Completion
Date
?
Who is
Responsible
?
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 I EMS 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 Jbe 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
Ifs 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
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management and staff to understand how things are going if they have benchmarks
as guidelines.
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
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< number of complaints from community; number of responses to complaints
< 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
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check about each category to be assessed. These worksheets are more of a
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 IEMS 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
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management system need to be reviewed at once, and the review process may take
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 manufacturer and series #:
(specify):
• Check one:
0 - 25%.. .0 25 - 50%.. .0 50 - 75%.. .0 75 - 100%.. .0
Time between end of press run and start of ink removal with
(hours or mins. ; specify units)
product
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 note
any side effects of the product on the screen)
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?)
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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
1 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:
Time from emulsion removal completed to start of haze removal:
Dilution
Emulsion Remover
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
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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LmaofUPHr PROJECT BuiteiiN 4
A Cooperative Project
between the
U.S. Environmental
Protection Agency
and the
Printing Trade
Associations
Nationwide
October 1996
U.S.EPA
HIGHLIGHTS
This Bulletin highlights
How to Find a Setter
Blanket Wash for
Your Company
Ccst Categories
Blink* I Ctakftt
•to the trtshelio Chose
A Worksheet to Help YOU
choose a Better Wash
There are many factors to consider when choosing a blanket wash or other press chemical
thai Is best for your shop. Perhaps the most obvious arc purchase price anil performance.
But there are other, less obvious factors that arc just as important. How flammable is the wash?
is it a regulated material? How hazardous is it to worker health or to the environment? liven
if it is cheaper to buy, a wash that is more hazardous, 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 not
so obvious. Use it to compare your blanket wash options - it may help you find a blanket wasii
that is better for your shop.
The Worksheet: How Does it Work?
The worksheet can help you compare test blanket washes to your normal wash. Complete
the worksheet after you (or your press operators) IW 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 iw ymtr shop,
All 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 (MSDSI that comes with the blanket wash
* your blanket wash supplier
If the Final Worksheet Scon is...
Greater titan zero
Less tiian 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 batter cholc©
for your facility than your norms! blanket wash
The test wash is approximately the
same as your normal wash
° tf the test wash appears to be approximately the same as your normal wash overall, look at each
Individual category. Which is most important to you? Different scares in that category may still
help you decide which blanket wash is best for your shop.
156
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I Could a wash be a better choice for pur
1* Use the scorecard below to figure out whether a substitute blanket wash mav be a better choice for your facility.
fcfc,
<}, Add the scores to see if the substitute wash is better, worse, or the same as your current wash.
TestWash:
Supplier Name and Phone:
j,f(« I |f 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:
Enter
Scores Score
Compared to your normal blanket wash, -2 -t o i 2 Below
; 1 I Is the price per gallon of the test blanket wash: ,,, ,Maeh more More Saute Less Much less
3" J Is the amount of test wash used to clean each blanket: .Much more More Same Less Much less
5 ; Is ths lime required to clean B blanket with tho tast wash: Much more More Same Lew Much tew,
f—- ' '
| '& What does the press operator think ol the ten blanket wash? bit Much worse Worse Sam* Better Much better
Consult MSDS forms and contact the blanket wash supplier (o answer questions *>-<).
Does the test wash Contain hazardous chemicals as defined by Federal/State enviranmamM regulations or OSHA? Ye» = -2 Ho » 2!
Scores
Compared to your normal blanket wash, -2 -101 2
j t J ] is th» vapor pressure of the test wash; , Much higher Higher Same Lower Much Lower
| /*! h the percentage VOCs of the test wash: .Much higher Higher Sam* Lower Much ioww
| SI is the flash point of the test wash; Much lower Lower Same Higher Much higher
f How does tho test wash compare on any other factors: ,.,, Much worse Worse Sime Better Much better
Add all nine scores on this worksheet to get the total score for this test blanket wash. Total i
Remember, when adding negative numbers -2 + 2^0,
What dees the score mean?
A score greater than zero means the test wash may be 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.
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W orksheet Quest
o n s
What Do They Mean?
price; 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?
1'hc most obvious difference between two blanket washes is the cost to buy them, OompMe
the cost per gallon of your normal wash to the tesl wash, Answer "much more"
if the test wash costs twice ;is much as your normal wash or "much less" if it is half the
price, or less, lector in dilution ratios tor those washes that are shipped its eo
Amount Compared to your normal blanket wash, h the amount
of test wash used to clean each blanket much more, more, the same, less, or much less?
The more wash you use each time you clean a blanket, the more it costs you. Ask press
operators how much of the test wash Ls needed to clean I he blanket compared io ihtr amount
of normal wash. Answer "much more" (f it takes twice as much test wash or "much less" if if
takes less ih clean the blanket, mHwen*
"much more". Answer "much less" If the test wash lakes only half as long as 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?
A.sk press operators to compare the test wash to the mx'irui! wash on odor, blanket swell, the
time required for the press to conic hack to color, the effort required to use the washes, and
any other factors they think are important, Combine these Into an overall score for this ques-
tion,
Use the
Worksheet to
Choose a Better
Roller Wash Too!
Hazardous chemical*: Does the test wash contain hazardous chemicals as defined by
environmental laws or the Occupational Safety and Health Act iOSHAI?
Contact the supplier or manufacturer Jbr this jntoriniutou. A variety of environmental regula-
tions apply to h;i£!irdo»s matcruils hccause of their potential clangers to people ami Use envi-
ronment. Violations may result Jn large finrs. At the very kast, using a rcRiiIatcd haxardouH
chemical may increu.se compliance costs. Ask your blanket wash supplier if the blanket wash,
or its waste, is considered hazarcfous under :my ciivirountcnia! law (such as KOUA, ("AA, CllK.-
CLA, or liPCRA • Section 2, etc.) or tinder OSHA. Never mix ha&irtbus and nyn-hnxyrdoiis
wastes, The ha&;r»-
tuio OSHA hazardous chemicals, [kit beware. The MSDS lists OSHA hazsuxlous chemicals only,
The blanket wash may still cont.im chemicals tleftneil as hazardous hy oilier environmental reg-
ulations, If this* section is blank, ask your supplier, .See QiiestJoiss to Ask Wfeea You Call
Yotir Blanket Wasls Supplicf for more sHtbnnation,
0@$jgn far tin E
158
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If the test wish vapor pressure (in rnwH^ is
Batwran IB tines hiyhv and 1.5 times lovm
BetwEsii 1.B tines gmt ten times lower
More than ten tines low»
Ewaporatiort: Compared to your normal blanket wash, Is the
vapor pressure of the test wash much higher, higher, the same,
lower, or much lower?
See MSDS Section 3 - 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 a blanket wash, {he quicker is evaporates, If a blanket
wash has hazardous ingredients, (hey can evaporate itiio the air In
your shop, enter the lungs of your workers, and pollute the sur-
rounding environment. If the vapor pressure of your lest wash is
less than the wash von are currently using.il m;iy evaporate less in your shop. Vapor
pressure is usually expressed in minllg. Call your supplier if (lie vapor pressures of the
washes are expressed in different units. 10 mmHg is usually x regulatory cut-off, but tit
lower the vapor pressure ihe (letter.
Environmental Regulations and Worker Health; Compared to your normal
blanket wash, Is the percentage VOCs of the test wash much higher, higher, the same, tower,
or much lower?
Contact supplier or manufacturer 1'or this Information. The amount of Volatile Organic
Compounds (VOCs) in your blanket wash can affect your cosis of complying with
environmental regulations, especially Clears Air Act regulations on emissions from your shop.
VOCs contribute to lower level smog and may have health concerns. If the test blanket wash
has low or no VOC content, your environmental compliance responsibilities (and costs) may-
he lowered and the health and safety of your employees may be improved. You might need to
contact your blanket wash manufacturer lor this item (sec Questions to Ask When You Cad
Your Blankci Wash Supplier for more information). Score "much higher" if the percentage
YOC content of Ihe test wash is two times or more that of the normal wash or "much lower" if
the percentage VOC content of the test wash is two times or more lower. Score "same" if with-
in 10%.
Fiammability: Compared to your normal blanket wash. Is the flash point of the test wash
much higher, higher, the same, lower, or much lower?
See MSDS Section 4 • Fire and Explosion Data - for flash point information. The flash point
is one measurement of the temperature at which a chemical will ignite, In general, as flash
point increases, so docs safety, liven though the minimum flash point for flammability is 100" F
and for hazardous wastes is H0"i; the higher the flash point the better A less flammable chemi-
cal may save you money on your property insurance a.s well as exempt you from costly storage
and reeord keeping requirements of environmental and safety regulations such as RCRA and
OSHA. Contact your insurance underwriter for a reappraisal !o determine the cost savings from
using a less flammable blanket wash at your shop. If the flash point of the test wash is two
times lower than the normal wash, mark "much lower" on the worksheet. If the flash point of
the test wash fe more than two limes higher, mark "much higher" on the worksheet. Score
"same" if within 15"l;.
Score
Much higher
San
lowar
Mucli tar
Other: Compared to your normal blanket wash. How does the test wash compare on any
other factors? Much worse, worse, same, bettor, or much better?
Compare the performance of the lest wash to your normal wash on any other factors
important lo your shop. Some examples include acceptability of wash to commercial laundry,
eorrison of press parts, wash availability, dilution, and availability of recycled containers.
thsip fa Ilia Ewtonrotul 3
159
-------
Why a Worksheet?
The worksheet provided with
this bulletin gives you a place
to keep information about the
washes you try out at your
shop. Make extra copies of the
blank worksheet arid record
information about each blanket
wash you t«st. After trying a
variety of wastes, you can use
the completed worksheets to
compare them and find the
one that Is best for your shop.
The worksheet is not a
scientific evaluation and
may not cover every potential
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, and safety costs of blanket washes are often hidden,
if your lest wash is less harmful to your workers or the environment, or is less
flammable than your current blanket wash, you may save money hy using it even
if il costs more per gallon. Potential savings Include:
•* Improved waiter aaii salety
••'» cBSts (such its workers compensation, fire, anil liability)
---?> Other decreased costs (such as energy)
Choosing a Better Wash — An Example
By testing a variety of washes you may he able to find one that Is cheaper to use and better
for the environment. During the Dili Lithography Project (see page (t for more Information),
a vegetable ester wash was found that worked well and cost (ess 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 (he petroleum-based wash at one facility, but was more expensive at another
facility. White savings may he even greater when factors such as those 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.
160
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What You Can Do To
Compare Blanket Washes
follow I be checklist
below when nesting
different blanket washes:
Test Blanket Wash for a Set
Amount of lima:
a Discuss blanket wash
tests with press operators
i Sat a trial period of one
of 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 ,
i 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:
o Does the final result
indicate potential
improvement?
0 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 & better blanket wash will require some
i-X|x*rinK'nt;itifm and ;in open mind. Not every blanket wash will work well at your shop
right away, but some may work belter us press operators become more eomlhrmhk' with
them. For this reason* allow a set period of time for trying ;i blanket wash, and stick 10 it,
F<>r more idea* on cost saving ways to reduce pollution ami w«tste at your facility, see other
Design for the linvifomoeni (DilJ) Bulletins for the Lithographic Industry.
to Ask You Call Your
To complete the worksheet you will 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.)
Poes the blanket wash contain chemicals deemed hazardous
under anv environmental statute or OSHA?
What is the percent Volatile Organic Compound
(VOC1 content of the blanket wash?
What is the Vapor Pressure at the wash In mmHg?
About the Design for the Environment Lithography Project
The goal of (he Design for the Environment (Ofli) Lithography Project Is to provide lithographers
with information that can help them design an operation which is more environmentally sound,
safer for workers, and more cost effective.
Concentrating cm the process of blanket washes, (he partners of the Dfil Lithography Project,
in a voluntary cooperative effort, evaluated 37 different blanket wash products, information
was gathered on tin* perforni-in.ee, cost, and health and etwironmenyU risk trade-offs of the
different types of substitute blanket wash. For more details on the
evaluations, please refer to the booklet, Hiwlttating ftlunket Washes:
A Guide Fur Printers.
In addition to the Lithography Project, similar DfH projects are currently
underway with hoth the screen printing and llcxography Industries.
To obtain additional copies of (his or other bulletins and case studies, or for more information
about BPA's Design for the Environment Program contact:
EPA\s Pollution Prevention Information Clearinghouse
-------
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.
162
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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 ;t«W \ "Cleaner" and BiaM 8
Cleaner" with Bm4 t CVtantr and replacing the fcrnr^ &
"Stencil Remover" withifftrtlC*' "Stencil Remover". The biggest
$ impact is the difference in price and yield of gfi&fiA G"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 . fcmwd ^ "Cleaner".
is non-hazardous. It contains no
cyclohexanone, xylene or glycol ether. The flash point is 122F.
Brant X 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 f5nm)4 ^
"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.
163
-------
AH 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 ficftnd 0 OlearWY- onto the ink
side of screen
H. Squeegee off ink into small bucket below screen
IIL Repeat steps 1 and 2
IV, Wipe with cloth rag saturated with 3 oz. of Bm«J A
"Cleaner", Repeats this operation an average of 3 times
¥. Wipes with dry rag
VI. Total time: an average 5.5 minutes (This depends on
UV or Solvent ink used or whether black ink was used)
Proposed Method
I. Spray 1 oz. of Sn&Azl C* Ckfrnsr onto the ink
side of screen
n. Squeegee off ink into small bucket below screen
HI, Repeat steps 1 and 2
IV. Spray 1 oz. of 6m«iG Cleo^r ^ 7 on cloth rag and
wipe clean
V. Total time: an average of 4 minutes
Cost Comparison
I Cost Elements:
L ftrt^ 6 CJeanftr* - $800/55gals. or
,114/ok.
2. Brand ftCteoiw - $590/55gals. or
.084/oz.
3. irema C Oefwifer , - $735/55gals. or
.104/oz.
164
-------
II. Present Method:
1. 4 oz. of. SrW 8 cifonec - $ .456
2. 9 oz, of e>rt*nd A CAeflkftW - J56
'total Chemical Cost -$1.21
III. Proposed Method:
1. 3 oz. of ( &riMv\ O a*ww, ; - $ .315
Total Chemical Cost - $ .315
IV. Yearly Chemical Savings:
50 screens/day X 250 workdays/year X $.895
savings/screen — SI 1»188
V, Yearly Labor Savings:
50 screens/day X 250 work days/year X
1.5 minute savings/screen / 60min./hour
X$10/hour - $3,125
Reclaiming Process for Screens. Of the 50 screens that cycle
through the Screen Room, only 30 (est.) screens go through this
additional step to remove the emulsion.
Present Method
I. Spray 5 oz, of • fcn^ (> %ed 9$ \ on both sides
II. Power Rinse w/water - 1 side
III. Spray both sides with. 6roM fc ^
-------
Proposed Method
!. Spray 5 oz. of Bn*(d c^Pttikot- 1 on both sides
II. Power rinse w/water - 1 side
HI. Spray with 'Brand o frt?4ttc4 Z. " - I side-45oz.
IV, Power rinse w/water - 1 side
V. A) 25 % of screens; Brush with Brt\r»d| o Fr«to£
- both sides- 1 ,4oz,
B) 75% of screens: Wipe with cloth rag saturated with
fcr-Ard ""6 ' pnj&tfr *r-2 sides-2oz,; Go to step VIII**
VI 25% of screens; 10 minute queue time so #VA will
work
VIL 25% of screens; Power rinse w/ water - 1 side
VIIL Move to Rinse tank
IX. Total time; an average 6 minutes
**This is possible because of the elimination of
K Cleaner" which locks the image into the mesh,
ee«w4 C- fVoAwvc* 3 will only be needed on dark colors,
part, black,**
Cost Comparison
I, Cost Elements;
1. Bnj>nd c.^Pco
-------
3. 1.4 oz, of iSrawJI O ftxriw* 5 - , .388
Total Chemical Cost $2.25
II. Proposed Method:
1. 5oz, ofan^e-jWiAC-fl - $.740
2, 45 oz. of Brwd C- ft^dwj z. ,270
3. 25% of screens; 1.4 oz. of
•e^rd C- ftttUtit-s .388
75% of screens: 2 oz, of
tord O RoxiiAd 4- .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(75% of total) X 250 workdays/year
X $1.22 savings/screen *= $1439.8
IV. Yearly Labor Savings:
30 screens/day X 250 workdays/year X 2 minutes
savings/screen / 60min./hour X $10/hour= $2^500
YEARLY SAVINGS IN SCREEN OPERATIONS:
CHEMICAL SAVINGS - $25,586
LABOR SAVINGS - 5,625
TOTAL $31,211
167
-------
DESIGN ART
Cbllect
Gust omer Specs/
Develop Preliminary
Layout
Final Layout
Customer
Approval
Dgit al Out put
to Film
RECEIVE MATERIALS
Inspect Shipments
Invent ory
Control
Mat erial
Handling and
Freparat ion
168
-------
PREPARE EMULSION AND SCREEN
L
f Film N^ ^^^
V Negat ivesy^^^^^
/ Stretch Mesh
and
Attach to Frame/
I
Apply Emulsion
or capillary film
to mesh and dry.
i
Expose Negat ive
i
Wash t o reveal
image and dry
7
^^^ Block out /
/ andRnhde/
INK PREPARATION
V\6rkCrder
from
Account
Management
169
-------
PRMT
Regist er Press
for
Product ion Run
I
PRIISTT
170
-------
INPUT/OUTPUT SUMMARY
NC Process Flow Maps
RECEIVE MATERIALS
I Store Shipment
Inputs
a Energy
Q Building Space
Q Safe Storage
Q Recordkceping
Outputs
a Leaking Containers
p Waste Products
D Spills 0?)
II Inventory Control
Inputs
Q Energy
a Kecordkecpmg
Outputs
a Expired Products
U Waste Products
IjlJMaterigl Handling & Preparation
Inputs
a Energy
a Recardkecping
Outputs
Q limply containers
171
-------
DESIGN ART
Specifications
Inputs
a Energy
a Paperwork
Outputs
a Unusable Artwork
Q Waste Packaging Materials
Inputs
Q Energy
Q Paperwork
a Proofing Materials
Outputs
a Spent Printer Toner (cartridge)
a Paper
a Unusable Artwork
a Waste Packaging
1 II ! Customer App roval
Inputs
U Energy
Q Paperwork
IV_Final .
Inputs
D Energy
0 Paperwork
V Digital Q,yjputJ
Inputs
D Energy
D Paperwork
0 Film Stock
U Imaging Device
u Imaging Material
Outputs
u Spent Imaging Materials
D Waste Film
172
-------
PREPARE EMULSION AND SCREEN
I Strctcfr Mesh & Attach to Frame
Inputs
o Frame
D Mesh
o Adhesive
Q Energy
Q Paperwork
Outputs
Q Minimal Air Emissions
Q Waste Adhesive
u Waste Mesh
Q Waste Frame (potential)
a Used Razorblades
n Apply Emulsion or Capillary Film to Mesh and Dry
Inputs
D Energy
n Paperwork
Cl Activator
D Film or Emulsion
a Water
Outputs
Q Expired Emulsion
0 Waste Emulsion
Q Waste Activator
Inputs
a Energy
a Paperwork
Q Film Positive (or negative)
D UV Bulbs
Outputs
a UV Bulbs
a Film
XY
Inputs
u Energy
D Water
a Light Bulbs
Outputs
o Waste Water
a U$ed Light Bulbs
173
-------
PREPARE EMULSION AND SCREEN (cont'd)
V Blackout &
Inputs
O lincrgy
a Paperwork
O B lockout
u Water
o Tape
Ci Waste Water
U Waste Blockout
u Waste ttlockout Applicator
p Hxpircd Materials
174
-------
INK PREPARATION
/ Color Match Approve!
Inputs
Q Bner&y
o Paperwork
Q Jnk
D Substrate
Q Containers
u Solvents
G Additives
D Mesh
D UV Bulbs
Outputs
o Waste Ink
a Mixing Sticks
o Empty Containers
D Color Proofing
O Substrate
u Used Shop Rags
a Waste Mesh (potential)
Q Waslo Frame (potential)
Ji Mix Ink
Inputs
u Energy
a Paperwork
a Containers
D Substrate
a Solvents
o Ink
a Ink Additives
Outputs
a Waste Ink
D Waste Ink Additives
Q limply Containers
a Substrate
D Mixing Sticks
U Used Shop Rags
175
-------
PRINT
Inputs
O
a Paperwork
Outputs
a Used Shop Rags
Inputs
a Shop Rags
O Additives
a Solvents
O Paperwork
p Energy
U Substrate
u Ink
Outputs
a Used Shop Towels
D Tape
O Setup Paper
Q Waste Substrate
a Waste Ink
in Print
Inputs
Q Energy
a Shop Rags
Q .Paperwork
a Solvents
D Additives
Q Substrate
a Ink
O Coatings
u Adliesives
Outputs
Q Used Shop Rags
o Waste Jnks
o Waste Solvent
Q Spills (possible)
o Used ink Containers
u Tape
176
-------
SCREEN RECLAIMING
I Apply Ink Itcmovcr
Inputs
O Solvent
a Shop Rags
Q Squeegee
D Ink Remover
Q Storage ConU!,incr
Outputs
U Used Shop Rags
p Waste Ink
a Spills (possible)
a Energy
a Waicr
Outputs
Q Waste Water
HI JteniQVc Km iitsion or Capillary
Inputs
Q Energy
D Shop Rags
Q Water
p Stencil Remover
Q Scrubbers
Outputs
o Waster Waier
D Tape
Q Used Shop Rags
G Spills (possible)
IV Ulnsc
Inputs
n Bnergy
Q Wai«r
Outputs
Q Waste Water
Inputs
u
O Water
G Haze Remover
a Scrubbers
a Shop Hags
177
-------
SCREEN RECLAIMING (cont'd)
Output
a Waster Water
o Used Shop Rags
G Spills (possible)
VI Rinse
Inputs
O I vnorgy
u Water
Outputs
D Waste Water
VII Drv
Inputs
D Lincrgy
178
-------
FINISHING, PACKAGING, & SHIPPING
j Finishiitg .
Inputs
G Paperwork
u Knergy
D Wnshing Materials
u iMnisliing Tools
P Tape
Outputs
u Waste Material
U Trimmings
u Adhesive
u Spent Kinislitng Materials
a Spent Finishing Tools
JI racknpiog Activities
Inputs
n Hnetgy
o Paperwork
0 Pallets
D Boxes
o Packing Materials
Outputs
Q Broken Containers
O Packaging Waste
|II Ship^iin^ Activiticji
Inputs
O Transportation
Q tinergy
D Paperwork
Outputs
D Refused Product
Q Transportation Hmtssions
179
-------
SIGNIFICANT ENVIRONMENTAL ASPECTS (SEAs)
1) Reduce VOCs
2) Contain lead contamination (water table)
3) Employee health and safety
180
-------
Worksheet 8-1 : Functions and Alternatives
Aspect
B*Stli>W»
P^C^bw
Alternative Product*
•Scr-atvi o(0OMJMy
Vr\Vs- /*r*
*W«A*v.
r«wi« / ,y\V. few
Brand C, Cleans*"
ftrttfii o CAeaney
Alternative
Technologies
cv-ev
^vrh» iCA--«j:-vx
OO*«.slia-v
Alternative Work
Practices
Recycling'
Reuse
Treatment
Disposal
Date Completed: Contact Person:
Worksheet 8-2: Alternative Products Environmental Effects Comparison
Chemical Product
Baseline
'SrorxiCGWher
Brilfti D C>£,W
Known Effects1
Cft-VlC'C.j^1
Hr F,R
Odor
SK,n
irrr^«A\y>
Management of Effects2
^\oV<*2>
esHrVtM.^f A-v*S
glpvj
-------
Worksheet 8-3: Performance Comparison of Alternatives
now well does It work how long does It take how easy Is It to use total
cWarw
Brand
\s
Worksheet 8-4: Regulatory Comparison of Alternatives
Regulations Required
Controls Required
Cost of Regulations
Total
Brand A
t'f
182
-------
Worksheet 8-5: Cost Comparison of Alternatives
raw
material
labor
disposal
tout coat
savings '
nateoat
&>$**
***
Worksheet 8-6: Alternative Products Evaluation Worksheet
Chemical Product
'Brat^A-
ftflmHO
&ramdD
Performance
_ .
•/-
•+
Regulations
-
•f"
f-
Coat
—
-y-f-
f-
Effects' Score
^~
-f
-f f"
Overall
Score1
Date Completed: Contact Person:
Take score from Environmental Effects Comparison Table above (last column).
! Score on a scale of low to high to reflect the desirability of each product. This is a judgment call.
183
-------
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.I 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.
fable 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
184
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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. 1 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."
185
-------
Figure F.1 Current Cleaning Process
Product
Input
Solvent
Energy
Cleaning
Spent
Solvent
Product
Output
Figure F.2 Alternative Cleaning Process
Product
Input
Make-up
Solvent
Energy -
Recovered Solvent-
Cleaning
Product
Output
-Spent Solvent-
Distillation
186
-------
Note: Remember that
changes in one process may
affect costs in other
Drocesses. 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.
187
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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
Recordkeeping
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.
188
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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)
189
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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, 100. 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:
FVt
-T—\
(l + 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 = 7 - ri + 7 - r2 + 7 - rs + 7 - r4 or:
(1 + 0.10) (1 + 0.10) (1 + 0.10) (1 + 0.10)
190
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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 SPV 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.
191
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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.landF.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
192
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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
193
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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
194
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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.
195
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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. orCu. 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).
196
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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
197
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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.
198
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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.
199
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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.htm
DfE website: http://www.epa.gov/dfe
The John Roberts Company
9687 East River Road
Minneapolis, MN 55433
(612)755-0394
200
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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
401M Street, S.W. (7406)
Washington, B.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
401M Street, S.W. (7406)
Washington, B.C. 20460
Phone: 202-260-1566
E-mail: prothero.scott@epa.gov
201
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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:
Franklyn Hall
U.S. Environmental Protection Agency
OPPT, Economics, Exposure & Technology Division
401M Street, S.W. (7406)
Washington, B.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
401M Street, S.W.
Washington, B.C. 20460
Phone: 202-260-3928
E-mail: delphire.lynn@epamail.gov
202
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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
401M Street, S.W. (7406)
Washington, B.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.
204
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Worksheet 1-1: Costs and Benefits of Developing and Implementing an IEMS
Costs
Contact Person:
Benefits
Date completed:
205
-------
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.
206
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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
207
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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:
208
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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.
209
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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.
210
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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
211
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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.
212
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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:
*lf 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.
213
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Worksheet 3-3: Community Issues
Operation
Aspect
Community Issues (List)
Rank
Contact Person: Date:
214
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Worksheet 3-4: Natural Resources Use
Operation
Aspect
Natural Resources Used
Rank
Contact Person: Date:
215
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Worksheet 3-5:a Criteria to Determine Significant Aspects'3
Operation
Aspect"
Regulatory
Concerns
Chemical and Material Risk
Worker
Eff/Expc
Community
Eff/Expc
Contact Person:
Environment
Eff/Expc
Worker
Safety
Other
Community
lssues: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
216
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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:
217
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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
218
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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:
219
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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.
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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)?
uman Health Effects by
'athways
cute and Chronic0
nhalation
Dermal
Oral
Comments
Effects on Wildlife
and Other
Environmental
Effects d
Air
Water
Land
Worker
Safety6
Rank
Human f
Env
221
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Contact Person:
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 drink a
certain amount of Scotch. Drinking a large quantity of Scptch, 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.
222
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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 Period
Exposure Time
Duration**
Frequency
Personal Protective
Equipment (PPE)
Contact Person:
Pathway
Human:
Inhalation,
Dermal, Oral
Environment:
air, water, land
Rank Exposed Groups
Workers
Community
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.
223
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Worksheet: 4-4: Alternatives Evaluation: Community Issues
Significant Environmental Aspect:
Alternative
Community Issues (List)
Contact Person:
Rank
Date:
224
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Worksheet: 4-5: Alternatives Evaluation: Natural Resource Use
Significant Environmental Aspect:
Alternative
Natural Resources Used (List)
Contact Person:
Rank
Date:
225
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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.
226
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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.
227
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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.
228
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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:
229
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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
230
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Worksheet 4-9c: Initial Investment Costs*
Significant Environmental Aspect:
Baseline:
Alternative
Purchased
Equipment
Utility Systems/
Connection
Planning/
Engineering
Site
Preparation
Contact Person:
Construction/
Installation
Start-up/
Training
Permitting
Other**
Total Inv.
Costs
Date:
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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.
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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.
233
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Figure 5-a. Root Cause Diagram
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Worksheet 5-1: Environmental Performance Measurement Indicators
Aspect
Objective
Indicator
Date
Checked
Contact Person:
Who Checked
Result
Corrective Action
Date Completed:
235
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Worksheet 5-2: Calibration Log
Indicator
Measurement Method
Contact Person:
Equipment Used
Equipment calibrated:
date/method
Date Completed:
236
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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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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.
238
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Worksheet 6-2: Operational Control Responsibilities
Significant Aspect
Procedures (list)
Contact Person:
Responsible for
maintaining
controls
Date Completed:
239
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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:
240
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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:
241
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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.
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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:
243
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Worksheet 7-4: Environmental Emergency Preparedness and Res
Potential Emergency
Scenario
Potential Environmental
Impact
Action Required
ponse
Procedures Needed
Training Needed
244
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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:
245
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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.
246
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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:
247
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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.
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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.
249
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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:
250
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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.
251
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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 IEMS 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.
252
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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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