PRACTICAL TOOLS & CONCEPTS
for
ENVIRONMENTAL AUDITS & ASSESSMENTS
EPA/600/A-93/280
by
James S. Bridges
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, Ohio, USA 45268
Presented at
Environmental Audit Seminar
Singapore, July 27, 1993
KEY ISSUE: How can we produce and consume goods and services within'compliance
of environmental regulations, in the most efficient manner, with the least cost
and environmental impact?
Introduction:
There are a number of practical tools and concepts to assist decision-makers in
determining the best choices for environmentally conscious production and
consumption. For the last twenty years corporate environmental responsibi1ity
has been increasing to protect corporate tfirectors and the company from liability
claims, regulatory problems, public pressure, and other external and internal
environmental issues. The purpose of this paper is to discuss the use of
Environmental Audits (EA), Pollution Prevention Opportunity Assessments (PPOA),
and Life Cycle Assessment (LCA) as management tools designed to identify and
evaluate waste generating activities, to determine how to best manage the waste
stream, and to implement a waste management program and measure environmental
progress.
Environmental Auditing
Environmental Auditing (EA) is the basic tool used by management to facilitate
control of environmental practices and is usually conducted as an internal
process by a company to ensure compliance with environmental regulations and
operating practices established by the company. The EA is an acceptable well-
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organized systematic approach to determine if waste streams meet the regulatory
standards for use, treatment,, storage,, disposal and release. Regulatory
organization within government entities encourage companies to develop and
implement an internal EA program tailored for the needs of the company. The
public and clients consider companies who have a sound EA program as good
environmental stewards and good neighbors within the community. The decision-
makers within the company consider good environmental management to be an
essential part of good management practices for the company and industry. As
companies embrace accepted management practices such as Total Quality Management
(TQM) for critical self-examinations of the company's processes and technologies,
EA becomes the tool of choice to make it happen.
Regular auditing provides all involved with a better understanding of the
company's procedures and processes and permits the employees to become aware of
the compliance issues and risks to human health and the environment. This
awareness encourages management and non-management personnel to seek solutions
for environmental issues together including the use of technologies and practices
which reduce the generation of wastes through material and process/operation
changes. EA should not be seen as only a tool to achieve environmental
compl iance, but a way to achieve environmental1y sound manufacturing of goods and
services which will benefit the producer and consumer.
Larger companies have established formal EA programs as the major part of
corporate environmental management, and have established EA Teams to conduct
periodic audits. It is important that the individuals on these teams are
properly trained with the skills and knowledge to perform the EA functions and
continue to be aware of innovative technologies and techniques' for waste
reduction and control -as well as changes in environmental regulations and
policies. Cooperation and coordination with regulatory permit personnel and
environmental inspectors will establish a good working relationship for all who
are trying to meet the same overall goal. It is also important for larger
companies to support trade and professional associations who support smal1-medium
size companies who often perform functions for the larger companies under sub-
contracts and offer services where it is not cost effective for the larger
companies. Both large and small companies should adhere to environmental
regulations and environmental stewardship, especially within the community.
Environmental Auditing has evolved over the years with differing procedures and
internal tools to review and evaluate waste generating activities. In the United
States, EA has evolved with the myriad of local, state and federal regulations.
While multi-media EA is ideal in concept, in practice the complexities and
details of separate environmental laws usually require several auditors because
there are few auditors with the experience and knowledge in all of the
environmental laws and media. Again, it is so important for auditors to keep
current with changing technologies and environmental regulations. At the sane
time it is tempting to add related areas to the EA such as safety and health,
energy, and pollution prevention and too many additions may weaken the EA. The
more that is added to the EA, the greater the chance for not fulfilling the,
objectives sought.
Regardless of the EA tool selected for your company's EA there are a number of
essential elements that need to be included. These elements, listed in Figure
1, can be added to by other elements specific for a corpany.
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o Management Support
o Compliance Team Objectivity
o Qua 1i fied Audi t Team
o Systematic Approach
o Proper Documentation
o Qua 1ity Assurance
o Follow-up of Recommendations
Figure 1.
Essential Elements of EA
EA may vary in some details, but all have generic characteristics as noted with
the essential elements described previously. The basic steps/approach are: 1.
Pre-Audit 2. Audit 3. Post-Audit. Over time these characteristies have formed
the sound basis for EA around the world. Figure 2 lists these EA
characteristics.
PRE-AUDIT .
Select Boundaries
Schedule Audit
Select Audit Team
Pre-Audit Visit
Gather Data
AUDIT
Site Review Meeting
Assess Controls
Gather Audit Data
Evaluate Findings
Present Findings
POST-AUDIT ¦
Issue Oraft Report
Integrate Feedback
Issue Final Report
Implementation
Follow-up
Figure 2.
Basic Steps of EA
Pollution Prevention Opportunity Assessment
While EA targets environmental compliance, the pollution prevention opportunity
assessment (PPOA) targets the reduction or elimination of waste generation
regardless of regulatory constraints. A major element in any company's
environmental program is carrying out periodic assessments to identify
opportunities for reducing waste. The steps involved in conducting a PPOA are
outlined in figure 3 and are similar to the systematic approach for conducting
an environmental audit. The differences occur with the selection of the waste
stream which may not be regulated, the selection of team members which requires
more technical knowledge of the process and the products and perhaps less
knowledge of environmental regulations than their EA counterparts, and the
feasibility analysis phase for selecting options for implementation.
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When EA and the PPOA are combined for .nulti-media environmental assessments, it
is customary for the member(s) representing PPOA to accompany the EA team members
to acknowledge where compliance issues exist and where major waste streams are
being monitored. It is important for the pollution prevention team members to
look beyond the compliance focus which may require additional discussions and
independent evaluations not considered by the EA team members. Since it is
important to have the involvement and consensus building of company employees,
the EA part of combined EA/PPOA may stifle the creativity and openness needed for
successful PPOAs. Executives and managers will assign priorities and set the
tone for audits and assessments. Quite often, environmental compliance becomes
the overall focus and this focus increases pressure for pollution prevention
members to provide pollution prevention opportunities for all compliance issues.
There are several practical EPA "tools" for conducting PPOAs. The Facilitv
Pollution Prevention Guide. (EPA/600/R-92/088) pictured in figure 4, was written
for those individuals responsible for implementing pollution prevention in their
facilities. The "Guide" describes how to identify, assess, and implement
opportunities for pollution prevention and how to stimulate the ongoing search
for such opportunities. Companies that have used the generalized approach
described in the "Guide" to establishing a pollution prevention program within
their facility have found that they reduced both their operating costs and their
potential liabilities while providing environmental stewardship. Other PPOA
"tools" include a series of industry-specific guides which include case studies
within the specific industry (see figure 5).
Facility Poulhon Pmvcvtioh Gudc
• Guides to Pollution Prevention
Pesticide Formulating Industry
Paint Manufacturing Industry
Fabricated Metal Products Industry
Printed Circuit Board Industry
Commercial Printing tndusiry
Selected Hospital Waste Streams
Research and Education Institutions
Photoprocessing Industry
Auto Repair Industry
Fiberglass Reinforced and Composite
Plastics Industries
Marine Maintenance/Repair Industry
Automotive Refinishing Industry
Pharmaceutical Industry
Mechanical Equipment Repair
Meial CaslinjfUeat Treating Industry
Metal Finishing Industry
(EP.V62i^-90/004)
(EP/V62V7-90/005)
(EPA/625/7-90/006)
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(EPA/625/R-92/009)
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Figure 4.
Faci1ity Pollution
Prevention Guide
Figure 5.
Industry- Specific
Pollution Prevention Guides
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Life Cycle Assessment (LCA) •
ICA is a tool that assists the decision-maker in looking at a product, process,
•or activity from its inception through its completion. For environmental use,
the LCA can provide a way of addressing potential pollution prevention issues and
determining environmental impacts within a system's boundary. Two popular
manuals developed by EPA's Risk Reduction Engineering Laboratory are: 1) Li fe-
Cvcle Assessment: Inventory Guidelines and Principles (EPA/600/R-92/245) and 2)
Life Cycle Design Manual (EPA/600/R-92/226). (See figure 6)
LIFE CYCLE OESIGN
GUIDANCE MANUAL
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statements which make this document very easy to use. The next step is to get
real data and feedback from this manual's use. For EA/PPCA teams, it is helpful
to review this document in light of the company's operations and understand the
concept of LCA. There are occasions during the conduct of an audit/assessment
when it is necessary to place the boundaries of thought beyond the immediate
activity or operation and consider environmental impacts upstream and downstream.
For example, the solution to a waste generation problem at a manufacturing plant
may be found further upstream in the system and may result from a change in the
raw material needed for manufacturing.
The Life Cycle Design Guidance Manual was developed to promote the reduction of
environmental impacts and health risks through a systems approach design based
on the life cycle concept. While this document targets the design, manufacture,
use and disposal of a specific product, the design procedure can also be applied
to a process or activity. Consideration of designs that reduce total
environmental impacts and satisfy customer needs are two goals of this "tool" in
assisting designers. Since the life cycle framework provides the most complete
profile of goods and services, the design practitioner is encouraged to adopt
environmental criteria based on the life cycle concept. Anyone who produces a
product or provides a service will benefit from using this environmental tool.
This manual is a working document and comments from users are both welcome and
sought. It is anticipated that this manual will be revised to include
improvements and case study examples. Comments from EA/PPOA team members will
provide a dimension of use by those who are actively seeking solutions to
existing environmental issues.
•
LCA may be the foundation for proving pollution prevention solutions and the
measurement of pollution prevention progress. The LCA concept combined with
Total Cost Assessment (TCA) will assist decision-makers with the tough
determinations that may be unpopular, but correct for the future of the firm.
LCA is needed to develop the technical criteria for defining cleaner production
and cleaner products. The LCA concept as applied to multiple problems will help
managers wrestle with the Key Issue set forth in the beginning of this paper.
Summary
Environmental Auditing, Pollution Prevention Opportunity Assessment and Life
Cycle Assessment are three focus areas which any successful environmental program
within a company should use. EA and PPOA may be conducted together or
independently depending on the team make-up and understanding of the objectives.
Several practical "tools" are available from the EPA which encourage
environmental compliance and pollution prevention. With every environmental
issue the life cycle concept should be included. The future for EA, PPOA and LCA
is excellent as the RD&D strategies through the 1990's are: 1) to study high risk
environmental problems where pollution prevention offers a cost-effective
solution for reducing the risks, 2) to conduct cross-cutting research such as
measurement, modelling, and LCA that can be applied to multiple problems, and 3)
to establish joint global pollution prevention ventures for cleaner production
and cleaner products. EPA will continue to improve and develop "tools" that help
both producers and consumers fill their needs in this global economy and meet new
technical challenges. The technical challenges will require better and more
sophisticated "tools" for all of us.
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References
Office ;f Research and Development, U.S. Environmental Protection Agency (1993)
Life Cycle Assessment: Inventory Guidelines and Principles, £PA/600/R-92/245
Office of Research and Development, U.S. Environmental Protection Agency (1993)
Life Cycle Design Manual, Environmental Requirerrents and the Product System,
EPA/600/R-92/226
Office of Research and Development, U.S. Environmental Protection Agency (1992)
Facility Pollution Prevention Guide,
E PA/600/R- 92/088
UNEP Industry and Environment, October/November/December 1988, Vol. 11, No 4
Hazardous Waste Minimization, 1990, Harry M, Freeman, Editor, McGraw-Hill, Inc.
ISBN 0-07-022043-3
NOTE: Documents published by the U.S. Environmental Protection Agency are
available from the Center for Environmental Research Information, 26 West
Martin Luther King Drive, Cincinnati, Ohio 45268 or by telephone
513-559-7562.
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TECHNICAL REPORT DATA
(Please reed Instructions on the reverse before comple
1 REPORT NO. 2
EPA/t00/A-93/280
3.
4. TITLE AND SUBTITLE
Practical Tools & Concepts for
Environmental Audits & Assessments
5 REPORT DATE
July, 1993
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
James S. Bridges
8. PERFORMING ORGANIZATION REPORT NO.
9 PERFORMING ORGANIZATION NAME AND ADDRESS
US EPA
Pollution Prevention Research Branch
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
Risk Reduction Engineering Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
13. TYPE OF REPORT AND PERIOD COVERED
Proceedings PaDer
14. SPONSORING AGENCY CODE
EPA/600/14
15. supplementary notes Project Officer = James Bridges (513) 569-7683
Seminar on Environmental Auditing, 7/27/93, p:l-8
16. ABSTRACT
The purpose of this paper is to discuss the use of Environmental Audits (EA),
Pollution Prevention Opportunity Assessments (PPOA), and Lice Cycle Assessment (LCA)
as management tools designed to' identify and evaluate waste generating activities,
„t-o'determine how to best manage the wastestream, and-to' implement a waste management
program^and measure environmental progress. While each of these three tools are
different in approach and purpose, each tool provides for an organized approach with
essential elements. While EA targets environmental compliance, -the-PPOA targets the
reduction or elimination of waste generation regardless of regulatory constraints.
LCA may better be described as the foundation for proving pollution prevention
solutions and the measurement of pollution prevention progress.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSati Field/Croup
Pollution prevention
Waste minimization
Source reduction
Life cycle assessment
Environmental assessment
Environmental audit
18. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19 SECURITY CLASS (This Report)
UNCLASSIFIED
21. NO. OF PAGES
10
20 SECURITY CLASS /This page/
UNCLASSIFIED
22 PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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