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December 2013
(Revised December, 2015)
U.S. Environmental Protection Agency Region 2
Pollution Prevention and Climate Change Section
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Table of Contents
Contents
Introduction 2
Part I Good Housekeeping 2
Procurement 2
Proper Storage 3
Spill Preparedness 5
Disposal 6
Training 6
Part 11 Saving Money through Sound Environmental Management 8
Green Procurement 8
Saving energy 8
Saving Water 9
Reducing Waste Management Costs 10
Part 111 Keeping Your Environmental Program Alive 10
Ways to Keep Employees Involved 11
Ways to Keep Communities, Suppliers and Vendors Informed 11
Contacts for more Environmental Information Error! Bookmark not defined.
Major References 12
Other References 12
Appendix One - H-R Industries 15
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Introduction
Hurricane Sandy, which cut a path 1,100 miles along the Atlantic coast, was the deadliest and most
destructive hurricane of the 2012 Atlantic hurricane season and the second-costliest hurricane in United
States history. One of the many unfortunate results of this storm was the release of toxic materials from
small businesses that were impacted by flooding, storm surge, and high winds. Given the significant
impacts this storm and other severe weather events such as Hurricanes Katrina and Irene, had on small
businesses, and the likelihood of similar events occurring in the future, sound management of toxics needs
to be well understood and implemented to reduce the potential for future releases of toxic materials.
This best management practices (BMPs) guide prepared by the Pollution Prevention and Climate Change
(P2C2) Section of EPA Region 2, provides information on minimizing potential public health and
environmental impacts posed by chemicals used in small manufacturing business facilities. This material
together with energy, water and solid waste management strategies, can help your business save money,
enhance your reputation in the eyes of your employees, your customers and the community. Part I of the
BMPs provides recommendations focusing on good housekeeping, Part II discusses the benefits of
environmentally preferable products and services, reducing energy and water consumption, and
implementing a sound waste management program. Part III discusses how to sustain an environmental
management program at your business.
Although the BMPs primarily focus on voluntary efforts, related regulatory
information is periodically highlighted in the document by the icon pictured on the
left. These BMPs are not designed to replace or overrule local, state or federal
regulatory requirements applicable to business operations. You must consult with the
appropriate regulatory agencies in your area to ensure compliance with all applicable
laws and regulations.
Please contact the P2C2 Section at 212-637-3890, if you have questions about this document.
Part I Good Housekeeping
Good Housekeeping is a safeguard against unexpected and costly environmental problems at your
business. Good housekeeping can be organized into six major categories: Procurement, Proper Storage,
Handling, Spill Preparedness, Disposal and Training.
Procurement
• Start by taking a look at your purchasing practices. Establish a procurement schedule. Chart your
material use and needs, and the vendors you use. Check your vendors' policies on "buy-back" or
returns, material guarantees, and any other amenities they may provide.
• If possible, minimize your toxics material inventory. Many vendors will work with you on the
concept of "just in time and just the right amount." This means that they will deliver your raw
material more frequently in amounts that match your process needs.
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• Do an assessment of alternatives to reduce toxicity; (e.g. water-based, not solvent based.) The
Small Business Assistance Program may be able to help you in identifying non-toxic alternatives
to some of the chemicals you may presently be using.
• EPA's Safer Choice Program (formally the Design for the Environment or DfE Program) at
http ://www2. epa. gov/saferchoice identifies a number of products that are cost-effective that may
be environmentally preferable to some of the products you are currently using in your business.
Proper Storage
• In areas of flood risk, consider storing materials indoors or at a minimum on higher ground.
• Take a close look at the chemicals in your work area weekly or so. If you notice containers in bad
condition get rid of them (using proper disposal) or transfer their contents to a new container.
• Check to see that containers have good caps that are tightly closed and that the chemicals are
unable to permeate, erode, or leak.
• Ensure that you are using the proper container type (one that does not react with the toxic
material).
• Materials that are incompatible should not be stored together since they may have a violent
reaction if accidentally mixed.
• Make sure chemical containers are located in a safe area (i.e., that is, away from the edges of
shelves, away from high traffic areas, and out of the way of swinging doors.
• Do not reuse storage containers that previously contained a different toxic material unless you are
sure that there will be no chemical reaction.
• Ensure that proper ventilation is in place where toxics are being stored.
• Ensure that toxics that are reactive with others are properly sealed with no possibility of mixing.
• Put containers holding hazardous chemicals or wastes into other containers, trays, or drip pans to
catch and contain any chemical that spills or leaks out.
See the references section for further information on safe storage.
Handling
• When you move a chemical container from one place to another, put small containers in a bucket
or pail and place larger containers in a tub with hand grips or onto a cart with sides on it that will
prevent any spill from flowing off.
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• When transferring a chemical from its original container, be sure the new container will safely
hold the chemical you are pouring into it: Is it made of a material that won't react with or dissolve
in the chemical? Does it have a tight fitting cap? Be careful not to overfill the new container.
• Have proper labels on all containers. When transferring chemicals from the original container to
new one, label the new container right away so you won't forget what it is.
• At the end of a shift, be sure your employees tightly close any chemical containers they are using
and return them to their designated storage space.
• When deciding on a label for a waste container, be specific. If not, too soon you will have a
mixture of wastes that will be hard to classify, unsafe to handle (because you don't know what's in
it) and more costly to ship out.
When deciding on a label for a waste container, it makes a big difference whether
or not it is a "hazardous waste" as defined by regulations. Hazardous wastes have
particular requirements, including labeling. You should still label wastes that are
not hazardous so you don't get them mixed up with hazardous wastes and because
many non-hazardous wastes can still be toxic and pose hazards to your employees.
If you are not sure what labels are required, consult the Small Business Assistance
Program or Region 2 EPA's Division of Enforcement and Compliance Assistance.
• Material handling activities including storage, loading and unloading, transportation or
conveyance, of any raw material, intermediate product, by-product, final product or waste product
in the outdoor space of your facility, should be conducted in a storm-resistant shelter. These
shelters include completely roofed and walled buildings or structures with only a top cover but no
side coverings, provided material under the structure is not otherwise subject to any run-on and
subsequent runoff of storm water.
In general, temporary outdoor sheltering of industrial materials and activities should only occur
during facility renovation or construction. Additionally, EPA recommends the following:
o That a designated individual regularly conduct inspections of containers stored in outdoor
storm shelters.
o Any time external containers are open, deteriorated or leaking, they must immediately be
closed, replaced or sheltered.
o Containers, racks and other transport platforms (E.g., wooden pallets) used with the drums,
barrels, etc., can be stored outside providing they are contaminant-free.
If you are storing chemicals in above ground storage tanks (ASTs) outside, you
must satisfy the following conditions:
o They must be physically separated from and not associated with vehicle
maintenance operations.
o There must be no piping, pumps or other equipment leaking contaminants
that could contact storm water.
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o Wherever feasible, ASTs should be surrounded by some type of physical containment (e.g.,
an impervious dike, berm or concrete retaining structure) to prevent runoff in the event of a
structural failure or leaking transfer valve.
Additional information about material handling is cited in the references section of the BMPs.
Spill Preparedness
• To reduce the chance of spills from damaged containers, have Standard Operating Procedures in
place for regular inspections of toxic materials.
• When checking for leaks and bad containers, check the labels too. If any are falling off or fading,
write the label information on a fresh sticker and attach it to the container.
• If a spill occurs, know which toxic materials can be neutralized and how to do this, as well as any
ways to best isolate toxic materials to reduce the chance of inadvertently mixing two or more toxic
materials.
• Have supplies and Personal Protective Equipment (for example, safety goggles, gloves, etc.) for
safely cleaning up small spills in each work space, in a location that is easy to get to and is well
marked, and ensure employees are trained on when and how to use them. Further information on
proper safety equipment can be found in the references section.
• Locate all the drains on your property, both indoors and outdoors, and determine where they go to.
If your building is old, you may be surprised to find that the drain you were sure led to the sanitary
sewer and your local wastewater treatment plant actually connects to the storm sewer system that
drains directly to a lake or river. After you go to all this trouble, mark your drains accordingly.
Consider locating drain covers and spill supplies close by drains so you can quickly close these
drains off if there is a spill, if you have time and it is safe to do so.
• If you don't have a Chemical Incident Response Plan, make it a high priority to develop one. This
doesn't mean your employees have to know how to clean up a spill by themselves. In fact, they
should not clean up chemical spills at all, except for tiny ones, unless they have had extensive
training. But, anyone in your business who works with chemicals should know how to keep
themselves and their coworkers safe if there is a spill and who to call for help.
• Take some time to ask about the capabilities of your city or county emergency services. Do they
have a Hazardous Materials Response Team (often called a HAZMAT team)? If so, do they have
the necessary equipment and training to clean up the types of spills that could happen at your
business? If you call them in, how much will it cost?
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The Emergency Planning and Community Right-to-Know Act (EPCRA)
identifies hazardous chemical storage reporting requirements. For any hazardous
chemical used or stored in the workplace, facilities must maintain a material
safety data sheet (MSDS). MSDSs, or a list of chemicals, must be submitted to
their State Emergency Response Commission (SERC), Local Emergency
Planning Committee (LEPC) and local fire department. Facilities must also
report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and
local fire department. Further information about the EPCRA storage reporting requirements is in
the references section.
Disposal
No matter how much you improve procurement, storage, handling and spill preparedness, proper disposal
of toxics is critical if you are maintaining the use of any chemicals on site.
• Empty containers should be marked as such and properly disposed of right away, or at least staged
at a labeled bin or shelf, so they don't get confused with products still in use.
• Think about the schedule that is in place for waste removal from your business - are toxic
materials sitting in your facility for long periods waiting to be disposed? Track how your
business is generating toxic waste and establish the schedule for waste pick-up accordingly.
• Follow appropriate protocols for disposal of each chemical (the protocol should be on the product
label; if applicable, make sure to follow any local regulations, in addition to those on the product
label).
• Ensure that toxics are disposed separately from everyday non-toxic waste (such as food waste or
other landfill trash) so as to not put trash collectors at risk.
• Never pour toxics down drains, flush them town toilets, or dump them outside.
• When disposing of aerosols, ensure containers are completely empty to avoid explosive risk and
follow the disposal method found on the aerosol container's label.
• When disposing chemicals, make sure that you are in compliance with federal and state hazardous
waste regulations. For further information contact your state's small business assistance program
or Region 2 EPA's Division of Enforcement and Compliance Assistance.
Training
Pollution prevention training should become part of your business culture. Everyone from top
management to staff should implement practices that improve the overall operation of your facility,
protect the environment and build a good neighbor image.
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• Make sure you have training programs as required by regulations. Develop a list of training
topics that make sense for each job, beginning with training required by regulations.
• Have material safety data sheets (MSDS) accessible for all toxics and ensure that all employees
know how to read them.
• Have a protocol in place to secure toxic materials during an impending extreme weather event.
This should include a designated person or persons to carry out such protocols - such as a
designated Hazardous Materials Team. If you are already doing OSHA Right-to-Know (Hazard
Communication Standard) training, which is about how to keep safe when using chemicals, it is a
simple thing to add a short segment on how to properly handle and dispose of wastes associated
with the use of that chemical. Your State Small Business Assistance Program or Small Business
Environmental Ombudsman can help.
• If your business is employing non-English speaking employees, training materials and standard
operating procedures should be made available in the language spoken by those employees (in
addition to English).
Good housekeeping practices will help ensure that your business will be in compliance
with relevant federal and state environmental regulations and have the following
important benefits:
• Compliance with regulations can lower the cost of liability insurance, because
insurance companies will have less concern about the future costs of a clean-up
or the risk of harm to the health of your employees and community.
• Before loaning money, banks usually require buyers to pay for a professional
review of previous property uses to see if the property may have been
contaminated in some way. Because of this, if you ever need to change
locations or use your property for collateral, it will become important to
demonstrate that your activities have not caused contamination.
Keep records of your efforts and successes. Good records tell you at a glance what's
going on and what needs to be done on a regular basis (like annual training or weekly
inspections). They also put you in a better position to pass a regulatory inspection.
Most inspectors start with a close look at your environmental records. It pays to be
clear on what files you must have to be in compliance and get them organized first
After that, you can decide what information has additional value to you. Some records
are essential to protect you from legal and financial troubles down the road. Others can give you valuable
data on business performance, or come in handy when you want to show your customers and neighbors
that your business is "green." Be sure to go back and look at the records and documents that you are
required to maintain by the particular regulations that apply to your business to make sure nothing is
missing. Consult your state's Small Business Assistance Program or Small Business Environmental
Ombudsman if you are not sure.
If you do get inspected (even just once) it will pay to be prepared. The inspector will usually look at
records first and then ask for a tour of your operations. Environmental regulations warrant record keeping
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associated with spill response, training, waste management, air management, wastewater management and
storm water management. Responsible parties who fail to take notice of (or severely disregard)
environmental regulations may be criminally prosecuted and may even serve jail time.
When your business is fined for environmental violations or has an accidental spill it often ends up as
front page news - not the kind of publicity a business prefers. Not only can an undesirable image hurt
sales in your local market, it can also hinder expansion activities you may be planning.
Part 11 Saving Money through Sound Environmental Management
There are opportunities to make your business more profitable, productive and more environmentally
friendly. Sound environmental management can be organized into four major categories: Green
Procurement, Saving Energy, Saving Water and Reducing Waste Management Costs.
Green Procurement
EPA has developed the Greener Products Portal to assist you in identifying a variety of products that you
may wish to use in your small business. If you are looking to replace existing appliances, office products
or supplies, electronics, cleaning products and other items, then consult the Greener Products Portal for
cost-competitive goods that pose less impact to the environment at: http://www.epa. gov/greenerproducts/
Saving energy
Saving energy in your business translates into saving money. Using less electricity means burning less
coal or natural gas, which reduces greenhouse gas emissions and other forms of air pollution and also
conserves resources for future generations. There is free assistance available to help your business
explore some of the more involved energy saving options - so why not take advantage of it? Below are
some practices you can implement to lower your energy use.
• Turn off lights or office equipment at night and on weekends or take advantage of natural daylight
for lighting needs.
• Disconnect unnecessary equipment completely.
• Turn up or turn back the thermostat during unoccupied times or consider buying a programmable
thermostat.
• Caulk and weather-strip windows and doors.
• Install blinds or shades to keep out summer sun to lower air-conditioning costs.
• Purchase fans to keep warm air from accumulating at the ceiling during winter.
• Insulate hot water holding tanks and hot and cold pipes and improve insulation of the climate
controlled portions of your facility.
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• Replace light bulbs with more efficient ones. However, some of the more efficient bulbs meet the
definition of hazardous waste when disposed of and they need to be managed accordingly. (For
example fluorescent bulbs contain mercury which is toxic.) See EPA's website on compact
fluorescent light bulbs at: http://www2.epa.gov/cfl
• Replace light bulbs with the most energy efficient technology that also has and no toxics. This is
the "Light Emitting Diode" technology; known as LEDs. More information about LEDs can be
found here: https://www.energystar.gov/index.cfm?c=lighting.pr what are
• Place your lights on motion detectors or install timers on lights and electric equipment to keep
them on only when in use.
• It may be worthwhile to replace lighting fixtures instead of just the bulbs. The new fixtures can
allow you to utilize a smaller bulb and get the same amount of light, or reuse the ballast portion of
the light.
• Call your local utility company to see if they still have a program to evaluate your building for
energy efficiency. If the service is available, the utility will provide you with specific options for
making your business more energy efficient, usually for free. If your local utility company does
not provide this service, check with your state's energy program to see if they do, or know who
does.
• Consider participating in the ENERGY STAR program which offers useful guidance to small
businesses at: http://www.energystar.gov/buildings/facilitv-owners-and-managers/small-
biz?c=small business, sb index
Saving Water
Most business activities are using part of a limited supply of water that is good enough to drink! Only a
tiny fraction of the planet's water is drinkable. Ninety-seven percent is sea water, which is expensive and
difficult to desalinate. About two percent is caught in polar ice caps. That leaves just one percent to
sustain life. Your business pays for using this resource. This may not seem like a large part of your
overhead until you realize that you pay for it twice: coming to the tap and going to the sewer. Take a look
at your combined water-sewer bill to get a more accurate cost of using water.
Industrial process water that normally goes to a publically owned treatment works (POTW) facility might
in times of severe storms bypass the facility and go directly into the local waterway. If your business has
process wastewater holding capacity on-sight, and a heavy storm is approaching, you might consider
holding your process wastewater for a few days after the storm is over before discharging to the POTW.
If you want to save some money while reducing the impact of your business on your community's water
supply, consider some of the water saving ideas below:
• Keep your plumbing fixtures in good working order and upgrade older fixtures.
• Test for leaks in the toilet- put food dye in the toilet tank and let it sit for an hour or two without
flushing. If you see dye in the toilet bowl, you have a leak. Also, check to make sure the overflow
tube is not flowing continually.
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• Consider an inspection program for leaks.
• Repair dripping faucets by replacing washers.
• It may be worthwhile to replace plumbing fixtures with more water efficient options.
• Faucet aerators with flow restrictors are available to reduce water use.
• Some heating and cooling equipment models reuse or recycle water.
• Automatic shut offs on water supplies such as sinks and hose nozzles will keep them from being
left on.
• High pressure/low volume cleaning nozzles on spray washers also use less water.
• Cover liquid holding areas when not in use to reduce evaporation.
(See the reference section at the end of this document for additional information on water saving and
efficiency best management practices.)
Reducing Waste Management Costs
In addition to energy and water use, waste disposal can drive up your costs. Here are some tips for
reducing your waste costs:
• If you hire a hazardous waste contractor, ask them to help you find ways to cut down on costs.
While it might seem that it is not in your contractor's best interest to do this, the hazardous waste
market has gotten so competitive that contractors are looking for ways to add value to their service
and set themselves apart from the competition.
• Look for ways to reduce the amount of wastes your business creates. A simple example is to
reuse corrugated boxes two or three times before you send them off for recycling. Since new
boxes are expensive, savings can add up fast.
• Consider any reuse opportunities for chemicals. Another option for reuse is to provide it to
someone else who may have a use for it - such as a school or other business.
Part 111 Keeping Your Environmental Program Alive
Environmental efforts within your company will be more successful if employees are directly involved.
Employees are a great source of knowledge on environmental issues related to their work areas and the
effectiveness of current procedures. Consider setting up an Environmental Management Team and
making a company environmental policy. The team should include representatives from throughout the
company. For example, at a small company, a team could include supervisors from each process line as
well as people responsible for human resources, sales, and plant operations.
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The first task is to write a company environmental policy. The policy should reflect your commitment to
the environmental program. It should be short, to the point, and well communicated throughout the
company so that employees understand and remember the policy.
Ways to Keep Employees Involved
• Post the Environmental Policy at prominent locations throughout your business.
• Set up a suggestion box for environmental improvements. Recognize or give awards to
employees who make suggestions that get incorporated into environmental management
procedures.
• Inform employees through a company newsletter or bulletin board and provide them updates
on the company's progress in fulfilling its Environmental Policy.
• Once you have a policy established, you can build on it. Whenever the environmental policy
changes, enlist the Environmental Management Team to communicate those changes to your
employees. Employees want to know why it is important to accomplish a particular
environmental task and what part they are to play in achieving selected goals.
The next task is to communicate your environmental efforts to those outside your business. The opinions
of your neighbors and the community around you can be important to the success of your business.
Ways to Keep Communities, Suppliers and Vendors Informed
• You may post a copy of your environmental policy so that it is visible to anyone who visits
your business.
• If your business has a website, you may wish to post some of the environmental results that
you have achieved under your environmental management program.
• Information about your company's environmental achievements can be added to the product
packaging.
• You may also communicate with your suppliers and vendors that you favor materials and
services that result in improved environmental performance.
Finally, while this BMP guide will help you get started, there is also a wealth of information available to
you about environmental regulations, management systems, policies and pollution prevention practices
beyond this guide. We encourage you to reach out to Federal, state and local government agencies, non-
profit organizations and companies specializing in assessments and implementations of environmentally
beneficial and cost saving practices specifically designed for your business.
Contacts for more Environmental Information
• For questions concerning pollution prevention practices, contact the Region 2 EPA Pollution
Prevention and Climate Change Section: 212-637-3755 or 212-637-3764.
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• For questions regarding compliance with federal environmental regulations, contact
Region 2 EPA's Division of Enforcement and Compliance Assistance at 212- 637-3565.
• For questions concerning state environmental regulations contact:
o The New Jersey Department of Environmental Protection Small Business
Assistance Program at: 609-777-0518.
o The New York State Small Business Environmental Ombudsman at: 877- 247-2329.
o The New York State Department of Environmental Conservation - Division of
Environmental Permits, Pollution Prevention Unit at: 518-408-0213.
Major References
1. Practical Guide to Environmental Management for Small Business. EPA Publication 23 3-K-
02-001, September 2002. This practical guide will help you design a management plan that
addresses all of the environmental concerns of your business. The guide will also help you save
money and make your business look good in the eyes of your customers and your community. Go
to: http://nepis.epa.gov/Exe/ZyPDF.cgi/P100EDKE.PDF?Dockev=P 100EDKE.PDF
2. Building an Environmental Management System: H-R Industries' Experience. Creating an
Environmental Management System (EMS) might seem like an overwhelming task, especially for
a small or medium-sized company, but many of the elements needed for an EMS may already be
in place at your facility. Such elements as your procedures to track environmental compliance or
your state-required pollution prevention plans can be used directly to give you a significant head
start for developing your EMS. To learn more see "Appendix One - H-R Industries."
3. Environmental Management Systems: An Implementation Guide for Small and Medium-
Sized Organizations. This comprehensive guide is designed to explain Environmental
Management System (EMS) concepts and to support and facilitate the development of an EMS
among small and medium-sized organizations. Go to: http://www2.epa.gov/ems/environmental -
management-svstems-implementation-guide-small-and-medium-sized-organizations
Other References
4. Zero Waste Network developed a database that includes 537 success stories. Each case study
explains of how a real facility saved money, reduced waste, and/or lowered their regulatory burden
through innovative P2 practices. Go to: http://www.zerowastenetwork.org/success/index.cfm
5. Lean Manufacturing is a business model and collection of methods that emphasize eliminating
non-value added activities while efficiently delivering quality products on time at least cost. This
EPA website contains techniques and strategies for integrating environmental considerations into
Lean initiatives and methods. Go to: http://www2.epa.gov/lean/lean-manufacturing-resources
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6. Here are three examples of companies that provide lean manufacturing training, implementations
and case studies:
a. Go to: http://www.tpslean.com/
b. Go to: http://continental-design.com/lean-manufacturing/success-stories.html
c. Go to: http://www.emsstrategies.com/
7. Green Chemistry is the design of chemical products and processes that reduce or eliminate the use
or generation of hazardous substances. Goto: http ://www2. epa. gov/ green-chemi stry
8. Green Engineering is the design, commercialization and use of processes and products that are
feasible and economical while reducing the generation of pollution at the source and minimizing
the risk to human health and the environment. Go to: http://www2.epa.gov/green-engineering
9. Many organizations have found that implementing lean concepts and tools results in
improvements in environmental performance, even when lean activities were not initiated for
environmental reasons. This EPA site has examples of the types of environmental benefits that
result from lean implementation. Go to: http://www2.epa.gov/lean
10. New Jersey Department of Health compiled useful Sandy Recovery Resources that include
guidance on dealing with mold and asbestos. Go to:
http://www.state.ni.us/health/er/hurricane recovery resources.shtml
11. EPA's Mold homepage has on-line training courses. Go to: http://www2.epa.gov/mold
12. EPA resource: Guidance Manual for Conditional Exclusion from Storm Water Permitting
Based On "No Exposure" of Industrial Activities to Storm Water, EPA 833-B-00-001; June
2000. Goto: http://www3.epa.gov/npdes/pubs/noxguide.pdf
13. EPA resource: Developing your Stormwater Pollution Prevention Plan: A Guide for
Industrial Operators, EPA 833-B-09-002; February 2009. Go to:
http://www3.epa.gov/npdes/pubs/industrial swppp guide.pdf
14. To aid in the safe storage of materials, this is a useful compatibility chart. Go to:
http://www.trainex.org/osc2012/uploads/541/incompatiblematerials.pdf
15. This EPA site has a good hazardous waste handbook for small businesses entitled, "Managing
Your Hazardous Waste: A Guide for Small Businesses" in English and Spanish. Go to:
http://www2.epa.gov/hwgenerators/managing-vour-hazardous-waste-guide-small-businesses
16. Emergency Planning and Community Right-to-Know Act (EPCRA) Hazardous Chemical Storage
Reporting Requirements. Goto: http://www2.epa.gov/epcra/epcra-sections-311-312
17. OSHA proper safety equipment for cleanup (Personal Protective Equipment.) Go to:
https://www.osha.gov/SLTC/personalprotectiveequipment/
18. EPA Enforcement. Goto: http ://www2 .epa. gov/enforcement
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19. U.S. Small Business Administration - Industry Laws & Regulations. Go to:
https://www.sba.gov/content/environmental-regulations
20. EPA's emergency management activities and regulations help protect the environment and human
health from releases or discharges of oil, chemicals and other hazardous substances. This EPA
site has information on chemical accident prevention, chemical reporting, oil spills and hazardous
substance releases. Go to: http://www2.epa.gov/regulatory-information-topic/emergencies
21. EPA's role in responding to oil spills; chemical, biological, radiological releases. This EPA site
includes response tools, partners and contacts. Go to: http://www2.epa.gov/emergency-response
22. This EPA site defines hazardous waste generators and the three categories: Conditionally Exempt
Small Quantity Generators, Small Quantity Generators, and Large Quantity Generators. Go to:
http://www2.epa.gov/hwgenerators/categories-hazardous-waste-generators
23. EPA site for water-efficiency best management practices and EPA's WaterSense program. Go to:
http://www3.epa.gov/watersense/commercial/bmps.html
24. The Alliance for Water Efficiency non-profit organization has information about water efficient
products and programs, and provides information and assistance on water conservation efforts.
Go to: http://www.allianceforwaterefficiencv.org/about/default.aspx
25. The Reuse Marketplace is a free reuse service to find, sell, trade, or give away reusable and
surplus items that would otherwise end up as trash. Businesses including sole proprietorships are
welcome to create accounts and post or browse listings. Goto: http://www.reusemarketplace.org/
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Appendix One - H-R Industries
A Cooperate Project
befeveen the
U.S. EnvlnWMWfrtal
Protection Agency
and PWB
Manufacturers
NaliomvidK
US. EPA
PRINTED WIRING
BOARD PROJECT
This case study introduces the initial steps necessary for devel-
oping an EMS, and shows the similarity between tbe requirements
for ISO 14001 ami ISO 9000,
Do You Need an EMS?
As companies strive to improve their management i>f environ-
mental issues and increase profits at the same fime, many have
found that an EMS can do more than improve llwir environmental
perfottmiice — it can help (hem meet their business goals too. By
providing a systematic way to review and improve operations for
better environmental performance, an EMS can help a company
use materials more efficiently and streamline opersttons-
Cumpaniea that have implemented EMSs have
experienced benefits such as:
• fetter environmental performance
• cost savings in operations
• increased efficiency of operations
• resource conservation
• lower insurance costs
• improved public relations
Even companies not pursuing certification aw using the ISO
14001 model for 1 eerfift-
;abli:Jtedirr^7ri and is a wholly
Jald TesfmSlSies, Inc. With ap-
at fjJfiiiiiiaji fRichatdson and
ny aaKce&a wide range of multi-
file ISO
nan nental
Orsttd
rwo^siantlSrds, Many of
nearly identical Managed#
StSaticmal standard for envj-
closely modeled on ISO
jiicant overlap between the
meats arc similar, and some arc
ystcms, whether for quality or
share common elements including
procedures, training, tecordkeep-
action.
15
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ronmcnlai improvement, rather tlian daily "Fuiefighfing''just to
keep up wish regulatory requirements
Reviewj'Oureurrent environmental programs. Once
you lave management COmmittBSHl, (he next stop is to conduct
and ducumenl a preliminary review of you' company's entreat
environmental programs and management systems* This
process includes reviewing your existing environmental maii-
MgSHKflt policies, operating procedures, and training programs,
as wctt (is your methods for identifying your regulatory require-
ments.
Determine what's missing. Next you need to evaluate
lio W elosciy existing pioeedures conform to the requirements of
an ISO MOOt EMS, Such 5 "jiap analysis" identifies the actions
necessary to build your EMS. To do lJris, you'll awed to
compare your existing procedures to the five main stages of an
ISO WQ01 EMS.
O Environmental Pulley
ft Planning
ffi Implementation and Operation
Q Clrecking and Corrective Action
© Management Review
Repealing tlitsc five steps forms a cycle of continuous EMS
improvement, with tlie overall goal of improving environmental
performance,
Links Between ISO 14001 and ISO 9001
IF your company is ISO 9QO0 registered, the gap analysis
may repeal that many of the materials already prepared for your
quality system will be helpful in developing your 6MS. This is
because ISO MOO and ISO 14000 use similar management
frameworks. Table 1 provides an outline of the ISO 14001 EMS
Standard and shows corresponding ISO 3O01 elements, where
(hey exist. The ISO 9001 standard is used for cmnpflristui in
this case study because it is the most comprehensive of the ISO
9040 series of standards. Most of these comparisons are also
applicable to facilities registered under ISO 9002.
Tiic most direct linkages with ISO WO I occur withm three
pluses of the EMS: Implementation and Operation, Checking
and Corrective Aclion, tmd Management Review. The elements
addressed within these phases, such as organizational structure
and responsibility, training, document and records control, and
audit and management review requirements, have direct paral-
lels within the ISO 9QG1 system, in SOttW cases, however, theic
is od dtTeet link between ISO 14Q01 and ISO 9001.
The H-R Industries Experience
II-R Industries has been active m reducing tlie envfroamca-
tai impact of its operations in past years through changes such
as using glycol-free strippers and aqueous solder masks. The
company viewed the creation oFa Formal EMS and ISO 14001
certification as a way to achieve discipline in its environmental
programs, incorporate environmental responsibility into ail job
descriptions, demonstrate industry leadership, and gain a mar-
keting advantage.
When in-house slaff at H-R Industries conducted a gap
analysis, they found that ihey would be able to borrow signifi-
cantly from their ISO 9002 Quality Management System. The
overlap included using the same forms and stamps to indicate
document approval, and using the same procedures and person-
nel for documentation control,
in general, the company used the same documentation
system for writing EMS policies and procedures as it had for
its quality program. Specific examples of how H-R Industries
used its quality system to develop several EMS elements are
described below.
O Environmental Policy. H-R Industries modified its
Quality Policy to include its environmental policy. The policy
was enlarged to poster-size, signed by all employees, and
posted as a reminder of the company's commitment.
© Planning, A key clement of an effective EMS is
identifying the environmental aspects of your company's activi-
ties, products, and services, and determining which aspects
have significant impacts on the environment. These "signifi-
cant aspects" form the basis for setting your environmental ob-
jectives. Although there is no parallel element in ISO 9002.
H-R Industries extended its ISO 9002 purchasing policy to
add«4S pnitTilial environmental impacts by making suppliers
and contracture awaie of the environmental aspects associated
with their products. For example, tlve formality of an EMS
provided tie incentive to work with a chemical supplier to
convert their permanganate halii maintenance procedure.
Sodium hypochlorite additions were replaced by permanent
electrodes in the solution for electroregeneration, extending
bath life 2 to 3 (uses. This change resulted in reductions in
hazardous waste generation, material handling reporting, and
recordkeeping. Annual savings totaled over $ 12,500.
0 Implementation and Operation. Essential to both
quality and environmental management systems is the assign-
ment of responsibility, authority, and adequate resources. To
rnake^ the most of limited resources, H-R Industries assigned
the same individuals responsibility for both quality and EMS
elements where there was overlap. For example, the
Safety/Health Officer provides training required by ISO 9002
and ISO 14001. Documentation a&d records for ihe Quality
and EttVcrcimtietstil Management Systems are controlled and
maintained hy tlie same individual.
Successftd implementation of an EMS also depends on
bath management and employees folly understanding and con-
trolling the company's potential impact on Hue environment
H-R Industries uses the training framework already in place for
16
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ISO 9002., safely, and employee riglsl4ii4®(iw programs to
ittftwro new emptoyos of ISO 14001 MS requirements.
Ttauning had to be expanded. to educate employees stall lie
awftwnwnl aspects of tfiair activities and the potential envi-
ronmental comeqo&mce* of their performance, For example,
platers needed to kmow flat dumping a contaminated bati to
wastewater treatment could not only disrupt the treatment
system, tat also nay cause an iiMcteftalsly high 8««l of metals
discharged w t!« environment.
Acccntling; to H-R Industries' Process Biigisseriog
Maaager, "Willi ISO 9002, had to become everybodyls
business, Willi bii EMS, evcrytiody ted to become iwsic of
how their work impacted the environment" Fot eiatriplss,
wastewater treatment opauMwsntvM procedures to address
eiivuijiimeoiitl aspects of treatment operations.
• ClKrIuntt and Corrective Action. H-R.Industries
tnmsfetred its ISO 9002 jncitoN for making corrective
»»CiSon.rei|Mesfe tirec% to ils EMS, The IMs Mjiu >1 H'.ipiy
relets to tne Corrective Action Request foftn already in use For
quality. For axampla, such a fonn might he used for ft Mk
feat Sroiilldy, II-R kiAtsliiw nif®jf owlet! fiis records
its EMS,
• MwMfeownl Bprhw. MwagBnmt must periodi-
cally review the EMS to ewhatt its suitability and tlM»
«m ISO 90CH contains ii» mom wfwwwwt Although, (toe
b sotue overlap in personnel on the quality nod »AwmM
review committees at H-R Industries, Itic two systems are rc-
vicwcd separately. The review foam and control of meeting
records, hewmwr,»the mm. 8* Mwkitt Mi tint
smaller companies may have an iidvanlBge to tke revie w
process in. that tiic committees; may he composed «f tliE same
Tataie 1: Similarities Between ISO 14001 and ISO 9001
¦ 1 i' 11135305 whtti9 guniiantiss whh between fie two qifms,
1 ¦1 < > ¦ ¦ wjiffl^srr zziz
6en«rf|J
' jn»tSl.J
Planning
Environmental aspects
Lepsl and other naq'-iiremnnts
QbfacHvss and targets
Environmental management program*
jBiJlESiSlfeS.. IP'iOP®ra!top_
iiuciu« anS rtafMi'&Miily'
-J
Although then is no direct equivalent in ISO 9000,. opportwatw
for eonaWefing environmental aspects may exist In «w» such a#
contact review, purchasing, handling. storage, packaging,
preservation, and delivery.
Pocyment control
Ojwmfiwtal control
Emergency prBpecedrwaB and response
CSckf^aii^
Monitoring arid measurement
Nonconformance and cotredtve
airiS pr«wnti» action'
Rieonds.
mm man
Biifiagiiitit Rsvliw * ' "
4.1.2 Organization
4.18 Training ___
'4,2,1 GerwtrS
4.5 Document and data control
4,9 Contract tevtew
4.6 Purchasing
4..? Control of custnmer-wpplteij product
4,i Process control
4,1 i Ceiiiwi of fnspactSon, meastirtngaridiMieciiJipmKnl
4.t4 Correctve wei pwoMMi mSom
4W CwiW «f quaBtjr iwconj#
4,1? Iniactial quBl% audita . •
"A". 1.3 BanagHmenjreview ¦ "2" "'J'
17
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Miment
pcriORiKl, ¦flowing both quality and cnvirooineiitil systems to
be reviewed «t lie same time.
Lessens Learned About the EMS Process
tte |mm of developing at EMS for * siiil« m&n-
sized terajany »«<• net b* overwhelming, Hit Industrie*' m-
penenwe stows ttwit * company an ine it# existing
environmental policies andpr^rcaurc., unf *•»"». Jevetaped for
ISO 9002 ntgtebalion, I® help boild an EMS mat i«
will its fjmlity assurance program. H-R Industriei" advice is to
begin Willi simple, miiimatla gab, awl focus on pwgriuns
*1i« there is tfbvtau em Wtnic benefit, As your EMS
matures, the procedure) anil pMfmtits «n be expanded to
farther improve tavironmentat perfatnumee and to eonitoua in-
tegtttton of the EMS into ether twines frnwtte*,
Tim* required to develop Mil maintain the EMS: The
lime hmpM »jaftaam ISO 14001EMS depeod»y
sebe Juting tie ISO 14001 certifimtiari a-jiil a.-J The ISO 9002
six-month sweillaow audit at the same time and with the saw
r*m.
Acknowledgments
EPA's DIE Program would like to think H-R Industries for
participating in tfciSMise study, along wish MB fWB Fttyltct
partfcipnjits item CMt Ceatr-r, lire , rut (aiwamtui
Teeliiftlogiei Ostp, who< provided advice and guidance.
H'ftat is #!;n *is seiks of
eonnmeji'ts, pji*« let m ham ^ D®
2®2-2W-l67? or ni«ni '• "
^ }\ 8
Racyelad
PrniMI an piipiir Bial contains at
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