Indiana Clean Manufacturing Technology and Safe Materials Institute
2655 Yeager Road, Suite 103, West Lafayette, Indiana 47906-1337
ENVIRONMENTAL MANAGEMENT SYSTEMS
A QUICK-START METHOD for SELECTING EMS PRIORITIES
Companies in the United States are increasingly interested in developing a planned approach to investigate the impact of their manufacturing systems on the environment as well as the impact of governmental environmental regulations on their business operations. This interest can be exemplified by the development of the new International Organization for Standardization (ISO) and by other environmental planning initiatives, collectively termed Environmental Management Systems (EMS).
This guide is not offered as an explanation of the ISO 14000 system, nor is it offered as the only blueprint to begin an EMS within a company. This guide suggests a method to "quick-start" the priorities to establish a developing EMS program.
Too often, companies shelve or lose interest in the full EMS because the process can be lengthy, tedious, and involved. Often the initial results of an earnestly begun EMS results in little success—which can discourage the company and, perhaps, lead to an abandonment of the program. The Quick-Start Method can be used by EMS advocates to quickly demonstrate the value a full and formal EMS can bring to a company.
TYPICAL EMS PROCESS
Usually, the first steps of a full EMS process are (1) a review of all permits as well as the applicable environmental regulations pertaining to the company, and (2) a formal inventory of all hazardous chemicals used in manufacturing and related processes. These steps are tedious and require the allocation of extensive resources.
The regulation and permit data review is performed to determine the areas of environmental impact and/or the liability of the company. The responsible manufacturing process streams (which contribute to these areas) are then identified. Systems are then developed to ensure that the responsible processes operate in a compliant manner. Depending on the aggressiveness of the EMS, these processes may receive specialized scrutiny and, ultimately, move beyond compliance requirements by reducing or eliminating the environmental/regulatory impact.
The formal inventory of all hazardous chemicals used in manufacturing and/or ancillary processes is perhaps the most demanding undertaking of a full EMS process. Hazardous chemical inventory usually is accomplished by reviewing all material safety data sheets (MSDSs), each of which represents a raw material (or product) used by the company. Every chemical from every product (MSDS) is analyzed for toxicity or hazardousness and should be compared against lists of regulated hazardous chemicals, such as the EPA's "Title III List of Lists" (EPA document number 560/4-91-011 and its updates). The chemicals which match the list's chemicals should receive special notice by "tagging" the MSDS (i.e., tagging the product of which the chemicals are constituents).
All products which contain chemicals listed on the various governmental hazardous chemical lists should be quantified for annual use as well as daily on-hand inventory. This process (or its facsimile) is currently required for companies that file SARA Title III Tier I and Tier II reports. When these data are tabulated, a company should systematically review each process stream which requires the use of products (MSDSs) which contain hazardous chemicals, with the intent to reduce, eliminate, and/or control the environmental impact of those particular hazardous chemicals (see Figure 1 for a schematic depiction of the hazardous chemical and process analysis).
This is an up-front, resource-intensive project. The outcome of this extensive information gathering process is the selection of potential process streams which might merit individual process evaluation. Much time and effort is spent just evaluating products (MSDS) and their location of use within the company. This work, while important, doesn't begin to address the question of how to reduce, eliminate, or control the subject chemical(s). This process can consume so much of a company's time and energy, that management may become prematurely discouraged with a lack of tangible results and, therefore, may abandon the notion of a proactive EMS.
The following offers an alternative which can lead to a more comprehensive EMS process and emphasizes the idea that early success will motivate the company and encourage the adoption of the tedious and comprehensive EMS.
The Quick-Start Method, just as with a comprehensive EMS, begins with the company's executive management's initiation and solid support of the EMS effort. A key person within the company should be selected to champion the Quick-Start EMS project. The designated person should form a small team of people who possess knowledge of the company's environmental impact and the overall manufacturing processes responsible for the impact.
The key to the Quick-Start strategy is to focus the company's team on a fast track course of action, with a high probability of success. This is accomplished by identifying the waste streams which the company feels have the greatest environmental impact and which the team feels can be quickly and successfully transformed. Stack and/or fugitive emissions, wastewater discharge, RCRA hazardous waste, and/or streams of a less toxic nature (such as special wastes)--all qualify as waste stream candidates (see Figure 2).
After selecting two or three waste streams which have the greatest environmental impact, each should be studied so that the waste generated can be traced upstream to the manufacturing production line(s) responsible. The team may find that multiple production lines generate the waste. An analysis should be performed to ascertain the percentage each line contributes to the total waste. This percentage is then multiplied by the percent reduction the team believes could be achieved, given some course of action to reduce waste. The product of that multiplication offers an estimate of the total waste reduction potential of that action. The estimated cost or savings the reduction may provide should be gauged against the estimated resources which are believed necessary to accomplish the reduction. If the estimated outcome does not justify the expenditure, then that particular reduction option should be replaced with a more attractive alternative. At this early stage, the estimates of the reduction percentage should be an order of magnitude "guesstimate."
REDUCTION OPTION DEVELOPMENT
The team should share the data obtained with company personnel directly involved with the responsible production lines and develop a list of source reduction ideas to reduce waste generation. These ideas should involve changes in the process and/or raw materials—not better waste treatment methods. Earlier estimates of potential waste reduction percentage can be revised and refined at this time.
When an "ideas list" has been developed, a cost-to-benefit analysis should be performed. The team should then prioritize the list in the order of
1. the most financially beneficial, greatest, hazardous chemical reduction option;
2. the most financially beneficial, most easily accomplished option;
3. the most financially beneficial, environmentally toxic reduction option; and
4. the most financially beneficial option.
The Quick-Start Method is designed to demonstrate quick, successful results; thus, the team should select number 2 on the priority list and compare financial benefit with ease of accomplishment. Any (or all) of the top options from this list should be adopted and implemented by the company. When the fledgling EMS has been proven, the company can use other priority schemes as the option selection source.
MEASUREMENT OF SUCCESS
After the reduction option(s) has been implemented, the team should compare the actual financial benefit (or cost) to the estimate, and compare the actual quantity of waste produced (and/or the amount of hazardous chemical use reduction) to the estimate. Typically, this is accomplished by quantifying the amount of waste generated (e.g. pounds) per amount of product (or process stream) produced (e.g. pounds). This unit-to-unit, pound-to-pound step normalizes the data and ensures that the data monitored to gauge success will not be influenced by changes in rate or volume and will, therefore, represent the actual unit change stemming from waste reduction option(s). When success has been substantiated, it should be highly publicized within the company.
The Quick-Start Method is suggested as a way to initiate and nurture an Environmental Management Systems within a company. The Indiana Clean Manufacturing Technology and Safe Materials Institute has been involved in countless pollution prevention projects and can attest that the Quick-Start Method can lead to effective Environmental Management Systems. The benefits of a full EMS are enormous. Companies gain an otherwise unrealized, intimate understanding of their production processes and of the dramatic effects slight process changes can have throughout the company—far beyond just environmental effects. Companies realize that production changes implemented primarily for pollution prevention or waste reduction can lead not only to cost savings, but also to increased quality, increased capacity, increased production flexibility, increased yield from raw material, reduced energy use, improved employer-employee communications, and improved inter-departmental cooperation, etc.
A full EMS is not just an environmental program, it is a better, more thorough way to run a company.