METAL FINISHING EMS TEMPLATE INTRODUCTION by kmb15358

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									                                              METAL FINISHING EMS TEMPLATE

                                                                             INTRODUCTION

OVERVIEW
This Template is designed to help metal finishers create an environmental management system (EMS)
that improves compliance with environmental regulations, promotes pollution prevention (P2), and can
be implemented in a streamlined, cost-effective manner. An EMS provides a framework for a metal
finisher to systematically identify, prioritize, manage, mitigate, and document the environmental aspects
and impacts of its operations (see Figure 1).



                                                          Determine          M&M
                         Identify Environmental
                          Aspects and Impacts             Significant        Communications
                                                         Environmental
                                                           Impacts           Roles & Responsibilities
    Activities,                                                              Training
    Products
                                                                             ER&P
        &
    Services                                                                 Corrective & Preventive
                              Determine                   Establish          Action for Compliance
                            Legal & Other                Objectives &        Records
                            Requirements                   Targets
                                                                             EMS Document Control



                                                                             Management Review
                    Establish/Revise                     Review Policy       Audits
                  Environmental Policy                   Components          EMS Nonconformance &
                                                                             Corrective Action




    Figure 1. An EMS establishes a continuous improvement process wherein a metal finisher
    establishes and achieves environmental performance objectives.




                                                   I-1
The metal finishing EMS (MFEMS) Template consists of four modules, and each module consists of
one or more elements.

                             MFEMS TEMPLATE ELEMENTS


                Number                               Element
              Module 1: Policy
                  1.1      Environmental Policy
              Module 2: Planning
                  2.1      Environmental Aspects and Impacts
                  2.2      Compliance
                  2.3      Objectives and Targets
              Module 3: Implementation
                  3.1      Roles and Responsibility
                  3.2      Communications
                  3.3      Training
                  3.4      EMS Document Control
                  3.5      Emergency Response and Preparedness
              Module 4: Review and Improvement
                  4.1      Measurement and Monitoring
                  4.2      EMS Nonconformance and Corrective Action
                  4.3      Corrective and Preventive Action for Compliance
                  4.4      Records
                  4.5      Audits
                  4.6      Management Review




                                               I-2
This introduction:

         F reviews EMS benefits

         F describes important features of an EMS

         F outlines "pre-EMS" activities that should be considered before you begin using this
           Template

         F provides general EMS implementation ideas

         F introduces the MFEMS Template organization and format


BENEFITS OF IMPLEMENTING AN EMS
Quotes from metal finishing companies who have used this Template:

 “The EMS gave Artistic Plating a better general awareness about the environment. It helped us
look at the cost of different aspects and at ways of reducing not only the cost, but the amount of
hazardous materials used. We are more aware of where to look for substitutes.”
– Ruben Angel, Artistic Plating & Metals Finishing

“This was an excellent program that is very helpful in keeping the plant in compliance. Just
compliance is not enough! We must be able to show agencies and the public what we are
accomplishing in pollution prevention, waste minimization, and source reduction.”
– Nick Avedissian, Quaker City Plating

“This program increases awareness of how to manage out environmental issues.”
– Willie Bell, Metal Surfaces, Inc.

“The EMS Bulletin Board made my job easier when an inspector came by.”
– Hassan Dabiri, Highland Plating

“The EMS program helps achieve compliance and at the same time improve our bottom line.
We set our Objectives and Targets and raised our level of awareness and our team efforts in
areas like pollution prevention. It gave us tools to communicate our progress, successes, and the
hurdles to our objectives.”
– Filomena Bundang, Crown City Plating

“Very informative program. It was great that everyone was willing to share their information.
We heard about other ways of doing things. The Compliance Checklist is absolutely invaluable.
It really helped review what you are doing and what you are not doing.”
– Karron Hagler, Metal Surfaces, Inc.




                                                     I-3
 “We use our EMS bulletin board as a marketing tool with customers. It makes a difference.
 We got 3 good customers within the last 6 months.”
 – Sandy Mayfield, Highland Plating

 “The EMS workshop series is a real value to a company like ours. A small company needs
 these kinds of tools to help us stay on track.”
 – Carol McCracken, Foss Plating Co.

 “EMS is a very positive program, especially for a company that doesn’t have much
 environmental management in place. The EMS Template helps us to participate with EPA and
 to know what they are looking for.”
 – Clarence Young, Gene’s Plating

 “At A.C. Plating, the EMS helped up open up lines of communication between management
 and workers, so we know what is going on. EMSs help share the work load.”
 – Bob McBride, A.C. Plating

 “Setting up an EMS planted valued seeds. It should be very fruitful down the road. It
 provides a good matrix that we can and should be using.”
 – Geoff Blake, All Metals Processing of O.C.



                   Incentives for Implementing an Environmental Management System
Demonstrate commitment to environmental management            Reduce environmental costs and improve bottom line

Improve working conditions for employees                      Streamline regulatory compliance

Establish and maintain positive community relations           Reduce raw material use and waste generation

Improve relations with government agencies                    Distinguish company from competition

Enhance public image                                          Make progress towards ISO 14000 registration

Reduce insurance premiums                                     Meet Strategic Goals Program goals

Avoid fines and expensive corrective action measures due to   Improve process control and monitor trends
compliance issues or lawsuits




                                                        I-4
IMPORTANT EMS FEATURES
    & Management commitment. An EMS without management commitment is like a car
      without a driver – it will not run. Successful EMSs are characterized by upper
      management commitment demonstrated through words and actions.

    & Continuous improvement. An EMS features continuous improvement through "plan-do-
      check-act" strategies that lead to more efficient EMS implementation and better
      environmental performance.

    & Employee awareness and involvement. Employees should be aware of the EMS, its
      purpose and elements, and how they contribute to achieving environmental performance
      objectives.

    & Dynamic and adaptable. An EMS should be dynamic and adaptable to respond to
      changing environmental priorities, regulations, and business conditions.

    & Results-oriented. Although the EMS creates documentation during its implementation, the
      focus should be on achieving results, that is, measurable or demonstrable environmental
      performance improvements.

    & Emphasis on pollution prevention. When developing options for achieving objectives
      and targets, the EMS favors solutions that prevent pollution through source reduction over
      others lower on the waste management hierarchy, such as improved treatment.


BEFORE YOU BEGIN
    ü Obtain top management commitment.

    ü Identify an Environmental Manager responsible for coordinating EMS efforts and other
      environmental issues.

    ü Form an EMS Team led by the Environmental Manager and including process supervisors,
      platers, wastewater treatment operators, and others familiar with your company’s
      processes. At least one person on the TMS Team should have good spreadsheet skills (for
      example, Microsoft Excel), which will streamline measurement charting.

    ü Communicate the EMS initiative to all employees and invite employee input.

    ü Conduct a preliminary review, or gap analysis, to identify (1) current environmental
      management practices that can "evolve" into EMS elements and (2) missing EMS elements.

    ü Quantify baseline environmental conditions at your facility for comparison to future
      conditions.




                                              I-5
EMS IMPLEMENTATION IDEAS

       ⇒ Avoid "reinventing" procedures for the EMS.               Smaller organizations such as metal
           Leverage components of other business systems and       finishing companies have some
           programs; for example, adapt existing training          advantages over larger
           programs to include environmental training or model     organizations in ensuring effective
           EMS documentation and document control                  environmental management. This
           procedures on existing quality system document          is because smaller organizations
           control.                                                generally have more direct lines of
                                                                   communication, less complex
                                                                   organization structures, employees
       ⇒ EMS elements should be implemented in                     who perform multiple functions, and
           a top-down fashion and address priority areas first.    easier access to management.

       ⇒ Get help! EMS assistance can be obtained from a
           variety of organizations and documents including the following:

           •   An Implementation Guide for Small and Medium-Sized Organizations
               (www.epa.gov/ownmitnet/wm046200.htmEMS % 20 Demo)
           •   Environmental Management Systems: A Guide for Metal Finishers
               (www.nsf-isr.org)
           •   National Metal Finishing Resource Center (www.nmfrc.org)


MFEMS TEMPLATE ORGANIZATION AND FORMAT
The MFEMS Template consists of four modules that parallel implementation phases:

       Module 1:       Policy

       Module 2:       Planning

       Module 3:       Implementation

       Module 4:       Review and Improvement

Each module consists of one or more elements that comprise the MFEMS. Each module element has
the following structure:

       •   Brief overview of element subject, instructions, and references        (2 pages)

       •   Procedure for implementing element                                     (1 page)

       •   Tools and examples to assist element implementation                    (1 to 5 pages)


                                                 I-6
Nomenclature and concepts for each element were derived generally from ISO 14001; however, the
Template does not strictly adhere to all aspects of ISO 14001.

Creating and implementing an EMS is a challenging endeavor. Although companies may choose to
implement all elements of the EMS contained in this Template as part of a single effort, experience
testing this Template with metal finishers indicates that companies gain momentum and understanding
most quickly when they take 3 to 6 months to complete the following elements first:

       •   Element 1.1         Environmental Policy

       •   Element 2.1         Environmental Aspects and Impacts

       •   Element 2.2         Compliance

       •   Element 2.3         Objectives and Targets

       •   Element 3.1         Roles and Responsibilities

       •   Element 3.2         Internal Communication

       •   Element 4.1         Measurement and Monitoring

   The rest of the elements can then be implemented over the next 3 to 6 months.


Note: This Template is not an EMS primer or general guidance document. Template users should
be familiar with basic EMS concepts or review numerous existing general EMS documents.




                                                 I-7
                                           GLOSSARY

Baseline Environmental Conditions. Environmental conditions at the facility before EMS
implementation.

Commitment to Compliance. The organization’s commitment to achieving and or maintaining
regulatory compliance. This commitment is reflected in documented practices and procedures that
ensure that regulatory compliance is a top priority of the organization and the EMS. Examples include
systematic and documented procedures for periodic regulatory compliance audits and for corrective
action taken in response to discovered instances of noncompliance.

Document Control. A system to ensure responsible management of all EMS documents.

Emergency Response and Preparedness Program. A program that plans and prepares for
emergencies, such as employee injuries or hazardous chemical spills.

Environmental Aspects. An element of an organization’s activities, products, or services that can
interact with the environment.

Environmental Impacts. Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization’s activities, products, or services.

Environmental Management System (EMS). A continuous cycle of planning, implementing,
reviewing and improving the actions that an organization takes to meet its environmental obligations.

EMS Audit. A process of objectively obtaining and evaluating evidence to determine whether an
organization’s EMS is operating as intended.

EMS Nonconformance and Corrective Action. A corrective action taken to address and rectify a
deficiency or nonconformance with the EMS.

Environmental Metrics. Measurable parameters that reflect environmental performance trends.

Environmental Policy. Company statement of its intentions and principles in relation to its overall
environmental performance, which provides a framework for action and a backup for its environmental
objectives and targets.




                                                   I-8
Gap Analysis or Preliminary Review. A review of an organization’s position with regard to the
environment done in advance of or at the beginning stages of planning the EMS. The review should
cover three key areas: legislative and regulatory requirements, identification of significant environmental
aspects, and an examination of all existing environmental management practices.

ISO 14001. A widely accepted, official international standard for environmental management systems.

Management Review. Periodic review of an EMS to ensure effectiveness and continuous
improvement.

Noncompliance and Corrective Action/Preventive Action: A corrective (or preventive) action
taken to address and rectify (or prevent) a deficiency or noncompliance with environmental standards or
regulations.

Objective. A facility goal that is consistent with the company’s environmental policy, priority
environmental aspects, and applicable environmental regulations.

Operational Control. The identification, planning, and management of operations and activities in line
with the EMS policy, objectives and targets.

Pollution Prevention (P2). Prevention of pollution through source reduction and waste minimization
techniques and technologies.

Prioritization Criteria. Criteria for prioritizing environmental aspects.

Records. Proof of actions taken that were outlined in the EMS.

Target. A detailed performance requirement related to and supporting a specific objective. Such
targets feature measurable parameters and timelines for attainment.




                                                    I-9
                                                                                   ELEMENT 1.1

                                                           ENVIRONMENTAL POLICY

The intent of an environmental policy is to state the organization’s commitment to continuous
improvement in environmental performance. A strong, clear environmental policy can serve as both a
starting point for developing the EMS and a reference point for maintaining continuous improvement.
The policy should be evaluated regularly and modified, as necessary, to reflect changing environmental
priorities.

The policy should function in two ways: (1) within the company, the policy should focus attention on
environmental issues associated with company activities, products, and services; and (2) outside the
company, the policy is a public commitment to addressing environmental issues and continuously
improving environmental performance.

The environmental policy must address:

        •   Commitment to compliance with relevant environmental legislation and regulations

        •   Pollution prevention

        •   Continuous improvement


Tips for Developing an Environmental Policy:
1. Develop a policy that reflects perspectives of various employees within the company (for example,
    line worker, owner, wastewater treatment operator, quality inspector, compliance/legal manager,
    production manager).
2. Display the policy statement in view of all employees; the policy should be available to the public
    and customers if requested and be printed in languages other than English, as appropriate.
3. Include top management signatures on the policy to demonstrate understanding and commitment.




                                                   1-1                                      Element 1.1
                       EMS Procedure                                  1.1
                         Effective Date
    Company Name            Subject                        Environmental Policy


Purpose      This procedure is used to develop and write the company’s environmental policy.

Step 1       The environmental manager will form a policy development team responsible for
             developing and writing the environmental policy. The policy will address, at a minimum,
             compliance, pollution prevention, and continuous improvement.

Step 2       The policy development team will review other relevant documents to ensure
             consistency with other company policies and guide the content and phrasing of the
             policy. Example documents include the company mission statement and the example
             environmental policies included in this EMS element.

Step 3       The policy will be displayed in view of all employees and introduced to new employees;
             the policy will be available in languages other than English, as appropriate, and to the
             public (on request) and customers (as appropriate).

Step 4       The environmental manager will review the environmental policy at least annually, and
             update it if needed.




   Responsible Person:

   Signature and Date:




                                               1-2                                      Element 1.1
Environmental Policy Example
        It is the policy of COMPANY NAME to conduct its operations in a manner that is
        environmentally responsible and befitting a good corporate neighbor and citizen. In accordance
        with this policy, COMPANY NAME complies with all environmental laws and manages all
        phases of its business in a manner that minimizes the impact of its operations on the
        environment.



        To further this policy, COMPANY NAME shall:

        1. Include environmental requirements in planning and design activities

        2. Comply with applicable environmental laws and regulations

        3. Eliminate, or reduce to the maximum practical extent, the release of contaminants into the
           environment, first through pollution prevention (material substitution and source reduction),
           then recycling, and finally through treatment and control technologies

        4. Effectively communicate with company employees, suppliers, regulators, and customers, as
           well as the surrounding community, regarding the environmental impact of company
           operations

        5. Periodically review and demonstrate continuous improvement in the company’s environmental
           management system




                                                          SIGNATURE




Responsible Person


Effective Date


                                                    1-3                                       Element 1.1
                   Metal Finishing Company
                 ENVIRONMENTAL POLICY
                         December 18, 1999


_________________________ IS COMMITTED TO IMPROVE THE HEALTH,
SAFETY AND ENVIRONMENT FOR OUR EMPLOYEES, NEIGHBORS, AND
FAMILIES.

WE WILL MEET AND OR EXCEED LAWFUL COMPLIANCE THROUGH
POLLUTION PREVENTION PRACTICES AND CONTINUOUS IMPROVEMENT.

TO IMPLEMENT THIS POLICY WE WILL CREATE AN ENVIRONMENTAL
MANAGEMENT SYSTEM TO IDENTIFY GOALS, SYSTEMS, MEASUREMENTS
AND SAMPLING METHODS.

TO SUPPLEMENT THIS POLICY WE WILL INCORPORATE SOURCE
REDUCTION THROUGH REUSE, RECYCLING, MATERIAL SUBSTITUTION,
NEW AND IMPROVED TECHNOLOGIES, CREATIVE MANAGEMENT AND
OPERATIONAL PRACTICES.

TO MAINTAIN THIS POLICY WE WILL PERFORM MANAGEMENT
REVIEW, PREVENTATIVE MAINTENANCE, EMPLOYEE TRAINING, AND A
COMMITMENT AND INVOLVEMENT FROM OUR EMPLOYEES AND
MANAGEMENT TO SUPPORT THIS POLICY.




                                1-4                       Element 1.1
1-5   Element 1.1
      Sample Policy — Actual policy reproduced with permission. Policy is not in original format.



Pacific Gas and Electric Company

Environmental Quality                                                     Policy Statement

PG&E is committed to a clean,                                    We will:
healthy environment. We provide                                  Comply fully with the letter and spirit of
our customers with safe, reliable,                               environmental laws and regulations, and strive to
                                                                 secure fundamental reforms that will improve their
and responsive utility service in an                             environmental effectiveness and reduce the cost of
                                                                 compliance.
environmentally sensitive and
                                                                 Consider environmental factors and the full
responsible manner. We believe                                   acquisition, use, and disposal costs when making
that sound environmental policy                                  planning, purchasing, and operating decisions.

contributes to our competitive                                   Work continuously to improve the effectiveness of
                                                                 our environmental management.
strength and benefits our
                                                                 Provide appropriate environmental training and
customers, shareholders, and                                     educate employees to be environmentally
employees by contributing to the                                 responsible on the job and at home.

overall well-being and economic                                  Monitor our environmental performance regularly
                                                                 through rigorous evaluations.
health of the communities we
                                                                 Seek to prevent pollution before it is produced,
serve.                                                           reduce the amount of waste at our facilities, and
                                                                 support pollution prevention by our customers
                                                                 and suppliers.

                                                                 Manage land, water, wildlife, and timber resources
                                                                 in an environmentally sensitive manner.

                                                                 Use energy efficiently throughout our operations,
                                                                 and support the efficient use of gas and electricity
                                                                 by our customers and suppliers.

                                                                 Re-use and recycle whenever possible.

                                                                 Use environmentally preferred materials.

                                                                 Clean up residual pollution from past operations in
                                                                 a cost-effective manner.

                                                                 Work cooperatively with others to further common
                                                                 environmental objectives.

                                                                 Communicate and reinforce this policy throughout
                                                                 the company.




                                                 1-6                                          Element 1.1
       Sample Policy — Actual policy reproduced with permission. Policy is not in original format.




September 1995




                                                  1-7                                        Element 1.1
         Sample Policy — Actual policy reproduced with permission. Policy is not in original format.



EMS Addendum



                Statement of Corporate Environmental Policy


Milan Screw Products Inc. Is committed to continuous improvement of its Environmental
Management System (EMS), which includes waste minimization, the prevention of
pollution, and compliance with all relevant federal, state, and local environmental legislation
and regulations. The company will meet or exceed the environmental requirements of other
organizations to which Milan Screw Products subscribes. To sustain this commitment, the
requirements of the Environmental Management System described in this Manual applies
to all activities, equipment, material and employees.

The company’s Environmental Compliance Officer is the company’s EMS Management
Representative who has the responsibility and authority to plan, enforce, and maintain the
company’s Environmental Management System.             This responsibility also includes
stoppage of activities that deviate from the requirements of this Manual.             The
Environmental Compliance Officer, with the assistance of the Environmental Task Group,
will propose annual targets and objectives to be approved by the Management Review
Board.

The EMS management Representative may delegate some of this authority downward
through the organization in order to effectively implement the system.



                                                                                           Charles Tellas
                                                                                      President and CEO



December 10, 1995




                                                    1-8                                         Element 1.1
                                                                                   ELEMENT 2.1

                               ENVIRONMENTAL ASPECTS AND IMPACTS

The fundamental purpose of the EMS is to control and reduce the environmental impacts of your
facility’s processes and products. For this reason, a critical element of the EMS involves identifying and
prioritizing the environmental aspects and impacts associated with your facility. An environmental
aspect is an element of an organizations activities, products, or services that can interact with
the environment. For example, chrome plating is a metal finishing activity and an associated aspect is
chrome air emissions. This aspect may have an impact on the environment in several ways, for
example, ambient air quality degradation.

The environmental aspects and impacts of your metal finishing operations can be identified, prioritized,
and documented in several ways. This Template includes two approaches, either of which can be
used during EMS implementation. Use the approach that works best for your circumstances. This
process is important because high-priority environmental aspects and impacts will be considered when
environmental objectives and targets are established.

    Aspects and Impacts Form A -- The first approach uses the experience and judgment of
    employees familiar with facility processes to identify the top five environmental issues currently
    facing the facility. These issues and their specific aspects and impacts should be summarized using
    Aspects and Impacts Form A.

    Aspects and Impacts Form B -- The second approach uses detailed, structured matrices to list
    and prioritize environmental aspects and impacts according to the following categories:

        •   Environmental Aspects and Impacts:           Wastewater
        •   Environmental Aspects and Impacts:           Air Emissions
        •   Environmental Aspects and Impacts:           Hazardous and Solid Waste
        •   Environmental Aspects and Impacts:           Raw Materials
        •   Environmental Aspects and Impacts:           Water and Energy

    The matrices that comprise Form B will help facility staff identify and document environmental
    aspects and impacts. The matrices also provide criteria for prioritizing environmental aspects and
    impacts; this process is important because high-priority environmental aspects and impacts will be
    considered when environmental objectives and targets are established. One possible way to
    prioritize environmental aspects and impacts using Form B is described as follows:




                                                   2-1                                      Element 2.1
Step 1:
For each aspect and impact, score each prioritization criterion      Each environmental aspect and
on a scale from 1 to 5, where 1 indicates the criterion is very      impact form is designed to
important or relevant to that aspect (for example, the aspect is     document the source of each
strictly regulated, is the subject of compliance violations, or is   aspect, which should encourage
a waste generated in large quantities), and 5 indicates the          you to consider source reduction
criterion is relatively unimportant or irrelevant to that aspect     (pollution prevention) strategies
(for example, the aspect is an unregulated waste, is generated       for mitigating the aspect and its
infrequently, and is inexpensive to manage).                         impact.

Step 2:
Add the scores of all criteria for each aspect and write the total in the right-most column of the form.
This number indicates the relative priority of the aspect compared to other aspects and impacts in
the same category. The lower the total score, the higher the priority.




                                                 2-2                                      Element 2.1
                         EMS Procedure                                 2.1
                         Effective Date
    Company Name            Subject                   Environmental Aspects and Impacts


Purpose      This procedure is used to identify, document, and update the environmental aspects and
             impacts of facility processes and operations.

Step 1       The environmental manager and other facility personnel selected by the environmental
             manager are responsible for identifying and prioritizing the environmental aspects and
             impacts of facility operations during EMS planning and development.
             Environmental aspects are characteristics of facility processes and products that interact
             with the environment. Only environmental aspects the company can control or influence
             will be considered.

             Environmental impacts are the effects of an organization's activities, products or services
             on the environment.

Step 2       Environmental aspects and impacts will be documented and prioritized. Environmental
             aspects and impacts will be associated with the following categories:
                     •    Wastewater
                     •    Air emissions
                     •    Hazardous and solid waste
                     •    Raw materials
                     •    Water and energy
             High-priority environmental aspects and impacts will be considered when environmental
             objectives and targets are set.

Step 3       The environmental manager and other facility personnel will review and update the
             environmental aspects and impacts documentation annually.

Step 4       Environmental aspects and impacts documentation will be retained at the facility for at
             least 2 years.

   Responsible Person:

   Signature and Date:




                                                2-3                                       Element 2.1
                                   TOP 5 ENVIRONMENTAL ASPECTS AND IMPACTS


Wastewater, Air Emissions,     Hazardous                Sources           Quantity and        Current
Hazardous and Solid Waste,    Constituents       (indicate process line      Cost           Management         Rationale for
 Raw Materials, or Utility      (if any)               and tank)          (per month)        Practice             Top 5
ex. Chrome-containing            Chrome          • 3 chromic acid         200,000 gal/mo   Treatment and   • Discharge limit
    wastewater from chrome                         tanks (rack line)                       discharge to    • Past violations
    plating                                      • 1 chromic acid tank      $4,000 mo      POTW
                                                   (barrel line)
ex. PERC vapors from parts   Perchloroethylene   • Vapor degreasing         < 1 gal/mo     Engineering     • Worker exposure
    cleaning                                       tent                     cost is low    controls        • AQMD regulation
                                                                                                           • Compliance burden
1.



2.



3.



4.



5.




Responsible Person


Effective Date                                                 2-4                                         ASPECTS FORM A
                                                                    ENVIRONMENTAL ASPECTS AND IMPACTS: WASTEWATER

                                               SOURCE(S)            WEEKLY VOLUME
  TYPE OF                                  (indicate process line         (gallons)                                                         PRIORITIZATION               PRIORITY
WASTEWATER            CONTAMINANTS           and tank number)       or FLOW RATE (gpm)        MANAGEMENT               DISCHARGED TO           CRITERIA                (Sum of Scores)
   Chrome-               Cr+6                                                            Cr+6 reduction                POTW                  Regulatory compliance
   containing            Cr+3                                                                q Sodium metabisulfite    Domestic sewer        Toxicity
                         Cr+6 & Cr+3                                                         q SO2                     Stormwater sewer      Quantity
                                                                                             q Other:                  Surface water body    Process chemical costs
                                                                                         Chemical precipitation                              Treatment costs
                                                                                         Ion exchange
   Cyanide-           Cyanide                                                            CN oxidation                  POTW                  Regulatory compliance
   containing            Cu                                                                      Sodium hypochlorite   Domestic sewer        Toxicity
                         Zn                                                                      Chlorine gas          Stormwater sewer      Quantity
                         Cd                                                                      Ozone                 Surface water body    Process chemical costs
                         Au                                                                      Other:                                      Treatment costs
                         Ag                                                              Chemical precipitation
                         Brass (Cu & Zn)                                                 Ion exchange
   Acid or alkaline                                                                      pH adjustment                 POTW                  Regulatory compliance
   (no plating                                                                           Chemical precipitation        Domestic sewer        Toxicity
   metals)
                                                                                         Ion exchange                  Stormwater sewer      Quantity
                                                                                                                       Surface water body    Process chemical costs
                                                                                                                                             Treatment costs
   Non-cyanide           Cu                                                              pH adjustment                 POTW                  Regulatory compliance
   metals-               Ni                                                              Chemical precipitation        Domestic sewer        Toxicity
   containing
                         Zn                                                              Ion exchange                  Stormwater sewer      Quantity
                         Cd                                                                                            Surface water body    Process chemical costs
                         Au                                                                                                                  Treatment costs
                         Ag
                         Al
                         Organic dyes
   RO                                                                                    pH adjustment                 POTW                  Regulatory compliance
   DI unit reject                                                                        Chemical precipitation        Domestic sewer        Toxicity
                                                                                         Ion exchange                  Stormwater sewer      Quantity
                                                                                         Direct discharge to sewer     Surface water body    Process chemical costs
                                                                                                                                             Treatment costs
Responsible Person


Effective Date                                                                               2-5                                                                      ASPECTS FORM B
                                                              ENVIRONMENTAL ASPECTS AND IMPACTS: WASTEWATER (Continued)

                                         SOURCE(S)               WEEKLY VOLUME
   TYPE OF                           (indicate process line            (gallons)                                                       PRIORITIZATION               PRIORITY
 WASTEWATER           CONTAMINANTS     and tank number)          or FLOW RATE (gpm)        MANAGEMENT             DISCHARGED TO           CRITERIA                (Sum of Scores)
     Spent cooling                                                                    Direct discharge to sewer   POTW                  Regulatory compliance
     water                                                                            Reused on site              Domestic sewer        Toxicity
                                                                                          In rinse tanks          Stormwater sewer      Quantity
                                                                                          Other ______________    Surface water body    Process chemical costs
                                                                                                                                        Treatment costs
     Laboratory                                                                                                   POTW                  Regulatory compliance
     wastewater and                                                                                               Domestic sewer        Toxicity
     liquids
                                                                                                                  Stormwater sewer      Quantity
                                                                                                                  Surface water body    Process chemical costs
                                                                                                                  Returned              Treatment costs
     Boiler                                                                           Treated on site             POTW                  Regulatory compliance
     blowdown                                                                         Discharged to sewer         Domestic sewer        Toxicity
                                                                                                                  Stormwater sewer      Quantity
                                                                                                                  Surface water body    Process chemical costs
                                                                                                                                        Treatment costs
     Cooling tower                                                                                                POTW
     water                                                                                                        Domestic sewer
                                                                                                                  Stormwater sewer
                                                                                                                  Surface water body
     Air scrubber                                                                                                 POTW
                                                                                                                  Domestic sewer
                                                                                                                  Stormwater sewer
                                                                                                                  Surface water body




Responsible Person


Effective Date                                                                            2-6                                                                    ASPECTS FORM B
                                           ENVIRONMENTAL ASPECTS AND IMPACTS: HAZARDOUS AND SOLID WASTE

                                                           HAZARDOUS             ON-SITE                                       PRIORITIZATION               PRIORITY
TYPE OF WASTE                SOURCE      QUANTITY         CONSTITUENTS         MANAGEMENT                   DISPOSAL              CRITERIA                (Sum of Scores)
 Wastewater              WWTS              tons/mo        Cr                    Rolloff bins        Hazardous waste landfill   Regulatory compliance
 Treatment Sludge           Batch                         Cu                    Drum                Special waste landfill     Toxicity
                            Continuous                    Ni                    Sacks               Recycling facility         Quantity
                          Other                           Zn                                                                   Disposal cost
                      _______________                     Cd
                                                          Au
                                                          Ag
 Spent Process                             gal/mo         Cr                    Drums               Recycling facility         Regulatory compliance
 Baths                                                    Cu                    Tanks               Hazardous waste            Toxicity
                                                          Ni                    On-site treatment   treatment facility         Quantity
                                                          Zn                                        POTW                       Disposal cost
                                                          Cd
                                                          Au
                                                          Ag
                                                          CN
 Spent IX Resins                                                                Drums               Recycler                   Regulatory compliance
                                                                                Dumpster            Other                      Toxicity
                                                                                                                               Quantity
                                                                                                                               Disposal cost
 Filter Media                                                                   Drums               HW landfill                Regulatory compliance
 Cartridges                                                                     Dumpster            Incinerator                Toxicity
 Loose Media                                                                    Sacks               SW landfill                Quantity
 Bag Filters                                                                                                                   Disposal cost
 Waste PPE                  Gloves         drums/mo                             Drums               HW landfill                Regulatory compliance
                            Masks                                               Dumpster            Incinerator                Toxicity
                            Boots                                                                   SW landfill                Quantity
                            Aprons                                                                                             Disposal cost
                            Other




 Responsible Person


 Effective Date                                                          2-7                                                                           ASPECTS FORM B
                                   ENVIRONMENTAL ASPECTS AND IMPACTS: HAZARDOUS AND SOLID WASTE (Continued)

                                                        HAZARDOUS             ON-SITE                            PRIORITIZATION               PRIORITY
 TYPE OF WASTE            SOURCE    QUANTITY           CONSTITUENTS         MANAGEMENT            DISPOSAL          CRITERIA                (Sum of Scores)
   Waste Masking                                                             Drums          HW landfill          Regulatory compliance
                                                                             Trash can      Incinerator          Toxicity
                                                                                            SW landfill          Quantity
                                                                                                                 Disposal cost
   Rags / Wipes                                                              Drums          Industrial Laundry   Regulatory compliance
                                                                             Dumpster       HW landfill          Toxicity
                                                                                            SW landfill          Quantity
                                                                                                                 Disposal cost
   Spent Solvents                                                            Drums          Recycling Facility   Regulatory compliance
       Liquid                                                                               Incinerator          Toxicity
       Still bottoms                                                                                             Quantity
                                                                                                                 Disposal cost
Absorbent                                                                    Drums         HW Landfill
       Pads
       Loose
   Waste Packaging                                                           Trash can      SW landfill          Regulatory compliance
        Cardboard                                                            Dumpster       Recycled             Toxicity
        Pallets                                                              Pile                                Quantity
        Wrapping                                                                                                 Disposal cost
   Aluminum            Employees       /mo                                   Trash can      SW landfill          Regulatory compliance
                                                                             Dumpster       Recycled             Toxicity
                                                                             Dedicated                           Quantity
                                                                             container                           Disposal cost
   Paper               Office          /mo                                   Trash can      SW landfill          Regulatory compliance
                                                                             Dumpster       Recycled             Toxicity
                                                                                                                 Quantity
                                                                                                                 Disposal cost
   Copper Wire                                                               Dedicated      Recycled             Regulatory compliance
                                                                             container                           Toxicity
                                                                                                                 Quantity
                                                                                                                 Disposal cost

  Responsible Person


  Effective Date                                                      2-8                                                                ASPECTS FORM B
                                                                       ENVIRONMENTAL ASPECTS AND IMPACTS: AIR EMISSIONS

                                                     SOURCE(S)                        TANK                                            PRIORITIZATION CRITERIA        PRIORITY
        EMISSION TYPE                  (indicate process line and tank number)   SURFACE AREA (ft 2)             MANAGEMENT                (1 = high, 5 = low)     (Sum of scores)
Chrome Plating                                                                                         Scrubbers              Balls    Regulatory compliance
       Cr+6                                                                                            Demisters              None     Toxicity
       Cr+3                                                                                            Surfactant                      Emission control costs
                                                                                                       Foam                            Worker exposure
Solvent: Controlled                                                                                    Chiller                         Regulatory compliance
       Trichlorethane                                                                                  Unit cover                      Toxicity
       Perchoroethylene                                                                                Distillation                    Emission control
       Mineral spirits                                                                                 Increased Freeboard             Worker exposure
Solvent: Uncontrolled                                                                                  Venting                         Regulatory compliance
       Acetone                                                                                         None                            Toxicity
       Other:                                                                                                                          Emission control
                                                                                                                                       Worker exposure
Acid Vapors                                                                                            Scrubber                        Regulatory compliance
       HCl                H2SO4                                                                        Uncontrolled                    Toxicity
       HNO3               Mixed                                                                                                        Emission control costs
                                                                                                                                       Worker exposure
Alkaline Vapors                                                                                        Venting                          Regulatory compliance
                                                                                                       None                            Toxicity
                                                                                                       Fume Suppressant                Emission control costs
                                                                                                                                       Worker exposure
    Water vapor and trace metals     Evaporator                                                        Condensers                       Regulatory compliance
                                                                                                       None                            Toxicity
                                                                                                                                       Emission control costs
                                                                                                                                       Worker exposure
    Water vapor, particulates, and   Sludge dryer                                                      Particulate removal:            Regulatory compliance
    trace metals                                                                                                                       Toxicity
                                                                                                       None                            Emission control costs
                                                                                                                                       Worker exposure




  Responsible Person


  Effective Date                                                                                 2-9                                                             ASPECTS FORM B
                                                        ENVIRONMENTAL ASPECTS AND IMPACTS: AIR EMISSIONS (Continued)

                                             SOURCE(S)                        TANK                                     PRIORITIZATION CRITERIA        PRIORITY
             EMISSION TYPE     (indicate process line and tank number)   SURFACE AREA (ft 2)           MANAGEMENT           (1 = high, 5 = low)     (Sum of scores)
         Engine exhaust      Delivery Vehicles                                                 Maintenance              Regulatory compliance
                                                                                               Other                    Toxicity
                                                                                               None                     Emission control costs
                                                                                                                        Worker exposure




Responsible Person


Effective Date                                                                          2-10                                                      ASPECTS FORM B
                                      ENVIRONMENTAL ASPECTS AND IMPACTS: RAW MATERIALS

                                                                                          PRIORITIZATION
                                      ANNUAL COST           ANNUAL QUANTITY USED              CRITERIA             PRIORITY
           RAW MATERIAL OR RESOURCE      ($/year)              (gallons or pounds)        (1 = High, 5 = Low)    (Sum of Scores)
 1.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat
 2.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat
 3.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat
 4.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat
 5.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat
 6.                                                                                      Regulatory compliance
                                                                                         Toxicity
                                                                                         Quantity
                                                                                         Cost
                                                                                         Difficult to treat

Responsible Person


Effective Date                                              2-11                                                         ASPECTS FORM B
                                           ENVIRONMENTAL ASPECTS AND IMPACTS: WATER AND ENERGY

                                                                                                 PRIORITIZATION     PRIORITY
                     RESOURCE                        USE                 QUANTITY                   CRITERIA      (Sum of Scores)

       Water                    Process water                              gallons/month             Quantity


                                DI                                         gallons/month             Cost


                                RO                                         gallons/month


                                Sanitary                                   gallons/month


                                Irrigation                                 gallons/month


       Electricity              Plating rectifiers                         kW-hr/month              Quantity


                                Equipment operation                                                  Cost


                                Facility lighting


                                Process bath heating

       Gas                      Heat process baths                         cubic feet/month         Quantity


                                Building heating                                                     Cost


                                Boiler


                                Oven


                                Degreaser


                                Office heat




Responsible Person


Effective Date                                                    2-12                                                    ASPECTS FORM B
                                                                                  ELEMENT 2.2

                                                                                COMPLIANCE

All EMSs must, at a minimum, address compliance with applicable environmental regulations. Because
metal finishing operations generate a variety of wastes in many forms (wastewater, air emissions, sludge,
spent process baths, etc.) it is especially critical that companies develop and implement a structured,
comprehensive approach to compliance. Costs of noncompliance (in terms of penalties and public
image and customer relations) can have a significant effect on profits and long-term competitiveness.

To be in compliance with the laws and regulations that apply to your company and its operations, you
must (1) know what the regulations are and (2) implement procedures and install equipment to
comply with those regulations.

Changes in compliance requirements might require you to modify your environmental objectives or other
elements of your EMS. By anticipating new requirements, you may be able to minimize future
compliance obligations through process changes. Therefore, it’s important to (1) identify and use
information and assistance sources such as guidance documents, technical contacts at pertinent
regulating agencies (such as the publicly owned treatment works [POTW] and the Bay Area Air Quality
Management District [BAAQMD]), (2) maintain contact with local and national industry associations,
and (3) commit to reviewing your compliance requirements at regular time intervals during the year.

                                                          Also, as you complete the process of cataloging
Regulatory compliance requirements include :
                                                          compliance requirements, you should begin to
• Federal requirements
                                                          identify “environmental metrics” that should be
• State and local requirements
                                                          addressed in Element 4.1, Measurement and
• Permit conditions                                       Monitoring.
Other environmental “requirements” might
include:
                                                          The Template contains a procedure and
• Customer-specific codes
                                                          several EMS tools to help you in identifying
• Standards in locations where you sell products
                                                          and meeting your compliance requirements.
• International Chamber of Commerce (ICC)                 Those tools are described below:
   Charter for Sustainable Development
• Strategic Goals Program (SGP)
• Other industry codes or programs to which your
   organization voluntarily subscribes




                                                  2-13                                     Element 2.2
Environmental and Health & Safety Regulatory Compliance Checklist. The Environmental and
Health & Safety Regulatory Compliance Checklist (Checklist) contains an extensive, but not
comprehensive, overview of a wide range of applicable federal, state, and local regulations that metal
finishers in northern California commonly encounter. The Checklist is designed as an “office exercise”
to identify any apparent weaknesses in your facility’s current compliance approach and status. Gather a
team of employees who have first-hand knowledge of the questions posed in the Checklist. Answer the
questions honestly and precisely to create an accurate assessment of your company’s compliance
performance. References are provided for each question in the checklist and include the governing
regulation, guidance documents, and other helpful resources.

Compliance Calendar. The compliance calendar provides a summary of the Checklist organized
around the frequency of completing and reporting requirements. With cross-references that point to
relevant sections of the Checklist, the compliance calendar summarizes deadlines for requirements that
must be completed daily, weekly, monthly, annually, or on a specific date.

Regulatory Agency Diagram. This tool is a one-page diagram of the regulatory framework that
surrounds metal finishers in northern California. The diagram is a simplified representation of the various
federal, state, and local regulatory agencies and the associated compliance areas.




                                                   2-14                                      Element 2.2
                      EMS Procedure                                   2.2
                        Effective Date
    Company Name           Subject                               Compliance


Purpose      This procedure is used to (1) identify weaknesses in a company’s current compliance
             status and performance, and (2) help the company become informed about and track
             compliance requirements.

Step 1       The environmental manager and other facility staff will complete the Environmental and
             Health & Safety Compliance Checklist in its entirety. The group tasked with completing
             the Checklist will, to the greatest degree possible, have first-hand knowledge of the
             answers given to each question.

Step 2       After working through the Checklist, the environmental manager will prepare a list of
             potential objectives and targets related to compliance requirements or performance.
             The list will be used in completing Element 2.3, Objectives and Targets.

Step 3       The environmental manager will use the Compliance Calendar during day-to-day
             operations to assist in planning for and meeting the company’s compliance requirements.

Step 4       The environmental manager or designee will stay informed of changing environmental
             regulations. This can be achieved by (check those that apply):

                     Obtaining a Metal Finishing Guidance Manual and maintaining a
                     subscription to receive updates
                     Reviewing regulatory updates and the compliance calendar and attending
                     compliance workshops offered by state and local regulatory agencies and
                     the Surface Technology Association (STA)
                     Using a consultant specializing in compliance issues
                     Visiting Internet websites with compliance assistance content:
                         www.nmfrc.org (National Metal Finishing Resource Center)
                         www.epa.gov/commonsense/metals/index.htm
                         (Common Sense Initiative for Metal Finishing)
                         www.finishing.com
                         www.metal-finishing.com
                         Other




                                               2-15                                     Element 2.2
Step 5      The environmental manager or designee will complete the Checklist at least every 6
            months to identify new and existing weakness, and in response to new or changed
            environmental regulations.



   Responsible Person:

   Signature and Date:




                                             2-16                                    Element 2.2
Environmental Management System
Compliance Calendar

DAILY
                                          Program/
  Agency               Program            Question                Scheduled Task

Cal/OSHA    Injury & Illness Prevention     16/2     Safety Suggestion Box – check for new
            Program                                  suggestions

DTSC        On-Site Hazardous Waste         10/7     Facility Inspection – check areas subject to
            Treatment                                spills, overfill control equipment, monitoring
                                                     data, and uncovered tanks


WEEKLY
                                          Program/
  Agency               Program            Question                Scheduled Task

DTSC,       On-site Hazardous Waste         10/7     Facility Inspection -- check containment,
RWQCB       Treatment                                stored containers, and tanks


MONTHLY
                                          Program/
  Agency               Program            Question                Scheduled Task

Cal/OSHA    Injury & Illness Prevention     16/      Employee Training – conduct monthly safety
            Program                                  meeting
            Employee Training               26/7

Cal/OSHA    Injury & Illness Prevention     16/2     Safety Committee – conduct monthly safety
            Program                                  committee meeting

RWQCB       Storm Water Pollution           15/6     Facility Inspection – conduct storm water
            Prevention                               discharge visual observation – check for
                                                     presence of floating and suspended
                                                     material, oil and grease, discoloration,
                                                     turbidity, odor, and pollutants (monthly during
                                                     wet season: Oct. 1 – May 31)


QUARTERLY
                                          Program/
  Agency               Program            Question                Scheduled Task

POTW        Industrial Wastewater           7/4      Periodic Report of Continued Compliance –
            Discharge                                submit quarterly discharge monitoring report
                                                     to local sewer agency (Note: report
                                                     submittal schedule may differ)

RWQCB       Storm Water Pollution           15/5     Facility Inspection – conduct non-storm
            Prevention                               water discharge visual observation – check
                                                     for flow, debris, odor, and discoloration




                                          2-17                                      Element 2.2
ANNUALLY
                                                 Program/
     Agency                 Program              Question                         Scheduled Task

CUPA or Local       Hazardous Materials               5/2            Submit annual update of Hazardous Materials
Agency              Business Plan                                    Business Plan (HMBP) to CUPA or Local
                                                                     Agency

POTW                Industrial Wastewater             7/1            Industrial Discharge Permit – submit annual
                    Discharge                                        update (Note: update schedule may differ)

DTSC                On-site Hazardous Waste           10/7           Facility Inspection – check storage tank
                    Treatment                                        system

Cal/OSHA            Hearing Conservation              21/4           Complete annual audiometric testing for
                    Program                                          employees exposed to noise levels higher
                                                                     than 85 dBA (8-hour Time-Weighted Average)

Cal/OSHA            Respiratory Protection            22/5           Complete annual medical examination for
                    Program                                          employees who use a respirator

Cal/OSHA            Process and Laboratory           23/2, 3         Test process tanks and laboratory hood for
                    Ventilation                                      proper ventilation velocities

Cal/OSHA            Recordkeeping                      ---           Annual notice to employees of existence,
                                                                     location, and availability of employee
                                                                     exposure and medical records

USEPA, DTSC,        Employee Training                 26/6           Emergency Coordinator Training – annual
Federal OSHA,                                                        refresher training
Cal/OSHA, CUPA,
DOT


PERIODICALLY
                                                       Program/
    Date          Agency            Program            Question                     Scheduled Task

January 31      Cal/OSHA     Recordkeeping                     ---       Post Annual Summary of Occupational
                                                                         Illnesses and Injuries during the month
                                                                         of February

March 1         DTSC         On-site Hazardous               10/2        Tiered Permit – submit annual Facility-
                             Waste Treatment                             Specific Notification on agency forms

March 1         DTSC         On-site Hazardous               10/4        Closure Plan – adjust closure cost
                             Waste Treatment                             estimate

March 1 of      USEPA,       On-site Hazardous               10/9        Biennial Report – submit completed
Even Number     DTSC         Waste Treatment                             report on agency forms, if required (Note:
Years                                                                    forms are updated each reporting period)

June 1          RWQCB        Storm Water Pollution           15/8        Facility Inspection & Plan Review –
                             Prevention                                  conduct annual inspection of storm water
                                                                         structures and evaluation of SWPP Plan

July 1          USEPA        Multimedia Reporting            12/1        Form R Reporting – submit completed
                             (Form R)                                    report on agency forms, if required (Note:
                                                                         forms are updated each reporting period)




                                                 2-18                                                Element 2.2
PERIODICALLY (continued)
                                                       Program/
     Date         Agency             Program           Question                Scheduled Task

 July 1          RWQCB         Storm Water Pollution       15/9     Annual Report – submit completed
                               Prevention                           annual report on agency forms, if
                                                                    required (Note: facility may be included in
                                                                    a Group Monitoring Plan)

 September 1     DTSC          Waste Minimization          13/1     Evaluation & Plan, and Performance
 Every 4 Years                 Reporting                            Report – update the Plan and Report
 (99, 03, 07…)                                                      every 4 years, if required

 September 1     DTSC          Waste Minimization          13/2     Waste Audit Study & Compliance
 Every 4 Years                 Reporting                            Checklist – update the Waste Audit Study
 (99, 03, 07…)                                                      & Compliance Checklist every 4 years, if
                                                                    required

 September 1     DTSC          Waste Minimization          13/3     Summary Progress Report – update the
 Every 4 Years                 Reporting                            Summary Progress Report every 4 years
 (99, 03, 07…)                                                      and submit it to DTSC, if required

 October 1 –     RWQCB         Storm Water Pollution       15/7     Storm Water Sampling and Analysis –
 May 31                        Prevention                           take samples of storm water from two
                                                                    storm events and have analyzed for
                                                                    required contaminants (Note: facility may
                                                                    be include in a Group Monitoring Plan)

 Each Batch or   DTSC          On-site Hazardous           10/8     Log each batch or amount of hazardous
 Amount of                     Waste Treatment                      waste treated on site
 Hazardous
 Waste
 Treated


Agency Codes:
 CUPA            Certified Unified Program Agency
 DOT             U.S. Department of Transportation
 DTSC            California Department of Toxic Substances Control
 OSHA            Occupational Safety and Health Administration (Federal OSHA and Cal/OSHA)
 POTW            Publicly Owned Treatment Works (Sewer Authority)
 RWQCB           Regional Water Quality Control Board
 USEPA           U.S. Environmental Protection Agency




                                                    2-19                                       Element 2.2
            ENVIRONMENTAL and HEALTH & SAFETY REGULATORY COMPLIANCE
                                                          CHECKLIST



                                                        Table of Contents
                                                                                                                                            Page

I.     Self-Audit Procedures ..................................................................................................              2
II.    Additional Information ..................................................................................................             2
III.   Additional Requirements .............................................................................................                 2
IV.    Legal Authority ..............................................................................................................        3
V.     EH&S Compliance Checklist:
           1.   EH&S Program Administration .................................................................................                4
           2.   Pollution Prevention .................................................................................................       4
           3.   Emergency Response .............................................................................................             5
           4.   Hazardous Materials Storage Permit .........................................................................                 6
           5.   Hazardous Materials Business Plan (HMBP) .............................................................                       6
           6.   Accidental Release Prevention (CalARP) ...................................................................                   6
           7.   Industrial Wastewater Discharge (POTW) ..................................................................                    7
           8.   Hazardous Waste Activity Registration ......................................................................                 7
           9.   Local Hazardous Waste Generator Permit .................................................................                     7
           10. Onsite Hazardous Waste Treatment (Tiered Permit) ...................................................                          8
           11. Hazardous Materials and Hazardous Waste Storage ..................................................                            8
           12. Multimedia Reporting (Form R) .................................................................................               9
           13. Waste Minimization Reporting (SB-14) ......................................................................                   9
           14. Air Pollution Control .................................................................................................      10
           15. Storm Water Pollution Prevention (SWPP) ................................................................                     12
           16. Injury and Illness Prevention Plan (SB-198) ................................................................                 13
           17. Hazard Communication ............................................................................................            13
           18. Safe Drinking Water and Toxic Enforcement Act (Proposition 65) ................................                              14
           19. Energy Control Program (Lockout/Tagout) .................................................................                    14
           20. Confined Spaces .....................................................................................................        14
           21. Hearing Conservation ...............................................................................................         14
           22. Respiratory Protection .............................................................................................         15
           23. Process and Laboratory Ventilation ...........................................................................               15
           24. Chemical Hygiene Plan ............................................................................................           16
           25. Personal Protective Equipment .................................................................................              16
           26. Employee Training ...................................................................................................        16
           27. Facility Inspections .................................................................................................       17
                Footnotes ...............................................................................................................   18




                                                                           2-20                                                 Element 2.2
                                                     ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST




Self-Audit Procedures: (See Procedure 2.2 for further instructions). The following checklist should be used as an aid in reviewing your facility’s
compliance with industry environmental and health & safety regulations and requirements. The listed references (column 6) provide additional
information as to the specific requirements for each program. Reference documents may be available through your association. Column 7
(Status/Notes) should be used to document your compliance.

Pollution prevention (P2) items have been strategically placed near the beginning of the checklist. By completing the P2 items first, a facility may realize
compliance with other regulatory programs by simply instituting good waste minimization practices.

Additional Information: This checklist is based on the current laws and regulations as of the date of publication. Regulations frequently change.
Therefore, you should review current laws and regulations for any recent changes in the requirements. Some of the items you should check include:
   §   Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 7 (California Occupational Safety and Health Administration –
       Cal/OSHA) – General Industrial Safety Orders
   §   Title 22, California Code of Regulations, Division 4.5 (California Department of Toxic Substances Control) – Environmental Health Standards
       for the Management of Hazardous Waste
   §   California Health & Safety Code, Chapter 6.95 and Local Certified Unified Program Agency (CUPA) Requirements – Hazardous Materials
       Business Plan and Accidental Release Prevention Program
   §   Local Sewer Authority – Industrial Wastewater Discharge
   §   South Coast Air Quality Management District – Air Pollution Control Rules

   §   Regional Water Quality Control Board – Storm Water Pollution Prevention Plan and Monitoring Program
   §   Internet: DTSC – http://www.dtsc.ca.gov/                     USEPA – http://www.epa.gov/
                 SCAQMD – http://www.aqmd.gov/                      Fed/OSHA – http://www.osha.gov/
                 SWRCB – http://www.swrcb.ca.gov/                   Cal/OSHA – http://www.dir.ca.gov/occupational_safety.html
                 OES – http://www.oes.ca.gov/                       NMFRC – http://www.nmfrc.org/




                                                           2-21                                 Element 2.2
                                                  ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST

Additional Requirements: In addition to recent changes in the requirements, you should also consider additional Cal/OSHA standards that might apply
to your facility. Regulatory information may be found in Title 8 California Code of Regulations. These might include any of the following:
   §   Employer postings; ergonomics; process safety management; use of asbestos, formaldehyde, or lead containing substances; bloodborne
       pathogens; welding operations; use of compressed air and gases; boiler operations; use of power tools, hoists and grinding equipment; spray
       coating; elevated platforms; aisleway, ramp, door and exit requirements; fire sprinkler requirements; and seismic requirements.

Legal Authority: The compliance requirements provided on the following pages are taken from the respective laws and regulations, as indicated in the
“References” column. In addition to the statutory and regulatory requirements, some compliance items that reflect improved and accepted management
practices have been included. These management practices have been included because of their overall industry acceptance and their potential to
reduce environmental risk and improve compliance.




                                                                       2-22
                                                                   ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST



                                     2                                                                                                    3
     Program              Agencies                                Check                               Yes   No   %          References           Status/Notes
1. EH&S Program     All                  1.   Has a Program Administrator been assigned to
   Administration                             oversee all EH&S activities for the facility? It is a
                                              good policy to have one person assigned this
                                              responsibility.

2. Pollution        DTSC, POTW, USEPA    1.     Has the facility installed rinsewater reuse and                      - Local Ordinances
   Prevention                                   reduction measures:
                                                                                                                     - 22 CCR §67100.1-.14
                                              A.     Flow restrictors
                                              B.     Countercurrent rinses                                           - DTSC and USEPA P2
                                              C.     Spray rinses                                                      Documents*
                                              D.     Dragout rinses
                                              E.     Timer flow controls                                             - DTSC Document #402
                                              F.     Conductivity flow controls                                        (Hazardous Waste
                                              G.     Reuse of rinsewater in scrubber                                   Minimization Checklist
                                              H.     Recapture of dragout rinsewater                                   & Assessment Manual
                                                                                                                       for the Metal Finishing
                                              I.     Improved rinsewater agitation
                                                                                                                       Industry)
                                         2. Has the facility instituted the practice of optimizing
                                            bath use:                                                                - POTW P2 Documents
                                            A.    Filtration of bath                                                 - EMS Form
                                            B.    Bath change by analysis
                                            C.    New chemistry to reduce waste                                      -- EMS Checklist
                                            D.    Evaporation to concentrate waste
                                         3. Has the facility instituted practices to reduce
                                            dragout:
                                            E. Operate bath at low end of concentration
                                            F. Increase bath temperature
                                            G. Drip bars
                                            H. Slower workpiece removal
                                            I.  Spray rinses over process tanks
                                            J. Air knives
                                            K. Coated racks
                                            L. Drain boards




                                                                                                  2-23
                                                              ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                2                                                                                                   3
     Program         Agencies                                Check                             Yes   No   %            References         Status/Notes
2. Pollution     DTSC, POTW, USEPA   4.   Has the facility instituted practices to improve                    - Local Ordinances
   Prevention                             waste treatment:
                                                                                                              - 22 CCR §67100.1-.14
   (continued)                            A.   Improved treatment chemistry
                                                                                                              - DTSC and USEPA P2
                                          B.   Flow equalization
                                                                                                                Documents*
                                          C.   Batch treatment
                                                                                                              - DTSC Document #402
                                                                                                                (Hazardous Waste
                                                                                                                Minimization Checklist
                                                                                                                & Assessment Manual
                                                                                                                for the Metal Finishing
                                                                                                                Industry)

                                                                                                              - POTW P2 Documents

                                                                                                              - EMS Form

                                                                                                              - EMS Checklist

3. Emergency     CUPA, DTSC, DOT,    a.   Has the facility prepared a written Emergency                       --   H&SC §25500
   Response      OSHA, USEPA              Response Plan that includes Emergency                               --   29 CFR 1910.120
                                          Procedures and the information listed below? All                    --   22 CCR §66265.52
                                          employees should be trained in emergency                            --   8 CCR §5192
                                          procedures.                                                         --   CUPA HMBP*
                                     b.   Have Emergency Coordinators been designated                         -- EMS Form
                                          for response to emergency incidents?
                                          Responsible staff members should be trained for
                                          emergencies.
                                     c.   Has the facility prepared a Facility Evacuation                     -- EMS Form
                                          Map that clearly shows evacuation routes? Is
                                          the map posted throughout the facilities?
                                          Employees should be trained in evacuation
                                          procedures and evacuation drills should be
                                          conducted.




                                                                                             2-24
                                                             ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                2                                                                                                  3
     Program         Agencies                               Check                                Yes   No   %         References       Status/Notes
3. Emergency     CUPA, DTSC, DOT,   d.   Have Emergency Telephone Numbers been                                  -- EMS Form
   Response      OSHA, USEPA             documented for Emergency Coordinators,
   (continued)                           emergency services agencies and companies,
                                         and senior facility staff? The list should be
                                         posted in the facility.
                                    e.   Has a list of Emergency Equipment been                                 -- EMS Form
                                         prepared for the facility?
                                    f.   Have arrangements been made with Emergency                             -- EMS Form
                                         Services Companies to provide emergency
                                         response? Written agreements should be
                                         obtained.
                                    g.   Has the facility assembled and Inventory of                            -- EMS Form
                                         Hazardous Materials to be made available in the
                                         event of an emergency? If the facility has
                                         prepared a Hazardous Materials Inventory
                                         Statement, include a copy of it with your
                                         Emergency Response Plan.
                                    h.   Has the facility prepared an Emergency Action                          -- 8 CCR §3220
                                         Plan that discusses procedures to follow in an
                                         emergency? This plan may be included in the
                                         facility’s Emergency Response Plan
                                    i.   Has the facility prepared a Fire Prevention Plan
                                         that discusses methods to prevent fires in the                         -- 8 CCR §3221
                                         facility? This plan may be included in the facility’s
                                         Emergency Response Plan.




                                                                                            2-25
                                                                     ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                       2                                                                                                  3
     Program               Agencies                                 Check                             Yes   No   %           References                Status/Notes
4. Hazardous           Local Agency        1.   Has the facility submitted a Hazardous Materials                     - Local Ordinances –
   Materials Storage                            Storage Permit application, if required? Some                          (typically Fire Dept or local
   Permit                                       local agencies may include this permit with their                      CUPA)
                                                Hazardous Materials Business Plan requirement
                                                or their CUPA registration.

5. hazardous           CUPA or Local       1.   If the facility uses more than the threshold                         - H&SC §25500
   Materials           Agency, OES              quantities of hazardous material, has the facility
                                                                                                                     - OES HMBP Forms*
   Business Plan                                submitted a Hazardous Materials Business Plan
   (HMBP)                                       (HMBP) to the local governing agency?                                - Local Agency HMBP
                                                Threshold quantities are 500 pounds, 55 gallons,                       Forms*
                                                or 200 cubic feet of hazardous materials at any
                                                one time during the year.                                            - EMS Checklist

                                           2.   Has the facility updated the HMBP as required or
                                                annually? A revised HMBP must be submitted to
                                                the local agency within 30 days when material
                                                quantities increase by 100% or any new material,
                                                or annually.

6. Accidental          CUPA or Local       1.   If the facility uses listed acutely hazardous                        -- H&SC §25531
   Release             Agency, OES              materials above threshold quantities, has the                        -- CUPA Registration
   Prevention                                   facility submitted a CalARP Registration form?                          Form*
   (CalARP)                                2.   If required by the local agency, has the facility
                                                submitted a Risk Management Plan (required                           - OES RMP Guidance
                                                6/21/99)?                                                              Document*

7. Industrial          POTW                1.   If the facility discharges treated industrial                        - Local Industrial
   Wastewater                                   wastewater to the sewer, has the facility                            Discharge Ordinance and
   Discharge                                    submitted a Wastewater Discharge Permit                              Permit Application*
                                                Application to the local POTW?
                                           2.   Has the facility ensured compliance with its                         - 40 CFR §403*
                                                wastewater discharge permit by:
                                                A. Notifying the local POTW of any new or
                                                     modified processes or discharge sources
                                                B. Confirming sampling point(s) complies with
                                                     federal and local requirements
                                                C. Confirming sampling methods comply with
                                                     federal and local requirements



                                                                                                    2-26
                                                                   ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                     2                                                                                                  3
     Program              Agencies                                Check                              Yes   No   %          References       Status/Notes
7. Industrial         POTW               2.   Has the facility ensured compliance with its                          - 40 CFR §403*
   Wastewater                                 wastewater discharge permit by:
   Discharge                                  D. Ensuring the facility’s solvent management
   (continued)                                     and slug control plans are effectively
                                                   implemented
                                              E. Ensuring industrial wastewater discharge
                                                   includes no diluting streams
                                              F. Ensuring wastewater treatment operators
                                                   are properly trained to assess the
                                                   performance of the facility’s wastewater
                                                   treatment system
                                         3.   Has the facility completed required sampling and
                                              analysis of industrial wastewater?
                                         4.   Has the facility submitted a Periodic Report of
                                              Continued Compliance (PRCC) or Self
                                              Monitoring Report (SMR) on the established
                                              submittal schedule?

                                                                                                                    - Local POTW PRCC/SMR
                                                                                                                      forms*

8. Hazardous Waste    DTSC, USEPA        1.   Has the facility completed a Hazardous Waste                          - EPA Form 8700-12
   Activity                                   Activity form that correctly reflects the waste
   Registration                               generation at the facility?

9. Local Hazardous    Local Agency       1.   If required by a local agency, has the facility                       - Local Ordinance
   Waste Generator                            completed and submitted a local Hazardous
   Permit                                     Waste Generator’s Permit Application?

10. On-Site           CUPA, DTSC         1.   If the facility treats hazardous waste onsite, has                    - 22 CCR §67450.1-.13
    Hazardous                                 the facility prepared and submitted an Onsite
    Waste                                     Hazardous Waste Treatment Notification Form
    Treatment                                 (Tiered Permit)?
    (Tiered Permit)                      2.   Has the facility completed all annual updates to                      - DTSC Form 1772*
                                              the Onsite Hazardous Waste Treatment
                                              Notification Form? Updates are due to DTSC by
                                              March 1.
                                         3.   Has the facility prepared a Waste Analysis Plan?                      - EMS Checklist




                                                                                                   2-27
                                                                    ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                     2
     Program              Agencies                                 Check                             Yes   No   %          References 3       Status/Notes
10. On-Site           CUPA, DTSC          4.   Has the facility prepared a Closure Plan and                         - 22 CCR
    Hazardous                                  updated the Closure Cost Estimate annually or                          §67450.3(a)(13)(B)
    Waste                                      as required?
    Treatment                             5.   Has the facility completed a Tiered Permit Phase                     - 22 CCR §67450.7
    (Tiered Permit)                            I Environmental Assessment?                                          - DTSC Form 1151*
    (continued)                                                                                                     - 22 CCR §66265.52
                                          6.   Has the facility completed a Contingency Plan?
                                               (May be part of Emergency Response Plan)
                                          7.   Has the facility completed and recorded Facility                     - 22 CCR §66265.15(b)
                                               Inspections?
                                          8.   Has the facility recorded all quantities of
                                               hazardous waste treated?
                                                                                                                    - USEPA Biennial Report
                                          9.   Has the facility completed and submitted Biennial
                                                                                                                      Booklet*
                                               Reports, if a Large Quantity Generator? The
                                               Biennial Report must be submitted to USEPA
                                               and/or DTSC on agency forms each even
                                               numbered year by March 1.

11. Hazardous         DTSC, CUPA or Local 1.   Are all containers of hazardous materials and                        - 22 CCR §66264.170-178
    Materials and     Agency, OSHA             hazardous waste properly segregated?                                 - 8 CCR §5164
    Hazardous                             2.   Are all containers of hazardous materials and                        - Local Ordinances
    Waste Storage                              hazardous waste closed, except during                                - EMS Checklist
                                               dispensing?
                                          3.   Are all hazardous materials and hazardous
                                               waste containers in good condition?
                                          4.   Are all containers of hazardous waste stored
                                               inside secondary containment?
                                          5.   Are all containers of hazardous waste properly
                                               labeled with a Hazardous Waste Label, which
                                               includes the accumulation start time (limit is 90
                                               days)?




                                                                                                   2-28
                                                                ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                  2                                                                                                   3
     Program           Agencies                                Check                               Yes   No   %          References           Status/Notes
12. Multimedia     USEPA              1.   Has the facility completed and submitted Toxic                         -- USEPA Form R Booklet*
    Reporting                              Release Inventory (Form R) Reports, if the
    (Form R)                               facility processes or uses more than the
                                           threshold quantities of listed materials. The Form
                                           R Report must be submitted to USEPA each year
                                           by July 1.

13. Waste          DTSC, CUPA         1.   If the facility generates more than 12,000 Kg of                       - 22 CCR §67100.1-.14
    Minimization                           hazardous waste, or 12 Kg of extremely                                 - H&SC 25244.12-.23
    Reporting                              hazardous waste, has the facility prepared a                           - Hazardous Waste
    (SB-14)                                Source Reduction Evaluation and Plan and                                 Source Reduction
                                           Performance Report (SB-14)? The documents                                Guidance Manual*
                                           must be updated every four years by September
                                           1 (1999, 2003…)
                                      2.   If the facility is a small business, has the facility                  - California Government
                                           prepared an industry-specific Waste Audit Study                          Code Article 2, Section
                                           or a Source Reduction Compliance Checklist?                              11342
                                           The documents must be updated every four
                                                                                                                  - Hazardous Waste
                                           years by September 1 (1999, 2003…)
                                                                                                                  Source Reduction
                                      3.   If captured by SB-14, has the facility prepared a                      Compliance Checklist*
                                           Summary Progress Report that summarizes the
                                           results from previously implemented source
                                           reduction methods, and estimates future
                                           anticipated source reduction achievements. This
                                           document must be SENT to DTSC every four
                                           years by September 1 (1999, 2003…)




                                                                                               2-29
                                                                ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                  2                                                                                                 3
      Program          Agencies                                Check                              Yes   No   %         References        Status/Notes
14. Air Pollution   CARB, SCAQMD      1.   If the facility emits any hazardous substance                         - H&SC §42300
    Control                                above emission standards, has the facility                            - SCAQMD Rule 201 and
                                           submitted an Air Pollution Control Permit                               Permit Application
                                           Application?                                                            Forms
                                      2.   If the facility performs electrolytic chrome plating                  - SCAQMD Rule 1469
                                           or chromic acid anodizing:
                                           A.   Facilitywide chromium emissions are less
                                                than 2 lbs/year:
                                                1.   Has the facility added anti-mist additive
                                                     to each process tank, or installed other
                                                     control equipment to reduce tank
                                                     emissions by at least 95%, or

                                                2.    Has the facility reduced emissions from
                                                      the emissions collection system to less
                                                      than 0.05 mg/amp-hr for decorative
                                                      chrome plating and less than 0.15
                                                      mg/amp-hr for hard chrome plating or
                                                      chromic acid anodizing?




                                                                                              2-30
                                                                ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                  2                                                                                                 3
      Program          Agencies                                Check                              Yes   No   %         References       Status/Notes
14. Air Pollution   CARB, SCAQMD      2.   If the facility performs electrolytic chrome plating                  - SCAQMD Rule 1469
    Control                                or chromic acid anodizing:
    (continued)                            B.   Facilitywide chromium emissions are
                                                between 2 and 10 lbs/year:
                                                1.   Has the facility added anti-mist additive
                                                     to each process tank, or installed other
                                                     control equipment to reduce tank
                                                     emissions by at least 99%, or
                                                2.   Has the facility reduced emissions from
                                                     the emissions collection system to less
                                                     than 0.03 mg/amp-hr?
                                           C.   Facilitywide chromium emissions are greater
                                                than 10 lbs/year:
                                                1.   Has the facility added anti-mist additive
                                                     to each process tank, or installed other
                                                     control equipment to reduce tank
                                                     emissions by at least 99.8%, or
                                                2.    Has the facility reduced emissions from
                                                      the emissions collection system to less
                                                      than 0.006 mg/amp-hr?
                                           D.   Has the facility maintained records of:
                                                1.   Written Compliance Plan
                                                2.    Anti-mist additive concentrations for
                                                      each tank?
                                                3.    Daily log of ampere-hours applied to
                                                      each tank?
                                                4.    Records maintained for 2 years?




                                                                                              2-31
                                                  ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                     2                                                                                              3
Program   Agencies                                Check                           Yes   No   %         References       Status/Notes
                         3.   If the facility performs solvent degreasing                        -- SCAQMD Rule 1122
                              operations:
                              A.   Are containers and equipment free of
                                   cracks, holes, defects, or leaks?
                              B.   Is the parts degreasing process performed
                                   in a manner that minimizes solvent
                                   emissions and in accordance with SCAQMD
                                   rules?
                              C.   Is the design and maintenance of the
                                   degreasing equipment in accordance with
                                   SCAQMD rules?
                              D.   Are environmental controls properly
                                   implemented to maintain proper ventilation
                                   and minimize exposure? Are solvent use
                                   records maintained in accordance with
                                   SCAQMD rules?                                                 -- SCAQMD Rule 1171
                         4.   If the facility performs solvent cleaning
                              operations:
                              A.   Do the solvents used comply with SCAQMD
                                   Rule 1171 standards?
                              B.   Is the use of solvents by one of SCAQMD
                                   approved methods?
                              C.   Are all VOC-containing solvents properly
                                   stored and disposed of in accordance with
                                   SCAQMD Rule 1171?
                              D.   Are emission collection and control systems
                                   designed and operated in accordance with
                                   SCAQMD Rule 1171?
                              E.   Are records maintained in accordance with
                                   SCAQMD rules?




                                                                                2-32
                                                          ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST

15. Storm Water   SWRCB, RWQCB   1.   If the facility has industrial activity exposed to          -- State Water Resources
    Pollution                         storm water, has the facility submitted a Notice-              Control Board Order
    Prevention                        Of-Intent to SWRCB?                                            97-03-DWQ*
    (SWPP)                       2.   Has the facility prepared a Storm Water Pollution
                                      Prevention Plan
                                 3.   Has the facility prepared a Monitoring Program
                                      (or is the facility covered under a Group
                                      Monitoring Plan)?
                                 4.   Has the facility implemented its SWPP Plan best
                                      management practices in accordance with its
                                      implementation schedule?
                                 5.   Has the facility completed its Non-Storm Water              -- Forms are provided in
                                      Discharge Visual Observations quarterly?                       the SWRCB SWPP
                                 6.   Has the facility completed its Storm Water                     Packet*
                                      Discharge Visual Observations monthly during
                                      the wet season?
                                 7.   Has the facility completed its Storm Water
                                      Sampling twice during the wet season?
                                 8.   Has the facility completed its annual review of its
                                      SWPP? This review must be documented and
                                      submitted with the Annual Report to RWQCB.
                                 9.   Has the facility submitted its Annual Storm Water           -- Annual Report forms
                                      Report to RWQCB each year? The Annual                          are provided in the
                                      Report must be submitted to RWQCB annually by                  SWRCB SWPP Packet
                                      July 1.




                                                                                           2-33
                                                          ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST

16. Injury and Illness   OSHA   1.   Has the facility prepared an Injury and Illness           - 8 CCR §3203
    Prevention Plan                  Prevention Plan in accordance with OSHA                   - Cal/OSHA Guidance
    (SB-198)                         guidelines?                                                 Document*
                                2.   Does the company provide a method for
                                     communication of workplace hazards with its
                                     employees (e.g. committees or safety suggestion
                                     box)?
                                3.   Has the company evaluated its facility for                - EMS Form
                                     workplace hazards?
                                4.   Does the facility perform routinely scheduled             - EMS Form
                                     safety inspections of its facility?
                                5.   Has the facility prepared Codes of Safe Practice          - EMS Form
                                     for its employees and their jobs?
                                6.   Has the facility investigated all workplace injuries      - EMS Form
                                     and illnesses?
                                7.   Has the facility corrected all hazardous
                                     conditions?                                               - EMS Form
                                8.   Has the facility maintained records of hazard
                                     assessments, inspections, and employee safety
                                     training?

17. Hazard               OSHA   1.   Has the facility prepared a written Hazard                - 8 CCR §5194
    Communication                    Communication Program?                                    - Cal/OSHA Guidance
                                2.   Has the facility prepared an inventory of                   Document*
                                     hazardous chemicals used at the facility? An
                                     HMBP Hazardous Materials Inventory Statement
                                     may meet this requirement.
                                3.   Has the facility provided Materials Safety Data
                                     Sheets for its employees for the chemicals used
                                     in the Facility?
                                4.   Are all containers of hazardous chemicals
                                     properly labeled with the chemical name and
                                     hazard warnings?




                                                                                        2-34
                                                                 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                    2                                                                                                  3
     Program             Agencies                               Check                               Yes   No   %         References           Status/Notes
18. Safe Drinking                       1.   If the facility has any Prop 65 listed chemical,                      - H&SC §25249.5-.13
    Water and Toxic                          does the facility provide warnings to its
    Enforcement Act                          employees and the community? Warning signs
    (Prop 65)                                should be placed at business entrances and in
                                             work areas.

19. Energy Control    OSHA              1.   Does the facility have a written Energy Control                       - 29 CFR §1910.147
    Program                                  Program for the control of energy during
                                                                                                                   - 8 CCR §2320, 3314, and
    (Lockout/                                servicing and maintenance of machines and
                                                                                                                     6004
    Tagout)                                  equipment?
                                                                                                                   - Cal/OSHA Guidance
                                        2.   Has the facility developed Lockout/Tagout
                                                                                                                     Document*
                                             procedures for its machinery and equipment?
                                             Written procedures should be prepared for
                                             appropriate machinery and equipment.
                                                                                                                   - EMS Form
                                        3.   Does the facility have a supply of locks and tags
                                             to implement the Lockout/Tagout

20. Confined          OSHA              1.   Has the facility prepared written procedures for                      - 29 CFR §1910.146
    Spaces                                   entry into confined spaces?
                                                                                                                   - 8 CCR §5156, 5157, and
                                        2.   Has the facility marked areas or equipment that                         5158
                                             are confined spaces?
                                                                                                                   - Cal/OSHA Guidance
                                                                                                                     Document*

                                                                                                                   - EMS Form

21. Hearing           OSHA              1.   If the facility has noise levels above 85 decibels                    - 29 CFR §1910.95
    Conservation                             (TWA 4), has the facility prepared a Hearing
                                                                                                                   - 8 CCR §5095-5100
                                             Conservation Program?
                                        2.   Has the company conducted area noise sampling                         - Cal/OSHA Guidance
                                             to determine noise levels?                                              Document*
                                        3.   Has the facility conducted baseline testing of                        - EMS Form
                                             employees exposed to noise levels above 85
                                             dBA?
                                        4.   Has the facility conducted annual audiometric
                                             testing for employees exposed to noise levels
                                             higher than 85 dBA (TWA)?




                                                                                                  2-35
                                                             ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                2                                                                                                3
     Program         Agencies                               Check                              Yes   No   %         References       Status/Notes
22. Respiratory   OSHA              1.   If employees are exposed to hazardous                                - 29 CFR §1910.134
    Protection                           chemicals above their permissible exposure limit,
                                                                                                              - 8 CCR §5144
                                         has the facility prepared a written Respiratory
                                         Protection Program?                                                  - Cal/OSHA Guidance
                                                                                                                Document*
                                    2.   Has the facility conducted air sampling to
                                         determine need for respirator use?                                   - EMS Form
                                    3.   If respirators are required for employees, have                      - EMS Form
                                         the employees been fit tested for respirator use?

                                    4.   If respirators are required for employees, have
                                         the employees been instructed in the proper use
                                         and maintenance of their respirator?

                                    5.   Have employees who use a respirator completed
                                         an annual medical examination?

23. Process and   OSHA              1.   If process tanks emit gases, vapors, or mists of                     - 8 CCR §5154
    Laboratory                           hazardous chemicals above permissible
                                                                                                              - EMS Form
    Ventilation                          exposure limits, has the facility provided process
                                         tank ventilation?                                                    - 8 CCR §5154.1
                                    2.   Has the facility periodically tested and recorded                    - EMS Form
                                         process tank ventilation air velocities? A periodic
                                         testing of process tank ventilation (e.g.
                                         semiannually) should be established to confirm
                                         ventilation air velocities meet design and
                                         performance requirements.

                                    3.   If the facility has a laboratory hood, has the
                                         facility tested the face velocity of the hood to
                                         confirm compliance? A periodic testing of
                                         laboratory hoods should be established to
                                         confirm ventilation face velocities meet design
                                         and performance requirements.




                                                                                            2-36
                                                                   ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                    2                                                                                                  3
     Program             Agencies                                 Check                             Yes   No   %         References           Status/Notes
24. Chemical       OSHA                 1.   If the facility has a laboratory, has the facility                    - 8 CCR §5191
    Hygiene Plan                             prepared a written Chemical Hygiene Plan?

                                        2.   Has the facility implemented all segments of the
                                             Chemical Hygiene Plan (MSDSs, exhaust hood
                                             measurements, inspections, etc.)?

25. Personal       OSHA                 1.   Has the company assessed the hazards of each                          - 8 CCR §3203, 3380-3400
    Protective                               job for personal protection requirements?
                                                                                                                   - EMS Form
    Equipment

26. Employee       All                  1.   Has the facility completed and recorded Right-To-                     - H&SC §25500
    Training                                 Know, Hazard Communication, General Health &
                                                                                                                   - 29 CFR §1910.120
                                             Safety, and job specific training for all of its
                                             employees?                                                            - 29 CFR §1910.1200
                                        2.   Has the facility completed and recorded                               - 49 CFR §172.700
                                             Hazardous Materials Handling training for its
                                             employees that handle hazardous materials?                            - 22 CCR §66265.16

                                        3.   Has the facility completed and recorded                               - 8 CCR §3202
                                             Hazardous Materials Transportation training for                       - 8 CCR §5192
                                             its employees that are involved in hazardous
                                             materials transportation related jobs?                                - Cal/OSHA Guidance
                                                                                                                     Documents*
                                        4.   Has the facility completed and recorded
                                             Hazardous Waste Handling training for its                             - EMS Checklist
                                             employees that handle hazardous waste?
                                                                                                                   - EMS Form
                                        5.   Has the facility completed and recorded
                                             Hazardous Waste Treatment training for its
                                             employees that treat hazardous waste?

                                        6.   Has the facility completed and recorded
                                             Emergency Coordinator training for its employees
                                             that serve as emergency coordinators?

                                        7.   Has the facility completed and recorded periodic
                                             (e.g. monthly) safety training for all of its
                                             employees?




                                                                                                  2-37
                                                                  ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST


                                      2                                                                                              3
       Program             Agencies                              Check                         Yes   No   %            References                Status/Notes
27. Facility         All                  1.   Has the facility completed and recorded the                      - Local Ordinances
    Inspections                                required facility inspections?                                   - CUPA HMBP*
                                                                                                                - 22 CCR §66265.15(b)
                                                                                                                - 8 CCR §3203
                                                                                                                - State Water Resources
                                                                                                                  Control Board Order 97-
                                                                                                                  03-DWQ*
                                                                                                                - EMS Checklist
                                                                                                                - EMS Form

   Footnotes:
   2     Agency/Association Abbreviations:
            CARB       California Air Resources Board
            CUPA       Certified Unified Program Agency
            DOT        Department of Transportation
            DTSC       Department of Toxic Substances Control
            EPA        Environmental Protection Agency (USEPA and Cal/EPA)
            NMFASC Metal Finishing Association of Southern California
            NMFRC National Metal Finishing Resource Center
            OES        Office of Emergency Services (State)
            OSHA       Occupational Safety and Health Administration (Cal/OSHA and Federal OSHA)
            POTW       Public Owned Treatment Works (Local Sewer Department)
            RWQCB Regional Water Quality Control Board
            SCAQMD South Coast Air Quality Management District
            SWRCB State Water Resources Control Board
   3     References shown with an asterisk are available from MFASC. References shown in bold are the primary reference for support materials.
   4     TWA means time-weighted average.




                                                                                             2-38
Environmental Management System
EMS Forms & Checklists
                                                                                              Requires…
                 Program                                        Item                      Form       Checklist
 2.   Pollution Pr evention               P2 Audit Checklist                                            ü
 2.   Pollution Prevention                P2 Project Payback Calculation Form              ü
 3.   Emergency Response                  Posting Form: Emergency Coordinator              ü
                                          Information

 3.   Emergency Response                  Posting Form: Evacuation Map                     ü
 3.   Emergency Response                  Emergency Telephone Numbers                      ü
 3.   Emergency Response                  Emergency Equipment                              ü
 10. On-Site Hazardous Waste Treatment    Program Completion Checklist (notification,                   ü
                                          waste analysis plan, closure plan, phase I
                                          assessment, emergency response plan, facility
                                          inspections, reports, etc.)

 14. Air Pollution Control                EMS forms and checklists for the inspection      ü            ü
                                          and recordkeeping as required by SCAQMD
                                          rules

 15. Storm Water Pollution Prevention     Non-storm water visual observation               ü
 15. Storm Water Pollution Prevention     Storm water discharge visual observation         ü
 15. Storm Water Pollution Prevention     Storm water sampling and analysis                ü
 16. Injury and Illness Prevention Plan   Emergency incident investigation form            ü
 16. Injury and Illness Prevention Plan   Workplace hazard form                            ü
 16. Injury and Illness Prevention Plan   Safety meeting record form                       ü
 19. Energy Control Program               Lockout/tagout procedures form                   ü
 20. Confined Spaces                      Confined space entry permit form                 ü
 21. Hearing Conservation                 Area noise sampling form                         ü
 22. Respiratory Protection               Respirator fit test form                         ü
 23. Process and Laboratory Ventilation   Process tank ventilation measurement form        ü
 23. Process and Laboratory Ventilation   Laboratory hood ventilation measurement form     ü
 25. Personal Protective Equipment        Workplace hazard assessment form                 ü
 26. Employee Training                    Employee training record form                    ü
 27. Facility Inspections                 Facility inspection form                         ü



Environmental Management System
                                                                       2-39                          Element 2.2
Emergency Coordinators
     Contact                  Name/Address              Work Phone            Pager            Home Phone

 PRIMARY




 1ST ALTERNATE




 2ND ALTERNATE




 3RD ALTERNATE




Emergency Reporting

               In the case of a Fire or Emergency call 911 and give the following information: “My name is
               [your name]. I am calling from [company name], at [address of company], in [city or
               area]. We have an emergency (specify the type of emergency). The closest cross-street is
               [cross-street]. Someone will be waiting in front of the building to offer directions when you
               arrive. I am at this phone number: [company phone number].”




                                                    2-40
Environmental Management System
Emergency Telephone Numbers
FEDERAL/NATIONAL
                                         Agency                                  Telephone

   CHEMTREC – Chemical Transportation Emergency Center                  (800) 424-9300
   National Response Center                                             (800) 424-8802
   US EPA SARA Title III Hotline                                        (800) 535-0202
   US EPA RCRA Hotline                                                  (800) 424-9346
   US EPA – Region IX                                                   (415) 744-2000
   US Department of Transportation Hotline                              (800) 752-6367



STATE
                                                  Agency                                     Telephone

   Office of Emergency Services – OES                                               (800) 852-7550
   Department of Toxic Substances Control – Headquarters – Sacramento               (916) 445-4171
   California Highway Patrol – Hazardous Materials Section                          (916) 327-3310



COUNTY/LOCAL AREA
                                         Agency                                  Telephone

   Department of Health Services
   Air Quality Management District
   Regional Water Quality Control Board
   Department of Toxic Substances Control



CITY/LOCAL
                                         Agency                                  Telephone

    Fire Department
    Police Department
    Water Quality Control Plant (POTW)




                                                           2-41
Environmental Management System
Emergency Equipment
    Qty   Unit        Item Description          Location




                                         2-42
Environmental Management System
Non-Storm Water Visual Observation
        Requirements

    §     Visually observe all drainage areas for the presence of unauthorized non-storm water discharges.


    §     Frequency: Quarterly, during daylight hours, on days with no storm water discharges, during scheduled facility operating hours,
          conducted within 6-18 weeks of each other.


    § Locations: (1) NSW-01 – ____________________________________________

                  (2) NSW-02 – ____________________________________________

                  (3) NSW-03 – ____________________________________________

                  (4) NSW-04 – ____________________________________________

                  (5) NSW-05 – ____________________________________________


    §     Observation: Presence of any discolorations, stains, odors, floating materials, and the source of any discharge.




Observed By                                                                            Date




____________________
Title                                                                        Time


              Location              Discharge            Indications of                   Observations/Source of Discharge
                                    Observed?                 Prior
                                                          Discharge?
        NSW-01

        NSW-02

        NSW-03

        NSW-04

        NSW-05




 Comments/Corrective Actions Taken:




                 _




                                                                       2-43
  Environmental Management System
  Storm Water Discharge Visual Observation
  Requirements


    §      Visually observe all storm water discharges for the presence of pollutants.


    §      Frequency: One storm event per month during the wet season (October 1 - May 30), during the first hour of discharge, during daylight
           hours, during scheduled facility operating hours, storms that are preceded by at least three (3) working days without storm water
           discharges.


    § Locations: (1) SW-01 – Storm Drains

                   (2) SW-02 – Roof Downspouts

                   (3) SW-03 – Stormwater Culvert


    §      Observation: Presence of any floating and suspended material, oil and grease, discolorations, turbidity, odor, and the source of any
           pollutants.




  Observed By                                                                                              Date




  ____________________
  Title                                                                                                    Time




  Month                                                                                       Time Storm Started


          Location                            Describe Discharge                                 Describe Source of Discharge


SW-01
Storm Drains

SW-02
Roof Downspouts

SW-03
Stormwater Culvert




  Comments/Corrective Actions Taken:




                                                                     2-44
Environmental Management System
Emergency Incident Investigation
 DATE OF INCIDENT         TIME OF INCIDENT               REPORT COMPLETED BY

 LOCATION OF INCIDENT

 EXTENT OF EMERGENCY

 TYPE OF INCIDENT

     Fire      Fire/Explosion         Chemical Spill      Chemical Release To Air        Occupational Accident
 CAUSE OF EMERGENCY

     Storage Tank/Drum Leak             Process Release/Spill           Fire     Explosion
                                                                                                                      Other
 ____________________________________________________________________________________________
 IDENTIFICATION OF HAZARDOUS MATERIAL

  Shipping Name ______________________________________________________ UN/NA Number ________________
  Chemical                                                                                                           Name
 ______________________________________________________________________________________
  Trade                                                                                                              Name
 _________________________________________________________________________________________
  Other
 ______________________________________________________________________________________________
  Physical Description of Material:       Solid        Liquid      Gas         Radioactive        Infectious
 IF MATERIAL HAS RUN OFF-SITE, GIVE AMOUNT AND LOCATION

 ENVIRONMENT AFFECTED

     Storage Area(s)              Roadway (Public)                  Bay/Ocean                  Agriculture Land
     Facility Buildings           Unimproved Shoulder               Coastal Beach              Air Release
     Parking Areas                Entered Sewer(S)                  Lake/Stream
     Roadway (Private)            Entered Storm Drain(s)            Irrigation Water
  Threat                     to                      Environment/Wildlife                                         (explain):
 __________________________________________________________________


 _________________________________________________________________________________________________
 __
 HEALTH

     Yes     No Exposure to Employees (#______)                   Yes      No Employees Injured (#______)
     Yes     No Exposure to Public                                Yes      No Public Injured
     Yes     No Medical Attention                                 Yes      No Hospitalized




                                                           2-45
EVACUATION NECESSARY

    Yes    No       Number of staff evacuated from on-site sources: ______________
                    Number evacuated from offsite sources (if known): ____________
 Names                         of                        Staff                       Exposed/Injured:
_________________________________________________________________________
 Hospital(s)                                    Transported                                      To:
_____________________________________________________________________________
 Describe               Injuries              or                Exposure                (Symptoms):
________________________________________________________________
AGENCIES NOTIFIED

ACTIONS TAKEN TO CONTROL PROBLEM

NOTES




                                                  2-46
Environmental Management System
Workplace Hazard
  Date of Inspection                            Inspector


  Hazard Type:


         q      Hazardous Workplace                         q        Hazardous Process

         q      Hazardous Equipment                         q        Hazardous Procedure

  Description of Hazard:




  Recommended Corrective Action:




  Corrective Action Taken:




  q      Completed           ________________
                             Date                     Completed By




                                                      2-47
Environmental Management System
Safety Meeting Record
  _____________________
  Date                       Meeting Administrator


  Topics Discussed:




  Attendees:

  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature


  __________________________________
  Name                                               Signature




                                                2-48
Environmental Management System
Lockout/Tagout Procedure
 Procedure No.                                                         Date




 Machine Identification (Description, Model, Serial No., Location)




   Energy Source

   ___________________________________________________________________________




   Shutdown/Lockout Procedures




   Startup Procedures




   Affected Employees

   _____________________________________




   Authorized Employees




____________________________________



                                                                2-49
Environmental Management System
Confined Space Entry Permit
This permit authorizes entry into the described confined space when done so in accordance with the restrictions of the
Confined Space Entry procedures and the following additional criteria:
 Space to be Entered:




 Purpose of Entry:




 Date of Entry:                                                                                    Duration of Entry:




 Names of Employees Authorized to Enter the Confined Space:




 Name(s) of Safety Attendant(s):




 Name of Entry Supervisor:                                                                         Signature of Entry Supervisor:




 Hazards of the Confined Space:




 Safety Measures to be Used to Control Hazards Before and During the Confined Space Work Period:




 Acceptable Entry Conditions:




 Results of Atmospheric Testing:




 Rescue and Emergency Services Available:




 Communication Procedures to be Used by Entrants and Attendants:




 Required Personal Protective Equipment for Entrants and Attendants:




 Additional Safety Information:




 Additional Permits Required Before Entry:




                                                                                    2-50
Environmental Management System
Area Noise Sampling
   _________________________________________________
   Area                                                 Job Classification


   _________________________________________________
   Sampled By                                           Date

Area Testing

  No.                            Sample Location/Task                        dBA

  1

  2

  3

  4

  5

  6

  7

  8

  9

  10

  11

  12

  13

  14

  15

  16

  17

  18

  19

  20


Comments/Notes




                                           2-51
Environmental Management System
Respirator Fit Test
   _________________________________________________
   Employee Name                                                                Date


   _________________________________________________
   Job Title/Description

Type of Respirator:

  No.                              Make                                       Model/Size                        Full or Half-Face

   1

   2

   3

   4


Testing Protocol:

   q Isoamyl Acetate                      q Saccharin Aerosol            q Irritant fume
   Cartridge Type: ___________________________________________

Test Exercises (P=Pass, F=Fail):

                                                                                           Respirator No.
                                                                     1                 2                    3              4

 Normal Breathing

 Deep Breathing

 Nodding Head

 Read Passage

 Jogging in Place

 Normal Breathing

                                                    Overall

   ________________________________________________
   Employee Signature


   ________________________________________________
   Trainer Signature




                                                              2-52
Environmental Management System
Process Tank Ventilation
  ___________________            ____________________________________
  Date                           Measured By


                                                                    Class               Exhaust Velocity
  Tank                                         Hazardous         8 CCR 5154             (feet per minute)
   No.        Tank Description                 Substances      (Table V-7/8/9)   Required              Measured




                                               2-53
Environmental Management System
Laboratory Hood Ventilation
   ___________________________________________________________________________
   Description of Hood


                                                                                       __________
   Inspector                                                                           Date               Time


   _____________                   _______________ _
   Temperature                     Barometric Pressure         Velocity Correction


Diagram of Face of Hood Showing Sampling Areas




Air Velocity Measurements of Sampling Areas
  No.                        Velocity                    No.                Velocity                No.          Velocity

  1                                                      11                                         21

  2                                                      12                                         22

  3                                                      13                                         23

  4                                                      14                                         24

  5                                                      15                                         25

  6                                                      16                                         26

  7                                                      17                                         27

  8                                                      18                                         28

  9                                                      19                                         29

  10                                                     20                                         30

Calculation of Volume Flow Rate
                Average Velocity


                Hood Face Area


               Volume Flow Rate




                                                                 2-54
Environmental Management System
Workplace Hazard Assessment
   Area                                            Job Classification




   Assessed By                                     Date


 Hazard Description




 Hazard Category

          q Impact                    q Heat
          q Penetration               q Harmful Dust
          q Compression (Roll-Over)   q Light (Optical) Radiation
          q Chemical

 Estimate of Potential Injury




 Personal Protective Equipment

 Eye and Face:
 Head:
 Foot and Leg:
 Hand and Arm:
 Torso and Other:

 Comments/Notes:




                                         2-55
Environmental Management System
Employee Training Record
  ________________________________________________________________________
  Employee Name


  ________________________________________________________________________
  Job Title/Description


  ___________ ___________ ________________________________________________
  Training Date           Hours of Training   Instructor Name

  [Check boxes for training received]
  ALL EMPLOYEES


        q RIGHT-TO-KNOW / HAZARD COMMUNICATION
                  Hazard Communication, Container Labeling, Material Safety Data Sheets
        q GENERAL HEALTH & SAFETY
                  Emergency Procedures and Evacuation, Injury and Illness Prevention Plan, Hearing Conservation, Confined
                  Spaces, Lockout/Tagout, General Safety Rules, Codes of Safe Practice, Fire Prevention, Chemical Hygiene
        q JOB SPECIFIC TRAINING
                  Duties, Hazardous Materials, Workplace Hazards, Codes of Safe Practice, and Personal Protective
                  Equipment Related to Employee’s Specific Job Assignment
  PROCESS EMPLOYEES


        q HAZARDOUS MATERIAL HANDLING
                  Hazardous Chemicals, Personal Protective Equipment, Hazardous Materials Handling, Incompatible
                  Materials, Spill Cleanup
        q HAZARDOUS MATERIAL TRANSPORTATION
                  Hazardous Material Classification, Shipping Containers, Labeling and Marking Containers, Shipping
                  Documents, Hazardous Material Handling, Emergency Response
        q HAZARDOUS WASTE HANDLING
                  Identifying Hazardous Waste, Handling Hazardous Waste, Labeling Hazardous Waste, Shipping
                  Hazardous Waste, Hazardous Waste Minimization
        q HAZARDOUS WASTE TREATMENT
                  Operation of Treatment Facilities, Shutdown of Waste Treatment Facilities, Emergency and Monitoring
                  Equipment, Recordkeeping

        q EMERGENCY COORDINATOR TRAINING
                  Emergency Coordinator Authority and Duties
        q RESPIRATOR TRAINING
                  Respirator Selection, Use and Limitations of Respirator, Cleaning and Disinfection, Storage, Inspection
                  and Maintenance
  _______________________________________________________                                         __________________
  Employee Signature certifying receipt of training described above                               Date

  _______________________________________________________                                         __________________
  Instructor Signature                                                                            Date




                                                                2-56
Environmental Management System
Facility Inspection
   ___________________
   Date of Inspection                 Time of Inspection                  Inspector


   Circle type of inspection: DAILY WEEKLY MONTHLY ANNUAL

                                                       Frequency

 _Loading and unloading areas                     X


 Freeboard level in uncovered tanks               X

 Overfill/spill control equipment                 X

 Tank monitoring data                             X

 Hazardous materials/waste containers             X

 Aisle space                                      X

 Incompatible material storage areas              X

 Safety suggestion box                            X

 Hazardous material storage/transfer                       X
 areas

 Hazardous material tank systems                           X

 Hazardous waste treatment areas                           X

 Storm water management structures                         X

 Employer notices                                               X

 Posting of evacuation map / phone                              X
 numbers

 Material safety data sheets                                    X

 Hazardous material/waste                                       X
 containers/labels

 Emergency alarms                                               X

 Fire extinguishers                                             X

 Emergency equipment and supplies                               X

 Process area ventilation                                       X

 Housekeeping                                                   X

 Employer posters and accident forms                                  X

 Emergency Response Plan review                                       X

 Hazardous material storage tanks                                     X




                                                               2-57
FREQUENCY: D-Daily, W-Weekly, M-Monthly, A-Annual




                                                    2-58
                                                                                   ELEMENT 2.3

                                                         OBJECTIVES AND TARGETS

After you identify the facility’s environmental aspects and impacts and regulatory compliance
requirements, objectives and targets should be developed for the EMS. An objective is a facility goal
that is consistent with the company’s environmental policy, priority environmental aspects and impacts,
and applicable environmental regulations. A target is a more detailed performance requirement related
to and supporting a specific objective. In other words, specific targets must be met for an objective to
be achieved.

                                              Examples


                 Objective                                             Target
 Reduce hazardous wastewater treatment        • Reduce dragout from nickel plating baths by 25%
 sludge (F006) generation                       within 18 months
 Improve chrome emission compliance           • Continuously train 100% of chrome platers about
                                                chrome emission control procedures and
                                                recordkeeping
 Eliminate cyanide from all plating           • Pilot test three non-cyanide chemistries within 12
 operations                                     months
 Improve employee awareness of                • Hold bimonthly training courses
 environmental issues and costs               • Train 100% of employees within 12 months
 Reduce energy consumption                    • Reduce electricity use 15% within 12 months
                                              • Reduce natural gas use 10% within 12 months
 Improve compliance with wastewater           • Zero permit violations by December 1999
 discharge permit limits
 Use process water more efficiently           • Reduce water consumption by 20% within 12 months
                                              • Continuously train all platers in good rinsing
                                                techniques




                                                 2-19                                       Element 2.3
Targets should be:                          The objectives and targets represent the transition from
• Quantitative                              planning to action. Many other EMS elements, particularly
• Realistic                                 measurement and monitoring activities, will be driven by the
                                            objectives and targets. For this reason, they should be
• Linked to a source (of the
    waste or environmental aspect)          carefully expressed and energetically communicated to all
                                            facility workers. In addition, input from facility workers is
• Measureable
                                            critical in developing objectives and targets that are
                                            meaningful and practical. Reviewing the objectives and
targets at regular intervals provides a good opportunity to gauge progress, cost savings, and improved
environmental performance.

There is one EMS procedure and several EMS tools associated            Objectives and targets
with the objectives and targets element. The procedure, 2.3               originate from:
Objectives and Targets, describes the process your facility            • Environmental Policy
should follow to develop and update its environmental objectives       • Aspects and Impacts
and targets. The EMS tools that support this procedure include           Review
a matrix that facilitates and documents the process of developing      • Compliance Checklist
objectives, targets associated with those objectives, and              • Corrective and
parameters that will be measured to track progress made to meet          Preventive Action
the objective.




                                                   2-20                                      Element 2.3
                        EMS Procedure                                    2.3
                         Effective Date
    Company Name            Subject                          Objectives and Targets


Purpose     This procedure is used to develop and update the objectives and targets that are
            addressed by the EMS.

Step 1       The environmental manager and other facility personnel selected by the environmental
             manager are responsible for developing the objectives and targets for the EMS.

             Objectives are facility goals that are consistent with the company’s environmental
             policy, priority environmental aspects, and applicable environmental regulations.

             Targets are detailed performance requirements related to and supporting a specific
             objective. Targets should be quantitative, realistic, linked to the source, and
             measurable.

Step 2       Objectives and targets will be developed and documented using the Objectives and
             Targets tools: Summary of EMS Objectives and Targets and Actions Planned and
             Taken to Achieve Objectives and Targets.

Step 3       Objectives and targets will be supported and tracked according to procedures
             described in Element 4.1, Measurement and Monitoring.

Step 4       The impact of corrective and preventive actions on objectives and targets will be
             evaluated and documented monthly.

Step 5       The environmental manager and other facility personnel will review and update the
             environmental objectives and targets every      months.

Step 6       Objective and target documentation will be retained at the facility for at least 2 years.



   Responsible Person:

   Signature and Date:




                                                2-21                                       Element 2.3
 Summary of EMS Objectives and Targets

                 Objective          Target   Deadline
1.




2.




3.




4.




5.




Responsible Person


Effective Date
                             2-22             Element 2.3
 Actions Planned and Taken to Achieve Objectives and Targets
 OBJECTIVE:

 TARGET(S):


 PARAMETERS FOR TRACKING PROGRESS AND MEASUREMENT FREQUENCY:

                     Parameter                                     Measurement Frequency




 ACTIONS PLANNED AND TAKEN                                                        What type of action?
                                                                                    Source Reduction
 Consider what type of actions you are evaluating to achieve targets for            Material Substitution
 objectives. Are there pollution prevention alternatives such as source             In-Process Recycling
 reduction, material substitution, in-process recycling, or waste minimization,     Reuse
                                                                                    Improved Treatment
 that could achieve your objectives and targets? Try to find an action that
                                                                                    Waste Treatment
 addresses the pollution source most directly.                                      Compliance


 Action 1:
 Deadline:                                        Responsible Person:
 Action Taken:

 Action 2:
 Deadline:                                        Responsible Person:
 Action Taken:

 Action 3:
 Deadline:                                        Responsible Person:
 Action Taken:

 Action 4:
 Deadline:                                        Responsible Person:
 Action Taken:

Responsible Person


Effective Date
                                                    2-23                                      Element 2.3
                                                                                    ELEMENT 3.1

                                                   ROLES AND RESPONSIBILITIES

An EMS should establish roles and responsibilities for environmental management. These roles and
responsibilities must be clearly and effectively communicated to all employees. In addition, top
management should designate an employee who (1) ensures that the EMS is established and
implemented; (2) reports on the EMS’s performance over time; and (3) works with others to modify the
EMS when necessary.

The structure of a business will have a direct effect on the organization of personnel responsibilities for
the EMS. Smaller businesses, such as many metal finishing facilities, have some advantages over larger
businesses in creating an EMS team. For example, smaller businesses usually have less hierarchy, more
direct lines of communication, and faster decision-making processes. Because many metal finishing
employees often perform multiple functions, integrating environmental responsibilities with other
functions can simplify the EMS structure and minimize use of resources.

Procedure 3.1, Roles and Responsibilities, describes how to assign responsibilities and determine
organizational roles for the EMS. The procedure can be implemented, in part, through the
Responsibilities Matrix and Organizational Chart. The matrix and chart should be used to assign EMS
responsibilities and can also be used to communicate these responsibilities to other people in the
company. After EMS responsibilities have been assigned, it will be helpful to develop an organizational
chart showing responsible employees, lines of communication and reporting, and any hierarchy that may
be in place.




                                                   3-1                                       Element 3.1
                          EMS Procedure                                    3.1
                           Effective Date
         Company Name         Subject                        Roles and Responsibilities


Purpose        This procedure is used to determine the organizational roles and personnel
               responsibilities for the company’s EMS.

Step 1         The company will first designate an environmental manager whose role is to oversee
               company environmental activities. The environmental manager and other facility
               personnel selected by the environmental manager are responsible for implementing the
               EMS.

Step 2         The environmental manager will develop and          Things to consider in
               assign EMS roles and responsibilities and           developing and reviewing EMS
                                                                   roles and responsibilities:
               document them using the Responsibility
               Matrix.                                             •    Capabilities of business
                                                                   •    Personnel involved
Step 3         The environmental manager will communicate
                                                                   •    Training and resources required
               EMS roles and responsibilities to all
               employees.                                          •    Results of previous audits
                                                                   •    Improvement of current
Step 4         The environmental manager and other facility             structure
               personnel will review and update                    •    Integration with other business
               the EMS roles and responsibilities every                 functions and existing
               12 months.                                               management systems

Step 5         Roles and responsibilities documentation will be retained at the facility for at least
               2 years.




   Responsible Person:

   Signature and Date:




                                                   3-2                                        Element 3.1
                                                                                                                               RESPONSIBLITY MATRIX
                                                                                             PERSONNEL
                                           Fill in names and “L” (lead) or “S” (supporting) responsibilities to EMS team members using the possible positions listed
                                          Shop      Environmenta      Plating     Productio     Laboratory                                     All
         RESPONSIBILITY                  Owner       l Manager       Manager          n           Staff         Maintenance Accounting Employees             Other
                                                                                  Superviso
                                                                                      r
Develop and distribute environmental
policy
Develop budget for environmental
management
Identify and prioritize environmental
aspects
Obtain and renew permits and develop
compliance plans
Comply with applicable regulatory
requirements
Track/analyze new regulations

Establish environmental objectives and
targets
Develop EMS structure and identify
personnel responsible
Implement internal communication

Coordinate external communication

Train employees

Integrate environmental metrics into
performance appraisal process
Coordinate emergency response efforts

Track corrective and preventive action
efforts
Coordinate auditing efforts




   Responsible Person
                                                                                                                                                     Element 3.1
   Effective Date
Conduct management review




  Responsible Person
                            Element 3.1
  Effective Date
                     (COMPANY NAME) EMS ORGANIZATION




   Example Organizations




Responsible Person
                                                       Element 3.1
Effective Date
                                                                                  ELEMENT 3.2

                                                                     COMMUNICATIONS

Communication is an important feature of a successful EMS. Active communication can increase the
effectiveness of the EMS by (1) explaining environmental policy and how it relates to the overall
business strategy; (2) motivating employees; (3) making sure roles and expectations are understood by
all employees; (4) demonstrating management commitment; and (5) identifying potential system
improvements.

Both internal and external communications should be performed to ensure that environmental goals are
met. Internal communication should explain the environmental policy and address the EMS roles and
responsibilities delegated to employees as well as progress toward specific objectives and targets. This
communication should possess mechanisms for top-down and bottom-up information flow.

External communication is also an important element of the EMS. Communication with community
groups and stakeholders in the business, such as regulators, local residents, stockholders, insurers,
emergency responders, and customers interested in the environmental impacts of the business should be
addressed and documented. By maintaining meaningful dialogue and a proactive approach with external
parties, a company can more easily meet EMS and other business goals.

Procedure 3.2a, Internal Communication, describes how and when to initiate and document internal
communication. The procedure can be implemented, in part, through the Internal Communications
form. Procedure 3.2b, External Communication, describes how and when to initiate and document
external communication. The procedure is implemented, in part, through the External Communications
form. Both Internal and External Emergency Communications can be implemented through the
Emergency Responses Communications form.




                                                 3.2-1                                   Element 3.2
                         EMS Procedure                                  3.2a
                          Effective Date
         Company Name        Subject                        Internal Communication


Purpose        This procedure is used to ensure adequate internal communication about the EMS.

Step 1         Identification of internal audiences should be performed. Internal audiences will include
               employees and other stakeholders of the business who play a role in everyday business
               operations. This may include contractors.

Step 2         The environmental manager will determine the         Methods of Internal
               type of information that needs to be                 Communication:
               communicated. This may be general EMS policy
                                                                    •   Staff/employee meetings
               information, individual EMS responsibilities, or
                                                                    •   Newsletters
               specific waste reduction targets and
               measurements.                                        •   Bulletin boards/posters
                                                                    •   Brown bag lunches
Step 3         Based on the audience involved and type of           • Training
               information to be communicated, the
               environmental manager will determine methods of internal communication. Initial forms
               of internal communication may include training, followed by meetings and postings in
               newsletters or bulletin boards.

Step 4         The environmental manager will determine the frequency of internal communication.
               Since the types of information being communicated will vary, the frequency with which
               the information will be communicated will also vary.

Step 5         The environmental manager and other facility personnel designated by the environmental
               manager will ensure that adequate internal communication is occurring.

Step 6         Documentation of internal communications will be achieved using the Internal
               Communications and the Emergency Response Communications forms. All internal
               communication documentation will be retained at the facility for at least 2 years.




   Responsible Person:

   Signature and Date:




                                                                                           Element 3.2
                        EMS Procedure                                 3.2b
                          Effective Date
         Company Name        Subject                      External Communication


Purpose        This procedure is used to ensure adequate external communication.

Step 1         The environmental manager will identify external audiences. External audiences may
               include community members, customers, suppliers,
               and stakeholders in the company, such as neighbors, Methods of External
                                                                      Communication:
               community groups, local officials, insurers,
               stockholders, regulatory agencies, and emergency       • Open houses
               responders.                                            • Focus groups
                                                                      •   Press releases
Step 2         The environmental manager will determine the type of   •   Annual reports
               information that needs to be communicated. This may    •   Advertising
               be company waste reduction successes, permit
                                                                      •   Community meetings
               applications for new processes, or future plans to
                                                                      •   Permits/applications
               change business practices.

Step 3         Based on the audience and the type of information to be communicated, the
               environmental manager will determine methods of external communication.

Step 4         The environmental manager will determine the frequency of external communication.
               The types of information and the frequency with which the information will be
               communicated will vary.

Step 5         The environmental manager and other facility personnel designated by the environmental
               manager will ensure that adequate external communication is occurring.

Step 6         External communications will be documented using the External Communications and
               the Emergency Response Communications forms. All external communication
               documentation will be retained at the facility for at least 2 years.




   Responsible Person:

   Signature and Date:




                                                                                        Element 3.2
                                                                                          INTERNAL COMMUNICATIONS
                                                                                          Form of Communication
                                           Frequency of                          Staff    Individual     Bulletin
          Type of Information             Communication   Audience   Training   Meeting    Meeting        Board     Newsletter     Other

Company Environmental Policy

Identification of Environmental Aspects

Prioritization of Environmental Aspects

Compliance Awareness

Targets and Objectives

Individual EMS Responsibilities

Process Change

Emergency Response and Preparedness

Measurement and Monitoring

Corrective and Preventive Action

Results of Audits and Management
Review

Other




        Responsible Person
                                                                                                                          Element 3.2
        Effective Date
                                                                                          EXTERNAL COMMUNICATIONS


                                                                                             Form of Communication
                                    Frequency of              Community   Individual                              Annual   Trade
        Type of Information        Communication   Audience    Meeting     Meeting     Newsletter   Advertising   Report   Group     Other

Company Environmental Policy

Targets and Objectives for Waste
Reduction

Waste Reduction Successes

Health and Safety Successes

Preventive Actions

Results of Audits and Management
Review

Future Company Changes

Permit Applications

Other




        Responsible Person
                                                                                                                           Element 3.2
        Effective Date
                                                                      EMERGENCY RESPONSE COMMUNICATIONS

                                                                               Audience
                                Emergency                                                    Regulatory
        Type of Emergency       Responders          Employees            Community           Agencies      Other
Chemical Release/Spill       Fire Department     Notify by Sounding   Notify Neighbors    Coast Guard
                             National Response   Alarm                                    POTW
                             Center              Telling to Vacate                        EPA
                                                 the Building
                                                                                          DTSC
Worker Injury                911                                                          OSHA
                             Fire Department
                             Ambulance
                             Hospital


Natural Disaster             911
                             Fire Department
                             Ambulance
                             Hospital
Other




        Responsible Person
                                                                                                          Element 3.2
        Effective Date
                                                                                 ELEMENT 3.3

                                                                                     TRAINING

Training is an important aspect of the EMS because it can be used to communicate to all employees (1)
                                             the environmental impacts of their activities, (2) the
Training Hints:                              company’s environmental policy, (3) EMS roles and
                                             responsibilities, and procedures, and (4) methods and
• Use opportunities like safety
                                             actions for reducing waste generation and meeting EMS
    meetings, staff meetings, and
    production meetings to provide           objectives and targets.
    “training” and reinforce
    EMS goals.                               Because every employee plays an integral role in the
•   Consider videotaping                     function of a business, it is important that the training
    training sessions for use later as       needs of all employees be evaluated and met at a level
    refreshers or with new employees.        that enables them to support the goals of the EMS in their
•   Factor training needs and abilities      daily activities. Training should be based on the previous
    into hiring practices.                   education, training, and work experience of an employee.




                                                3.3-1                                    Element 3.3
                         EMS Procedure                                     3.3
                          Effective Date
         Company Name         Subject                                 Training


Purpose        This procedure is used to develop and implement a training program that (1) complies
               with environmental regulations requiring training and (2) addresses high-priority
               environmental aspects and objectives and targets.


Step 1         A training program will be developed. This program will identify training topics, who
               should receive the training, when training should be given, and the training method. The
               program will also distinguish between training
               conducted to comply with environmental regulations        Training Resources:
               and other training.                                       • Internal trainers
                                                                           •     Consultants
Step 2         A critical first step in developing a training program is
                                                                           •     Educational institutions
               to assess employee training needs. The environmental
                                                                           •     Suppliers/vendors
               manager and others will review past training and the
               nature of the employee’s work. Based on this review,        •     Technical/trade associations
               specific training requirements for each employee or         •     Self study
               type of employee will be documented.                        •     Computer-based training

Step 3         The training program will be
               implemented and training dates, subjects,
               and attendees                                  When Training is Needed:
               will be documented.                           • New hire
                                                             •   New job/change in employees role or
Step 4         Training documentation will be retained           responsibility
               at the facility for at least 2 years.         •   Procedure change
                                                             •   New process, material, or equipment
Step 5         Training effectiveness will be evaluated
               to ensure that the EMS is being               •   New regulation
               implemented effectively. Improvements         •   Increase employee performance
               to trainings will be made accordingly.



   Responsible Person:

   Signature and Date:




                                                                                               Element 3.3
TRAINING NEEDS


Employee Name:

Job Function(s):

Date:

Training Completed:




Training Required:




                      Element 3.3
                                                                                      TRAINING PROGRAM
                                                                                        YEAR __________

                                                                     JOB FUNCTIONS
                                                                    Waste              Shift/Line
              Topic Title                 Platers   Maintenance   Treatment     Lab   Supervisors   Management
EMS Awareness
Supervisor EHS Training
Hazardous Waste Management
Wastewater Treatment
Spill Prevention & Response
Chemical Handling
Emergency Response
Dragout Reduction
Hazard Communication
Personal Protective Equipment
Fire Safety
Electrical Safety
Hearing Conservation
Job-Specific Training (List)

   Enter dates or frequency of each training.


  Responsible Person
                                                                                                    Element 3.3
  Effective Date
                                                                                   ELEMENT 3.4

                                                         EMS DOCUMENT CONTROL

The purpose of EMS document control is to ensure that the facility creates and maintains documents in
a manner and to the extent necessary to implement the EMS. The primary focus of the organization
should be effective EMS implementation, not a large documentation control system. There are several
types of documents that are integral to the EMS, including the environmental policy and various written
procedures, records, and forms used to implement the EMS. Document control ensures that EMS
documents can be easily located, periodically reviewed and updated as needed, and removed
when obsolete.

Controlled documents should be centrally located at your facility, usually with the environmental
manager. In addition, controlled documents should feature the following characteristics:

        •   Effective date

        •   Approval signature and date

        •   Copy number (if more than one controlled copy is required)

Document control should be the responsibility of one person – usually the environmental manager.
Procedure 3.4 describes how EMS documents should be controlled.




                                                 3.4-1                                      Element 3.4
                          EMS Procedure                                   3.4
                           Effective Date
         Company Name         Subject                        EMS Document Control


Purpose        This procedure governs EMS document control.

Step 1         The environmental manager is responsible for EMS document control. EMS
               documents that are addressed by this document control procedure may include the
               following:

               3 The environmental policy
               3 All EMS procedures (including this one)
               3 The following completed EMS Template forms used to implement EMS
                 procedures:
                   •    Environmental aspects tables
                   •    Compliance self-assessment checklist
                   •    Compliance calendar
                   •    Objectives and targets matrix
                   •    Organizational chart
                   •    Training needs
                   •    Emergency, internal, and external communication

Step 2         The controlled EMS documents listed in Step 1 will be designated by headers and/or
               footers with the following:
                   •    Effective date
                   •    Approval signature and date

Step 3         The controlled EMS documents listed in Step 1 will be maintained in a binder or file
               under the safekeeping and control of the facility environmental manager.

Step 4         The collection of controlled EMS documents will contain an index of all documents and
               a distribution list that identifies other facility personnel who should receive copies of
               EMS documents.

Step 5         The index of controlled EMS documents will be updated whenever one of the
               documents is revised.




                                                                                           Element 3.4
Responsible Person:

Signature and Date:




                      Element 3.4
                                                                                       ELEMENT 3.5

                          EMERGENCY RESPONSE AND PREPAREDNESS

Most metal finishing facilities have experienced an event that required some kind of emergency
response. Unfortunate events such as an employee injury, a spill of hazardous chemicals, or a fire do
occasionally occur. With the large number of hazardous chemicals and the potential for accidents
inherent in a manufacturing setting, metal finishing facilities should be particularly vigilant in planning and
preparing for emergencies. Emergency planning can limit injuries; protect employees, neighbors and the
environment; reduce asset losses; and minimize downtime.

An effective emergency response and preparedness program should include provisions for:

        •   Assessing the potential for accidents and emergencies

        •   Preventing incidents and their associated environmental impacts

        •   Responding to incidents, and

        •   Mitigating impacts associated with these incidents

Procedure 3.5, Emergency Response and Preparedness, describes the personnel responsible for
completing emergency preparations and incident reviews, and how and when the tasks will be
completed. There are many overlapping requirements in local, state and federal regulations concerning
emergency response and preparedness.
                                                                     Helpful Documents:
Often, the most difficult part of developing emergency          • Process flow diagrams
preparedness and response plans is identifying the potential
                                                                • Plant maps
for accidents and emergencies. The environmental manager
should form a team composed                                     • Drainage plans
of company personnel (and outside consultants or regulators if • Design codes and standards
necessary or beneficial) to examine all facility activities.
Extend your evaluation beyond those facility materials and operations that are obviously or inherently
dangerous; ask “what if” questions under both normal and abnormal conditions.

No tool is provided for this element because the tools and forms associated with emergency response
and preparedness are already included as part of the documents required by federal, state, and local
regulations.




                                                    3.5-1                                        Element 3.5
                        EMS Procedure                                 3.5
                         Effective Date
         Company Name       Subject              Emergency Response and Preparedness


Purpose        This procedure is used to anticipate, document, prepare, and review emergency events
               and preparedness plans.

Step 1         The environmental manager and other facility personnel selected by the environmental
               manager are responsible for identifying dangers, taking proactive steps to prevent
               emergency incidents, and completing tasks in preparation for emergencies.

Step 2         The environmental manager will prepare and update an Emergency Response Plan that
               contains all emergency procedures required by local, state and federal regulatory
               agencies.

Step 3         The environmental manager will familiarize and train employees and emergency
               coordinators on the procedures described in the Emergency Response Plan.

Step 4         For each emergency incident, the environmental manager, emergency coordinators and
               the involved employees will determine the cause of the emergency, evaluate the
               response to the incident, and identify actions to be taken to minimize its recurrence.

Step 4         At least twice per year, the environmental manager and other facility personnel will
               review the Emergency Response Plan and any emergency incidents that occurred since
               the last review.

Step 5         Documentation concerning emergency response and preparedness and emergency
               incidents will be retained at the facility for at least 5 years.




   Responsible Person:

   Signature and Date:




                                                                                         Element 3.5
                                                                                   ELEMENT 4.1

                                           MEASUREMENT AND MONITORING

Basing decisions and operational improvements on quantified environmental performance data is an
important part of the EMS approach and a central feature of both quality management programs and
EMSs. If the primary goal of an EMS is to improve environmental performance through consistent
compliance and waste reduction, there must be measurable parameters, or metrics, that reflect
environmental performance trends.

After objectives and targets are created, specific parameters must be identified and measured to track
progress toward the objective and target. For example, if CN-bearing wastewater is a high-priority
environmental aspect and CN-bearing wastewater reduction is an objective, with a target of 10 percent
reduction in the next 12 months, then parameters must be identified and periodically measured to
determine if the target is reached. In this example, typical parameters that could be included in a
measurement and monitoring program are volume and concentration of CN-containing rinse water and
dragout volume from CN-containing process baths.

There are also several important facility-wide metrics that should be used to monitor environmental
performance. An Excel spreadsheet is included as a tool to record and chart facility metrics.
Suggestions for target-specific metrics and a procedure for measuring dragout are also discussed.

Target-Specific Metrics

Target-specific metrics are unique to your facility’s objectives and targets. Examples of metrics that
relate to common objectives and targets are listed below.

        •   Copper concentration (measured using conductivity) in final rinse after acid copper plating

        •   Percentage of rejected parts requiring stripping

        •   Duration of storage before disposal of waste sludge

        •   Weekly volume of chrome dragout recovered and returned to plating bath

        •   Concentration of cyanide in wastewater as a percentage of allowable limit

        •   Percentage of measurements of chrome tank surface tension below allowable limit

Dragout is the primary source of waste in metal finishing, and dragout from particular tanks is often
linked to specific objectives and targets. Because of its importance for understanding process efficiency
and its impact on operating costs, metal finishers should measure dragout.

                                                  4.1-1                                     Element 4.1
Facility Metrics

Eight facility metrics that provide at-a-glance information about environmental performance are identified
in the table below.

        Metric                                                 Description
Rejects/rework rate     Process rejects and associated rework generate up to three times the waste of an
                        acceptable part because waste is generated (1) the first time the parts are processed
                        (through dragout losses), (2) when the parts are stripped, and (3) the second time the
                        parts are processed. Rejects also affect quality and customer satisfaction.
Water use               Water is an important natural resource used by metal finishing operations, and its use is
                        directly related to wastewater generation. Water use objectives are common to many
                        EMSs. The Strategic Goals Program established a water reduction goal of 50 percent from
                        a baseline year (typically 1992).
Wastewater discharge    Wastewater is usually the largest environmental release from a metal finishing facility.
quality                 Treated wastewater quality (measured by contaminant concentrations) is regulated by
                        discharge permits; therefore, measurement and monitoring of contaminant concentration
                        is important for both compliance and pollution prevention.
Treatment residuals     Wastewater treatment residuals include sludge from conventional chemical precipitation
                        treatment systems and saturated resin canisters from ion exchange treatment systems.
                        These waste streams contain most process chemicals lost through dragout and are
                        therefore important metrics to track the impact of dragout reduction techniques.
                        Treatment residuals are also expensive to manage and dispose of and present potential
                        long-term liability concerns.
Chemical use rate       Process chemicals used in metal finishing baths are lost or “wasted” through dragout to
                        rinse water that must be treated and discharged. If dragout is reduced, fewer chemical
                        additions are required. This metric tracks process efficiency and waste generation from
                        the perspective of raw material use; the monthly or weekly quantity and cost of the top
                        five to ten process chemicals added to process baths are recorded and charted.
Bath dumps              In addition to dragout, periodic bath dumps are the other main source of metal finishing
                        wastes. Spent baths usually require batch treatment or are bled into the on-site
                        wastewater treatment system — both treatment methods generate a sludge requiring off-
                        site disposal. In addition, extending bath life will reduce chemical purchases.
Energy use              Energy (electricity, natural gas, or other power source) is a primary resource used by metal
                        finishers. Energy use is important to track the effects of efficiency initiatives.
Production              A measure of production is needed to determine whether trends in other metrics are a
                        result of changes in production. For example, it is important to know that reductions in
                        water or chemical use or sludge generation are caused by process changes, not
                        production declines. Examples of production metrics are number of parts plated, revenue,
                        number of racks processed, amp-hours.




                                                    4.1-2                                           Element 4.1
                          EMS Procedure                                    4.1
                           Effective Date
         Company Name         Subject                      Measurement and Monitoring


Purpose        This procedure is used to implement a measurement and monitoring program designed
               to support the EMS and specific EMS objectives and targets.

Step 1         The environmental manager and key facility production staff will track the following
               facility metrics by collecting and charting data relevant to the metric at the frequency
               indicated below.

                        Facility Metric                   Data Collection Frequency
            Rejects/Rework Rate
            Water Use
            Wastewater Discharge Quality
            Treatment Residuals
            Chemical Use Rate
            Bath Dumps
            Energy Use
            Production


Step 2         The environmental manager and key production staff will identify and measure unique
               parameters for each EMS objective and target.

Step 3         The environmental manager or designee will measure, monitor, and record target-
               specific parameters at a predetermined frequency.

Step 4         The environmental manager and key facility staff will review facility and target-specific
               measurement and monitoring data every 3 months to identify trends, evaluate progress
               toward meeting EMS objectives and targets, and discuss overall environmental
               performance.




   Responsible Person:

   Signature and Date:


                                                                                             Element 4.1
                                                                                 ELEMENT 4.2

           EMS NONCONFORMANCE AND CORRECTIVE ACTION

EMS audits, self-inspections, and day-to-day EMS procedure implementation will occasionally reveal
deficiencies in the EMS or activities that do not conform to the EMS. When nonconformance is
identified, corrective action must be taken to address and rectify the causes of the nonconformance and
improve the EMS. Examples of EMS nonconformance are described below.

Example 1: EMS procedures are not executed                    Why do EMS problems occur?
correctly or are not periodically reviewed by the
person responsible for the procedure.                         •   Poor communication
                                                              •   Faulty or missing procedures
Example 2: Employees are unaware of their EMS-related         •   Equipment malfunction (or lack
                                                                  of maintenance)
responsibilities.
                                                              •   Lack of training
                                                              •   Lack of understanding
Example 3: Facility-wide and target-specific data are not
evaluated and corrected.                                      •   Failure to enforce procedures


Procedure 4.2, EMS Nonconformance and Corrective Action, describes how and when corrective
action will be taken. The procedure is implemented, in part, through the EMS Noncoformance
Corrective Action form. This form should be used to document corrective actions. Specifically, the
form enables you to describe the “problem” (the EMS nonconformance), the most likely causes of the
problem, possible solutions, implemented solution (corrective actions), and results.




                                                    4.2-1                                 Element 4.2
                         EMS Procedure                                   4.2
                           Effective Date
          Company Name        Subject              EMS Nonconformance Corrective Action


Purpose        This procedure is used to respond to EMS deficiencies and EMS nonconformance.

Step 1         Corrective action that responds to nonconformance is initiated using the attached EMS
               Nonconformance Corrective Action form. Corrective action may be initiated by a
               variety of events including internal audits, management reviews, employee suggestions,
               and routine EMS procedures. The form describes the EMS nonconformance or
               deficiency, identifies the root cause(s) of the problem, describes the implemented
               solution, and summarizes the resolution of the corrective action.

Step 2         The EMS Nonconformance Corrective Action form will be signed by the environmental
               manager or designee.

Step 3         The responsible person must report the status of corrective actions to the environmental
               manager at least every 2 weeks.

Step 4         Completed corrective action forms will be retained on site for at least 2 years after
               completion of the corrective action.




   Responsible Person:

   Signature and Date:




                                                                                            Element 4.2
                 EMS NONCONFORMANCE CORRECTIVE ACTION FORM


 Problem Identified:                                  Resolution Due Date:
 Problem Identified By:



Problem (describe existing or anticipated problem):



Most Likely Cause(s):

Due Date:
Completed:



Possible Solution(s):

Due Date:
Completed:



Implemented Solution(s):

Due Date:
Completed:


Resolution (confirm effectiveness of implemented solutions):




Responsible Person                                                           Element 4.2

Effective Date
                                                                                    ELEMENT 4.3

                                     CORRECTIVE AND PREVENTIVE ACTION
                                                      FOR COMPLIANCE

Regulatory compliance audits, self-inspections, and measurement and monitoring activities will
occasionally reveal (1) instances of noncompliance with regulations, or (2) situations that are contrary to
targets and objectives. When such situations occur, corrective action must be taken to address and
rectify the causes of the noncompliance or realign actions to meet specific objectives and targets.

Preventive actions should be taken when process measurement and monitoring indicate critical
processes are not operating "in control." For example, if wastewater discharge monitoring shows a
steady increase in metals concentration that approach the discharge limit, preventive action should be
taken to ensure that the wastewater treatment system is operating correctly. In this way, the
measurement and monitoring program and preventive action are directly linked. Similarly,
measurements taken to evaluate progress toward various pollution prevention targets (for example,
dragout source reduction) may suggest preventive actions to ensure continued progress.

Procedure 4.3, Corrective and Preventive Action for Compliance, describes how and when actions
will be taken. The procedure is implemented, in part, through the Corrective and Preventive Action
form. This form should be used to document corrective and preventive actions. Specifically, the form
enables you to describe the "problem" (the noncompliance event or situations inconsistent with meeting
specific targets), the most likely causes of the problem, possible solutions, implemented solution
(corrective actions), and results.




                                                  4.3-1                                      Element 4.3
                          EMS Procedure                                  4.3
                              Effective
          Company Name        Subject                  Corrective and Preventive Action
                                                                for Compliance


Purpose       This procedure is used to respond to deficiencies and noncompliance with environmental
              regulations.

Step 1        Preventive action or corrective action that anticipates or responds to noncompliance is
              initiated using the attached Corrective and Preventive Action for Compliance form.
              Corrective or preventive action may be initiated by a variety of events including internal
              audits, management reviews, employee suggestions, and routine EMS procedures. The
              form can be used to document the problem, identify the root cause(s) of the problem,
              describe the implemented solution, and summarize the resolution of the corrective action.

Step 2        The Corrective and Preventive Action for Compliance form will be signed by the
              environmental manager or designee and the person responsible for the actions taken.

Step 3        The responsible person must report the status of corrective actions to the environmental
              manager at least every 2 weeks.

Step 4        Completed Corrective and Preventive Action forms will be retained on site for at least 2
              years after completion of the corrective or preventive action.




     Responsible Person:

     Signature and Date:




                                                                                          Element 4.3
         CORRECTIVE AND PREVENTIVE ACTION FOR COMPLIANCE FORM

Noncompliance or Potential Noncompliance
 Problem Identified:                                  Resolution Due Date:
 Problem Identified By:


Problem (describe existing or anticipated problem):



Most Likely Cause(s):

Due Date:
Completed:



Possible Solution(s):

Due Date:
Completed:



Implemented Solution(s):

Due Date:
Completed:



Resolution (confirm effectiveness of implemented solutions):




     Responsible Person:

     Signature and Date:




                                                                             Element 4.3
**EXAMPLE** CORRECTIVE AND PREVENTIVE ACTION FOR COMPLIANCE FORM

Noncompliance or Potential Noncompliance
 Problem Identified: March 14, 1999                 Estim. Resolution Due Date: March 21, 1999
 Problem Identified By: Jim Filtercake, Wastewater Operator



Problem (describe existing or anticipated problem) Requires Corrective Action:

First quarter, 1999 wastewater sample collected and analyzed by POTW exceeds total cyanide limit: 5.5
mg/L versus limit of 5.0 mg/L. The sample was collected just from the outlet of the cyanide destruct
treatment tank.


Most Likely Cause(s):

Due Date: March 15        Employee on copper cyanide plating line dumped cyanide-containing stripper
                          into wastewater. New employee not aware of treatment/disposal process for
Completed: March 15
                          stripper.

Possible Solution(s):


Due Date: March 15        Add instructions for stripper treatment/disposal to new employee training
                          manual and train all employees.
Completed: March 16


Implemented Solution(s):

Due Date: March 17        (1) Retrained all platers on treatment/disposal of strippers.
Completed: March 17       (2) Platers drafted new section in employee training manual.


Resolution (confirm effectiveness of implemented solutions): Existing employees have been trained
and new employees will be trained on stripper treatment/disposal using new section in manual. Reduced
stripper use (and resulting dump for treatment) by 35%.

     Responsible Person:       Jim Filtercake

     Signature and Date:




                                                                                          Element 4.3
                                                                                     ELEMENT 4.4

                                                                                          RECORDS

Records management should enable you to prove that your company is actually implementing the EMS
as designed. Records management is often viewed as bureaucratic, but it is hard to imagine a process
or system operating consistently without keeping accurate records. Good records will primarily benefit
company employees while they develop, implement, review, and revise the EMS. Occasionally it may
be necessary to prove the effectiveness of the EMS to people outside the company including customers,
the public, or a “registrar” that has been asked to certify the EMS as conformant to an environmental
standard such as ISO 14000/14001.

Basic records management is straightforward – Procedure 4.4, Records, describes what records you
should keep, how they are kept and for how long, and how to dispose of records that are no longer
needed. If your organization has an ISO 9000 management system, you should have a system for
managing quality records.


 Tips for Implementing a Manageable and Complete Records System:
      Ø    Focus on records that add value – avoid bureaucracy. If records have no value, do not keep
           them. Make the records that you do keep accurate and complete. Consider their value in ISO
           14000 certification.
      Ø    Consider combining your records management systems for environmental and health and
           safety (as has been done in other parts of this EMS Template).
      Ø    Use a computer to maintain records and documents; make records available to employees
           via a designated computer or via a company network.
      Ø    Consider the need for security. Should access to some records be limited? Should duplicates
           of some records be maintained elsewhere?
 Establish a records retention policy considering relevant regulatory requirements and stick with it.




                                                   4.4-1                                      Element 4.4
                         EMS Procedure                                   4.4
                           Effective Date
         Company Name         Subject                                 Records


Purpose        This procedure is used to maintain EMS records.

Step 1         The environmental manager and other facility personnel selected by the environmental
               manager are responsible for identifying records that are maintained by the company as
               part of the EMS.

Step 2         The environmental manager and other facility personnel will maintain all records in a
               single location.

Step 3         The environmental manager and other facility personnel will maintain a document index
               of all records that are maintained as part of the EMS, the data and person responsible
               for the last revision, and the length of retention for each type of record.

Step 4         The environmental manager and other facility personnel will identify and note on the
               document index any restrictions on records necessary for security.

Step 5         The environmental manager and other facility personnel will review the records and
               purge obsolete records at least every 3 months.




   Responsible Person:

   Signature and Date:




                                                                                           Element 4.4
                                                                                   ELEMENT 4.5

                                                                                           AUDITS

After your organization has established its EMS, verifying the implementation of the system will be
critical. To identify and resolve EMS deficiencies you must actively seek them out.

In a small organization, audits are particularly relevant since managers are often so close to the work
that they may not see problems or bad habits that have developed. Periodic EMS audits will establish
whether or not all requirements of the EMS are being carried out in the appropriate manner.

For your EMS audit program to be effective, you should:
                                                               Audit procedure should describe:
        •   Develop audit procedures and protocols             • Audit scope
                                                                 (areas and activities covered)
        •   Establish an appropriate audit frequency
                                                               • Audit frequency
        •   Train your auditors                                • Audit methods
                                                               • Key responsibilities
        •   Maintain audit records
                                                               • Reporting mechanisms
To get started, consider the following questions:

•   How frequently do we need to audit?

        As a rule of thumb, all parts of the EMS should be audited at least annually. You can audit the
        entire EMS at one time or break it down into discrete elements for more frequent audits.
        (There may be advantages to more frequent audits, but the decision is up to you.)

•   Who will perform the audits?

        You will need trained EMS auditors. Auditor training should be both initial and ongoing.
        Commercial EMS auditor training is available, but it might be more cost-effective to link up with
        businesses and other organizations in your area (perhaps through a trade association) to sponsor
        an auditor training course. A local community college may also provide auditor training.

        EMS auditors should be trained in auditing techniques and management system concepts. In
        addition, knowledge of environmental regulations, facility operations, and environmental science
        is desirable, and in some cases may be essential to adequately assess the EMS. Some auditor
        training can be obtained on the job. Your organization's first few EMS audits can be
        considered part of your auditor training program (but make sure that an experienced auditor
        takes part in those "training" audits).


                                                    4.5-1                                  Element 4.5
         If your company is registered under ISO 9000, consider using your internal ISO 9000 auditors
         as EMS auditors. Although some additional training might be needed, many of the required
         skills are the same for both types of audits.

•   How should management use audit results?

         Management can use EMS audit results to identify trends or patterns in EMS deficiencies. The
         organization must also make sure that any identified system gaps or deficiencies are corrected in
         a timely fashion, and that the corrective actions are documented.

Hints:

•   Your EMS audits should focus on objective evidence of                   Sources of Evidence
    conformance (if you cannot tell whether or not a particular        • Interviews
    procedure has been followed, then you should consider              • Document review
    revising the procedure). During the actual audit, auditors         • Observation of work practices
    should resist the temptation to evaluate why a procedure was
    not followed that step comes later.

•   During the course of the audit, auditors should discuss identified deficiencies with the people who
    work in the area; this will help the auditors verify and validate their evaluations.

•   If possible, train at least two people as internal auditors. This allows your auditors to work as a
    team. It also allows audits to take place when one auditor has a schedule conflict (which is
    unavoidable in a small organization!).

•   Before you start an audit, be sure to communicate the
                                                                    Some Options for Auditing
    audit scope, schedule, and other pertinent information
                                                                 • Barter for audit services with other
    with the people in the affected area. This will help avoid
                                                                   small companies
    confusion and will facilitate the audit process.
                                                                 • Use external auditors
•   Consider linking your EMS audit program to your              • Have office personnel audit
    regulatory compliance audit process. But keep in mind          production areas (and vice-versa)
    that these audit programs have different purposes, and
    while you might want to communicate the results of
    EMS audits widely within your organization, the results of compliance audits might need to be
    communicated in a more limited fashion (in order to maintain attorney-client or attorney work
    product privilege, for example).




                                                  4.5-2                                      Element 4.5
                          EMS Procedure                                   4.5

                           Effective Date
          Company Name         Subject                                Self Audits


Purpose         This procedure is used to define the process for scheduling, conducting, and reporting
                periodic, internal audits of the EMS. Internal audits help to ensure the proper
                implementation and maintenance of the EMS by verifying that activities conform with
                documented procedures and that corrective actions are undertaken and are effective.

Step 1          One or more auditors will be selected to form the audit team. If the team consists of
                more than one auditor, a Lead Auditor will be designated. The Lead Auditor will be
                responsible for audit team orientation, coordinating the audit process, and coordinating
                preparation of the audit report.

Step 2          The Lead Auditor will ensure that the team is adequately prepared to initiate the audit.
                Pertinent policies, procedures, standards, regulatory requirements and prior audit
                reports will be made available for review by the audit team. Each auditor will have
                appropriate audit training.

Step 3          The Lead Auditor is responsible for ensuring the preparation of a written plan for the
                audit. The Internal EMS Audit Checklist may be used as a guide for this plan.

Step 4          The plant areas and people to be audited will be notified a reasonable time prior to the
                audit.

Step 5          Conducting the Audit

                1. A preaudit conference will be held with appropriate personnel to review the scope,
                   plan and schedule for the audit.
                2. Auditors are at liberty to modify the audit scope and plan if conditions warrant.
                3. Objective evidence will be examined to verify conformance to EMS requirements,
                   including operating procedures. All audit findings must be documented.
                4. Specific attention will be given to corrective actions for audit findings from previous
                   audits.
                5. A postaudit conference will be held to present audit findings, clarify any
                   misunderstandings, and summarize the audit results.
Step 6.         The Lead Auditor will prepare the audit report, which summarizes the audit scope,
                identifies the audit team, describes sources of evidence used, and summarizes the audit
                results.

                Findings requiring corrective action will be entered into the corrective action database.

                                                                                             Element 4.5
Step 7.      The Environmental Manager is responsible for communicating the audit results to
             responsible area and/or functional management.

Step 8.      Management in the affected areas and/or functions is responsible for any follow-up
             actions needed as a result of the audit.

Step 9.      Audit reports will be retained for at least 2 years from the date of audit completion.




    Responsible Person:

    Signature and Date:




                                                                                          Element 4.5
                                                                                  ELEMENT 4.6

                                                                MANAGEMENT REVIEW

Management reviews are the key to continuous improvement and to ensuring that the EMS will continue
to meet your organization’s needs over time.

Management reviews are also a good opportunity to keep your EMS efficient and cost effective. For
example, some organizations have found that certain procedures and processes initially put in place
were not needed to achieve their environmental objectives or control key processes. If EMS
procedures and other activities don’t add value, eliminate them.

The key question that a management review seeks to answer is: “Is the system working?” (for example,
is the EMS suitable, adequate, and effective, given our needs?).

Hints:

•   Two kinds of people should be involved in the management review process:

         –   people who have the right information and knowledge

         –   people who can make decisions

•   Determine the frequency for management reviews that will work best for your organization. Some
    organizations combine these reviews with other meetings (such as director meetings), while other
    organizations hold “stand-alone” reviews. For ISO 9000 purposes, management reviews are
    typically held once or twice per year.

•   Make sure that someone takes notes on what issues were discussed, what decisions were arrived
    at, and what action items were selected. Management reviews
    should be documented.                                                   Review
                                                                       Have we:
•   The management review should assess how changing                   ü Established a process for
    circumstances might influence the suitability, effectiveness, or     periodic reviews of our
    adequacy of your EMS. Changing circumstances may be                  EMS?
    internal to your organization (for example, new facilities, new    ü Documented the results
    materials, changes in products or services, and new                  of such reviews?
    customers), or may be external factors (such as new laws, new      ü Followed up on action
    scientific information, or changes in adjacent land use).            items to ensure closure?




                                                 4.6-1                                     Element 4.6
                                       •   Once you have documented the action items arising from
Many of the benefits of an EMS
cannot be anticipated beforehand.          your management review, be sure to follow up. Progress on
You will discover them as pleasant         these action items should be tracked.
surprises, at some point after
implementation. They WILL be           •   As you evaluate potential changes to your EMS, consider
there.                                     other organizational plans and goals. Environmental
                                           decision-making should be integrated into your overall
CONGRATULATIONS!! YOU
                                           management strategy.
NOW HAVE ALL OF THE
ELEMENTS OF AN
EFFECTIVE EMS.




                          Questions to Ponder During Management Reviews
  ü Did we achieve our objectives and targets? (If not, why not?) Should we modify our objectives?
    Should we set new objectives and targets?
  ü Is our environmental policy still relevant to what we do?
  ü Are roles and responsibilities clear and do they make sense?
  ü Are we applying resources appropriately?
  ü Are the procedures clear and adequate? Do we need others? Should we eliminate some?
  ü Are we monitoring our EMS (e.g., via system audits)?
  ü What effects have changes in materials, products, or services had on our EMS and its effectiveness?
  ü Do changes in laws or regulations require us to change some of our approaches?
  ü What stakeholder concerns have been raised since our last review?
  ü Is there a better way? What else can we do to improve?
  ü Is a new aspects or impacts analysis needed?




                                                 4.6-2                                    Element 4.6
                          EMS Procedure                                     4.6
                           Effective Date
          Company Name         Subject                           Management Review


Purpose         The purpose of this procedure is to document the process and primary agenda of issues
                to be included in the Management Review meetings for evaluating the organization’s
                EMS. The Management Review process is intended to provide a forum for discussion
                and improvement of the EMS and to provide management with a vehicle for making any
                changes to the EMS necessary to achieve the organization’s goals.

Step 1          The Environmental Manager is responsible for scheduling and conducting a minimum of
                two Management Review meetings during each 12-month period. The Environmental
                Manager is also responsible for ensuring that the necessary data and other information
                are collected prior to the meeting.

Step 2.         At a minimum, each Management Review meeting will consider the following:

                •   the suitability, adequacy and effectiveness of the environmental policy
                •   the suitability, adequacy and effectiveness of the environmental objectives (as well
                    as the organization’s current status against these objectives)
                •   the overall suitability, adequacy and effectiveness of the EMS
                •   the status of corrective and preventive actions and the results of any EMS audit
                    conducted since the last Management Review meeting
                •   the suitability, adequacy and effectiveness of training efforts
                •   the results of any action items from the previous Management Review meeting
Step 3.         Minutes will be taken of the Management Review. These meeting minutes will include,
                at a minimum, a list of attendees, a summary of key issues discussed, and any action
                items arising from the meeting.

Step 4.         A copy of the meeting minutes will be distributed to attendees and any individuals
                assigned action items. A copy of the meeting minutes will be retained on file.




    Responsible Person:

    Signature and Date:




                                                                                              Element 4.6

								
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