METAL FINISHING EMS TEMPLATE INTRODUCTION

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). Identify Environmental Aspects and Impacts Determine Significant Environmental Impacts M&M Communications Roles & Responsibilities Training ER&P Activities, Products & Services Determine Legal & Other Requirements Establish Objectives & Targets Corrective & Preventive Action for Compliance Records EMS Document Control Management Review Establish/Revise Environmental Policy Review Policy Components Audits 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 Module 1: Policy 1.1 2.1 2.2 2.3 3.1 3.2 3.3 3.4 3.5 4.1 4.2 4.3 4.4 4.5 4.6 Environmental Policy Environmental Aspects and Impacts Compliance Objectives and Targets Roles and Responsibility Communications Training EMS Document Control Emergency Response and Preparedness Measurement and Monitoring EMS Nonconformance and Corrective Action Corrective and Preventive Action for Compliance Records Audits Management Review Module 2: Planning Element Module 3: Implementation Module 4: Review and Improvement 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 Improve working conditions for employees Establish and maintain positive community relations Improve relations with government agencies Enhance public image Reduce insurance premiums Avoid fines and expensive corrective action measures due to compliance issues or lawsuits Reduce environmental costs and improve bottom line Streamline regulatory compliance Reduce raw material use and waste generation Distinguish company from competition Make progress towards ISO 14000 registration Meet Strategic Goals Program goals Improve process control and monitor trends 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-docheck-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. Leverage components of other business systems and programs; for example, adapt existing training programs to include environmental training or model EMS documentation and document control procedures on existing quality system document control. Smaller organizations such as metal finishing companies have some advantages over larger organizations in ensuring effective environmental management. This is because smaller organizations generally have more direct lines of communication, less complex organization structures, employees who perform multiple functions, and easier access to management. ⇒ EMS elements should be implemented in a top-down fashion and address priority areas first. ⇒ 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: Module 2: Module 3: Module 4: Policy Planning Implementation 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 Procedure for implementing element Tools and examples to assist element implementation (2 pages) (1 page) (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 Element 2.1 Element 2.2 Element 2.3 Element 3.1 Element 3.2 Element 4.1 Environmental Policy Environmental Aspects and Impacts Compliance Objectives and Targets Roles and Responsibilities Internal Communication 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 Effective Date Company Name 1.1 Subject Environmental Policy Purpose Step 1 This procedure is used to develop and write the company’s environmental policy. 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. 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. 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). The environmental manager will review the environmental policy at least annually, and update it if needed. Step 2 Step 3 Step 4 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 PG&E is committed to a clean, healthy environment. We provide our customers with safe, reliable, and responsive utility service in an environmentally sensitive and responsible manner. We believe that sound environmental policy contributes to our competitive strength and benefits our customers, shareholders, and employees by contributing to the overall well-being and economic health of the communities we serve. Policy Statement We will: Comply fully with the letter and spirit of environmental laws and regulations, and strive to secure fundamental reforms that will improve their environmental effectiveness and reduce the cost of compliance. Consider environmental factors and the full acquisition, use, and disposal costs when making planning, purchasing, and operating decisions. Work continuously to improve the effectiveness of our environmental management. Provide appropriate environmental training and educate employees to be environmentally responsible on the job and at home. Monitor our environmental performance regularly through rigorous evaluations. Seek to prevent pollution before it is produced, 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: Environmental Aspects and Impacts: Environmental Aspects and Impacts: Environmental Aspects and Impacts: Environmental Aspects and Impacts: Wastewater Air Emissions Hazardous and Solid Waste Raw Materials 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 on a scale from 1 to 5, where 1 indicates the criterion is very important or relevant to that aspect (for example, the aspect is strictly regulated, is the subject of compliance violations, or is a waste generated in large quantities), and 5 indicates the criterion is relatively unimportant or irrelevant to that aspect (for example, the aspect is an unregulated waste, is generated infrequently, and is inexpensive to manage). 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. Each environmental aspect and impact form is designed to document the source of each aspect, which should encourage you to consider source reduction (pollution prevention) strategies for mitigating the aspect and its impact. 2-2 Element 2.1 EMS Procedure Effective Date Company Name 2.1 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. 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 1 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. Environmental aspects and impacts documentation will be retained at the facility for at least 2 years. Step 4 Responsible Person: Signature and Date: 2-3 Element 2.1 TOP 5 ENVIRONMENTAL ASPECTS AND IMPACTS Wastewater, Air Emissions, Hazardous and Solid Waste, Raw Materials, or Utility ex. Chrome-containing wastewater from chrome plating ex. PERC vapors from parts cleaning 1. Hazardous Constituents (if any) Chrome Sources (indicate process line and tank) • 3 chromic acid tanks (rack line) • 1 chromic acid tank (barrel line) • Vapor degreasing tent Quantity and Cost (per month) 200,000 gal/mo $4,000 mo < 1 gal/mo cost is low Current Management Practice Treatment and discharge to POTW Engineering controls Rationale for Top 5 • Discharge limit • Past violations Perchloroethylene • Worker exposure • AQMD regulation • Compliance burden 2. 3. 4. 5. Responsible Person Effective Date 2-4 ASPECTS FORM A ENVIRONMENTAL ASPECTS AND IMPACTS: WASTEWATER SOURCE(S) (indicate process line and tank number) WEEKLY VOLUME (gallons) TYPE OF WASTEWATER Chromecontaining CONTAMINANTS Cr+6 Cr+3 Cr+6 & Cr+3 or FLOW RATE (gpm) MANAGEMENT Cr+6 reduction q Sodium metabisulfite q SO2 q Other: Chemical precipitation Ion exchange DISCHARGED TO POTW Domestic sewer Stormwater sewer Surface water body PRIORITIZATION CRITERIA Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs PRIORITY (Sum of Scores) Cyanidecontaining Cyanide Cu Zn Cd Au Ag Brass (Cu & Zn) CN oxidation Sodium hypochlorite Chlorine gas Ozone Other: Chemical precipitation Ion exchange pH adjustment Chemical precipitation Ion exchange POTW Domestic sewer Stormwater sewer Surface water body Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Acid or alkaline (no plating metals) POTW Domestic sewer Stormwater sewer Surface water body Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Non-cyanide metalscontaining Cu Ni Zn Cd Au Ag Al Organic dyes pH adjustment Chemical precipitation Ion exchange POTW Domestic sewer Stormwater sewer Surface water body RO DI unit reject pH adjustment Chemical precipitation Ion exchange Direct discharge to sewer POTW Domestic sewer Stormwater sewer Surface water body Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Responsible Person Effective Date 2-5 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: WASTEWATER (Continued) SOURCE(S) (indicate process line and tank number) WEEKLY VOLUME (gallons) TYPE OF WASTEWATER Spent cooling water CONTAMINANTS or FLOW RATE (gpm) MANAGEMENT Direct discharge to sewer Reused on site In rinse tanks Other ______________ DISCHARGED TO POTW Domestic sewer Stormwater sewer Surface water body POTW Domestic sewer Stormwater sewer Surface water body Returned PRIORITIZATION CRITERIA Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs Regulatory compliance Toxicity Quantity Process chemical costs Treatment costs PRIORITY (Sum of Scores) Laboratory wastewater and liquids Boiler blowdown Treated on site Discharged to sewer POTW Domestic sewer Stormwater sewer Surface water body Cooling tower water POTW 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 CONSTITUENTS Cr Cu Ni Zn Cd Au Ag Spent Process Baths gal/mo Cr Cu Ni Zn Cd Au Ag CN Spent IX Resins Drums Dumpster Recycler Other Regulatory compliance Toxicity Quantity Disposal cost Filter Media Cartridges Loose Media Bag Filters Waste PPE Gloves Masks Boots Aprons Other drums/mo Drums Dumpster HW landfill Incinerator SW landfill Drums Dumpster Sacks HW landfill Incinerator SW landfill Regulatory compliance Toxicity Quantity Disposal cost Regulatory compliance Toxicity Quantity Disposal cost Drums Tanks On-site treatment Recycling facility Hazardous waste treatment facility POTW Regulatory compliance Toxicity Quantity Disposal cost ON-SITE MANAGEMENT Rolloff bins Drum Sacks PRIORITIZATION CRITERIA Regulatory compliance Toxicity Quantity Disposal cost PRIORITY (Sum of Scores) TYPE OF WASTE Wastewater Treatment Sludge SOURCE WWTS Batch Continuous Other _______________ QUANTITY tons/mo DISPOSAL Hazardous waste landfill Special waste landfill Recycling facility Responsible Person Effective Date 2-7 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: HAZARDOUS AND SOLID WASTE (Continued) HAZARDOUS CONSTITUENTS ON-SITE MANAGEMENT Drums Trash can PRIORITIZATION CRITERIA Regulatory compliance Toxicity Quantity Disposal cost Rags / Wipes Drums Dumpster Industrial Laundry HW landfill SW landfill Spent Solvents Liquid Still bottoms Absorbent Pads Loose Waste Packaging Cardboard Pallets Wrapping Aluminum Employees /mo Trash can Dumpster Dedicated container Paper Office /mo Trash can Dumpster SW landfill Recycled SW landfill Recycled Trash can Dumpster Pile SW landfill Recycled Regulatory compliance Toxicity Quantity Disposal cost Regulatory compliance Toxicity Quantity Disposal cost Regulatory compliance Toxicity Quantity Disposal cost Copper Wire Dedicated container Recycled Regulatory compliance Toxicity Quantity Disposal cost Responsible Person TYPE OF WASTE Waste Masking SOURCE QUANTITY DISPOSAL HW landfill Incinerator SW landfill PRIORITY (Sum of Scores) Regulatory compliance Toxicity Quantity Disposal cost Regulatory compliance Toxicity Quantity Disposal cost Drums Recycling Facility Incinerator Drums HW Landfill Effective Date 2-8 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: AIR EMISSIONS SOURCE(S) (indicate process line and tank number) TANK SURFACE AREA (ft 2) PRIORITIZATION CRITERIA (1 = high, 5 = low) Balls None Regulatory compliance Toxicity Emission control costs Worker exposure Regulatory compliance Toxicity Emission control Worker exposure Regulatory compliance Toxicity Emission control Worker exposure Acid Vapors HCl HNO3 Alkaline Vapors H2SO4 Mixed Venting None Fume Suppressant Water vapor and trace metals Evaporator Condensers None Scrubber Uncontrolled Regulatory compliance Toxicity Emission control costs Worker exposure Regulatory compliance Toxicity Emission control costs Worker exposure Regulatory compliance Toxicity Emission control costs Worker exposure Water vapor, particulates, and trace metals Sludge dryer Particulate removal: None Regulatory compliance Toxicity Emission control costs Worker exposure PRIORITY (Sum of scores) EMISSION TYPE Chrome Plating Cr+6 Cr+3 Solvent: Controlled Trichlorethane Perchoroethylene Mineral spirits Solvent: Uncontrolled Acetone Other: MANAGEMENT Scrubbers Demisters Surfactant Foam Chiller Unit cover Distillation Increased Freeboard Venting None Responsible Person Effective Date 2-9 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: AIR EMISSIONS (Continued) SOURCE(S) (indicate process line and tank number) Delivery Vehicles TANK SURFACE AREA (ft 2) Other None PRIORITIZATION CRITERIA (1 = high, 5 = low) Regulatory compliance Toxicity Emission control costs Worker exposure PRIORITY (Sum of scores) EMISSION TYPE Engine exhaust MANAGEMENT Maintenance Responsible Person Effective Date 2-10 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: RAW MATERIALS PRIORITIZATION CRITERIA (1 = High, 5 = Low) 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 RAW MATERIAL OR RESOURCE 1. ANNUAL COST ($/year) ANNUAL QUANTITY USED (gallons or pounds) PRIORITY (Sum of Scores) Effective Date 2-11 ASPECTS FORM B ENVIRONMENTAL ASPECTS AND IMPACTS: WATER AND ENERGY PRIORITIZATION CRITERIA Quantity Cost PRIORITY (Sum of Scores) RESOURCE Water Process water DI RO Sanitary Irrigation Electricity Plating rectifiers USE QUANTITY gallons/month gallons/month gallons/month gallons/month gallons/month kW-hr/month Quantity Cost Equipment operation Facility lighting Process bath heating Gas Heat process baths Building heating Boiler Oven Degreaser Office heat cubic feet/month Quantity Cost 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. Regulatory compliance requirements include : • Federal requirements • State and local requirements • Permit conditions Other environmental “requirements” might include: • Customer-specific codes • Standards in locations where you sell products • International Chamber of Commerce (ICC) Charter for Sustainable Development • Strategic Goals Program (SGP) • Other industry codes or programs to which your organization voluntarily subscribes Also, as you complete the process of cataloging compliance requirements, you should begin to identify “environmental metrics” that should be addressed in Element 4.1, Measurement and Monitoring. The Template contains a procedure and several EMS tools to help you in identifying and meeting your compliance requirements. Those tools are described below: 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 Effective Date Company Name 2.2 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. 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. 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. 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. 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 Step 1 Step 2 Step 3 Step 4 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 Agency Cal/OSHA DTSC Program Injury & Illness Prevention Program On-Site Hazardous Waste Treatment Program/ Question 16/2 10/7 Scheduled Task Safety Suggestion Box – check for new suggestions Facility Inspection – check areas subject to spills, overfill control equipment, monitoring data, and uncovered tanks WEEKLY Agency DTSC, RWQCB MONTHLY Agency Cal/OSHA Program Injury & Illness Prevention Program Employee Training Cal/OSHA RWQCB Injury & Illness Prevention Program Storm Water Pollution Prevention Program/ Question 16/ 26/7 16/2 15/6 Safety Committee – conduct monthly safety committee meeting Facility Inspection – conduct storm water 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) Scheduled Task Employee Training – conduct monthly safety meeting Program On-site Hazardous Waste Treatment Program/ Question 10/7 Scheduled Task Facility Inspection -- check containment, stored containers, and tanks QUARTERLY Agency POTW Program Industrial Wastewater Discharge Program/ Question 7/4 Scheduled Task Periodic Report of Continued Compliance – submit quarterly discharge monitoring report to local sewer agency (Note: report submittal schedule may differ) Facility Inspection – conduct non-storm water discharge visual observation – check for flow, debris, odor, and discoloration RWQCB Storm Water Pollution Prevention 15/5 2-17 Element 2.2 ANNUALLY Agency CUPA or Local Agency POTW DTSC Cal/OSHA Program Hazardous Materials Business Plan Industrial Wastewater Discharge On-site Hazardous Waste Treatment Hearing Conservation Program Respiratory Protection Program Process and Laboratory Ventilation Recordkeeping Program/ Question 5/2 Scheduled Task Submit annual update of Hazardous Materials Business Plan (HMBP) to CUPA or Local Agency Industrial Discharge Permit – submit annual update (Note: update schedule may differ) Facility Inspection – check storage tank system Complete annual audiometric testing for employees exposed to noise levels higher than 85 dBA (8-hour Time-Weighted Average) Complete annual medical examination for employees who use a respirator Test process tanks and laboratory hood for proper ventilation velocities Annual notice to employees of existence, location, and availability of employee exposure and medical records Emergency Coordinator Training – annual refresher training 7/1 10/7 21/4 Cal/OSHA Cal/OSHA Cal/OSHA 22/5 23/2, 3 --- USEPA, DTSC, Federal OSHA, Cal/OSHA, CUPA, DOT PERIODICALLY Date January 31 Employee Training 26/6 Agency Cal/OSHA Program Recordkeeping Program/ Question --- Scheduled Task Post Annual Summary of Occupational Illnesses and Injuries during the month of February Tiered Permit – submit annual FacilitySpecific Notification on agency forms Closure Plan – adjust closure cost estimate Biennial Report – submit completed report on agency forms, if required (Note: forms are updated each reporting period) Facility Inspection & Plan Review – conduct annual inspection of storm water structures and evaluation of SWPP Plan Form R Reporting – submit completed report on agency forms, if required (Note: forms are updated each reporting period) March 1 March 1 March 1 of Even Number Years June 1 DTSC DTSC USEPA, DTSC RWQCB On-site Hazardous Waste Treatment On-site Hazardous Waste Treatment On-site Hazardous Waste Treatment Storm Water Pollution Prevention Multimedia Reporting (Form R) 10/2 10/4 10/9 15/8 July 1 USEPA 12/1 2-18 Element 2.2 PERIODICALLY (continued) Date July 1 Agency RWQCB Program Storm Water Pollution Prevention Program/ Question 15/9 Scheduled Task Annual Report – submit completed annual report on agency forms, if required (Note: facility may be included in a Group Monitoring Plan) Evaluation & Plan, and Performance Report – update the Plan and Report every 4 years, if required Waste Audit Study & Compliance Checklist – update the Waste Audit Study & Compliance Checklist every 4 years, if required Summary Progress Report – update the Summary Progress Report every 4 years and submit it to DTSC, if required Storm Water Sampling and Analysis – 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) Log each batch or amount of hazardous waste treated on site September 1 Every 4 Years (99, 03, 07…) September 1 Every 4 Years (99, 03, 07…) September 1 Every 4 Years (99, 03, 07…) October 1 – May 31 DTSC Waste Minimization Reporting Waste Minimization Reporting 13/1 DTSC 13/2 DTSC Waste Minimization Reporting Storm Water Pollution Prevention 13/3 RWQCB 15/7 Each Batch or Amount of Hazardous Waste Treated DTSC On-site Hazardous Waste Treatment 10/8 Agency Codes: CUPA DOT DTSC OSHA POTW RWQCB USEPA Certified Unified Program Agency U.S. Department of Transportation California Department of Toxic Substances Control Occupational Safety and Health Administration (Federal OSHA and Cal/OSHA) Publicly Owned Treatment Works (Sewer Authority) Regional Water Quality Control Board U.S. Environmental Protection Agency 2-19 Element 2.2 ENVIRONMENTAL and HEALTH & SAFETY REGULATORY COMPLIANCE CHECKLIST Table of Contents Page I. II. III. IV. V. Self-Audit Procedures .................................................................................................. Additional Information .................................................................................................. Additional Requirements ............................................................................................. Legal Authority .............................................................................................................. EH&S Compliance Checklist: 1. 2. 3. 4. 5. 6. 7. 8. 9. EH&S Program Administration ................................................................................. Pollution Prevention ................................................................................................. Emergency Response ............................................................................................. Hazardous Materials Storage Permit ......................................................................... Hazardous Materials Business Plan (HMBP) ............................................................. Accidental Release Prevention (CalARP) ................................................................... Industrial Wastewater Discharge (POTW) .................................................................. Hazardous Waste Activity Registration ...................................................................... Local Hazardous Waste Generator Permit ................................................................. 2 2 2 3 4 4 5 6 6 6 7 7 7 8 8 9 9 10 12 13 13 14 14 14 14 15 15 16 16 16 17 18 10. Onsite Hazardous Waste Treatment (Tiered Permit) ................................................... 11. Hazardous Materials and Hazardous Waste Storage .................................................. 12. Multimedia Reporting (Form R) ................................................................................. 13. Waste Minimization Reporting (SB-14) ...................................................................... 14. Air Pollution Control ................................................................................................. 15. Storm Water Pollution Prevention (SWPP) ................................................................ 16. Injury and Illness Prevention Plan (SB-198) ................................................................ 17. Hazard Communication ............................................................................................ 18. Safe Drinking Water and Toxic Enforcement Act (Proposition 65) ................................ 19. Energy Control Program (Lockout/Tagout) ................................................................. 20. Confined Spaces ..................................................................................................... 21. Hearing Conservation ............................................................................................... 22. Respiratory Protection ............................................................................................. 23. Process and Laboratory Ventilation ........................................................................... 24. Chemical Hygiene Plan ............................................................................................ 25. Personal Protective Equipment ................................................................................. 26. Employee Training ................................................................................................... 27. Facility Inspections ................................................................................................. Footnotes ............................................................................................................... 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 Program 1. EH&S Program Administration All Agencies 2 Check 1. Has a Program Administrator been assigned to oversee all EH&S activities for the facility? It is a good policy to have one person assigned this responsibility. Has the facility installed rinsewater reuse and reduction measures: A. Flow restrictors B. Countercurrent rinses C. Spray rinses D. Dragout rinses E. Timer flow controls F. Conductivity flow controls G. Reuse of rinsewater in scrubber H. Recapture of dragout rinsewater I. Improved rinsewater agitation Yes No % References 3 Status/Notes 2. Pollution Prevention DTSC, POTW, USEPA 1. - Local Ordinances - 22 CCR §67100.1-.14 - DTSC and USEPA P2 Documents* - DTSC Document #402 (Hazardous Waste Minimization Checklist & Assessment Manual for the Metal Finishing Industry) - POTW P2 Documents - EMS Form -- EMS Checklist 2. Has the facility instituted the practice of optimizing bath use: A. Filtration of bath B. Bath change by analysis C. New chemistry to reduce waste 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 Program 2. Pollution Prevention (continued) Agencies 2 Check 4. Has the facility instituted practices to improve waste treatment: A. B. C. Improved treatment chemistry Flow equalization Batch treatment Yes No % References - Local Ordinances 3 Status/Notes DTSC, POTW, USEPA - 22 CCR §67100.1-.14 - DTSC and USEPA P2 Documents* - DTSC Document #402 (Hazardous Waste Minimization Checklist & Assessment Manual for the Metal Finishing Industry) - POTW P2 Documents - EMS Form - EMS Checklist 3. Emergency Response CUPA, DTSC, DOT, OSHA, USEPA a. Has the facility prepared a written Emergency Response Plan that includes Emergency Procedures and the information listed below? All employees should be trained in emergency procedures. Have Emergency Coordinators been designated for response to emergency incidents? Responsible staff members should be trained for emergencies. Has the facility prepared a Facility Evacuation 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. ------ H&SC §25500 29 CFR 1910.120 22 CCR §66265.52 8 CCR §5192 CUPA HMBP* b. -- EMS Form c. -- EMS Form 2-24 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 3. Emergency Response (continued) Agencies 2 Check d. Have Emergency Telephone Numbers been documented for Emergency Coordinators, emergency services agencies and companies, and senior facility staff? The list should be posted in the facility. Has a list of Emergency Equipment been prepared for the facility? Have arrangements been made with Emergency Services Companies to provide emergency response? Written agreements should be obtained. Has the facility assembled and Inventory of 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. Has the facility prepared an Emergency Action Plan that discusses procedures to follow in an emergency? This plan may be included in the facility’s Emergency Response Plan Has the facility prepared a Fire Prevention Plan that discusses methods to prevent fires in the facility? This plan may be included in the facility’s Emergency Response Plan. Yes No % CUPA, DTSC, DOT, OSHA, USEPA References -- EMS Form 3 Status/Notes e. f. -- EMS Form -- EMS Form g. -- EMS Form h. -- 8 CCR §3220 i. -- 8 CCR §3221 2-25 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 4. Hazardous Materials Storage Permit Agencies Local Agency 2 Check 1. Has the facility submitted a Hazardous Materials Storage Permit application, if required? Some local agencies may include this permit with their Hazardous Materials Business Plan requirement or their CUPA registration. If the facility uses more than the threshold quantities of hazardous material, has the facility submitted a Hazardous Materials Business Plan (HMBP) to the local governing agency? Threshold quantities are 500 pounds, 55 gallons, or 200 cubic feet of hazardous materials at any one time during the year. 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. If the facility uses listed acutely hazardous materials above threshold quantities, has the facility submitted a CalARP Registration form? If required by the local agency, has the facility submitted a Risk Management Plan (required 6/21/99)? If the facility discharges treated industrial wastewater to the sewer, has the facility submitted a Wastewater Discharge Permit Application to the local POTW? Has the facility ensured compliance with its 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 Yes No % References 3 Status/Notes - Local Ordinances – (typically Fire Dept or local CUPA) 5. hazardous Materials Business Plan (HMBP) CUPA or Local Agency, OES 1. - H&SC §25500 - OES HMBP Forms* - Local Agency HMBP Forms* - EMS Checklist 2. 6. Accidental Release Prevention (CalARP) CUPA or Local Agency, OES 1. -- H&SC §25531 -- CUPA Registration Form* - OES RMP Guidance Document* - Local Industrial Discharge Ordinance and Permit Application* - 40 CFR §403* 2. 7. Industrial Wastewater Discharge POTW 1. 2. 2-26 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 7. Industrial Wastewater Discharge (continued) Agencies POTW 2 2. Check Has the facility ensured compliance with its wastewater discharge permit by: D. Ensuring the facility’s solvent management 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 Has the facility completed required sampling and analysis of industrial wastewater? Has the facility submitted a Periodic Report of Continued Compliance (PRCC) or Self Monitoring Report (SMR) on the established submittal schedule? Yes No % References - 40 CFR §403* 3 Status/Notes 3. 4. - Local POTW PRCC/SMR forms* 8. Hazardous Waste Activity Registration 9. Local Hazardous Waste Generator Permit 10. On-Site Hazardous Waste Treatment (Tiered Permit) DTSC, USEPA 1. Has the facility completed a Hazardous Waste Activity form that correctly reflects the waste generation at the facility? If required by a local agency, has the facility completed and submitted a local Hazardous Waste Generator’s Permit Application? If the facility treats hazardous waste onsite, has the facility prepared and submitted an Onsite Hazardous Waste Treatment Notification Form (Tiered Permit)? Has the facility completed all annual updates to the Onsite Hazardous Waste Treatment Notification Form? Updates are due to DTSC by March 1. Has the facility prepared a Waste Analysis Plan? - EPA Form 8700-12 Local Agency 1. - Local Ordinance CUPA, DTSC 1. - 22 CCR §67450.1-.13 2. - DTSC Form 1772* 3. - EMS Checklist 2-27 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 10. On-Site Hazardous Waste Treatment (Tiered Permit) (continued) Agencies CUPA, DTSC 2 Check 4. Has the facility prepared a Closure Plan and updated the Closure Cost Estimate annually or as required? Has the facility completed a Tiered Permit Phase I Environmental Assessment? Has the facility completed a Contingency Plan? (May be part of Emergency Response Plan) Has the facility completed and recorded Facility Inspections? Has the facility recorded all quantities of hazardous waste treated? Has the facility completed and submitted Biennial 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. Are all containers of hazardous materials and hazardous waste properly segregated? Are all containers of hazardous materials and hazardous waste closed, except during dispensing? Are all hazardous materials and hazardous waste containers in good condition? Are all containers of hazardous waste stored inside secondary containment? Are all containers of hazardous waste properly labeled with a Hazardous Waste Label, which includes the accumulation start time (limit is 90 days)? Yes No % References 3 - 22 CCR §67450.3(a)(13)(B) - 22 CCR §67450.7 - DTSC Form 1151* - 22 CCR §66265.52 - 22 CCR §66265.15(b) Status/Notes 5. 6. 7. 8. 9. - USEPA Biennial Report Booklet* 11. Hazardous Materials and Hazardous Waste Storage DTSC, CUPA or Local 1. Agency, OSHA 2. - 22 CCR §66264.170-178 - 8 CCR §5164 - Local Ordinances - EMS Checklist 3. 4. 5. 2-28 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 12. Multimedia Reporting (Form R) Agencies USEPA 2 Check 1. Has the facility completed and submitted Toxic Release Inventory (Form R) Reports, if the 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. If the facility generates more than 12,000 Kg of hazardous waste, or 12 Kg of extremely hazardous waste, has the facility prepared a Source Reduction Evaluation and Plan and Performance Report (SB-14)? The documents must be updated every four years by September 1 (1999, 2003…) If the facility is a small business, has the facility prepared an industry-specific Waste Audit Study or a Source Reduction Compliance Checklist? The documents must be updated every four years by September 1 (1999, 2003…) If captured by SB-14, has the facility prepared a 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…) Yes No % References 3 Status/Notes -- USEPA Form R Booklet* 13. Waste Minimization Reporting (SB-14) DTSC, CUPA 1. - 22 CCR §67100.1-.14 - H&SC 25244.12-.23 - Hazardous Waste Source Reduction Guidance Manual* 2. - California Government Code Article 2, Section 11342 - Hazardous Waste Source Reduction Compliance Checklist* 3. 2-29 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 14. Air Pollution Control Agencies 2 Check 1. If the facility emits any hazardous substance above emission standards, has the facility submitted an Air Pollution Control Permit Application? If the facility performs electrolytic chrome plating 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 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? Yes No % References 3 Status/Notes CARB, SCAQMD - H&SC §42300 - SCAQMD Rule 201 and Permit Application Forms - SCAQMD Rule 1469 2. 2. 2-30 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 14. Air Pollution Control (continued) Agencies 2 Check 2. If the facility performs electrolytic chrome plating or chromic acid anodizing: 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 Has the facility reduced emissions from the emissions collection system to less than 0.03 mg/amp-hr? Yes No % References 3 Status/Notes CARB, SCAQMD - SCAQMD Rule 1469 2. 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 Has the facility reduced emissions from the emissions collection system to less than 0.006 mg/amp-hr? Written Compliance Plan Anti-mist additive concentrations for each tank? Daily log of ampere-hours applied to each tank? Records maintained for 2 years? 2. D. Has the facility maintained records of: 1. 2. 3. 4. 2-31 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program Agencies 2 Check 3. If the facility performs solvent degreasing operations: A. B. Are containers and equipment free of cracks, holes, defects, or leaks? Is the parts degreasing process performed in a manner that minimizes solvent emissions and in accordance with SCAQMD rules? Is the design and maintenance of the degreasing equipment in accordance with SCAQMD rules? Are environmental controls properly implemented to maintain proper ventilation and minimize exposure? Are solvent use records maintained in accordance with SCAQMD rules? Yes No % References 3 Status/Notes -- SCAQMD Rule 1122 C. D. -- SCAQMD Rule 1171 4. If the facility performs solvent cleaning operations: A. B. C. Do the solvents used comply with SCAQMD Rule 1171 standards? Is the use of solvents by one of SCAQMD approved methods? Are all VOC-containing solvents properly stored and disposed of in accordance with SCAQMD Rule 1171? Are emission collection and control systems designed and operated in accordance with SCAQMD Rule 1171? Are records maintained in accordance with SCAQMD rules? D. E. 2-32 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST 15. Storm Water Pollution Prevention (SWPP) SWRCB, RWQCB 1. If the facility has industrial activity exposed to storm water, has the facility submitted a NoticeOf-Intent to SWRCB? Has the facility prepared a Storm Water Pollution Prevention Plan Has the facility prepared a Monitoring Program (or is the facility covered under a Group Monitoring Plan)? Has the facility implemented its SWPP Plan best management practices in accordance with its implementation schedule? Has the facility completed its Non-Storm Water Discharge Visual Observations quarterly? Has the facility completed its Storm Water Discharge Visual Observations monthly during the wet season? Has the facility completed its Storm Water Sampling twice during the wet season? Has the facility completed its annual review of its SWPP? This review must be documented and submitted with the Annual Report to RWQCB. Has the facility submitted its Annual Storm Water Report to RWQCB each year? The Annual Report must be submitted to RWQCB annually by July 1. -- Annual Report forms are provided in the SWRCB SWPP Packet -- Forms are provided in the SWRCB SWPP Packet* -- State Water Resources Control Board Order 97-03-DWQ* 2. 3. 4. 5. 6. 7. 8. 9. 2-33 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST 16. Injury and Illness Prevention Plan (SB-198) OSHA 1. Has the facility prepared an Injury and Illness Prevention Plan in accordance with OSHA guidelines? Does the company provide a method for communication of workplace hazards with its employees (e.g. committees or safety suggestion box)? Has the company evaluated its facility for workplace hazards? Does the facility perform routinely scheduled safety inspections of its facility? Has the facility prepared Codes of Safe Practice for its employees and their jobs? Has the facility investigated all workplace injuries and illnesses? Has the facility corrected all hazardous conditions? Has the facility maintained records of hazard assessments, inspections, and employee safety training? Has the facility prepared a written Hazard Communication Program? Has the facility prepared an inventory of hazardous chemicals used at the facility? An HMBP Hazardous Materials Inventory Statement may meet this requirement. Has the facility provided Materials Safety Data Sheets for its employees for the chemicals used in the Facility? Are all containers of hazardous chemicals properly labeled with the chemical name and hazard warnings? - 8 CCR §5194 - Cal/OSHA Guidance Document* - EMS Form - EMS Form - EMS Form - EMS Form - 8 CCR §3203 - Cal/OSHA Guidance Document* 2. 3. 4. 5. 6. 7. 8. - EMS Form 17. Hazard Communication OSHA 1. 2. 3. 4. 2-34 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 18. Safe Drinking Water and Toxic Enforcement Act (Prop 65) 19. Energy Control Program (Lockout/ Tagout) Agencies 2 Check 1. If the facility has any Prop 65 listed chemical, does the facility provide warnings to its employees and the community? Warning signs should be placed at business entrances and in work areas. Does the facility have a written Energy Control Program for the control of energy during servicing and maintenance of machines and equipment? Has the facility developed Lockout/Tagout procedures for its machinery and equipment? Written procedures should be prepared for appropriate machinery and equipment. Does the facility have a supply of locks and tags to implement the Lockout/Tagout Has the facility prepared written procedures for entry into confined spaces? Has the facility marked areas or equipment that are confined spaces? Yes No % References 3 Status/Notes - H&SC §25249.5-.13 OSHA 1. - 29 CFR §1910.147 - 8 CCR §2320, 3314, and 6004 - Cal/OSHA Guidance Document* 2. - EMS Form 3. 20. Confined Spaces OSHA 1. 2. - 29 CFR §1910.146 - 8 CCR §5156, 5157, and 5158 - Cal/OSHA Guidance Document* - EMS Form 21. Hearing Conservation OSHA 1. If the facility has noise levels above 85 decibels (TWA 4), has the facility prepared a Hearing Conservation Program? Has the company conducted area noise sampling to determine noise levels? Has the facility conducted baseline testing of employees exposed to noise levels above 85 dBA? Has the facility conducted annual audiometric testing for employees exposed to noise levels higher than 85 dBA (TWA)? - 29 CFR §1910.95 - 8 CCR §5095-5100 - Cal/OSHA Guidance Document* - EMS Form 2. 3. 4. 2-35 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 22. Respiratory Protection Agencies OSHA 2 Check 1. If employees are exposed to hazardous chemicals above their permissible exposure limit, has the facility prepared a written Respiratory Protection Program? Has the facility conducted air sampling to determine need for respirator use? If respirators are required for employees, have the employees been fit tested for respirator use? If respirators are required for employees, have the employees been instructed in the proper use and maintenance of their respirator? Have employees who use a respirator completed an annual medical examination? If process tanks emit gases, vapors, or mists of hazardous chemicals above permissible exposure limits, has the facility provided process tank ventilation? Has the facility periodically tested and recorded 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. 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. Yes No % References 3 Status/Notes - 29 CFR §1910.134 - 8 CCR §5144 - Cal/OSHA Guidance Document* - EMS Form - EMS Form 2. 3. 4. 5. 23. Process and Laboratory Ventilation OSHA 1. - 8 CCR §5154 - EMS Form - 8 CCR §5154.1 - EMS Form 2. 3. 2-36 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 24. Chemical Hygiene Plan Agencies OSHA 2 Check 1. 2. If the facility has a laboratory, has the facility prepared a written Chemical Hygiene Plan? Has the facility implemented all segments of the Chemical Hygiene Plan (MSDSs, exhaust hood measurements, inspections, etc.)? Has the company assessed the hazards of each job for personal protection requirements? Has the facility completed and recorded Right-ToKnow, Hazard Communication, General Health & Safety, and job specific training for all of its employees? Has the facility completed and recorded Hazardous Materials Handling training for its employees that handle hazardous materials? Has the facility completed and recorded Hazardous Materials Transportation training for its employees that are involved in hazardous materials transportation related jobs? Has the facility completed and recorded Hazardous Waste Handling training for its employees that handle hazardous waste? Has the facility completed and recorded Hazardous Waste Treatment training for its employees that treat hazardous waste? Has the facility completed and recorded Emergency Coordinator training for its employees that serve as emergency coordinators? Has the facility completed and recorded periodic (e.g. monthly) safety training for all of its employees? Yes No % References - 8 CCR §5191 3 Status/Notes 25. Personal Protective Equipment 26. Employee Training OSHA 1. - 8 CCR §3203, 3380-3400 - EMS Form - H&SC §25500 - 29 CFR §1910.120 - 29 CFR §1910.1200 - 49 CFR §172.700 - 22 CCR §66265.16 - 8 CCR §3202 - 8 CCR §5192 - Cal/OSHA Guidance Documents* - EMS Checklist - EMS Form All 1. 2. 3. 4. 5. 6. 7. 2-37 ENVIRONMENTAL and HEALTH & SAFETY COMPLIANCE CHECKLIST Program 27. Facility Inspections All Agencies 2 Check 1. Has the facility completed and recorded the required facility inspections? Yes No % References - Local Ordinances - CUPA HMBP* 3 Status/Notes - 22 CCR §66265.15(b) - 8 CCR §3203 - State Water Resources Control Board Order 9703-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 References shown with an asterisk are available from MFASC. References shown in bold are the primary reference for support materials. TWA means time-weighted average. 3 4 2-38 Environmental Management System EMS Forms & Checklists Program 2. 2. 3. 3. 3. 3. Pollution Pr evention Pollution Prevention Emergency Response Emergency Response Emergency Response Emergency Response P2 Audit Checklist P2 Project Payback Calculation Form Posting Form: Emergency Coordinator Information Posting Form: Evacuation Map Emergency Telephone Numbers Emergency Equipment Program Completion Checklist (notification, waste analysis plan, closure plan, phase I assessment, emergency response plan, facility inspections, reports, etc.) EMS forms and checklists for the inspection and recordkeeping as required by SCAQMD rules Non-storm water visual observation Storm water discharge visual observation Storm water sampling and analysis Emergency incident investigation form Workplace hazard form Safety meeting record form Lockout/tagout procedures form Confined space entry permit form Area noise sampling form Respirator fit test form Process tank ventilation measurement form Laboratory hood ventilation measurement form Workplace hazard assessment form Employee training record form Facility inspection form Item Requires… Form Checklist ü ü ü ü ü ü ü 10. On-Site Hazardous Waste Treatment 14. Air Pollution Control ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü 15. Storm Water Pollution Prevention 15. Storm Water Pollution Prevention 15. Storm Water Pollution Prevention 16. Injury and Illness Prevention Plan 16. Injury and Illness Prevention Plan 16. Injury and Illness Prevention Plan 19. Energy Control Program 20. Confined Spaces 21. Hearing Conservation 22. Respiratory Protection 23. Process and Laboratory Ventilation 23. Process and Laboratory Ventilation 25. Personal Protective Equipment 26. Employee Training 27. Facility Inspections 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 National Response Center US EPA SARA Title III Hotline US EPA RCRA Hotline US EPA – Region IX US Department of Transportation Hotline (800) 424-9300 (800) 424-8802 (800) 535-0202 (800) 424-9346 (415) 744-2000 (800) 752-6367 STATE Agency Telephone Office of Emergency Services – OES Department of Toxic Substances Control – Headquarters – Sacramento California Highway Patrol – Hazardous Materials Section (800) 852-7550 (916) 445-4171 (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 Observed? Indications of Prior Discharge? Observations/Source of 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 LOCATION OF INCIDENT EXTENT OF EMERGENCY TYPE OF INCIDENT TIME OF INCIDENT REPORT COMPLETED BY 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 ______________________________________________________________________________________ Trade _________________________________________________________________________________________ Name 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) Facility Buildings Parking Areas Roadway (Private) Roadway (Public) Unimproved Shoulder Entered Sewer(S) Entered Storm Drain(s) Bay/Ocean Coastal Beach Lake/Stream Irrigation Water Agriculture Land Air Release Threat to Environment/Wildlife __________________________________________________________________ (explain): _________________________________________________________________________________________________ __ HEALTH Yes Yes Yes No Exposure to Employees (#______) No Exposure to Public No Medical Attention Yes Yes Yes No Employees Injured (#______) No Public Injured 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 _________________________________________________________________________ Hospital(s) Transported _____________________________________________________________________________ Describe Injuries or Exposure ________________________________________________________________ AGENCIES NOTIFIED ACTIONS TAKEN TO CONTROL PROBLEM NOTES Exposed/Injured: To: (Symptoms): 2-46 Environmental Management System Workplace Hazard Date of Inspection Inspector Hazard Type: q q Hazardous Workplace Hazardous Equipment q q Hazardous Process 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 Area Testing No. Sample Location/Task dBA Date 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 8 CCR 5154 (Table V-7/8/9) Exhaust Velocity (feet per minute) Required Measured Tank No. Tank Description Hazardous Substances 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 2 3 4 5 6 7 8 9 10 Calculation of Volume Flow Rate Average Velocity Hood Face Area Volume Flow Rate 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 2-54 Environmental Management System Workplace Hazard Assessment Area Job Classification Assessed By Date Hazard Description Hazard Category q Impact q Penetration q Compression (Roll-Over) q Chemical Estimate of Potential Injury q Heat q Harmful Dust q Light (Optical) Radiation 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 Freeboard level in uncovered tanks Overfill/spill control equipment Tank monitoring data Hazardous materials/waste containers Aisle space Incompatible material storage areas Safety suggestion box Hazardous material storage/transfer areas Hazardous material tank systems Hazardous waste treatment areas Storm water management structures Employer notices Posting of evacuation map / phone numbers Material safety data sheets Hazardous material/waste containers/labels Emergency alarms Fire extinguishers Emergency equipment and supplies Process area ventilation Housekeeping Employer posters and accident forms Emergency Response Plan review Hazardous material storage tanks X X X X X X X X X X X X X X X X X X X X X X X 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 Reduce hazardous wastewater treatment sludge (F006) generation Improve chrome emission compliance Target • Reduce dragout from nickel plating baths by 25% within 18 months • Continuously train 100% of chrome platers about chrome emission control procedures and recordkeeping • Pilot test three non-cyanide chemistries within 12 months • Hold bimonthly training courses • Train 100% of employees within 12 months • Reduce electricity use 15% within 12 months • Reduce natural gas use 10% within 12 months Improve compliance with wastewater discharge permit limits Use process water more efficiently • Zero permit violations by December 1999 • Reduce water consumption by 20% within 12 months • Continuously train all platers in good rinsing techniques Eliminate cyanide from all plating operations Improve employee awareness of environmental issues and costs Reduce energy consumption 2-19 Element 2.3 The objectives and targets represent the transition from planning to action. Many other EMS elements, particularly • Quantitative measurement and monitoring activities, will be driven by the • Realistic objectives and targets. For this reason, they should be • Linked to a source (of the carefully expressed and energetically communicated to all waste or environmental aspect) 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 with the objectives and targets element. The procedure, 2.3 Objectives and Targets, describes the process your facility should follow to develop and update its environmental objectives and targets. The EMS tools that support this procedure include a matrix that facilitates and documents the process of developing objectives, targets associated with those objectives, and parameters that will be measured to track progress made to meet the objective. Objectives and targets originate from: • Environmental Policy • Aspects and Impacts Review • Compliance Checklist • Corrective and Preventive Action Targets should be: 2-20 Element 2.3 EMS Procedure Effective Date Company Name 2.3 Subject Objectives and Targets Purpose This procedure is used to develop and update the objectives and targets that are addressed by the EMS. 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 1 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. Objectives and targets will be supported and tracked according to procedures described in Element 4.1, Measurement and Monitoring. The impact of corrective and preventive actions on objectives and targets will be evaluated and documented monthly. The environmental manager and other facility personnel will review and update the environmental objectives and targets every months. Objective and target documentation will be retained at the facility for at least 2 years. Step 3 Step 4 Step 5 Step 6 Responsible Person: Signature and Date: 2-21 Element 2.3 Summary of EMS Objectives and Targets Objective 1. Target Deadline 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 Consider what type of actions you are evaluating to achieve targets for objectives. Are there pollution prevention alternatives such as source reduction, material substitution, in-process recycling, or waste minimization, that could achieve your objectives and targets? Try to find an action that addresses the pollution source most directly. Action 1: Deadline: Action Taken: Action 2: Deadline: Action Taken: Action 3: Deadline: Action Taken: Action 4: Deadline: Action Taken: Responsible Person What type of action? Source Reduction Material Substitution In-Process Recycling Reuse Improved Treatment Waste Treatment Compliance Responsible Person: Responsible Person: Responsible Person: 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 Effective Date Company Name 3.1 Subject Roles and Responsibilities Purpose This procedure is used to determine the organizational roles and personnel responsibilities for the company’s EMS. 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. The environmental manager will develop and assign EMS roles and responsibilities and document them using the Responsibility Matrix. The environmental manager will communicate EMS roles and responsibilities to all employees. The environmental manager and other facility personnel will review and update the EMS roles and responsibilities every 12 months. Things to consider in developing and reviewing EMS roles and responsibilities: • • • • • • Capabilities of business Personnel involved Training and resources required Results of previous audits Improvement of current structure Step 1 Step 2 Step 3 Step 4 Integration with other business functions and existing 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 Owner l Manager Manager n Staff Maintenance Accounting Employees Other Superviso r RESPONSIBILITY 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 Effective Date Company Name 3.2a Subject Internal Communication Purpose Step 1 This procedure is used to ensure adequate internal communication about the EMS. 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. The environmental manager will determine the type of information that needs to be communicated. This may be general EMS policy information, individual EMS responsibilities, or specific waste reduction targets and measurements. Methods of Internal Communication: • • • • Staff/employee meetings Newsletters Bulletin boards/posters Brown bag lunches Step 2 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. 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. The environmental manager and other facility personnel designated by the environmental manager will ensure that adequate internal communication is occurring. 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. Step 4 Step 5 Step 6 Responsible Person: Signature and Date: Element 3.2 EMS Procedure Effective Date Company Name 3.2b Subject External Communication Purpose Step 1 This procedure is used to ensure adequate external communication. 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, • Open houses stockholders, regulatory agencies, and emergency • Focus groups responders. The environmental manager will determine the type of information that needs to be communicated. This may be company waste reduction successes, permit applications for new processes, or future plans to change business practices. • • • • • Press releases Annual reports Advertising Community meetings Permits/applications Step 2 Step 3 Based on the audience and the type of information to be communicated, the environmental manager will determine methods of external communication. 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. The environmental manager and other facility personnel designated by the environmental manager will ensure that adequate external communication is occurring. 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. Step 4 Step 5 Step 6 Responsible Person: Signature and Date: Element 3.2 INTERNAL COMMUNICATIONS Form of Communication Type of Information 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 Frequency of Communication Audience Training Staff Meeting Individual Meeting Bulletin Board Newsletter Other Responsible Person Element 3.2 Effective Date EXTERNAL COMMUNICATIONS Form of Communication Type of Information 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 Frequency of Communication Audience Community Meeting Individual Meeting Newsletter Advertising Annual Report Trade Group Other Responsible Person Element 3.2 Effective Date EMERGENCY RESPONSE COMMUNICATIONS Audience Type of Emergency Chemical Release/Spill Emergency Responders Fire Department National Response Center Employees Notify by Sounding Alarm Telling to Vacate the Building Community Notify Neighbors Regulatory Agencies Coast Guard POTW EPA DTSC OSHA Other Worker Injury 911 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 company’s environmental policy, (3) EMS roles and Training Hints: responsibilities, and procedures, and (4) methods and • Use opportunities like safety actions for reducing waste generation and meeting EMS meetings, staff meetings, and objectives and targets. production meetings to provide • “training” and reinforce EMS goals. Consider videotaping training sessions for use later as refreshers or with new employees. Factor training needs and abilities into hiring practices. • Because every employee plays an integral role in the function of a business, it is important that the training needs of all employees be evaluated and met at a level that enables them to support the goals of the EMS in their daily activities. Training should be based on the previous education, training, and work experience of an employee. 3.3-1 Element 3.3 EMS Procedure Effective Date Company Name 3.3 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 Training Resources: conducted to comply with environmental regulations and other training. • Internal trainers A critical first step in developing a training program is to assess employee training needs. The environmental manager and others will review past training and the nature of the employee’s work. Based on this review, specific training requirements for each employee or type of employee will be documented. The training program will be implemented and training dates, subjects, and attendees will be documented. Training documentation will be retained at the facility for at least 2 years. Training effectiveness will be evaluated to ensure that the EMS is being implemented effectively. Improvements to trainings will be made accordingly. • • • • • • Consultants Educational institutions Suppliers/vendors Technical/trade associations Self study Computer-based training Step 2 Step 3 When Training is Needed: • New hire • • • • • Step 4 New job/change in employees role or responsibility Procedure change New process, material, or equipment New regulation Increase employee performance Step 5 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 Topic Title 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. Platers Maintenance Waste Treatment Lab Shift/Line Supervisors Management 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 Effective Date Company Name 3.4 Subject EMS Document Control Purpose Step 1 This procedure governs EMS document control. 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. 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. The index of controlled EMS documents will be updated whenever one of the documents is revised. Step 4 Step 5 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 • Drainage plans should form a team composed 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 Effective Date Company Name 3.5 Subject Emergency Response and Preparedness Purpose This procedure is used to anticipate, document, prepare, and review emergency events and preparedness plans. 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. The environmental manager will prepare and update an Emergency Response Plan that contains all emergency procedures required by local, state and federal regulatory agencies. The environmental manager will familiarize and train employees and emergency coordinators on the procedures described in the Emergency Response Plan. 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. 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. Documentation concerning emergency response and preparedness and emergency incidents will be retained at the facility for at least 5 years. Step 1 Step 2 Step 3 Step 4 Step 4 Step 5 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 Rejects/rework rate Description 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 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 is usually the largest environmental release from a metal finishing facility. 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. 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. 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. 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 offsite disposal. In addition, extending bath life will reduce chemical purchases. 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. 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. Water use Wastewater discharge quality Treatment residuals Chemical use rate Bath dumps Energy use Production 4.1-2 Element 4.1 EMS Procedure Effective Date Company Name 4.1 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. 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 Rejects/Rework Rate Water Use Wastewater Discharge Quality Treatment Residuals Chemical Use Rate Bath Dumps Energy Use Production Data Collection Frequency Step 1 Step 2 The environmental manager and key production staff will identify and measure unique parameters for each EMS objective and target. The environmental manager or designee will measure, monitor, and record targetspecific parameters at a predetermined frequency. 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. Step 3 Step 4 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 correctly or are not periodically reviewed by the person responsible for the procedure. Example 2: Employees are unaware of their EMS-related responsibilities. Example 3: Facility-wide and target-specific data are not evaluated and corrected. Why do EMS problems occur? • • • • • Poor communication Faulty or missing procedures Equipment malfunction (or lack of maintenance) Lack of training Lack of understanding 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 Effective Date Company Name 4.2 Subject EMS Nonconformance Corrective Action Purpose Step 1 This procedure is used to respond to EMS deficiencies and EMS nonconformance. 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. The EMS Nonconformance Corrective Action form will be signed by the environmental manager or designee. The responsible person must report the status of corrective actions to the environmental manager at least every 2 weeks. Completed corrective action forms will be retained on site for at least 2 years after completion of the corrective action. Step 2 Step 3 Step 4 Responsible Person: Signature and Date: Element 4.2 EMS NONCONFORMANCE CORRECTIVE ACTION FORM Problem Identified: Problem Identified By: Resolution Due Date: 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 Effective Company Name 4.3 Subject Corrective and Preventive Action for Compliance Purpose This procedure is used to respond to deficiencies and noncompliance with environmental regulations. 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. 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. The responsible person must report the status of corrective actions to the environmental manager at least every 2 weeks. Completed Corrective and Preventive Action forms will be retained on site for at least 2 years after completion of the corrective or preventive action. Step 1 Step 2 Step 3 Step 4 Responsible Person: Signature and Date: Element 4.3 CORRECTIVE AND PREVENTIVE ACTION FOR COMPLIANCE FORM Noncompliance or Potential Noncompliance Problem Identified: Problem Identified By: Resolution Due Date: 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 Completed: March 15 Possible Solution(s): Due Date: March 15 Completed: March 16 Implemented Solution(s): Due Date: March 17 Completed: March 17 (1) Retrained all platers on treatment/disposal of strippers. (2) Platers drafted new section in employee training manual. Add instructions for stripper treatment/disposal to new employee training manual and train all employees. Employee on copper cyanide plating line dumped cyanide-containing stripper into wastewater. New employee not aware of treatment/disposal process for stripper. 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: Signature and Date: Jim Filtercake 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. Consider combining your records management systems for environmental and health and safety (as has been done in other parts of this EMS Template). Use a computer to maintain records and documents; make records available to employees via a designated computer or via a company network. Consider the need for security. Should access to some records be limited? Should duplicates of some records be maintained elsewhere? Ø Ø Ø Establish a records retention policy considering relevant regulatory requirements and stick with it. 4.4-1 Element 4.4 EMS Procedure Effective Date Company Name 4.4 Subject Records Purpose Step 1 This procedure is used to maintain EMS records. 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. The environmental manager and other facility personnel will maintain all records in a single location. 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. The environmental manager and other facility personnel will identify and note on the document index any restrictions on records necessary for security. The environmental manager and other facility personnel will review the records and purge obsolete records at least every 3 months. Step 2 Step 3 Step 4 Step 5 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 Establish an appropriate audit frequency Train your auditors Maintain audit records • Audit scope (areas and activities covered) • Audit frequency • Audit methods • Key responsibilities • 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 conformance (if you cannot tell whether or not a particular procedure has been followed, then you should consider revising the procedure). During the actual audit, auditors should resist the temptation to evaluate why a procedure was not followed that step comes later. Sources of Evidence • Interviews • Document review • Observation of work practices • • 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 audit scope, schedule, and other pertinent information with the people in the affected area. This will help avoid confusion and will facilitate the audit process. Some Options for Auditing • Barter for audit services with other small companies • Use external auditors • Have office personnel audit production areas (and vice-versa) • • Consider linking your EMS audit program to your regulatory compliance audit process. But keep in mind 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 Effective Date Company Name 4.5 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. 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. 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. 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. The plant areas and people to be audited will be notified a reasonable time prior to the audit. 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 1 Step 2 Step 3 Step 4 Step 5 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. Management in the affected areas and/or functions is responsible for any follow-up actions needed as a result of the audit. Audit reports will be retained for at least 2 years from the date of audit completion. Step 8. Step 9. 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 circumstances might influence the suitability, effectiveness, or adequacy of your EMS. Changing circumstances may be internal to your organization (for example, new facilities, new materials, changes in products or services, and new customers), or may be external factors (such as new laws, new scientific information, or changes in adjacent land use). ü Established a process for periodic reviews of our EMS? ü Documented the results of such reviews? ü Followed up on action items to ensure closure? 4.6-1 Element 4.6 Many of the benefits of an EMS cannot be anticipated beforehand. You will discover them as pleasant surprises, at some point after implementation. They WILL be there. CONGRATULATIONS!! YOU NOW HAVE ALL OF THE ELEMENTS OF AN EFFECTIVE EMS. • Once you have documented the action items arising from your management review, be sure to follow up. Progress on these action items should be tracked. As you evaluate potential changes to your EMS, consider other organizational plans and goals. Environmental decision-making should be integrated into your overall management strategy. • 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 Effective Date Company Name 4.6 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. 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. 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 1 Step 2. 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. 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. Step 4. Responsible Person: Signature and Date: Element 4.6