Practical guide to environmental management for small business · The Practical Guide to Environmental Management for Small Business is your Guide to getting orga-nized and making

Practical Guide to

Management forSmall Business

Environmental

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Acknowledgements

This document was prepared under the direction of the U. S. Environmental Protection Agency’s(EPA) Small Business Division. The EPA Small Business Division wishes to acknowledge thevaluable review and comments received from EPA, state Small Business Assistance Program repre-sentatives, Small Business Ombudsmen, National Compliance Advisory Panel members, tradeassociations, small business owners, and others. Your suggestions and assistance were greatlyappreciated.

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I. Introduction.................................................................................... 3

II. Responsible Environmental Basics—“Have to’s” .................................. 6

III. Saving Money Through Sound Environmental Management ................ 22

IV. Keeping the Program Alive ............................................................. 30

V. Taking it Outside Your Facility ........................................................ 36

VI. Summary ..................................................................................... 39

Contents

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I. Introduction

What is this Guide about?What is this Guide about?What is this Guide about?What is this Guide about?What is this Guide about?

The Practical Guide to Environmental Managementfor Small Business is your Guide to getting orga-nized and making the most of the valuable timeyou and your employees spend on environmentalaffairs. It will help you design a managementplan that addresses all of the environmentalconcerns of your business. The Guide will alsohelp you save money and make your businesslook good in the eyes of your customers andyour community.

As the top person at your business, you haveto make the overall decisions and provide the

driving force for improving environmentalmanagement. But, as a small business, it is likelyto take a team effort to make much progress,and you will probably have to delegate some dayto day environmental activities to others. That iswhy the Guide is written in plain language. It canbe easily understood by everyone at your busi-ness.

As you work through the Guide, you will findsome ideas that you can use right away toproduce immediateresults. Evenmore important,

In a nutshell…In a nutshell…In a nutshell…In a nutshell…In a nutshell…

Do you as a small business owner feel like environmental management equals crisis management? Everwonder how to get control of all the environmental issues at your business once and for all withoutsinking too much time and money into it? Don’t know where to start? This Guide will help you get ahandle on these questions and maximize the cost savings and other benefits associated with goodenvironmental management. Following the Guide’s step-by-step process, you will learn what goodenvironmental management is and how environmental management duties can slowly be pulled intoeveryday activities without disruption. The end result will be that you can feel confident that yourcompany is in compliance with environmental regulations, your employees are saving time and money,and you are better able to chart your company’s future. So, go ahead and plant the seed to cultivate areliable, responsible, and efficient environmental management program for your business!

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by going through the Guide step-by-step, youwill gradually be able to create an effectivesystem to manage your environmental responsi-bilities and make it much easier and less timeconsuming to meet regulatory requirements—one that will improve as time goes on.

Here is a quick preview of eachHere is a quick preview of eachHere is a quick preview of eachHere is a quick preview of eachHere is a quick preview of eachGuide Section.Guide Section.Guide Section.Guide Section.Guide Section.

Section II covers the basicsyour business must have inplace to meet the require-ments of environmentalregulations and to keepemployees, the commu-nity, and the environmentsafe. (Don’t get discour-aged: the following Sectionswill show you how to makethese tasks more manageable astime goes on.)

Once you have the basics in place, you canbegin to take advantage of the business benefitsof environmental management by workingthrough Section III. This Section shows youhow to use information you developed whileworking through Section II to find ways to savemoney by conserving water and energy andreducing waste.

Section IV is about taking your early effortsand getting them organized by writing a policy,streamlining who does what, and measuringprogress. This enhances your business by making

I. Introduction

sure that environmental efforts support yourbusiness strategy, that responsibilities arehandled in a productive way, and that you aremoving forward—not spinning your wheels.

Section V explains why it is valuable to shareyour environmental efforts with those outsideyour business. It provides suggestions forshowing off your environmental successes to

customers and your community andfor partnering with suppliers and

others to improve yourbusiness’ environmental

performance.

Section VI looks at anapproach called an envi-ronmental management

system (EMS) which iswhat all the other Sections of

the Guide lead up to. For thoseof you who like to read the back of

the book first, you might want to glance atSection VI to get a better idea of where theGuide is headed.

The steps outlined in the Guide can be fitinto the time you and your employees haveavailable and the workflow of your business. Itcould take a month to work through the Guideif you can devote some sizeable chunks of timeto it, or more than a year if time is more re-stricted, but the end result will be equally sound.The important thing is to devote regular atten-tion to it while not detracting from your criticalbusiness functions.

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I. Introduction

The Guide will help you develop a soundapproach to environmental management.However, it is not a manual on environmentallaws and regulations. It will not tell you thedetails of what you need to do to comply withspecific regulations. However, the Guide doestell you who you can rely on for help withunderstanding environmental regulations, andhow this important step fits into the overallenvironmental management strategy.

Here’s a vision of what you can achieve byworking through this Guide: You will understandall the ways your business affects the environ-ment. Your employees will be prepared to handlespills, they will know how to keep safe, and yourbusiness will fulfill the requirements of environ-mental regulations. You will find ways to savemoney, increase productivity, and maybe evenlessen regulatory requirements. Environmentalmanagement responsibilities will be efficientlyorganized and delegated within your business,and good practices will make compliance easier.By being better organized and taking a strategicapproach to environmental management, youand your staff will spend less time on it, yet yourbusiness will continue to improve its environ-mental performance. Your environmentalmanagement program will be so good that youwill be able to show it off to customers and yourcommunity.

The Guide is designed to go hand in handwith the U.S. Environmental Protection Agency(EPA) Workbook, Documenting Your EnvironmentalManagement Plan—A Workbook for Small Business.

The Guide provides an explanation of the stepsto take to improve your business’ environmentalmanagement activities. The Workbook gives youa place to keep and organize all of the informa-tion you compile while working through thedocument. If you would like to obtain a copy ofthe Workbook, call EPA’s Small Business Divi-sion at 800-368-5888 or download it fromwww.epa.gov/ems/or www.smallbiz-enviroweb.org.

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II. Responsible Environmental Basics—“Have to’s”


Now that you’ve planted the seed, you need to take care of the seedling. This Section of the Guideexplains how to put in place the critical functions a business must have to keep employees safe, preventand be prepared for spills, and comply with regulations. It is vital to get these functions under controlfirst because failing to do so poses a high legal and financial risk to your business. By working throughthis Section with your employees, they will develop good habits that will make regulatory compliancepart of the daily routine and save time down the road. The ideas in this Section will get you organizedand help you make sure you’ve got the basics covered using a logical and systematic approach: Firstyou will learn how to develop a process map to quickly get a handle on how your business affects theenvironment. In turn, this will help you determine what environmental regulations may apply to yourbusiness. Then, with this background, you can put in place the essential activities of sound environmen-tal management—being prepared for spills, labeling, housekeeping, training, recordkeeping, and beingready for a regulatory inspection. These activities will tie together to provide a safeguard againstunexpected and costly environmental problems at your business. They will also provide a solid founda-tion that you can build on as you work through later Sections of the Guide to attain real cost savingsand increased productivity for your business.

How can I understand how myHow can I understand how myHow can I understand how myHow can I understand how myHow can I understand how mybusiness is affecting thebusiness is affecting thebusiness is affecting thebusiness is affecting thebusiness is affecting theenvironment?environment?environment?environment?environment?

You know how when you open the box of anew electronic gizmo like a computer or DVDplayer, there is usually a handy picture laying ontop showing you how to connect all the parts?This part of the Guide explains howto create a picture of your company’sprocesses that is just as handy. Thispicture, called a process map, willshow what comes in and what goesout of the process. The process mapis a great tool for environmentalmanagement because it will help yousee how your business affects theenvironment. This will help you

figure out what regulations might apply and atwhat points in the process you need to keeprequired records. Because it shows the flow ofchemical products through your business, itallows you to identify the areas where spills aremore likely to happen, where housekeeping maybe a big concern, and what kinds of labels areneeded. You can make sure you are providing

training that fits each employee’sresponsibilities by looking at whichsteps in the process map they areinvolved with.

Getting started is easy. Look overthe example in Figure 1 to get anidea of what your picture can looklike and fill in the blanks. Begin withthe basics: the raw materials, the

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II. Responsible Environmental Basics—“Have to’s”Figure 1: Generalized Process Flow Diagram

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process, and the product. Good start, but it isn’tthe complete picture. The process probablyrequires additions other than just the rawmaterials. Do you use a tool or dispenser tointroduce a raw material to the process? Do theraw materials feed through some type of ma-chine? If so, there are elements or processesrequired to make it work—probably a powersource, possibly oil, filters, or parts that arereplaced when they are used up. As you examineall the steps in the process and what makes eachof them work, you can add more detail to yourprocess map. At first, this diagram will qualifyrather than quantify the flow of materials—justwhat is involved in the process, not how much.You can plug in numbers later when yourcompany wants to look at process changes andyou need to measure results. When you look atthe process as a complete cycle, the pieces startto fall into place. Raw materials are just one ofthe resources utilized. For example, when youconsider that a specific tool is used and look atthe source of its power, it points out anotherinput for the diagram. Then, you can pinpointoutput details because all the inputs have to leavethe process in some way, shape, or form.

Once you have it, you can get lots of mileageout of your process map as a business manage-ment tool. It helps you think about aspects ofyour process that may have escaped notice in thepast. As you work through later Sections of theGuide, the process map will help you understandhow to improve the process because it helps yousee clearly the inputs and outputs—and associ-ated costs—of each step. Opportunities to

reduce waste or conserve energy will be moreobvious. You might notice that you have a“byproduct,” something that leaves your processas a waste but can be used to benefit someoneelse’s process. They may even be willing to payyou for it. The process map is also a greatplanning tool. As you look for areas to improve,the visual diagram will make it easier for you toexplain your process, where it is now, and whereyou want to go with it. It can also be a great wayto explain a job position to a new employee.

How can I get a handle onHow can I get a handle onHow can I get a handle onHow can I get a handle onHow can I get a handle onenvironmental lawsenvironmental lawsenvironmental lawsenvironmental lawsenvironmental lawsand regulations?and regulations?and regulations?and regulations?and regulations?

If you feel uncertainabout what environmentallaws and regulations applyto your business and whatexactly to do about them,you are not alone. Manysmall business owners,because of their extremely limited time, havedifficulty with this. This part explains why it isvital to your business to take on the task ofunderstanding your environmental legal obliga-tions. It provides an overview of environmentallaws and explains how to use your process mapto get an idea of which areas apply to yourbusiness. Then, it tells you how you can getcompetent help to quickly understand the detailsof what is required of your business.

If you are not careful at the beginning todetermine all of the environmental requirements

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your business must live up to, then your environ-mental management program will be incompleteand maybe even flawed from the get go. Takeextra care with this step and seek outside help.By all means, don’t throw up your hands and giveup—the possibility of a penalty for breakingenvironmental laws—even once, even by acci-dent—is way too big of a risk to take for yoursmall business and the people who work there!

What if I find my business isnot in compliance?

While determining what laws and regulationsapply to your business, you might discover thatyou have not been meeting requirements thatyou should have been in the past. If this hap-pens, the Small Business Policy can help. Thispolicy states that if you are working with yourstate’s Small Business Assistance Program to fixa problem, you will be given at least a 90 daywindow of opportunity to correct the problemwithout the regulatory agency stepping in. Sincethis policy has not been adopted by all states,and some states have modified the policy whenthey adopted it, ask your Small Business Assis-tance Program representative for details aboutthe policy that is in effect in your state.

A second option is to follow EPA Self-AuditPolicy. Under this policy, you can disclose anyviolations you discover to EPA, and yourbusiness will have 60 days to correct the viola-tions after discovery. If your business disclosesviolations under this policy, EPA cannot assessfinancial penalties, except that they may assess

economic based penalties – the amount ofmoney your institution saved while not meetingrequirements. Before entering into a disclosureunder EPA Self-Audit Policy, consult with yourSmall Business Assistance Program representa-tive for advice.

Why comply withWhy comply withWhy comply withWhy comply withWhy comply withenvironmental regulations?environmental regulations?environmental regulations?environmental regulations?environmental regulations?

The most obvious reason is to avoid penaltiesassociated with non-compliance—fines forviolations can be in the thousands—a severeblow to a small business (not to mention theblack mark of being labeled a violator). Howdoes this happen? Certain agencies at thefederal, state, and locallevels are there to see thatbusinesses follow environ-mental regulations. To makethis determination, they cansend inspectors to any business to see first handif it is playing by the rules. Of course, when theyfind problems, your business will be required tofix them. The agency will send an official letterwith the list of the problems or violations. Theywill spell out what they expect you to do abouteach violation and a due date that it must becompleted by. Depending on the violations, yourbusiness may be required to pay monetary fines.The regulator can even close down your businesstemporarily until problems are fixed. It ispossible that the responsible person at yourcompany who has completely failed to takenotice of or severely disregarded the regulationsmay be criminally prosecuted and may even

Why Comply?Why Comply?Why Comply?Why Comply?Why Comply?

!!!!! MonetaryMonetaryMonetaryMonetaryMonetaryfinesfinesfinesfinesfines

!!!!! Your businessYour businessYour businessYour businessYour businesscould becould becould becould becould beclosed downclosed downclosed downclosed downclosed downuntil theuntil theuntil theuntil theuntil theproblems areproblems areproblems areproblems areproblems arefixedfixedfixedfixedfixed

!!!!! CriminalCriminalCriminalCriminalCriminalprosecution orprosecution orprosecution orprosecution orprosecution orjail timejail timejail timejail timejail time

!!!!! ReinspectionReinspectionReinspectionReinspectionReinspection

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serve jail time. Often, regulatory agency staff willdo a follow up inspection to make sure theproblems have really been fixed.

If just dealing with the inspection wasn’tenough, your problems can make the news. Youmay have a difficult time getting your localnewspaper to mention the food drive yourbusiness sponsors, but it’s front page news whenyour business is fined for environmental viola-tions or has an accidental spill. The regulatoryagencies keep records of all violations and theyare public documents. Anyone can ask to seethem—they are allowed to under the “Freedomof Information Act.” People are expressingmore interest these days in knowing what thecompanies in their community are doing. EPA’swebsite is experiencing 40 million hits permonth. Real estate search engines can findenvironmental problems in areas surrounding aproperty. Not only can a negative image hurtsales in your local market, it can also hinder anyexpansion activities you may plan. This isbecause some expansions require an environ-mental permit before you can proceed. When acompany is applying for a new permit, there is apublic comment period and often a publichearing. If your company has a bad reputationfor environmental harm, members of yourcommunity are likely to oppose the permit,causing a delay. If the public is really opposed,the permit may not be issued at all, jeopardizingyour expansion plans.

Compliance with environmental regulationswill help retain the value of your property. Any

negative environmental impact can decrease yourproperty value. Before loaning money, banksusually require buyers to pay for a professionalreview of previous property uses to see if theproperty may have been contaminated in someway. Because of this, if you ever need to changelocations or use your property for collateral, itwill become important to be able to show thatyour activities have not caused contamination.Good documentation that your company is incompliance with environmental regulations canprotect you from having to pay for past contami-nation to your site. Likewise compliance withregulations can lower the cost of liability insur-ance, because insurance companies will have lessconcern about the future costs of a clean-up orthe risk of harm to the health of your employeesand community.

Why can’t I wait until someoneWhy can’t I wait until someoneWhy can’t I wait until someoneWhy can’t I wait until someoneWhy can’t I wait until someonetells me what to do?tells me what to do?tells me what to do?tells me what to do?tells me what to do?

There are a lot of environmental laws outthere and not all of them matter to your busi-ness. Why should you weed through all of thatnow instead of catching up on work that shouldhave been done yesterday? Why not wait until aninspector shows up, takes a tour, and creates alist of burning issues—signed, sealed, anddelivered? After all, the bureaucrats createdregulations that no one else can understand—letthem tell you what you are supposed to be doingabout the whole mess. Well, sorry to say, this isnot the easy way out.

First, not understanding what regulations

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apply to your business is not an acceptableexcuse for failing to meet the requirements. Justas you can be ticketed for breaking a traffic lawwithout being aware of it or penalized for amistake in a tax return or failure to pay enough,ignorance of the rules does not protect youfrom enforcement, even criminal enforcement.

Second, although an inspection will provideyou with a handy list of things that you need todo, dropping everything to meet the imposeddeadlines can cost more than would have beeninvested to get into compliance in the first place.You will not have the luxury of time to look forthe least expensive and disruptive way to workwithin the rules.

What regulations might impactWhat regulations might impactWhat regulations might impactWhat regulations might impactWhat regulations might impactme?me?me?me?me?

‘There are so many environmental laws andregulations that they fill many books. Whenyou’re already swamped with day to day business,how can you find out which regulations areimportant without wasting too much time? Agood place to start is to pull out your processmap and think about how your businessactivities could affect the environment. Youbring in raw materials and after some work isdone, they leave as a product. Or, maybe youuse raw materials to perform a servicethat fixes, improves, or cleans some-thing for your customer. But, what elseis going on? Is the air and water leavingyour property the same as when it camein? If your process has leftovers that

may be contaminated by chemicals—even in tinyamounts—they could be regulated. Where dothey go? To a storm drain or sanitary sewer? Tothe dumpster? Perhaps you keep materials onyour property that could cause a spill if theircontainers leaked. As you think about thesequestions, this is a good time to add to yourprocess map any new inputs or outputs you havethought of. Now you are ready to take a look atthe table at the back of the Guide called “MajorCategories of Environmental Regulations.”Although it doesn’t cover every last environmen-tal regulation, and provides only a generalpicture, it will give you a good idea of commonregulations that you should be concerned aboutas well as ones that are not likely to apply.

How can I get more informationHow can I get more informationHow can I get more informationHow can I get more informationHow can I get more informationabout regulations that mayabout regulations that mayabout regulations that mayabout regulations that mayabout regulations that mayapply to my business?apply to my business?apply to my business?apply to my business?apply to my business?

This Guide would be too long and compli-cated if it gave you detailed information on eachregulation, and it would go out of date quickly.Besides, the table in the back of the Guide

covers federal regulations only. You alsoneed to look at your state’s require-

ments, and maybe even thoseof your city or county.Fortunately, you can call your

state’s Small Business Assis-tance Program to help you.

Just a phone call away is aperson who’s not a regulator oran inspector but has the

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experience and know-how to help you cutthrough the red tape and quickly figure out whatregulations apply to your business. After all, youcall a tax auditor to be sure you have filed yourtaxes properly, don’t you? In the same way, youmay need an expert to help you take care of allthe nitty gritty details of environmental compli-ance. If you need assistance finding the phonenumber and contact person for the SmallBusiness Assistance Program in your state, callEPA’s Small Business Division at 800-368-5888or go to www.smallbiz-enviroweb.org/.

Consultation with your Small BusinessAssistance Program is free of charge. Also, ifyour business seeks help from your SmallBusiness Assistance Program, the Clean Air ActCompliance Assistance Enforcement Policy cangive you some leeway to correct any problemsthat you find without triggering enforcement.Some states have similar policies or agreements.

As you work with your Small BusinessAssistance Program contact, ask himor her to help you write down theactions you need to take to complywith each regulation that applies toyour company. These actions mightinclude training, labeling,recordkeeping, filing reports, andothers. Once you have a goodhandle on what regulations apply toyour business and what specificactions you need to take to comply,you can go about getting to it. But,don’t forget that regulations are

notorious for changing often. You also need tofind a way to stay on top of this so you don’t getout of compliance by accident. One way is toattend an update conference on the regulationsthat apply to your business once a year or so. Or,you could just put a tickler on your calendar tocall the Small Business Assistance Program on aregular basis and ask them to help you stay in theloop.

What are the basics of goodWhat are the basics of goodWhat are the basics of goodWhat are the basics of goodWhat are the basics of goodenvironmental management?environmental management?environmental management?environmental management?environmental management?

Now that you understand the ways yourbusiness can affect the environment and whatenvironmental regulations your business has tocomply with, you are ready to put in place thebasics of good environmental management:preventing and being prepared for spills, makingsure all chemical materials have proper labels,practicing good housekeeping, training employ-

ees in their environmental responsibili-ties, keeping good records, andbeing prepared for a regulatoryinspection. This part begins with

spill preparedness because it needsto be among your highest priorities as

a small business owner. Having a spillcan be a nightmare, especially if it gets off

of your property and contaminates a water-way or groundwater. A spill can injure youremployees or make them sick. It can lead tofires and other property damage. It canbecome a source of bad press and jeopar-

dize your relationship with the community.Having a high profile spill is a sure way

Fines can add upFines can add upFines can add upFines can add upFines can add upto large sums. Ato large sums. Ato large sums. Ato large sums. Ato large sums. Akitchen and bathkitchen and bathkitchen and bathkitchen and bathkitchen and bathcabinet companycabinet companycabinet companycabinet companycabinet companywith 50 employ-with 50 employ-with 50 employ-with 50 employ-with 50 employ-ees was finedees was finedees was finedees was finedees was fined$25,000 for$25,000 for$25,000 for$25,000 for$25,000 forneglecting to fileneglecting to fileneglecting to fileneglecting to fileneglecting to filean annual reportan annual reportan annual reportan annual reportan annual reportunder EPCRA.under EPCRA.under EPCRA.under EPCRA.under EPCRA.The fine wasThe fine wasThe fine wasThe fine wasThe fine wasbased on $5000based on $5000based on $5000based on $5000based on $5000per report timesper report timesper report timesper report timesper report times5 years. The5 years. The5 years. The5 years. The5 years. Theregulation citedregulation citedregulation citedregulation citedregulation citedallows for finesallows for finesallows for finesallows for finesallows for finesup to $25,000up to $25,000up to $25,000up to $25,000up to $25,000per violation,per violation,per violation,per violation,per violation,which wouldwhich wouldwhich wouldwhich wouldwhich wouldhave added uphave added uphave added uphave added uphave added upto $125,000. But,to $125,000. But,to $125,000. But,to $125,000. But,to $125,000. But,the ‘low’ penaltythe ‘low’ penaltythe ‘low’ penaltythe ‘low’ penaltythe ‘low’ penaltywas allowedwas allowedwas allowedwas allowedwas allowedbecause it was abecause it was abecause it was abecause it was abecause it was asmall businesssmall businesssmall businesssmall businesssmall businessusing smallusing smallusing smallusing smallusing smallamounts ofamounts ofamounts ofamounts ofamounts ofchemicals.chemicals.chemicals.chemicals.chemicals.

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to get an inspector to showup at your business. And,on top of all that, even asmall spill can cost thou-sands to clean up.

Working on spillpreparedness naturally leads to working on someof the other basics. Having proper labels oncontainers makes it much easier to handle a spillbecause you know what you are dealing with.Practicing good housekeeping helps keep spillsfrom happening. Since a spill situation can bedangerous, it is sensible to make sure everyone istrained so they know how to keep safe and whatto do the moment a spill happens. Having goodrecordkeeping in place helps ensure that thechemical incident response plan is readilyavailable as well as the response call list. If a spilldoes trigger a regulatory inspection, you will beable to handle it better if you have a game planand employees know what is expected of them.This illustrates how the basics of good environ-mental management inter-relate, so that doing agood job in one area has a positive effect onperformance in the other areas.

Prevent and Be Prepared for Spills. Acommon cause of spills is the container: either itis so old and decrepit that it springs a leak, orsomeone knocks it over or drops it. There areseveral easy ways to prevent this. Make sure allemployees who work with chemicals know thesetips:• Take a close look at the chemicals in your

work area every week or so. If you notice


any containers in bad condition, get rid ofthem (using proper disposal methods) ortransfer their contents to a new container.Check to see that containers have good capsthat are tightly closed.

• Put containers holding hazardous chemicalsor wastes into other containers, trays, or drippans to catch and contain any chemical thatspills or leaks out.

• When you move a chemical container fromone place to another, place small containersin a bucket or pail. Place larger containers ina tub with hand grips or onto a cart withsides on it that will prevent any spill fromflowing off.

• When transferring a chemical from itsoriginal container, be sure the new containerwill safely hold the chemical you are pouringinto it: Is it made of a material that won’treact with or dissolve in the chemical? Doesit have a tight fitting cap? Be careful not tooverfill the new container.

Another good thing to do is to locate all thedrains on your property, both indoors andoutdoors, and determine where they go to. Ifyour building is old, you may be surprised to findthat the drain you were sure led to the sanitarysewer and your local wastewater treatment plantactually connects to the storm sewer system thatdrains directly to a lake or river.After you go to all thistrouble, mark your drainsaccordingly.Consider placingeasy-to-use drain

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covers and spill supplies close by drains to closethem off from a spill if you have time and it issafe to do so.

If you don’t have a chemical incident re-sponse plan, make it a high priority to developone. Chances are you have to have some type ofincident response plan anyway to comply withregulations. This doesn’t mean your employeeshave to know how to clean up a spill by them-selves. In fact, they should not clean up chemicalspills at all, except for tiny ones, unless they havehad extensive training. But, anyone in yourbusiness who works with chemicals should knowhow to keep themselves and their coworkers safeif there is a spill and who to call for help. Takesome time to ask about the capabilities of yourcity or county emergency services. Do they havea hazardous materials response team (oftencalled a hazmat team)? If so, do they have thenecessary equipment and training to clean up thetypes of spills that could happen at your place?If you call them in, how much will it cost?Answer these questions before you have a spill inprogress and things are going to go a lot moresmoothly.

Train employees. Too often, the environ-mental management program hides infiles and reports and never gets outto where the rubber meets theroad. You can have the greatestideas in the world to protect theenvironment, and even somethat will save money to boot,but nothing will come of themif employees don’t know about

them. This sounds obvious until you rememberthat at most small businesses everyone is shorton time. Because of this, it is not unusual thatwhat needs to be done never gets communicatedto who needs to do it. A well thought outtraining program is like sunlight to your seedlingenvironmental management program. It ener-gizes employees because training sheds light onwhat they need to be doing.

Here are some tips for setting up and manag-ing your training program:• As you get your training up and running, set

priorities—(1) train those who handlechemicals to use them safely and on what todo if there is a spill or release, (2) make sureyou have training programs as required byregulations (contact your Small BusinessAssistance Program if you don’t know), (3)train them on additional good practices.

• Use your process maps to discover whosejobs involve tasks that could affect theenvironment.

• Develop a list of training topics that makesense for each job, beginning with trainingrequired by regulations. You can use a matrixto help with this (Figure 2). These tools canhelp you set up training efficiently so each

employee gets the training he or sheneeds, but does not sit throughtraining they don’t need (a good

way to make them mad at you andlose interest).• If your business already hasa strong employee safetyprogram, build your environ-

mental training into the existing

Document anyDocument anyDocument anyDocument anyDocument anytraining even if ittraining even if ittraining even if ittraining even if ittraining even if itis an informalis an informalis an informalis an informalis an informaltailgate session.tailgate session.tailgate session.tailgate session.tailgate session.Keep a record ofKeep a record ofKeep a record ofKeep a record ofKeep a record ofwho was trained,who was trained,who was trained,who was trained,who was trained,the topic, thethe topic, thethe topic, thethe topic, thethe topic, thedate, how long itdate, how long itdate, how long itdate, how long itdate, how long itwas, andwas, andwas, andwas, andwas, andwhether it waswhether it waswhether it waswhether it waswhether it wasclassroom, one-classroom, one-classroom, one-classroom, one-classroom, one-on-one, or on-on-one, or on-on-one, or on-on-one, or on-on-one, or on-the-job. If train-the-job. If train-the-job. If train-the-job. If train-the-job. If train-ing involves aing involves aing involves aing involves aing involves anew task, offernew task, offernew task, offernew task, offernew task, offerto help theto help theto help theto help theto help theemployee theemployee theemployee theemployee theemployee thefirst time theyfirst time theyfirst time theyfirst time theyfirst time theyundertake theundertake theundertake theundertake theundertake thetask, or teamtask, or teamtask, or teamtask, or teamtask, or teamhim or her uphim or her uphim or her uphim or her uphim or her upwith an em-with an em-with an em-with an em-with an em-ployee experi-ployee experi-ployee experi-ployee experi-ployee experi-enced in theenced in theenced in theenced in theenced in thetask. Thistask. Thistask. Thistask. Thistask. Thiscounts as train-counts as train-counts as train-counts as train-counts as train-ing too.ing too.ing too.ing too.ing too.

15


safety training to be more efficient withemployees’ time and to help them betterunderstand the big picture. For example, ifyou are already doing OSHA Right-to-Know(Hazard Communication Standard) training,which is about how to keep safe when usingchemicals, it is a simple thing to add a shortsegment on how to properly handle anddispose of wastes associated with the use ofthat chemical.

• Make sure those in your business who are

doing training are available for follow upquestions and know ahead of time who tocall if someone asks a question they don’tknow the answer to. (Your Small BusinessAssistance Program contact can help heretoo.)

Label Hazardous Materials and WastesProperly. Have you ever looked at a glass jar ofclear liquid in your maintenance cabinet trying toremember what it is? You think on it and narrow

Employee’s Name: John DoeEmployment Date: March 21, 2000Termination Date:Job Title: Press Operator

Note: OJT refers to On the Job Training.

Required Training:• Hazardous Waste—initial and annual.• Incident Response—initial, annual drill, incident

critiques, and when plan changes.• DOT—initial Awareness, initial Function Specific,

three-year refresher.• Storm Water—per permit, annual.• Air—per permit, initial and when permit changes

affect press operation.Training

Hazardous Waste

Incident ResponsePlan

DOT Hazmat

Storm Water

Air Permit

Initial

3/30/00

3/30/00

Awareness: 3/30/00Function Specific:4/12/00

3/30/00

3/30/00

2001

Annual Refresher: 3/15/01Update (OJT):

Drill: 1/10/01Incident Critique: 2/23/01Plan Update: 3/15/01

Update (OJT): 3/11/01

Update (OJT): 2/29/01

2002 2003

Figure 2: Sample Employee Training Matrix

16

it down to one of twothings: a xylene-based paint

thinner or a paint strippercontaining methylene chloride.This is a serious problembecause these products havevery different hazards. The

paint thinner is flammable while the stripperis not. The stripper is a lot more toxic than thethinner. You can’t even dispose of it properlybecause they each have a different hazardouswaste code. To prevent this headache, when youlook over your chemicals to check for leaks andbad containers, check the labels too. If any arefalling off or fading, write the label informationon a fresh sticker and attach it to the container.When transferring chemicals from the originalcontainer to another one, label the new containerright away so you won’t forget what it is. Whendeciding on a label for a waste container, bespecific. If not, too soon you will have a mixtureof wastes that will be hard to classify, unsafe tohandle because you don’t know what’s in it, andmore costly to ship out.

When deciding on a label for a waste con-tainer, it makes a big difference whether or not itis a “hazardous waste” as defined by regulations.Hazardous wastes have particular requirements,including labeling. You should still label wastesthat are not hazardous so you don’t get themmixed up with hazardous wastes and becausemany non-hazardous wastes still pose hazards toyour employees. Here are some examples ofgood labels for waste containers that might befound in your small business:

Important Note: The above labels meetcertain hazardous waste requirements only.There may be additional labeling requirementsdepending on the regulations that apply to yourbusiness. If you are not sure what labels arerequired, consult with your Small BusinessAssistance Program contact.

Maintain Good Housekeeping. Here aresome signs that you need to devote more time tohousekeeping:• You find yourself ordering a chemical

product that you already have because yourshelves were so cluttered when you lookedfor it you couldn’t see it was there.

• You pick up a spray paint can out of thestorage cabinet only to discover that it isempty.

• You open the shop door and knock over acan of paint that was sitting just inside.

Here are some goals to strive for:• You open any storage cabinet and can tell at

Waste PartsWaste PartsWaste PartsWaste PartsWaste PartsCleanerCleanerCleanerCleanerCleaner(contains(contains(contains(contains(containsmethylenemethylenemethylenemethylenemethylenechloride)chloride)chloride)chloride)chloride)

Waste PaintWaste PaintWaste PaintWaste PaintWaste PaintThinnerThinnerThinnerThinnerThinner(contains(contains(contains(contains(containsxylene)xylene)xylene)xylene)xylene)

Waste EtchWaste EtchWaste EtchWaste EtchWaste EtchBathBathBathBathBath

(contains(contains(contains(contains(containssulfuric acid)sulfuric acid)sulfuric acid)sulfuric acid)sulfuric acid)

Paint StripperPaint StripperPaint StripperPaint StripperPaint StripperWasteWasteWasteWasteWaste

(contains(contains(contains(contains(containsmethylenemethylenemethylenemethylenemethylenechloride)chloride)chloride)chloride)chloride)


17

a glance what products are there andwhether any containers have leaked orspilled.

• There is a list nearby to check off chemicalsthat need reordering.

• Chemical containers are situated safely—thatis, away from the edges of shelves, awayfrom high traffic areas, and out of the wayof swinging doors.

• Empty containers are marked as such andproperly disposed of right away, or at leaststaged at a labeled bin or shelf, so they don’tget confused with products still in use.

• You cannot find a container without a labelanywhere in your business.

• At the end of a shift, your employees tightlyclose any chemical containers they are usingand return them to their designated storagespace.

• You have supplies and personal protectiveequipment (also called PPE, e.g., safetygoggles and protective gloves) for safelycleaning up small spills in each work space ina location that is easy to get to and wellmarked, and employees are trained on whenand how to use them.

If you think your housekeeping is in prettygood shape, invite your local fire inspector in fora look. He or she will probably give you a fewmore ideas. Getting your housekeeping in orderis like weeding—it’s a pain in the neck but it hasto be done so you can see whether anythingworthwhile is under all the clutter.

Keep records of your efforts and suc-cesses. Good records tell you at a glance what’sgoing on and what needs to be done on a regularbasis (like annual training or weekly inspections).They put you in a better position to pass aregulatory inspection. Most inspectors start witha close look at your environmental records.Records in good shape start you off on a goodnote. It pays to be clear on what files you musthave to be in compliance and get them organizedfirst. After that, you can decide what informationhas additional value to you. Some records areessential to protect you from legal and financialtroubles down the road. Others can give youvaluable data on business performance, or comein handy when you want to show your customersand neighbors that your business is “green.”

The Sample Master File List in Figure 3 givesyou a simple system to organize your environ-mental management files and records. It coversthe most common environmental filing andrecordkeeping requirements, the ones that applyto most small businesses, so you can use it as astarting point. However, be sure to go back andlook at the records and documents that you arerequired to maintain by the particular regulationsthat apply to your business to make sure nothingis missing. Consult your Small Business Assis-tance Program contact again if you are not sure.Table 2 summarizes the information in theMaster File List, explains why each file needs tobe maintained, and provides guidelines for howlong files and records need to be kept.


18

While thinking about files, here is an impor-tant point. Make sure that all critical communica-tions with regulators are documented. Either askthe regulator to send you something in writing(e.g., letter, regulation, interpretation) or writedown your understanding of what was said in aletter, send it to the regulator, and keep a copy inyour file. Also keep a copy of all importantcorrespondence, such as permit applications,required reports, or written responses to regula-tory inspection citations, and send the originalcertified mail with return receipt.

Be Prepared for a Regulatory Inspection.Maybe you think it can’t happen to you becauseyour business is too small. But, if you do getinspected—even just once—it will pay to beprepared. Knowing what to expect will help yoube more confident and less stressed during aninspection.

Before an inspection takes place, decide whocan best answer questions about your business’compliance with environmental regulations whilealso having a good grasp of its operations.Designate a primary contact and a back-upperson. Both should have access to the files,records, and locations within the business that aninspector may want to look at.

Let’s say you, as the business owner, are theprimary contact. Tell front office staff that if aninspector drops by, they should welcome him orher and call or page you or your back-up. Onceyou get the call, get there as soon as possible.When you first meet the inspector, it is appropri-ate to ask for some identification and for

information about the kinds of issues he or sheis interested in. The inspector will usually look atrecords first and then ask for a tour of youroperations. Be sure to provide appropriatepersonal protective equipment (safety glasses areusually a minimum), then take the inspector toany place in your facility they request. Takethorough notes during the inspection. If theinspector takes a sample (such as a wastewatersample) ask him or her to split the sample withyou so you can have your own analysis done laterif you choose to. Take photos of whatever theinspector photographs. If you can, directemployees to immediately correct any problemsbrought up by the inspector, as long as youclearly understand what needs to be done.

At the end of the inspection, if you arecomfortable doing so, ask the inspector what heror his impression was to get a sense of whereyou stand. After the inspector leaves it may takeweeks or even months for you to receive afollow up letter from the regulatory agencystating the results. But, don’t consider the matterclosed until you receive a letter that says so. Ifyou are served with a Notice of Violation orother citation as a result of the inspection don’tpanic. Ask your contact at the Small BusinessAssistance Program to help you respond. Theycan help you understand what corrective actionsyou must take and how soon. They may be ableto serve as a go between and advocate for you.Finally, try to keep a positive outlook. Goingthrough an inspection can be a stressful anddisruptive experience, but you will get through it.Afterwards you will know better how yourenvironmental management program is doing.


19

General Environmental Management FilesFacility ID number(s)—In many states, the regulatory agency assigns an ID number to your facility that applies agency-wide.Keep this on file so you can find it when talking to regulators, or when visiting the regulatory agency to look at files or recordsthey have about your facility.

Spill Response—Keep copies of all your spill response plans and associated documents here. At the top of each plan, keep acurrent call list for your on-site emergency coordinators and off-site responders (e.g., city hazmat team). If these contacts arethe same for all plans, place the call list in a separate, well marked file folder at the front of this part of files. Do the same forlisting phone numbers you would use to report a spill to regulatory agencies (e.g., state spill response hotline, State Emer-gency Response Board, National Response Center). Helpful categories could include:• Incident response call list and decision tree• Spill reporting call list• Hazardous waste spill response plan• SPCC plan• Storm water spill preparedness plan

Within each plan file include:• Copy of plan• Summary of annual plan exercises• Documentation and critique of incidents that triggered the plan

Interaction with Regulators—Keep a record of all your interactions with regulators here, except for information directly relatedto a specific environmental permit, which should be kept in the permit file. This includes copies of any letters you send toregulators and brief notes of any conversations you have with them—not just the stuff they send to you. If you act based ontheir answer to one of your questions and someone later disagrees, it will help to be able to show who gave you thatinformation and when. If there isn't a lot of information, you may be able to keep it all in one file. If not, consider breaking it upinto files for each agency (e.g., EPA, your state environmental regulatory agency, municipal sanitary sewer authority, localsolid waste authority) or by areas (e.g., air, water, waste, emergency response). It's best to keep these documents in order bydate so you can easily lay your hands on the information when you need it. The information in these files should include:• Regulatory inspections (active and closed, filed by agency)• Reports of spills or releases• Other correspondence with regulatory agencies

Training Records—While many different environmental regulations require training, most companies find it easiest to organizethem according to employee. For each person, place the matrix of the training they need to meet their job responsibilities (asexplained in the previous Section) in the front of their training folder. Behind this, keep the employee's training certificate andan agenda or topics list for each training session. Place this information in chronological order, and use the matrix to quicklypull training records needed during an inspection. Some regulations (such as hazardous waste) require that you write outeach employee’s duties in that area. If possible, append these to the employee's position description in their personnel file soit is clear that he or she is working within the scope of their job when doing hazardous waste or other environmental duties.

Figure 3: Master File List


Use red fileUse red fileUse red fileUse red fileUse red filefolders or filefolders or filefolders or filefolders or filefolders or filetabs for yourtabs for yourtabs for yourtabs for yourtabs for youremergencyemergencyemergencyemergencyemergencycontact files socontact files socontact files socontact files socontact files soyou can get youryou can get youryou can get youryou can get youryou can get yourhands on themhands on themhands on themhands on themhands on themquickly during aquickly during aquickly during aquickly during aquickly during aspill or emer-spill or emer-spill or emer-spill or emer-spill or emer-gency.gency.gency.gency.gency.

Write downWrite downWrite downWrite downWrite downcontact informa-contact informa-contact informa-contact informa-contact informa-tion for regula-tion for regula-tion for regula-tion for regula-tion for regula-tors you commu-tors you commu-tors you commu-tors you commu-tors you commu-nicate with oftennicate with oftennicate with oftennicate with oftennicate with oftenon the inside ofon the inside ofon the inside ofon the inside ofon the inside ofthe file folder forthe file folder forthe file folder forthe file folder forthe file folder foreasy access.easy access.easy access.easy access.easy access.

If your companyIf your companyIf your companyIf your companyIf your companyhas a spread-has a spread-has a spread-has a spread-has a spread-sheet or data-sheet or data-sheet or data-sheet or data-sheet or data-base computerbase computerbase computerbase computerbase computerprogram, youprogram, youprogram, youprogram, youprogram, youcan keep eachcan keep eachcan keep eachcan keep eachcan keep eachemployee’semployee’semployee’semployee’semployee’straining matrixtraining matrixtraining matrixtraining matrixtraining matrixelectronically,electronically,electronically,electronically,electronically,and print a hardand print a hardand print a hardand print a hardand print a hardcopy to put incopy to put incopy to put incopy to put incopy to put inthe file.the file.the file.the file.the file.

20

Media-specific Environmental Management FilesWaste Management—Keep all information associated with management of your business' waste streams in this file.Suggested categories include:• EPA Generator ID number(s)• Current hazardous waste permit and associated documents and correspondence (if applicable)• Records of waste determination (information you used to tell whether a waste is hazardous or not; keep them

even if the waste is not hazardous)• Hazardous waste shipment paperwork• Special waste shipment paperwork, including, but not limited to:

• Universal waste batteries• Universal waste lamps• Universal waste mercury switches• Used oil• PCB and non-PCB Ballast recycling

• Solid waste tipping records• Inspection logs

Air Management• Current permits for major or minor sources and associated documents and correspondence• Emission calculations for Potential to Emit (PTE)• Annual air toxics inventory• Inspection records and chemical usage records as required by permit conditions (e.g., VOC records, pressure

drop inspections, operating hours).

Wastewater Management• Correspondence with local wastewater treatment plant authority• Copy of current sanitary sewer ordinance• Pre-treatment permit (if applicable) and associated documents and correspondence

Storm Water Management• Inventory of storm water drainage and outfalls from your property (include map)• Storm water pollution prevention plan• Maintenance plan for storm water infrastructure• Storm water permit (if applicable) and associated documents and correspondence• Storm water annual reports and sampling results (if applicable)

Figure 3: Master File List (cont’d.)


In the languageIn the languageIn the languageIn the languageIn the languageof environmentalof environmentalof environmentalof environmentalof environmentalmanagement,management,management,management,management,the term “me-the term “me-the term “me-the term “me-the term “me-dia” refers todia” refers todia” refers todia” refers todia” refers tohow pollutantshow pollutantshow pollutantshow pollutantshow pollutantscan get into thecan get into thecan get into thecan get into thecan get into theenvironmentenvironmentenvironmentenvironmentenvironmentsuch as waste,such as waste,such as waste,such as waste,such as waste,water, or air.water, or air.water, or air.water, or air.water, or air.

21

What to Include

Facility ID number(s)

Spill Response

Interaction withRegulators

Training Records

Waste Management

Air Management

Wastewater Management

Storm Water Management

Why?C1 L2 GMP3

!!!!!

!!!!! !!!!! !!!!!

!!!!!

!!!!! !!!!! !!!!!

!!!!! !!!!! !!!!!

!!!!! !!!!!

!!!!! !!!!!

!!!!! !!!!!

Records Retention Recommendations

Keep active facility numbers up front, keep inactive facility numbers in the backof the file.

Keep current plans at the front of the file. Keep summaries of drills and exercisesfor three years. Move dated plans, closed incident reports, and critiques to backof the file after three years and retain indefinitely.

Keep active inspection documents and notes on interpretations or advice fromregulators up front. Keep closed inspection files for three years, then you canshred them. Keep regulatory notes that are no longer in effect at the back of thefile as a record of past practices.

Keep at the front training records and environmental position descriptions foremployees throughout their employment. (Hazardous waste training recordsmust be retained for three years, even if the employee has left.) Move trainingrecords of employees who have left the company to the back and keep them incase you need to account for your past practices.

Keep up front active EPA ID numbers, permits, and waste determinations. Moveinactive EPA ID numbers, expired permits and the original permit application,and waste determinations for wastes you no longer generate to the back of thefile. Keep hazardous waste/universal waste shipping records, and activity reportson file for three years (required), then move them to the back of the file. Keepinspection logs for three years, then shred. Keep solid waste tipping records upfront for one year, then move them to the back of the file and keep them.

Keep active permits up front. Move expired permits, original permit applications,any calculations or data that you used in the permit process or to prove xemptionto the back. Keep up front annual air emissions reports and monitoring results forthe past three years, then move them to the back of the file.

Keep active permits and the current sanitary sewer ordinance up front. Moveexpired permits, the original permit application, and expired ordinances to theback. Keep up front annual reports and results of required monitoring for threeyears, then move them to the back.

Keep up front active permits and storm water pollution prevention plans. Moveexpired permits and plans to the back. Keep up front annual reports andmonitoring results for the past three years, then move them to the back.

Table 1: Summary of Environmental Files

1 Compliance—Means you need to keep this file to meet recordkeeping requirements of environmental regulations.2 Liability—Keep this file because it contains information that could help stay out of financial and legal trouble from future environ-

mental claims.3 Good Management Practice—Keep this on file because it provides information that helps you keep track of your environmental

program, or saves you and your staff time later.


22

III. Saving Money Through Sound Environmental Management


Your tree is maturing and requires less attention to flourish. You are starting to see the return on yourefforts as it provides shade for your yard. After working through Section II, you are beginning todevelop a sound environmental management program and no longer feel like you are in crisis manage-ment mode. You can talk knowledgably about the regulatory requirements and what methods you areusing to meet them. Now that you have the basics in place, you can turn some of your attention to thefun stuff: looking for opportunities to make your business more profitable and productive as well asmore friendly toward the environment. This Section includes pointers for cutting back on your energy,water, and waste disposal costs. After you have worked at this for a while, you may even find that yourregulatory requirements have been reduced by changing, scaling back, or eliminating a process. All ofthis will be good preparation for working though Section IV which is about streamlining environmentalmanagement and ensuring that the program will continuously improve over the long run.

How can I use the process mapHow can I use the process mapHow can I use the process mapHow can I use the process mapHow can I use the process mapto save money?to save money?to save money?to save money?to save money?

To be useful for working through this Sectionof the Guide, you may need to add some detailsto the process map that you put together at thebeginning of Section II. If you haven’t alreadydone so, look at the inputs and outputs of eachstep in the process, and figure out quantities andcosts associated with them. You may need tomake some estimates if you don’t keep detailedrecords, and that’s OK. You are looking for aballpark idea of the magnitude of expenses.Once you identify your big cost centers, you canmake better decisions about where to focus yourefforts to reduce costs. To see where this isgoing, take a look at figure 1 on page 9. The ideahere is to plug the leaks to cut back on wasteenergy, wastewater, or waste that is created in theprocess. You also want to find ways to make theprocess more efficient so you can cut back onthe inputs without decreasing the quality or rateof production of the end product.

How can I conserve energy?How can I conserve energy?How can I conserve energy?How can I conserve energy?How can I conserve energy?

Here are three reasons to work on energyconservation:• First, saving energy in your business trans-

lates into cost savings.• Second, using less electricity means less coal

and less natural gas are burned, whichreduces greenhouse gas emissions and otherforms of air pollution and conservesresources for future generations.

• Third, there is free assistance available tohelp your business explore even some of themore involved options so why not takeadvantage of them?

Let us first start withno cost and very low costsuggestions. Most of these involve changes inemployee activities and some readily madeequipment changes:• Turn off lights or office equipment at night

and on weekends or take advantage of

Greenhousegases such ascarbon dioxide(CO2), sulfurdioxide (SO2),and nitrous oxide(N2O) are respon-sible for globalclimate change,acid rain andsmog.

23


natural daylight for lighting needs.• Disconnect unnecessary equipment com-

pletely.• Turn up or turn back the thermostat during

unoccupied times or consider buying aprogrammable thermostat.

• Caulk and weather-strip windows and doors.• Install blinds or shades to keep out summer

sun to lower air-conditioning costs.• Purchase fans to keep warm air from

accumulating at the ceiling during winter.• Insulate hot water holding tanks and hot and

cold pipes and improve insulation of theclimate controlled portions of your facility.

• Replace light bulbs with more efficient ones.You can order inexpensive sub-compactfluorescent lamps through a U.S. Depart-ment of Energy (DOE) program. These lasteight to ten times as long as a regular bulband use one quarter to one third of theenergy.

• Place your lights on motion detectors orinstall timers on lights and electric equip-ment to keep them on only when in use.

• It may be worthwhile to replace lightingfixtures instead of just the bulbs. The newfixtures can allow you to utilize a smallerbulb and get the same amount of light, orreuse the ballast portion of the light.

Call your local utility company to see ifthey still have a program to evaluate yourbuilding for energy efficiency. (Manyhave dropped their programs sincederegulation.) If the service isavailable, the utility will provide you

with specific options for making your busi-ness more energy efficient, usually for free. Ifyour local utility company does not providethis service, check with your state’s energyprogram to see if they do, or know who does.There are Industrial Assessment Centersthroughout the country that perform processaudits to reduce energy use, improve effi-ciency, or reduce waste. (To find the IndustrialAssessment Center in your area seewww.oit.doe.gov/iac/)

Consider Participating in the Energy Star®

Program. Energy Star® is the trade mark EPAuses to signify energy-efficient products. Thisvoluntary program is a partnership betweenEPA, the U.S. Department of Energy (DOE),product manufacturers, local utility compa-nies, and retailers. The agencies set energyefficiency criteria for specific consumer andcommercial products. Products meeting orexceeding the energy efficiency criteriaestablished by the agencies are awarded theEnergy Star® label. These include items likecomputers, monitors, fax machines, printersand copiers. Energy Star® also has a smallbusiness partnership program.

There are some real possibilities for costsavings over time by replacing major equip-

ment within your facility. Not only willthere be savings on operational costs

because of increased efficiency, itcan also avoid maintenanceproblems that take up time andbudget, and justify replacing

24


equipment that is out of date for reasons otherthan just efficiency. One example is that tradi-tional systems often have wasted energy andmoney by running motors continuously at fullcapacity, regardless of the end-use need. Fortu-nately, motors can now be equipped withvariable speed drives to allow the motor toclosely match its power output with the energynecessary for the task—eliminating waste andsaving money.

It is possible to make necessary upgrades withno up-front capital and pay for them laterthrough the energy savings that result. Best ofall these savings can be guaranteed through theenergy performance contracting and assistanceprovided by your state energy office in coopera-tion with the Energy Services Coalition (ESC).This works by entering into an agreement with a

private Energy Service Company (ESCO). Theenergy service company identifies and evaluatesenergy-saving opportunities and recommendssome improvements to be paid for throughsavings. The savings must meet or exceed annualpayments to cover all project costs over thecontract period, usually seven to ten years, or theenergy service company pays the difference. Toensure savings the energy service companyoffers staff training and long term maintenanceservices. Check with the National Association ofEnergy Service Companies at www.naesco.org orcall them at 202-822-0950 to find a companynear you. Your state energy office can alsoprovide you with information, local case studies,and resources to get you started.

Alternative energy sources merit consider-ation too. At University of Texas MedicalBranch, alternative energy uses include theinstallation of a photovoltaic system in a parkinggarage. UTMB parking garages are required tohave lighting 24 hours a day, 7 days a week toprovide safe parking. Photovoltaic panels arecurrently being installed with grant money fromthe Texas Natural Resource ConservationCommission. In addition, solar water heating isbecoming a very popular way of saving energy infacilities with large water heating needs.

How can I conserve water?How can I conserve water?How can I conserve water?How can I conserve water?How can I conserve water?

Think about it: most business activities areusing part of a limited supply of water that isgood enough to drink. Only a tiny fraction ofthe planet’s water is drinkable. Ninety-seven

Twenty thousand dollars can buy a lot of bread. That isTwenty thousand dollars can buy a lot of bread. That isTwenty thousand dollars can buy a lot of bread. That isTwenty thousand dollars can buy a lot of bread. That isTwenty thousand dollars can buy a lot of bread. That iswhat a fast food franchise owner is saving by takingwhat a fast food franchise owner is saving by takingwhat a fast food franchise owner is saving by takingwhat a fast food franchise owner is saving by takingwhat a fast food franchise owner is saving by takingadvantage of energy-efficient technologies at his restau-advantage of energy-efficient technologies at his restau-advantage of energy-efficient technologies at his restau-advantage of energy-efficient technologies at his restau-advantage of energy-efficient technologies at his restau-rant. What is his recipe for success? He upgraded hisrant. What is his recipe for success? He upgraded hisrant. What is his recipe for success? He upgraded hisrant. What is his recipe for success? He upgraded hisrant. What is his recipe for success? He upgraded hisstore’s lighting from 40-watt T-12 lamps and magneticstore’s lighting from 40-watt T-12 lamps and magneticstore’s lighting from 40-watt T-12 lamps and magneticstore’s lighting from 40-watt T-12 lamps and magneticstore’s lighting from 40-watt T-12 lamps and magneticballasts to T-8 lamps and electronic ballasts. In addition toballasts to T-8 lamps and electronic ballasts. In addition toballasts to T-8 lamps and electronic ballasts. In addition toballasts to T-8 lamps and electronic ballasts. In addition toballasts to T-8 lamps and electronic ballasts. In addition tohis 50-percent energy savings, he now has brighter lightinghis 50-percent energy savings, he now has brighter lightinghis 50-percent energy savings, he now has brighter lightinghis 50-percent energy savings, he now has brighter lightinghis 50-percent energy savings, he now has brighter lightingto make the food look more appetizing. He replaced his oldto make the food look more appetizing. He replaced his oldto make the food look more appetizing. He replaced his oldto make the food look more appetizing. He replaced his oldto make the food look more appetizing. He replaced his oldair-conditioning units with high-efficiency models andair-conditioning units with high-efficiency models andair-conditioning units with high-efficiency models andair-conditioning units with high-efficiency models andair-conditioning units with high-efficiency models andadded ceiling fans to circulate the store’s air. He can nowadded ceiling fans to circulate the store’s air. He can nowadded ceiling fans to circulate the store’s air. He can nowadded ceiling fans to circulate the store’s air. He can nowadded ceiling fans to circulate the store’s air. He can nowset the store’s thermostats 3 to 5 degrees higher in theset the store’s thermostats 3 to 5 degrees higher in theset the store’s thermostats 3 to 5 degrees higher in theset the store’s thermostats 3 to 5 degrees higher in theset the store’s thermostats 3 to 5 degrees higher in thesummer without affecting comfort. With these upgrades,summer without affecting comfort. With these upgrades,summer without affecting comfort. With these upgrades,summer without affecting comfort. With these upgrades,summer without affecting comfort. With these upgrades,he will pay back his investment in three years. (Source:he will pay back his investment in three years. (Source:he will pay back his investment in three years. (Source:he will pay back his investment in three years. (Source:he will pay back his investment in three years. (Source:EPA Smallbiz Success Stories)EPA Smallbiz Success Stories)EPA Smallbiz Success Stories)EPA Smallbiz Success Stories)EPA Smallbiz Success Stories)

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For More Information…For More Information…For More Information…For More Information…For More Information…

Energy Star® program: Energy Star® program: Energy Star® program: Energy Star® program: Energy Star® program: www.epa.gov/smallbiz/ or 888-STAR-YESwww.epa.gov/smallbiz/ or 888-STAR-YESwww.epa.gov/smallbiz/ or 888-STAR-YESwww.epa.gov/smallbiz/ or 888-STAR-YESwww.epa.gov/smallbiz/ or 888-STAR-YES.....

Federal Energy Management Program: Federal Energy Management Program: Federal Energy Management Program: Federal Energy Management Program: Federal Energy Management Program: 800-363-3732800-363-3732800-363-3732800-363-3732800-363-3732.....

Putting Energy Into Profits—Energy Star® Guide for Small Businesses isavailable through both of the above agencies.

For info on motor selection:For info on motor selection:For info on motor selection:For info on motor selection:For info on motor selection:www.eren.doe.gov/femp/procurement/pdfs/motor.pdfwww.eren.doe.gov/femp/procurement/pdfs/motor.pdfwww.eren.doe.gov/femp/procurement/pdfs/motor.pdfwww.eren.doe.gov/femp/procurement/pdfs/motor.pdfwww.eren.doe.gov/femp/procurement/pdfs/motor.pdf

The Department of Energy’s Industrial Best Practices:The Department of Energy’s Industrial Best Practices:The Department of Energy’s Industrial Best Practices:The Department of Energy’s Industrial Best Practices:The Department of Energy’s Industrial Best Practices:www.oit.doe.gov/bestpractices/www.oit.doe.gov/bestpractices/www.oit.doe.gov/bestpractices/www.oit.doe.gov/bestpractices/www.oit.doe.gov/bestpractices/

State renewable energy assistance programs:State renewable energy assistance programs:State renewable energy assistance programs:State renewable energy assistance programs:State renewable energy assistance programs:www.energy.ca.gov/reports/500-99-008.PDFwww.energy.ca.gov/reports/500-99-008.PDFwww.energy.ca.gov/reports/500-99-008.PDFwww.energy.ca.gov/reports/500-99-008.PDFwww.energy.ca.gov/reports/500-99-008.PDF

percent is sea water, which is expen-sive and difficult to desalinate. Abouttwo percent is caught in polar icecaps. That leaves just one percent tosustain life. Much of the world’spopulation gets their drinking waterfrom natural underground storage

tanks called aquifers. Humankind is rapidly usingup those reserves, digging ever-deeper wells andlowering water levels in every continent. Also,your business pays for using this resource. Thismay not seem like a large part of your overhead.That is, until you realize that you pay for it twice:coming to the tap and going to the sewer. Take alook at your combined water-sewer bill. If youwant to save some money while reducing theimpact of your business on your community’swater supply, consider some of the ideas belowas a starting point for your water conservationefforts.

Find out how your company uses water. Youmay have water guzzling processes that can bechanged or updated. Some water cooled equip-ment can be replaced with air cooled equipment.Are you spending more for the water to run aprocess than you would spend to buy the goodsor services directly? If the water use in theprocess can’t be eliminated completely, perhapsthe water can be reused. For example, can yourbusiness reuse process water to wash equipmentinstead of sending it to the sewer? Since fewpeople would ignore ways to reduce chemicaluse, doesn’t it make sense to look at reduction inwater use as well? Rinsewaters can be used forlower priority cleaning applications just as you

might use a slightly contaminated solvent foranother use before you dispose of it. And just asused solvents can be reclaimed through distilla-tion, water can be reclaimed through ultrafiltra-tion. Furthermore, water recycled throughultrafiltration or reverse osmosis systems can beof better quality than supply water.

Keeping your plumbing fixtures in goodworking order or upgrading fixtures can saveboth water and money. Below are several ideasand suggestions for you to try:• An easy way to test for leaks in the toilet is

to put food dye in the toilet tank. Let it sitfor an hour or two without flushing. If yousee dye in the toilet bowl, you have a leak.Check to make sure the overflow tube is notflowing continually.

• Consider an inspection program for leaks.• Repair dripping faucets by replacing washers.• It may be worthwhile to replace plumbing

fixtures with more water efficient options.

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• Faucet aerators with flow restrictors areavailable to reduce water use.

• Some heating and cooling equipment modelsreuse or recycle water.

• Automatic shut offs on water supplies suchas sinks and hose nozzles will keep themfrom being left on.

• High pressure/low volume cleaning nozzleson spray washers also use less water.

• Cover liquid holding areas when not in useto reduce evaporation.

If you have grounds or greenspace, look atoutdoor water uses, such as landscaping.Remember that established plants and lawnsneed less water than new ones, and many nativeplant species do with less water than imports.Here are some additional ideas:• Adding mulch can further reduce your water

needs.• Set sprinkler patterns to avoid watering

structures and concreted areas and installmoisture-detection devices on automaticoutdoor sprinklers so that they will notactivate when it is raining.

• Water lawns early in themorning when tempera-ture and wind speed arelowest to reduce evapo-ration.

• Upgrade to an irrigation system that relieson data on natural water loss through solarradiation, temperature, wind velocity, soilconditions and humidity to avoid overwatering by replacing only the water lost.

Small adjustments in your process can help

you to save money on your water and sewer bills.Keep track of these expenses so that you cangauge progress and quickly spot changes. Checkyour meter for increased use that can signal aproblem. It is possible through continuedimprovements that your company could reach apoint where there is “zero discharge” from yourprocesses through water recycling and reuse.Other companies have achieved this level ofefficiency motivated either by a desire to reducecost associated with water consumption or toeliminate the need to permit wastewater dis-charge or to pay to dispose of wastewater. Ifpossible, talk with other companies aboutmethods they have used to save water. Yourwater utility company may also be a source ofinformation on conservation methods.

How can I reduce wasteHow can I reduce wasteHow can I reduce wasteHow can I reduce wasteHow can I reduce wastemanagement costs?management costs?management costs?management costs?management costs?

Waste disposal can drive up unit costs on yourproduction lines. Here are some tips for gettingthem under control:

One strategy is to make sure you are manag-ing your wastes efficiently. When you hire ahazardous waste contractor, ask them to helpyou find ways to cut down on costs. While itmight seem that it is not in your contractor’s bestinterest to do this, the hazardous waste markethas gotten so competitive that contractors arelooking for ways to add value to their service andset themselves apart from the competition.Things you should consult with your contractorabout: Would accumulating your waste in acontainer of a different size or type make it less

Did you knowDid you knowDid you knowDid you knowDid you knowhow quickly ahow quickly ahow quickly ahow quickly ahow quickly asmall water leaksmall water leaksmall water leaksmall water leaksmall water leakcan add up?can add up?can add up?can add up?can add up?Toilet leaks canToilet leaks canToilet leaks canToilet leaks canToilet leaks canwaste more thanwaste more thanwaste more thanwaste more thanwaste more than50 gallons of50 gallons of50 gallons of50 gallons of50 gallons ofwater a day,water a day,water a day,water a day,water a day,18,250 per year.18,250 per year.18,250 per year.18,250 per year.18,250 per year.One drip perOne drip perOne drip perOne drip perOne drip persecond from asecond from asecond from asecond from asecond from aleaky faucetleaky faucetleaky faucetleaky faucetleaky faucetequates to 2,700equates to 2,700equates to 2,700equates to 2,700equates to 2,700gallons of watergallons of watergallons of watergallons of watergallons of waterper year.per year.per year.per year.per year.

27


costly for the contractor to handle? Could yousave money by sending your hazardous wastesolvents for use as fuel for cement kilns? Maybethere is a component in your waste that makes ithard to manage and drives up its disposal cost.Look for an opportunity to keep this item out ofthe waste either by collecting it separately orfinding a replacement for it in your process.

Another approach is to look for ways toreduce the amount of wastes your businesscreates. A simple example is to reuse corrugatedboxes two or three times before yousend them off for recycling. Sincenew boxes are expensive,savings can add up fast. Let’suse the example of a spraypainting operation to illustrateseveral more waste recycling andpollution prevention ideas. Beginwith the inventory of paints you keep on hand.Do you sometimes have paint that you can’t useup because their shelf life has expired? Or excesspaint that you have no use for anymore and haveto be disposed? If so, take a look at your pur-chasing practices. Many vendors will work withyou on the concept of “just in time and just theright amount.” This means that they will deliveryour raw material more frequently in amountsthat nearly match your process needs. This maybe a little more costly than ordering bulk quanti-ties up front, but you may be surprised: withtoday’s shipping options, many suppliers havethe ability for quick delivery at only a littleadditional cost. Once you take into account allthe costs of handling paint purchased in bulk(managing the material in storage, dispensing it,

disposing of excess or expired material) you mayfind that you will come out ahead by opting for“just in time” delivery.

After you look at how paint is delivered toyour process, take a look at the process itself. Sitdown with the workers who are most familiarwith the process and figure out exactly howwastes are created in the spraypainting operation. Perhaps you areusing fresh mineral spirits each timeyou clean the paint guns. What ifyou could keep some mineral spiritsin a container to be reused the nexttime you clean the guns? It’s likelythat you use several rinses to get the guns cleanand that the mineral spirits used in the final passisn’t very dirty. This could be reused in the initialrinse the next cleaning and brand new mineralspirits saved for the final rinses only. Every bitof chemical that is reused is saving that muchnew material and reducing the waste created bythat amount too. So, you save money on bothends of the process.

Another strategy is to find a different materialto use to clean the paint guns so that a hazard-ous waste would not be generated at all. Thereare new clean-up products available that are notcombustible and aren’t hazardous wastes oncethey are used up. Of course, it would be prudentto do some trials on a limited scale so you canmake sure the switch is going to work just as welland be cost effective. Beyond paint operations,there are similar green products available forparts washing and stripping operations, to namea couple. Some of these products have been on

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the market for more than a decade, sothey have the bugs worked out ofthem. In addition to saving money andreducing the amount of hazardouswaste your business generates, manyof these greener products are alsosafer for employees to use.

Another thing you might try is to get betterequipment. Perhaps you can upgrade your spraypaint equipment to a gun that has a smallerreservoir but delivers the paint just as effectively.Use plastic liners to eliminate cleaning the gunreservoirs. Also, a newer HVLP gun is likely tobe more efficient by having higher depositefficiency and less overspray, thus saving money

on paint purchases. An enclosed paintgun cleaning system that recyclescleaning fluid will also save money bylosing less product to evaporation andre-using product. These processchanges will save on waste disposalcosts as well as product purchases.

They will greatly reduce air emissions, perhaps tolevels that do not require an environmentalpermit. If you have been operating under an airpermit, you know how costly it is to keep up, sobeing able to drop the permit will save time andmoney too.

How do I predict savings fromHow do I predict savings fromHow do I predict savings fromHow do I predict savings fromHow do I predict savings fromproposed projects?proposed projects?proposed projects?proposed projects?proposed projects?

This part of the Guide has emphasizedprojects that are likely to have a financial pay-back. It is understandable that you, as the topperson at your business, will want to know howmuch and how soon the return will be for theeffort and funding invested in the project. But,after you have sharpened your pencil, whatexactly do you include in a cost work up?

The question you need to answer is, “What isthe up front cost of the change you are consid-ering, and how long will it take for enoughsavings to accumulate to offset this up frontcost?” This is the “return on investment,” andusually, if it will take more than two years forbenefits to outweigh the initial outlay, it may bedifficult to convince you and your staff to do theproject unless there are other really good reasonsto do it, such as improved employee safety. With

Creative Solutions…Creative Solutions…Creative Solutions…Creative Solutions…Creative Solutions…

A trophy company owner had a dilemma—finding an inex-A trophy company owner had a dilemma—finding an inex-A trophy company owner had a dilemma—finding an inex-A trophy company owner had a dilemma—finding an inex-A trophy company owner had a dilemma—finding an inex-pensive shipping solution for the large-sized trophies. Thepensive shipping solution for the large-sized trophies. Thepensive shipping solution for the large-sized trophies. Thepensive shipping solution for the large-sized trophies. Thepensive shipping solution for the large-sized trophies. Thelarge, odd-sized boxes he needed were more expensivelarge, odd-sized boxes he needed were more expensivelarge, odd-sized boxes he needed were more expensivelarge, odd-sized boxes he needed were more expensivelarge, odd-sized boxes he needed were more expensivethan normal shipping boxes. Through the Minnesota Materi-than normal shipping boxes. Through the Minnesota Materi-than normal shipping boxes. Through the Minnesota Materi-than normal shipping boxes. Through the Minnesota Materi-than normal shipping boxes. Through the Minnesota Materi-als Exchange program, the business owner was put inals Exchange program, the business owner was put inals Exchange program, the business owner was put inals Exchange program, the business owner was put inals Exchange program, the business owner was put intouch with a chemical company that was willing to parttouch with a chemical company that was willing to parttouch with a chemical company that was willing to parttouch with a chemical company that was willing to parttouch with a chemical company that was willing to partwith a supply of boxes that were the exact size hewith a supply of boxes that were the exact size hewith a supply of boxes that were the exact size hewith a supply of boxes that were the exact size hewith a supply of boxes that were the exact size heneeded—for free! Since then, the trophy company hasneeded—for free! Since then, the trophy company hasneeded—for free! Since then, the trophy company hasneeded—for free! Since then, the trophy company hasneeded—for free! Since then, the trophy company hasfound other boxes and bubble wrap for packing trophiesfound other boxes and bubble wrap for packing trophiesfound other boxes and bubble wrap for packing trophiesfound other boxes and bubble wrap for packing trophiesfound other boxes and bubble wrap for packing trophiesthrough the program. Using the Materials Exchange Pro-through the program. Using the Materials Exchange Pro-through the program. Using the Materials Exchange Pro-through the program. Using the Materials Exchange Pro-through the program. Using the Materials Exchange Pro-gram his company saves about $4,500 per year.gram his company saves about $4,500 per year.gram his company saves about $4,500 per year.gram his company saves about $4,500 per year.gram his company saves about $4,500 per year.

For other case studies see:For other case studies see:For other case studies see:For other case studies see:For other case studies see:State of Texas: State of Texas: State of Texas: State of Texas: State of Texas: http://p2.utep.edu/success/index.cfmhttp://p2.utep.edu/success/index.cfmhttp://p2.utep.edu/success/index.cfmhttp://p2.utep.edu/success/index.cfmhttp://p2.utep.edu/success/index.cfmState of Minnesota:State of Minnesota:State of Minnesota:State of Minnesota:State of Minnesota: http://www.moea.state.mn.us/http://www.moea.state.mn.us/http://www.moea.state.mn.us/http://www.moea.state.mn.us/http://www.moea.state.mn.us/p2week99/stories.cfmp2week99/stories.cfmp2week99/stories.cfmp2week99/stories.cfmp2week99/stories.cfm

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For More Information About Pollution Prevention…For More Information About Pollution Prevention…For More Information About Pollution Prevention…For More Information About Pollution Prevention…For More Information About Pollution Prevention…

Environmental Protection AgencyEnvironmental Protection AgencyEnvironmental Protection AgencyEnvironmental Protection AgencyEnvironmental Protection AgencyPollution Prevention Information Clearinghouse:Pollution Prevention Information Clearinghouse:Pollution Prevention Information Clearinghouse:Pollution Prevention Information Clearinghouse:Pollution Prevention Information Clearinghouse:www.epa.gov/opptintr/library/libppic.htmwww.epa.gov/opptintr/library/libppic.htmwww.epa.gov/opptintr/library/libppic.htmwww.epa.gov/opptintr/library/libppic.htmwww.epa.gov/opptintr/library/libppic.htm

Envirofacts:Envirofacts:Envirofacts:Envirofacts:Envirofacts: www.epa.gov/enviro/index_java.htmlwww.epa.gov/enviro/index_java.htmlwww.epa.gov/enviro/index_java.htmlwww.epa.gov/enviro/index_java.htmlwww.epa.gov/enviro/index_java.html

Environmentally Preferable Purchasing web site:Environmentally Preferable Purchasing web site:Environmentally Preferable Purchasing web site:Environmentally Preferable Purchasing web site:Environmentally Preferable Purchasing web site: www.epa.gov/oppintr/eppwww.epa.gov/oppintr/eppwww.epa.gov/oppintr/eppwww.epa.gov/oppintr/eppwww.epa.gov/oppintr/epp

Region 1: Region 1: Region 1: Region 1: Region 1: www.epa.gov/region1/compliance/assist/p2page.htmlwww.epa.gov/region1/compliance/assist/p2page.htmlwww.epa.gov/region1/compliance/assist/p2page.htmlwww.epa.gov/region1/compliance/assist/p2page.htmlwww.epa.gov/region1/compliance/assist/p2page.htmlRegion 2:Region 2:Region 2:Region 2:Region 2: www.epa.gov/r02earth/p2/p2home.htmwww.epa.gov/r02earth/p2/p2home.htmwww.epa.gov/r02earth/p2/p2home.htmwww.epa.gov/r02earth/p2/p2home.htmwww.epa.gov/r02earth/p2/p2home.htmRegion 3:Region 3:Region 3:Region 3:Region 3: www.epa.gov/reg3p2p2/www.epa.gov/reg3p2p2/www.epa.gov/reg3p2p2/www.epa.gov/reg3p2p2/www.epa.gov/reg3p2p2/Region 4:Region 4:Region 4:Region 4:Region 4: www.epa.gov/region4/air/polprev.htmwww.epa.gov/region4/air/polprev.htmwww.epa.gov/region4/air/polprev.htmwww.epa.gov/region4/air/polprev.htmwww.epa.gov/region4/air/polprev.htmRegion 5:Region 5:Region 5:Region 5:Region 5: www.epa.gov/reg5rcra/wptdiv/p2pages/index.htmlwww.epa.gov/reg5rcra/wptdiv/p2pages/index.htmlwww.epa.gov/reg5rcra/wptdiv/p2pages/index.htmlwww.epa.gov/reg5rcra/wptdiv/p2pages/index.htmlwww.epa.gov/reg5rcra/wptdiv/p2pages/index.htmlRegion 8:Region 8:Region 8:Region 8:Region 8: www.epa.gov/region08/conservation_recycling/p2home/www.epa.gov/region08/conservation_recycling/p2home/www.epa.gov/region08/conservation_recycling/p2home/www.epa.gov/region08/conservation_recycling/p2home/www.epa.gov/region08/conservation_recycling/p2home/ p2home.html p2home.html p2home.html p2home.html p2home.htmlRegion 9:Region 9:Region 9:Region 9:Region 9: www.epa.gov/region09/cross_pr/p2/index.htmlwww.epa.gov/region09/cross_pr/p2/index.htmlwww.epa.gov/region09/cross_pr/p2/index.htmlwww.epa.gov/region09/cross_pr/p2/index.htmlwww.epa.gov/region09/cross_pr/p2/index.htmlRegion 10:Region 10:Region 10:Region 10:Region 10: yosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrecyosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrecyosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrecyosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrecyosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrec

OtherOtherOtherOtherOtherPacific Northwest National Laboratory P2 website:Pacific Northwest National Laboratory P2 website:Pacific Northwest National Laboratory P2 website:Pacific Northwest National Laboratory P2 website:Pacific Northwest National Laboratory P2 website: www.pnl.gov/p2/www.pnl.gov/p2/www.pnl.gov/p2/www.pnl.gov/p2/www.pnl.gov/p2/Kentucky Pollution Prevention Center: Kentucky Pollution Prevention Center: Kentucky Pollution Prevention Center: Kentucky Pollution Prevention Center: Kentucky Pollution Prevention Center: www.kppc.org/www.kppc.org/www.kppc.org/www.kppc.org/www.kppc.org/

this in mind, here are some cost categories toconsider as you work up your analysis.

Initial start up costs. In addition to the costof purchasing, will the change require remodel-ing or modifications to meet building codes?

Changeover costs. When changing from theold process to the new process, what will happento excess raw materials that can no longer beused? Will employees need training before theycan begin using the new process? Will you need atrial period to work out any bugs?

With the up front costs nailed down, comparethe old process and the new process head tohead.

Operating costs. These can include electric-ity, water use, and ventilation systems. Also lookat whether the new process will be more or lesslabor intensive. Will the new process be moreproductive, for example, higher units of outputper hour or lower amount of raw materials perunit?

Environmental management and compli-ance costs. What are the waste managementcosts? Will compliance be made easier by thenew process? For example, will it eliminate arequired report to regulators? Will it put you in ahazardous waste generator category with reducedrequirements? Will you be able to discontinue anenvironmental permit? If so, try to estimate thetime company employees put into these effortsto come up with an estimate of dollars saved.

Avoided costs. In addition to avoided wastedisposal costs, consider whether the new processrequires less raw material inputs, thus savingcosts in purchasing them. Will the new processeliminate spills and their associated costs? Willthere be less personal protective equipment andsafety training required?

It may not be a formal and totally completeanalysis, but if you think through all of theabove categories you will have a much clearerpicture when you get done of whether your ideais as valuable as you first thought.

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How do we involve ourHow do we involve ourHow do we involve ourHow do we involve ourHow do we involve ouremployees in environmentalemployees in environmentalemployees in environmentalemployees in environmentalemployees in environmentalmanagement activities?management activities?management activities?management activities?management activities?

By now you have taken some steps to put abasic environmental management program inplace and find that it makes good sense. You, asthe business owner, continue to offer visiblesupport for environmental management so theprogram is taken seriously. But, do you wonderhow you are ever going to keep it going whilestill meeting everyday business demands? It’stime to enlist some help. Environmental effortswithin your company will be more successful ifemployees are directly involved. Employees are agreat source of knowledge on environmentalissues related to their work areas and the effec-tiveness of current procedures. Consider setting

IV. Keeping the Program Alive

up an Environmental Management Team andmaking a company environmental policy. Theteam can then use the policy to make thecompany’s environmental efforts more efficientand to get more employees actively involved inthem.

The team approach will help to fit anotheractivity into an already busy schedule and thediscussion it brings about will create a morecomplete picture of where you currently standand where you go from here. If you can’t guidethe Environmental Management Team all the


Now that your tree is fully mature, you want to make sure it will stay healthy over the long run. Could itbecome susceptible to disease or get blown down in a storm? To this point, you have put in place theessential functions of environmental management; you’ve taken some opportunities to save money. But,you worry about losing the momentum. You want to bring your environmental management program upto a level that no matter what changes occur at your business, it will reliably steer your businessactivities in a direction that keeps employees safe, avoids bad effects on the environment, complies withregulations, and saves money. This Section of the Guide helps you accomplish that. It will help you getemployees more thoroughly involved in environmental management. It explains how a company’senvironmental policy can act as a tap root, feeding environmental concerns into all decision makingbranches. While it may seem like you have to devote more time at first, you will be streamlining andintegrating environmental responsibilities—thinning them out and making them easier and less timeconsuming for each employee. Then you can apply methods to gauge progress over time, set goals, andform a simple environmental management plan to guide your program towards improvement. Once thisis done, you will be able to have complete confidence in the long term vitality of your environmentalprogram. Then, you will be ready to make people outside your company aware of your business’exemplary performance in environmental management by working through Section V.

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time, appoint a team leader to encourage com-munication between employees, supervisors, andcompany leadership. For this to work, the teamleader needs some authority to keep thingsmoving. The team should include representativesfrom throughout the company. For example, at asmall company, a team could include supervisorsfrom each process line as well as people respon-sible for human resources, sales, and plantoperations. In a very small company, the teamleader and the business owner may be the sameperson, and the team may consist of the entirestaff. Small companies can have a real advantageover larger companies. Communication is easier,staff is used to having multiple roles, andprocesses are well understood by everyone.

The first task is to write a company environ-mental policy. You may want to do this and passit down to the team, or you can ask the team todo it for your review and approval. A companyenvironmental policy is the shared starting pointfor people to understand the basic environmen-tal beliefs and commitments of the company’sleaders. It states how environmental concernsare considered in the company’s decision makingand how these concerns fit into its day to dayactivities. The policy should reflect your commit-ment to the environmental program. It shouldbe short, to the point, and wellcommunicated throughoutthe company so thatemployees understand andremember the policy. Allthe other steps for improv-ing the environmental

management program are geared towardsmeeting the environmental beliefs stated in thepolicy.

How do we go about gettingHow do we go about gettingHow do we go about gettingHow do we go about gettingHow do we go about gettingthings written down and whythings written down and whythings written down and whythings written down and whythings written down and whyshould we spend time on this?should we spend time on this?should we spend time on this?should we spend time on this?should we spend time on this?

With the policy in hand, the team can begin toorganize and write down the activities that makeup your environmental management program.To do this, bring together and examine all partsof the environmental management programyour company developed by working throughSection II of the Guide. This written programwill support your policy and later form the basisfor setting goals and making an environmentalmanagement plan. Your written program should

Ways to Keep Employees InvolvedWays to Keep Employees InvolvedWays to Keep Employees InvolvedWays to Keep Employees InvolvedWays to Keep Employees Involved

1.1.1.1.1. Post the Environmental Policy at prominentPost the Environmental Policy at prominentPost the Environmental Policy at prominentPost the Environmental Policy at prominentPost the Environmental Policy at prominentlocations throughout your business.locations throughout your business.locations throughout your business.locations throughout your business.locations throughout your business.

2.2.2.2.2. Set up a suggestion box for environmentalSet up a suggestion box for environmentalSet up a suggestion box for environmentalSet up a suggestion box for environmentalSet up a suggestion box for environmentalimprovements. Recognize or give awards toimprovements. Recognize or give awards toimprovements. Recognize or give awards toimprovements. Recognize or give awards toimprovements. Recognize or give awards toemployees that make suggestions that getemployees that make suggestions that getemployees that make suggestions that getemployees that make suggestions that getemployees that make suggestions that getincorporated into environmental managementincorporated into environmental managementincorporated into environmental managementincorporated into environmental managementincorporated into environmental managementprocedures.procedures.procedures.procedures.procedures.

3.3.3.3.3. Inform employees through a company newsletterInform employees through a company newsletterInform employees through a company newsletterInform employees through a company newsletterInform employees through a company newsletteror bulletin board and provide them updatesor bulletin board and provide them updatesor bulletin board and provide them updatesor bulletin board and provide them updatesor bulletin board and provide them updateson the company’s progress in fulfilling itson the company’s progress in fulfilling itson the company’s progress in fulfilling itson the company’s progress in fulfilling itson the company’s progress in fulfilling itsEnvironmental Policy.Environmental Policy.Environmental Policy.Environmental Policy.Environmental Policy.

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assign roles and responsibilities foraccomplishing the activities that youhave identified. Break these downinto small manageable jobs thatare clearly defined so thateveryone knows what their job isand nothing gets missed. Thebenefit of doing this is that when youadd up the duties of all individuals it will providecomplete coverage of your company’s environ-mental responsibilities and commitments, but noone person will have too much to do.

Another good reason to spend time on awritten program is that the team will see wherethere is duplication of effort that can be stream-lined. For example, your team may discover thatemployees are being pulled out of their work fortraining several times per year. What if yourcompany set aside time for training covering allrequirements on one day each year? You can alsostreamline training by covering more than oneregulation under a given topic—such as trainingon labeling requirements that covers require-ments of both the Occupational Safety andHealth Administration (OSHA) and EPA, as wellas any local requirements such as those of yourmunicipal fire department.

Another area that can often be streamlined isspill preparedness. Some small businesses mayhave more than one spill response plan—one tocover storm water regulations, one to coverhazardous waste spills, and one to cover petro-leum product spills. For a small company wherethese plans are not too complicated, covering all

the requirements in one plan will reducethe amount of effort it takes to keep it

up to date. It makes the plan moreeffective too because employees

don’t have to learn a different setof procedures for each plan, and

try to remember during a spillsituation which plan applies to it.

With a good overview of the environmentalmanagement program, the team can begin tolook at more detailed procedures that need to beconsistent with the written program and theenvironmental policy. Ask employees to writedown what they do during normal daily activities.Getting this written down makes sense so thatnothing gets forgotten and procedures are easyto communicate. Written procedures make crosstraining easier, ensuring that someone will beavailable to perform a critical function if theregular employee is away. They can make turn-over easier because the person hiring will have abetter idea of what each job entails.

Once they are written down, the team canevaluate procedures so that each employee’sactivities include good environmental manage-ment practices. Without good environmentalmanagement practices, employees may get theimpression that anything other than stepsabsolutely crucial to making the product are“extras.” They have to rely on word of mouthfor information, and the answer depends onwho they ask. With no good environmentalmanagement practices, they are more likely totake shortcuts when pressed for time that are not

33

safe or good for the environment. Your com-pany can reinforce the importance of goodenvironmental management practices by makingthem part of job performance evaluations.Supervisors can use the good environmentalpractices in written procedures to explain to newemployees how the company environmentalpolicy relates to their job.

When evaluating environmental managementpractices, you should see if best environmentalmanagement practices have been identified foryour business sector by environmental regulatoryagencies or your trade or industry association.For example, EPA Small Business Division hascompiled best environmental managementpractices for certain sectors in its publicationcalled Plugging into Best Environmental ManagementPractices. To find out what sectors are includedand, if they pertain to your business, obtain acopy, call EPA’s Small Business Division at 800-368-5888.

How does this fit in with myHow does this fit in with myHow does this fit in with myHow does this fit in with myHow does this fit in with mycompany’s safety or qualitycompany’s safety or qualitycompany’s safety or qualitycompany’s safety or qualitycompany’s safety or qualitymanagement program?management program?management program?management program?management program?

While the focus here is environmentalmanagement, don’t overlook the opportunity tointegrate with other business managementsystems such as process quality, productioncontrol, or safety management. They offer manyopportunities to complement your environmen-tal management efforts and vice versa. If you arealready doing job hazard assessments to developsafety procedures, it is a simple extra step to

address environmental hazards at the same time.Material safety data sheets that you must havefor your safety program and product specifica-tion or quality verification sheets that youmaintain for your quality program offer a wealthof information about environmental issues. Ifyour business has an electronic business manage-ment system, this puts information at yourfingertips such as rates of raw material use,product outputs, and cost data—a great resourcefor environmental performance improvement.

Is this working—are we gettingIs this working—are we gettingIs this working—are we gettingIs this working—are we gettingIs this working—are we gettingthe results we wanted?the results we wanted?the results we wanted?the results we wanted?the results we wanted?

After your environmental managementprogram has been in place a while, you might bewondering how you can tell how things aregoing. Are you making progress on getting intocompliance? Are all your shops and operationsgetting the information they need to keepmoving ahead?

Audits are a great way to gather informationon how well your environmental managementefforts are working. These can be done internallyunder the oversight of the EnvironmentalManagement Team oryour business can getoutside help. Byinvolving employees inenvironmental audits,you will give them afirst hand look at whatthey are doing rightand what still needs


34


improvement. If getting intocompliance is a big priority, then it iswise to get some assistance fromoutside your company. Fortunately,there are many outside resources youcan draw on. A number of complianceassistance organizations make auditchecklists freely available that coverspecific regulations. A representative from yourstate Small Business Assistance Program cancome do a compliance audit for you. This hasthe added weight of an outside expert withoutthe headaches that you would get from a trueregulatory inspection. Since a compliance auditconducted by an outside organization feels a lotlike a regulatory inspection to your employees, itis also good practice. After each audit, organizefindings and follow up actions by work area tomake it easier to pass them on to those respon-sible. In addition, the auditor should provide asummary of larger tasks that need to be donecompany-wide.

Your audits help you gaugewhich areas you are makingprogress in and which areas are

lagging. Once you have audit results,it is a good time to set some goalsand targets. After all, there is a lot oftruth to the old adage, “What gets

measured gets done.” Get the Envi-ronmental Management Team together, go overthe audit results with them, and ask them fortheir impressions of how things are going. Thisis a great time to go over other information thattells you how you are doing: How many spills didyou have last year? Are the consumption ofchemical raw materials and the amount of wastegenerated per unit of product produced increas-ing or decreasing? Do problems in a particulararea signal that procedures need to be updated?Are new employees getting trained soon afterthey come on board?

As a group, decide on a few goals. Be surethat these goals are realistic and fit into previ-ously established organizational goals. With allthe other demands on small businesses, settingexpectations that are exceedingly difficult tomeet would sure put the chill on the progressyou’ve made so far. After the group agrees on agoal, then they need to decide how to measure inthe future whether or not you are makingprogress toward your goal and by how much youwant to improve. This is your target.

One last bit of advice on goals and targets.Don’t set too many of them in a given year, oryou will wind up with a mini-bureaucracy of

On Setting TargetsOn Setting TargetsOn Setting TargetsOn Setting TargetsOn Setting Targets

Let’s say your goal is to reduce hazardous waste.Let’s say your goal is to reduce hazardous waste.Let’s say your goal is to reduce hazardous waste.Let’s say your goal is to reduce hazardous waste.Let’s say your goal is to reduce hazardous waste.You could look for a percentage reduction in theYou could look for a percentage reduction in theYou could look for a percentage reduction in theYou could look for a percentage reduction in theYou could look for a percentage reduction in theamount of all hazardous waste generated. But, thisamount of all hazardous waste generated. But, thisamount of all hazardous waste generated. But, thisamount of all hazardous waste generated. But, thisamount of all hazardous waste generated. But, thiswon’t be meaningful if your waste generation iswon’t be meaningful if your waste generation iswon’t be meaningful if your waste generation iswon’t be meaningful if your waste generation iswon’t be meaningful if your waste generation islinked to production and your production doubles inlinked to production and your production doubles inlinked to production and your production doubles inlinked to production and your production doubles inlinked to production and your production doubles inthe coming year. What if you look for a percentagethe coming year. What if you look for a percentagethe coming year. What if you look for a percentagethe coming year. What if you look for a percentagethe coming year. What if you look for a percentagereduction in hazardous waste per unit of productreduction in hazardous waste per unit of productreduction in hazardous waste per unit of productreduction in hazardous waste per unit of productreduction in hazardous waste per unit of productproduced? This is a measure you can use to set aproduced? This is a measure you can use to set aproduced? This is a measure you can use to set aproduced? This is a measure you can use to set aproduced? This is a measure you can use to set ameaningful target—say, a ten percent reduction inmeaningful target—say, a ten percent reduction inmeaningful target—say, a ten percent reduction inmeaningful target—say, a ten percent reduction inmeaningful target—say, a ten percent reduction inhazardous waste per unit produced.hazardous waste per unit produced.hazardous waste per unit produced.hazardous waste per unit produced.hazardous waste per unit produced.

35


your own. Remember, the beauty of this tool isthat you can get back together next year, look atyour results to see whether your company met itsgoal and then regroup. You can choose adifferent approach if the first one you tried isn’tas useful as you hoped. You can add newgoals—perhaps in an entirely different area orproduction line. Once you have the system setup to measure performance, keeping it going willbe a lot less time intensive than the initialinvestment to get it up and running. It is a goodidea to take your time to select goals that have alot of mileage and find the right measures forthem. In just a few years, you will be able todemonstrate in hard numbers the value of yourenvironmental management program, and, well,that’s just good business.

You may not realize it, but you have just laidthe groundwork for an effective annual plan foryour environmental management program. Takeyour company policy; add a summary of auditresults, accomplishments, and setbacks for thepast year. Then, review the thinking used toanalyze problems, set criteria, select goals for thecoming year, and update the list of goals andtargets. Now you have an environmental man-agement plan. Of course, this is a simplifiedplanning approach—but once you have theprocess established, you can build on it. When-ever the plan changes enlist the EnvironmentalManagement Team to communicate the changes.Employees want to know why it is important toaccomplish a particular environmental task andwhat part they are to play in achieving selectedgoals.

What exactly is an environmental management plan?What exactly is an environmental management plan?What exactly is an environmental management plan?What exactly is an environmental management plan?What exactly is an environmental management plan?

An environmental management plan describes theAn environmental management plan describes theAn environmental management plan describes theAn environmental management plan describes theAn environmental management plan describes theactions an organization is taking to determine how itactions an organization is taking to determine how itactions an organization is taking to determine how itactions an organization is taking to determine how itactions an organization is taking to determine how itaffects the environment, complies with regulations,affects the environment, complies with regulations,affects the environment, complies with regulations,affects the environment, complies with regulations,affects the environment, complies with regulations,keeps track of environmental management activities,keeps track of environmental management activities,keeps track of environmental management activities,keeps track of environmental management activities,keeps track of environmental management activities,and meets environmental goals and targets. It alsoand meets environmental goals and targets. It alsoand meets environmental goals and targets. It alsoand meets environmental goals and targets. It alsoand meets environmental goals and targets. It alsodocuments key elements of environmental manage-documents key elements of environmental manage-documents key elements of environmental manage-documents key elements of environmental manage-documents key elements of environmental manage-ment. It is the compass for your environmentalment. It is the compass for your environmentalment. It is the compass for your environmentalment. It is the compass for your environmentalment. It is the compass for your environmentalmanagement program because it tells you whatmanagement program because it tells you whatmanagement program because it tells you whatmanagement program because it tells you whatmanagement program because it tells you whatdirection you are going in.direction you are going in.direction you are going in.direction you are going in.direction you are going in.

OK, now you have your written environmen-tal management program, you have a plan forwhat you want to improve and how you aregoing to measure improvements. By now,employee environmental management responsi-bilities are so well defined and accepted that theyare second nature—just like filing a timesheet, orstarting up their line at the beginning of a shift.There’s only one last thing your company needsto do to make your environmental managementprogram complete. Make sure top managementat your company checks in on a regular basis.

As the small business owner, you may need toperiodically do your own assessment of how theenvironmental management program is working.Revisit the environmental policy and make yourown evaluation of whether it is still in synchwith company goals. Finally, pull this togetherinto a written review to give the EnvironmentalManagement Team feedback on what needs tobe changed, if anything.

36


The environmental management program you have cultivated is providing value to your customers andyour community. This Section of the Guide explores the value of paying attention to relationshipsbeyond the walls of your small business to show off and improve your environmental managementactivities. It suggests ways to make neighbors, the surrounding community, customers, suppliers, andothers aware of your environmental management achievements and how to team up with them toimprove environmental performance.

V. Taking it Outside Your Facility

How do I communicate ourHow do I communicate ourHow do I communicate ourHow do I communicate ourHow do I communicate ourenvironmental managementenvironmental managementenvironmental managementenvironmental managementenvironmental managementefforts to those outside of ourefforts to those outside of ourefforts to those outside of ourefforts to those outside of ourefforts to those outside of ourbusiness?business?business?business?business?

There are people outside your business whoare either interested in your efforts or can helpyou with them. Now that your company hasinvested effort to develop a good environmentalmanagement program it’s time you got a pat onthe back for it. One relationship that you arealready very interested in is the one you havewith your customers. After all, that’s what keepsthe money coming in and the wheels turning.But, the relationships your business developswith community officials, suppliers,and the regulatory community arealso important to your business.That is where you get informa-tion and the support to makeyour program more effective.

The opinions of your neigh-bors and the community aroundyou are important to the successof your business. How do you tell

these people that you are taking steps to beenvironmentally friendly? First, you can post acopy of your company environmental policy sothat it is visible to anyone who visits yourbusiness. Look for a way to make them a partnerin your efforts such as having them return yourpackage for a refill. This gives them yet anotherreason to come see you. Another idea is tosponsor an education day for a local schoolbiology, ecology, or environmental science classto tour your facility. Every parent that asks“What did you do in school today?” will get tohear a little about your company. You can alsopost information or make information availableon the latest improvement you made at your

business that made a positiveimpact on the environment.Place this information in yourfront office to help waitingvisitors pass the time.

Companies who don’t seetheir end users in person canadd information about positiveenvironmental achievementsdirectly to the product packag-

37

ing. You can modify your packaging to show useof a post consumer recyclable product or thepotential for recycling after use. These steps mayhelp catch the eye of new customers as well. Youcan create a refill version of your product thateliminates the large packaging completely. Thismay attract the customer who is conscious aboutthe amount of waste they generate or it may justbe more convenient to carry or store. You canalso pursue obtaining environmentally friendlydesignations for your products such as “EnergyStar®” or “Grown in accordance with theCalifornian Organic Foods Act.” Consumers inmany markets have proven that they are inter-ested in buying environmentally superior prod-ucts. People will invest extra money in energyefficient products if they know that theseproducts will pay for the difference in futuresavings. The market for organically grownproduce continues to increase even though theprices for these items are substantially greaterthan their less environmentally sound competi-tors. There are organizations and web sites thatspread the word about green products. Yourbusiness may be able to obtain a listing on thesesources if your product is produced in anenvironmentally friendly manner.

How can the activities of ourHow can the activities of ourHow can the activities of ourHow can the activities of ourHow can the activities of oursuppliers complement oursuppliers complement oursuppliers complement oursuppliers complement oursuppliers complement ourefforts towards environmentalefforts towards environmentalefforts towards environmentalefforts towards environmentalefforts towards environmentalmanagement?management?management?management?management?

Your suppliers can be an extension of yoursuccessful program. Once you communicate to

your suppliers and vendors that you favor rawmaterials and services that result in improvedenvironmental performance, they can assist youwith your needs. They can reformulate your rawmaterials to meet your waste reduction goals andhelp you find better substitute products. Theycan offer “just in time” delivery, allowing you tokeep less hazardous chemicals on-site at anygiven time, and possibly to use smaller contain-ers. Some suppliers will allow you to returnunused product to be beneficially reused orrecycled in their process. You can encouragethem to incorporate recycled materials in theirproducts and packaging, or to modify thequantity of product or the product container tobest fit your needs. You can talk with them aboutthe option of returning their packaging for arefill. Many companies have discovered that itsaves them money to pick up the empty contain-ers when they deliver fresh product, rather thanto constantly replace them.

When you consider a new product:• Ask manufacturers for substantive data on

their green products compared with conven-tional products.

• Obtain customer references to verifyproduct performance.

• Request a guarantee policy and special pricesto test green products on a trial basis.

• Determine whether another organizationhas certified that the product is environmen-tally preferable.


38

Of course you wantto make sure that thegreener productsperform to acceptablestandards, are com-petitively priced, and

do not offset environ-mental gains in other areas,

such as a cleaning product that requires morewater. There are resources that can help youmore quickly identify environmentally superiorproducts, or get a sense of what’s available in themarket. EPA’s Comprehensive ProcurementGuidelines at www.epa.gov/cpg/ providerecommended specifications for recycled contentfor a variety of products. Another resource is theGreen Seal program at www.greenseal.org.

What’s the key to improvingWhat’s the key to improvingWhat’s the key to improvingWhat’s the key to improvingWhat’s the key to improvingmy image in the greatermy image in the greatermy image in the greatermy image in the greatermy image in the greatercommunity?community?community?community?community?

There are many organizations in place toassist small businesses. Taking advantage ofthese services is viewed positively by regulatoryagencies and can offer many benefits. A greatstrategy is to become active in the trade orindustry association for your type of business.Through this relationship, you will get valuableinformation about new regulations, and have amuch greater voice on Capitol Hill by joiningwith others. These can connect businesses forpeer exchange or business-to-businessmentoring. In addition to being a great resourceon questions about upcoming and existingregulations, your state’s Small Business Assis-

tance Program staff can help you identify whattrade and industry associations are out there andhelp you develop a strategy to get your messageout to the community. The Regulatory FlexibilityAct requires that the impact of new regulationson small businesses be studied before they gointo effect. Staying in the loop will allow you toput your two cents in before another rule isadded to the books. The Small Business Assis-tance Program staff can also tell you about otherservices you might want to take advantage of,such as agencies that help you find pollutionprevention ideas that save your business money.You might also want to become involved in yourstate’s Compliance Advisory Panel, a group ofsmall business owners appointed in some statesto advise the Small Business Assistance Programon how it can better serve small businesses.There is also a National Compliance AdvisoryPanel that advises EPA.

Consider having a representative from yourbusiness get involved in local boards or commit-tees such as the Local Emergency PlanningCommittee. Often the Chamber of Commercewill have an environmental affairs group. Theregulatory agency may have an industry feedbackgroup of some type.Their meetings giveyou an opportunityto obtain informa-tion about newdevelopments andto ask questions andshare concerns in arelaxed atmosphere.


39


Because you have invested effort regularly over many months or even years, your environmentalmanagement program has grown strong. Like a healthy tree, it provides protection for you and yourneighbors. You have set up an approach to environmental management that naturally leads to ongoingimprovement. You may not realize it, but you have put in place an environmental management system.If you want to, you can even seek outside recognition or official verification of your environmentalmanagement system. This Section of the Guide explains the components of an environmental manage-ment system and how you can determine whether you have all the components in place. It also describeswhat kinds of official recognition you can seek for your environmental management system, and what toconsider when deciding whether seeking recognition is a good idea for your business.

VI. Summary

What is an environmentalWhat is an environmentalWhat is an environmentalWhat is an environmentalWhat is an environmentalmanagement system?management system?management system?management system?management system?

An environmental management system (EMS)is an organizational approach to environmentalmanagement that incorporates quality improve-ment principles (sometimes referred to as “Plan-Do-Check-Act”) to develop, achieve, review, andmaintain an environmental policy. The compo-nents of an environmental management systemwere outlined in 1995 in a standard developed bythe International Organization for Standardiza-tion called ISO 14001. Since then, many ap-proaches to environmental management systemshave been developed, but nearly all have similarcomponents:

Environmental Policy. This is the statementby top management of their intentions andprinciples in relation to environmental perfor-mance. It is at the heart of the environmentalmanagement system and provides the frameworkfor planning and action the organization takesthrough the environmental management system.

Environmental Planning. The steps informal environmental planning include figuringout all the ways the business impacts the envi-ronment (called “environmental aspects”),identifying the legal and other requirements thatthe business must comply with, setting goals andtargets to improve environmental performance,and putting in place a written program to achieve

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

40

VI. Summary

your goals. The plan also documents key ele-ments of environmental management includingthe environmental policy, responsibilities,environmental manual, applicable standardoperating procedures and best managementpractices, recordkeeping, document control,reports, communication, training, monitoring,and corrective action.

Implementation and Operation. This partof the environmental management systemdefines the structure and assigns responsibilityfor environmental management. It lays outtraining needs and how they will be met. It setsup communication channels to make sure thateveryone within your business is aware of theenvironmental management system and thatpersons outside the company can provide input.It puts in place an information managementsystem that includes document control. Itoutlines procedures for control of operationsthat impact or have potential to impact theenvironment and sets up an emergency pre-paredness and response program.

Checking and Corrective Action. Thisincludes the methods for monitoring processesand measuring their impact on the environment.It identifies what actions the business takes tocorrect problems that come up and to preventthem from happening again. It defines who isresponsible for taking action if there is non-conformance. It defines what environmentalrecords must be kept and for how long. It alsoexplains the audit program used to check onhow well the business is meeting its environmen-tal management goals.

Management Review. This is a process inwhich the business owner and other key peoplereview the environmental management system todetermine if it is still suitable and effective, andwhether the business is doing what it hascommitted to do.

How does what I’ve done so farHow does what I’ve done so farHow does what I’ve done so farHow does what I’ve done so farHow does what I’ve done so farrelate to an environmentalrelate to an environmentalrelate to an environmentalrelate to an environmentalrelate to an environmentalmanagement system?management system?management system?management system?management system?

Although the description of an environmentalmanagement system may be daunting, how toput it in place has already been described inearlier Sections of the Guide, as shown by Table2. You can see that if you continue to makesteady progress on the recommendations inSections II through V of the Guide, you willhave nearly all the components of an environ-mental management system. Even if you don’thave all of the elements in place yet, keepingthem in mind helps you get a vision of the fullpotential of your environmental managementprogram as it keeps improving over time.

How do you know when you have assembledall the components of an environmental man-agement system? You can find this out yourselfby comparing what you’ve got in place at yourbusiness against the ISO 14001 standard oranother widely accepted benchmark. This isreferred to as doing a “gap analysis.” If your gapanalysis finds that you have all the componentsof the environmental management system inplace, then you need to look at whether yourenvironmental management system is perform-

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VI. Summary

ing the way you want it to. Is your business’performance consistent with your environmentalpolicy? Are you making forward progress onenvironmental objectives and targets? This isreferred to as doing an audit of your environ-mental management system, or an “EMS audit.”(This is the last piece you need to put in place tohave all the components of an environmentalmanagement system.) Let’s say that your gapanalysis shows that you have all the componentsof an environmental management system inplace, and your EMS audit shows that yourenvironmental management system is perform-ing as it was intended to. If so, then, congratula-tions! You have put in place an environmentalmanagement system.

To demonstrate that your business has met allof the criteria for an environmental managementsystem, you can also seek verification or certifi-cation from an outside party. For example, somestates have programs (often called “environmen-tal leadership programs”) that give recognition,awards, or other perks to businesses that demon-strate they have an effective environmentalmanagement system in place. EPA also has aprogram, called National Performance Track,that recognizes and encourages top environmen-tal performers—those who go beyond compli-ance with regulations to attain levels of perfor-mance that benefit people, communities, and theenvironment. (See www.epa.gov/performancetrack/index.htm.) You can obtainthe most official type of approval by hiring anoutside auditor to come in and look at yourenvironmental management system to confirm

that it has all of the elements required by ISO14001 and is functioning properly. If it passesthe audit, your company will be “ISO 14001certified.” This certification carries with it adistinction similar to being “ISO 9001 certified”for quality management.

Why would I want to have anWhy would I want to have anWhy would I want to have anWhy would I want to have anWhy would I want to have anenvironmental managementenvironmental managementenvironmental managementenvironmental managementenvironmental managementsystem?system?system?system?system?

After working through previous GuideSections, you already know many of the benefitsof having an environmental managementsystem. It has helped you cut costs. It gives you acomfort level that you have covered your basesas far as meeting regulatory requirements, andthat there will be no unpleasant surprises. Itmakes it easier for you to answer inquiries fromemployees, neighbors, community leaders, andregulators about your business’ environmentalperformance. It demonstrates your business’commitment to being a good neighbor and putsinformation at your fingertips about yourbusiness’ track record and current environmentalefforts.

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Table 2: Correlation Between Environmental Management System (EMS) Components and Guide Sections

EMS ComponentEMS ComponentEMS ComponentEMS ComponentEMS Component

Environmental PolicyEnvironmental Planning! Identify environmental aspects! Identify legal and other requirements! Set objectives and targets! Written plan

Implementation and Operation! Structure and responsibility! Training

! Communication

! Documentation and document control

! Operational control

! Emergency preparedness and response

Monitoring and Measurement! Monitoring and measurement

! Non-conformance and corrective andpreventive action

! Records

! EMS audits

Management Review

VI. Summary

IV. How do we involve our employees in environmental management activities?

II. How can I understand how my business is affecting the environment?II. How can I get a handle on environmental laws and regulations?IV. Is this working—are we getting the results we wanted?IV. Is this working—are we getting the results we wanted?

IV. How do we go about getting things written down and why should we spend time on this?II. What are the basics of good environmental management?IV. How do we go about getting things written down and why should we spend time on this?II. What are the basics of good environmental management?IV. How do we involve our employees in environmental management activities?V. How do I communicate our environmental management efforts to those outside of our business?

What’s the key to improving my image in the greater community?II. What are the basics of good environmental management?IV. How do we go about getting things written down and why should we spend time on this?II. All Parts.III. How can I use the process map to save money?

How do I predict savings from proposed projects?IV. All Parts.II. What are the basics of good environmental management?IV. How do we go about getting things written down and why should we spend time on this?

III. How can I use the process map to save money?How do I predict savings fromproposed projects?

IV. Is this working—are we getting the results we wanted?II. What are the basics of good environmental management?IV. Is this working—are we getting the results we wanted?II. What are the basics of good environmental management?IV. How do we go about getting things written down and why should we spend time on this?IV. Is this working—are we getting the results we wanted?IV. Is this working—are we getting the results we wanted?

Guide Section(s) and Part(s)Guide Section(s) and Part(s)Guide Section(s) and Part(s)Guide Section(s) and Part(s)Guide Section(s) and Part(s)

43

VI. Summary

So why would you want to obtain outsiderecognition or certification for your environmen-tal management system? Obtaining recognitionfrom a state environmental leadership programor EPA’s National Performance Track mayimpress some of your customers and distinguishyou from your competitors. ISO certification isexpensive, so it may not be worthwhile for asmall business to do. But, if one of your majorcustomers requires it, as some of the majorautomobile manufacturers have of their suppli-ers, it may be worth the money. Also, the rigorof the ISO certification process provides astructure and focus that prevents environmentalmanagement efforts from backsliding over time.

Why are trade organizations andWhy are trade organizations andWhy are trade organizations andWhy are trade organizations andWhy are trade organizations andregulatory agencies supportingregulatory agencies supportingregulatory agencies supportingregulatory agencies supportingregulatory agencies supportingenvironmental managementenvironmental managementenvironmental managementenvironmental managementenvironmental managementsystems?systems?systems?systems?systems?

Many businesses have demonstrated thatthrough their environmental management systemthey can make great improvements in theirenvironmental performance while saving moneyand increasing productivity. As a result, tradeassociations and other business organizationssupport environmentalmanagement systemsbecause they make goodbusiness sense. Also, ifthe majority of compa-nies in a business sectoradopt environmentalmanagement systemsand show greatly

improved environmental performance, thisenhances the long term viability of the businesssector, and gives it a fresh marketing angle.

Regulatory agencies support environmentalmanagement systems because they are aware thatthe traditional “command and control” systemof environmental regulation is limited in itspotential to have major positive impacts on theenvironment over the long term. They are moreopen to working with industries and tradeorganizations on more flexible and perfor-mance-based approaches to improving environ-mental performance than traditional compliancemethods. When making agreements to allowsuch flexibility, regulatory agencies often requirebusinesses to put an environmental managementsystem in place to show accountability for theiractions in the absence of certain elements of thetraditional compliance framework. This allowsregulatory agencies to make forward progresstowards streamlining regulations while account-ing to the public that the new systems areworking. Regulatory agencies have also incorpo-rated the environmental management systemapproach into their enforcement activities. It isvery common for regulators to require a violatorto put an environmental management system inplace as part of the settlement agreement.

How can I get help with puttingHow can I get help with puttingHow can I get help with puttingHow can I get help with puttingHow can I get help with puttingan environmental managementan environmental managementan environmental managementan environmental managementan environmental managementsystem in place and gettingsystem in place and gettingsystem in place and gettingsystem in place and gettingsystem in place and gettingrecognition for it?recognition for it?recognition for it?recognition for it?recognition for it?

Your Small Business Assistance Program can

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give you assistance with environmental manage-ment systems. (Again, to get contact informationfor your state, visit www.smallbiz-enviroweb.org/or call EPA’s Small Business Division at 800-368-5888.) They can also help you make applicationto EPA’s National Performance Track program,make you aware of other recognition programsthat your business may qualify for, or put you intouch with reputable third party auditors if youwish to seek ISO 14001 certification. EPA’sSmall Business Division can also provideassistance and refer you to other contacts andresources. Finally, if you want to learn moreabout environmental management systems, thereis a wealth of resources available at EPA’swebsite, www.epa.gov/ems/. At that website,you might be especially interested in the casestudy for Federal Foam, a small business inWisconsin that decided to seek ISO 14001certification. Another good resource is thecompanion publication to this one, DocumentingYour Environmental Management Plan—A Workbookfor Small Business, which includes worksheets forachieving the steps outlined in this Guide. It isavailable through EPA’s Small Business Divisionand at www.epa.gov/ems/. EPA’s Small BusinessDivision is also collecting best managementpractices for selected business sectors. If yourbusiness sector is included, you may want to takea look at these.

What’s the bottom line here?What’s the bottom line here?What’s the bottom line here?What’s the bottom line here?What’s the bottom line here?

This Guide has given you tools to develop acomplete environmental management system,geared to your business’ available time andresources. No matter how long it takes, if youfollow the recommendations in Guide SectionsII through V, you will have a solid complianceprogram, an environmental policy to focus yourefforts, programs and procedures that arewritten down and kept up to date, and clearlydefined roles that are understood by eachemployee. You set goals and targets for each yearand have a plan to move your business in thedirection of improvement. You work at this overtime because it makes good business sense,increases your business’ productivity, and bringsyou peace of mind. If you have gotten this far,your business has all the components of anenvironmental management system and is in agood position to seekoutside verification.But, in the end,whether or not itwill be valuable orcost effective toseek outside verificationof your environmentalmanagement system is upto you.

VI. Summary

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Type of Impact

Wastes containing chemicals even in tinyamounts.

Examples: Parts washing fluids, paintthinners, acids, caustics, toxic chemicals likepesticides or chlorinated solvents, andwastes that have toxic metals in them likelead, cadmium, or chromium.

Waste disposal liability.

Example: The company that took your wasteten years ago went bankrupt, leaving acontaminated landfill. Now you may berequired to share in the cost for the site’sclean-up.

Air pollutants released from businessoperations.

Examples: Boilers and furnaces, paint anddye application, parts cleaning, sand blastingor other dusty operations.

Contaminated water from businessoperations or propery.

Examples: Process water going off yourproperty through a drain. Storm water thatruns off your property through a storm drainor another waterway.

Applicable Law(s)

Resource Conservationand Recovery Act (RCRA)of 1976 and subsequentamendments

ComprehensiveEnvironmental Response,Compensation, and LiabilityAct (CERCLA)

Clean Air Act (CAA) and itsamendments

Clean Water Act (CWA)and its amendments

Overview of Regulations1

Tells you what a hazardous waste is and sets requirements for taking care of it on-site, moving it from oneplace to another, and where and how it may be treated or disposed. Regulation includes special provisionsto make recycling easier for universal wastes: mercury-containing lamps, batteries, mercury switches, andrecalled pesticides.

Thresholds: Applies to any amount of hazardous waste.Requires Permit? Yes, for certain hazardous waste activities.Regulatory Reports? Yes, annually, for some, but not all, generators, and any business that must have a permit. Mayalso require notification of the regulatory agency of hazardous waste activities depending on the amount of wastegenerated.Important Considerations: The law requires your business to determine whether any of its wastes arelegally classified as hazardous. Make sure this is done properly to avoid severe financial and liability risk ifwastes are illegally disposed (even by accident).

Maintains “Superfund” to pay for clean up of hazardous waste sites up front. Later, the Environmental ProtectionAgency (EPA) can recover costs from each “Responsible Party (RP).” Those who once owned the site, presentlyown the site, or sent waste to the site can be an RP.

Thresholds: Anyone who owned or contributed waste to a site can be an RP.Requires Permit? No.Regulatory Reports? No, but lots of other paperwork.Important Considerations: If you ever receive a letter that suggests your business may be an RP, get a goodenvironmental attorney before you reply.

Sets up a system of controls to be sure that pollutants coming from a business’ operations or heating plant do nothurt the overall air quality in the region. It regulates numerous pollutants. Of particular concern to small businessesare volatile organic compounds (VOCs), nitrous oxides (NOx), and hazardous air pollutants (HAPs), thoughadditional ones may apply.

Thresholds: Numerous thresholds for specific air contaminants, usually given in tons or pounds per year. Thesethresholds are based on your business’ potential to emit (PTE), assuming 24 hour production at peak rates, as wellas its actual emissions, so your business could be covered even if its actual emissions are low.Requires Permit? Yes, depending on what contaminants are emitted and the amount of actual and potentialemissions.Regulatory Reports? Yes, annually, if your business is subject to a permit. Daily monitoring and quarterly reportingmay also be required depending on the type of operation.Important Considerations: A business may require a permit based on its potential to emit, even if its actualemissions do not exceed thresholds. Also, you may have to obtain a permit before you can beginconstruction of operations that will increase air emissions.

Sets up a system of controls to be sure that contaminated water coming from cities, businesses, and farms does nothurt waterways such as wetlands, ponds, streams, and lakes, or harm groundwater quality. Industrial wastewatercannot be discharged into a septic system. If you put anything but sanitary waste down the drain, you must abide bythe local sanitary sewer ordinance.

Thresholds: Vary for each contaminant based on where it is going and what authority has control. It can be verysmall, such as a couple parts per million.Requires Permit? Yes, if your business dumps contaminated water into a waterway, onto the ground, or into thestreet, a storm drain, or a ditch, you may have to obtain a permit, even if you treat the wastewater first. Some localauthorities also require a permit for discharges to the sanitary sewer. Under storm water regulations, even if you arenot required to have a storm water permit, you still may have to file a “no exposure certification.”Regulatory Reports? Yes, if your business is covered by the permit requirements. Monitoring may also be required.Businesses required to have a storm water permit will also have to submit a storm water pollution prevention plan.

Table 3: Major Categories of Environmental Regulations

1This table provides only a general overview of regulatory requirements. It is not all inclusive and does not describe specific state or local requirements. Its purpose is to give you an overallunderstanding so you will be better prepared to seek assistance from your state Small Business Assistance Program contact and to begin looking at specific regulations that apply to your business.

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Table 3: Major Categories of Environmental Regulations (cont’d.)

Applicable Law(s) Overview of Regulations1


Makes possible a national emergency response program for certain spills and accidental releases. If yourbusiness releases certain chemicals, called “hazardous substances,” you must notify the National ResponseCenter.

Thresholds: Amount of a substance released is more than or equal to its listed “Reportable Quantity,” or “RQ.”These amounts vary by substance and can be as small as one pound.Requires Permit? No.Regulatory Reports? Yes, in follow up to reported releases.

Requires you to notify state and local emergency planning commissions immediately if your business has anunplanned release of certain chemicals. In addition to the CERCLA hazardous substances mentioned just above,it covers “extremely hazardous substances” that are listed in regulations put in place to carry out the EmergencyPlanning and Community Right-to-Know Act.

Thresholds: Amount of a substance released is more than or equal to its “Reportable Quantity” (RQ).Requires Permit? No.Regulatory Reports? Yes, in follow up to reported releases.

Puts in place coordination and planning so that state and local government agencies can prepare for and respondto hazardous chemical spills. If your business is covered by these requirements, you must notify state and localplanning commissions and assist these agencies with maintaining the local emergency plan, including providingpertinent information.

Thresholds: If the amount of a listed substance kept on-site at your business is more than or equal to the listedThreshold Planning Quantity (TPQ). then you must participate in local emergency planning as described above.TPQ’s vary by substance and can be as little as one pound.Requires Permit? No.Regulatory Reports? Notification of any changes at your facility that affect emergency planning.

Provides a way for the pubic to access information about hazardous chemicals that community businesses use,store, or release to the environment. Requires you to submit copies of Material Safety Data Sheets for certainhazardous chemicals you keep and use at your business, and to report how much of each you have.

Thresholds: For listed substance, the TPQ or 500 pounds, whichever is less; for all other OSHA hazardouschemicals, 10,000 pounds.Requires Permit? No.Regulatory Reports? Yes, an annual chemical inventory report, called a “Tier 1” or “Tier 2” report is required.Which report your business will have to file depends on local and state requirements.

For certain hazardous chemicals used by certain industries (as determined by SIC code), requires you to measureor estimate the amount that came on your site during the year and what happened to it; such as, how much wentinto your wastestream. You are exempt if your business does not have 10 or more full-time employees. Thisinformation is made available to the public, such as on EPA’s EnviroFacts web site.

Thresholds: You manufacture or process 25,000 pounds or otherwise use 10,000 pounds of a listed hazardoussubstance at your site in a year. (Certain chemicals of special concern have lower thresholds, like mercury at 10pounds, lead at 100 pounds, and polycyclic aromatic compounds at 100 pounds.)Requires Permit? No.Regulatory Reports? Yes, an annual Toxic Release Inventory (TRI) that identifies the amounts of toxic chemicals,covered by the requirement, your business releases to the environment.

ComprehensiveEnvironmental Response,Compensation, andLiability Act (CERCLA)

Emergency ReleaseNotification under theEmergency Planning andCommunity Right-to-KnowAct (EPCRA)

Emergency Planningunder EPCRA

Hazardous ChemicalReporting: CommunityRight-to-Know underEPCRA

Toxic Chemical ReleaseReporting: CommunityRight-to-Know underEPCRA

Type of Impact

Chemical spills to air, water, or land.

Examples: A chemical leaks into a stormdrain and contaminates a stream. A valve onyour refrigeration unit fails, releasingammonia gas to the air.

Emergency planning for chemicals storedand used at your business site.

Example: Your business has hazardouschemicals on-site that could pose a dangerto the local community if they spilled, werereleased, or involved in a fire.

Telling the community and localresponders about chemicals stored andused at your business site.


Telling the community and regulatorsabout chemicals released into theenvironment as part of your normalbusiness operations.


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Table 3: Major Categories of Environmental Regulations (cont’d.)


Managing Chemical Risks.

Example: You have a process within yourbusiness operations that could release adangerous amount of toxic chemicals to theair if it malfunctioned.

Pesticides.

Examples: Your staff apply weed killers onoutdoor property, use pesticides to controlrodents or insects, or you hire a pesticideapplicator to do this.

Polychlorinated Biphenyls (PCBs).

Example: You have equipment that uses aPCB-containing transformer as acomponent; you have to replace PCB-containing electrical ballasts in your lightingfixtures.

Storage, management, and disposal ofpetroleum products.

Examples: Your business has one or morestorage tanks for petroleum products suchas gasoline, diesel fuel, or heating oil. Youbusiness drains used oil from motorvehicles. Your business has potential to spillpetroleum products into a waterway.

Chemical AccidentPrevention under theClean Air Act

Federal Insecticide,Fungicide andRodenticide Act (FIFRA)

Polychlorinated Biphenyls(PCBs) under the ToxicSubstances Control Act(TSCA)

Underground storagetank and used oilregulations of RCRA.EPA’s Oil PollutionPrevention Regulation,part of CWA.

Requires you to evaluate certain processes of your business operations to determine if it could pose a danger toyour neighbors through an accidental chemical release. If so, you must undertake planning to prevent malfunctionsfrom occurring and to reduce the harm from a chemical release if it does occur.

Thresholds: The amount of a chemical in a process is equal to or more than its listed threshold.Requires Permit? No.Regulatory Report? Yes, requires initial submission of Risk Management Plan and registration form whichdocuments that your business has completed the hazard assessment, analysis, and planning necessary to preventand respond to accidental chemical releases from any process covered by the regulation. Also, requires updatesaccording to a schedule given in the regulation.

Governs the use and disposal of all pesticides to prevent harm to people and the environment. Requires that yoube sure that people using certain pesticides at your business are certified, and, if you are an agricultural business,that you put in place an extensive Worker Protection program for employees who work with pesticides. (There aremany additional requirements if your business manufactures pesticides or creates plants that are genetically pestresistant.)

Thresholds: Applies to any amount of restricted use pesticide, and certain other pesticides.Requires Permit? Requires certification of persons who apply certain pesticides.Regulatory Report? No.

Requires identification and extensive recordkeeping for PCB-containing items. Sets requirements for taking care ofthese items on-site, moving them from one place to another, and where and how they may be treated or disposed.

Thresholds: Applies to certain PCB-containing material (depends on whether PCB concentration of the source ofcontamination was 50 ppm or greater).Requires Permit? Yes, if your business treats or disposes of PCB-containing wastes.Regulatory Report? Yes, requires submission of annual report if you use or store greater than 45 kg at one time.Reporting requirements are identified in 40 CFR 761.180.

Applies to petroleum products stored and used such as vehicle fuel, heating oil, and motor oil. Undergroundpetroleum storage tanks must meet performance standards, the purpose of which is to prevent leaks into soil orgroundwater. (Underground storage tank systems containing other hazardous chemicals may also be regulated.)Requires additional controls and management practices to detect, prevent, and respond to petroleum leaks or spills.If your property becomes contaminated by a petroleum spill, there are specific clean up requirements that apply.

Thresholds: Your business is required to develop a Spill Prevention Control and Countermeasure Plan if yourbusiness has a total on-site storage capacity of more than 1,320 gallons of petroleum products in abovegroundtanks and containers (containers less than 55 gallons in capacity are exempt) or has underground petroleumstorage capacity of greater than 42,000 gallons (completely buried tanks regulated under 40 CFR Parts 280 and281 are exempt), and can reasonably be expected to discharge oil in harmful quantities into waters of the UnitedStates.Requires Permit? No.Regulatory Report? Yes, in follow up to reportable releases.

Type of Impact Applicable Law(s) Overview of Regulations1

United StatesEnvironmental Protection Agency(1801)Washington, DC 20460

Official BusinessPenalty for Private Use $300

EPA233-K-02-001September 2002

Documents

Practical guide to environmental management for small business · The Practical Guide to Environmental Management for Small Business is your Guide to getting orga-nized and making