Transcript Similarities and Differences Among Environmental
Similarities and Differences Among Environmental Management Systems
Richard N. Andrews Professor of Environmental Policy Director, National Database on Environmental Management Systems University of North Carolina at Chapel Hill
MSWG Conference on “Learning Together,” June 4, 2001
National Database on Environmental Management Systems NDEMS: A Joint Project of The University of North Carolina at Chapel Hill and The Environmental Law Institute Supported by the U.S. Environmental Protection Agency In cooperation with the Multi-State Working Group (MSWG) on Environmental Management Systems
National Database on Environmental Management Systems
Purpose
To determine effects of ISO and other environmental management systems on • Environmental performance/conditions • Economic performance • Regulatory compliance • Pollution prevention • Engagement with stakeholders
National Database on Environmental Management Systems
Database Scope
• 50+ pilot facilities in 12 economic sectors • Business and government, large and SME • Implementing EMSs (ISO 14001 and others) • In 10 states
(AZ, CA, IL, IN, NC, NH, OR, PA, VT, WI)
• Baseline (3 years) EMS design updates
Activities
EMS Planning Process
Environmental Policy Scope of EMS Aspects Impacts Significance e Targets Objectives
Need for Empirical Research
• Actual use of ISO 14001 EMS procedure: – What activities, products, services included in EMS scope?
– What environmental aspects, impacts?
– Which designated as significant, by what processes and criteria? – What objectives and targets?
• Implications for business, public expectations
Presentation
• Comparison of EMS planning documents • Data from 40 facilities so far • Data Source: National Database on Environmental Management Systems (NDEMS)
Should Expect Variation
• Differences in sectors, operations • in size, scale, complexity • in environmental conditions • in competence, perceptions, priorities, teamwork • in interpretation of the ISO 14001 standard
What Have We Found?
Activities
• ISO 14001 Guidance
:
– An organization should identify the various activities, processes, products or services that are included in the scope of the EMS – Distinguishing them in such a way that they are “large enough for meaningful examination and small enough to be sufficiently understood.”
Activities: Findings
• Great variation in characterization, detail • Majority defined activities as production processes, on-site operations, business functions • Examples: – Manufacturing, maintenance, construction, housekeeping, grounds-keeping, transportation, waste management
Activities: Findings
• Some (15) identified more specific processes and equipment operations • Examples: – Boilerhouse operations, rinsing, stripping, molding, cleaning, extrusion, polishing , de icing, forklift operation, aircraft refueling • A few (6) listed specific chemicals used: – Nitric acid, chlorine, cyanide, heavy metals, alcohol, mercury, ...
Activities: Findings
• Still others (6) listed specific resource uses and waste streams – Use of electricity, water, raw materials – Waste generation, air emissions, wastewater discharges, land contamination • A few: minute detail – Trash, cardboard, soiled rags – Drinking fountains, toilets, janitorial sinks, shoveling snow
Activities: Findings
• Few included products or services • Nearly all focused on site-specific production and support activities • Few mentioned life-cycle analysis, product stewardship, sustainability
Aspects
• ISO 14001 guidance: – Identify all environmental aspects of activities, products and services – Aspect = element of activity, product or service which can have a beneficial or adverse effect on the environment – Include all those that the organization “can control and over which it can be expected to have an influence”
Findings – Aspects
• Varied in characterization, specificity • More than half included more detailed actions associated with each activity • 25% simply duplicated activity lists • Three identified more detailed business functions without environmental content
Example 1: AAIS Identification
- Note discrimination of significance for some impacts
Activity
Synthesis Synthesis Synthesis Synthesis Synthesis Synthesis Synthesis Synthesis Synthesis
Aspects
Chemical usage Glassware disposal Glassware cleaning Residue from reaction Residue from reaction Cleaning from synthesis Column hardware Heat, oven Air emissions Raw materials
Impacts
Solid waste Cleaning agent disposal Solid waste disposal Hazardous waste disposal Liquid hazardous waste disposal Solid waste disposal Energy use Volatile solvents yes yes no no no no
Significance
no no no
Example 2: AAIS Identification
- Note every identified impact ranked as significant
Activity
Facility operations Facility operations Facility operations Facility operations Facility operations Facility operations Facility operations Facility operations
Aspects
Air Air Hazardous waste Hazardous waste Hazardous waste Water Water Water
Impacts
Environmental impact Compliance Compliance Environmental impact Money Compliance Environmental impact Money
Significance
Yes Yes Yes Yes Yes Yes Yes Yes
Impacts
• ISO 14001 guidance: – Organization should identify as many as possible of the actual or potential environmental impacts associated with each aspect of its activities – Impact = change which takes place in the environment as a result of the aspect, either positive or negative
Impacts -- Findings
• Impacts usually described generically – Most (32) identified impacts only by 15-20 generic types, without details or quantification • Degradation of air, water, groundwater, soil • Use of energy, water, natural resources; • Generation of wastes, impacts on landfill capacity; noise; wildlife habitat, endangered species
Impacts -- Findings
• A few mentioned others: cultural resources, pathogens and vectors • Six included occupational health and safety • Only seven included positive environmental effects – Can be important: e.g. natural resource management, cleaner-production technologies
Significance Determination - Findings
• Variation in procedures for determining • Also in actual judgments of significance – What is significant in the judgment of one facility may not seem so to another – Major hazardous waste streams or air pollutant emissions, versus snow-blower fuel and oil contaminated Q-tips
Significance Ranking Judgments and Procedures
Facility
A B C
Activity
Mill operations Mill operations Mill operations Compressors (product) Nitric acid stripping baths pH adjustment Oil-soaked rags Municipal trash Toilets
Aspect
Effluent discharge Scrap board Scrap board Compressors (product) Nitric acid stripping baths pH adjustment
Impact
Nutrient loading Decreased raw material use Decreased waste generation Land
Significant
Yes No Yes Water Water No Yes Hazardous waste Solid waste Wastewater discharge, water consumption Release—soil and water Depletion of natural resources Depletion of natural resources, POTW contamination Yes Yes Yes
Basis
Total rank score = 25 Total rank score = 7.7
Total rank score = 7.0
Impact rating = 334 Impact rating = 174 Impact rating = 39; permitted activity Hazardous waste is categorically significant Solid waste has immediate impact on environment Semi-controlled potential impact
Significance Ranking Judgments and Procedures
Facility
D E
Activity
Lubrication Air emissions
Aspect
Waste Regulated sources Air emissions Unregulated sources
Impact
Q-tips with oil or silicone
Significant
Yes
Basis
Worksheet: env. and business considerations, frequency, severity, cost Stringently regulated Potential releases to environment Potential releases to environment No Low level of regulation Water use Municipal Natural resource depletion No Low cost, not regulated from environmental perspective
Objectives and Targets - Findings
• Four distinct types of objectives and targets identified: – Performance-oriented – Project-oriented, – Management activity-oriented – Compliance-oriented – A few others -- no common category
Performance-based O & T
Example
A B
Objective
Reduce hazardous air pollutants by 10%
Target
0.00048 lbs. of HAPs per pound of rubber processed (monthly monitoring) Reduce hazardous waste by 10% 3,734 lbs. total (Average = 415 lbs.
per month; monthly monitoring)
Target Date
December 31, 2000 December 31, 2000 C D E F Recycle industrial waste (any item that could be disposed of in a sanitary landfill) Minimize HAZMAT incidents Increase eco-productivity index for general energy usage Water conservation Recycle 58% of industrial waste (monthly monitoring) Reduce trichloroethylene spills to zero Increase by at least 1.5 points in 2000 and 2001 Reduce water usage by 5% per million gallons/pounds of product from 1997 level December 31, 2000 December 2000 July 1, 2000 Not specified
Project-based O & T
Example
A
Objective
Reduce disposal costs and future potential liability for cleanup of waste disposal sites B Recycle antifreeze C D E
Target
Substitute coolant containing chlorinated paraffin Install antifreeze recycling system
Target Date
December 1999 Completed in 1998 Reduce mop water sent as waste Install evaporator with belt skimmer for oil removal Eliminate perchloroethylene parts cleaning Eliminate use of enamel based paint and solvents 100% elimination Eliminate use of enamel-based paint and solvents December 1999 June 1, 2000 Summer 1999 F Stop landfilling light bulbs Properly recycle/dispose of all light bulbs July 30, 1998
Management, Training, and Awareness-Raising as O & T
Example
A
Objective
Reduce solid waste disposal B Conduct quarterly safety committee meetings
Target
Increase employee awareness Conduct 2 meetings C D E
Target Date
December 2000 January 1, 2000 Assess hazardous materials and environmental awareness survey scores of laboratory workers See that scores demonstrate improvement over life of the project Not specified Conduct training for employees regarding recycling Manage vendor activities concerning chemical usage (assure vendors invited to come to the facility through the Procurement Department are aware of their responsibilities) 100% of all employees Vendor notification sent to all vendors who conduct environmentally impacting operations inside the plant March 2000 April 2000
Compliance Assurance O & T
Example A B C D E
Objective
Decrease CN in wastewater to eliminate violations Comply with FIFRA Comply with permit for … [34 separate regulatory requirements identified] Continue to implement existing preventive measures and spill response procedures Improve wastewater pretreatment quality
Target
CN concentration in effluent from CN oxidation tanks 50% lower than permitted, or 0/60 mg/L
Target Date
January 1, 2000 Maintain contractor (grounds maintenance) requirements PM = 10.82 tons/year, VOC = 1.45
tons/year, pH = 6.0-9.0, … [etc.] Maintain preventive and response measures Maintain BOD levels in our wastewater discharge less than or equal to 300 mg/l Not specified Not specified Not specified Ongoing from 11/98
Other Considerations
• Few included identifiable objectives related to life-cycle analysis, product stewardship • Only three facilities specifically mentioned risk reduction O & T – All for maintaining regulatory compliance • Very few involved external interested parties
Target Dates
• Target dates: three categories – Already accomplished (a few cases) – Coming year (2000-01) – “Continuous," “ongoing" • None mentioned any O & T for more than two years in the future – Immediate, incremental, facility-level • No longer-term strategic objectives
Conclusions …
• Facilities have great discretion in EMS design • In practice, EMSs vary significantly • Content more important than certificate per se • Certification = organization has good information easily available • Key issues: Internal versus external uses, openness about performance
National Database on Environmental Management Systems