Practical Guide to

Management for

Small Business

Environmental

Small

Business

Division

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1

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 the

valuable review and comments received from EPA, state Small Business Assistance Program representatives, Small Business Ombudsmen, National Compliance Advisory Panel members, trade

associations, small business owners, and others. Your suggestions and assistance were greatly

appreciated.
 2

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
3

I. Introduction

What is this Guide about?

The Practical Guide to Environmental Management

for Small Business is your Guide to getting organized and making the most of the valuable time

you and your employees spend on environmental

affairs. It will help you design a management

plan that addresses all of the environmental

concerns of your business. The Guide will also

help you save money and make your business

look good in the eyes of your customers and

your community.

As the top person at your business, you have

to make the overall decisions and provide the

driving force for improving environmental

management. But, as a small business, it is likely

to take a team effort to make much progress,

and you will probably have to delegate some day

to day environmental activities to others. That is

why the Guide is written in plain language. It can

be easily understood by everyone at your business.

As you work through the Guide, you will find

some ideas that you can use right away to

produce immediate

results. Even

more important,

In a nutshell...

Do you as a small business owner feel like environmental management equals crisis management? Ever

wonder how to get control of all the environmental issues at your business once and for all without

sinking too much time and money into it? Don’t know where to start? This Guide will help you get a

handle on these questions and maximize the cost savings and other benefits associated with good

environmental management. Following the Guide’s step-by-step process, you will learn what good

environmental management is and how environmental management duties can slowly be pulled into

everyday activities without disruption. The end result will be that you can feel confident that your

company 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 a

reliable, responsible, and efficient environmental management program for your business!

○○○○○○○○○○○○○○○ ○○○○○○○○○○○○○○○○○○○○
 4

by going through the Guide step-by-step, you

will gradually be able to create an effective

system to manage your environmental responsibilities and make it much easier and less time

consuming to meet regulatory requirements—

one that will improve as time goes on.

Here is a quick preview of each

Guide Section. Guide Section.

Section II covers the basics

your business must have in

place to meet the requirements of environmental

regulations and to keep

employees, the community, and the environment

safe. (Don’t get discouraged: the following Sections

will show you how to make

these tasks more manageable as

time goes on.)

Once you have the basics in place, you can

begin to take advantage of the business benefits

of environmental management by working

through Section III. This Section shows you

how to use information you developed while

working through Section II to find ways to save

money by conserving water and energy and

reducing waste.

Section IV is about taking your early efforts

and getting them organized by writing a policy,

streamlining who does what, and measuring

progress. This enhances your business by making

I. Introduction

sure that environmental efforts support your

business strategy, that responsibilities are

handled in a productive way, and that you are

moving forward—not spinning your wheels.

Section V explains why it is valuable to share

your environmental efforts with those outside

your business. It provides suggestions for

showing off your environmental successes to

customers and your community and

for partnering with suppliers and

others to improve your

business’ environmental

performance.

Section VI looks at an

approach called an environmental management

system (EMS) which is

what all the other Sections of

the Guide lead up to. For those

of you who like to read the back of

the book first, you might want to glance at

Section VI to get a better idea of where the

Guide is headed.

The steps outlined in the Guide can be fit

into the time you and your employees have

available and the workflow of your business. It

could take a month to work through the Guide

if you can devote some sizeable chunks of time

to it, or more than a year if time is more restricted, but the end result will be equally sound.

The important thing is to devote regular attention to it while not detracting from your critical

business functions.
5

I. Introduction

The Guide will help you develop a sound

approach to environmental management.

However, it is not a manual on environmental

laws and regulations. It will not tell you the

details of what you need to do to comply with

specific regulations. However, the Guide does

tell you who you can rely on for help with

understanding environmental regulations, and

how this important step fits into the overall

environmental management strategy.

Here’s a vision of what you can achieve by

working through this Guide: You will understand

all the ways your business affects the environment. Your employees will be prepared to handle

spills, they will know how to keep safe, and your

business will fulfill the requirements of environmental regulations. You will find ways to save

money, increase productivity, and maybe even

lessen regulatory requirements. Environmental

management responsibilities will be efficiently

organized and delegated within your business,

and good practices will make compliance easier.

By being better organized and taking a strategic

approach to environmental management, you

and your staff will spend less time on it, yet your

business will continue to improve its environmental performance. Your environmental

management program will be so good that you

will be able to show it off to customers and your

community.

The Guide is designed to go hand in hand

with the U.S. Environmental Protection Agency

(EPA) Workbook, Documenting Your Environmental

Management Plan—A Workbook for Small Business.

The Guide provides an explanation of the steps

to take to improve your business’ environmental

management activities. The Workbook gives you

a place to keep and organize all of the information you compile while working through the

document. If you would like to obtain a copy of

the Workbook, call EPA’s Small Business Division at 800-368-5888 or download it from

www.epa.gov/ems/or www.smallbizenviroweb.org.
 6

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

In a nutshell...

Now that you’ve planted the seed, you need to take care of the seedling. This Section of the Guide

explains how to put in place the critical functions a business must have to keep employees safe, prevent

and be prepared for spills, and comply with regulations. It is vital to get these functions under control

first because failing to do so poses a high legal and financial risk to your business. By working through

this Section with your employees, they will develop good habits that will make regulatory compliance

part of the daily routine and save time down the road. The ideas in this Section will get you organized

and help you make sure you’ve got the basics covered using a logical and systematic approach: First

you will learn how to develop a process map to quickly get a handle on how your business affects the

environment. In turn, this will help you determine what environmental regulations may apply to your

business. Then, with this background, you can put in place the essential activities of sound environmental management—being prepared for spills, labeling, housekeeping, training, recordkeeping, and being

ready for a regulatory inspection. These activities will tie together to provide a safeguard against

unexpected and costly environmental problems at your business. They will also provide a solid foundation that you can build on as you work through later Sections of the Guide to attain real cost savings

and increased productivity for your business.

How can I understand how my

business is affecting the

environment?

You know how when you open the box of a

new electronic gizmo like a computer or DVD

player, there is usually a handy picture laying on

top showing you how to connect all the parts?

This part of the Guide explains how

to create a picture of your company’s

processes that is just as handy. This

picture, called a process map, will

show what comes in and what goes

out of the process. The process map

is a great tool for environmental

management because it will help you

see how your business affects the

environment. This will help you

figure out what regulations might apply and at

what points in the process you need to keep

required records. Because it shows the flow of

chemical products through your business, it

allows you to identify the areas where spills are

more likely to happen, where housekeeping may

be a big concern, and what kinds of labels are

needed. You can make sure you are providing

training that fits each employee’s

responsibilities by looking at which

steps in the process map they are

involved with.

Getting started is easy. Look over

the example in Figure 1 to get an

idea of what your picture can look

like and fill in the blanks. Begin with

the basics: the raw materials, the
7

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

Figure 1: Generalized Process Flow Diagram
 8

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

process, and the product. Good start, but it isn’t

the complete picture. The process probably

requires additions other than just the raw

materials. Do you use a tool or dispenser to

introduce a raw material to the process? Do the

raw materials feed through some type of machine? If so, there are elements or processes

required to make it work—probably a power

source, possibly oil, filters, or parts that are

replaced when they are used up. As you examine

all the steps in the process and what makes each

of them work, you can add more detail to your

process map. At first, this diagram will qualify

rather than quantify the flow of materials—just

what is involved in the process, not how much.

You can plug in numbers later when your

company wants to look at process changes and

you need to measure results. When you look at

the process as a complete cycle, the pieces start

to fall into place. Raw materials are just one of

the resources utilized. For example, when you

consider that a specific tool is used and look at

the source of its power, it points out another

input for the diagram. Then, you can pinpoint

output details because all the inputs have to leave

the process in some way, shape, or form.

Once you have it, you can get lots of mileage

out of your process map as a business management tool. It helps you think about aspects of

your process that may have escaped notice in the

past. As you work through later Sections of the

Guide, the process map will help you understand

how to improve the process because it helps you

see clearly the inputs and outputs—and associated costs—of each step. Opportunities to

reduce waste or conserve energy will be more

obvious. You might notice that you have a

“byproduct,” something that leaves your process

as a waste but can be used to benefit someone

else’s process. They may even be willing to pay

you for it. The process map is also a great

planning tool. As you look for areas to improve,

the visual diagram will make it easier for you to

explain your process, where it is now, and where

you want to go with it. It can also be a great way

to explain a job position to a new employee.

How can I get a handle on

environmental laws

and regulations?

If you feel uncertain

about what environmental

laws and regulations apply

to your business and what

exactly to do about them,

you are not alone. Many

small business owners,

because of their extremely limited time, have

difficulty with this. This part explains why it is

vital to your business to take on the task of

understanding your environmental legal obligations. It provides an overview of environmental

laws and explains how to use your process map

to get an idea of which areas apply to your

business. Then, it tells you how you can get

competent help to quickly understand the details

of what is required of your business.

If you are not careful at the beginning to

determine all of the environmental requirements
9

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

your business must live up to, then your environmental management program will be incomplete

and maybe even flawed from the get go. Take

extra care with this step and seek outside help.

By all means, don’t throw up your hands and give

up—the possibility of a penalty for breaking

environmental laws—even once, even by accident—is way too big of a risk to take for your

small business and the people who work there!

What if I find my business is

not in compliance?

While determining what laws and regulations

apply to your business, you might discover that

you have not been meeting requirements that

you should have been in the past. If this happens, the Small Business Policy can help. This

policy states that if you are working with your

state’s Small Business Assistance Program to fix

a problem, you will be given at least a 90 day

window of opportunity to correct the problem

without the regulatory agency stepping in. Since

this policy has not been adopted by all states,

and some states have modified the policy when

they adopted it, ask your Small Business Assistance Program representative for details about

the policy that is in effect in your state.

A second option is to follow EPA Self-Audit

Policy. Under this policy, you can disclose any

violations you discover to EPA, and your

business will have 60 days to correct the violations after discovery. If your business discloses

violations under this policy, EPA cannot assess

financial penalties, except that they may assess

economic based penalties – the amount of

money your institution saved while not meeting

requirements. Before entering into a disclosure

under EPA Self-Audit Policy, consult with your

Small Business Assistance Program representative for advice.

Why comply with

environmental regulations?

The most obvious reason is to avoid penalties

associated with non-compliance—fines for

violations can be in the thousands—a severe

blow to a small business (not to mention the

black mark of being labeled a violator). How

does this happen? Certain agencies at the

federal, state, and local

levels are there to see that

businesses follow environmental regulations. To make

this determination, they can

send inspectors to any business to see first hand

if it is playing by the rules. Of course, when they

find problems, your business will be required to

fix them. The agency will send an official letter

with the list of the problems or violations. They

will spell out what they expect you to do about

each violation and a due date that it must be

completed by. Depending on the violations, your

business may be required to pay monetary fines.

The regulator can even close down your business

temporarily until problems are fixed. It is

possible that the responsible person at your

company who has completely failed to take

notice of or severely disregarded the regulations

may be criminally prosecuted and may even

Why Comply?

! Monetary

fines

! Your business

could be

closed down

until the

problems are

fixed

! Criminal Criminal

prosecution or prosecution or

jail time

! Reinspection
 10

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

serve jail time. Often, regulatory agency staff will

do a follow up inspection to make sure the

problems have really been fixed.

If just dealing with the inspection wasn’t

enough, your problems can make the news. You

may have a difficult time getting your local

newspaper to mention the food drive your

business sponsors, but it’s front page news when

your business is fined for environmental violations or has an accidental spill. The regulatory

agencies keep records of all violations and they

are public documents. Anyone can ask to see

them—they are allowed to under the “Freedom

of Information Act.” People are expressing

more interest these days in knowing what the

companies in their community are doing. EPA’s

website is experiencing 40 million hits per

month. Real estate search engines can find

environmental problems in areas surrounding a

property. Not only can a negative image hurt

sales in your local market, it can also hinder any

expansion activities you may plan. This is

because some expansions require an environmental permit before you can proceed. When a

company is applying for a new permit, there is a

public comment period and often a public

hearing. If your company has a bad reputation

for environmental harm, members of your

community are likely to oppose the permit,

causing a delay. If the public is really opposed,

the permit may not be issued at all, jeopardizing

your expansion plans.

Compliance with environmental regulations

will help retain the value of your property. Any

negative environmental impact can decrease your

property value. Before loaning money, banks

usually require buyers to pay for a professional

review of previous property uses to see if the

property may have been contaminated in some

way. Because of this, if you ever need to change

locations or use your property for collateral, it

will become important to be able to show that

your activities have not caused contamination.

Good documentation that your company is in

compliance with environmental regulations can

protect you from having to pay for past contamination to your site. Likewise compliance with

regulations can lower the cost of liability insurance, because insurance companies will have less

concern about the future costs of a clean-up or

the risk of harm to the health of your employees

and community.

Why can’t I wait until someone

tells me what to do?

There are a lot of environmental laws out

there and not all of them matter to your business. Why should you weed through all of that

now instead of catching up on work that should

have been done yesterday? Why not wait until an

inspector shows up, takes a tour, and creates a

list of burning issues—signed, sealed, and

delivered? After all, the bureaucrats created

regulations that no one else can understand—let

them tell you what you are supposed to be doing

about the whole mess. Well, sorry to say, this is

not the easy way out.

First, not understanding what regulations
11

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

apply to your business is not an acceptable

excuse for failing to meet the requirements. Just

as you can be ticketed for breaking a traffic law

without being aware of it or penalized for a

mistake in a tax return or failure to pay enough,

ignorance of the rules does not protect you

from enforcement, even criminal enforcement.

Second, although an inspection will provide

you with a handy list of things that you need to

do, dropping everything to meet the imposed

deadlines can cost more than would have been

invested to get into compliance in the first place.

You will not have the luxury of time to look for

the least expensive and disruptive way to work

within the rules.

What regulations might impact What regulations might impact

me?

‘There are so many environmental laws and

regulations that they fill many books. When

you’re already swamped with day to day business,

how can you find out which regulations are

important without wasting too much time? A

good place to start is to pull out your process

map and think about how your business

activities could affect the environment. You

bring in raw materials and after some work is

done, they leave as a product. Or, maybe you

use raw materials to perform a service

that fixes, improves, or cleans something for your customer. But, what else

is going on? Is the air and water leaving

your property the same as when it came

in? If your process has leftovers that

may be contaminated by chemicals—even in tiny

amounts—they could be regulated. Where do

they go? To a storm drain or sanitary sewer? To

the dumpster? Perhaps you keep materials on

your property that could cause a spill if their

containers leaked. As you think about these

questions, this is a good time to add to your

process map any new inputs or outputs you have

thought of. Now you are ready to take a look at

the table at the back of the Guide called “Major

Categories of Environmental Regulations.”

Although it doesn’t cover every last environmental regulation, and provides only a general

picture, it will give you a good idea of common

regulations that you should be concerned about

as well as ones that are not likely to apply.

How can I get more information

about regulations that may

apply to my business?

This Guide would be too long and complicated if it gave you detailed information on each

regulation, and it would go out of date quickly.

Besides, the table in the back of the Guide

covers federal regulations only. You also

need to look at your state’s requirements, and maybe even those

of your city or county.

Fortunately, you can call your

state’s Small Business Assistance Program to help you.

Just a phone call away is a

person who’s not a regulator or

an inspector but has the
 12

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

experience and know-how to help you cut

through the red tape and quickly figure out what

regulations apply to your business. After all, you

call a tax auditor to be sure you have filed your

taxes properly, don’t you? In the same way, you

may need an expert to help you take care of all

the nitty gritty details of environmental compliance. If you need assistance finding the phone

number and contact person for the Small

Business Assistance Program in your state, call

EPA’s Small Business Division at 800-368-5888

or go to www.smallbiz-enviroweb.org/.

Consultation with your Small Business

Assistance Program is free of charge. Also, if

your business seeks help from your Small

Business Assistance Program, the Clean Air Act

Compliance Assistance Enforcement Policy can

give you some leeway to correct any problems

that you find without triggering enforcement.

Some states have similar policies or agreements.

As you work with your Small Business

Assistance Program contact, ask him

or her to help you write down the

actions you need to take to comply

with each regulation that applies to

your company. These actions might

include training, labeling,

recordkeeping, filing reports, and

others. Once you have a good

handle on what regulations apply to

your business and what specific

actions 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 to

find a way to stay on top of this so you don’t get

out of compliance by accident. One way is to

attend an update conference on the regulations

that apply to your business once a year or so. Or,

you could just put a tickler on your calendar to

call the Small Business Assistance Program on a

regular basis and ask them to help you stay in the

loop.

What are the basics of good

environmental management?

Now that you understand the ways your

business can affect the environment and what

environmental regulations your business has to

comply with, you are ready to put in place the

basics of good environmental management:

preventing and being prepared for spills, making

sure all chemical materials have proper labels,

practicing good housekeeping, training employees in their environmental responsibilities, keeping good records, and

being prepared for a regulatory

inspection. This part begins with

spill preparedness because it needs

to be among your highest priorities as

a small business owner. Having a spill

can be a nightmare, especially if it gets off

of your property and contaminates a waterway or groundwater. A spill can injure your

employees or make them sick. It can lead to

fires and other property damage. It can

become a source of bad press and jeopardize your relationship with the community.

Having a high profile spill is a sure way

Fines can add up

to large sums. A

kitchen and bath

cabinet company

with 50 employ- with 50 employees was fined

$25,000 for $25,000 for

neglecting to file

an annual report

under EPCRA. under EPCRA.

The fine was

based on $5000

per report times

5 years. The

regulation cited

allows for fines

up to $25,000

per violation, per violation,

which would

have added up

to $125,000. But, to $125,000. But,

the ‘low’ penalty

was allowed

because it was a

small business

using small using small

amounts of

chemicals. chemicals.
13

to get an inspector to show

up at your business. And,

on top of all that, even a

small spill can cost thousands to clean up.

Working on spill

preparedness naturally leads to working on some

of the other basics. Having proper labels on

containers makes it much easier to handle a spill

because you know what you are dealing with.

Practicing good housekeeping helps keep spills

from happening. Since a spill situation can be

dangerous, it is sensible to make sure everyone is

trained so they know how to keep safe and what

to do the moment a spill happens. Having good

recordkeeping in place helps ensure that the

chemical incident response plan is readily

available as well as the response call list. If a spill

does trigger a regulatory inspection, you will be

able to handle it better if you have a game plan

and employees know what is expected of them.

This illustrates how the basics of good environmental management inter-relate, so that doing a

good job in one area has a positive effect on

performance in the other areas.

Prevent and Be Prepared for Spills. A

common cause of spills is the container: either it

is so old and decrepit that it springs a leak, or

someone knocks it over or drops it. There are

several easy ways to prevent this. Make sure all

employees who work with chemicals know these

tips:

• Take a close look at the chemicals in your

work area every week or so. If you notice

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

any containers in bad condition, get rid of

them (using proper disposal methods) or

transfer their contents to a new container.

Check to see that containers have good caps

that are tightly closed.

• Put containers holding hazardous chemicals

or wastes into other containers, trays, or drip

pans to catch and contain any chemical that

spills or leaks out.

• When you move a chemical container from

one place to another, place small containers

in a bucket or pail. Place larger containers in

a tub with hand grips or onto a cart with

sides on it that will prevent any spill from

flowing off.

• When transferring a chemical from its

original container, be sure the new container

will safely hold the chemical you are pouring

into it: Is it made of a material that won’t

react with or dissolve in the chemical? Does

it have a tight fitting cap? Be careful not to

overfill the new container.

Another good thing to do is to locate all the

drains on your property, both indoors and

outdoors, and determine where they go to. If

your building is old, you may be surprised to find

that the drain you were sure led to the sanitary

sewer and your local wastewater treatment plant

actually connects to the storm sewer system that

drains directly to a lake or river.

After you go to all this

trouble, mark your drains

accordingly.

Consider placing

easy-to-use drain
 14

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

covers and spill supplies close by drains to close

them off from a spill if you have time and it is

safe to do so.

If you don’t have a chemical incident response plan, make it a high priority to develop

one. Chances are you have to have some type of

incident response plan anyway to comply with

regulations. This doesn’t mean your employees

have to know how to clean up a spill by themselves. In fact, they should not clean up chemical

spills at all, except for tiny ones, unless they have

had extensive training. But, anyone in your

business who works with chemicals should know

how to keep themselves and their coworkers safe

if there is a spill and who to call for help. Take

some time to ask about the capabilities of your

city or county emergency services. Do they have

a hazardous materials response team (often

called a hazmat team)? If so, do they have the

necessary equipment and training to clean up the

types 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 in

progress and things are going to go a lot more

smoothly.

Train employees. Too often, the environmental management program hides in

files and reports and never gets out

to where the rubber meets the

road. You can have the greatest

ideas in the world to protect the

environment, and even some

that will save money to boot,

but nothing will come of them

if employees don’t know about

them. This sounds obvious until you remember

that at most small businesses everyone is short

on time. Because of this, it is not unusual that

what needs to be done never gets communicated

to who needs to do it. A well thought out

training program is like sunlight to your seedling

environmental management program. It energizes employees because training sheds light on

what they need to be doing.

Here are some tips for setting up and managing your training program:

• As you get your training up and running, set

priorities—(1) train those who handle

chemicals to use them safely and on what to

do if there is a spill or release, (2) make sure

you have training programs as required by

regulations (contact your Small Business

Assistance Program if you don’t know), (3)

train them on additional good practices.

• Use your process maps to discover whose

jobs involve tasks that could affect the

environment.

• Develop a list of training topics that make

sense for each job, beginning with training

required by regulations. You can use a matrix

to help with this (Figure 2). These tools can

help you set up training efficiently so each

employee gets the training he or she

needs, but does not sit through

training they don’t need (a good

way to make them mad at you and

lose interest).

• If your business already has

a strong employee safety

program, build your environmental training into the existing

Document any

training even if it

is an informal is an informal

tailgate session. tailgate session.

Keep a record of

who was trained, who was trained,

the topic, the

date, how long it

was, and

whether it was

classroom, one- classroom, oneon-one, or on- on-one, or onthe-job. If train- the-job. If training involves a

new task, offer new task, offer

to help the

employee the

first time they

undertake the

task, or team

him or her up

with an em- with an employee experi- ployee experienced in the

task. This

counts as train- counts as training too. ing too.
15

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

safety training to be more efficient with

employees’ time and to help them better

understand the big picture. For example, if

you are already doing OSHA Right-to-Know

(Hazard Communication Standard) training,

which is about how to keep safe when using

chemicals, it is a simple thing to add a short

segment on how to properly handle and

dispose of wastes associated with the use of

that chemical.

• Make sure those in your business who are

doing training are available for follow up

questions and know ahead of time who to

call if someone asks a question they don’t

know the answer to. (Your Small Business

Assistance Program contact can help here

too.)

Label Hazardous Materials and Wastes

Properly. Have you ever looked at a glass jar of

clear liquid in your maintenance cabinet trying to

remember what it is? You think on it and narrow

Employee’s Name: John Doe

Employment Date: March 21, 2000

Termination 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 Response

Plan

DOT Hazmat

Storm Water

Air Permit

Initial

3/30/00

3/30/00

Awareness: 3/30/00

Function Specific:

4/12/00

3/30/00

3/30/00

2001

Annual Refresher: 3/15/01

Update (OJT):

Drill: 1/10/01

Incident Critique: 2/23/01

Plan 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 two

things: a xylene-based paint

thinner or a paint stripper

containing methylene chloride.

This is a serious problem

because these products have

very different hazards. The

paint thinner is flammable while the stripper

is not. The stripper is a lot more toxic than the

thinner. You can’t even dispose of it properly

because they each have a different hazardous

waste code. To prevent this headache, when you

look over your chemicals to check for leaks and

bad containers, check the labels too. If any are

falling off or fading, write the label information

on a fresh sticker and attach it to the container.

When transferring chemicals from the original

container to another one, label the new container

right away so you won’t forget what it is. When

deciding on a label for a waste container, be

specific. If not, too soon you will have a mixture

of wastes that will be hard to classify, unsafe to

handle because you don’t know what’s in it, and

more costly to ship out.

When deciding on a label for a waste container, it makes a big difference whether or not it

is a “hazardous waste” as defined by regulations.

Hazardous wastes have particular requirements,

including labeling. You should still label wastes

that are not hazardous so you don’t get them

mixed up with hazardous wastes and because

many non-hazardous wastes still pose hazards to

your employees. Here are some examples of

good labels for waste containers that might be

found in your small business:

Important Note: The above labels meet

certain hazardous waste requirements only.

There may be additional labeling requirements

depending on the regulations that apply to your

business. If you are not sure what labels are

required, consult with your Small Business

Assistance Program contact.

Maintain Good Housekeeping. Here are

some signs that you need to devote more time to

housekeeping:

• You find yourself ordering a chemical

product that you already have because your

shelves were so cluttered when you looked

for it you couldn’t see it was there.

• You pick up a spray paint can out of the

storage cabinet only to discover that it is

empty.

• You open the shop door and knock over a

can of paint that was sitting just inside.

Here are some goals to strive for:

• You open any storage cabinet and can tell at

Waste Parts

Cleaner Cleaner

(contains

methylene

chloride) chloride)

Waste Paint Waste Paint

Thinner Thinner

(contains

xylene) xylene)

Waste Etch

Bath

(contains

sulfuric acid) sulfuric acid)

Paint Stripper Paint Stripper

Waste

(contains

methylene

chloride) chloride)

II. Responsible Environmental Basics—“Have to’s”
17

a glance what products are there and

whether any containers have leaked or

spilled.

• There is a list nearby to check off chemicals

that need reordering.

• Chemical containers are situated safely—that

is, away from the edges of shelves, away

from high traffic areas, and out of the way

of swinging doors.

• Empty containers are marked as such and

properly disposed of right away, or at least

staged at a labeled bin or shelf, so they don’t

get confused with products still in use.

• You cannot find a container without a label

anywhere in your business.

• At the end of a shift, your employees tightly

close any chemical containers they are using

and return them to their designated storage

space.

• You have supplies and personal protective

equipment (also called PPE, e.g., safety

goggles and protective gloves) for safely

cleaning up small spills in each work space in

a location that is easy to get to and well

marked, and employees are trained on when

and how to use them.

If you think your housekeeping is in pretty

good shape, invite your local fire inspector in for

a look. He or she will probably give you a few

more ideas. Getting your housekeeping in order

is like weeding—it’s a pain in the neck but it has

to be done so you can see whether anything

worthwhile is under all the clutter.

Keep records of your efforts and successes. Good records tell you at a glance what’s

going on and what needs to be done on a regular

basis (like annual training or weekly inspections).

They put you in a better position to pass a

regulatory inspection. Most inspectors start with

a close look at your environmental records.

Records in good shape start you off on a good

note. It pays to be clear on what files you must

have to be in compliance and get them organized

first. After that, you can decide what information

has additional value to you. Some records are

essential to protect you from legal and financial

troubles down the road. Others can give you

valuable data on business performance, or come

in handy when you want to show your customers

and neighbors that your business is “green.”

The Sample Master File List in Figure 3 gives

you a simple system to organize your environmental management files and records. It covers

the most common environmental filing and

recordkeeping requirements, the ones that apply

to most small businesses, so you can use it as a

starting point. However, be sure to go back and

look at the records and documents that you are

required to maintain by the particular regulations

that apply to your business to make sure nothing

is missing. Consult your Small Business Assistance Program contact again if you are not sure.

Table 2 summarizes the information in the

Master File List, explains why each file needs to

be maintained, and provides guidelines for how

long files and records need to be kept.

II. Responsible Environmental Basics—“Have to’s”
 18

While thinking about files, here is an important point. Make sure that all critical communications with regulators are documented. Either ask

the regulator to send you something in writing

(e.g., letter, regulation, interpretation) or write

down your understanding of what was said in a

letter, send it to the regulator, and keep a copy in

your file. Also keep a copy of all important

correspondence, such as permit applications,

required reports, or written responses to regulatory inspection citations, and send the original

certified mail with return receipt.

Be Prepared for a Regulatory Inspection.

Maybe you think it can’t happen to you because

your business is too small. But, if you do get

inspected—even just once—it will pay to be

prepared. Knowing what to expect will help you

be more confident and less stressed during an

inspection.

Before an inspection takes place, decide who

can best answer questions about your business’

compliance with environmental regulations while

also having a good grasp of its operations.

Designate a primary contact and a back-up

person. Both should have access to the files,

records, and locations within the business that an

inspector may want to look at.

Let’s say you, as the business owner, are the

primary contact. Tell front office staff that if an

inspector drops by, they should welcome him or

her and call or page you or your back-up. Once

you get the call, get there as soon as possible.

When you first meet the inspector, it is appropriate to ask for some identification and for

information about the kinds of issues he or she

is interested in. The inspector will usually look at

records first and then ask for a tour of your

operations. Be sure to provide appropriate

personal protective equipment (safety glasses are

usually a minimum), then take the inspector to

any place in your facility they request. Take

thorough notes during the inspection. If the

inspector takes a sample (such as a wastewater

sample) ask him or her to split the sample with

you so you can have your own analysis done later

if you choose to. Take photos of whatever the

inspector photographs. If you can, direct

employees to immediately correct any problems

brought up by the inspector, as long as you

clearly understand what needs to be done.

At the end of the inspection, if you are

comfortable doing so, ask the inspector what her

or his impression was to get a sense of where

you stand. After the inspector leaves it may take

weeks or even months for you to receive a

follow up letter from the regulatory agency

stating the results. But, don’t consider the matter

closed until you receive a letter that says so. If

you are served with a Notice of Violation or

other citation as a result of the inspection don’t

panic. Ask your contact at the Small Business

Assistance Program to help you respond. They

can help you understand what corrective actions

you must take and how soon. They may be able

to serve as a go between and advocate for you.

Finally, try to keep a positive outlook. Going

through an inspection can be a stressful and

disruptive experience, but you will get through it.

Afterwards you will know better how your

environmental management program is doing.

II. Responsible Environmental Basics—“Have to’s”
19

General Environmental Management Files

Facility 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 records

they 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 a

current call list for your on-site emergency coordinators and off-site responders (e.g., city hazmat team). If these contacts are

the 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 for

listing phone numbers you would use to report a spill to regulatory agencies (e.g., state spill response hotline, State Emergency 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 related

to a specific environmental permit, which should be kept in the permit file. This includes copies of any letters you send to

regulators and brief notes of any conversations you have with them—not just the stuff they send to you. If you act based on

their answer to one of your questions and someone later disagrees, it will help to be able to show who gave you that

information 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 up

into files for each agency (e.g., EPA, your state environmental regulatory agency, municipal sanitary sewer authority, local

solid waste authority) or by areas (e.g., air, water, waste, emergency response). It's best to keep these documents in order by

date 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 organize

them according to employee. For each person, place the matrix of the training they need to meet their job responsibilities (as

explained in the previous Section) in the front of their training folder. Behind this, keep the employee's training certificate and

an agenda or topics list for each training session. Place this information in chronological order, and use the matrix to quickly

pull training records needed during an inspection. Some regulations (such as hazardous waste) require that you write out

each employee’s duties in that area. If possible, append these to the employee's position description in their personnel file so

it 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

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

Use red file

folders or file

tabs for your tabs for your

emergency

contact files so

you can get your you can get your

hands on them

quickly during a

spill or emer- spill or emergency.

Write down

contact informa- contact information for regula- tion for regulators you commu- tors you communicate with often

on the inside of

the file folder for the file folder for

easy access. easy access.

If your company

has a spread- has a spreadsheet or data- sheet or database computer base computer

program, you

can keep each

employee’s

training matrix

electronically, electronically,

and print a hard

copy to put in

the file. the file.
 20

Media-specific Environmental Management Files

Waste 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.)

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

In the language

of environmental of environmental

management, management,

the term “me- the term “media” refers to

how pollutants

can get into the

environment

such as waste, such as waste,

water, or air. water, or air.
21

What to Include

Facility ID number(s)

Spill Response

Interaction with

Regulators

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 back

of the file.

Keep current plans at the front of the file. Keep summaries of drills and exercises

for three years. Move dated plans, closed incident reports, and critiques to back

of the file after three years and retain indefinitely.

Keep active inspection documents and notes on interpretations or advice from

regulators up front. Keep closed inspection files for three years, then you can

shred them. Keep regulatory notes that are no longer in effect at the back of the

file as a record of past practices.

Keep at the front training records and environmental position descriptions for

employees throughout their employment. (Hazardous waste training records

must be retained for three years, even if the employee has left.) Move training

records of employees who have left the company to the back and keep them in

case you need to account for your past practices.

Keep up front active EPA ID numbers, permits, and waste determinations. Move

inactive EPA ID numbers, expired permits and the original permit application,

and waste determinations for wastes you no longer generate to the back of the

file. Keep hazardous waste/universal waste shipping records, and activity reports

on file for three years (required), then move them to the back of the file. Keep

inspection logs for three years, then shred. Keep solid waste tipping records up

front 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 xemption

to the back. Keep up front annual air emissions reports and monitoring results for

the past three years, then move them to the back of the file.

Keep active permits and the current sanitary sewer ordinance up front. Move

expired permits, the original permit application, and expired ordinances to the

back. Keep up front annual reports and results of required monitoring for three

years, then move them to the back.

Keep up front active permits and storm water pollution prevention plans. Move

expired permits and plans to the back. Keep up front annual reports and

monitoring 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 environmental 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.

II. Responsible Environmental Basics—“Have to’s”
 22

III. Saving Money Through Sound Environmental Management

In a nutshell...

Your tree is maturing and requires less attention to flourish. You are starting to see the return on your

efforts as it provides shade for your yard. After working through Section II, you are beginning to

develop a sound environmental management program and no longer feel like you are in crisis management mode. You can talk knowledgably about the regulatory requirements and what methods you are

using to meet them. Now that you have the basics in place, you can turn some of your attention to the

fun stuff: looking for opportunities to make your business more profitable and productive as well as

more 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 your

regulatory requirements have been reduced by changing, scaling back, or eliminating a process. All of

this will be good preparation for working though Section IV which is about streamlining environmental

management and ensuring that the program will continuously improve over the long run.

How can I use the process map

to save money?

To be useful for working through this Section

of the Guide, you may need to add some details

to the process map that you put together at the

beginning of Section II. If you haven’t already

done so, look at the inputs and outputs of each

step in the process, and figure out quantities and

costs associated with them. You may need to

make some estimates if you don’t keep detailed

records, and that’s OK. You are looking for a

ballpark idea of the magnitude of expenses.

Once you identify your big cost centers, you can

make better decisions about where to focus your

efforts to reduce costs. To see where this is

going, take a look at figure 1 on page 9. The idea

here is to plug the leaks to cut back on waste

energy, wastewater, or waste that is created in the

process. You also want to find ways to make the

process more efficient so you can cut back on

the inputs without decreasing the quality or rate

of production of the end product.

How can I conserve energy?

Here are three reasons to work on energy

conservation:

• First, saving energy in your business translates into cost savings.

• Second, using less electricity means less coal

and less natural gas are burned, which

reduces greenhouse gas emissions and other

forms of air pollution and conserves

resources for future generations.

• Third, there is free assistance available to

help your business explore even some of the

more involved options so why not take

advantage of them?

 Let us first start with

no cost and very low cost

suggestions. Most of these involve changes in

employee activities and some readily made

equipment changes:

• Turn off lights or office equipment at night

and on weekends or take advantage of

Greenhouse

gases such as

carbon dioxide

(CO2), sulfur

dioxide (SO2),

and nitrous oxide

(N2O) are responsible for global

climate change,

acid rain and

smog.
23

III. Saving Money Through Sound Environmental Management

natural daylight for lighting needs.

• Disconnect unnecessary equipment completely.

• Turn up or turn back the thermostat during

unoccupied times or consider buying a

programmable 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 the

climate controlled portions of your facility.

• Replace light bulbs with more efficient ones.

You can order inexpensive sub-compact

fluorescent lamps through a U.S. Department of Energy (DOE) program. These last

eight to ten times as long as a regular bulb

and use one quarter to one third of the

energy.

• Place your lights on motion detectors or

install timers on lights and electric equipment to keep them on only when in use.

• It may be worthwhile to replace lighting

fixtures instead of just the bulbs. The new

fixtures can allow you to utilize a smaller

bulb and get the same amount of light, or

reuse the ballast portion of the light.

Call your local utility company to see if

they still have a program to evaluate your

building for energy efficiency. (Many

have dropped their programs since

deregulation.) If the service is

available, the utility will provide you

with specific options for making your business more energy efficient, usually for free. If

your local utility company does not provide

this service, check with your state’s energy

program to see if they do, or know who does.

There are Industrial Assessment Centers

throughout the country that perform process

audits to reduce energy use, improve efficiency, or reduce waste. (To find the Industrial

Assessment Center in your area see

www.oit.doe.gov/iac/)

Consider Participating in the Energy Star®

Program. Energy Star® is the trade mark EPA

uses to signify energy-efficient products. This

voluntary program is a partnership between

EPA, the U.S. Department of Energy (DOE),

product manufacturers, local utility companies, and retailers. The agencies set energy

efficiency criteria for specific consumer and

commercial products. Products meeting or

exceeding the energy efficiency criteria

established by the agencies are awarded the

Energy Star® label. These include items like

computers, monitors, fax machines, printers

and copiers. Energy Star® also has a small

business partnership program.

There are some real possibilities for cost

savings over time by replacing major equipment within your facility. Not only will

there be savings on operational costs

because of increased efficiency, it

can also avoid maintenance

problems that take up time and

budget, and justify replacing
 24

III. Saving Money Through Sound Environmental Management

equipment that is out of date for reasons other

than just efficiency. One example is that traditional systems often have wasted energy and

money by running motors continuously at full

capacity, regardless of the end-use need. Fortunately, motors can now be equipped with

variable speed drives to allow the motor to

closely match its power output with the energy

necessary for the task—eliminating waste and

saving money.

It is possible to make necessary upgrades with

no up-front capital and pay for them later

through the energy savings that result. Best of

all these savings can be guaranteed through the

energy performance contracting and assistance

provided by your state energy office in cooperation with the Energy Services Coalition (ESC).

This works by entering into an agreement with a

private Energy Service Company (ESCO). The

energy service company identifies and evaluates

energy-saving opportunities and recommends

some improvements to be paid for through

savings. The savings must meet or exceed annual

payments to cover all project costs over the

contract period, usually seven to ten years, or the

energy service company pays the difference. To

ensure savings the energy service company

offers staff training and long term maintenance

services. Check with the National Association of

Energy Service Companies at www.naesco.org or

call them at 202-822-0950 to find a company

near you. Your state energy office can also

provide you with information, local case studies,

and resources to get you started.

Alternative energy sources merit consideration too. At University of Texas Medical

Branch, alternative energy uses include the

installation of a photovoltaic system in a parking

garage. UTMB parking garages are required to

have lighting 24 hours a day, 7 days a week to

provide safe parking. Photovoltaic panels are

currently being installed with grant money from

the Texas Natural Resource Conservation

Commission. In addition, solar water heating is

becoming a very popular way of saving energy in

facilities with large water heating needs.

How can I conserve water?

Think about it: most business activities are

using part of a limited supply of water that is

good enough to drink. Only a tiny fraction of

the planet’s water is drinkable. Ninety-seven

Twenty thousand dollars can buy a lot of bread. That is

what a fast food franchise owner is saving by taking

advantage of energy-efficient technologies at his restau- advantage of energy-efficient technologies at his restaurant. What is his recipe for success? He upgraded his

store’s lighting from 40-watt T-12 lamps and magnetic

ballasts to T-8 lamps and electronic ballasts. In addition to

his 50-percent energy savings, he now has brighter lighting

to make the food look more appetizing. He replaced his old

air-conditioning units with high-efficiency models and

added ceiling fans to circulate the store’s air. He can now

set the store’s thermostats 3 to 5 degrees higher in the

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:

EPA Smallbiz Success Stories) EPA Smallbiz Success Stories)
25

III. Saving Money Through Sound Environmental Management

For More Information...

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

Federal Energy Management Program: 800-363-3732.

Putting Energy Into Profits—Energy Star® Guide for Small Businesses is

available through both of the above agencies.

For info on motor selection:

www.eren.doe.gov/femp/procurement/pdfs/motor.pdf

The Department of Energy’s Industrial Best Practices:

www.oit.doe.gov/bestpractices/

State renewable energy assistance programs:

www.energy.ca.gov/reports/500-99-008.PDF

percent is sea water, which is expensive and difficult to desalinate. About

two percent is caught in polar ice

caps. That leaves just one percent to

sustain life. Much of the world’s

population gets their drinking water

from natural underground storage

tanks called aquifers. Humankind is rapidly using

up those reserves, digging ever-deeper wells and

lowering water levels in every continent. Also,

your business pays for using this resource. This

may 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 a

look at your combined water-sewer bill. If you

want to save some money while reducing the

impact of your business on your community’s

water supply, consider some of the ideas below

as a starting point for your water conservation

efforts.

Find out how your company uses water. You

may have water guzzling processes that can be

changed or updated. Some water cooled equipment can be replaced with air cooled equipment.

Are you spending more for the water to run a

process than you would spend to buy the goods

or services directly? If the water use in the

process can’t be eliminated completely, perhaps

the water can be reused. For example, can your

business reuse process water to wash equipment

instead of sending it to the sewer? Since few

people would ignore ways to reduce chemical

use, doesn’t it make sense to look at reduction in

water use as well? Rinsewaters can be used for

lower priority cleaning applications just as you

might use a slightly contaminated solvent for

another use before you dispose of it. And just as

used solvents can be reclaimed through distillation, water can be reclaimed through ultrafiltration. Furthermore, water recycled through

ultrafiltration or reverse osmosis systems can be

of better quality than supply water.

Keeping your plumbing fixtures in good

working order or upgrading fixtures can save

both water and money. Below are several ideas

and 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 sit

for an hour or two without flushing. If you

see dye in the toilet bowl, you have a leak.

Check to make sure the overflow tube is not

flowing 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.
 26

III. Saving Money Through Sound Environmental Management

• Faucet aerators with flow restrictors are

available to reduce water use.

• Some heating and cooling equipment models

reuse or recycle water.

• Automatic shut offs on water supplies such

as sinks and hose nozzles will keep them

from being left on.

• High pressure/low volume cleaning nozzles

on spray washers also use less water.

• Cover liquid holding areas when not in use

to reduce evaporation.

If you have grounds or greenspace, look at

outdoor water uses, such as landscaping.

Remember that established plants and lawns

need less water than new ones, and many native

plant 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 install

moisture-detection devices on automatic

outdoor sprinklers so that they will not

activate when it is raining.

• Water lawns early in the

morning when temperature and wind speed are

lowest to reduce evaporation.

• Upgrade to an irrigation system that relies

on data on natural water loss through solar

radiation, temperature, wind velocity, soil

conditions and humidity to avoid over

watering 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 can

gauge progress and quickly spot changes. Check

your meter for increased use that can signal a

problem. It is possible through continued

improvements that your company could reach a

point where there is “zero discharge” from your

processes through water recycling and reuse.

Other companies have achieved this level of

efficiency motivated either by a desire to reduce

cost associated with water consumption or to

eliminate the need to permit wastewater discharge or to pay to dispose of wastewater. If

possible, talk with other companies about

methods they have used to save water. Your

water utility company may also be a source of

information on conservation methods.

How can I reduce waste

management costs?

Waste disposal can drive up unit costs on your

production lines. Here are some tips for getting

them under control:

One strategy is to make sure you are managing your wastes efficiently. When you hire a

hazardous waste contractor, ask them to help

you find ways to cut down on costs. While it

might seem that it is not in your contractor’s best

interest to do this, the hazardous waste market

has gotten so competitive that contractors are

looking for ways to add value to their service and

set themselves apart from the competition.

Things you should consult with your contractor

about: Would accumulating your waste in a

container of a different size or type make it less

Did you know

how quickly a

small water leak

can add up?

Toilet leaks can

waste more than

50 gallons of

water a day, water a day,

18,250 per year. 18,250 per year.

One drip per One drip per

second from a

leaky faucet

equates to 2,700

gallons of water gallons of water

per year. per year.
27

III. Saving Money Through Sound Environmental Management

costly for the contractor to handle? Could you

save money by sending your hazardous waste

solvents for use as fuel for cement kilns? Maybe

there is a component in your waste that makes it

hard to manage and drives up its disposal cost.

Look for an opportunity to keep this item out of

the waste either by collecting it separately or

finding a replacement for it in your process.

Another approach is to look for ways to

reduce the amount of wastes your business

creates. A simple example is to reuse corrugated

boxes two or three times before you

send them off for recycling. Since

new boxes are expensive,

savings can add up fast. Let’s

use the example of a spray

painting operation to illustrate

several more waste recycling and

pollution prevention ideas. Begin

with the inventory of paints you keep on hand.

Do you sometimes have paint that you can’t use

up because their shelf life has expired? Or excess

paint that you have no use for anymore and have

to be disposed? If so, take a look at your purchasing practices. Many vendors will work with

you on the concept of “just in time and just the

right amount.” This means that they will deliver

your raw material more frequently in amounts

that nearly match your process needs. This may

be a little more costly than ordering bulk quantities up front, but you may be surprised: with

today’s shipping options, many suppliers have

the ability for quick delivery at only a little

additional cost. Once you take into account all

the costs of handling paint purchased in bulk

(managing the material in storage, dispensing it,

disposing of excess or expired material) you may

find that you will come out ahead by opting for

“just in time” delivery.

After you look at how paint is delivered to

your process, take a look at the process itself. Sit

down with the workers who are most familiar

with the process and figure out exactly how

wastes are created in the spray

painting operation. Perhaps you are

using fresh mineral spirits each time

you clean the paint guns. What if

you could keep some mineral spirits

in a container to be reused the next

time you clean the guns? It’s likely

that you use several rinses to get the guns clean

and that the mineral spirits used in the final pass

isn’t very dirty. This could be reused in the initial

rinse the next cleaning and brand new mineral

spirits saved for the final rinses only. Every bit

of chemical that is reused is saving that much

new material and reducing the waste created by

that amount too. So, you save money on both

ends of the process.

Another strategy is to find a different material

to use to clean the paint guns so that a hazardous waste would not be generated at all. There

are new clean-up products available that are not

combustible and aren’t hazardous wastes once

they are used up. Of course, it would be prudent

to do some trials on a limited scale so you can

make sure the switch is going to work just as well

and be cost effective. Beyond paint operations,

there are similar green products available for

parts washing and stripping operations, to name

a couple. Some of these products have been on
 28

III. Saving Money Through Sound Environmental Management

the market for more than a decade, so

they have the bugs worked out of

them. In addition to saving money and

reducing the amount of hazardous

waste your business generates, many

of these greener products are also

safer for employees to use.

Another thing you might try is to get better

equipment. Perhaps you can upgrade your spray

paint equipment to a gun that has a smaller

reservoir but delivers the paint just as effectively.

Use plastic liners to eliminate cleaning the gun

reservoirs. Also, a newer HVLP gun is likely to

be more efficient by having higher deposit

efficiency and less overspray, thus saving money

on paint purchases. An enclosed paint

gun cleaning system that recycles

cleaning fluid will also save money by

losing less product to evaporation and

re-using product. These process

changes will save on waste disposal

costs as well as product purchases.

They will greatly reduce air emissions, perhaps to

levels that do not require an environmental

permit. If you have been operating under an air

permit, you know how costly it is to keep up, so

being able to drop the permit will save time and

money too.

How do I predict savings from

proposed projects?

This part of the Guide has emphasized

projects that are likely to have a financial payback. It is understandable that you, as the top

person at your business, will want to know how

much and how soon the return will be for the

effort and funding invested in the project. But,

after you have sharpened your pencil, what

exactly do you include in a cost work up?

The question you need to answer is, “What is

the up front cost of the change you are considering, and how long will it take for enough

savings to accumulate to offset this up front

cost?” This is the “return on investment,” and

usually, if it will take more than two years for

benefits to outweigh the initial outlay, it may be

difficult to convince you and your staff to do the

project unless there are other really good reasons

to do it, such as improved employee safety. With

Creative Solutions...

A trophy company owner had a dilemma—finding an inex- A trophy company owner had a dilemma—finding an inexpensive shipping solution for the large-sized trophies. The

large, odd-sized boxes he needed were more expensive

than normal shipping boxes. Through the Minnesota Materi- than normal shipping boxes. Through the Minnesota Materials Exchange program, the business owner was put in

touch with a chemical company that was willing to part

with a supply of boxes that were the exact size he

needed—for free! Since then, the trophy company has

found other boxes and bubble wrap for packing trophies

through the program. Using the Materials Exchange Pro- through the program. Using the Materials Exchange Program 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:

State of Texas: State of Texas: http://p2.utep.edu/success/index.cfm

State of Minnesota: State of Minnesota: http://www.moea.state.mn.us/ http://www.moea.state.mn.us/

p2week99/stories.cfm
29

III. Saving Money Through Sound Environmental Management

For More Information About Pollution Prevention...

Environmental Protection Agency

Pollution Prevention Information Clearinghouse:

www.epa.gov/opptintr/library/libppic.htm

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

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

Region 1: www.epa.gov/region1/compliance/assist/p2page.html www.epa.gov/region1/compliance/assist/p2page.html

Region 2: www.epa.gov/r02earth/p2/p2home.htm

Region 3: www.epa.gov/reg3p2p2/

Region 4: www.epa.gov/region4/air/polprev.htm

Region 5: www.epa.gov/reg5rcra/wptdiv/p2pages/index.html www.epa.gov/reg5rcra/wptdiv/p2pages/index.html

Region 8: www.epa.gov/region08/conservation_recycling/p2home/

 p2home.html p2home.html

Region 9: www.epa.gov/region09/cross_pr/p2/index.html www.epa.gov/region09/cross_pr/p2/index.html

Region 10: yosemite.epa.gov/R10/OWCM.NSF/prevent/prvntrec

Other

Pacific Northwest National Laboratory P2 website: www.pnl.gov/p2/

Kentucky Pollution Prevention Center: www.kppc.org/

this in mind, here are some cost categories to

consider as you work up your analysis.

Initial start up costs. In addition to the cost

of purchasing, will the change require remodeling or modifications to meet building codes?

Changeover costs. When changing from the

old process to the new process, what will happen

to excess raw materials that can no longer be

used? Will employees need training before they

can begin using the new process? Will you need a

trial period to work out any bugs?

With the up front costs nailed down, compare

the old process and the new process head to

head.

Operating costs. These can include electricity, water use, and ventilation systems. Also look

at whether the new process will be more or less

labor intensive. Will the new process be more

productive, for example, higher units of output

per hour or lower amount of raw materials per

unit?

Environmental management and compliance costs. What are the waste management

costs? Will compliance be made easier by the

new process? For example, will it eliminate a

required report to regulators? Will it put you in a

hazardous waste generator category with reduced

requirements? Will you be able to discontinue an

environmental permit? If so, try to estimate the

time company employees put into these efforts

to come up with an estimate of dollars saved.

Avoided costs. In addition to avoided waste

disposal costs, consider whether the new process

requires less raw material inputs, thus saving

costs in purchasing them. Will the new process

eliminate spills and their associated costs? Will

there be less personal protective equipment and

safety training required?

It may not be a formal and totally complete

analysis, but if you think through all of the

above categories you will have a much clearer

picture when you get done of whether your idea

is as valuable as you first thought.
 30

How do we involve our How do we involve our

employees in environmental employees in environmental

management activities?

By now you have taken some steps to put a

basic environmental management program in

place and find that it makes good sense. You, as

the business owner, continue to offer visible

support for environmental management so the

program is taken seriously. But, do you wonder

how you are ever going to keep it going while

still meeting everyday business demands? It’s

time to enlist some help. Environmental efforts

within your company will be more successful if

employees are directly involved. Employees are a

great source of knowledge on environmental

issues related to their work areas and the effectiveness of current procedures. Consider setting

IV. Keeping the Program Alive

up an Environmental Management Team and

making a company environmental policy. The

team can then use the policy to make the

company’s environmental efforts more efficient

and to get more employees actively involved in

them.

The team approach will help to fit another

activity into an already busy schedule and the

discussion it brings about will create a more

complete picture of where you currently stand

and where you go from here. If you can’t guide

the Environmental Management Team all the

In a nutshell...

Now that your tree is fully mature, you want to make sure it will stay healthy over the long run. Could it

become susceptible to disease or get blown down in a storm? To this point, you have put in place the

essential 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 up

to a level that no matter what changes occur at your business, it will reliably steer your business

activities in a direction that keeps employees safe, avoids bad effects on the environment, complies with

regulations, and saves money. This Section of the Guide helps you accomplish that. It will help you get

employees more thoroughly involved in environmental management. It explains how a company’s

environmental policy can act as a tap root, feeding environmental concerns into all decision making

branches. While it may seem like you have to devote more time at first, you will be streamlining and

integrating environmental responsibilities—thinning them out and making them easier and less time

consuming for each employee. Then you can apply methods to gauge progress over time, set goals, and

form a simple environmental management plan to guide your program towards improvement. Once this

is done, you will be able to have complete confidence in the long term vitality of your environmental

program. 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.
31

IV. Keeping the Program Alive

time, appoint a team leader to encourage communication between employees, supervisors, and

company leadership. For this to work, the team

leader needs some authority to keep things

moving. The team should include representatives

from throughout the company. For example, at a

small company, a team could include supervisors

from each process line as well as people responsible for human resources, sales, and plant

operations. In a very small company, the team

leader and the business owner may be the same

person, and the team may consist of the entire

staff. Small companies can have a real advantage

over larger companies. Communication is easier,

staff is used to having multiple roles, and

processes are well understood by everyone.

The first task is to write a company environmental policy. You may want to do this and pass

it down to the team, or you can ask the team to

do it for your review and approval. A company

environmental policy is the shared starting point

for people to understand the basic environmental beliefs and commitments of the company’s

leaders. It states how environmental concerns

are considered in the company’s decision making

and how these concerns fit into its day to day

activities. The policy should reflect your commitment to the environmental program. It should

be short, to the point, and well

communicated throughout

the company so that

employees understand and

remember the policy. All

the other steps for improving the environmental

management program are geared towards

meeting the environmental beliefs stated in the

policy.

How do we go about getting

things written down and why

should we spend time on this?

With the policy in hand, the team can begin to

organize and write down the activities that make

up your environmental management program.

To do this, bring together and examine all parts

of the environmental management program

your company developed by working through

Section II of the Guide. This written program

will support your policy and later form the basis

for setting goals and making an environmental

management plan. Your written program should

Ways to Keep Employees Involved

1. Post the Environmental Policy at prominent

locations throughout your business. locations throughout your business.

2. Set up a suggestion box for environmental Set up a suggestion box for environmental

improvements. Recognize or give awards to

employees that make suggestions that get

incorporated into environmental management

procedures. procedures.

3. Inform employees through a company newsletter Inform employees through a company newsletter

or bulletin board and provide them updates

on the company’s progress in fulfilling its

Environmental Policy. Environmental Policy.
 32

IV. Keeping the Program Alive

assign roles and responsibilities for

accomplishing the activities that you

have identified. Break these down

into small manageable jobs that

are clearly defined so that

everyone knows what their job is

and nothing gets missed. The

benefit of doing this is that when you

add up the duties of all individuals it will provide

complete coverage of your company’s environmental responsibilities and commitments, but no

one person will have too much to do.

Another good reason to spend time on a

written program is that the team will see where

there is duplication of effort that can be streamlined. For example, your team may discover that

employees are being pulled out of their work for

training several times per year. What if your

company set aside time for training covering all

requirements on one day each year? You can also

streamline training by covering more than one

regulation under a given topic—such as training

on labeling requirements that covers requirements of both the Occupational Safety and

Health Administration (OSHA) and EPA, as well

as any local requirements such as those of your

municipal fire department.

Another area that can often be streamlined is

spill preparedness. Some small businesses may

have more than one spill response plan—one to

cover storm water regulations, one to cover

hazardous waste spills, and one to cover petroleum product spills. For a small company where

these plans are not too complicated, covering all

the requirements in one plan will reduce

the amount of effort it takes to keep it

up to date. It makes the plan more

effective too because employees

don’t have to learn a different set

of procedures for each plan, and

try to remember during a spill

situation which plan applies to it.

With a good overview of the environmental

management program, the team can begin to

look at more detailed procedures that need to be

consistent with the written program and the

environmental policy. Ask employees to write

down what they do during normal daily activities.

Getting this written down makes sense so that

nothing gets forgotten and procedures are easy

to communicate. Written procedures make cross

training easier, ensuring that someone will be

available to perform a critical function if the

regular employee is away. They can make turnover easier because the person hiring will have a

better idea of what each job entails.

Once they are written down, the team can

evaluate procedures so that each employee’s

activities include good environmental management practices. Without good environmental

management practices, employees may get the

impression that anything other than steps

absolutely crucial to making the product are

“extras.” They have to rely on word of mouth

for information, and the answer depends on

who they ask. With no good environmental

management practices, they are more likely to

take shortcuts when pressed for time that are not
33

safe or good for the environment. Your company can reinforce the importance of good

environmental management practices by making

them part of job performance evaluations.

Supervisors can use the good environmental

practices in written procedures to explain to new

employees how the company environmental

policy relates to their job.

When evaluating environmental management

practices, you should see if best environmental

management practices have been identified for

your business sector by environmental regulatory

agencies or your trade or industry association.

For example, EPA Small Business Division has

compiled best environmental management

practices for certain sectors in its publication

called Plugging into Best Environmental Management

Practices. To find out what sectors are included

and, if they pertain to your business, obtain a

copy, call EPA’s Small Business Division at 800-

368-5888.

How does this fit in with my

company’s safety or quality

management program?

While the focus here is environmental

management, don’t overlook the opportunity to

integrate with other business management

systems such as process quality, production

control, or safety management. They offer many

opportunities to complement your environmental management efforts and vice versa. If you are

already doing job hazard assessments to develop

safety procedures, it is a simple extra step to

address environmental hazards at the same time.

Material safety data sheets that you must have

for your safety program and product specification or quality verification sheets that you

maintain for your quality program offer a wealth

of information about environmental issues. If

your business has an electronic business management system, this puts information at your

fingertips such as rates of raw material use,

product outputs, and cost data—a great resource

for environmental performance improvement.

Is this working—are we getting

the results we wanted?

After your environmental management

program has been in place a while, you might be

wondering how you can tell how things are

going. Are you making progress on getting into

compliance? Are all your shops and operations

getting the information they need to keep

moving ahead?

Audits are a great way to gather information

on how well your environmental management

efforts are working. These can be done internally

under the oversight of the Environmental

Management Team or

your business can get

outside help. By

involving employees in

environmental audits,

you will give them a

first hand look at what

they are doing right

and what still needs

IV. Keeping the Program Alive
 34

IV. Keeping the Program Alive

improvement. If getting into

compliance is a big priority, then it is

wise to get some assistance from

outside your company. Fortunately,

there are many outside resources you

can draw on. A number of compliance

assistance organizations make audit

checklists freely available that cover

specific regulations. A representative from your

state Small Business Assistance Program can

come do a compliance audit for you. This has

the added weight of an outside expert without

the headaches that you would get from a true

regulatory inspection. Since a compliance audit

conducted by an outside organization feels a lot

like a regulatory inspection to your employees, it

is also good practice. After each audit, organize

findings and follow up actions by work area to

make it easier to pass them on to those responsible. In addition, the auditor should provide a

summary of larger tasks that need to be done

company-wide.

Your audits help you gauge

which areas you are making

progress in and which areas are

lagging. Once you have audit results,

it is a good time to set some goals

and targets. After all, there is a lot of

truth to the old adage, “What gets

measured gets done.” Get the Environmental Management Team together, go over

the audit results with them, and ask them for

their impressions of how things are going. This

is a great time to go over other information that

tells you how you are doing: How many spills did

you have last year? Are the consumption of

chemical raw materials and the amount of waste

generated per unit of product produced increasing or decreasing? Do problems in a particular

area signal that procedures need to be updated?

Are new employees getting trained soon after

they come on board?

As a group, decide on a few goals. Be sure

that these goals are realistic and fit into previously established organizational goals. With all

the other demands on small businesses, setting

expectations that are exceedingly difficult to

meet would sure put the chill on the progress

you’ve made so far. After the group agrees on a

goal, then they need to decide how to measure in

the future whether or not you are making

progress toward your goal and by how much you

want 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, or

you will wind up with a mini-bureaucracy of

On Setting Targets

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 the

amount of all hazardous waste generated. But, this

won’t be meaningful if your waste generation is

linked to production and your production doubles in

the coming year. What if you look for a percentage

reduction in hazardous waste per unit of product

produced? This is a measure you can use to set a

meaningful target—say, a ten percent reduction in

hazardous waste per unit produced. hazardous waste per unit produced.
35

IV. Keeping the Program Alive

your own. Remember, the beauty of this tool is

that you can get back together next year, look at

your results to see whether your company met its

goal and then regroup. You can choose a

different approach if the first one you tried isn’t

as useful as you hoped. You can add new

goals—perhaps in an entirely different area or

production line. Once you have the system set

up to measure performance, keeping it going will

be a lot less time intensive than the initial

investment to get it up and running. It is a good

idea to take your time to select goals that have a

lot of mileage and find the right measures for

them. In just a few years, you will be able to

demonstrate in hard numbers the value of your

environmental management program, and, well,

that’s just good business.

You may not realize it, but you have just laid

the groundwork for an effective annual plan for

your environmental management program. Take

your company policy; add a summary of audit

results, accomplishments, and setbacks for the

past year. Then, review the thinking used to

analyze problems, set criteria, select goals for the

coming year, and update the list of goals and

targets. Now you have an environmental management plan. Of course, this is a simplified

planning approach—but once you have the

process established, you can build on it. Whenever the plan changes enlist the Environmental

Management Team to communicate the changes.

Employees want to know why it is important to

accomplish a particular environmental task and

what part they are to play in achieving selected

goals.

What exactly is an environmental management plan?

An environmental management plan describes the

actions an organization is taking to determine how it

affects the environment, complies with regulations, affects the environment, complies with regulations,

keeps track of environmental management activities, keeps track of environmental management activities,

and meets environmental goals and targets. It also

documents key elements of environmental manage- documents key elements of environmental management. It is the compass for your environmental ment. It is the compass for your environmental

management program because it tells you what

direction you are going in. direction you are going in.

OK, now you have your written environmental management program, you have a plan for

what you want to improve and how you are

going to measure improvements. By now,

employee environmental management responsibilities are so well defined and accepted that they

are second nature—just like filing a timesheet, or

starting up their line at the beginning of a shift.

There’s only one last thing your company needs

to do to make your environmental management

program complete. Make sure top management

at your company checks in on a regular basis.

As the small business owner, you may need to

periodically do your own assessment of how the

environmental management program is working.

Revisit the environmental policy and make your

own evaluation of whether it is still in synch

with company goals. Finally, pull this together

into a written review to give the Environmental

Management Team feedback on what needs to

be changed, if anything.
 36

In a nutshell...

The environmental management program you have cultivated is providing value to your customers and

your community. This Section of the Guide explores the value of paying attention to relationships

beyond the walls of your small business to show off and improve your environmental management

activities. It suggests ways to make neighbors, the surrounding community, customers, suppliers, and

others aware of your environmental management achievements and how to team up with them to

improve environmental performance.

V. Taking it Outside Your Facility

How do I communicate our How do I communicate our

environmental management environmental management

efforts to those outside of our efforts to those outside of our

business?

There are people outside your business who

are either interested in your efforts or can help

you with them. Now that your company has

invested effort to develop a good environmental

management program it’s time you got a pat on

the back for it. One relationship that you are

already very interested in is the one you have

with your customers. After all, that’s what keeps

the money coming in and the wheels turning.

But, the relationships your business develops

with community officials, suppliers,

and the regulatory community are

also important to your business.

That is where you get information and the support to make

your program more effective.

The opinions of your neighbors and the community around

you are important to the success

of your business. How do you tell

these people that you are taking steps to be

environmentally friendly? First, you can post a

copy of your company environmental policy so

that it is visible to anyone who visits your

business. Look for a way to make them a partner

in your efforts such as having them return your

package for a refill. This gives them yet another

reason to come see you. Another idea is to

sponsor an education day for a local school

biology, ecology, or environmental science class

to tour your facility. Every parent that asks

“What did you do in school today?” will get to

hear a little about your company. You can also

post information or make information available

on the latest improvement you made at your

business that made a positive

impact on the environment.

Place this information in your

front office to help waiting

visitors pass the time.

Companies who don’t see

their end users in person can

add information about positive

environmental achievements

directly to the product packag-
37

ing. You can modify your packaging to show use

of a post consumer recyclable product or the

potential for recycling after use. These steps may

help catch the eye of new customers as well. You

can create a refill version of your product that

eliminates the large packaging completely. This

may attract the customer who is conscious about

the amount of waste they generate or it may just

be more convenient to carry or store. You can

also pursue obtaining environmentally friendly

designations for your products such as “Energy

Star®” or “Grown in accordance with the

Californian Organic Foods Act.” Consumers in

many markets have proven that they are interested in buying environmentally superior products. People will invest extra money in energy

efficient products if they know that these

products will pay for the difference in future

savings. The market for organically grown

produce continues to increase even though the

prices for these items are substantially greater

than their less environmentally sound competitors. There are organizations and web sites that

spread the word about green products. Your

business may be able to obtain a listing on these

sources if your product is produced in an

environmentally friendly manner.

How can the activities of our How can the activities of our

suppliers complement our suppliers complement our

efforts towards environmental efforts towards environmental

management?

Your suppliers can be an extension of your

successful program. Once you communicate to

your suppliers and vendors that you favor raw

materials and services that result in improved

environmental performance, they can assist you

with your needs. They can reformulate your raw

materials to meet your waste reduction goals and

help you find better substitute products. They

can offer “just in time” delivery, allowing you to

keep less hazardous chemicals on-site at any

given time, and possibly to use smaller containers. Some suppliers will allow you to return

unused product to be beneficially reused or

recycled in their process. You can encourage

them to incorporate recycled materials in their

products and packaging, or to modify the

quantity of product or the product container to

best fit your needs. You can talk with them about

the option of returning their packaging for a

refill. Many companies have discovered that it

saves them money to pick up the empty containers when they deliver fresh product, rather than

to constantly replace them.

When you consider a new product:

• Ask manufacturers for substantive data on

their green products compared with conventional products.

• Obtain customer references to verify

product performance.

• Request a guarantee policy and special prices

to test green products on a trial basis.

• Determine whether another organization

has certified that the product is environmentally preferable.

V. Taking it Outside Your Facility
 38

Of course you want

to make sure that the

greener products

perform to acceptable

standards, are competitively priced, and

do not offset environmental gains in other areas,

such as a cleaning product that requires more

water. There are resources that can help you

more quickly identify environmentally superior

products, or get a sense of what’s available in the

market. EPA’s Comprehensive Procurement

Guidelines at www.epa.gov/cpg/ provide

recommended specifications for recycled content

for a variety of products. Another resource is the

Green Seal program at www.greenseal.org.

What’s the key to improving

my image in the greater my image in the greater

community?

There are many organizations in place to

assist small businesses. Taking advantage of

these services is viewed positively by regulatory

agencies and can offer many benefits. A great

strategy is to become active in the trade or

industry association for your type of business.

Through this relationship, you will get valuable

information about new regulations, and have a

much greater voice on Capitol Hill by joining

with others. These can connect businesses for

peer exchange or business-to-business

mentoring. In addition to being a great resource

on questions about upcoming and existing

regulations, your state’s Small Business Assistance Program staff can help you identify what

trade and industry associations are out there and

help you develop a strategy to get your message

out to the community. The Regulatory Flexibility

Act requires that the impact of new regulations

on small businesses be studied before they go

into effect. Staying in the loop will allow you to

put your two cents in before another rule is

added to the books. The Small Business Assistance Program staff can also tell you about other

services you might want to take advantage of,

such as agencies that help you find pollution

prevention ideas that save your business money.

You might also want to become involved in your

state’s Compliance Advisory Panel, a group of

small business owners appointed in some states

to advise the Small Business Assistance Program

on how it can better serve small businesses.

There is also a National Compliance Advisory

Panel that advises EPA.

Consider having a representative from your

business get involved in local boards or committees such as the Local Emergency Planning

Committee. Often the Chamber of Commerce

will have an environmental affairs group. The

regulatory agency may have an industry feedback

group of some type.

Their meetings give

you an opportunity

to obtain information about new

developments and

to ask questions and

share concerns in a

relaxed atmosphere.

V. Taking it Outside Your Facility
39

In a nutshell...

Because you have invested effort regularly over many months or even years, your environmental

management program has grown strong. Like a healthy tree, it provides protection for you and your

neighbors. You have set up an approach to environmental management that naturally leads to ongoing

improvement. 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 environmental

management system. This Section of the Guide explains the components of an environmental management system and how you can determine whether you have all the components in place. It also describes

what kinds of official recognition you can seek for your environmental management system, and what to

consider when deciding whether seeking recognition is a good idea for your business.

VI. Summary

What is an environmental What is an environmental

management system?

An environmental management system (EMS)

is an organizational approach to environmental

management that incorporates quality improvement principles (sometimes referred to as “PlanDo-Check-Act”) to develop, achieve, review, and

maintain an environmental policy. The components of an environmental management system

were outlined in 1995 in a standard developed by

the International Organization for Standardization called ISO 14001. Since then, many approaches to environmental management systems

have been developed, but nearly all have similar

components:

Environmental Policy. This is the statement

by top management of their intentions and

principles in relation to environmental performance. It is at the heart of the environmental

management system and provides the framework

for planning and action the organization takes

through the environmental management system.

Environmental Planning. The steps in

formal environmental planning include figuring

out all the ways the business impacts the environment (called “environmental aspects”),

identifying the legal and other requirements that

the business must comply with, setting goals and

targets to improve environmental performance,

and putting in place a written program to achieve

○○○○○○○○○ ○○○○○○○○○○○
 40

VI. Summary

your goals. The plan also documents key elements of environmental management including

the environmental policy, responsibilities,

environmental manual, applicable standard

operating procedures and best management

practices, recordkeeping, document control,

reports, communication, training, monitoring,

and corrective action.

Implementation and Operation. This part

of the environmental management system

defines the structure and assigns responsibility

for environmental management. It lays out

training needs and how they will be met. It sets

up communication channels to make sure that

everyone within your business is aware of the

environmental management system and that

persons outside the company can provide input.

It puts in place an information management

system that includes document control. It

outlines procedures for control of operations

that impact or have potential to impact the

environment and sets up an emergency preparedness and response program.

Checking and Corrective Action. This

includes the methods for monitoring processes

and measuring their impact on the environment.

It identifies what actions the business takes to

correct problems that come up and to prevent

them from happening again. It defines who is

responsible for taking action if there is nonconformance. It defines what environmental

records must be kept and for how long. It also

explains the audit program used to check on

how well the business is meeting its environmental management goals.

Management Review. This is a process in

which the business owner and other key people

review the environmental management system to

determine if it is still suitable and effective, and

whether the business is doing what it has

committed to do.

How does what I’ve done so far How does what I’ve done so far

relate to an environmental relate to an environmental

management system?

Although the description of an environmental

management system may be daunting, how to

put it in place has already been described in

earlier Sections of the Guide, as shown by Table

2. You can see that if you continue to make

steady progress on the recommendations in

Sections II through V of the Guide, you will

have nearly all the components of an environmental management system. Even if you don’t

have all of the elements in place yet, keeping

them in mind helps you get a vision of the full

potential of your environmental management

program as it keeps improving over time.

How do you know when you have assembled

all the components of an environmental management system? You can find this out yourself

by comparing what you’ve got in place at your

business against the ISO 14001 standard or

another widely accepted benchmark. This is

referred to as doing a “gap analysis.” If your gap

analysis finds that you have all the components

of the environmental management system in

place, then you need to look at whether your

environmental management system is perform-
41

VI. Summary

ing the way you want it to. Is your business’

performance consistent with your environmental

policy? Are you making forward progress on

environmental objectives and targets? This is

referred to as doing an audit of your environmental management system, or an “EMS audit.”

(This is the last piece you need to put in place to

have all the components of an environmental

management system.) Let’s say that your gap

analysis shows that you have all the components

of an environmental management system in

place, and your EMS audit shows that your

environmental management system is performing as it was intended to. If so, then, congratulations! You have put in place an environmental

management system.

To demonstrate that your business has met all

of the criteria for an environmental management

system, you can also seek verification or certification from an outside party. For example, some

states have programs (often called “environmental leadership programs”) that give recognition,

awards, or other perks to businesses that demonstrate they have an effective environmental

management system in place. EPA also has a

program, called National Performance Track,

that recognizes and encourages top environmental performers—those who go beyond compliance with regulations to attain levels of performance that benefit people, communities, and the

environment. (See www.epa.gov/

performancetrack/index.htm.) You can obtain

the most official type of approval by hiring an

outside auditor to come in and look at your

environmental management system to confirm

that it has all of the elements required by ISO

14001 and is functioning properly. If it passes

the audit, your company will be “ISO 14001

certified.” This certification carries with it a

distinction similar to being “ISO 9001 certified”

for quality management.

Why would I want to have an

environmental management environmental management

system?

After working through previous Guide

Sections, you already know many of the benefits

of having an environmental management

system. It has helped you cut costs. It gives you a

comfort level that you have covered your bases

as far as meeting regulatory requirements, and

that there will be no unpleasant surprises. It

makes it easier for you to answer inquiries from

employees, neighbors, community leaders, and

regulators about your business’ environmental

performance. It demonstrates your business’

commitment to being a good neighbor and puts

information at your fingertips about your

business’ track record and current environmental

efforts.
 42

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

EMS Component EMS Component

Environmental Policy

Environmental 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 and

preventive 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)
43

VI. Summary

So why would you want to obtain outside

recognition or certification for your environmental management system? Obtaining recognition

from a state environmental leadership program

or EPA’s National Performance Track may

impress some of your customers and distinguish

you from your competitors. ISO certification is

expensive, so it may not be worthwhile for a

small business to do. But, if one of your major

customers requires it, as some of the major

automobile manufacturers have of their suppliers, it may be worth the money. Also, the rigor

of the ISO certification process provides a

structure and focus that prevents environmental

management efforts from backsliding over time.

Why are trade organizations and

regulatory agencies supporting

environmental management environmental management

systems?

Many businesses have demonstrated that

through their environmental management system

they can make great improvements in their

environmental performance while saving money

and increasing productivity. As a result, trade

associations and other business organizations

support environmental

management systems

because they make good

business sense. Also, if

the majority of companies in a business sector

adopt environmental

management systems

and show greatly

improved environmental performance, this

enhances the long term viability of the business

sector, and gives it a fresh marketing angle.

Regulatory agencies support environmental

management systems because they are aware that

the traditional “command and control” system

of environmental regulation is limited in its

potential to have major positive impacts on the

environment over the long term. They are more

open to working with industries and trade

organizations on more flexible and performance-based approaches to improving environmental performance than traditional compliance

methods. When making agreements to allow

such flexibility, regulatory agencies often require

businesses to put an environmental management

system in place to show accountability for their

actions in the absence of certain elements of the

traditional compliance framework. This allows

regulatory agencies to make forward progress

towards streamlining regulations while accounting to the public that the new systems are

working. Regulatory agencies have also incorporated the environmental management system

approach into their enforcement activities. It is

very common for regulators to require a violator

to put an environmental management system in

place as part of the settlement agreement.

How can I get help with putting

an environmental management an environmental management

system in place and getting

recognition for it?

Your Small Business Assistance Program can
 44

give you assistance with environmental management systems. (Again, to get contact information

for your state, visit www.smallbiz-enviroweb.org/

or call EPA’s Small Business Division at 800-368-

5888.) They can also help you make application

to EPA’s National Performance Track program,

make you aware of other recognition programs

that your business may qualify for, or put you in

touch with reputable third party auditors if you

wish to seek ISO 14001 certification. EPA’s

Small Business Division can also provide

assistance and refer you to other contacts and

resources. Finally, if you want to learn more

about environmental management systems, there

is a wealth of resources available at EPA’s

website, www.epa.gov/ems/. At that website,

you might be especially interested in the case

study for Federal Foam, a small business in

Wisconsin that decided to seek ISO 14001

certification. Another good resource is the

companion publication to this one, Documenting

Your Environmental Management Plan—A Workbook

for Small Business, which includes worksheets for

achieving the steps outlined in this Guide. It is

available through EPA’s Small Business Division

and at www.epa.gov/ems/. EPA’s Small Business

Division is also collecting best management

practices for selected business sectors. If your

business sector is included, you may want to take

a look at these.

What’s the bottom line here?

This Guide has given you tools to develop a

complete environmental management system,

geared to your business’ available time and

resources. No matter how long it takes, if you

follow the recommendations in Guide Sections

II through V, you will have a solid compliance

program, an environmental policy to focus your

efforts, programs and procedures that are

written down and kept up to date, and clearly

defined roles that are understood by each

employee. You set goals and targets for each year

and have a plan to move your business in the

direction of improvement. You work at this over

time because it makes good business sense,

increases your business’ productivity, and brings

you peace of mind. If you have gotten this far,

your business has all the components of an

environmental management system and is in a

good position to seek

outside verification.

But, in the end,

whether or not it

will be valuable or

cost effective to

seek outside verification

of your environmental

management system is up

to you.

VI. Summary
45

Type of Impact

Wastes containing chemicals even in tiny

amounts.

Examples: Parts washing fluids, paint

thinners, acids, caustics, toxic chemicals like

pesticides or chlorinated solvents, and

wastes that have toxic metals in them like

lead, cadmium, or chromium.

Waste disposal liability.

Example: The company that took your waste

ten years ago went bankrupt, leaving a

contaminated landfill. Now you may be

required to share in the cost for the site’s

clean-up.

Air pollutants released from business

operations.

Examples: Boilers and furnaces, paint and

dye application, parts cleaning, sand blasting

or other dusty operations.

Contaminated water from business

operations or propery.

Examples: Process water going off your

property through a drain. Storm water that

runs off your property through a storm drain

or another waterway.

Applicable Law(s)

Resource Conservation

and Recovery Act (RCRA)

of 1976 and subsequent

amendments

Comprehensive

Environmental Response,

Compensation, and Liability

Act (CERCLA)

Clean Air Act (CAA) and its

amendments

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 one

place to another, and where and how it may be treated or disposed. Regulation includes special provisions

to make recycling easier for universal wastes: mercury-containing lamps, batteries, mercury switches, and

recalled 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. May

also require notification of the regulatory agency of hazardous waste activities depending on the amount of waste

generated.

Important Considerations: The law requires your business to determine whether any of its wastes are

legally classified as hazardous. Make sure this is done properly to avoid severe financial and liability risk if

wastes are illegally disposed (even by accident).

Maintains “Superfund” to pay for clean up of hazardous waste sites up front. Later, the Environmental Protection

Agency (EPA) can recover costs from each “Responsible Party (RP).” Those who once owned the site, presently

own 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 good

environmental attorney before you reply.

Sets up a system of controls to be sure that pollutants coming from a business’ operations or heating plant do not

hurt the overall air quality in the region. It regulates numerous pollutants. Of particular concern to small businesses

are volatile organic compounds (VOCs), nitrous oxides (NOx), and hazardous air pollutants (HAPs), though

additional ones may apply.

Thresholds: Numerous thresholds for specific air contaminants, usually given in tons or pounds per year. These

thresholds are based on your business’ potential to emit (PTE), assuming 24 hour production at peak rates, as well

as 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 potential

emissions.

Regulatory Reports? Yes, annually, if your business is subject to a permit. Daily monitoring and quarterly reporting

may 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 actual

emissions do not exceed thresholds. Also, you may have to obtain a permit before you can begin

construction 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 not

hurt waterways such as wetlands, ponds, streams, and lakes, or harm groundwater quality. Industrial wastewater

cannot be discharged into a septic system. If you put anything but sanitary waste down the drain, you must abide by

the local sanitary sewer ordinance.

Thresholds: Vary for each contaminant based on where it is going and what authority has control. It can be very

small, such as a couple parts per million.

Requires Permit? Yes, if your business dumps contaminated water into a waterway, onto the ground, or into the

street, a storm drain, or a ditch, you may have to obtain a permit, even if you treat the wastewater first. Some local

authorities also require a permit for discharges to the sanitary sewer. Under storm water regulations, even if you are

not 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

1

This 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 overall

understanding 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.
 46

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

Applicable Law(s) Overview of Regulations1

1

This 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 overall

understanding 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.

Makes possible a national emergency response program for certain spills and accidental releases. If your

business releases certain chemicals, called “hazardous substances,” you must notify the National Response

Center.

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 an

unplanned 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 Emergency

Planning 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 respond

to hazardous chemical spills. If your business is covered by these requirements, you must notify state and local

planning commissions and assist these agencies with maintaining the local emergency plan, including providing

pertinent information.

Thresholds: If the amount of a listed substance kept on-site at your business is more than or equal to the listed

Threshold 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 certain

hazardous 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 hazardous

chemicals, 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 measure

or estimate the amount that came on your site during the year and what happened to it; such as, how much went

into your wastestream. You are exempt if your business does not have 10 or more full-time employees. This

information 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 hazardous

substance at your site in a year. (Certain chemicals of special concern have lower thresholds, like mercury at 10

pounds, 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.

Comprehensive

Environmental Response,

Compensation, and

Liability Act (CERCLA)

Emergency Release

Notification under the

Emergency Planning and

Community Right-to-Know

Act (EPCRA)

Emergency Planning

under EPCRA

Hazardous Chemical

Reporting: Community

Right-to-Know under

EPCRA

Toxic Chemical Release

Reporting: Community

Right-to-Know under

EPCRA

Type of Impact

Chemical spills to air, water, or land.

Examples: A chemical leaks into a storm

drain and contaminates a stream. A valve on

your refrigeration unit fails, releasing

ammonia gas to the air.

Emergency planning for chemicals stored

and used at your business site.

Example: Your business has hazardous

chemicals on-site that could pose a danger

to the local community if they spilled, were

released, or involved in a fire.

Telling the community and local

responders about chemicals stored and

used at your business site.

Example: Your business has hazardous

chemicals on-site that could pose a danger

to the local community if they spilled, were

released, or involved in a fire.

Telling the community and regulators

about chemicals released into the

environment as part of your normal

business operations.

Example: Your business has hazardous

chemicals on-site that could pose a danger

to the local community if they spilled, were

released, or involved in a fire.
47

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

1

This 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 overall

understanding 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.

Managing Chemical Risks.

Example: You have a process within your

business operations that could release a

dangerous amount of toxic chemicals to the

air if it malfunctioned.

Pesticides.

Examples: Your staff apply weed killers on

outdoor property, use pesticides to control

rodents or insects, or you hire a pesticide

applicator to do this.

Polychlorinated Biphenyls (PCBs).

Example: You have equipment that uses a

PCB-containing transformer as a

component; you have to replace PCBcontaining electrical ballasts in your lighting

fixtures.

Storage, management, and disposal of

petroleum products.

Examples: Your business has one or more

storage tanks for petroleum products such

as gasoline, diesel fuel, or heating oil. You

business drains used oil from motor

vehicles. Your business has potential to spill

petroleum products into a waterway.

Chemical Accident

Prevention under the

Clean Air Act

Federal Insecticide,

Fungicide and

Rodenticide Act (FIFRA)

Polychlorinated Biphenyls

(PCBs) under the Toxic

Substances Control Act

(TSCA)

Underground storage

tank and used oil

regulations of RCRA.

EPA’s Oil Pollution

Prevention Regulation,

part of CWA.

Requires you to evaluate certain processes of your business operations to determine if it could pose a danger to

your neighbors through an accidental chemical release. If so, you must undertake planning to prevent malfunctions

from 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 which

documents that your business has completed the hazard assessment, analysis, and planning necessary to prevent

and respond to accidental chemical releases from any process covered by the regulation. Also, requires updates

according 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 you

be 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 are

many additional requirements if your business manufactures pesticides or creates plants that are genetically pest

resistant.)

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 of

these 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 of

contamination 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. Underground

petroleum storage tanks must meet performance standards, the purpose of which is to prevent leaks into soil or

groundwater. (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 your

business has a total on-site storage capacity of more than 1,320 gallons of petroleum products in aboveground

tanks and containers (containers less than 55 gallons in capacity are exempt) or has underground petroleum

storage capacity of greater than 42,000 gallons (completely buried tanks regulated under 40 CFR Parts 280 and

281 are exempt), and can reasonably be expected to discharge oil in harmful quantities into waters of the United

States.

Requires Permit? No.

Regulatory Report? Yes, in follow up to reportable releases.

Type of Impact Applicable Law(s) Overview of Regulations1
United States

Environmental Protection Agency

(1801)

Washington, DC 20460

Official Business

Penalty for Private Use $300

EPA233-K-02-001

September 2002