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Environmental Management Strategies

By Gabriele Crognale

Published by Prentice Hall

Published Date: Jan 27, 1999

Table of Contents

(NOTE: Most chapters begin with an Introduction.)

I. STARTING OUR JOURNEYS.

1. Environmental Management at a Crossroads: Time for a Radical Breakthrough.

Environmental Management: The Present. Environmental Audits: Effective Management Tools. Pollution Prevention: A Goal Worth Considering. Design for the Environment (DfE): Out-of-the-Box Thinking. Software: A Role Player in EH&S/EMS Management. ISO 14000 Champions a New Era for Environmental Management. What This Signals for the Maturing Field of Environmental Management. What’s on the Horizon for Regulated Organizations, and Where Might We Be Going? What Should We Look For? What Additional Benefits Can We Achieve? A Look Forward.

2. The USEPA’s Enforcement Strategy: The Evolution of Environmental Enforcement.

EPA Enforcement at a Glance: An Overview.

Some of the Enforcement Tools Used by EPA. EPA’s Evolving Compliance and Enforcement.

EPA’s Four-Year Plan. EPA’s Five-Year Plan. EPA’s FY 1997 Enforcement and Compliance Assurance Priorities. Additional EPA FY 1997 Compliance Assurance Priorities. EPA at a Crossroads.

The 33/50 Program. The Environmental Leadership Program. The Common Sense Initiative. Project XL.

Tracking EPA’s Reinvention Efforts: Are We There Yet?

GAO Reports. U.S. Chamber of Commerce Survey on U.S. Businesses. EPA’s Two-Year Anniversary Report.

Additional EPA Considerations. Industry Participation in Developing Science and Regulation: The Case of Endoctrine Disrupters. A Closing Thought: Are We There Yet?

3. OSHA Safety and Health Management Responsibilities.

Introduction. Regulatory Background. OSHA Regulatory Requirements. OSHA Standards Promulgation. Advisory Committees. NIOSH Recommendations. Standards Adoption. Emergency Temporary Standards. Standard Promulgation Summary. Injury and Illness Records. Recordkeeping Forms. Other Recordkeeping Requirements. Posting Requirements. Workplace Inspection. Inspection Priorities. Imminent Danger. Catastrophes and Fatal Accidents. Employee Complaints. Programed Inspections. Follow-up Inspections. Inspection Process. Opening Conference. Walk-Around Inspection. Closing Conference. Safety and Health Programs. Respiratory Protection: Need for Respirators. Engineering Controls. Written Standard Operating Procedures. Program Evaluation. Selection of Respirators. Training. Fit Testing. Inspection. Cleaning. Storage. Medical Examinations. Work Area Monitoring and Assessment. Summary. Occupational Noise Exposure. Noise Monitoring. Employee Training. Hearing Protection. General Personal Protective Equipment. OSHA PPE Regulations. Head Protection. Eye/Face Protection. Foot Protection. Hand Protection. Body Protection. Hazard Communication. Material Safety Data Sheets. Training and Information. Container Labeling. Hazardous Materials List. Emergency Preparedness and Response. Evacuation Plans. Hazardous Material Emergency Response Plans. Electrical Safety. Lockout/Tagout. Program Requirements. Employee Training. Machine Guarding. Point of Operation. Power Transmission Apparatus. Confined Spaces. Confined Space Program. Training. Summary.

4. An overview of SEC Environmental Requirements for Publicly-held Companies.

The SEC Environmental Reporting Requirements. What this May Entail for Publicly-held Companies. A Look Ahead.

5. An Overview of Multi- and Single Media EPA Inspections.

How EPA Inspections are Planned. Categories of Compliance Inspections. Developing an EPA Inspection Scheme. Choosing the Level of EPA Inspection. Multimedia Inspections. Sample Enforcement Actions. Conclusion.

6. A Look at Innovative Strategies for the Environmental Manager.

A Sampling of Innovation Strategies. Keeping Up with Regulatory Requirements. Following Up with Environmental and EMS Audit Deficiencies. Delving in Root-Cause Issues to Improve EMSs. Providing Adequate and Appropriate Training to Affected Workers. Expanding Awareness into Other Business Areas of the Organization. Shifting Gears into a Progressive Awareness Mode. Environmental Progress is More Than Just Compliance. Getting the Organization to Pull Together. Do the Benefits Outweigh the Costs? Innovative Strategies . . . Moving Forward.

Plan-Do-Check-Act. Provide Follow-Up to Track and Measure Program Effectiveness.

Past to Present: The Developing EH&S Professional from the 1970s to the 1990s. Confronted by a World of Change. Moving Forward to the Future. The Next Wave of EH&S. Sustainable Competitive Advantage. The Emergent EH&S Professional: Changing Skills to Address New Directions. A Look Forward.

II. INNOVATING THE ENVIRONMENTAL LANDSCAPE.

7. Benchmarking Studies: Adding Insight and Value to Organizations’ EH&S Programs.

Using Benchmarking to Provide Solutions to EH&S Inquiries. What Can be Gained by an Organization in a Benchmarking Study? Initiating a Benchmarking Study: Key Considerations. Developing a Baseline. Choosing a Partner: What to Look for.

Preview of a Benchmark Study Looking at a Company’s EMS. Preview of a Benchmarking Study Looking at Company’s ISO 14001 Certification Process.

Benchmarking Examples: Noteworthy Case Studies.

The APQC’s International Benchmarking Clearinghouse Report. The IRRC Corporate Environmental Profiles Directory 1996 Executive Summary. U.S. General Accounting Office (GAO) Report on Environmental Auditing.

Recent Trends: A Sneak Peak at Environmental Conferences. What the Numbers Tell Us: Emerging Trends.

8. Building Blocks for Improving a Company’s Environmental Management System.

Business Forces Changing the Environmental Landscape. Defining the Environmental Manager’s Role: Setting the Building Blocks in Place. Innovative Solutions to Enhance Environmental Management Systems. Business Changes Fostered by Regulators and Legislators. Inside Environmental Compliance: A Corporate View. When is Improving Compliance Performance Justified? What Commonsense Elements Can Improve a Compliance Program? Management Statement. List of Requirements. Operating Requirements. Reporting Requirements. Employee Training Requirements. Record Keeping Requirements. Assignment of Responsibility. Training. Legal Support. Audit Process. Elements to Improve Compliance Performance. User-friendly List of Requirements. Changing Requirements. Lobby and Advocacy. New and Amended Laws and Regulations. Court Decisions. Enforcement Policy. Open Communications. Incident Investigation. Understanding the Potential for Noncompliance. Reduce Dependence on Audits. Conclusion. The Millipore EMS Example. What the Future May Bring.

9. The Environmental Audit as an Effective Management Tool.

Environmental Audit Drivers. What We Can Expect from Audit Programs as They Continue to Evolve. History of the Environmental Audit. Types of Audits. Compliance Audits. Management System Audits. Legal Aspects of Auditing. State Audit Privilege Laws. Attorney-Client Privilege. Auditing Beyond the Fence Line. Superfund Liability. Toll Manufacturers. Customer/Suppliers. Measuring Audit Program Success. Benchmarking the Audit Program. Summary. Lucent Technologies: Corporate Goals. Introduction. Program Description. Scheduling the Audit. Pre-Audit Phase. Compliance Audit Coordinator. Audit Announcement Correspondence. Pre-Audit Questionnaire. Pre- Audit Questionnaire Attachment. EH&S Compliance Audit Protocols. Regulation Review. Audit Plan. Auditor Qualifications. Team Development and Audit Assignments. Facility Coordination. Audit Phase. Opening Conference. Wide- aisle Tour. Interview Scheduling. Interviews and Data Gathering. Management System and Corporate Goals Review. Facility Briefings. Root Cause Analysis. Action Plan Preparation. Action Item Prioritization. Closing Conference. Action Plan Input. Program Compliance Rating. Post-Audit Phase. Reporting. Follow-up. Annual Report. The Hewlett-Packard Company. The Early 1970s: The Beginning of Environmental Awareness. Late 1970s to the Early 1980s: The Adolescence of Environmental Awareness. Mid-1980s to Early 1990s: Environmental Awareness Enters Teenage Years. Early 1990s to Present: Environmental Awareness Matures. In Conclusion.

III. PUTTING INNOVATION INTO PRACTICE: A CLOSER LOOK.

10. Progressive Environmental Stewards in Industry.

EG&G, Inc.: Background. The New EG&G Paradigm. Waste Reduction Pays (WARP) Program. From Compliance to Excellence. Quality. Training. Monitoring. Cultural Change. Results. The Gillette Company and the Environment. Gillette Policies. Environmental Programs and Accomplishments. Gillette’s Pollution Prevention Program. EPA’s 33/50 Program. Energy and Water Conservation. EPA’s Green Lights Program. Product Stewardship. Design for the Environment. Packaging. EPA’s Environmental Leadership Program. Draft Framework for National ELP. Conclusion. Chevron Corporation—The Chevron Way. A Sampling of Environmental Reports: The Primary Industry Drivers. The PERI Guidelines. The Chemical Manufacturers Associations’s (CMA) Responsible Care Program. The American Petroleum Institute (API). A Few Progressive Companies: Highlighting Voluntary Environmental Reports. IBM. Hewlett-Packard. Texaco. EHS Policies and Standards. EHS Auditing. Product Stewardship. Boeing Company. Chevron Company. In Summary.

11. Effective Risk Management and Communication: Tips on Working with the Public.

Prudent Risk Management and Risk Communication. Proactive Risk Management and Risk Communication. Paradigm-Breaking Risk Management and Risk Communication. Some Examples of Ineffective and Effective Environmental Risk Management and Communication. Two Examples of Ineffective Risk Management and Communication. Example No. 1: The Valdez Oil Spill. Example No. 2: The Bhopal Disaster. Two Effective Examples of Risk Management and Risk Communication. Example No. 1: Ashland Oil’s Incident. Example No. 2: Two Examples from Very Different Phases. Good Example 2a: Ely Lilly’s Disaster that (So Far) Never Happened. Good Example No. 2b: The Tylenol Scare—A Serious, Real Disaster Successfully Contained and Managed. What Risk Management and Risk Communication are and How They’re Supposed to Work. Views on the Nature of Risk Management, Communication and Their Integration. Risk Management. Risk Communication. Integrated Risk Management and Communication. Some Benefits Effective Risk Management and Risk Communication Can Provide. Some Lessons Learned: Why Systematic Risk Management and Risk Communication are Needed. What Can Go Wrong Without Appropriate Risk Management and Risk Communication. Some Examples. Case Study #1: No Real Risk Management or Risk Communication. Case Study #2: Inadequate Risk Management — Risk Communication Can Only Do So Much. Case Study #3: Acceptable Risk Management, but Inadequate Risk Communication. What Can Go Right with Appropriate Risk Management. Case Study #1: Acceptable Risk Management and Risk Communication. Case Study #2: Exemplary Risk Management or Communication and Acceptable Risk Management or Communication. Putting It All Together: Developing Your Risk Management and Risk Communication Strategies. Where to Start. Developing Your Approaches to an Integrated RM Program: Some Recommended Steps. How Effective is Your Risk Management Program? Concluding Thoughts and Remarks. Need for Continuous Improvement. Risk Management and Risk Communication and Other Company Functions. Concluding Perspectives.

12. What ISO 14000 Brings to Environmental Management and Compliance.

Introduction to the New ISO 18000 Standards. Background on ISO 14000. The Family of ISO 14000: How the Standards Complement Each Other. ISO 14001. ISO 14004. ISO 14010s. ISO 14020s. ISO 14031. ISO 14040s. Certification to ISO 14001: What It Entails. Benefits to ISO 14001 Certification. Getting to Certification. Continual Improvement: What That Really Means. A Current Snapshot: Where are we in 1998? Environmental Management with ISO 14001 at SGS-THOMSON. Microelectronics. Introduction. Background on ISO 14000. Background on ST. The Elements of ISO 14001: Commitment and Policy. Management Commitment. Policy. Planning. Initial Review: Register of Significant Effects. Legislative Register and Compliance. Objectives. Implementation and Operation. Training. Communication. Documentation. Document Control. Operational Control. Chemical Management. Emission Abatement Equipment Operation. Hazardous Waste Management. Off-Site Services/Contractors. Checking and Corrective Action. Monitoring and Measurements. Trending. SPC. Calibration. Environmental Management System Audit. Management Review. Conclusion. Lucent Technologies Approach to Performing an Internal EMS Audit. Environmental Management Systems. Purpose of the Section. Lucent Technologies: A Leader in EMS Implementation. EMS Audit Program Objectives. EMS Audit Process. Operating Units Request EMS Audit. Notification Letter and Pre-Audit Questionnaire. EMS Audit Plan Preparation and Approval. Review of EMS Documentation. EMS Audit. Opening Conference. On-Site Audit Activities. Audit Findings. Closing Conference. Preparing EMS Audit Reports. Document Control. EMS Audit as the Key to Continual Improvement. EMS Audit Procedure. Performing the EMS Audit. In Conclusion.

IV. WHERE ENVIRONMENTAL MANAGEMENT MAY BE HEADED.

13. Utilizing Software to Enhance Environmental Management Responsibilities.

The Evolution of Computers and Peripherals. The Evolution of EH&S Software. Software Advances: Spurred by Increased User Demands. Highlights of a Few EH&S Software Package Capabilities. A Case Study—Ocean Spray Cranberries, Inc. IBM’s Specialty Software—Enterprise Document Management. Solutions. Caribou Systems. Nortel. Peregrine, Inc. The Next Wave in EH&S and Other Software Systems. A Partial Listing of Software Providers. EH&S Compliance, Including Audits. ISO 14001 Considerations—EMS and Gap Analyses. Intelligent Real-Time Expert Systems. Enterprise Resources Planning (ERP) and Electronic Document Management (EDM) Systems. ISO 900 Software. Conclusion.

14. Sources of Environmental Information.

Appreciating the Enormity of Keeping Current. What are the Odds You Will be Caught? The Relationship Between Laws and Regulations. What are ‘Primary’ and ‘Secondary’ Sources of Information? Acquiring a Good Base of Compliance Knowledge. Using Videotapes as a Source of EH&S Information. Considering Looseleaf Services for Access to Changing Information. Newsletters Can Provide Timely Information at a Reasonable Price. Finding Out About Environmental Trade Magazines and Journals. Looking More Closely at Libraries. Business Libraries. College Libraries. County or State Law Libraries. Moving Ahead with Electronic Information. How Much Do You Need? How Often Do You Need It? What are the Main Differences Between Floppy Disks and CD-ROM? What Makes Online Services Better than Disks or CDs for Obtaining Information? What is the Difference Between a Free Online Service and One That Costs Money? What is the Internet and How Can it be Used to Obtain EH&S Information? Gaining Access to the Net. What are ‘Listservs’ and Newsgroups, and What’s Wrong with Getting ‘Flamed’? Listservs. Newsgroups. Flaming. Rising to the Challenge.

15. What the Future May Look Like in Environmental Management: A Perspective.

What Some Companies are Doing. Outsourcing Core EH&S Responsibilities. Some Companies Rely on Boutique Firms: Strategic ‘Outsourcing.’ Strategic Alliances: Another Alternative. What This Portends for Next-Generation Environmental Management. The IBM Case Study. Other Considerations.

Appendix A. Sample EPA Inspection Checklist.

Appendix B. Publications, Professional & Industry Associations, Public Interest Groups and Governmental Agencies.

Appendix C. List of Acronyms.

Appendix D. Environmental Guiding Principles & Codes of Ethics.

Appendix E. Organization’s Environmental Policies, Mission Statements and Other Supportive Documents.

Appendix F. Additional Readings.

Appendix G. Supplemental Information.

Index.

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