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GREEN PROFITS
The Manager's Handbook for ISO
14001 and Pollution Prevention

Nicholas P. Cheremisinoff, Ph.D.
Avrom Bendavid-Val

S

UTTERWORTH
E I=-N E M A 'N 1~

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Library of Congress Cataloging-in-Publication Data
Cheremisinoff, Nicholas E
Green Profits: the manager's handbook for ISO 14001 and pollution prevention /
Nicholas P. Cheremisinoff, Avrom Bendavid-Val.
p. cm.
Includes indexes.
ISBN-13 978-0-7506-7401-0
ISBN-10 0-7506-7401-6 (all paper)
I. ISO 14000 Series Standards. 2. Manufacturing industries--Environmental
aspects. I. Bendavid-Val, Avrom. II. Title.
TSI55.7.C454 2001
658.4;08--dc21

2001025366

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Printed in the United States of America



CONTENTS
Preface

vii

Acknowledgements

xm

Abbreviations

xiv

~176176

ROAD MAP TO PART I: ENVIRONMENTAL
MANAGEMENT SYSTEMS
CHAPTER 1. EMS" PRINCIPLES AND CONCEPTS

4

The Basics of an EMS: What Is It, and Why Do It
What the ISO 14001 Standard Is All About
Essential Elements of the ISO 14001 EMS
One More Time
Questions for Thinking and Discussing

4

7
12
15
16

CHAPTER 2. EMS: APPLIED MODELS

18

ISO 14001 and Implementation Overview
Environmental Policy (Clause 4.2)
Planning: Environmental Aspects (Subclause 4.3.1)
Planning: Legal and Other Requirements (Subclause 4.3.2)
Planning: Objectives and Targets (Subclause 4.3.3)
Planning: Environmental Management Programs (Subclause 4.3.4)
Implementation and Operation: Structure and Responsibility (Subclause 4.4.1)
Implementation and Operation"
Training, Awareness, and Competence (Subclause 4.4.2)
Implementation and Operation: Communication (Subclause 4.4.3)
Implementation and Operation: EMS Documentation (Subclause 4.4.4)
Implementation and Operation: Document Control (Subclause 4.4.5)
Implementation and Operation: Operational Control (Subclause 4.4.6)
Implementation and Operation: Emergency Preparedness and Response
(Subclause 4.4.7)
Checking and Corrective Action: Monitoring and Measurement
(Subclause 4.5.1)
Checking and Corrective Action: Nonconformance and Corrective
and Preventative Action (Subclause 4.5.2)

18

22
29
36
37
45
50

iii

54
58
60
63
66
69
71
75


Checking and Corrective Action: Records (Subclause 4.5.3)
Checking and Corrective Action: EMS Audit (Subclause 4.5.4)
Management Review (Clause 4.6)
One More Time
Two Exercises
Questions for Thinking and Discussing

CHAPTER 3. TOOLS AND TECHNIQUES

79
81

87
92
93
99

101

Using this Chapter
Before Policy
Environmental Policy (Clause 4.2)
Planning: Environmental Aspects (Subclause 4.3.1)
Planning: Legal and Other Requirements (Subclause 4.3.2)
Planning: Objectives and Targets (Subclause 4.3.3)
Planning: Environmental Management Programs (Subclause 4.3.4)
Implementation and Operation: Structure and Responsibility
(Subclause 4.4.1)
Implementation and Operation: Training, Awareness, and Competence
(Subclause 4.4.2)
Implementation and Operation: Communication (Subclause 4.4.3)
Implementation and Operation: EMS Documentation (Subclause 4.4.4)
Implementation and Operation: Document Control (Subclause 4.4.5)
Implementation and Operation: Operational Control (Subclause 4.4.6)
Implementation and Operation: Emergency Preparedness
and Response (Subclause 4.4.7)
Checking and Corrective Action: Monitoring and Measurement
(Subclause 4.5.1)
Checking and Corrective Action: Nonconformance and Corrective
and Preventative Action (Subclause 4.5.2)
Checking and Corrective Action: Records (Subclause 4.5.3)
Checking and Corrective Action: EMS Audit (Subclause 4.5.4)

Management Review (Clause 4.6)
One More Time
Exercises
Questions for Thinking and Discussing

101
103
105
109
118
119
124

CHAPTER 4. EMS" FIRST STEPS

175

The Benefits of an EMS
Initial Environmental Review (IER) and Gap Analysis
EMS Lite
One More Time
Exercises

iv

126
128
131
135
141

146
148
149
153
156
157
171
172
173
173

175
177
185
191
193


R O A D M A P T O P A R T II: P O L L U T I O N P R E V E N T I O N

194

C H A P T E R 5. P O L L U T I O N P R E V E N T I O N : P R I N C I P L E S
AND CONCEPTS
The Basics of P2: What Is It, and Why Do It
What Pollution Prevention is All About
Essential Elements of Pollution Prevention
What About Material Waste and Energy?
How are P2 and EMS Related?
One More Time

Questions for Thinking and Discussing

196
196
199
202
205
209
210
211

C H A P T E R 6. I N D U S T R Y - S P E C I F I C P O L L U T I O N
PREVENTION PRACTICES
Defining P2 One More Time
Hierarchy of Pollution Management
Why and How Is P2 Done?
The P2 Benefits Matrix
Industry Specific Guidelines and Practices
Questions for Thinking and Discussing

213
213
214
215
229
233
258

C H A P T E R 7. T H E P O L L U T I O N P R E V E N T I O N A U D I T
Introduction

The Pre-assessment (Phase I)
The In-plant Assessment (Part 1 of Phase II)
Working with Material Balances
The In-plant Assessment (Part 2 of Phase II)
Synthesis, Benchmarking, and Corrective Actions (Phase III)
One More Time
A Summary of All the Steps
Questions for Thinking and Discussing

259

C H A P T E R 8. F I N A N C I A L P L A N N I N G T O O L S
Introduction
Total Cost and Cost Accounting
Establishing Baseline Costs
Revenues, Expenses, and Cash Flow
Interest and Discount Rates
Income Taxes
Application of Total-Cost Assessment

321
321
321
326
331
336
337
339

259

262
273
286
300
304
317
318
319


The Life-Cycle Analysis
Final Comments
Glossary of Important Terms

347
356
360

Appendix A: ADDITIONAL ISO 14001 AND
POLLUTION PREVENTION RESOURCES

362

Index to Tables

371

Subject Index

375



PREFACE
Environmental management systems, or EMSs, are planned and organized means
that an enterprise can use to manage its interactions with the environment ~ in
particular, those interactions that contribute to resource consumption, environmental
degradation, and human health risk. An EMS is a structured program of continual
environmental improvement that follows procedures drawn from established business
management practices. EMS concepts are straightforward, and EMS principles can be
easily applied if supported by top management.
The best known EMS worldwide is ISO 14001. ISO 14001 is an international
standard for EMSs that embodies essential elements of other EMSs, such as Britain's
BS7750 and the European Union's EMAS, and clearly is becoming universally
recognized among industry and the public as the standard for an EMS.
A proper EMS is a program of continual improvement in environmental
performance that follows a sequence of steps based on established sound businessmanagement practice. Accordingly, it allows an enterprise to understand and track its
environmental performance, and provides a framework for identifying and carrying out
improvements that may be desirable for financial or other corporate reasons, or that
may be required to meet regulatory requirements. Under the best conditions, an EMS
is built on an existing quality-management system. A typical sequence of planning and
management steps that structure an EMS is:
1) Establish an environmental policy for the enterprise
2) Review the environmental consequences of enterprise operations
3) Establish environmental performance goals
4) Develop and carry out an action plan to achieve the goals
5) Monitor performance
6) Report the results
7) Review the system and the outcomes and strive for continual improvement
As this sequence of steps suggests, perhaps the most important characteristic of
an EMS, and one that can yield significant long-term benefits, is that it represents a

systematic strategic management approach through which an enterprise deals with
environmental issues. The opposite of strategic management is reactive decisionmaking m when something breaks, fix it; when markets fail, scramble for new ones;
when the public clamors for greater corporate responsibility, figure out what to do.
Winners in the marketplace today are increasingly those with good strategic planning
and management systems.
Environmental regulators m certainly in Western countries m are slowly but
definitely moving from media-based to systems-based compliance enforcement
approaches that reward enterprises for engaging in strategic environmental
management through an EMS. For recent evidence of this see the U.S. Environmental
Protection Agency's new National Environmental Performance Track program
(www.epa.gov/perftrac/program/program.html).
The public also is demanding that corporations deal with environmental, quality,
health and safety, and social-justice issues in a systematic, integrated, and strategic
way, under the overall heading of "corporate social accountability" or similar terms.
vii


Already, corporations at the leading edge are exploring ways to integrate their quality,
environmental, and occupational health and safety (OHS) management systems.
System-based strategic management is good management, and a sound EMS
complements and reinforces a systematic strategic approach to managing an enterprise.
An EMS helps management identify and address environmental priorities in terms of
their ecological and health implications, as well as in terms of the strategic
requirements of the enterprise, rather than just checking and enforcing compliance
with a collection of unrelated and unprioritized standards. This makes an EMS an
instrument for promoting enterprise sustainability and long-term prosperity.
A key feature of ISO 14001 is its specification of the elements of a system that
can be independently audited and certified as conforming to an internationally
accepted EMS standard. The question of certification underlies much of the discussion
about environmental management systems, and the real or hoped-for benefits of

certification have provided the principal motivation for implementing ISO 14001 in
many enterprises. But the benefits associated with certification represent only a small
portion of overall benefits gained by implementing an EMS. Enterprises need not
focus on certification when they begin the process of implementing an ISO 14001based EMS. An enterprise can use ISO 14001 either as guidance for implementing a
very simple EMS as the first step on a long road that may ultimately involve seeking
certification, or as a set of precise specifications for setting up an EMS that can be
certified relatively soon.
The greatest direct benefits to an enterprise of implementing an EMS usually
come from the savings generated by pollution prevention (P2) practices and
technologies. About 50 percent of the pollution generated in a typical "uncontrolled"
plant can be prevented with minimal investment by adopting simple and inexpensive
process improvements. In industrial countries, increased discharge fees and wastedisposal charges provide much of the incentive for cost-effective pollution reduction.
A major consequence of implementing an EMS is the identification of wasteminimization and cleaner production opportunities for the enterprise. The process of
introducing the EMS can be a catalyst for worker support for environmentalperformance improvements (including the simple changes that make up "good
housekeeping"), and also for making the best use of existing P2 and control
equipment.
Pollution prevention diverts attention away from pollution controls and posttreatment practices (that is, treatment of pollution after it has been generated), and
focuses instead on replacing technologies that generate pollution and undesirable byproducts with those that do not, or that generate them at greatly reduced levels.
Ultimately, P2 through waste minimization and cleaner production is more costeffective and environmentally sound than traditional pollution control and posttreatment methods. P2 techniques apply to any manufacturing process or business
operation, and range from relatively easy operational changes and good housekeeping
practices to more extensive changes, such as finding substitutes for toxic substances,
investing in clean technologies, and using state-of-the-art materials-recovery
equipment. Pollution prevention can improve plant efficiency, enhance the quality and
quantity of natural resources for production, and make it possible to invest more
financial resources into enterprise competitiveness. To illustrate:

viii


The EPA, through its voluntary Green Lights program, introduced the concept of

using low life-cycle-cost lighting systems rather than the lowest first-cost lighting
systems. Pollution prevention activities under the energy-efficiency program
include reducing wattage per square foot; changing from incandescent to
fluorescent bulbs; changing ballast materials; using sodium- and mercury-vapor
lamps; and installing motion detectors to detect when an area is occupied, and
activate lights only then. Based on a survey of 200 participating companies, on
average each enterprise was able (through decreased electricity demand) to reduce
their emissions of carbon dioxide (CO2) by 826 metric tons (kkg) per year; to
reduce their emissions of sulfur dioxide (SO2) by 6.5 kkg per year; and to reduce
their emissions of nitrogen oxides (NOx) by 2.7 kkg per year. This is equivalent to
burning about 2,100 barrels of oil per year. But the participants did much more
than reduce air-pollution emissions. Over the life of the program, participants
have saved more than 380 million kilowatt-hours annually. This is enough
electricity to run 42,000 Americanhouseholds for a full year. The cost savings for
the representative group of companies is impressive. The average total cost for
such P2 activities per company was $245,550; the average annual savings per
company was $113,431. In other words, on average, a one-time investment of
$245,550 returned $113,341 for every year thereafter. Payback periods ranged
from less than one year to more than four years (source m EPA doc. #
742/96/002).
Motorola Inc.'s Government Systems and Technology Group, in an effort to
eliminate ozone-depleting chemicals (ODCs), developed a soldering process for
circuit-board manufacturing that is so clean that the chemical fluxes normally
used to remove oxides prior to soldering was no longer necessary. The fluxes
leave corrosive residues, which must be removed with chemical rinses. Freon 113
and trichloroethane (TCA), both ODCs, were commonly used as part of these
chemical-rinse activities. Old-style soldering machines use up to 8,000 pounds of
cleaner per month (i.e., 48 tons of cleaners per year). The newer technology has
eliminated the need for a rinsing stage and, therefore, has eliminated the use of
Freon 113 and TCA c l e a n e r s - and their associated air emissions. Each machine

that employs this new soldering process saves between $50,000 and $245,000 per
year in chemical use alone. Conventional wave solder machines can be retrofitted
for $40,000 to $100,000, thereby providing very attractive payback periods
(source- EPA doc. # 742/96/002).
A recent study of the Polish chemical industry identified 43 pollution prevention
projects among manufacturers of fertilizers, pesticides, synthetic rubber, plastics,
dyes and pigments, coke chemicals, inorganic chemicals, and pharmaceuticals. P2
activities ranged from simple housekeeping practices, to materials substitutions,
to technology changes. The table below summarizes the results of the study. Total
investment for all 43 projects amounted to $1,439,075. In just the first year, these
projects in combination yielded a return of $7,184,490 - - or nearly 500 percent!
The payback periods for these P2 investments ranged from less than 1 month to
more than 2 years, and the projects will continue to generate savings in both
pollution and money in the years to come. What is important to note from the
ix


table is that more than 60 percent of the cost savings were achieved by relatively
low levels of investments (less than $50,000 per activity). Just as the first example
illustrates, P2 is not necessarily a high capital investment. Instead, it can be a lot
of common sense (source: study performed by the authorfor the United State's

Agency for h~ternational Development- USAID).

Investment
Threshold
Low-cost/no-cost:
$10,000 or less
Moderate cost:
$10,000-50,000

Major investment"
$50,000 or more

Total emissions
reduction,
tons/yea r

Raw materials
savings,
tons/year

455,578

832,034

$1,423,430

2,263

2261652

$ 2,898,060

71,108

4201545

"$ 2,863,000

9


Cost savings,
S/year

'

The financial benefits of P2 to a company are most often derived from
incremental savings over time, and from a number of successful projects. Pollution
prevention is every bit a corporate religion that must be adopted throughout an
organization - - starting with top management and working its way throughout the
ranks of a company. The concept of eliminating or reducing polluting wastes (as
opposed to controlling them or treating them after the fact) must be practiced on a
daily basis, in the same way that an enterprise would approach building qualitymanagement principles and philosophy into its products and services. Enterprises must
also carefully monitor the financial performance of P2 projects, and take corrective
actions as needed. For this reason, P2 practices provide the best chances for success
and profitability when they are implemented through an overall environmental
management system.
We have argued that the greatest direct benefits of an EMS will be in the bottomline benefits of P2 practices and technologies, and we have argued that P2 practices
and technologies have their greatest power in the context of an EMS. That is why we
one of us an engineer, the other an economist and planner - - decided that we
needed to write a single volume that would provide managers with the basic
understanding, approaches, tools, and techniques to pursue either EMS or P2 in their
enterprises and, even more important, to pursue both, integrally. A review of the
literature reveals that though the integral nature of P2 and EMS is widely recognized
and understood, the two subjects are never covered together, at least not in any depth.
But they need to be covered together, to a reasonable depth, if the needs and
convenience of managers and practitioners concerned with enterprise environmental
performance are to be served well. They also need to be covered together to help
enterprises capture the full financial benefits EMS and P2 can deliver in combination.
This volume is structured in two parts. Part I is about how an EMS works,

particularly an EMS based on the ISO 14001 standard. It's also about how an
enterprise can establish an EMS that will serve it well, in light of its particular
circumstances and requirements. Part II is about P2 principles, practices, and the tools
for implementing P2 activities m auditing, energy and material balances, and methods


of calculating costs and returns of individual P2 investment and of optimizing P2
investments overall. Both parts are organized into four chapters.
In the EMS presentation in Part I, the chapter titles are:
Chapter 1)
EMS: Principles and Concepts
Chapter 2)
EMS: Applied Models
Chapter 3)
EMS: Tools and Techniques
Chapter 4)
EMS: First Steps
This represents a progression that begins with a sweeping description of EMSs in
general, and ISO 14001 in particular, and then goes to a detailed element-by-element
discussion of EMS and ISO 14001. It then examines a catalog of practical
implementation tools, and concludes by discussing how an enterprise can take the first
steps toward establishing its own EMS.
In the P2 presentation in Part II, the chapter titles are:
Chapter 5)
Pollution Prevention: Principles and Concepts
Chapter 6)
Industry-Specific Pollution Prevention Practices
Chapter 7)
The Pollution Prevention Audit
Chapter 8)

Financial Planning Tools
This represents a progression that begins with a sweeping description of P2; then
goes to detailed real-life examples of P2 practices; then to a step-by-step guide to
conducting a P2 audit to identify real P2 opportunities in an enterprise; and finally to a
catalog of tools for assessing potential P2 investments from a bottom-line point of
view.
Part I provides what managers need to embark on EMS implementation in their
enterprises, including a thorough understanding of the requirements of the
international ISO 14001 EMS standard. Readers who were hoping for a step-by-step
handbook that shows exactly what to do or, in effect, does it for you by providing
boilerplate documentation and procedural prescriptions to achieve ISO 14001
certification need to know that, despite any claims to the contrary, there simply can be
no such thing. Every enterprise is unique; the idea of a one-size-fits-all template for
establishing an EMS is one that will occur only to a person who thinks of an EMS as a
set of fixed requirements rather than as an environmental management system that
needs to be tailored to the circumstances and preferences of each enterprise.
Though Part I provides a thorough and practical understanding of the elements of
EMSs, and of the tools and techniques needed to implement an EMS, and help with
getting the implementation process started, managers will still have to bring their own
creativity, commitment, effort, and knowledge of their enterprise and its operations to
bear on the process of establishing an EMS. This is true whether they are establishing
their own unique model of EMS, establishing one that conforms fully to the
requirements of ISO 14001 and will be able soon to pass a certification audit, or
establishing one that will conform only partially to the requirements of ISO 14001
while aiming to gradually expand to full conformance and certification. Whatever the
case, managers of enterprises will have to invent their own "applied model"-- that is,
invent their own versions of some of the tools and techniques provided here m and
develop their own unique environmental policy statements, environmental procedures,
monitoring systems, and the like. Part I provides the essentials of how to implement an
xi



EMS; it certainly gives managers what they need to get the process started and it
equips them to hire an EMS implementation consultant and supervise him or her
knowledgeably. The aim of Part I is not to provide a substitute for EMS capabilities
that an enterprise lacks. The aim of Part I is to empower those involved with
establishing and operating an enterprise's EMS.
In Part II, the reader will find useful tables and matrices offering proven P2
practices and technologies for specific industry sectors. No less important, Part II
provides a concise approach, through the auditing method and the use of project
financing tools, to implementing P2 practices step-by-step. We place heavy emphasis
on simple but effective techniques for determining the economic viability of P2
projects, and on implementing P2 audits that can identify cost savings as well as
pollution-reduction measures.
The reader will find ample industry examples and case studies in Part II that
strengthen his or her understanding of P2 concepts, methods, and techniques. We
describe techniques for financial analysis of P2 projects, and ways to calculate and
demonstrate the importance of a P2 investment on a life-cycle or total-cost basis in
terms of revenues, expenses, and profits, and give practical examples taken from
industry. Our goal in this section is to equip readers not only with the ability to identify
true P2 opportunities in their enterprises, but also with the ability to sell the P2
investment to top management in terms that are meaningful to them.
Our discussions in Part II apply to different levels of P2 practices or investments.
Some industry sectors require high-tech solutions, and the P2 investments are
substantial. The electric utility industry is one example. If we look at the investments
required to convert older coal-fired plants to natural gas, investments in P2
technologies are staggering, with a single low-NOx gas turbine costing tens of millions
of dollars. These levels of investments may or may not carry with them immediate
returns. On the other hand, an old coal-fired plant can present a range of inexpensive
to moderately expensive P2 opportunities, which could allow for short-term

investment strategies that enable savings to accrue over time. These savings could then
defray costs of the larger-scale investments. For P2 programs to offer enterprises the
opportunity to optimize their investments and savings while achieving environmental
goals, they have to examine several levels of investment. That's why Part II of this
book focuses on identifying and optimizing P2 investment opportunities.
Part II is followed by an appendix titled "Additional Resources," which lists print
publications and Web sites first for ISO 14001-related resources, and then for those
related to P2. These additional sources of information are integral to getting the most
out of this book, and for this reason we reference them often throughout its chapters.
Two additional resources are provided to assist the reader. First, at the beginning of
the book the reader will find an extensive list of abbreviations that are referred to
throughout the volume. Second, the authors have provided, in addition to a subject
index, an index to the many tables that we use throughout the volume. The index to
tables can be found immediately following the appendix.
Nicholas P. Cheremisinoff
Avrom Bendavid-Val

Washington, DC
xii


A ckno wle d gements
Special thanks to Michael Forster and the others at Butterworth-Heinemann who
helped bring this book to light; and to Todd Bernhardt, of Enterworks, Inc. for
bringing his amazing editing talents to bear on the manuscript. Finally, a special thanks
to Tatyana Davletshina for final proof readings of the manuscript.
We'd like also to express our gratitude to the following individuals and organizations
for their many and diverse contributions to this work:
-


-

-

-

-

-

-

-

-

-

-

-

-

-

Peter B ittner, Chemonics International Inc., Washington, D.C.
Angela Crooks, U.S. Agency for International Development, Washington,
D.C.
David Gibson, Chemonics International Inc., Washington, D.C.

Alex Keith, Chemonics International, Inc., Washington, D.C.
Kevin Kelly, Chemonics International Inc., Washington, D.C.
Henry Koner, Chemonics International, Inc., Washington, D.C.
Dr. Svatislov Kurulenko, Ministry of Environmental Protection & Nuclear
Safety, Ukraine
Sergey V. Makarov, Mendeleev University of Chemical Technology,
Moscow
Dan Marsh, Chemonics International Inc., Washington, D.C.
Jennifer McGuinn, Chemonics International Inc., Washington, D.C.
William Moore, Edelman Communications International, Washington, D.C.
Ashraf Rizk, Chemonics International Inc., Washington, D.C.
John Shideler, Futurepast: Inc., Washington, D.C.
Thurston Teele, Chemonics International Inc., Washington, D.C.
Robert Wilson, IQuES, LLC., Detroit
CAST SA, Bucharest
CityProf Consulting, Krakow
Energo-Sistem, Skopje
POVVIK-EP, Sofia
Russian Engineering Academy, Volga District, Samara
The many participants in EMS/ISO 14001 implementation and internal
auditor courses conducted by Chemonics International Inc. in Russia, Eastern
Europe, Asia, and the Middle East.

xiii


Abbreviations
A
AATCC
ABS

acfm
ACM
ACRS
ACS
ADP
AHE
AIRS
AMD
AN
API
ASN
B
BAT
BATNEEC
BB
B/C
BIFs
BOD
BOF
BPT
BS
BS
C
CAA
CAAA
CAN
CCD
CERCLA
CFCs
cfm

CFR
CI
COD
COG
CP

American Association of Textile Chemists and Colorists
acrylonitrile butadiene styrene
actual cubic feet per minute
asbestos-containing materials
accelerated cost recovery system
American Chemical Society
air-dried pulp
acute hazards event
aerometric information retrieval system
acid mine drainage
ammonium nitrate
American Petroleum Institute
ammonium sulfate nitrate
best available technology
best available technology not entailing excessive cost
butane/butylene
benefit-to-cost ratio
boilers and industrial furnaces
biochemical oxygen demand
basic oxygen furnace
best practicable technology
black smoke or British smokeshade method
British Standard
Clean Air Act

Clean Air Act Amendments
calcium ammonium nitrate
continuous countercurrent decanting
Comprehensive Environmental Response, Compensation, and Liability
Act
chlorofluorocarbons
cubic feet per minute
Code of Federal Regulations
color index
chemical oxygen demand
coke oven gas
cleaner production
xiv


CPI
cpm
CSM
CTC
CTMP
CTSA
CWA

chemical process industry
cycles per minute
continuous stack monitoring
carbon tetrachloride
chemithermomechanical pulping
Cleaner Technology Substitute Assessment
Clean Water Act


D

DAF
DAP
DDT
DEA
DIPA
DMT
DO

dissolved air flotation
diammonium phosphate
dichlorodiphenyltrichloroethane
diethanolamine
di-isopropanolamine
dimethyl terephthalate
dissolved oxygen

E

EA
EAF
ECF
EIA
EIS
EMAS
EMS
emf
EMS

EPA
EPCRA
EPT
ERNS
ESP
EU

environmental assessment
electric arc furnace
elemental chlorine-free (bleaching)
environmental impact assessment
environmental impact statement
Eco-Management and Auditing Scheme
environmental management system
electromotive force
environmental management systems
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Environmental Policy and Technology
Emergency Response Notification System
electrostatic precipitator
European Union

F

FBC
FCC
FCCUs
FGD
FGR

FGT
G
GHG
GJ
GLPTS

fluidized bed combustion
fluidized catalytic cracking
fluidized-bed catalytic cracking units
flue gas desulfurization
flue gas recirculation
flue gas treatment
greenhouse gas
gigajoule
Great Lakes Persistent Toxic Substances
XV


GMP
gpm
gr
GW
GWP

Good Management Practices
gallons per minute
grain
gigawatt
global warming potential


H

HAPs
HCFCs
HCN
HCs
HDPE
HEPA
HFC
HSDB
HSWA

hazardous air pollutants
hydrochlorofluorocarbons
hydrogen cyanide
hydrocarbons
high density polyethylene
high efficiency particulate air filter
hydro fl uoroc arbo n
Hazardous Substances Data Bank
Hazardous and Solid Waste Amendments

I

IAF
IARC
ID
IER
IFC
IPCC

IQ
IRIS
ISO
L
LAB
LCA
LCC
LDAR
LDPE
LDRs
LEA
LEPCs
LLDPE
LPG

International Accreditation Forum
International Agency for Cancer Research
identification
Initial Environmental Review
International Finance Corporation
Intergovernmental Panel on Climate Change
intelligence quotient
integrated risk information system
International Organization for Standardization
linear alkyl benzene
life cycle analysis
life cycle costing or life cycle checklist
leak detection and repair
low density polyethylene
land disposal restrictions

low excess air
local emergency planning committees
linear low density polyethylene
liquefied petroleum gas

M

MACT
maximum allowable control technology
MAP
monoammonium phosphate
MCLGs maximum contaminant level goals
MCLs
maximum contaminant levels
MEK
methyl ethyl ketone
xvi


MIBK
MLAs
MMT
MOS
MSDSs
MTBE

methyl isobutyl ketone
multilateral agreements
methylcyclopentadienyl magnesium tricarbonyl
metal oxide semiconductor

Material Safety Data Sheets
methyltertbutylether

N

NAAQSs
NCP
NESHAPs
NGO
NGVs
NIS
NPDES
NPK
NPL
NRC
NSCR
NSPSs
O
ODP
ODSs
OFA
OSHA
OHS
OTA
OTC

National Ambient Air Quality Standards
National Contingency Plan
National Emission Standards for Hazardous Air Pollutants
non-governmental organizations

natural gas vehicles
Newly Independent States of the former Soviet Union
National Pollutant Discharge Elimination System
nitrogen-phosphorus-potassium
National Priority List
National Response Center
nonselective catalytic reduction
New Source Performance Standards
ozone depleting potential
ozone depleting substances
overfire air
Occupational Safety and Health Act
occupational health and safety
Office of Technology Assessment
over-the-counter (medicines)

P

PAH
P2M
P2
P3
P3AW
PAHs
PBR
PCB
PCE
PFA
PICs
PM

PMl0
PMN

polynuclear aromatic hydrocarbons
pollution prevention matrix
pollution prevention
pollution prevention practices
Pollution Prevention Project Analysis Worksheet
polynuclear aromatic hydrocarbons
polybutadiene rubber
polychlorinated biphenyls
perchloroethylene
pulverized fly ash
products of incomplete combustion
particulate matter
particulate matter smaller than 10 microns in size
premanufacture notice
xvii


POM
POTW
PP
ppm
ppb
ppmv
PUP
PVC
PVNB
PWB


prescription only medicines
publicly owned treatment works
propane/polypropylene
parts per million
parts per billion
parts per million by volume
per unit of product
polyvinyl chloride
present value of net benefits
printed wiring board

Q
QA

QC
R
R&D
RCRA
ROI
rpm
S
SARA
SBR
scfm
SCF
SCR
SCW
SDWA
SERCs

SIC
SIP
SMT
SNCR
SS
SSP
T
TAME
TCA
TCE
TCF
TCLP
TDI
TEWI
tpy

quality assurance
quality control
research and development
Resource Conservation and Recovery Act
return on investment
revolutions per minute
Superfund Amendments and Reauthorization Act
styrene butadiene rubber
standard cubic feet per minute
supercritical cleaning fluid
selective catalytic reduction
supercritical fluid
Safe Drinking Water Act
State Emergency Response Commissions

Standard Industrial Code
state implementation plan
surface mount technology
selective noncatalytic reduction
suspended solids
single phosphate
tertiary amyl methyl ether
total cost accounting or total cost analysis
1, l, l -trichloroethane
total chlorine-free
toxic characteristic leachate procedure
toluenediisocyanate
total equivalent waming impact
tons per year
xviii


TQEM
TQM
TRI
TRS
TSCA
TSD
TSP
TSS
U
UIC
UNEP
USEPA
USTs

UV
V
VAT
VCM
VOCs

Total Quality Environmental Management
Total Quality Management
Toxic Release Inventory
total reduced sulfur
Toxic Substances Control Act
transport, storage and disposal
total suspended particulates
total suspended solids
underground injection control
United Nations Environmental Programme
United States Environmental Protection Agency
underground storage tanks
ultraviolet
value added taxes
vinyl chloride monomer
volatile organic compounds

W

WBO
WEC
WHO

World Bank Organization

World Environmental Center
World Health Organization

xix


This Page Intentionally Left Blank


Road Map to Part I:
ENVIRONMENTAL
MANAGEMENT SYSTEMS
Part I of this book is designed to provide what the reader needs to put an
EMS in place. It includes information for convincing top management and others
that establishing an EMS is in the best interests of the enterprise, and shows how
an EMS fits in with and reinforces existing management systems. It provides the
means for assessing what kind of EMS would be best for a particular enterprise,
and shows how to take the first steps toward establishing one. It offers tools and
techniques for fully implementing an EMS, whether it's a minimal EMS or one
that will pass an ISO 14001 certification audit. And, most important, it aims to
provide a real understanding of what an EMS is, how it works, how it makes or
saves money for an enterprise, and how it can be adapted to the unique and
changing needs of a particular enterprise.
Our purpose in the four chapters of Part I is to serve anyone with an interest
in the subject of environmental management systems. We make the point (perhaps
too often) that an EMS is not about ISO 14001 certification; rather, it's about
running an enterprise better, more efficiently, more competitively, and more
sustainably, and about making and saving money. Running an enterprise is a
creative endeavor; accordingly, Part I is built on the assumption that readers want
to understand what an EMS is all about and then apply themselves creatively to

building one that operates efficiently and delivers huge benefits for their
enterprises. Consequently, Part I does not dwell so much on the details of what
different EMS procedures enterprises should include as it does on the knowledge
and tools managers need to figure this out for themselves in the context of their
enterprise's operations.
In some cases, top management may be interested for the time being only in
experimenting lightly with a simple and limited EMS, perhaps to see if it offers a
better way to ensure the enterprise's compliance with environmental regulations or
to minimize the risk of environmental liabilities. At the other extreme, top
management may be interested in achieving ISO 14001 certification in a few
months. The material in Part I has been developed to serve those extremes, as well
as everything between, while keeping in mind students and others who just want to
be well-informed on the subjects of EMS and ISO 14001.
Chapter I starts with a short overview of the basic principles and concepts of
EMSs, what ISO 14001 is all about, and the core elements of ISO 14001. As with
all chapters in this book, the last section of Chapter 1 contains a brief review of the
main points. At the end of the chapter are some questions for individual
consideration or classroom discussion (other chapters in Part I have questions and
exercises, or just exercises at the end). The reader who picks up this book only
because he or she is wondering exactly what an EMS is or perhaps what ISO
14001 is, and no more, will have their curiosity completely satisfied by Chapter 1.
If the chapter stimulates a deeper interest, or if for other reasons the reader wants
to go beyond basic principles and concepts, he or she should move on to Chapter 2.


2

GREEN PROFITS

Chapter 2 fully explains:

Each element of an EMS and what role it plays in the overall
management system
Each element's minimum requirements
How each element relates to other EMS elements
How each element can be adapted to the needs of different
enterprises
Exactly what ISO 14001 requires for each element
What an enterprise needs to have in place to pass an ISO 14001
certification audit
Chapter 2 follows the outline of ISO 14001, which is organized as a series of
clauses and subclauses that each represent a distinct element of the EMS. Except
for the introductory and review sections, the sections of Chapter 2 correspond to
the elements of ISO 14001. Though the material stands on its own, enterprises
concerned with ISO 14001 certification will benefit most by reading Chapter 2
with a copy of the ISO 14001 standard at hand. The chapter is called "EMS:
Applied Models" because it contains information that enables the reader to create
an EMS model uniquely appropriate for the circumstances of his or her enterprise.
After reading a section of Chapter 2, some readers will want immediately to
see the tools and techniques for implementing that EMS element. Those readers
can jump to the counterpart section of Chapter 3 before going on to the next
section of Chapter 2. For example, after reading the section of Chapter 2 on
environmental policy, learning what an environmental policy is, and what ISO
14001 requires for the environmental policy of an enterprise, a reader may want to
explore the processes and tools for establishing an environmental policy before
moving on to an explanation of the next EMS element. The counterpart section of
Chapter 3 will provide that information, and will be easy to find because the
counterpart sections in the two chapters have exactly the same names. In this case,
both are called "Environmental Policy (Clause 4.2)."
Chapter 3 presents tools and techniques for establishing and maintaining an
EMS, and is organized the same as Chapter 2 w by ISO 14001 clauses and

subclauses. If Chapter 2 is the overall "what and why" of each element of an EMS,
Chapter 3 is the "how and what does it contain?" chapter. Chapter 3 offers lists,
worksheets, outlines, tips, and so on - - practical help for creating an EMS and
maintaining it, whether it's an ISO 14001 or some other type of EMS. Readers
who already have a full understanding of the details of an EMS, have already taken
the first basic steps toward setting up an EMS in their enterprises, and want only to
access concrete tools for establishing, maintaining, or upgrading their EMSs, can
limit their reading to Chapter 3. However, we recommend reading Chapter 2 as
well, because the spirit of the presentation in Chapter 3 flows from the presentation
in Chapter 2, and there is some material in Chapter 2 that is equally relevant to
Chapter 3 but is not repeated there. Material in counterpart sections of Chapter 2 is


ROAD MAP TO PART I

3

referenced frequently in Chapter 3, and knowledge of the former will help in the
understanding of the latter.
Chapter 4 discusses what first needs to be done in an enterprise on the road to
establishing an EMS m convince top management of the value of an EMS, figure
out what sort of EMS is most appropriate and plan how to put it in place, and
possibly experiment with a minimal EMS that can serve later as the foundation of a
full-scale EMS based on the ISO 14001 standard. Readers who feel they fully
understand what an EMS is and just want some help getting started can begin with
Chapter 4, and next will want to read Chapter 3.
We have assembled the four chapters of Part I to address a sequence of four
questions:
9


What's an EMS in general, and specifically, what is ISO 14001 ?

9

What are the individual elements of an EMS in general, and what are
the ISO 14001 requirements for each of them?

9

What are the tools and techniques for creating each EMS element in
an enterprise?

9

How do I get started?

This sequence of questions imagines that after the first three chapters a reader
would conclude that his or her enterprise should and could establish an EMS, and
at that point would want to know how to get started. But, as we have seen, the
material in Part I can be approached from many different points of entry,
depending on the background and needs of each reader and enterprise.
Throughout the chapters of Part I, we make frequent reference to the material
on pollution prevention (P2) in Part II of this book. This is because P2
improvements in the production process of an enterprise are the ultimate focus of
an EMS, and the bottom-line benefits of an EMS most commonly come from the
P2 improvements it generates. The material in Part I is mostly of a planning and
management nature, while the material in Part II is mostly of an engineering and
financial nature. The presentations are different in approach, because the nature of
the material and the backgrounds of the principal authors of each part are different,
and yet the subjects fit together and reinforce each other in important ways. An

EMS yields big payoffs only through P2 practices, and P2 practices and audits will
have their greatest benefits for an enterprise in the context of an EMS. Sound
engineering and financial calculations applied through a sound strategic-planning
and management system is exactly what an enterprise needs to thrive in an
increasingly competitive and environmentally demanding marketplace.


Chapter 1
EMS: PRINCIPLES AND
CONCEPTS
THE BASICS OF AN EMS: WHAT IT IS, AND WHY DO IT

An environmental management system, or EMS, is an approach ... a tool ... a
set of procedures ... a planned and organized way of doing things ... a system. It is
any planning and implementation system that an enterprise employs to manage the
way it interacts with the natural environment.
An EMS is built around the way an enterprise operates. It focuses on an
enterprise's production processes and general management system - - not on its
emissions, effluents, and solid waste, as environmental regulations do. An EMS
enables an enterprise to address major and costly aspects of its operations
proactively, strategically, and comprehensively, as any good manager would want
to do. Without an EMS, an enterprise can only react to environmental disasters ...
to environmental regulations ... to threats of fines and lawsuits ... to being undercut
by more progressive and efficient competitors.
An EMS is integrated into the overall management system of an enterprise.
Like an overall management system, it represents a process of continual analysis,
planning, and implementation; it requires that top management commit and
organize such resources as people, money,
and equipment to achieve enterprise
Without an E M S , an

objectives;
and it requires that resources be
enterprise can only react
committed to support the management
to environmental
system itself.
Not
too surprisingly,
disasters ... to
productive EMSs are found only in
environmental
enterprises that are fairly well managed in
general. In some cases, these enterprises
regulations ... to threats
adopted EMSs because they already had
o f f i n e s a n d lawsuits ... to
good management systems in place. In other
being undercut by more
cases, installing and maintaining an EMS led
progressive and efficient
to better overall management because it
competitors.
showed the way to improve control over the
enterprise's operations.
There are lots of types of EMSs
around. Some are industry specific, with guidelines often issued by industry
associations. Examples of this kind of EMS include the Forest Stewardship
Council's SmartWood EMS for forest property and forest products; the World
Travel and Tourism Council's Green Globe 21 for the travel and tourism industry;
and the U.S. Government's Code of Environmental Management Principles for

federal agencies.
Many EMSs are uniquely designed for a particular facility: these range from
a simple "plan-act-review-revise" model to the high-tech FEMMS, or Facility


×