Case Study 7: Identifying Objectives for Your Environmental Management Systems Materials

This bulletin highlights the following pollution Prevention Work Practices: Getting Started Preventing Pollution The Design for the Environment (DfE) Approach For More Information... Expertise-Based Method to Identify Significant Aspects Criteria-Based Method to Identify Significant Aspects Guidelines for Identifying Significant Aspects Setting Your Objectives and Targets Acknowledgements

In 1996, H-R Industries became the first printed wiring board (PWB) manufacturer in the U.S. to obtain ISO (International Organization for Standardization) 14001 certification. H-R Industries has proven that you don't have to be a large, multinational firm to benefit from this certification, or from having and environmental management system (EMS). A wholly-owned subsidiary of McDonald Technologies, Inc., H-R Industries has 300 employees producing multi-layer PWBs at its manufacturing facilities in Richardson and Bonham, Texas.

ISO 14000 is the international standard for environmental management, much like ISO 9000 is the standard for quality management. ISO 14001 provides the framework for an EMS. An EMS is a systematic way to review and improve operations for better environmental performance. Companies have found economic as well as environmental benefites from implementing an EMS. Whther or not they intend to obtain ISO 14001 certification, companies have seen that an EMS helps them use materials more efficiently and streamline operations.

Why would a PWB company like H-R Industries decide to seek ISO 14001 certification? Before initiating its EMS, H-R had a good environmental compliance program and was active in implementing environmental projects to move the company beyond compliance. These programs were working well; however, they were strictly the domain of the Environmental, Health and Safety staff. Without widespread integration of these programs into other departments in the compnay, further environmental improvements were going to be hard to achieve. H-R Industries viewed an EMS as the way to incorporate environmental management into all levels of company operations and decision-making processes. Since implementing their EMS, awareness of environmental issues has risen in all employees, from the CEO to workers on the shop floor.

Other benefits of establishing an EMS have included:

• long-term economic benefit of balancing and integrating economic and environmental interests
• consolidation of all environmental programs into one coherent system. "It's the glue that holds all your environmental programs together," according to H-R Industries' Process Engineering Manager
• competitive advantage as customers may soon prefer, or even require, that suppliers have ISO 14001 certification

The stages of an EMS, as required for ISO 14001, are:

1. Environmental Policy
2. Planning
3. Implementing and Operation
4. Checking and Corrective Action
5. Management Review

The Environmental Policy and the Planning stages form the foundation of your EMS. Your company's commitment to the environment is stated in your Policy. It should include a description of your commitment to continuous imporovement, pollution prevention, and compliance with relevant regulations. Your entire EMS will be designed to implement the principles set in your environmental policy.

The Planning stage is critical to the success of your EMS. If you spend the time to develop a sound, meaningful plan, you will likely be rewarded with improved environmental results. As the saying goes,"if you fail to plan, you plan to fail." This case study focuses on two of the critical planning steps of the EMS:

• Environmental Aspects-identifying the environmental aspects of your operations and determinging which are significant;
• Objectives and targets-setting objectives and establishing targets based on your significant aspects.

All parts of the Planning phase build on identifying the significant Environmental aspects of your operations. An environmental aspect is any element of your business that can interact with the environment. The USO 14001 EMS also refers to impacts. Impacts are the actual or potential changes to the environmental resulting from any of the environmental aspects. The relationship between aspects and impacts is one of cause and effect, and is best illustrated with examples, as in Table 1.

One of the best ways to identify the environmental aspects of your operation is by developing a Proces Map. This exercise involves mapping every step of your process and the inputs and outputs associated with each step. Developiong a Process Map is best accomplished as a team effort. Representatives of a variety of departments and at diverse levels should be included to produce the most accurate description of your inputs and outputs. For this step, and throughout the EMS, working together as a team is likely to produce the best results.

While the ISO 14001 standard establishes the structure of the EMS, there is a lot of latitude for a company to develop the content that best fits its operations. For example, each company selects a mehtod for identifying significant environmental aspects that vest suits its needs. For most businesses, it is critical to choose a method that is simple and easy to understand. The method you use also must be clearly documented. This documentation is needed for the ISO 14001 audit, and also, you will want to review your original list of environmental aspects to help set future objectives.

Described below are two methods for identifying significant aspects. The description of these methods in this case study does not represent recommendations by EPA, but is instead provided as general information about how some companies have approached the task of identifying significant aspects. EPA's Design for the Environmental Program will soon begin working with seceral companies in the PWB industry to develop specific information on how to incorporate pollution prevention and design for the environment considerations when identifying significant environmental aspects.

Expertise-Based Method to Identify Significant Aspects

H-R Industries utilized the expertise of its staff to determine the significant environmental aspects of its operations and to set objectives. Managers from the Marketing, Operations, Environmental Health and Safety, and Engineering Departments met with the CEO to brainstorm how the activities of their area impacted the environment. This team identified aspects associated with the day-to-day functioning of the plant, focusing on those aspects over which they had some control or influence.

For each aspect identified, they determined the associated potential or actual environmental impact. The team came up with a long list of the environmental asects and their associated impacts. They then grouped similar ideas on the list. For example, they identified water use in their electroless copper process and water uise in their alkaline etchant line as aspects, and grouped both of these into one "water use" aspect. Next, they set out to determine which aspects were significant, based on the managers.

For each aspect they considered the severity, the frequency, and the location of its impact. After many iterations, they had a final list of siginificant environmental aspects.

Criteria-Based Method to Identify Significant Aspects

Other companies have developed a simple set of criteria to walk them through the steps inidentifying their significant environmental aspects. The table below shows one possible set of criteria and how to rank them. In the table, aspects are ranked based on six criteria that were considered most important to this fictitious facility. The aspects in the table were then reviewed by a team of employees from different departments in the company. Reviewers ranked the aspects for each criteria on a scale of zero to five. The aspects with total scores of 10 or greater were deemed significant.

The advantage of this systematic approach is that the selection process is Clearly documented for future renew (and for the ISO 14001 certification staff). Again, it is important to select criteria that are simple-the easier the system, the more likely it will be followed.

While the criteria, ranking, and scoring mehtod may work for this facility, it may not accurately reflect the environmental considerations of others. The specific criteria, the number of criteriam and the scoring system need to be determined by each facility, based on the guidelines described below.

Whichever method you find suitable for determining your significant aspects, there are some basic guidelines to follow:

• Refer back to your environmental policy. The method you choose for selecting significant asepcts should be consistent with your environmental policy, and should reflect the principles stated in your policy.
• Verify that your method applies to all processes. The selection method you use to determine which aspects are significant should be general enough so that it can be applied to any process in your facility. For example, worker health and safety" is a general criterion applicable to all processes, wheras "worker exposure to formaldehye is too specific to be applied to all operations in your facility.
• Your method should stand the test of time. You will need to use the same method when you re-evaluate your aspects. Make sure the criteria you use for determing significance are documented and in line with your longer-term environmental goals.

Once significant environmental apsects are identified, use them as the basis for setting your objectives and targets. Select a manageable number of objectives. The objectives do not need to address every significant aspect, as shown in Table 3. To decide which aspects to select, consider some of the non-environmental factors of each, such as:

• regulatory requirements
• technological opportunitues or barriers
• economic and business requirements
• the team's opinions.

It is important to note that environmental impacts were taken into consideration in identiying which aspects were significant, but these business considerations can play an important role in setting your objectivbes and targets.

After achieving some initial successes, your team should revisit the significant aspects that were not addressed in your objectives. It is this systematic process of contiuously evaluating environmental aspects and meeting objectives that drives and organization toward cointinuous environmental improvement.

EPA's Design for the Environment Program would like to thank H-R Industries for participating in this case study, along with DfE PWB Project participants from Circuit Center, Inc., Concurrent Technologies Corp., who provided advice and guidance.