Responsible Care: A New Strategy for Pollution Prevention and Waste Reduction Through Environment Management

By Nicholas Cheremisinoff, Paul Rosenfield and Anton Davletshin

Environmental regulations provide protection to the public, workers and the environment. To protect themselves from long-term liabilities, however, companies have to do more than just comply with the basic responsibilities. This handbook is designed to introduce terminology, methodology, tools, procedures and practical guidance for incorporating efficient pollution prevention strategies into the overall business plan. It is a company’s responsibility to protect and control its management of waste and pollution, and a company that fails to do so will ultimately inflict a negative impact on its bottom line, especially in financial performance. Responsible Care delivers critical guidelines and rules of thumb required for industrial managers to improve their companies’ profitability through waste reduction, cleaner production technologies and sound management practices.

• Language: English
• Publisher: Elsevier Science
• Release date: Nov 25, 2013
• ISBN: 9780127999852

Book preview

Responsible Care

A New Strategy for Pollution Prevention and Waste Reduction through Environmental Management

Nicholas P. Cheremisinoff, Ph.D.

Paul Rosenfeld, Ph.D.

Anton R. Davletshin

Table of Contents

Cover image

Title page

Copyright

About the Authors

Preface

Chapter 1: A Primer on Responsible Environmental Management

1.1 Introduction

1.2 Environmental Aspects

1.3 Aspects and Indicators

1.4 Identifying Environmental Aspects

1.5 Assigning Priorities to Environmental Aspects

1.6 Responsible Care

1.7 The Necessity of Investing in an Environmental Management System

Chapter 2: Worker Safety and P2

2.1 Introduction

2.2 Exposure Standards Tables

Chapter 3: The Chemical Process Industries

3.1 Definitions and Terminology

3.2 Polymers Industry

3.3 Rubber Products Manufacturing Industry

3.4 Sulfuric Acid Manufacturing

3.5 Phosphoric Acid Manufacturing

3.6 Insecticide Manufacturing

3.7 Case Study of Fluorine Emission, Recovery, and Utilization of By-Product H2SiF6 for AlF3 Production

3.8 Miscellaneous P2 Practices and Best Management Practices

3.9 Case Study of a Low-Cost P2 Opportunity at a PVC Plant

3.10 Case Study of P2 in Ammonium Nitrate Production

Chapter 4: Refineries

4.1 General Discussion

4.2 Pressure Relieving Systems

4.3 Inhalation Hazards from Tanker Operations

4.4 Oil-Water Effluent Systems

4.5 Air Emissions from Valves

4.6 Cooling Tower Operations

4.7 Miscellaneous Air Emissions

4.8 Case Study of a Crude Oil Unloading Station

4.9 IER Roadmap and Pollution Inventory

Chapter 5: The Wood Preserving Industry

5.1 Introduction

5.2 Historical Perspectives

5.3 Industry Overview

5.4 Chemicals Used by the Industry

5.5 Technology Overview

5.6 Sources of Pollution

5.7 Emission Factors

5.8 Case Studies

5.9 TRI Reporting

5.10 Waste Incineration Practices

5.11 Lessons Learned from the Case Studies

5.12 Source Controls and Best Management Practices

5.13 Using P2 and EMS to Turn Profits

Chapter 6: The Food and Dairy Industry

6.1 Introduction

6.2 Industry Practices and Environmental Aspects

6.3 Converting Waste to Energy

6.4 Economies of Scale

6.5 Meat Processing and Rendering

6.6 Fruit and Vegetable Processing

6.7 Vegetable Oil Processing

6.8 Sugar Manufacturing

6.9 Brewing

Glossary of Useful Terms

Chapter 7: P2 and Best Management Practices in Different Industries

7.1 Iron and Steel Manufacturing

7.2 Lead and Zinc Smelting

7.3 Nickel Ore Processing and Refining

7.4 Aluminum Manufacturing

7.5 Copper Smelting

7.6 Pulp and Paper Industry

7.7 Cement Manufacturing

7.8 Metals Finishing and Fabrication

Chapter 8: Environmental Economics

8.1 Introduction

8.2 Environmental Economics within the Context of Responsible Care

8.3 Financial Planning Tools

8.4 Summary of Tools

Chapter 9: Adopting an EMS

9.1 Introduction

9.2 Commitment and Environmental Policy

9.3 Initial Environmental Review

9.4 Planning the Environmental Policy

9.5 Implementing the Environmental Policy

9.6 Measurement and Evaluation

9.7 Developing an Environmental Effects Register

9.8 Monitoring and Measuring Hardware

9.9 Compliance Status

Index

Copyright

Responsible Care: A New Strategy for Pollution Prevention and Waste Reduction through Environmental Management

Copyright © 2008 by Gulf Publishing Company, Houston, Texas.

All rights reserved.

No part of this publication may be reproduced or transmitted in any form without the prior written permission of the publisher.

Gulf Publishing Company

2 Greenway Plaza, Suite 1020

Houston, TX 77046

10 9 8 7 6 5 4 3 2 1

Printed in the United States of America.

Text design and composition by Ruth Maassen.

Library of Congress Cataloging-in-Publication Data

Responsible care : a new strategy for pollution prevention and waste reduction through environmental management / Nicholas P. Cheremisinoff … [et al.].

p. cm.

Includes bibliographical references and index.

ISBN-10:1-933762-16-0 (alk. paper)

ISBN-13: 978-1-933762-16-6 (alk. paper)

1. Pollution—Prevention. 2. Waste minimization. 3. Environmental responsibility. 4. Environmental management. 5. Social responsibility of business. 6. Environmental protection—Case studies. I. Cheremisinoff, Nicholas P.

TD174.R474 2008

628.5—dc22

2008013770

About the Authors

Nicholas P. Cheremisinoff is a consultant to industry, international lending institutions, and donor agencies on responsible environmental care practices. His career spans more than 30 years over a diverse spectrum of industry sectors. His assignments brought him to many parts of Eastern Europe, where he helped draft Integrated Pollution Prevention and Control legislation for the government of Ukraine; to Romania, Bulgaria, other parts of the Balkans, where he conducted numerous pollution prevention programs and retooling of environmental regulators; to Russia, where he consulted with various industries on responsible care and cleaner production investments; to the Middle East where he consulted with the Ministry of Environment of the Hashemite Kingdom of Jordan on pollution prevention programs and retooled hundreds of industry stakeholders on the application of environmental management systems; and to other parts of the world on assignments focused on cleaner production investments and sound environmental management practices. He is the author, coauthor, or editor of more than 100 technical books and hundreds of state-of-the-art review articles and scientific papers. He received his B.Sc., M.Sc., and Ph.D. degrees in chemical engineering from Clarkson College of Technology.

Paul Rosenfeld is an environmental chemist at SWAPE, as well as a lecturer at UCLA’s School of Public Health. His focus is fate and transport of environmental contaminants, risk assessment, and ecological restoration. His project experience ranges from monitoring and modeling of pollution sources as they relate to human and ecological health. Dr. Rosenfeld investigated and designed cleanup programs and risk assessments for contaminated sites containing pesticides, radioactive waste, PCBs, PAHs, dioxins, furans, volatile organics, semi-volatile organics, chlorinated solvents, perchlorate, heavy metals, asbestos, odorants, petroleum, PFOA, unusual polymers, and fuel oxygenates.

Dr. Rosenfeld obtained much of his experience in evaluating contaminated sites while working for the United States Navy. He served as a remedial project manager for the Navy Base Realignment and Closure Team (BRAC) South West Division on Treasure Island, California. He has experience managing multiple sites with multiple contaminants including dioxins and PAHs, designing landfill caps for the Navy BRAC Pacific Division in Orote, Guam, and restoring the environment surrounding a 26-mile petroleum pipeline at Marine Base Camp Pendleton, California.

Dr. Rosenfeld received his Ph.D. at the University of Washington in soil chemistry, an M.S. degree from the University of California at Berkeley in environmental science and management, and a B.A. from the University of California at Santa Barbara in environmental studies.

Anton R. Davletshin is a fourth-year school of architecture and business major at Virginia Polytechnic Institute in Blacksburg. He is specializing in the design and construction management of green buildings. In the past, he had internships with N&P Ltd., where he researched information for various P2 projects and helped develop cost and engineer databases, and for Bittinger Associates Construction Company, where he gained construction supervisor experiences. He is currently under an internship with Forrester Construction Company of Rockville, Maryland, a large commercial construction firm that services clients nationwide.

Mr. Davlestshin developed his research and technical writing skills in numerous assignments, including the creation of this book. Among his technical skills is fluency in four languages.

Preface

This book is written for corporate environmental managers and those individuals who influence or help to create and steward the environmental policies of their companies and organizations. It is written at the operational level, meaning that technologies and practices for managing waste and pollution are examined.

Corporations owe it to themselves, their employees, and their investors to carefully monitor and control the environmental aspects of their business operations. To many companies, this means paying close attention to and following environmental regulations. However, we believe this is inadequate.

Environmental regulations are based on statutes created to provide a minimal level of protection to the public, workers, and the environment. Merely focusing on meeting statutory obligations does not ensure that a business is acting responsibly or meeting a high standard of environmental performance. When a company focuses its resources and efforts to meet only its statutory obligations, it is doing nothing more than making the minimum investments in controlling the negative impacts of its operations and services. Furthermore, we argue that, when a corporation does only what the regulations say it should do, long-term liabilities are likely to be encumbered that could result in significant financial losses to the company.

A simple example to this point may help convince some of our readers. Many companies maintain underground storage tanks that are regulated. When the Resource Conservation and Recovery Act, Title C, went into effect in 1988, facilities were given a 10-year grace period in which to meet new technical design and operating standards aimed at preventing accidental spills and leaks that adversely affect groundwater quality. Many companies faced with this legal obligation already had 25-year-old tanks, single-walled, bare-steel vessels that they suspected or should have suspected were potential leakers. The law was intended to eliminate this problem over time. Many companies simply chose to delay modernization investments until the compliance due date.

From one standpoint, this makes business sense, because after all, why initiate a high-capital investment when full compliance is a decade away? But, in another sense, this not only is a poor business decision but irresponsible. Companies that chose to wait until the compliance schedule mandated changes wound up dealing with a succession of environmental cleanup actions as well as civil suits from third-party property damages and, in some cases, community actions from entire neighborhoods. The costs for remediation of contaminated soil and groundwater from leaking tanks, in some instances, were but small components of the financial impact to some companies, when we consider the liabilities associated with medical monitoring, property diminution, legal fees, and damage to corporate reputation.

Our approach is quite simple. We believe that all companies should have a formal environmental management system (EMS) that focuses on the identification and systematic elimination of the negative environmental impacts of their operations. We argue that the focus of the EMS not be on meeting the minimum statutory requirements for environmental protection and worker safety but rather on a systematic approach to reducing wastes and inefficiencies over time. Waste and inefficiency are pollution. Waste and inefficiency cost a company money by raising operating costs that cannot be passed on to customers, by consuming resources in a reckless and irresponsible manner, and by placing the workforce and the public in harm’s way, which in turn results in financial threats to the company.

The book has nine chapters. The chapters are designed to introduce terminology, methodology, tools, procedures, and practical advice on how to improve profitability through investment in financially sound best management practices, pollution prevention, and cleaner production technologies, and to incorporate responsible care as a strategic objective in an overall business strategy.

We gratefully acknowledge the cooperation and contributions made by the Jordan Phosphate Mining Company and the Jordan Petroleum Refinery. These facilities are to be commended for allowing independent critical assessments of their environmental management systems with a focus on improving overall environmental performance. In particular, we thank Hani Dukhgan, Dr. K. G. Halaseh, and Dr. N. Abu Omar of the Jordan Phosphate Mining Company for their case study contribution to Chapter 3.

Finally, special gratitude and thanks are extended to the Gulf Publishing team for their dedication and tireless efforts to bring forth high-quality publications to the industrial community.

CHAPTER ONE

A Primer on Responsible Environmental Management

1.1 Introduction

This chapter serves as a primer for responsible environmental management. It introduces some important terminology that is used throughout the handbook, including the terms environmental aspects, responsible care, environmental management systems, environmental metrics, and several others.

After we standardize our vocabulary, we focus on certain aspects of responsible care, including fiscal responsibility or what we refer to in the Preface as environmental economics. Environmental economics is a subset of responsible care. We examine this subject in detail in Chapter 3.

A final word by way of introduction: For those readers already familiar with today’s jargon on responsible care and environmental management, this chapter still is worth looking over. We have not simply quoted generally recognized definitions of important terms but rather tried to place them within a practical context by relating them to experiences encountered in our consulting practices. Perhaps more important, we tried to relate some of the terminology within a context of historical use. We believe this is important. Although environmental management practices certainly have evolved over the years, the core principles of acting in a responsible manner—whether it be for worker protection, public safety, or fiscal soundness—have remained the same over the decades. This is best illustrated by the examples cited in those chapters that deal with case studies from different industry sectors.

1.2 Environmental Aspects

Today, we use the term environmental aspect to describe a certain feature of a business that, in fact, companies have concerned themselves with since as early as the late 19th century, albeit attaching lesser importance to it. The term environmental aspect (EA) refers to the relevant issue(s) that a management needs to address, irrespective of level of abstraction, such as waste management, worker protection, compliance, public safety, property damage, global warming, resource extraction, lack of knowledge about process emissions, toxic material management, and biodiversity. If we sat back and generated a list of EAs associated with our business or operating division within a company, we in fact would be developing a basis to define the scope of the responsibility of an environmental management system (EMS). The list that identifies the EAs logically leads to defining the inputs to other actions aimed at their management, which forms the basis for both a strategy and action plans. The EAs you identify on your company’s list are those specific to your operations and have an impact on the business of your company. They indeed are the only ones that the company can focus attention to, because they are specific to that business and not some other company. Hence, they are the basis of the company’s strategy, its policy toward environmental management and its action plans, and they influence corporate decisions that affect finances.

Companies that rely on a formal EMS apply the EA concept to managing compliance issues in an aggressive manner. In contrast, companies that conduct their business without an explicit list of EAs generally tend to lack transparency in the priority setting of their environmental work, even though they may have a corporate environmental policy statement. All companies really should explicitly identify their EAs, if for no other reason than that it brings clarity and transparency to the organization’s management of environmental issues. Among the reasons why transparency is needed are:

• Internal to the company management, both decision makers and line and function people require it to effectively implement corrective actions and action plans and to make the hard decisions concerning resource and money allocations.

• Internal to the company again, the accounting division needs transparency to properly account for environmental expenditures in the bottom line.

• External to the company, shareholders and investors demand this today, more so than at any other time in history.

• Homeland Security and emergency responders need access to this information, because it can have an impact on emergency preparedness and responses to environmental catastrophes.

• It can serve as a form of insurance against frivolous claims of wrongdoing and lawsuits, or in being named as a potentially responsible party (PRP) to environmental damages.

• It can help protect the future value of assets or property, especially at the time of sale or in mergers and acquisitions.

The term EA is used to identify the important issues an organization should take into consideration in its environmental work. These include things that we care about due to its human aspects, such as noise, odor, occupational exposures to potentially harmful environments and situations, laws and regulations, being a good neighbor, and responding to a complaining community. EAs can be a product’s or production process’s environmental impact, such as emissions to a nearby stream, lake, or river; smokestack emissions; or the overuse of energy. Some other examples are emissions of a chemical, waste generation, production leakage, recycling, hazardous materials, electromagnetic fields, and the impact on flora and fauna.

Now, of course, what we have focused on are negative EAs. The negative EAs are what companies need to focus on reducing, eliminating, or preventing as a part of their strategy. But, is it practical to eliminate all negative EAs? The answer is yes and no.

All organizations, large and small, have limitations. They have limitations in resources that range from expertise to money to personnel and even technologies. Elimination of all the negative EAs stemming from a business can be impractical in the short run, but is both a reasonable target and likely achievable over time. This is why simply having a list of EAs is simply not enough. An organization must place effort and resources into deciding which EAs are the most critical and should be addressed first. In other words, EAs must be given a prioriy for a company to develop a logical, effective action plan that systematically eliminates or reduces the severity of negative impacts over time.

Before we set priority EAs, let us first examine the term within the context of a specific EMS. There are different types of EAs according to the International Standards Organization (ISO) standards. The EMS, ISO 14001, and other international standards are used by companies to find a common basis for managing the environment affected by a business’ operations. Implementation of an EMS, like ISO 14001, includes defining the environmental policy, planning and implementing of an environmental program, checking measures according to goals, and reviewing by management. ISO 14001 is characterized by demands for continuous measurements and an EMS that is business focused.

According to ISO 14001 (1996), EAs are elements of an organization’s activities, products or services that can interact with the environment. The environment is defined as surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation.

Further, the term environmental impact (EI) is any change of the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services. Annex A to ISO 14001 states,

The process to identify the significant environmental aspects associated with the activities at operating units should, where relevant, consider:

• Emissions to air

• Releases to water bodies

• Waste management

• Contamination of land

• Use of raw materials and natural resources

• Other local environmental issues.

Significant EAs are the most important ones, those that cause the highest environmental impact or are important due to legislation and other requirements (e.g., environmental policy, customer demands). Significance equals the priority setting (not relative) among chosen EAs at a company.

1.3 Aspects and Indicators

Here’s another term to add to our vocabulary, environmental indicator (Ei). An Ei is a quantifiable aspect. In ISO 14042, the term aspect is not used; however, the term impact category is applied—but the terms are equivalent in a practical sense. A category indicator is a quantifiable representation of an impact category.

In ISO 14042, the term weighting is described as the process of converting indicator results of different impact categories by using numerical factors based on value-choices. The application and use of weighting methods should be consistent with the goal and scope of the organization, and it should be fully transparent. Weighting methodology is important because it allows an organization to quantify the significance, that is, to assign priority to specific, significant aspects.

The term characterization also is used in ISO 14042. Calculation of category indicator results is referred to as characterization. One approach to performing these calculations involves the numerical ranking of EAs and is described further on. This methodology uses characterization factors and the outcome of the calculation is a numerical indicator that enables us to establish a quantifiable basis for setting priorities on EAs; hence, it allows an organization to formulate an environmental action plan that systematically calls for corrective actions in accordance with the organization’s priorities.

From the ISO 14001 perspective, the impact categories are relevant issues for the EMS; and from the ISO 14042 perspective, they may be associated with both a characterizing description of how the environment is affected and a causal description of, for example, how a product or process gives rise to this effect.

In a practical sense, the first step is to identify, name, and define the list of aspects. There should be no unclearness about what an aspect includes. After assigning priorities to the aspects, a list of significant aspects can be created.

A cause-effect chain (characterization methodology) is used to trace the relationship between an environmental impact and, say, an aspect of an organizational behavior or a product. Let us consider an example. If we want to avoid contaminating fish in a local stream and exposing our neighbors who might rely on the local watercourse for recreational fishing, this would imply avoidance of emitting arsenic from a production facility. The logic of this reasoning involves a backtracking of the methods described in the framework of ISO 14042. It results in a logic description and an understanding of the company’s potential environmental cause-effect chains.

Many companies, even those that rely on formal EMSs, often have problems in identifying their EAs. In fact, most of the time, the list of EAs stems from compliance requirements, but sometimes the list goes beyond mere compliance. In fact, a lot of well-known companies make their environmental information open to review by the public, mainly in the form of an environmental management declaration (EMD), information about the company’s environmental policies, environmental performance and action plans, and the like. However, we have observed that the environmental impacts and the list of EAs often differ from the action plan and environmental goal set up for the organization for the next years. This means that a relatively small fraction of the aspects identified within an organization are actually addressed and improved upon. Some of the chapters dealing with case studies help illustrate this disturbing observation.

This factor implies a lack of consistency—companies may regard a number of the EAs as important and have knowledge about their own impact on the environment, but they do not take it into consideration in the daily work. There are many reasons for this disconnection, but an overriding one is an almost blinding focus on meeting minimum statutory requirements. Companies with seemingly good compliance records do not necessarily have good overall environmental performance records.

1.4 Identifying Environmental Aspects

The process of identifying environmental aspects is really an exercise in auditing. It involves taking a close look at the business and asking how the various activities interact with important factors in the surrounding environment. Let us walk through an example, but to simplify the exercise, let us ignore for the moment any statutory or regulatory compliance issues.

In this case, we consider a textile manufacturing facility located in the Middle East. The plant manufactures 100,000 units per week of fashion garments, which includes woven pants and men’s, ladies’, and children’s cotton and microfiber garments. The facility has a workforce of 1800 persons that perform their functions over two shifts, six days per week. The company’s products are made for an export market, and the products and processes are ISO 9000 quality assurance certified. The operation consists of a two-floor concrete building with a main production floor that is more than 27,000 square meters in size.

The first step in performing an audit should be to step back and ask ourselves how many and what types of operations there are. No audit should be started without at least a simple process diagram. For brevity, we list the main operations, which are:

• Garment cutting.

• Sewing.

• Embroidery.

• Finishing.

• Laundry.

• Packaging, warehousing, and distribution.

In addition to these, there are support functions:

• Chemical management.

• Utilities.

• Wastewater treatment.

Like any other audit, the way we find out information is by looking at the process steps and asking questions. Let us look at some of these operations and, while doing so, ask yourself how each of the processes interacts with the immediate environment. Figure 1.1 shows the cutting operations and Figure 1.2 shows the EAs associated with this stage of the manufacturing process. Figure 1.3 shows some of the functions performed in the garment finishing stages. Figures 1.4 and 1.5 show the operations and EAs in the washing stage, respectively. For brevity, we quickly look at the EAs associated with packaging, utilities, chemical management, and wastewater treatment operations, shown in Figures 1.6 through 1.9.

Figure 1.1 The cutting stage operation.

Figure 1.2 EAs associated with cutting operations.

Figure 1.3 Operations in the finishing stage.

Figure 1.4 Laundering (washing) stage.

Figure 1.5 EA stemming from washing stage.

Figure 1.6 EA from packaging and warehousing.

Figure 1.7 An EA in the chemical management operation.

Figure 1.8 EA from the utilities section.

Figure 1.9 EA from the wastewater treatment plant.

The photo expose reveals a variety of environmental aspects, which include:

• Poor housekeeping, leading to potential physical hazards from worker trips and falls, plus loss of materials, such as chemicals.

• Solid wastes from cutting and trimming operations and poor housekeeping practices.

• Worker exposure to vapors and particulates.

• Air emissions.

• Wastewater.

• Energy and steam losses.

In this example, wastewater is the most serious or highest priority EA that jumps out. First, the country has severe water restrictions, and hence its cost for clean water is high. It also pays for off-site disposal of wastewater that it pretreats on site using a DAF (dissolved air floatation) unit. The cost for raw water and transport and disposal of its blue water (treated wastewater) is more than $2.80 per cubic meter. Added to this cost is the cost of operating and maintaining a wastewater treatment plant and the labor associated with it. The enterprise also faces a long-term liability issue with its wastewater disposal. The country is evolving toward waste management legislation, which will require the company to maintain a generator and waste transport license and it may have to contribute to the cleanup of a large surface impoundment area in which it has been disposing of its wastes, along with other enterprises, for many years. The cost of that remediation is yet to be determined and depends in part on the impairment to groundwater quality in the region and the subsequent health effects suffered by the surrounding community.

Every one of the EAs has a negative impact on the environment; with the environment being the workers, the surrounding community, and the fiscal well-being of the enterprise itself. This is one of those examples where there is recognition of the environmental aspects of the manufacturing operations and even acknowledgment on the part of management that simple, low-cost corrective actions can be taken, but only the wastewater issue is being addressed. The obvious question is, why not take corrective actions against all of the EAs?

The answer to this lies in how far the impacts of an EA are analyzed and the ability to relate them in a fashion that provides senior decision makers the proper incentives to make changes. Every EA can be approached in the same manner: It either poses a potential threat to workers or public safety through exposure to chemicals and waste or it costs the company money. In fact, whether or not an EA poses a threat in terms of health and environmental protection, it has a cost to the company. After all, EAs are indicators of waste and inefficiency, and any waste or inefficiency is directly related to a dollar value that a company loses.

Let us take worker safety from inhalation exposure to particulates and even physical hazards posed by poor housekeeping. The adverse effects from the EAs have a direct impact on productivity, and employees are entitled to workers’ compensation claims (although the benefits are far below Western standards). Even with a low yearly impact to cost, the effects can be significant when one considers the cumulative losses over time. The way to look at the cost component of an EA is to project not only what you lose in dollars at any one point but the cumulative losses over time.

Even here, the cumulative costs may be too small to grab attention. But, if we analyze the EA a little more, we see that some of the impacts on worker productivity are related to other EAs, such as dry and bulk chemical losses from spills and leaking containers on shop floors (material losses), and draining hoses and leaking valves allowing water to flow onto shop floor areas, creating slipping hazards (with the lost water costing the company $2.80 per cubic meter, because it loses money from the use and disposal of the waste that goes to the plant’s sewer, which in turn feeds to the wastewater treatment plant on site). The root causes of one EA often are the root causes of other EAs. Another way to say this is that EAs often are not stand-alone aspects but interrelated with others. When you look at EAs from this standpoint, all of a sudden, the cumulative losses become magnified. The reason companies do not see this is they lack the data; in other words, they simply do not monitor these losses. If monitoring is not performed, then there is no database on which to calculate the financial losses to the company.

For now, let it suffice to say that an important activity closely connected to the identification of relevant aspects is to define these aspects. The proper definition needs to explicitly explain the included parts of the aspect. The importance of defining EAs in detail often is forgotten, which might cause misunderstandings and lost opportunities for saving. One perspective of the question of how far the aspects should be broken down and analyzed is that one should try to make the EA aspect quantitative, based on the same calculation, such as company year, and always related to a value. This enables comparison and ranking among the company’s EAs and provides senior management orientation in terms of the relative need to address corrective actions from a business standpoint.

There is another important reason why extra effort should be placed into dissecting an EA in detail—it has an educational or orientation and retooling impact on the work environment culture. Education is a prerequisite to be able to change workers attitudes and increase the awareness of environmental and sustainability issues.

Each EA, if possible, should be quantified in terms of an environmental indicator. The indicator can be defined or presented in nominal scale, ordinal scale, interval scale (e.g., the scale on a thermometer), and ratio scale. Tools are needed to facilitate the procedure to calculate the indicators. There are a number of approaches to this. One suggestion is offered in the next section.

1.5 Assigning Priorities to Environmental Aspects

A list of EAs can define the scope of responsibility of an EMS and thus help establish the priorities of an organization. The aspects on the list are the ones on which the company should focus its environmental activities. Economic, practical, health-related, and sustainability factors are various reasons why an organization needs to assign priorities to the aspects.

Logically, an organization should choose the aspects most relevant and important for them as those needing corrective action. Consider an example. Assume we are the owner of several convenience stores that sell gasoline as a part of the business. We are faced with the cost of meeting certain environmental technical standards to upgrade the underground storage tanks (USTs) and associated piping aperture. Now, we can approach this from facing a huge investment that involves removing the old tanks and upgrading them with modern, double-wall tanks and piping. Most probably, we face cleanup issues for groundwater and soil contamination if the UST systems are relatively old, or we could choose to delay meeting the full requirements of the standards by installing cathodic protection and conducting yearly tank integrity testing until several years into the future, when the law requires full compliance. The latter approach sounds reasonable from a business standpoint because we need not face a huge upgrade investment all at once.

However, that may not necessarily be the most cost-effective approach. Delaying upgrades runs the risk that one or several of the older tanks fails; in which case, the company faces financial exposure not only from site cleanup costs but potential legal liabilities from neighbors whose property values or health are placed at risk from gasoline releases leaving the property. Also, a potential negative community relations problem can adversely affect the business. The public is far less tolerant today of companies perceived to conduct business in an environmentally unfriendly manner. To a small local community, gasoline migration onto their neighbors’ properties that results in significant diminution of property value or gasoline seepage into the subbasement of a senior citizens’ apartment complex are consequences that could have been prevented by replacing older tanks right off the bat. These are the types of situations where sympathetic juries may favor punitive damages, costing the owner more than if the company addressed the EAs at an early stage of recognition.

There is no right or wrong approach to setting priorities on EAs and devising corrective actions. But, the more information we have and the more effort placed into the definition(s) used to apply a quantitative basis for assigning priority to the aspects, the higher the probability that the cost to the business on the whole will be minimized. In the preceding example, if we only looked at the UST EA from the standpoint of meeting a statutory requirement, we would ignore the potential consequences from a future liability. Now, one can argue that we place too much weight on something that may or may not happen. But, we can hedge our bets by defining the probability of LUSTs (leaking USTs). Clearly, we could step back and take inventory of our situation by defining the age of each tank, its size, the number of turnovers per year, the location of the tanks in relationship to sensitive receptors, and other factors. This type of characterization clearly would help us work from a more qualified basis to rank the relative importance of the UST EA compared to other EAs of the business. It further helps define a possible approach to managing the EA through, perhaps, a scheduled approach, where the oldest tanks at locations of highest risk of failure and impact could be addressed first, and those with lower probability of failure and impact addressed further along in time, thus spreading out the costs of modernization.

The right way for a company to rank its EAs is to develop a set of criteria for assigning numerical values. The criteria should be based on information specific to the company operations and on a detailed dissection and definition of each EA.

This sounds like a lot of work—and, frankly, it is. But we know of no other way to approach the subject. Proper analysis of EAs requires a dedicated person or group of people to sit down, understand why and what environmental effects there are or could be with each operation in the business, and then assign a degree of significance. Senior management does this with other aspects of the business. Successful business leaders know the details of their business. They understand the details of the aspects that are important to marketing, sales, manufacturing, product quality, partnering with others, and impacts from different market forces. The environmental aspects are a major part of any business, and ignoring them can not only cause ripples but could have devastating effects on the profitability and even sustainability of a business.

The following pages offer a generalized methodology to assigning priorities to your EAs. With some elbow grease and intimate knowledge of your company’s operations, you should be able to modify the approach so that it is specific to the company. An earlier publication provides some software that applies the methodology and performs the calculations described here (see Cheremisinoff and Haddadin, 2006). The software product is not write protected, so if you have IT smarts or access to someone with programming capabilities, get a hold of the book and software and tailor it to your needs.

Figure 1.10 shows a spreadsheet that helps illustrate the methodology. Although the very first step seems obvious and perhaps trivial, it is no less important than other steps in the procedure. Step 1 is to note down the name of the auditors and the date of the assessment. Who performs the assessment and when are important pieces of historical significance to the company. What comes out of the analysis is a recommendation that has a direct impact on the policies, practices, and investments the organization is likely to make. All technical and business decisions are subject to challenges and may have to be altered in the future. Hence, the people originally involved in the assessment are important, because they may be future consultants or play a role in revisiting the recommendations at some future date. The age of the assessment is important because recommendations made today may not be appropriate or require updating several years down the road.

Figure 1.10 The methodology for identifying and setting priorities for significant environmental aspects.

Step 2 should be to conduct a thorough review of the list of identified activities, products, and services provided by your business. The list can be generated from the EAs identified from a special type of audit, called an initial environmental review (IER). The information documented through an IER provides a baseline of the practices and regulatory status of the company. From that baseline, an audit team needs to identify specific aspects and activities.

Step 3 should be to assess whether the aspects are significant enough to warrant corrective actions. As illustrated by the UST example, several criteria can be used for performing such an assessment, but four general areas often are examined. Your company can focus on the direct impacts to the environment, whether or not the emissions or the control of the emissions meet regulatory (legislative) requirements and other standards, whether or not the output streams are under adequate management control, and finally, assessing the output streams from the standpoint of their effects on both internal and external stakeholders.

A central theme in this book is that acting responsibly means controlling or mitigating negative environmental aspects, even when there are no statutory requirements to do so. The reasons why a responsible company is concerned over negative aspects or interactions with the environment beyond meeting their regulatory obligations should be obvious to many. If not, the case studies in later chapters should offer convincing reasons. Public health and safety and the preservation of natural resources and wildlife are reasons enough. Since these should be among any facility’s greatest priorities, assessment of this category of aspects should be weighted more heavily than the other three. The aspects may be perceived as severe, moderate, or having low significance.

Meeting regulatory obligations is a necessity from the standpoint of staying in business, certainly in the short run. Assessment of this category of aspects also should be weighted more heavily than the remaining two. A severe aspect would be one where it is essential to have permits or meet other regulatory obligations. If those permits do not exist or have expired and the facility is discharging air emissions or liquid and solid waste, then criminal negligence or willful disregard of the law are among the charges facility managers will face, for starters. A moderate impact would reflect that the aspect requires administrative or even a voluntary degree of control to act responsibly and reduce impacts. This subject can be open for interpretation as to the perceived risks to a facility. For example, a facility might have a permit to discharge to the POTW (publicly owned treatment works) sewer system without monitoring its effluent or with minimal monitoring requirements and of only a few parameters. While no regulatory driver forces it to go beyond the minimum monitoring requirements, the facility may choose to do so, justifying the added costs and management from perceived future threats. Sewer lines break, some chemicals leach and seep through sewer lines, thereby threatening the groundwater aquifer quality. Such contamination could migrate off site and expose the facility to cleanup and civil actions from third-party damages. A low impact for the regulatory category simply means that it is not applicable or has a very small potential impact based on the information available to the assessors.

Management control is an important category that focuses on diligence and the efficiency with which environmental issues are addressed. The nature of an EMS forces better and more attentive management control. But, in the beginning, there are significant deficiencies in the management of many environmental aspects. If this were not the case, then there would be no need for the EMS. A severe aspect reflects essentially no management control over it. Moderate significance reflects some level of control but generally poor. Finally, a low-level significance would be one where the aspect is under control.

The last aspect rating category suggested is stakeholders. Internal stakeholders are employees, other operating divisions, marketing, research and development (R&D), and anyone or any operation that may be affected by the aspect being assessed. External stakeholders include investors, the public in terms of perceptions of corporate attitudes and practices toward the environment, banks, insurers, and many others. To assign a proper score to this aspect category, we need to understand how an aspect affects others and whether or not there are downsides to those relationships if the aspect is not controlled. A severe rating would reflect that the aspect is of high importance. A moderate rating reflects medium importance, and finally low simply means the aspect is of low importance.

Since the auditors are faced with several to many aspects to evaluate and their task is to develop a recommendation as to which ones require immediate attention (i.e., a list of priorities for recommended actions), criteria are needed to efficiently rank the aspects relative to each other. To accomplish this, a numerical scoring system can be used. This allows for a quantifiable set of priorities as well as a measurable level of significance for each aspect evaluated. The actual values are immaterial, since this is a relative ranking of importance. What has worked in exercises that we have gone through is for a severe rating to require values between 7 and 10 assigned based on the consensus of the audit team. For a moderate rating of the aspect, values between 4 and 6 can be assigned, again based on the group’s consensus. And for a low rating, values between 1 and 3 can be assigned. The ratings are entered into the evaluation table or matrix for the aspect under evaluation. Each number then is multiplied by the weighting factor (again a weighting factor of 3 is assigned to the Environment category, 2 is assigned to the Legislative category, and 1 is assigned to the Management Control and Stakeholder categories). By summing the multiplied values, a total score or value is obtained. The higher the score, the more significant the aspect. When the scores of several evaluated aspects are compared, those having the highest scores reflect operations with the most significant environmental aspects; hence, those that should be addressed first. This forms the starting basis by which the team can begin devising formal strategy and action plans to recommend to management.

Returning to the methodology’s sequence of steps outlined in Figure 1.10, in Step 4, we document the reasons for assigning the numerical score for each evaluation aspect category. The assessment needs to be transparent and should stand up to peer review. Again, the analysis should result in a recommended strategy and action plans that senior management will consider. The decisions management will make carry financial and other resource allocations; hence, the logic behind or justification for assigning a level of significance for each evaluated aspect is important.

Step 5 is the determination of the level of significance based on a numerical scoring system. The higher the numerical score, the more significant the aspect. When we repeat the exercise for several evaluated aspects and compare their values, the ones with the highest priority become apparent. We also need to be sensitive that there is a minimum threshold of significance, below which corrective actions are not warranted or simply not worth the effort. Since a major driver for investing in an EMS is the financial savings derived from improved environmental performance, an old adage comes to mind. If you see a 50-cent piece lying on the floor, your natural inclination is to bend over, pick it up, and put it in your pocket. But most people will think twice about bending over to pocket the coin if the effort carries the risk of breaking their back. For this reason, a threshold significance value is assigned. Although somewhat arbitrary, based on personal experience with hundreds of P2 audits, we assigned a value of 11, below which the aspect is not deemed significant. Any score above 11 is significant, but the aspect needs to be examined relative to other evaluated aspects.

1.6 Responsible Care

The chemical industry is responsible for the worst industrial disaster in history, the Bhopal disaster, which took place in the early hours of the morning of December 3, 1984, in the heart of the city of Bhopal, India, in the state of Madhya Pradesh. It was caused by the accidental release of 40 metric tons of methyl isocyanate (MIC) gas from a Union Carbide India, Limited, pesticide plant owned by Union Carbide. It was not until 1993 that the International Medical Commission on Bhopal was established to respond to the disaster. The BBC gives the death toll as nearly 3,000 people dead initially and at least 15,000 from related illnesses since. Greenpeace cites 20,000 total deaths as its conservative estimate.

On Saturday July 10, 1976, an explosion occurred in a TCP (2,4,5-trichlorophenol) reactor of the ICMESA chemical plant on the outskirts of Meda, a small town about 20 kilometers north of Milan, Italy. A toxic cloud containing TCDD (2,3,7,8-tetrachlorodibenzo-p-dioxin), then widely believed to be one of the most toxic humanmade chemicals, was accidentally released into the atmosphere. The dioxin cloud contaminated a densely populated area lying downwind from the site. This event became internationally known as the Seveso disaster, after the name of a neighboring municipality that was most severely affected. Eleven communities in the countryside between Milan and Lake Como were directly involved in the toxic release and its aftermath. The four municipalities affected most included Seveso (1976 population 17,000), Meda (19,000), Desio (33,000), and Cesano Maderno (34,000). Two other municipalities were subject to postaccident restrictions: Barlassina (6,000) and Bovisio Masciago (11,000). Health monitoring was extended to a further five municipalities. The entire affected area is part of the Brianza, a prosperous district of Lombardy, itself one of the wealthiest and most industrialized regions of Italy.

The Seveso disaster had a particularly traumatic effect on exposed local populations because its seriousness was recognized only gradually. People in other countries also experienced much heightened concern about industrial risks and the need for tighter regulation of hazardous chemical installations. In these respects, Seveso resembled the Bhopal (1984) and Chernobyl (1986) disasters, both of which have come to be regarded as international symbols of industrial pathology.

The chemical industry in the United States has done more to contribute to Superfund sites than any other industry sector, and it is a major offender in the pending disasters attributed to global warming.

The term responsible care has origins that stretch back to corporate responsibility, which began circa 1920 in the United States. Responsible care in part means applying practices, technologies, and policies that safeguard the public and workers from the harmful affects of industrial activities and the avoidance of catastrophes. Companies have long recognized that they have an obligation to eliminate or reduce the negative impacts of the environmental aspects of their business’ operations. Failure to apply responsible care is an act of negligence (Bendavid-Val and Cheremisinoff, 2003; Cheremisinoff and Bendavid-Val, 2001).

The U.S. Environmental Protection Agency (EPA) Web site (www.epa.gov/superfund/sites/npl/npl.htm) reports more than 1240 active Superfund sites across the country. While many are former military installations and landfills, most were created by the practices followed by the chemical industry before the creation of the U.S. EPA in 1972. No accurate figures are published on either the total costs for cleanup to the public or the numbers of responsible parties, nor are there reliable estimates of how many communities and lives have been adversely affected. In time, the damages will be understood much better than now. A review of the Superfund sites listed reveal that a number of sites are so badly contaminated that remediation costs are incalculable. Also, no reliable estimates have been published on the costs of litigation that range from disputes over cleanup liabilities to third-party damages to torts from toxic effects and class-action suits.

While the chemical industry proudly touts the principles of its Responsible Care program and a commitment to environmental protection, the not-too-distant past practices of many of today’s well-known companies show not only disregard for the environment, but even contempt and, in a number of situations, a display of reckless endangerment toward the public.

Acting responsibly in the environmental management context must be viewed in a holistic manner, addressing not just pollution management but safety, security, and conservation. The questionable practices of this industry continue through present time, largely because of a fixation on complying with regulations as opposed to focusing on good environmental performance.

The term responsible care generally is linked to two important terms that have legal definitions, which vary between states, but generally are:

• Negligence: The doing of something which a reasonably prudent person would not do, or the failure to do something which a reasonably prudent person would do under like circumstances. Negligence is a departure from what an ordinary reasonable member of the community would do in the same community (Source: www.lectlaw.com/def2/n010.htm).

• Reckless: Highly unreasonable conduct that is an extreme departure from ordinary care (Source: www.lectlaw.com/def/c091.htm).

While we can point to many bad past practices, it is important to recognize that much of the safe work practices that evolved in the United States stem from the two major industry sectors of the 20th century: the petroleum refining and allied chemical industries. From an historical standpoint, prior to the enactment of unified federal environmental legislation and a strict enforcement policy, there were both societal and governmental expectations that chemical manufacturers and suppliers acted in a responsible manner in disposing of their wastes as well as protecting workers and the public from harmful environments. The federal government allowed industry to retain control of its waste management and chemical handling practices under the assumption that it acted in a responsible manner. The only legal recourse for workers, the public, or environmental groups against companies that acted irresponsibly was through civil court actions.

Acting responsibly, it can be argued, has been an evolutionary process, where there are three periods or baselines of standards by which industry practices and policies have striven and now strive to meet. The baselines themselves are the best practices and technologies of the day and the regulatory obligations of each period.

The earliest baseline period is the pre-1970 era. Colten and Skinner’s (1996) historical reconstruction of industry practices show that, while concerns over waste and chemical management gained corporate-level attention prior to 1950, the implementation of pollution control measures remained largely a plant-level matter, and it was not until the mid-1960s that numerous companies appointed corporate-level executives to oversee pollution abatement programs. Moreover, up through the 1960s, there was little separation between plant safety and waste management issues. Oftentimes, plant safety engineers were assigned the dual responsibility of managing worker safety and environmental issues.

This practice changed during the late 1960s and continued throughout the second baseline period, known as the enforcement era. The role of the pollution engineer was created across all industry sectors to address compliance issues for air, water, and solid waste in the 1970s. This is best illustrated by the capital investments made in pollution abatement infrastructure. Colten and Skinner (1996) reported that, in the early 1950s, the chemical industry was expending approximately $40 to $50 million per year on pollution abatement equipment. Their limited data suggest that the majority of this was spent on waste treatment systems aimed at ground and surface water protection and associated largely with new facility investments. In other words, industry was not investing heavily in pollution abatement for facilities that had already undergone substantial depreciation.

A study conducted by McGraw-Hill in 1976 (Leung and Klein, 1976) shows that a significant change began to occur in the late 1960s, as pollution generators began to be confronted with a grassroots call for laws to preserve and protect the environment and safeguard the public health. Figures 1.11 and 1.12 provide graphical summaries of the data reported in the 1976 study along with Colten and Skinner’s single reference point.

Figure 1.11 Pollution control expenditures by industry. All data except 1950 are from the Leung and Klein survey, 1976.

Figure 1.12 Percent pollution to total investment ratio. (Source: Leung and Klein, 1976.)

Figure 1.11 provides a plot of pollution abatement expenditures for all industry sectors for those years in which data were reported. While it is generally recognized that, during the pre-1970 period, environmental spending principally was discretionary, between 1950 and 1967, there was more than a 20-fold increase in expenditures. Although the Colten and Skinner data largely represent the chemical industry and the McGraw-Hill study represents all industry, the chemical industry dominated the GNP during the 1950s and, hence, the increase between these years represents a reasonable relative comparison.

Figure 1.11 further shows that pollution control spending rose almost exponentially in absolute dollar terms between 1967 and 1974. This reflects a rapid industry response to the early stages of the regulatory period.

To further understand the significant and rapid responses made by industry to comply with the early obligations imposed under the regulatory period, Figure 1.12 shows a plot of the percentage of total capital investment made by industry between 1967 and 1974. Not only did pollution control spending rise in absolute dollar terms between those years, but its increase as a percentage of total capital investment during those years rose dramatically compared with the pre-1970 period. The study shows that 1.7% of the total capital spending in 1967 was aimed at pollution control; in 1970, 1971, 1972, and 1973, the percentages expanded to 3.1, 4, 5.1, and 5.7%, respectively. The 6.2% pollution to total investment ratio for 1974 was nearly four times that of 1967. The years subsequent to the 1976 study showed even greater levels of expenditures and higher percents of pollution to total investment ratios. These ratios began to decrease in the mid to late 1980s, as the era of environmental management began.

Regulations became the driver for improved environmental performance. While the preenforcement era had best practices and pollution abatement technologies available, investments into control technologies competed with capital-intensive projects aimed at growth and business sustainability. End-of-pipe control technologies represent sunk costs for a corporation. Wastewater treatment plants, air pollution controls, and solid waste management carry nonrecoverable costs. While there remained a period of time where the mentality among industry stakeholders was that such costs are a part of the cost of doing business and, in some cases, could be passed on to the consumer, cost competitiveness contributed to erratic and delayed investments before 1970.

During the regulatory period, regulations and enforcement, as profiled by prosecution of polluters and violators, provided the driver for pollution abatement investments throughout the 1970s and 1980s:

• The 1970 Clean Air Act established major deadlines for emissions reductions in 1975 and then further reductions in 1977, along with state implementation plans (SIPs), which in many instances were more aggressive than the minimum federal standards.

• Until 1972, the federal approach to water pollution was defined by the 1948 Federal Water Pollution Control Act (FWPCA; amendments were made in 1961, 1965, 1966, and