Getting Credit for Being Green
We all have an environmental impact. Is your company getting credit for how you protect your staff and the community? This article discusses a few core concepts and tools for an environmental management system. PLAN: In any management system, you start by looking at what you need to control. In ISO 14001 you start with evaluating your Aspects, Impacts, and Compliance obligations. This is the “Plan” of Plan-Do-Check-Adjust.
Aspects are the elements of your daily activity that could have an environmental impact (think electrical use, or hazardous chemicals)
Impacts are how those elements of your activities could affect the environment (e.g. raw materials, deforestation, water, land, or air pollution)
Compliance obligations are how regulatory bodies require you to control your Aspects to prevent Impacts (e.g. OSHA and EPA controls). Note there are connections for 14001 beyond planet protection, to include the workplace requirements for employee safety, also monitored under ISO 45001.
Identifying Aspects requires looking at each activity within the company from QC and Sales to Maintenance and Custodial, and asking: What do we use, to do this job? In normal and emergency situations, how could this affect our people or the environment? (This can include points from trip hazards, safety risks, paper and electrical use, to landfill use and chemicals getting into air and water supplies.)
Evaluating the impact of those Aspects helps to categorize the risk associated with that aspect, which helps prioritize actions you will take. Start by asking: What is the likelihood of something bad happening in this process? If there was an accident, how severe would the impact be?
Knowing your compliance obligations can feel overwhelming for a small company. But, over the years we’ve seen many small busy shops be impacted when they get a sudden OSHA or EPA visit and painful fines…all because no one took the time to learn the regulatory or compliance obligations. The most long-term option is to invest in training staff. Ask your Payroll or Workers Comp insurance company for guidance on finding regulatory experts that can help you identify the regulations that apply to your company and keep you updated when regulations change. Your local SBDC could also be a good source.
DO: Move on what you know. Once Aspects and potential Impacts have been identified, the next step is to prioritize the actions needed to stay or come into compliance. Within everyone’s 3 spheres of influence (Work/Home, Community and Planet) there are two main ways to address our Aspects and Impacts.
1) Engineering controls – how do we design this product or task to have the fewest potential impacts, now and at decommissioning? This may also include finding suppliers who will support your environmental goals, such as reclaiming pallets or packaging materials.
2) Administrative controls - How do we mitigate the impact of our established activities? What can we Reduce, Reuse, Recycle, Replace, or Return?
The goal is to balance between costs of program implementation vs. the level of severity of the risk and the likelihood that the identified impact will occur.
Control programs should have baseline measurements, and a written program of how the hazard is mitigated or controlled, and how often you will do periodic monitoring to make sure staff are following the control plan as defined and conditions haven’t changed. (Your control plans should ensure safe/appropriate use of everyday items like: Ladders, forklifts, flammable/combustible gasses, machine guarding, hot work, spill containment, confined space work, Lockout-Tagout of machines, Secondary container identification, recycling barrel identification, PPE use like glasses, gloves, aprons, respirators, hearing protection, face-shields, safety shoes, harnesses, etc.)
Recycling and hazardous waste should be collected in containers with the appropriate identification, and collectors should provide you with a chain of custody through EPA registered providers to prove that your waste isn’t ending up in a landfill or poison dump – or heating someone’s shed (true story, from an audit!). That means some research if your collector is not the final recycler.
CHECK: Monitoring effectiveness. If you write a plan to stay in compliance, monitor it to control the plan, keeping you in the clear with regulatory folks, and sending a message to your team that the program (and their safety) are important.
If air is exhausting chemicals, there should be a periodic monitoring to ensure you remain below regulatory limits.
Use of water and electricity should be monitored (tied to production output) to identify spikes that may indicate opportunities to reduce usage (like rolling machine startups to limit a costly energy surge).
Are suppliers and recyclers supporting your environmental objectives? Are they ISO 14001 or EPA certified?
Is wastewater meeting city cleanliness standards?
Is the permit for hazardous waste generation current?
If equipment sound is often above 85 decibels, how often is average exposure verified to ensure the program put in place is adequate?
Are hazardous chemicals appropriately stored to prevent explosions or access to ground water? Are secondary container labels accurate and readable?
Are machines appropriately locked and tagged out before maintenance is done?
Are spill containment kits maintained and located where they would be used?
Are forklift, scissor-lifts, and cranes checked before daily use for safety? Are user licenses current for all staff using the equipment?
Are machine guards kept in place? Or have staff moved them for ‘convenience’?
Are fire extinguishers mounted, well signed, serviced annually, and checked monthly to ensure they are still ready for use?
Is PPE being worn as required? Do employees understand the risk if they choose not to?
Have employees read the controls and SDS sheets related to their work?
Are you practicing all emergency drills annually? (Fire, tornado, spill control, etc)
Are Safety/First Aid kits well supplied, and checked periodically?
Are workplace injuries being reported immediately, and are ‘near-misses’ being tracked and evaluated to implement better controls?
ACT: Making Adjustments. Finding gaps between plan and performance is normal, the key is to take what we have found, and improve controls and monitoring and become more effective. Sometimes that’s adjusting a plan, sometimes it’s monitoring more frequently to ensure controls are effective. Once you have implemented an effective control, the aspect still exists but the potential impact has been reduced; but ongoing monitoring data tells you if/when any further adjustments need to be made.
This may sound overwhelming if you haven’t considered it before. After a while, just like making good products consistently, it becomes a habit. Ideally staff begin to own various sections of these controls and management can lead with vision and resources. There may also be savings on insurance or workers compensation premiums as claims go down. A safe work environment is proven to be more productive. Plus, if you pursue ISO 14001 certification, you can advertise that you are actively managing your company’s impacts – Ask us how to get started!
