Environmental Policy

  Evaluating Environmental Impacts

  Setting Environmental Goals and Objectives

  Incident Preparedness Plans

  Regulatory Checklist

  Training Log

  Letter For Suppliers

  Letter For Regulatory Agency

  Letter For AHFA

  Auditing Methods

  Corrective Action

  Gap Analysis

  Implementation Schedule

  Structure and Responsibilities

		Right click here to download the environmental policy worksheet in Microsoft Word 6.0 format (*.doc)
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An environmental impact is defined as any change to the environment resulting from the activities, products, or services of your facility.  The purpose of this procedure is to aid you in identifying environmental impacts from your manufacturing process.  In addition, guidance is provided on prioritizing environmental impacts. By identifying environmental impacts, an organization can effectively develop strategies for preventing, reducing, or eliminating potential emissions or releases to the environment.

This procedure provides guidance on examining all activities and products that your company can control or influence.  Activities and products with similar characteristics may be grouped to simplify the evaluation process.  EFEC only requires examining the impacts within your facility.  Impacts not directly associated with your plant can be examined, however, this is not required (i.e., fate of packing material, fate of furniture, environmental impacts of your power generator).

Step 1: Identify each component of your company and production cycle. Activities that are not directly linked to a product or production step, such as equipment maintenance, should also be evaluated.  A process flow diagram may be a good way of identifying the inputs and outputs to your process. These may include:

Step 2: The EFEC team should prioritize impacts.  Prioritization can be done by creating a chart listing the activity, impact, and other factors.  These factors can be frequency, quantity, regulatory status/concern, impact on worker safety, impact on the environment, chemical toxicity, severity, etc.  Once you have identified factors important to your company, you can assign additional weight to specific factors.  Tally up the score and the result should be a list of impacts with an associated priority.

Step 3: The results of the team’s evaluation must be documented.  The EFEC team has the responsibility of working with management to ensure that significant impacts are considered in setting or modifying the organization’s environmental objectives.  

		Right click here to download a sample facility impact assessment worksheet in Microsoft Word 6.0 format (*.doc)
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EFEC requires facilities to establish and maintain documented environmental goals and objectives.  Environmental goals and objectives are your program goals that are consistent with the environmental policy and consider significant environmental impacts. These goals should be flexible and realistic. Goals also aid in measuring the effectiveness of an organization’s environmental efforts and improving the performance of the environmental management system. 

Environmental targets are optional and are based on environmental goals and objectives. Goals and objectives should be more qualitative, while targets are more quantitative.

Management is responsible for adopting goals and targets.  The EFEC Team will establish the goals and targets. The first step is to hold a meeting to discuss the development of the goals and objectives. The EFEC Team will gather the necessary information and input to develop goals and objectives.  Input should be collected from each area within the facility.

The EFEC team should begin with a preliminary list of environmental goals and objectives. In developing these preliminary goals and objectives, the team should consider legal requirements, such as laws and regulations applicable to the facility, all environmental impacts of the facility, technological, financial, operational and other business requirements, and the views of outside interested parties.  Once these goals and objectives are refined, the EFEC Team should ensure that significant environmental impacts are addressed, and the proposed goals and objectives are consistent with the environmental policy.  After management review, the environmental goals and objectives are finalized. 

Goals and objectives may include:

  reduce waste and the depletion of natural resources

  reduce or eliminate pollution

  design products to minimize environmental impacts from production, use and disposal

  minimize the adverse environmental impacts of new activities

  promote environmental awareness among employees and the community

Periodic review of the organization’s progress toward the goals and objectives and targets must be conducted.  Management should conduct periodic reviews of the organization’s goals and objectives and the performance toward achieving them.  Actions should then be taken to support the desired improvement in environmental performance.  The information from the previous year should be used to set goals and objectives and targets for the following year.

This section lists examples of some of the incident preparedness plans that may be used at your facility.  Not all of these examples may be necessary at your facility and this list may not include all necessary plans.  This is not an exhaustive list, and other plans may be required under local or state regulations and requirements.  Your facility should review the incident preparedness plans already in place and update them where appropriate to ensure they meet all regulatory requirements.  Furthermore, a regulatory review should be conducted to determine if other plans are required.  A copy of potential regulatory requirements follows this section.

  Emergency Plan: An emergency plan should instruct employees what to do in the event of an emergency (i.e., fire, hazardous materials release, etc).  The Emergency Plan can include an Evacuation Plan and Hazardous Materials Release Plan.

  Evacuation Plan: The purpose of an evacuation plan is to provide a method for personnel to leave the facility in a prompt, safe, and orderly matter in the event of an incident.

  Hazardous Materials Release Plan: This plan applies to the release of hazardous materials and assigns procedures and specific duties to plant personnel.

  Spill Prevention, Control and Countermeasures (SPCC) Plan: This plan describes the procedures followed to prevent, control, and/or mitigate releases of oil and oil related products.  Required for facilities that store more than 1,320 gallons of oil or petroleum products or have an oil or petroleum product storage tank greater than 660 gallons (all in above ground tanks or containers). A SPCC plan is also required for facilities that have greater than 42,000 gallons of petroleum product storage capacity.

  Stormwater Pollution Prevention Plan: This plan describes the procedures followed to prevent the pollution of stormwater at a facility. Typically required for facilities that store material outside or have process areas that come in contact with precipitation.

  Waste Minimization Plan: This plan describes how your facility will reduce the waste generation.  RCRA requires Large Quantity Generators to have a waste minimization plan.

  Hazardous Waste Contingency Plan: This plan describes how your facility manages hazardous waste. 

  Accidental Release Prevention Requirements (Risk Management Plan): Required if facility has a chemical identified in the Clean Air Act Section 112(R) above the identified threshold.

Note: The Following categories are provided for reference only.  The actual applicable regulations will depend on your site operations.  In addition, many states and communities have regulations that either supersede Federal regulations or are in addition to Federal regulations. Permit terms and conditions may also apply specific requirements to your facility.  Environmental requirements that typically apply to furniture manufacturing are in italics.  

Legal Disclaimer

This document is intended to present accurate (as of the time of publication) information of interest to members of the American Furniture Manufacturers Association (Member Companies).  It does not provide legal or technical advice for specific applications.  Site-specific waste analysis and competent legal and technical advice should be obtained for specific applications.

Any Member Company using this document should be advised that regulations are subject to change and that state regulations can be more stringent than the corresponding federal regulations discussed in this document.

No statement in this document may be construed as legal conclusion, or legal advice, regarding any federal, state or local statue, law, or regulation.  To the extent that Member Companies require legal conclusions or advice regarding the nature and extent of the materials discussed in this document, the company should consult with its legal counsel.

EPA’s web site www.epa.gov/epahome/lawreg.htm provides a general guide to environmental laws and regulations and the Federal Register. State agencies typically have state regulations posted on their web site.

Air Pollution Regulations

1. National Emission Standards for Hazardous Air Pollutants (40 CFR 61)

2. Permits and Registration of Air Pollution Sources 

3. General Emission Standards, Prohibitions and Restrictions

4. Control of Incinerators

5. Process Industry Emission Standards

6. Control of Fuel Burning Equipment

7. Control of VOCs

8. Sampling, Testing and Reporting

9. Visible Emissions Standards

10. Control of Fugitive Dust 

11. Toxic Air Pollutants Control

12. Vehicle Emissions Inspections and Testing

13. National Emission Standards for Wood Furniture Manufacturing Operations

Hazardous Waste Management Regulations

1. Identification and Listing of Hazardous Waste (40 CFR 261)
   - Characteristic Waste
   - Listed Waste

2. Standards Applicable to Generators of Hazardous Waste (40 CFR 262)
   - Manifesting
   - Pre-transport requirements
   - Record keeping/reporting

3. Standards Applicable to Transporters of Hazardous Waste (40 CFR 263)
   - Transfer facility requirements
   - Manifest system and record keeping
   - Hazardous waste discharges

4. Standards for Owners and Operators of TSD Facilities (40 CFR 264)
   - General facility standards
   - Preparedness and prevention 
   - Contingency plan and emergency procedures
   - Manifest system, Record keeping and reporting
   - Groundwater protection 
   - Financial requirements 
   - Use and management of containers 
   - Tanks
   - Waste piles
   - Land treatment
   - Incinerators

5. Interim Status Standards for TSD Owners and Operators (40 CFR 265)

6. Interim Standards for Owners and Operators of New Hazardous Waste Land Disposal Facilities (40 CFR 267)

7. Administered Permit Program (Part B) (40 CFR 270) 

Hazardous Materials Management

1. Control of Pollution by Oil and Hazardous Substances (33 CFR 153)

2. Designation of Reportable Quantities and Notification of Hazardous Materials Spill (40 CFR 302)

3. Hazardous Materials Transportation Regulations (49 CFR 172-173)

4. Worker Right-to-Know Regulations (29 CFR 1910.1200)

5. Community Right-to-Know Regulations (40 CFR 350-372)

Solid Waste Management

1. Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257)

2. Permit Requirements for Solid Waste Disposal Facilities

3. Installation of Systems of Refuse Disposal

4. Solid Waste Storage and Removal Requirements 

5. Disposal Requirements for Special Wastes

Water Pollution Control Requirements

1. Oil Spill Prevention Control and Countermeasures (SPCC) (40 CFR 112)

2. Designation of Hazardous Substances (40 CFR 116)

3. Determination of Reportable Quantities for Hazardous Substances (40 CFR 117)

4. NPDES Permit Requirements (40 CFR 122)

5. Toxic Pollutant Effluent Standards (40 CFR 129)

6. General Pretreatment Regulations for Existing and New Sources (40 CFR 403) 

7. Organic Chemicals Manufacturing Point Source Effluent Guidelines and Standards (40 CFR 414)

8. Inorganic Chemicals Manufacturing Point Source Effluent Guidelines and Standards (40 CFR 415)

9. Plastics and Synthetics Point Source Effluent Guidelines and Standards (40 CFR 416)

10. Water Quality Standards

11. Effluent Limitations for Direct Dischargers

12. Permit Monitoring/Reporting Requirements

13. Classifications and Certifications of Operators and Superintendents of Industrial Wastewater Plants

14. Collection, Handling, Processing of Sewage Sludge 

15. Oil Discharge Containment, Control and Cleanup

16. Standards Applicable to Indirect Discharges (Pretreatment)

Drinking Water Regulations

1. Underground Injection and Control Regulations, Criteria and Standards (40 CFR 144, 146)

2. National Primary Drinking Water Standards (40 CFR 141) 

3. Community Water Systems, Monitoring and Reporting Requirements (40 CFR 141)

4. Permit Requirements for Appropriation/Use of Water from Surface or Subsurface Sources

5. Underground Injection Control Requirements

6. Monitoring, Reporting and Record keeping Requirements for Community Water Systems

Toxic Substances

1. Manufacture and Import of Chemicals, Record keeping and Reporting Requirements (40 CFR 704)

2. Import and Export of Chemicals (40 CFR 707)

3. Chemical Substances Inventory Reporting Requirements (40 CFR 710)

4. Chemical Information Rules (40 CFR 712) 

5. Health and Safety Data Reporting (40 CFR 716)

6. Pre-Manufacture Notifications (40 CFR 720)

7. PCB Distribution Use, Storage and Disposal (40 CFR 761)

8. Regulations on Use of Fully Halogenated Chlorofluoroalkanes (40 CFR 762)

9. Storage and Disposal of Waste Material Containing TCDD (40 CFR 775)

Pesticide Regulations

1. FIFRA Pesticide Use Classification (40 CFR 162)

2. Procedures for Disposal and Storage of Pesticides and Containers (40 CFR 165)

3. Certification of Pesticide Applications (40 CFR 171)

4. Pesticide Licensing Requirements

5. Labeling of Pesticides

6. Pesticide Sales, Permits, Records, Application and Disposal Requirements

7. Disposal of Pesticide Containers

8. Restricted Use and Prohibited Pesticides

Environmental Clean-Up, Restoration, Corrective Action

1. Comprehensive Environmental Response, Compensation and Liability Act (Superfund)

2. RCRA Corrective Action

This section gives an example of a training log for training requirements related to the EFEC program.  An effective and on-going training program is important to ensure awareness of environmental issues and attainment of environmental goals and targets.  A successful training program is interactive and provides the participants with information, awareness, and understanding of environmental issues.  It is important to note that this is only an example, and actual training needs and attendees may vary within your organization.

		Right click here to download a sample training log in Microsoft Word 6.0 format (*.doc)
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		Right click here to download the template letter in Microsoft Word 6.0 format (*.doc)
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		Right click here to download the template letter in Microsoft Word 6.0 format (*.doc)
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		Right click here to download the template letter in Microsoft Word 6.0 format (*.doc)
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EFEC is a continual improvement program.  As part of continual improvement, your EFEC program must be periodically reviewed to ensure it is up-to-date and properly working.  An internal audit of your EFEC program is an important tool for this review.  The purpose of this internal audit is to ensure that policies and procedures that conform to EFEC requirements are in place and have been properly implemented and maintained. 

This section presents basic procedures for conducting periodic internal audits of your EFEC program.  This procedure outlines the process for scheduling, conducting, and reporting EFEC audits.  However, your actual auditing procedure should be tailored to your specific program and needs.

The EFEC Team should review the EFEC program a minimum of once per year.  The EFEC audit is comprised of a planning meeting, the audit, and a closing meeting. The EFEC Leader should schedule the planning meeting. The purpose of this meeting is to adequately prepare the auditors by presenting and reviewing the pertinent policies, procedures, standards, regulatory requirements, and EFEC requirements.  This meeting should also establish which departments or areas will be audited and who will conduct those audits.  

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The auditors should then collect objective information from each area or department audited.  The gathering of information can be accomplished through departmental inspections, interviews with key staff, and the review of relevant documentation.  The purpose of the audit is to find out if the EFEC program is being implemented throughout the plant.  Although this is a self-audit, you should not be afraid to ask tough questions. All audit findings must be documented. An example of an auditor checklist follows this section.  This checklist should be saved and revisited at the next audit. Specific attention should be given to corrective action requests issued from previous audit findings to ensure that improvements were made.

		Right click here to download the EFEC audit checklist in Microsoft Word 6.0 format (*.doc)
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Once the audit has been completed, the audit team should meet to discuss their findings and recommendations.  An audit summary report should then be completed and forwarded to management for review.  An example format for the Audit Summary Report is provided.  The audit report should summarize the auditing process.  This includes documents reviewed, departments inspected, and people interviewed. A copy of the audit checklist should be attached to the report.  A copy of the report should be saved and referred to during the next audit.

		Right click here to download an example audit summary in Microsoft Word 6.0 format (*.doc)
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Based on the findings and recommendation of the audit, any appropriate corrective actions should be completed.  An example of this form is included in this Tool Kit.  Corrective action procedures are discussed in more detail in another section of this Tool Kit.  The EFEC Leader will then report the results of the audit and preventative or corrective actions to company management.

Please note that this process is designed to determine if your EFEC program meets all the requirements as defined by AHFA.  This is not a compliance audit. A compliance audit is a review of your facility and procedures to ensure that you operate in a manner that complies with all applicable federal, state, and local requirements.  You can add a compliance component to your EFEC audit, but this is not required.  EFEC does not specifically require compliance audits.  However, you may feel that a compliance audit makes good business sense and want to include it in your EFEC program.

This section outlines the procedures for identifying, documenting, analyzing, and implementing preventative and corrective actions.  Corrective action is generally a reactive process, resulting from the findings and recommendations of the EFEC audit.  Preventative action is a proactive process intended to address potential problems before they occur.  A preventative action may also be initiated by the findings of the EFEC audit.

Typically, the EFEC audit, EFEC Team or an employee will identify an issue requiring corrective action.  Once a non-conformance or non-compliance issue has been identified, a corrective action request must be completed.  The EFEC Team or designate has the responsibility of identifying the cause of the problem, identifying the appropriate actions, planning and implementing the corrective or preventative actions, and verifying the effectiveness of the actions. The auditor, department manager, or EFEC Leader must document a corrective and preventative action request and the action taken.  An example of this request follows.  A tracking log of corrective actions also must be kept as part of the EFEC manual..

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		Right click here to download a sample log in Microsoft Word 6.0 format (*.doc)
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The Gap Analysis is the first step in developing your EFEC program.  Basically, a Gap Analysis compares your current environmental program to the EFEC requirements to determine what you need to do to bring your program up to the EFEC standards. To do this you can use a combination of interviews with key site personnel, a walk over of key site operations and facilities and use of a checklist designed to guide the process through all the elements to complete the analysis. A Gap Analysis must:

  identify those elements of an environmental program that are already in place

  gain a clear understanding of all current and proposed activities and operations undertaken; and

  gain a clear understanding of  the existing management framework

In addition to the Gap Analysis itself, you will want to include a Gap Closure Plan for the facility that will enable it to identify those actions that need to be undertaken in order to implement EFEC.

The Gap Analysis requires an assessment process and documents the findings from that process. The EFEC Team or the EFEC Leader can conduct the gap analysis.  You will want to review your plant’s documentation and procedures. Interviews with employees may also be helpful in determining the environmental awareness within the facility.  A checklist can be helpful in measuring your current program.  At the conclusion of the assessment, a summary report should be prepared.  The report should provide the findings and identify areas that you will need to address. Recommendations for approaches to filling the identified gaps can be included in the report. The report should include:

  EFEC elements that are already fully in place;

  EFEC elements that are partially in place;

  EFEC elements that have yet to be developed;

  Recommendations for implementing the program.

The report should examining each element in depth.  For example it can describe the level of environmental awareness found among employees at the plant, the effectiveness of existing communication structures or the effectiveness of plans and procedures.

The Gap Analysis Report should also include an implementation schedule with an estimate of the anticipated time frame, schedule, man-hours and resources required to develop those elements identified as not currently conforming to the EFEC standard and to implement and register the program.

		Right click here to download a gap analysis worksheet in Microsoft Word 6.0 format (*.doc)
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This section of the Tool Kit presents an example of the process, level of effort and schedule to implement the EFEC program.  You should expect implementation to require from 6 to 12 months.  This time frame and other estimates are to be used as a guideline, and actual implementation at your facility could vary.

Implementation Process Diagram

Estimating Level of Effort

Right click here to download a sample worksheet in Microsoft Excel 5.0 format (*.xls)

Sample Schedule

This section of the Tool Kit gives a general guideline for the assignment of responsibilities in developing and implementing the EFEC program.  The following information is for example only.  The structures and responsibilities within your organization may need to be modified to accommodate your organization. 

The following list gives a general description of the roles and responsibilities of each party within your organization for the development and implementation of EFEC.

Facility Management

  Has overall responsibility for the development and implementation of the EFEC program.

  Allocates EFEC resources.

  Appoints EFEC Team Leader.

  Sets the focus of the environmental policy, objectives and targets for the organization/facility.

  Participates in management review of the EFEC program for suitability, adequacy and effectiveness.

EFEC Program Manager

  Assembles and directs EFEC Team.

  Coordinates review of existing environmental impacts and environmental management practices of facility.

  Supports management in creating environmental objectives and targets.

  Provides budget and schedule for EFEC program.

  Coordinates development and implementation of EFEC requirements.

  Reports to management on the status of the environmental management system, including environmental compliance, system audits and corrective action plans.

EFEC Team

  Performs review of existing environmental impacts and environmental management practices under the direction of the EFEC Team Leader.

  Maintains environmental procedures.

  Develops, implements and maintains EFEC program requirements under the direction of the EFEC Team Leader.

  Acts as pollution prevention, waste minimization and energy team.

Department/Area Managers

  Support the EFEC Team Leader in providing resources and information to successfully implement EFEC program and achieve environmental objectives and targets.

  Participate in reviewing the facility’s EFEC program.

Controller

  Manages accounting and financial operations of the plant including EFEC development and implementation funding.

  Participates in reviewing the facility’s EFEC program.

Human Resources Manager

  Responsible for providing industrial and public relations for the plant.

  Responsible for external communications with interested parties regarding EFEC.

  Oversees environmental training programs.

  Participates in reviewing the facility’s EFEC program.

Purchasing/Material Handling Manager

  Ensures that delivery, transportation, handling and storage of all materials are properly managed in compliance with the organization’s environmental policy and all rules and regulations.

  Managing disposal of waste materials.

  Maintains information on usage, storage and inventory of all materials.

  Manages facility layout optimization, facilitating material and waste flow.

  Communicates environmental expectations to suppliers and contractors.

  Participates in reviewing the facility’s EFEC program.

Quality Manager

  Assists EFEC Team Leader in maintaining records.

  Participates in reviewing the facility’s EFEC program.

Environmental Coordinator

  Monitors and interprets environmental legal requirements applicable to the facility.

  Coordinates emergency response plans.

  Generates and submits reports required by regulatory agencies.

  Maintains data and information on wastes, air emissions, and other environmental performance parameters.

  Determines the appropriate disposal methods for all wastes.

  Maintains environmental records.

  Manages Permit Applications.

  Maintains environmental management manuals.

Internal System Audit Team

  Schedules and coordinates internal EFEC audit program.

  Reports results of audit to Management and EFEC Team Leader.

  Verifies that corrective and preventive actions are implemented.

The table below shows both leading and supporting roles for each of the general tasks listed.  The actual tasks and assignment of responsibilities may vary within your organization.

Legend:    L = Lead Role     S = Supporting Role