A documented environmental policy serves as the foundation of the company’s EFEC effort. The policy should also provide a unifying vision of environmental concern by the entire organization. The policy serves as the framework for setting environmental objectives and targets. Management should present a structure and responsibility for the program, identifying specific individuals with roles and responsibilities.  Environmental policy examples are provided in Appendix C of this manual.  Everyone in the organization should be aware that an environmental policy exists.  In addition, they should understand the policy and what is expected of them. This policy should also be communicated externally.

Your company may have a written or unwritten environmental policy already in place.  A good starting point in developing a documented environmental policy is to identify existing environmental commitments.  For example, most companies are committed to complying with all environmental regulations to avoid fines and adverse public perception. The environmental policy should also state your facility's commitment to conforming to all voluntary commitments.  Consider the results of this preliminary review, and then finalize a policy that reflects the environmental components of your products and activities, such as emissions from finishing, boilers and woodworking.  Your environmental policy should consider continual improvement, pollution prevention, and compliance with relevant laws and regulations.

The finalized environmental policy should be short, simple and understandable.  The policy should be communicated to employees. Employees must understand the policy to promote commitment.  Internal communication of the plan may include incorporation of the policy into training, and posting it at various locations, such as the lunch room.  The environmental policy must be available to the general public on a requested basis.  Please refer to the public education section for more guidance.  

The environmental policy can be factored into a strategic plan and should be used to integrate environmental management with other business management processes such as health and safety, quality, or other organizational policies. An EFEC requirement is a written environmental policy signed by a responsible company official, such as an officer, vice president, or the board of directors, that is available to the public upon request.

It can be used as an objective tool to identify and evaluate opportunities to reduce the environmental aspects associated with a specific product, process, or activity. The facility aspect analysis should be applied to process changes to determine environmental aspects associated with them. Once important environmental aspects are identified, operations associated with the aspects should be identified and operational procedures should be established and maintained to reduce their impact.  

The facility aspect analysis should analyze the manufacturing process including procurement of raw materials, manufacturing, emissions and waste.  In other words, draw a box around your facility and evaluate the inputs and outputs.  There are three components of the facility aspect analysis:

1.   Identification and quantification of energy and resource use and waste emissions (inventory analysis), (items to examine: wood, finishing, dust, boiler emissions, packaging material)

2.   Assessment of the consequences those wastes have on the environment (impact analysis), i.e. more solid waste, air emissions

3.   Evaluation and implementation of opportunities to effect environmental improvements (improvement analysis).

Most companies are already familiar with this process if they have undertaken pollution prevention projects.  Once the environmental aspects have been identified, they can be minimized or eliminated.  The first step in this process is to analyze the company’s activities as a whole.  Consider what raw materials enter the activities (lumber, finishing material, fabric, power), what goods or services are produced, and what wastes or emissions are generated. A facility must also consider all legal requirements when conducting a facility aspect analysis.  A flow chart of major processes may be useful in this assessment.  An example of a facility aspect analysis flow chart is provided in the Tool Kit contained in Appendix C of this manual.  Your company may start with a simple process for assessing activities, and then refine the process over time.

Once the processes and activities conducted by your company have been detailed and assessed, the second step in the facility aspect analysis is to assess the environmental aspects associated with those activities and the regulatory requirements and/or voluntary commitments associated with those impacts (i.e., spill plans, permit requirements, etc.).  Aspects may be releases to the environment, solid and hazardous waste, worker safety, energy use, noise, and other characteristics of the manufacturing process.  An example worksheet is provided in Appendix C.

Your company must also decide which of those aspects are under your control or influence.  Your company is not expected to attempt to manage issues over which it has no control or influence.  For example, your company cannot influence the way the electricity it consumes is generated.  It can, however, control the amount of electricity it consumes.  

The facility aspect analysis should be revisited periodically, such as considering a new process or new equipment. Furthermore, the process of assessment itself should be updated over time as needed.

 EFEC registration requires documentation that a Facility Aspect Analysis has been conducted.

Once the Facility Aspect Analysis has been conducted and environmental aspects have been identified, goals should be determined with the environmental policy and aspects in mind.  They should be flexible and realistic, taking into consideration other issues such as legal requirements, the views and opinions of interested parties, financial and technological considerations, company operations, vendors, suppliers, etc.

Companies looking for definite environmental benchmarks can use optional targets.  Goals should be qualitative, while targets should be quantitative. Examples of goals and targets are shown in the table below.

There are no “standard” environmental goals for the furniture industry as a whole.  You will determine what goals are appropriate for your organization. These goals and targets should be linked to aspects identified in the facility aspect analysis, as well as any legal or voluntary commitments at the facility.  Generally, employees can provide valuable input in establishing, planning for, and achieving goals.  Furthermore, commitment to attaining goals will be built by including employees in the process.  The views of other interested parties, such as community groups and regulatory agencies, can also be considered in setting goals, but are not required.  Suppliers and contractors may also aid in setting and meeting goals.  Some factors to consider include, but are not limited to:

  Ability to control an environmental issue

  Ability to track or measure progress toward a goal or target

  Cost to track or measure progress toward a goal or target

  Links to environmental policy commitments of goals and targets

EFEC registration requires that each company provide written goals.  A sample goals worksheet and procedure is provided in Appendix C.

identifying the worker’s EFEC role and responsibility, and the importance of conforming to the EFEC program. Training should be directed toward the general nature of the work being performed by the employee.  For example, line workers (woodworking, finishing, assembly) would receive different training than office personnel.  Employee competence in the environmental aspects of their jobs is the goal of training.  

The first step in developing a training program is the assessment of training and skill needs.  Both general and specific aspects of workers’ jobs should be considered. Existing training programs and employee orientation can be modified or combined to stress the importance of EFEC. Training objectives and a plan for meeting those objectives should be developed, and training tools such as brochures, handouts, posters, web-based or computer training, videos, handbooks, signs, etc., should be used.  AHFA provides a video, brochure and posters to support this effort.  Training records and documentation must be maintained, and the trainer must be qualified, properly trained, and knowledgeable in the EFEC program. The training log must identify the employee, his/her function or department and the training date.  See Appendix C for an example.

Training opportunities include:

  When a new employee is hired or an employee is transferred to a new job or facility

  Job performance is unacceptable or an employee does not follow procedures correctly

  Procedures, processes, materials, or equipment are changed

  The company changes environmental objectives and/or targets

  New regulations or laws affect a process or activity

  Refresher training courses

Both top-down and bottom-up internal communication should be covered.  Workers should be encouraged to ask questions and offer suggestions. Workers that are performing work that has environmental impacts are an excellent source of information, issues and ideas.  An employee rewards and recognition program can be implemented to encourage employee motivation and commitment to the EFEC program.

A matrix detailing the structures and responsibilities within the facility's EFEC Program must be included in your facility's EFEC Manual. Also, the location of the EFEC Manual, and a defined procedure for access to the manual for review and updates must be documented in the EFEC Manual.

The AHFA offers a one-day Program Manager Workshop. This workshop provides the tools and insight to help EFEC Program Managers to successfully design and implement an EFEC Program. Though not required, this workshop is strongly recommended for all prospective EFEC Program Managers.

A company will be required to provide a description of their training program including types, workers covered, format, trainer qualification, frequency, record keeping, etc. that demonstrates their training program meets EFEC requirements to become EFEC registered.

An effective plan should not only address response, but also prevention. The plan should include provisions for: inspections, assessing the potential for accidents and emergencies; preventing incidents and any associated environmental aspects; plans and procedures for responding to incidents and emergencies; testing of the plan; training; and mitigating any impacts associated with an emergency.  A helpful tool in predicting where and when future incidents may occur is reviewing prior accident or incident reports.

Many environmental and health and safety regulatory programs require an emergency plan or procedures, so your facility may already have several emergency plans in place.  Since a typical plant will have one or more existing plans (i.e., spill prevention control and countermeasure plan (SPCC), stormwater pollution prevention plan (SWPPP), hazardous waste management plan, emergency contingency plan, etc.) these plans may be modified or combined to develop a comprehensive response plan. One tool that that combines multiple plans is an Integrated Contingency Plan (ICP). The various individual plans should be reviewed to ensure they are up to date and applicable.  These plans should also be living documents, updated whenever changes or an incident occurs.  Useful information that should be included in an incident preparedness plan includes:

  Plant drawings, site plans

  Bulk storage areas

  Material storage locations

  Site drainage

  Evacuation routes

  The location and description of personal protective equipment and spill response equipment

  Notification procedures and chain of command in emergency situations

  Names and phone numbers of local emergency response teams (fire department, police, etc.)

Once an effective incident preparedness plan is in place, it is important that everyone knows what to do in the event of an incident or accident.  Employees must know that plans exist, their location, and the person who controls the plans. Posting copies of critical contact names and phone numbers around the facility is an effective way to prepare for incidents and prevent them from getting worse.  Conducting mock drills can also reinforce training and provide feedback on the effectiveness of the incident preparedness plan.  Communication with local response officials, such as the fire department, police, local hospitals, etc. about potential emergencies is also important so that they can act quickly and correctly to assist in an emergency.  

EFEC registration requires each company to have the appropriate incident preparedness plans as well as certification by an EFEC auditor that the plan contains all of the necessary components required by EFEC. EFEC registered facilities must review all Incident Preparedness Plans annually at a minimum. A log showing the plan, original author, date, and latest revision date must be included in the EFEC Manual. EFEC facilities must also review all applicable regulations during this review process to ensure compliance. Each facility must also examine significant environmental aspects identified in the facility aspect analysis to ensure that adequate emergency response and preparedness for these aspects are in place. A list of typical plans is contained in Appendix C.

Both internal and external communication is a critical component of the EFEC program.  Communication of the EFEC program and its components will help the workforce understand the program and its importance, convey the company’s environmental policy (both internally and externally), define roles and responsibilities, and may aid in identifying system improvements.  Determining the audience is the first step in the communications program.  Once the audience has been determined, the message content and method of reaching the audience should be decided.  The message should be kept simple, clear, concise, and accurate and related to the EFEC program.  Appendix D contains more specific guidance on developing a communications plan.

EFEC registration requires auditor certification that the company has an adequate communication program or plan in place.

Partnerships between suppliers and your company should be formed with the goal of improving your environmental performance. Suppliers and contractors are very important and can help a company achieve their environmental goals.  For example, your finishing supplier can greatly affect your company’s environmental performance (i.e., a reformulation that reduces a company’s hazardous air pollutant emissions or VOC emissions).

Facilities should encourage their suppliers to be innovative and proactive on environmental issues. Ask them how they can help. Suppliers should be encouraged to provide easily accessible, user-friendly information that will help the facility meet its documentation and reporting requirements (e.g., emission estimates). Environmental data on processes and materials should be made available to enable the environmental assessment of the products and services provided by suppliers and contractors.

AHFA supplier awards will be created to encourage suppliers and contractors to consider the environmental aspects of their activities and products.

A policy statement or example projects and results must be provided to meet this EFEC requirement.  An example notification letter is contained in Appendix C.

Informing federal, state and local policy makers, regulators, and elected officials coincides with external communication.  AHFA wants to inform regulators that your facility has EFEC in place.

This element of EFEC requires the notification of your primary regulator that EFEC has been implemented. An example letter is contained in Appendix C.  Notification of your facility's EFEC program should be sent to any regulators you feel appropriate, including Federal, State and local agencies.

The goal of notification is to inform and educate the regulator.  The regulator will be invited to discuss EFEC and your specific program.  In addition, many states are offering benefits for companies with a formal EMS such as EFEC.  You should seek this information from your regulators.

Information and technology exchange helps distribute ideas throughout the furniture industry to enhance environmental efforts. This exchange will be facilitated by identifying companies or individuals as contacts concerning environmental issues or through companies actively supporting AHFA environmental activities by attending stakeholder or committee meetings.  EFEC registered companies agree to exchange non-confidential information related to environmental issues with fellow companies and work with AHFA in promoting the EFEC program.  An example notification letter is provided in Appendix C.

Measurement of progress is an integral component of EFEC.  A facility must continually determine how well EFEC is working, as well as monitor key environmental aspects, legal compliance, and progress toward goals and targets.  Monitoring allows a facility to gauge environmental performance, strive toward meeting their goals, analyze causes of problems, identify areas where corrective action is needed and improve performance and efficiency.  Regular and frequent environmental performance evaluations may also prevent environmental problems by identifying and correcting them before they occur.  Finally, this review must be shared with top management.

To effectively measure progress and performance, an organization needs to monitor key operational characteristics that have environmental impacts, their performance, and periodically evaluate EFEC compliance through internal EFEC audits. Important aspects of measurement include defining data needs and key characteristics to examine. This will be followed by a review meeting with top management. EFEC registered facilities must include a documented time frame and procedure for management review of the program in its EFEC Manual. This procedure for management review must include: top management's review of EFEC to ensure its suitability, adequacy, and effectiveness; management reviews will be documented; management reviews will address changes to policy, objectives and other elements of EFEC audit results, changing circumstances, and the commitment to continual improvement. EFEC registered facilities must include a documented time frame and procedure for management review of the program in its EFEC Manual. Meeting minutes must be kept on record to refer back to in the future. Example auditing methods and protocols are provided in Appendix C. An example agenda and meeting topics are also included in Appendix C. Measurement (auditing and management meetings) is required on an annual basis at a minimum. Results of an annual maintenance audit conducted by a certified EFEC auditor must be submitted to the AHFA to maintain registration. In addition, any facility in the EPA's Performance Track program must submit annual maintenance audit results to the EPA. In addition to the annual EFEC maintenance audits, an EFEC registered facility must evaluate its legal compliance annually. This compliance evaluation may be in the form of self-assessment or third party. To help satisfy this requirement, regulatory compliance reports from facility inspections conducted by the regulatory community may also be included in the EFEC Manual. However these assessments are conducted, EFEC requires registered facilities to document the assessment procedures in the EFEC Manual.

Problems and deficiencies may be discovered or might occur once EFEC has been implemented.  Furthermore, as a facility grows or changes, EFEC requirements may change. A facility can correct problems identified during internal auditing or monitoring. Once problems and deficiencies are identified, the organization must be committed to resolving them.  Deficiencies must be corrected as soon as possible.  EFEC requires that an action plan must be in place.  A corrective action plan should be in place that addresses the identification and investigation of problems and deficiencies and how corrective actions are implemented, tracked, and documented.  The corrective action plan must also establish an implementation schedule and specify responsibilities.  The corrective action plan must be proactive, striving to identify and correct deficiencies before they become problems.  Corrective Action procedures are contained in Appendix C.

In the event of Notice of Violations or other non-compliance issues that become public record, EFEC registered facilities agree to provide AHFA with a description of violation and corrective actions taken to address them and minimize the chance for a repeat violation.