Case Study
Scenario: GreenFab Inc. Develops an EMS
Company Background: GreenFab Inc. operates as a mid-sized metal fabrication and finishing business. It adopts an EMS to reduce pollution, ensure compliance, meet customer demands, and address community concerns. Below, GreenFab follows the EPA’s 27 steps for EMS development using the Plan-Do-Check-Act cycle, as outlined at EPA.gov.
Plan Phase Steps 1-12
- Explore the Context of the Organization
- GreenFab interviews local residents, identifying concerns about paint odors and air quality.
- Customers demand low-VOC parts, and competitors promote greener operations.
- Regulators notify GreenFab of stricter upcoming discharge rules for heavy metals.
- Secure Leadership Commitment
- The CEO issues a memo establishing the EMS as a corporate priority, allocating $100,000 over two years.
- Managers’ performance reviews include environmental target achievements.
- Establish an Environmental Policy
- GreenFab creates a policy: “GreenFab Inc. commits to pollution prevention, continual improvement, compliance with laws, and employee and stakeholder involvement.”
- The policy appears in English and Spanish, posted in departments, included in onboarding, and displayed on the company website.
- Roles and Responsibilities
- GreenFab appoints an EMS Manager from the environmental engineering team.
- Team members are selected from production, maintenance, health and safety, quality, procurement, and operations.
- The EMS Manager reports quarterly to leadership; production tracks solvent use; maintenance inspects equipment monthly; quality samples discharge water weekly.
- Hold Kick-Off Meeting
- The EMS team presents a slide presentation to department heads, explaining EMS benefits and roles.
- Departments contribute ideas, such as improved ventilation hoods (painting) and leak detection sensors (maintenance).
- Determine Environmental Aspects and Impacts
- The team reviews operations: cutting, grinding, plating, rinsing, painting, and polishing.
- They identify aspects: VOC emissions, heavy metal discharges, waste (sludge, scrap), energy use, chemical use, and noise.
- Significant impacts include painting booth VOCs and plating rinse water heavy metals, based on regulatory thresholds.
- Identify Compliance Obligations
- GreenFab compiles regulations: Clean Air Act (VOCs), NPDES (wastewater), RCRA (hazardous waste), OSHA chemical rules, and local odor ordinances.
- Voluntary commitments include customer “zero discharge” requirements and ISO 14001 alignment.
- Prepare Budget and Secure Resources
- GreenFab budgets $20,000 for VOC sensors, $30,000 for training, $40,000 for retrofits, and annual audit costs.
- Leadership approves the budget and allocates 10% of maintenance and operations staff time for EMS tasks.
- Set Environmental Objectives and Action Plan
- Objective: Reduce VOC emissions by 25% in 18 months. Targets: Retrofit three painting booths by month 12, cut solvent use by 15% by month 18.
- Objective: Reduce wastewater heavy metals by 30% in two years. Targets: Install rinse tank treatment by month 15, monitor monthly.
- Action plans assign roles, milestones, and resources.
- Identify Operational Controls, and Monitoring and Measurement Needs
- Controls include closed-loop solvent recovery, sealed paint booths, automatic shutoff valves, and chemical handling SOPs.
- Monitoring involves VOC sensors, weekly solvent tracking, monthly wastewater testing, and quarterly energy reviews.
- Define Roles and Responsibilities for Specific Environmental Tasks
- Maintenance oversees leak detection; production tracks solvent use; lab manages wastewater sampling; safety handles spill monitoring.
- Backup roles ensure continuity during absences.
- Establish Other System-Level Procedures
- Document control assigns revision numbers, restricts edits, and archives old versions.
- Records (measurements, audits) are stored for five years; communication includes bulletin boards, emails, and external reports.