Eight steps to environmental compliance.

An ISO 14000-certified foundry shares its proactive management plan.

Every foundry wants to ensure its stability for the future. As an industry, foundries are heavily regulated by the U.S. Environmental Protection Agency (EPA) and individual state agencies. An essential factor in providing for a secure future is taking proactive actions to keep your facility in compliance with all regulations.

Once compliance is achieved, the environmental manager needs to write and implement a comprehensive environmental management plan. This can be difficult because there aren't many guidelines to assist an environmental manager in writing such a plan. Plus, the task can be very time consuming.

If written properly, however, an environmental management plan can provide goals that will keep your organization ahead of future regulatory action and acting in a proactive rather than a reactive fashion. This article describes what goes into developing a proactive environmental management plan for foundries.

Such a plan can be created following a simple process and can be completed between 6-12 months, depending on the complexity of the facility. When finished, a good plan will probably be 7-10 pages for a mid-sized foundry, depending on the number of environmental factors it encompasses and the detail involved in the pollution prevention plans. We saved 40% in waste costs the first year our plan was implemented and reduced our waste costs by 70% during the next three years.

Perform an Environmental Audit

The most important step in the pollution planning process is auditing your facility. Before completing an audit, research all regulations using your local regulatory agency or local municipality. Find out what regulations apply to your facility to determine what planning materials you will need. Start by asking your local regulatory agency for a summary sheet to use in auditing your environmental program. State environmental agencies are more cooperative when you take a proactive rather than a reactive approach. Many agencies will offer to do a walk-through of your facility and offer suggestions to help. Record your findings from the audit and use them as a benchmark to refer back and gauge the results. A good source for an environmental compliance guide is available from the Pennsylvania Dept. of Environmental Protection's Office of Pollution Prevention and Compliance Assistance. It has published An Environmental Self-Evaluation for Small Business (publication 0200-BK-DEP2029), which is available by calling 717/657-4588 or by visiting its website at http://www.dep.state.pa.us.

1 Define Your Future

It is important to define where you want to be in the future. Do you want to maintain compliance or exceed regulations? Determine how important an environmental program is to your company. Is your company committed to achieving ISO 14000 compliance? If your facility exports to Canada or Europe, or provides castings to major automobile manufacturers, ISO 14000 may be more important than you originally thought. Developing an environmental policy statement can assist in defining where you want to go. A good example of an environmental policy will clearly state what the environmental management system (EMS) means to your company. Once an environmental policy is developed, it will assist in goal development and environmental planning.

2 Investigate Your Past and Fix It

After your audit, look into your past non-compliance issues and remedy them. Record what you did to fix the problem, and ensure the situation cannot occur again. Realize that your facility has been out of compliance, and try not to hide the situations that lead to the non-compliance. Take the time to understand how the non-compliance situations occurred. Also, focus on staying in compliance by educating employees and management on how the non-compliance situation occurred.

3 Investigate & Implement Waste Source Reduction

Through examining a schematic drawing of your plant, indicate what areas possess the potential for releasing pollution. Indicate all vents, water drains, sewer lines, solid waste holding areas, stormwater collection areas and door openings. Determine what potential pollutants may be present or may exit from each area. Then, ask yourself, what can be done to prevent the collection or escape of pollutants? Is there a ventilation system that can be installed to collect vapors, fumes or particulate dusts? Is the solid-waste storage area protected from rainwater runoff?

Consider any neighbors and go door-to-door to ask them what odors, noises or dust they would like to see your facility better control. Showing your neighbors that your company is starting a good-faith effort to control pollution is important to break the "community vs. industry" barrier that may exist. Use your state agencies to provide additional information and suggestions.

4 Investigate & Implement Waste Source Reduction

Flowchart every process in your facility and document what raw materials you use in the process. Document the volume of raw materials and the cost per piece of the raw material. Using the same flowchart, document the waste generated from the process, along with the volume and cost per piece. The flowcharting and documentation process you are completing is the initial step in environmental cost accounting.

Using the completed process flow-charts, you should have data that will allow you to rank the processes in order of cost or volume of waste generated. Using this data, you can determine where to focus efforts on waste source reduction. Rank the processes based on the amount of waste generated and cost of waste generated. The two rankings may differ. Focus on the areas that will provide you the greatest savings in either volume or cost. Once you have determined where you want to save money or reduce the volume of waste generated, modify the process identified. Look to use alternative raw materials, cheaper raw materials or raw materials that generate less waste. Some examples may include using different sand grades, binders, chemicals, or a complete substitution of different raw materials, which may be reused or recycled. In some cases, the switching of raw materials may yield different process results.

It is important to weigh the options of achieving a different process result (lower yield, quality changes) against the cost of waste disposal and/or raw material costs. Additional options include researching and refining the process to generate less waste, or using a different process. Contacting your state regulatory agency for assistance will offer opportunities to use their experts to help you in researching your process and modifying it using current technologies and innovative techniques. The flowcharts with costs of raw materials and waste generated (the basis of environmental cost accounting) will assist you in presenting the changes to management showing actual projected savings.

5 Incorporate Waste Reuse and Recycling 

Reusing sand and scrap metal is a viable opportunity for foundries to initiate a recycling project. Offer employees the opportunity to collect soft drink cans, newspapers or office paper and sell the material for their own profit (make sure you separate or shred any confidential information). Find a local recycling facility that will pay for recyclable materials. If starting a recycling project within the company, make enough drop-off points available so that it is easy for your employees. Setup your facility as a drop-off center for newspapers and work with local non-profit organizations (such as the Boy Scouts), that can collect materials and sell them to raise money for their programs.

If you can prove your waste is as good as a raw material, you may be able sell it for profit. Many foundries can sell their sand as alternative raw materials for concrete, road surface material, landfill daily cover and other similar processes. Contact your state transportation department, local landfill and local businesses to see if they would be interested. Also, contact your state regulating agency and see what permits already exist and if you can add your waste on the existing permits. Incorporating recycling methods is often cheaper than paying for disposal.

6 Work With Your Suppliers

Work with your raw material suppliers to provide you with returnable packaging. Attempt to use recycled materials as part of your raw materials. If you use solvents, purchase recycled solvents instead of new solvents. If you package your products, use recycled boxes and papers to pack your materials. Use newspapers instead of new, bleached paper. List all of your raw materials and call each manufacturer to ask what products are available as a recycled item.

Whenever changing raw materials, be sure to perform complete tests to ensure they can pass your specifications. Many recycled materials are equal to their non-recycled counterparts. Wilton Armetale has been able to work with suppliers of raw materials to get steel drums, plastic drums, wooden pallets and steel cages returned during product delivery. Fiber drums were given away to local businesses. Many sand distributors ship their sand in a steel or plastic cage. Instead of disposing of the cages, ask your supplier to pick them up whenever they deliver new sand.

7 Become Involved in Your Community

Your community means more than your immediate neighbors. It involves non-profit groups, regulatory agencies, local officials, customers and suppliers. Offer each group a chance to learn about your business, and become more knowledgeable about the foundry industry. If people remain unsure about what we do behind our factory walls, the "dirty industry" sticker will remain. Many people think of two things when discussing foundries - dirt and pollution. Make an effort to educate everyone that the first two things they think of should be reusable sand and pollution prevention.

Educate your state agency by offering tours of your facility on a non-technical basis. Regulatory agencies cannot turn away if they see a blatant violation, but explain to them beforehand that you want to take a more proactive effort and develop a partnership with them. Many agencies would welcome the idea to come for a tour and learn about a specific industry. By educating your regulatory agency, you will develop a relationship you will be forever thankful you started.

8 Seek Recognition

After you complete all the hard work developing an environmental plan, document the amount of waste and the costs saved, then look back at your benchmarked environmental audit. Take the opportunity to receive recognition from your state political officials. state regulatory agencies and trade associations. Apply for awards in your state. Many state awards are looking for companies to submit success stories. Keep your employees involved the entire time, and make sure they are excited about your changes.

If you are very successful with spreading the good news, you may even get calls from other local businesses stating that your efforts are making them "look bad." Just remember - you may be making them "look bad," but you are also developing solid plans and building long-term relationships that will preserve your stability into the future.

RELATED ARTICLE: THE ROAD TO CERTIFICATION

In some respects, Wilton Armetale, an aluminum green sand foundry, has been environmentally conscious since it was founded in 1892. However, it wasn't until 1994 that the company began to develop a solid environmental management plan. The effort made it easier for the foundry to register for ISO 14000 certification.

"We realized what we were doing in our plan was almost the same sort of thing we needed to do to be ISO 14000 certified," Schell said.

Wilton Armetale became the first ISO 14000-certified foundry in North America this past July. These efforts were recognized when Wilton Armetale won the 1996 Pennsylvania Governor's Award for Environmental Excellence.

Wilton Armetale saved 40% in waste costs the first year its plan was implemented. During the next three years, self-audits concluded that the company reduced its waste costs by more than 70%, Schell said.

"We want to ensure that our environmental record is accurate, complete and in compliance," Schell said. "Using environmental consulting firms to assist our internal staff when necessary, we self-audit our internal processes and develop new processes to ensure our environmental excellence. Also, we will keep the public informed on our status through informational meetings when necessary."

Projecting the right image is very important to Wilton Armetale. After working closely with the Pennsylvania Dept. of Environmental Protection in developing its environmental management plan, both parties decided to sponsor a website (http://www.dep.state.pa.us.) that describes the foundry's pollution prevention efforts. Included in the site is a virtual tour of the plant. It is the first time the DEP has partnered with a foundry in such a way.

- Marc Morency, assistant editor