Will Environmental Management Systems Replace TUR Planning
The following article has been
published in the February 2001 Massachusetts EnvironManagment Report.
Following a decade of toxic reduction
planning-and re-planning-under Massachusetts' Toxics Use Reduction Act
(TURA), stakeholders during the past year engaged in lengthy discussions
as to whether continued reductions of toxic chemical usage can be expected
under that law's current formulation.
Industry voiced concern that the
"low-hanging fruit" of toxics use reduction have been so fully harvested
that only the least technically- or economically-feasible TUR options
remain. Implementation of these options, they worry, will not result in a
repeat of the success realized during the program's early years.
Recognizing these concerns, the
Massachusetts Executive Office of Environmental Affairs' (EOEA's) has
proposed altering TURA so that, among other changes, companies could
implement an Environmental Management System (EMS) in place of their
current planning update requirements. A demonstration project, described
below, is underway to test the benefits of such an approach.
Advantages Of EMS Focus Over TUR
EOEA's proposed approach benefits
environmental quality as well as regulated companies' desire for
greater efficiencies.
While traditional TUR planning is limited
to reducing usage of listed chemicals, EMS's encourage improvement in all
areas of a company's operations that potentially impact the environment.
This would greatly expand potential progress in areas such as natural
resource utilization and energy use. EOEA also recognizes that a
well-designed EMS will help to ensure compliance and promote TUR within an
organization, which in turn will reduce negative impacts.
The shift of focus from toxics alone to
facility-wide system building also reflects the current realities of
corporate environmental management. There are now pressures for companies
to comply with environmental regulations and to develop, concurrently,
systems to satisfy the requests of their supply chain to have
environmental and quality systems in place.
A good EMS will not only satisfy customer
demand, but may also prove beneficial in streamlining the company's entire
environmental compliance effort, reducing overall costs. Moreover,
companies that implement an EMS will be inclined to develop proactive
methods for communicating with their employees and the public.
Pilot Project. To evaluate EMS
benefits, the Massachusetts Toxic Use Reduction Institute (TURI) recently
launched a demonstration project for companies agreeing to develop an EMS.
In return for funding that underwrites their costs of developing an EMS,
host companies agree to share their experience with other companies in
their sector who voluntarily participate in a TURI-organized workgroup. In
1999, for example, TURI funded an EMS development grant to
Photofabrication Engineering Inc. (PEI), of Milford Massachusetts. PEI
operates a photochemical machining facility, and has been involved with
Toxics Use Reduction Planning activities since the early 1990s. Ten other
companies, primarily from the metal finishing industrial sector,
volunteered for the workgroup.
As PEI developed its EMS, information
gained from its experience-including tools and procedures used, and
challenges faced-was shared with the workgroup. Meeting from late 1999 to
June 2000, workgroup members grew to freely share their EMS development
activities, offering valuable insight into the approaches taken in
specific areas. One of the participants, Allegro Microsystems, shared
their approach to creating a complex matrix that not only weighed the
environmental impacts of their operations but also took into account the
financial impact of the particular activity. Utilizing this matrix,
reductions in environmental impacts can be directly correlated to costs.
Problems and pitfalls were also discussed and ideas were shared on how to
overcome obstacles specific to the metal finishing industrial sector. TURI
has prepared a technical report, "Environmental Management Systems
Workgroup: Surface Finishing Sector," that summarizes the lessons learned.
This report can be obtained from the TURI office in Lowell, Massachusetts,
or from their Web site
http://www.turi.org.
TURI and the attending companies considered
this initial pilot a success. As a result, TURI is now funding two
additional EMS development and implementation workgroups focusing on
electronics and plastics/resins manufacturing industries in Massachusetts.
It was felt that these industries are representative of the types of
manufacturers who are often large users of toxic materials and who also
have other motivating factors to develop an EMS. Specifically, the three
largest U.S. automobile manufacturers, Ford, General Motors and Daimler
Chrysler, are all requiring that their suppliers conform to the ISO 14001
EMS model. Many plastics, resins and electronics manufacturers in
Massachusetts are direct suppliers to the automotive industry and
therefore have a vested interest in developing an EMS.
Recipients of the 2001 EMS Development
and Implementation grant are Nypro Corporation of Clinton,
representing the plastics/resins industry in Massachusetts, and M/A-COM of
Lowell, representing the electronics industries. Industry representatives
from the target sectors have volunteered to join in the working groups,
and are dedicated to working collaboratively and concurrently in
developing their own EMS's within the framework of the working group.
The support that TURI is providing to
assist the regulated community in developing EMS is indicative of their
commitment to bring about a positive change with respect to toxic chemical
usage for Massachusetts industries as well as the citizens of the
Commonwealth.
If you wish to participate in TURI's
workgroups, please contact Capaccio Environmental Engineering, Inc. at
(508) 970-0033.
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