Instituting a quality management involvement program - part II

• By Sandra Bienkowski
• Jun 01, 2000

This is the second in a two-part series of articles. Part I, which appeared in our May 2000 issue, explored the financial reasons companies should move toward making proper hazardous waste handling and reduction part of their corporate culture. Part II examines ways to institute a program for achieving this goal.

Inspections are a vital component of an effective regulatory system — as well as a Quality Management Involvement™ (QMI) program, which is a company-initiated program designed to improve specific processes such as hazardous waste management. Even the U.S. Environmental Protection Agency (EPA) recognizes that some companies with good facility management practices might be able to inspect less frequently without sacrificing human health and environmental protection. Imagine if everyone connected with the process — from the president of the company down to the employees on the factory floor — embraced the same high-quality inspection habits?

Currently, EPA is evaluating whether to revise the Resource Conservation and Recovery Act's (RCRA) inspection requirements by lengthening the time between inspections. EPA believes that some facilities might have controls in place that could allow them to reduce the frequency of inspections (something that could possibly be established on a case-by-case basis). These special inspection schedules could be worked out during facility permitting, or EPA might put a special variance in the regulations under which less frequent inspections would be allowed.

How QMI works

The goals of a QMI program includes helping employees understand how the concept of environmental caring is related to their profitability; helping them consider how this concept may impact their work in positive ways and helping them integrate ideas into their work day habits.

A QMI program is a compliant and cost-effective way to help companies manage all types of regulated waste from within. The program's scope is to:

• Assess your facility's waste management needs;

• Identify necessary policies, programs, services, capabilities;

• Develop and gain approval of the required strategies, plans and budgets to ensure that the necessary programs, services, capabilities and facilities are available to support your company's missions and follow government regulations; and

• To contract with other organizations to initiate these programs, services, capabilities and facilities.

QMI programs are different than Total Quality Management (TQM) efforts in that what the program aims at improving is different. TQM aims at improving the overall quality of a company through instituting behavioral and cultural changes. QMI aims at improving a specific process of a company (i.e., handling hazardous waste) through behavioral and cultural changes. Quality is a much broader issue than any single process. Another way to look at the difference is to realize that you can have many QMI programs going on without having a TQM program in place. However, it is rare to see TQM programs being pursued without QMI programs.

QMI start-up tips

No single off-the-shelf QMI program works for all companies. No two companies are exactly alike, and each has its own traditions and commitments that set it apart from other institutions. Each must, therefore, find its own "niche" in terms of instituting a QMI program and customize it according to company needs. Here are three ideas to help.

Start your thinking upstream, as close to the hazardous waste as possible. Figure 1. contains a list of some of the most commonly used solvents, spent solvents and solvent mixtures used in a variety of ways throughout various industries. There are also ignitable wastes for other hazardous solvents and 40 Code of Federal Regulations 261.31 lists the majority of hazardous waste solvents. QMI involves tracking these chemicals from the moment they enter the facility to the time they must be properly disposed of; this monitoring should be done by everyone — not just the people handling the chemicals.

An understanding of how proper handling relates to the company's profitability and how proper handling impacts all employee work should be made through workshops, or brought up as items in department meetings. Some QMI tactics for attaining involvement are educational programs that show individuals what these chemicals are designed to do, how they work and why they must be handled properly. In addition, people must be made aware of and able to detect when abnormal conditions around the chemicals exist that could trigger the need for immediate action. These conditions can be anything from the supply not showing up, to the inspection of the material on an ongoing basis.

Another idea to help institute a QMI program is to establish controls of the process in relation to the incidents of waste generation. For example, in the construction industry, paint preparation, painting, carpentry and floor work all produce ignitable wastes, toxic wastes, solvent wastes, paint wastes, used oil and more. QMI programs strive to make every individual aware of these wastes as a necessary by-product of the work and that proper care should be exercised when handling them. Likewise, in a vehicle maintenance-type business, degreasing, rust removal, paint preparation, spray booth filters, spray gun usage, brush cleaning, paint removal, tank cleanout and installing lead-acid batteries all contributes to waste generation. In both cases, QMI programs necessitate informing everyone in the company of the waste's potential. The potential is what might happen if the waste is mishandled or if an accident occurs.

Target thinking. QMI programs attempt to keep things simple, with the focus on reducing waste. Industries can reduce the amount of waste they produce in many ways.

Manufacturing process changes. Either eliminate a process that produces a hazardous waste or change the process so that it produces little or no hazardous waste.

Source separation. Prevent hazardous waste from coming into contact with non-hazardous waste.

Recycling. Remove a substance from a waste and return it to productive use.

Substitution of raw materials. Replace raw materials that generate a large amount of hazardous waste with those that generate little or no waste.

Product substitution. Find non-hazardous substitutes for materials and products used routinely in businesses.

QMI programs bring people together to solve waste generation problems. Through dialogue, ideas emerge and are implemented.

Conclusion

Your QMI program should provide overall fiscal and technical management of the waste management program including the minimization and pollution prevention functions. The goal is to stay focused on providing necessary environmental services program, increasing cost effectiveness, decreasing waste generation and aggressively reducing wastes because you want to. Wanting to has a positive effect on your company's profits — and on the safety of your employees.

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Figure 1

Benzene	F005
Carbon disulfide	F005
Carbon tetrachloide	F001
Chlorbenzene	F002
Cresols	F004
Cresylic acid	F004
O-dichlorobenzene	F002
Ethanol	D001
20ethoxyethanol	F005
Ethylene dichloride	d001
Isobutanol	F005
Isopropanol	D001
Kerosene	D001
Methyl Ethyl Ketone	F005
Methylene Chloride	F001, F002
Naptha	D001
Nitrobenzene	F004
2-Nitrobenzene	F004
Petroleum solvents (flashpoint less than 140 degrees F.)	D001
Pyridine	F005
1,1,1,-Trichloroethane	F001, F002
1,1,2-Trichloroethane	F002
Tetrachloroethylene (perchloroethylene)	F001, F002
Toluene	F005
Trichloroethylene	F001, F002
Trichlorofluoromethane	F002
Trichlorotrifluoroethane (vlaclene)	F002
White spirits	D001

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This article appeared in Environmental Protection magazine June 2000, Vol. 11, No. 6, p. 83.

This article originally appeared in the 06/01/2000 issue of Environmental Protection.