Cal/EPA Environmental Management System Project
Report to the Legislature: Sixth Quarterly Update
January through March 2001

Table of Contents

• Executive Summary
• Report to the Legislature: Sixth Quarterly Update
• Introduction
• Major Accomplishments
• Southern California Working Group Meeting and Tour at Lockheed Martin Aeronautics Company in Palmdale
• LM Aero Company Policy
• Upcoming Activities

Executive Summary

The purpose of this report is to update members of the Legislature on the Cal/EPA Environmental Management System (EMS) Project authorized by Assembly Bill 1102 (Stats. 1999, Ch. 65 ), codified in Public Resources Code, Section 71045 et seq.. This sixth quarterly report includes information on

• the progress and accomplishments at Lockheed Martin Aeronautics Company in Palmdale,
• presentation of recognition certificates by Cal/EPA to pilot project representatives,
• circulation of the California Supplemental Data Protocol, designed to answer questions posed by Public Resources Code (PRC), Section 71045 et seq., to the Regional Working Groups for review,
• circulation of the individual pilot project work plans to the Regional Working Groups for review, and
• upcoming activities.

Cal/EPA reports quarterly on progress to the Legislature and will provide a final analysis of results by January 1, 2002. Previous updates to the Legislature and additional information on the project may be obtained from the web site (http://www.calepa.ca.gov/EMS).

A new phase of the California EMS Project is underway. Regional Working Group meetings are being organized to facilitate a dialogue between pilot project participants and stakeholders regarding facility EMS design and implementation. Pilot facilities are sharing information on EMS implementation, providing a facility tour, answering questions, and receiving feedback. More than thirty representatives from government agencies, other pilot companies and interested businesses, academia and public interest groups were in attendance at the January meeting of the Southern California Regional Working Group. A brief summary of the information presented by the pilot organization is included in the report.

On January 18, 2001, the Southern California Working Group met at Lockheed Martin Aeronautics Company in Palmdale (LM Aero-Palmdale). The tour included the Joint Strike Fighter assembly area, a chemical control crib, and a site tour of Plant 10. Major accomplishments derived from LM Aero-Palmdale’s EMS include significant improvements in environmental regulatory compliance, pollution prevention, reduction of hazardous waste, and safety and health improvements:

• Since 1993, one notice of violation and four non-compliance events have occurred. No violations have occurred since 1998.
• While between four and five hundred hazardous materials were used to support predecessor aircraft, the Joint Strike Fighter concept demonstrator aircraft uses fifty-four hazardous materials.
• Between 1992 and 2000, hazardous waste was reduced ninety percent.
• Since 1990, volatile organic compounds have been reduced eighty percent.
• The usage of toxic chemicals reported under the Superfund Amendment and Reauthorization Act Toxic Release Inventory has decreased ninety percent since 1991. LM Aero-Palmdale has been below the reporting threshold since 1996.
• Safety and health problems, indicated by “Days Away Case Rate,” have been reduced by sixty-six percent, since 1995. LM Aero-Palmdale is seventy-five percent below the industry average for Days Away Case Rate.

Upcoming activities of the Cal/EPA EMS Project include

• continuing to facilitate regional EMS working group meetings at pilot project locations to learn about and comment on individual pilot project EMS development and implementation,
• data collection using the California Supplemental Data Protocol, designed to answer questions posed in PRC § 71045 et seq., after addressing any working group comments.

Report to the Legislature: Sixth Quarterly Update
January through March 2001

The purpose of this report is to update members of the Legislature on the Cal/EPA Environmental Management System (EMS) Project authorized by Assembly Bill 1102 (Stats. 1999, Ch. 65), codified in Public Resources Code, Section 71045 et seq. This sixth quarterly report includes information on

• the progress and accomplishments at Lockheed Martin Aeronautics Company in Palmdale,
• presentation of recognition certificates by Cal/EPA to pilot project representatives,
• circulation of the California Supplemental Data Protocol, designed to answer questions posed by Public Resources Code (PRC), Section 71045 et seq., to the Regional Working Groups for review,
• circulation of the individual pilot project work plans to the Regional Working Groups for review, and
• upcoming activities.

Cal/EPA reports quarterly on progress to the Legislature and will provide a final analysis of results by January 1, 2002. Previous updates to the Legislature and additional information on the project may be obtained from the web site (http://www.calepa.ca.gov/EMS).

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Introduction

During the previous phase of the EMS Project, public hearings were held in Northern and Southern California in fulfillment of the legislative requirement for a public hearing prior to selection of the pilot projects. Receiving one procedural comment, Cal/EPA announced selection of the pilot projects as proposed and adopted the pilot selection criteria, model pilot project work plan, and monitoring and evaluation parameters.

The following seven pilot projects are participating in the EMS Project:

1. Anheuser-Busch in Fairfield,
2. Wastewater treatment facilities (Central Marin Sanitation Agency in San Rafael and City of San Diego Metropolitan Wastewater Department, Operation and Maintenance Division),
3. IBM Corporation in San Jose,
4. Lockheed Martin Aeronautics Company (formerly the Skunk Works) in Palmdale,
5. Pentel of America, Ltd. in Torrance, and
6. Vineyards and wineries (Davis Bynum Winery and Benziger Family Winery in Sonoma County), and
7. Artistic Plating in Anaheim.

A new phase of the California EMS Project is well underway. Regional Working Group meetings are being organized to facilitate a dialogue between pilot project participants and stakeholders regarding facility EMS design and implementation. Pilot facilities are sharing information on EMS implementation, providing a facility tour, answering questions, and receiving feedback.

Representatives from government agencies, other pilot companies and interested businesses, academia and public interest groups have participated in Regional Working Group meetings at Artistic Plating and IBM in September 2000 and Benziger Family Winery in November 2000. A brief summary of the information presented at Artistic Plating and IBM is included in the Fourth Quarterly Update. Summary information presented at Benziger is included in the Fifth Quarterly Update.

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Major Accomplishments

Major accomplishments this quarter include

• facilitating a regional EMS working group meeting to learn about and comment on individual pilot project EMS development and implementation,
• presentation of recognition certificates by Cal/EPA to pilot project representatives,
• circulating the California Supplemental Data Protocol, designed to answer questions posed by PRC § 71045 et seq., to the Regional Working Groups for review, and
• circulating the individual pilot project work plans to the Regional Working Groups for review.

Regional Working Group Meeting

On January 18, 2001, the Southern California Working Group met at Lockheed Martin Aeronautics Company in Palmdale (LM Aero-Palmdale). More than thirty representatives from government agencies, other pilot companies and interested businesses, academia and public interest groups were in attendance. A brief summary of the information presented by the pilot organization is included in this report.

The tour included the Joint Strike Fighter assembly area, a chemical control crib, and a site tour of Plant 10. Major accomplishments derived from LM Aero-Palmdale’s EMS include significant improvements in environmental regulatory compliance, pollution prevention, reduction of hazardous waste, and safety and health improvements:

• Since 1993, one notice of violation and four non-compliance events have occurred. No violations have occurred since 1998.
• While between four and five hundred hazardous materials were used to support predecessor aircraft, the Joint Strike Fighter concept demonstrator aircraft uses fifty-four hazardous materials.
• Between 1992 and 2000, hazardous waste was reduced ninety percent.
• Since 1990, volatile organic compounds have been reduced eighty percent.
• The usage of toxic chemicals reported under the Superfund Amendment and Reauthorization Act Toxic Release Inventory has decreased ninety percent since 1991. LM Aero-Palmdale has been below the reporting threshold since 1996.
• Safety and health problems, indicated by “Days Away Case Rate,” have been reduced by sixty-six percent, since 1995. LM Aero-Palmdale is seventy-five percent below the industry average for Days Away Case Rate.

Cal/EPA Recognition of Pilot Projects

Certificates of recognition, signed by Secretary Winston Hickox, were presented by Cal/EPA to pilot project representatives. The certificates read

Cal/EPA recognizes and appreciates your pioneering efforts to establish an EMS as well as your willingness, as a Pilot Project, to share information on the design and operational performance of your EMS with our Northern (or Southern) California Working Group.

Data Collection Protocols

In coordination with other states, detailed national data protocols have been developed to collect standardized information on EMS design and performance. The national data protocols are available for review through a web site link at http://www.mswg.org. Baseline and update data on EMS design and performance has been collected for the Cal/EPA EMS Pilot Projects, using the national EMS data protocols.

In order to answer the questions provided in PRC § 71045 et seq., Cal/EPA is supplementing the national data protocols with a few additional questions. This quarter, the California Supplemental Data Protocol is being circulated to the Regional Working Groups for review. One pilot project will test the protocol for final modifications.

Using these combined protocols, also referred to as the Evaluation and Monitoring Parameters, pilot projects are submitting information in the following categories:

• environmental performance,
• regulatory compliance,
• use of pollution prevention techniques,
• continual improvement,
• employee involvement,
• involvement of interested parties,
• quality and quantity of information available to the public,
• EMS design, and
• EMS costs and benefits.

Pilot Project Work Plans

The Pilot Project Work Plans have been completed and are being provided to the Regional Working Groups for review and comment before being finalized. The purpose of the individual Pilot Project Work Plans is to describe how the work of each of the pilot projects will be carried out and how the goals of the California EMS project will be accomplished. This includes describing the pilot project management; data collection and management; data quality assessment, validation, and usability; and data analysis process. The Model Pilot Project Work Plan, finalized after Regional Working Group input and public hearings last year, served as the template for the individual pilot project work plans.

Information presented by one of the California pilot facilities, Lockheed Martin Aeronautics Company in Palmdale, is summarized in the following section. This information was presented by the pilot project as background for establishing dialogue with stakeholders during the Southern California Regional EMS Working Group meeting in January 2001.

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Southern California Working Group Meeting and Tour at Lockheed Martin Aeronautics Company in Palmdale

The facility visits allow the Working Groups to understand the EMS implementation at each pilot and help fulfill their role as participants in the Cal/EPA EMS Project. This role includes advising the pilot projects in the development, design, and implementation of their EMS and assisting Cal/EPA in answering the questions posed in PRC § 71045 et seq.

On January 18, 2001, the Southern California Working Group met at Lockheed Martin Aeronautics Company in Palmdale (LM Aero-Palmdale). The tour included the Joint Strike Fighter assembly area, a chemical control crib, a site tour of the LM Aero-Palmdale plant (Plant 10), and a presentation of their EMS. The meeting highlighted the role of their EMS in integrating the various business processes and systems at LM Aero into a comprehensive program that strives to improve environmental performance, worker safety, and economic efficiency. This report is based on the presentation given by Michael Haro, Environmental Resources Manager, LM Aero-Palmdale, and closely tracks the required elements of an ISO 14001 EMS.

Background

LM Aero-Palmdale, formerly known as Lockheed Martin Skunk Works, is the “front end” of the new Lockheed Martin Aeronautics Company (LM Aero) headquartered in Fort Worth, Texas. LM Aero was established in March 2000 when the Skunk Works joined with Lockheed Martin aircraft manufacturing facilities in Forth Worth, Texas and Marietta, Georgia. LM Aero-Palmdale specializes in the rapid development of advanced aerospace prototypes, technology, and systems. LM Aero-Palmdale was originally formed in the 1940s to design and develop the P-80 Shooting Star, America’s first production jet fighter. Their work continued with the development of the U-2, SR-71 Blackbird, and Low-Observable Technology aircraft like the F-117A Stealth Fighter, F-22 Advanced Tactical Fighter, and now the Joint Strike Fighter. Approximately four thousand employees work at the Palmdale, California facility.

Environmental Management System

The environmental management system operated by LM Aero-Palmdale has been in place since 1992. Their system combines occupational health aspects with environmental compliance and pollution prevention and is referred to as the Environmental, Safety and Health Management System (ESH-MS). After several years of refining their EMS, LM Aero-Palmdale self-declared conformance to the ISO 14001 Standard in 1998. However, their EMS is in transition as each of the three LM Aero facilities harmonizes their facility-level EMS into a single EMS for the entire company. Fort Worth has been third-party ISO 14001 certified and Palmdale may pursue third-party certification to the ISO 14001 standard as well. The transition to a new EMS has resulted in the need to create a new environmental policy statement, reevaluate aspects and impacts, set new objectives and targets, and develop new EMS procedures. The new elements of their EMS reflect the continuous improvement process that is integral to a highly functioning EMS.

Environmental Policy

Creating a single EMS for LM Aero began with the development of a new company policy on environment, safety, and health. Signed by Dain Hancock, President of LM Aero, the company policy establishes the environmental commitment of the organization and specifies roles and responsibilities. The policy also emphasizes the company’s will to integrate environmental safety and health into business decisions. The policy is presented below to illustrate the foundation of their environmental safety and health programs that will be discussed later in this report.

LM Aero Company Policy

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Environment, Safety and Health (ESH)

Purpose
To document company policy regarding safe and healthy working conditions, protecting the environment and conserving natural resources.

Policy
Responsibility for ESH is everybody’s business!

Lockheed Martin Aeronautics Company protects employees, customers, contractors, communities, visitors, and the environment from the hazards of Company activities, products or services. We:

• Prevent pollution, conserve resources, reduce waste, and recover or recycle resources where economically feasible.
• Maintain a safe and healthy workplace to prevent injuries and illnesses.
• Comply with applicable laws and regulations, and satisfy corporate and customer requirements.
• Minimize significant adverse ESH impacts by integrating ESH management practices into business decisions.
• Integrate ESH management practices into design processes to minimize adverse ESH impacts throughout production, use, and disposal of products.
• Integrate ESH management practices into procurement and property renovation, rearrangement, acquisition, consolidation and divestiture.
• Develop ESH performance objectives and targets to ensure continual improvement of the Environment, Safety and Health Management System (ESHMS) and reduce adverse ESH impacts.
• Respond to employee, community, customer, and regulatory agency concerns regarding potential adverse EHS impacts due to LM Aero activities, products or services.
• Establish pro-active partnerships with regulatory agencies, customers, and suppliers to improve ESH performance and compliance cost effectiveness.
• Provide people, specialized skills, technology, training, and budget to maintain an integrated ESHMS.
• Maintain ESH requirement awareness throughout the workforce and execute tasks using safe, healthy, and environmentally sound work practices.

Company Roles and Responsibilities

1. Senior Management establishes ESH objectives and reviews Company ESH performance.
2. People & Organization Services develops and administers the ESHMS.
3. Function and staff organizations define processes to communicate and implement ESH policy.
4. Programs use the defined ESH processes.

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Aspects and Impacts

LM Aero-Palmdale is in the process of reevaluating the significance of their environmental aspects and impacts. The new process evaluates aspects in terms of environmental safety and health impacts as well as business impact. The probability and consequence of the ESH impact is ranked low, medium, or high. Business impacts are evaluated in terms of compliance, costs and stakeholder interest/concern and are also ranked low, medium, or high. The two scores are combined on a risk/significance matrix which provides a significance level. Impacts ranked at level 1 have the highest risk/significance while level 5 are the lowest risk/significance.

Legal and Other Requirements

By utilizing a corporate ESH web site, LM Aero-Palmdale employees are able to keep up with legal and other requirements. Updated weekly, the web site includes regulatory information, guidance modules, best practices, training documents, energy savings information, and industry standards. The web site receives over 1600 hits per day.

LM Aero-Palmdale staff also maintain a Master Reports List that identifies all environmental reports, the agency involved, responsibility for the report and the due date. This allows easy tracking of all environmental reporting requirements.

Objectives and Targets

One of the processes for continual improvement of an EMS is the setting of and measuring progress towards objectives and targets. Objectives and targets may be performance driven, such as a reduction in waste production, or they may be systems improvements like developing new procedures. Both types of objectives and targets are found in LM Aero-Palmdale’s EMS.

LM Aero has an overall long-term goal of zero discharge and is working towards that goal through short-term objectives. One of the significant objectives for 2001 includes a 10 to 15 percent (27 - 31 tons) reduction in waste disposal over last year. This objective is implemented through the Chemical Control Board (CCB). Established in 1994 to control the purchase of hazardous chemicals, the CCB evolved to include specific pollution prevention (P2) objectives and projects. The CCB is made up of staff from ESH and from other LM Aero-Palmdale organizations including manufacturing and engineering. The CCB meets quarterly to monitor progress of the projects and each year presents an award to the project with the best performance.

The company objective to achieve 100 percent compliance on regulatory reviews was met for the year 2000 and is again a stated objective for 2001. Reducing the number of lost workdays due to work-related injuries is another EMS objective. Lost workdays are expressed as a Days Away Case Rate (DACR) and their objective is to achieve a 0.68 - 0.72 DACR per 200,000 person hours worked. The year 2000 DACR is 0.80. This represents a 66 percent reduction from the 1995 DACR of 2.33.

Program or system improvement objectives include completing the Cal/EPA EMS Pilot Project, revising ESH procedures, continuing the Stakeholder Roundtable (annual meetings with local and State government representatives and non-governmental organizations), and participation in the U.S. EPA Merit Partnership. LM Aero-Palmdale is also considering new objectives that involve the 6S housekeeping program (described in the section on operational controls), water quality monitoring, energy conservation, and developing new training videos.

Training and Communication

One of the most important processes for successful EMS implementation is training and communication. This importance is illustrated by comments made by Robert Elrod, LM Aero Vice President when he said, “Communication is the foundation of progress…. Training and discipline make systems work, not software and procedures.” The training and communication element of LM Aero’s EMS includes both internal communication to employees as well as external communication and involvement with stakeholders.

A series of classes called “ESH Training Topics” lie at the foundation of LM Aero-Palmdale’s training program. Through these classes each employee, from the shop floor to management, is educated about the ESH issues that are important to their job. Classes identify the importance of issues, procedures to be followed, and roles and responsibilities of each employee. Competency in the subject is measured through testing. Mandatory training topics like hazardous waste management and response to chemical spills are tracked and controlled through LM Aero-Palmdale’s computer network.

An ESH program that has not only improved communication but has also increased knowledge of ESH impacts at the work site is the Job Hazard Analysis (JHA). In 1998 LM Aero-Palmdale became involved in the Cal/OSHA Voluntary Protection Program (VPP). Participation in the VPP required that a more comprehensive evaluation of job hazards be conducted and that the hazards be communicated to employees. In order to satisfy the VPP requirements, LM Aero-Palmdale developed new procedures to evaluate both the environmental and worker hazards for every major shop, lab, and work area. Inclusion of environmental hazards went beyond VPP requirements; however, this allowed ESH staff to evaluate all hazards, environmental and health and safety, at the plant.

An Environmental JHA Evaluation Form was developed that identifies the location of the area being evaluated, the people responsible for the area and a general description of the processes in that area. A blank process flow chart is included to identify raw material inputs, processes, and waste or releases. A checklist identifies environmental release points, environmental controls, environmental aspects and source types. The last section of the form to be completed is the environmental risk section, in which the primary process hazard is identified and given a risk score. Probability of occurrence and severity are given a rating (1-low, 2-medium, or 3-high), and probability of detection is scored as 1-high, 2-medium, or 3-low. A total risk score is then given to the area. New environmental aspects are being identified using the Environmental JHA Evaluation Form and the risk scoring allows the ranking of significant aspects.

A Safety and Health JHA Evaluation is also completed for each area. The results of both the environmental and safety and health JHA evaluations are combined into a single product that lists all significant hazards in an area; environmental, safety and health controls; and training requirements for the work area. The completed JHA is given to the supervisor/manager of the area who must sign the form, post it in the affected area, and inform employees of the results.

The JHA has improved the quality of information going to employees by providing a “simple summary” of all the hazards of an area and what must be done to protect the worker and the environment. Traditionally, this type of information was provided though training or written policies and procedures organized by topic (air, water, waste) or activity (job function).

The Job Hazard Analysis is an example of an integrated program that meets several objectives. Through the analysis, new environmental aspects and impacts can be identified as well as the risks and significance. The program also communicates valuable information to management and staff enabling them to work in a safer and more responsible manner. The JHA also provides valuable information to ESH staff and contributes to the continual improvement process of their EMS. “You never stop learning about the factory and have to be aware of what goes on,” says Michael Haro, Environmental Resources Manager. To date, JHAs have been completed for 55 buildings/areas.

Another means to communicate ESH issues to employees are the ESH Information Boards. These boards are posted in 25 buildings and include information on ESH resources, building emergency action plans, JHAs, ESH objectives, ESH alerts, employee injury and illness data, environmental metrics, and emergency phone numbers and contacts.

Externally, LM Aero-Palmdale communicates with and involves stakeholders in a number of ways. Direct stakeholder communication involvement is accomplished though the Community Stakeholder Environmental Roundtable. Begun in 1997, the Roundtable allows stakeholders to review ESH performance and to provide input into LM Aero-Palmdale’s EMS. The yearly meeting and plant visits have resulted in joint projects including an Antelope Valley Pollution Prevention Fair. LM Aero-Palmdale also co-hosted several household hazardous waste roundups with Los Angeles County Sanitation District.

Community projects with the local schools are another form of outreach and communication. ESH staff have visited science classes and participated in science fairs. LM Aero-Palmdale also sponsors teachers to attend the Key Issues Institute in Colorado where teachers learn how to develop environmental curriculums that focus on local issues.

LM Aero-Palmdale maintains an external web page that includes the EMS policy statement, ESH information, community outreach, recognition/achievements, and related links. Their web address is www.skunkworks.net/esh/index.html.

Operational Controls

The purpose of operational controls in an EMS is to ensure that significant environmental aspects are managed in a way that is consistent with the environmental policy and so that the EMS objectives and targets for those aspects are met. Two of the operational controls in place at LM Aero-Palmdale worth noting are the 6S Program and the chemical control program.

Manufacturing is responsible for the 6S Program; however, it has been a successful way of integrating ESH into manufacturing activities and meeting ESH policy and objectives. The six “S’s” are Sort, Straighten, Shine, Standardize, Sustain, and Safety. Originally developed in Japan as a manufacturing housekeeping and efficiency program called 5S, the 6S Program has been successfully applied at LM Aero-Palmdale to work more efficiently, reduce waste, conserve resources, prevent accidents and maintain compliance. Sixty-one buildings and areas are audited 3-4 times per year and evaluated with a scorecard. Depending on the score, the areas are recognized as platinum, gold, silver, or bronze status.

Chemical management is a significant aspect at LM Aero-Palmdale and chemical disposal is a major significant aspect at LM Aero-Palmdale and they require extensive control. The major elements of the chemical control program involve the Chemical Control Board (CCB) and the chemical control cribs. In addition to pollution prevention projects, the CCB is responsible for approving all chemical purchases at LM Aero-Palmdale. Their review includes an analysis of the ESH risk involved with the chemical, the need for the chemical, and a search for less toxic alternatives.

The daily use of chemicals is tracked and managed through a system of chemical control cribs. A visit to one of the chemical control cribs was part of the EMS Working Group Tour of the LM Aero-Palmdale facility. The primary purpose of the chemical control cribs is to dispense and track the daily use of chemicals. The employee badge magnetic strip identifies the employee receiving the chemical. Each chemical package is given a bar code for identification. The package is weighed prior to leaving the crib, and the chemical is returned to the crib and weighed again at the end of the shift. This daily accounting allows LM Aero-Palmdale to meet the daily volatile organic compound (VOC) tracking requirements of the Antelope Valley Air Pollution Control District Rule 109, the Los Angeles County Fire Department requirement for reporting hazardous materials use, and other regulatory requirements for chemical tracking.

Internally, the package-by-package tracking of chemical use provides operational control. Combined with the approval process of the Chemical Control Board, the cribs ensure that no unauthorized chemicals are being used. The crib process also contributes to meeting pollution prevention goals. The accounting system reduces chemical usage and waste by ensuring that only necessary amounts of chemicals are provided to employees. This also has reduced the amount of chemicals that become waste due to shelf-life expiration.

The chemical identification system also allows for easy access of the Material Safety Data Sheet (MSDS) by the employees. By using the bar code on the chemical package, the MSDS can be obtained through the phone/fax system.

Emergency Preparedness

Although LM Aero-Palmdale is meeting the hazardous materials reporting requirements through their Hazardous Materials Business Plan, they realized that more information on hazardous materials is available through their EMS. In order to provide emergency responders with this information and to alleviate fears regarding “secret” chemicals, LM Aero-Palmdale gave seven seminars to 135 personnel from LA County, Kern County and US Air Force Plant 42 Fire Departments. Regular plant tours are also given to the two closest fire stations.

LM Aero-Palmdale is also exploring ways to connect with the fire departments through a Geographic Information System. This system would identify locations of chemicals and other hazards. LM Aero-Palmdale believes this would be a more useful product than the paper reports that they now submit.

Checking, Corrective Action and Management Review

Continual improvement of an EMS is not possible without the ability to check how the system is operating and take corrective actions to improve the system. A series of internal and corporate audits review compliance with regulatory and corporate requirements. These audits also check the resilience of the EMS. The review system includes:

• Biannual environmental inspections,
• Annual ESH Records and ESH Management System review,
• Annual Safety and Health inspections of all buildings,
• Monthly Building Manager Inspections,
• Correction Notice System for tracking corrective action,
• Biannual Senior Management Review,
• Annual US Air Force ESH Reviews at Plant 42,
• Corporate ESH Reviews every 3 years,
• Preventative Maintenance System (equipment checking), and
• Process Integrity Review Program (new system).

The results of these audits are reported to management on a regular basis.

Management is apprised of EMS performance though:

• Weekly highlights and staff meetings
• Monthly ESH Performance Reports
• Biannual Performance Summary Reports
• Nonconformance Report to President
• Process Integrity Reports to President
• Management Training Topics, ESH Alerts, ESH Report Cards
• Quarterly ESH Management System/ISO Reviews (LM Aero-Ft. Worth)

Environmental Performance

The measure of a successful EMS is its ability to reduce the impact of an organization’s operations on the environment. LM Aero-Palmdale began implementing an EMS in 1992, and in 1998 they self-declared conformance with the ISO 14001 standard. The early focus of their EMS was to make improvements in compliance, hazardous waste generation, and safety.

Compliance at LM Aero-Palmdale has greatly improved since EMS implementation. Since 1993, only one Notice of Violation and four Non-compliance events have occurred. No Notices of Violation have occurred since 1998.

An evaluation of their hazardous waste generation data shows substantial improvements during the first few years (1992 - 1996) of their EMS. During this period, hazardous waste generation was reduced from 3,692 tons in 1991 (baseline) to approximately 500 tons in 1996. Reductions slowed during the subsequent years, but continued to decline to 314 tons of hazardous waste in 2000. Between 1992 and 2000, hazardous waste was reduced 91%.

The emissions of volatile organic compounds (VOCs) show a similar reduction pattern as hazardous waste. Since 1990, VOCs have been reduced 81% from 256,000 pounds to 49,000 pounds in 2000. The greatest reduction occurred during 1991 when VOCs were reduced 153,000 pounds.

The use of Superfund Amendment and Reauthorization Act Toxic Release Inventory chemicals has decreased 91%, since 1991. LM Aero-Palmdale has been below the reporting threshold since 1996.

Safety and health performance is another key indicator of the EMS. This is measured by the Days Away Case Rate (DACR). A 66% reduction in DACR has occurred since 1995. LM Aero-Palmdale’s DACR is 75% below the industry average.

Joint Strike Fighter

The tour of LM Aero-Palmdale by the Cal/EPA EMS Southern California Working Group included a visit to the Joint Strike Fighter (JSF) X-35 assembly area. The JSF project demonstrates the successful integration of environmental, safety, and business considerations. Pollution prevention was considered from the initial design discussions, and pollution prevention technologies developed for the F117 Stealth Fighter, F16, and F22 were incorporated into the design of the JSF. Only fifty-four hazardous materials are used to support the JSF concept demonstrator aircraft, whereas four to five hundred hazardous materials are found in its predecessor aircraft.

One of the JSF projects is a demonstration of a paint-less topcoat. Made of 100% resin solids, the film totally eliminates VOCs from the manufacturing process. Because it is being demonstrated, only a small portion of the JSF is currently coated with the film. The remainder of the plane is painted with a chrome-free primer and low VOC topcoat. Using the paint-less topcoat could mean a $3 billion savings over the life of the project. Other environmental projects of the JSF include no ozone depleting chemicals, chrome free fuel tank sealant, no hydraulic oils (electronic actuators), and no oxygen bottles--oxygen is taken from atmosphere.

Conclusion

The LM Aero-Palmdale EMS illustrates the environmental, health and safety and economic benefits that a well functioning EMS can achieve. Another important lesson is that an EMS never stops improving. The continual improvement process is at work as LM Aero-Palmdale harmonizes their EMS with the other LM Aero facilities. The other LM Aero facilities will have the opportunity to benefit as they learn from the EMS experience at Palmdale. LM Aero-Palmdale will also improve their environmental performance as the ESH staff and the Chemical Control Board focus on new pollution prevention, solid waste reduction, energy conservation, green house gas emissions, and transportation projects.

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Upcoming Activities

The Cal/EPA EMS Project team is continuing to facilitate Regional EMS Working Group meetings at pilot project locations to learn about and comment on individual pilot project EMS development and implementation. Central Marin Sanitation Agency in San Rafael is hosting the March 2001 Northern California meeting. Northern and Southern California Regional Working Group meetings hosted by pilot facilities are being scheduled for April, May, and June.

After the individual pilot project work plans have been finalized, they will be posted on the Cal/EPA EMS Project web site.

The California Supplemental Data Protocol, designed to answer questions posed by PRC § 71045 et seq., will be finalized and posted on the web site after any working group comments have been addressed and a field test has been performed. The Supplemental Protocols will be field tested at Central Marin Sanitation Agency. After adjustments are made, Cal/EPA project managers will collect the supplemental data from the other pilot organizations.

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