Cal/EPA Agency-Wide Environmental Management System

DRAFT Selection Criteria and Descriptions of Proposed Pilot Projects

Pentel of America, Ltd.

As a leading international manufacturer of writing instruments, stationary goods, and art supplies, Pentel Company, Ltd. has facilities located worldwide. Headquartered in Tokyo, Japan, the company employs a total international workforce of 2,100 employees. Products manufactured include automatic (mechanical) pencils, non-refillable roller ball pens, refillable ballpoint pens, gel ink pens, ink, lead, erasers, correction fluid, highlighters, markers, crayons, water and oil paints, pastels, glue, and artist brushes. Pentel invented roller ball technology and pioneered graphite lead. In addition, Pentel is the only writing instrument company to receive the Deming Award for recognition of the highest standard of quality.

Pentel of America, Ltd. is headquartered in Torrance, California. Although there are offices in several states, and a separate blister packaging facility in Torrance, all U.S.A. manufacturing is carried out at the Torrance Factory. Operations here include precision metal machining, plastic injection molding, water-base ink production, and writing instrument assembly and packaging. There are approximately 200 employees at the Torrance Factory.

EMS Scope and Maturity
The Torrance Factory officially began EMS development in October of 1999, with intentions of obtaining ISO 14001 EMS registration in the summer of 2001. Pentel manufacturing facilities in Ibaraqi and Yoshikawa, Japan have successfully completed ISO 14001 registration, while the factory at Soka, Japan is nearing implementation of its EMS. These efforts together reflect the Japan headquarters’ long-held policy to preserve and improve the environment, and its support of ISO 14001 as one of the tools for accomplishing this.

Pentel's Torrance Factory directly impacts air and waste, and to a lesser extent, water and traffic. The EMS that is being implemented at this facility will address each of these impacts. Although a formally identified EMS will be a new addition, environmental concerns have traditionally influenced management decision-making and planning. Recently, the company made a significant investment in the installation of a state of the art, self-contained and completely enclosed, CO2 degreasing system to reduce solvent use and thereby minimize air quality impacts. It is expected that the systematic approach of an EMS will result in further environment related benefits in the areas of reduced waste generation, increased recycling of plastics and other materials, more efficient hazardous waste handling, and additional improvements in air quality, particularly in oil and particulate emissions.

Unique EMS Characteristics
This proposed pilot project contributes the perspective and experience of working with a medium-sized manufacturing facility, which is seeking to integrate to the degree possible an ISO 14001 compliant EMS with the currently existing ISO 9001 registered quality system. Furthermore, the heterogeneous nature of this particular manufacturing plant combines a variety of manufacturing processes within a single facility, providing a more extensive trial of the ISO 14001 EMS model than would occur in more homogeneous industries.

Stakeholder Involvement
Pentel is participating in the Cal/EPA Southern California EMS Working Group. Participants include representatives of community groups, environmental organizations, industry, academia, and local, state and federal regulatory agencies. The working group is developing a common understanding and knowledge of EMSs. The working group will be advising pilot organizations on the development and continual improvement of their EMSs; evaluating the performance of EMSs; and exploring related public policy issues.

Research Value for California Study
Pentel has committed to provide information consistent with the national research protocols as adopted by the Multi-State Working Group. Data categories include environmental performance, regulatory compliance, use of pollution prevention techniques, continual improvement, employee awareness, involvement of interested parties, EMS design and implementation, and costs and benefits. In addition, Cal/EPA will be collecting information about the quality and quantity of public information provided by organizations before and after implementing an EMS. Collection and analysis of this data is an integral part of the Cal/EPA EMS Project.

Contact Information
Please contact the Cal/EPA EMS Pilot Project Manager, Renée Lawver, at (916) 255-2655, or by E-mail at rlawver@ciwmb.ca.gov, for more information about the proposed pilot project.

Evaluation of Proposed Pilot Project
Cal/EPA staff evaluated the proposed pilot project based on the draft selection criteria. In staff’s judgement, this proposed pilot satisfies all the criteria, as tabulated below.

Selection Criteria	Pentel of America, Ltd.
(1) Pilot projects will have an ongoing or planned EMS that can reasonably be expected to produce greater environmental protection than would otherwise be achieved by the existing regulatory process.	Yes Developing an EMS with goal of achieving third-party certification to ISO 14001 EMS Standard
(2) Pilot projects will engage in a multi-media environmental approach (e.g., air, water, solid and hazardous waste).	Yes
(3) Pilot projects will pursue appropriate pollution and waste prevention opportunities.	Yes
(4) Pilot projects will share information learned from EMS implementation with Cal/EPA, regional and/or local working groups, and the public. Pilot projects agree to provide specific data on the goals, implementation, and performance of their EMS as reported in the national and California supplemental data protocols.	Yes
(5) Pilot projects will participate on the Northern or Southern California EMS Working Group.	Yes Southern California EMS Working Group
(6) Pilot projects will declare to Cal/EPA any current and past (three years) violations cited by environmental regulatory agencies.	Yes
(7) Pilot projects will address known regulatory deficiencies, as required by the appropriate regulatory agency, through their EMS.	Yes
(8) Pilot projects' top management will make a full commitment to participate in the project through a letter of intent.	Yes Corporate authorization and commitment
(9) Pilot projects should represent diversity in terms of location/geography, size, industry type or sector, environmental impacts, and in the range of EMS maturity.	Medium-sized manufacturing operation in Southern California

DRAFT Selection Criteria and Descriptions of Proposed Pilot Projects