Cal/EPA Environmental Management System Project
Pilot Project Work Plan

Pentel of America Ltd.

Section 1. Introduction

Finding more effective and innovative ways to achieve superior environmental protection is the primary goal of the Cal/EPA Innovation Initiative Environmental Management System (EMS) Project. Increasing use of EMSs by industry and government provides an opportunity to examine the benefits EMSs bring in protecting and enhancing California’s environment.

In order to examine the potential environmental benefits of EMSs, Cal/EPA has selected seven pilot projects. The information collected through the pilot projects will be reported to the Governor and Legislature quarterly, with the final analysis due January 1, 2002.

The purpose of the Pilot Project Work Plan is to describe how the work of the Pilot Projects will be carried out and the goals of the program accomplished. This includes describing the project management; data collection and management; data quality assessment, validation, and usability; and data analysis process. The Pilot Project Work Plan shall not be considered a contract or legal agreement and does not bind the pilot organization or Cal/EPA to any particular action.

The Model Pilot Project Work Plan, finalized after public hearings last year, served as a template for development of this draft work plan. The Working Groups will have the opportunity to review and comment on the draft Pentel Pilot Project Work Plan.

Section 2. Project Management

Project information, roles and responsibilities, stakeholder involvement, and reporting are described in this section.

2.1. Project Description
Project description includes background, scope, EMS Project Objectives as provided in Public Resources Code Section 71045 et seq. (PRC § 71045 et seq.), and specific research objectives of the pilot project.

2.1.1. Background
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.

2.1.2. Project Scope
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 is 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, carbon dioxide 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.

2.1.3. Research Objectives of the Cal/EPA EMS Project
Organizations are increasingly turning to EMSs as a means to ensure compliance with environmental regulations and to drive their environmental performance beyond what is required by law and regulations. Anecdotal evidence suggests that the use of an EMS can result in improved environmental performance; however, very few empirical studies exist to support this claim. The objective of the Cal/EPA EMS Project is to collect empirical data necessary to determine what effect, if any, an EMS has on an organization’s environmental performance and on the quality and quantity of environmental information shared with the public.

California law (PRC § 71045 et seq.) specifies that the Cal/EPA EMS Project shall answer the following question: whether and how the use of an environmental management system by a regulated entity that participates in a Pilot Project:

a) Increases public health and environmental protection over those protections provided through the issuance, enforcement, and monitoring of any permit, requirement, authorization, standard, certification, or other approval issued by a federal, state, regional, or local agency to the regulated entity for the protection of public health or the environment and

b) Provides the public with greater information on the nature and extent of the public health or environmental effects of activities or processes engaged in by the regulated entity than that information provided through the issuance, enforcement, and monitoring of any permit, requirement, authorization, standard, certification, or other approval issued to the regulated entity by a federal, state, regional, or local agency for the protection of public health or the environment, or any other law or regulation governing the disclosure of public information.

In addition, observations will be made regarding whether and how Pentel's existing quality management system supports their EMS implementation efforts.

2.1.4 Information to Support Research Objectives
Over the study period, the following information about the pilot project’s EMS will be analyzed.

Public Health and Environmental Protection

• solvent use and associated air pollutants
• solid and hazardous waste disposal
• aqueous waste management
• stormwater management
• the extent to which environmental objectives are integrated into product design
• public health and environmental protection compliance history
• features of the management system that help the organization continually improve its relationship to the environment

Public Information

• availability of information from the pilot organization's web site and/or environmental reports
• policy, procedure, and practice in responding to written and telephone requests by the public for environmental information
• other external communication or public education activities related to the environment,
• public information-related compliance history
• features of the management system that help the organization continually improve its ability to provide information about its environmental impacts to the public

2.2. Pilot Project Organization, Roles and Responsibilities
Pilot project roles, responsibilities and contact information is provided for Cal/EPA, the pilot project organization, University of North Carolina and the Environmental Law Institute.

2.2.1. Cal/EPA
As the administrator of the Pilot Project, Cal/EPA will:

• provide data collection protocols;
• provide a project manager to coordinate the collection of data, represent Cal/EPA, and provide technical assistance to the pilot;
• assist in data collection;
• coordinate data input to the national database on EMSs maintained at the University of North Carolina;
• facilitate communication with stakeholders and coordinate Northern and Southern California Working Groups;
• provide training on the subject of Environmental Management Systems;
• maintain a web site at www.calepa.ca.gov/EMS where EMS Project information can be accessed;
• communicate to the California Legislature and Governor on the progress and conclusions of the Pilot Project; and
• communicate with stakeholders on the progress and conclusions of the Pilot Project.

Cal/EPA Project Manager and Primary Contact

Renée Lawver, Senior Scientist, P.E. MSCEE
Cal/EPA, Integrated Waste Management Board
1001 I Street, P.O. Box 4025
Sacramento, CA 95812
Telephone: (916) 341-6293
Fax: (916) 341-6742
E-mail: rlawver@ciwmb.ca.gov 

Cal/EPA EMS Project Director

Ms. Jennifer Smith Grubb
Cal/EPA, Department of Toxic Substances Control
2151 Berkeley Way, Room 515
Berkeley, California 94704

Assistant Secretary for Environmental Management and Sustainability, Cal/EPA

Dr. Robert Stephens
2151 Berkeley Way, Room 515
Berkeley, California 94704

2.2.2. Pilot Project
As the Pilot, Pentel of America Ltd. will:

• contribute information on the design and operational performance of their Environmental Management System that is consistent with the data collection protocols of the Cal/EPA EMS Pilot Project,
• participate in the Southern California Working Group, and
• communicate with stakeholders about the design and performance of their EMS.

Pilot Project Manager and Primary Contact

Vern Lindquist, Management Representative
Pentel of America, Ltd.
2715 Columbia Street
Torrance, CA 90509
Telephone: (310) 320-3831
Fax: (310) 533-1401
E-mail: verlin@pentel.com

2.2.3. University of North Carolina and Environmental Law Institute
The University of North Carolina (UNC) and the Environmental Law Institute (ELI) maintain the National Database on Environmental Management Systems. Information is provided to the national database by states conducting Pilot Projects in the Multi-State Working Group (MSWG). The MSWG is a coalition of states, non-governmental organizations, and businesses interested in the application of EMS in public policy.

UNC and ELI will:

• maintain web site at www.eli.org/isopilots.htm where data protocols can be accessed,
• manage data as described in section 3: data collection and management, and
• publish public reports on national Pilot Projects.

UNC Project Leader

Deborah Amaral, Ph.D., Adjunct Associate Professor
CB#3435, Abernathy Hall
Chapel Hill, NC 27599-3435
Telephone: (919) 962-9827
Fax: (919) 962-5824
E-mail: NDEMS@unc.edu

2.3. Project Schedule
The project schedule identifies Cal/EPA EMS Project milestones and estimated completion dates. Major pilot-specific milestones are identified in the subsequent table.

Milestones	Estimated Completion Dates
Northern California Working Group Site Tour: IBM Southern California Working Group Site Tour: Artistic Plating	September 2000
Baseline and EMS Design Data Sign-off (only if not already completed)	October-November 2000
Northern California Working Group Site Tour: Benziger Winery	November 2000
Data Collection and Submittal Southern California Working Group Site Tour: Lockheed-Martin Aeronautics	January 2001
Northern California Working Group Site Tour: Central Marin Sanitation Agency Cal/EPA Supplementary Data Collection and Submittal Working Groups Review Draft Work Plans	March-April 2001
Northern California Working Group Site Tour: Davis Bynum Winery Southern California Working Group Site Tour: San Diego MWWD O&M	April  2001
Southern California Working Group Site Tour: Pentel of America Ltd.	May 2001
Northern California Working Group Site Tour: Anheuser-Busch, Inc.	May or June 2001
Working Group Meeting: Data analysis and discussion	June 2001
Data Collection and Submittal	July 2001
Working Group Meeting: Final data analysis and discussion	September 2001
Working Group Meeting: Review Draft Report to Legislature	October or November  2001

 

EMS Implementation Milestones for Pentel of America Ltd.	Estimated Completion Dates
Manager EMS training	November 2000
Develop list of environmental interactions and determine significance	December 2000
Set EMS objectives and targets	January 2001
Identify indicators and implement plan to achieve targets	March 2001
Modify existing and write new procedures	March 2001
Identify staff roles and revise job descriptions	April 2001
Identify and prepare needed emergency plans	May 2001
Manager responsibilities and authority training	May 2001
Prepare and conduct training for audit team	June 2001
EMS training for all factory employees	June 2001
Departments implement EMS	July 2001
Conduct Internal Audit	July 2001
Schedule and coordinate third-party registration audit	August 2001

2.4. Stakeholder Involvement
Stakeholder involvement activities of the pilot organization and the purpose of the Working Groups are described below.

2.4.1 Activities of the Pilot Project
The Pilot participates in the Southern California Working Group.

2.4.2. Working Groups
The Northern and Southern California Working Groups are the primary vehicle for stakeholder involvement in the Cal/EPA EMS Pilot Project. A stakeholder is any interested party, organization or individual, who may be affected by the activities of Cal/EPA, or of a Pilot Organization, and is interested in contributing to the Cal/EPA EMS Project.

The purpose of the Working Groups is to act as a public forum for the evaluation, analysis, and discussion of Environmental Management Systems in general and the EMSs of the Pilot Projects specifically. The Working Groups will take an active role in evaluating the Pilot’s EMS, assist in analyzing data generated by the Pilot Project, and participate in answering the questions presented in PRC § 71045 et seq. The Working Groups may also provide suggestions to Pilots for improving their EMSs.

The Working Groups are a forum for education, networking, and open communication between industry, regulatory agencies, environmental or community interest groups, and academics. Establishing cooperative working relationships between various stakeholders is a primary goal of the Working Groups.

Cal/EPA coordinates the Working Groups. Meetings will occur three to four times per year. The Pilot, Cal/EPA, and the Working Groups will participate in training and facility tours.

2.5. Reporting
Cal/EPA will prepare quarterly reports to the Legislature between January 1, 2000 and January 1, 2002. The reports will include Pilot baseline conditions, updates on the progress of the Pilot Projects, and activities of the Cal/EPA EMS Pilot Project. The conclusions of the studies, including the answers to the questions presented in PRC § 71045 et seq., will be presented in the final report due January 1, 2002.

Section 3. Data Collection and Management

In order to meet the objectives of the Pilot Project and answer the questions presented in PRC § 71045 et seq., data will be collected 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 environmental information produced,
• EMS design, and
• EMS costs and benefits.

Pilots will contribute baseline data prior to the introduction of the EMS, descriptive information about EMS design and four semiannual updates during the Cal/EPA study period.

In coordination with other states, detailed data protocols have been developed by the Multi-State Working Group. With the assistance of the University of North Carolina and the Environmental Law Institute, the MSWG maintains a national database on EMS design and performance. The California Pilot Projects are part of an effort that includes close to 100 Pilot Projects nationwide.

The Pilot will provide data through the completion of the national EMS data protocols and the few additional questions summarized in California’s Supplemental Data Questions to the National Protocols. Pilot Projects are provided with electronic and printed versions of the protocols. The national data protocols are available on the internet at www.eli.org/isopilots.htm. The California Supplement will be provided at www.calepa.ca.gov/EMS. After the pilot’s data entry is complete, the protocols are sent to the Cal/EPA project manager. If requested, Cal/EPA will assist in data collection.

After review, the data is sent to UNC and ELI, where they will:

• enter pilot data into the national EMS database;
• review data for completeness;
• respond to Cal/EPA and the Pilot Project manager detailing missing data, questions, or need for clarification; and
• return data to Cal/EPA and the Pilot Project manager for accuracy review.

Data collected through the Pilot Projects will be available to interested parties and summarized in reports to the Legislature.

Information to support the research objectives also will include interviews and observations by Cal/EPA pilot managers, public information from various sources, and evaluations from Working Group members, as needed.

Section 4. Data Quality Assessment, Validation and Usability

The Cal/EPA Pilot Project managers and the staff at UNC and ELI shall assess data quality by evaluating the following:

• completeness (all data included),
• appropriateness (scope and detail appropriate to support research objectives),
• accuracy (level of accuracy appropriate to questions being asked),
• precision (description of desired measurement),
• relevance (adds information that supports research objectives), and
• comparability (to other California pilots and other studies on EMS performance).

In the event that problems or omissions are encountered with the data, UNC will inform both the facility and the Cal/EPA Pilot Project manager, who will review the data with a facility representative. Any incorrect or unreported data will be corrected or added and forwarded to UNC for inclusion in the national database.

After the data has been entered into the national EMS database, UNC will return data printouts to the Pilot and Cal/EPA. The project managers will review the data for accuracy ensuring that the data keyed into the national data is the same information submitted by the Pilot Project.

The Cal/EPA Pilot Project manager will identify the descriptive information and performance statistics that are relevant to the questions posed by PRC § 71045 et seq.

Section 5. Data Analysis

The questions posed in PRC § 71045 et seq. will be answered through the analysis of relevant data collected. EMS performance, regulatory compliance, and the public’s access to environmental information will be compared before and after EMS implementation. Improvements of performance over baseline performance will indicate improved environmental protection and information. Performance, including information sharing, shall also be compared to regulatory requirements in these areas.

The collected data and analysis will be presented to the Northern and Southern California Working Groups. The Working Groups, Cal/EPA, and the Pilot will analyze the data and determine the answers to the questions posed by PRC § 71045 et seq. The final conclusions and subsequent report to the legislature will be based on information from all the California Pilot Projects, not from any individual project. Case studies and examples drawn from the Pilots may be used to illustrate conclusions.