Metal Painting and Coating Operations
Table of Contents Background
Regulatory Overview Planning P2 Programs
Overview of P2 Surface Preparation
How can assistance providers and regulatory compliance staff sell pollution prevention options to a facility? The most important point that an assistance provider can make is that pollution prevention can help the facility achieve regulatory compliance while saving money. The savings associated with recapturing and reclaiming materials is obvious; but the value of reducing the regulatory burden and the expense from wasted raw materials, can, in many cases, exceed the cost of pollution prevention projects. Overall, the benefits associated with pollution prevention include:
Potentially, a facility can realize other benefits from the implementation of a comprehensive pollution prevention program. Source reduction can lower insurance costs, protect property values, and improve relationships with financial institutions. Even though pollution prevention has clear economic advantages and the techniques can be simple, inexpensive, and time proven, many facilities still do not have significant source reduction programs (Haveman, 1995).
This chapter provides information on how to conduct an assessment of a facility that has a coating process. It provides information on a general facility assessment as well as specific information on assessing the coating process. Technical assistance providers should be aware that while a facility may have one process or chemical that is of major concern, assessing the entire facility is critical. In this way they can identify processes that are impacting the coating process and that might be increasing pollution generation.
Numerous factors can influence whether a facility adopts and implements pollution prevention techniques. Understanding what motivates a facility can help a technical assistance provider develop a message for the facility that will influence their decision to implement pollution prevention. The following list divides firms into categories and describes some characteristics of firms and their motivating factors:
The barriers that generally apply to some or all of these facilities are:
The key to developing a successful pollution prevention program is planning. Assistance providers can work with facilities to implement planning programs, assist in establishing baseline measures, and identify potential pollution prevention projects. The key steps to starting a pollution prevention program include:
The following pages outline an ideal planning process. Often, there are issues and limitations that inhibit a company's ability to carry out all of the outlined activities. Therefore, this process should be viewed as a flexible model.
The support of company management is essential for developing a lasting and successful pollution prevention program. The level of success that a facility can achieve in reducing waste generation appears to depend more on management interest and commitment than on technical and economic feasibility, particularly for source reduction technologies that require process modifications or housekeeping improvements. In some states, the technical assistance programs will not work with a facility until top management has shown that it is willing to support a long-term pollution prevention program.
At the outset of the P2 planning program, management endorsement is needed to help identify the pollution prevention team and give credence to the planning effort. Throughout the program, company management can support the team by endorsing goals and implementation efforts, communicating the importance of pollution prevention, and encouraging and rewarding employee commitment and participation in the effort (Dennison, p. 61).
At some companies, technical assistance providers may find that employees see only the barriers face in implementing a project, which they use as excuses to not implement pollution prevention. At other firms, motivated employees are empowered to find solutions to overcome obstacles, and the companies can reap the benefits of successful pollution prevention projects. Technical assistance providers should stress to management that a successful program has a wide range of benefits. These benefits include cost savings, reduced liability, and enhanced company image as described earlier.
Assistance providers should inform management that some initial labor costs will be incurred as a result of organizing and implementing a pollution prevention program. Usually, however, companies find this up-front investment is repaid several times over. Case studies often highlight the benefits that other companies have realized from implementing such programs.
Technical assistance providers can help facilitate management support by developing a plan that sells pollution prevention to a company's executives. Successful management initiatives that have promoted pollution prevention include: developing a corporate policy that makes pollution prevention a mandate; incorporating pollution prevention success into performance evaluations; and offering financial incentives for meeting pollution prevention goals or for finding pollution prevention opportunities.
Obviously, each firm is different. The assistance provider's approach to each company's leadership should attempt to address their specific interests and priorities as manifested by the corporate culture. Identifying these interests and priorities is a challenge for any assistance team. On these visits the teams discuss their priorities and pollution prevention in relation to those priorities. Technical assistance providers should also stress to management that planning is an ongoing task. Once the initial plan is completed, the facility should continue to reevaluate their operations to identify areas that can be improved (CAMF, 1995).
A successful pollution prevention program requires not only support from management, but also input and participation from all levels of the organization. To champion the effort, every pollution prevention program needs an effective pollution prevention coordinator. Assistance providers can help identify the team leader, work with the leader on developing their team, and suggest ways for the facility to implement its pollution prevention program.
A team approach allows tasks to be distributed among several employees and enables staff from different parts of the company to have input into the planning process. Members of the team are typically responsible for:
The pollution prevention team should include employees who are responsible for planning, designing, implementing, and maintaining the program. The ideal size of the team depends on the size of the organization. In small companies, the team can consist of one person who wears many hats, or the company manager and a technical person. In larger companies, the team might include environmental managers, building supervisors, technical staff, maintenance staff, marketing staff, purchasing staff, and other interested employees (Dennison, p. 63).
External personnel, such as technical assistance providers or consultants, can complement the team by providing technical or managerial expertise. Often these people can offer auditing expertise as well as knowledge of pollution prevention, and environmental laws and regulations. However, external contributors will be unfamiliar with the facility's operation. Once the team is established, assistance providers and regulatory staff should encourage the facility to take the following steps to properly evaluate the options for reducing pollution:
The following pages provide an overview of the typical steps involved in assessing a facility and coatings processes in particular. These steps include:
While the facility may have brought in a technical assistance provider to suggest methods for a single process or problem, the entire facility must be evaluated because the coating process will be affected by outside issues. Consider the case of a facility that wants to change from solvent cleaning to aqueous cleaning but has problems with removing cutting fluids. The machining process would need to be examined to see if the facility could use alternative cutting fluids that are easily removed using aqueous cleaning.
Once the team has defined its objectives and criteria for a pollution prevention program, the next step is to assess the facility. Beyond the facility tour, useful information for the assessment can be obtained from sources such as:
Locate or prepare drawings of the layout of the process and storage areas. These drawings should be to scale, showing the location of all relevant equipment and tanks, and identifying:
The first step in P2 assessments of coatings processes is to collect as much information as possible about the coating process from company personnel. Background information should establish the sources and nature of wastes generated, and can include:
Technical assistance providers should also review all operations of the facility that relate to chemical, energy, or water use. Some of the information that technical assistance providers should request includes:
The information listed above should be used in conjunction with the information obtained in the walk-through of the facility to determine what pollution prevention options are technically and economically feasible. This information should also provide the technical assistance provider with information to determine which processes in a facility need to be addressed to reduce pollution generation.
A great deal of data should be accumulated so that assistance providers can determine the best pollution prevention approaches for a facility. The first pieces of information gathered should be material/resource use, general operating procedures, and facility information. This information usually can be gathered prior to a facility tour and used to start a facility map that will be valuable during the site visit. Table 5 provides an overview of the basic operational information that technical assistance providers should obtain from the company prior to the technical assistance visit.
Additional information is gathered during the facility tour. When touring the coatings operations at a facility, technical assistance providers should observe or ask employees about workplace operating practices. Often, employees can provide valuable insight both into why waste is being generated and into some of the obstacles a plant may face in implementing new projects or methods. The following lists present some of the questions technical assistance providers might want to ask (KSBEAP, p.33):
Equipment and Materials
Cleanup and Disposal
If the technical assistance provider uses the team approach described above, many individuals from all areas of the company will have a chance to share their perspective on pollution problems and solutions. Working with this information, technical assistance providers can develop a process map, including data information. Using these tools, the P2 team can go onto the plant floor to discuss the process with those directly involved (e.g., supervisors and front-line production workers) to determine appropriate P2 projects and develop a baseline to measure all future efforts.
Once all the information has been gathered and a map of the facility is drawn, technical assistance providers can develop a process-flow diagram. Process-flow diagrams break the facility down into functional units, each of which can be portrayed in terms of material inputs, outputs, and losses. Developing a process map helps the facility understand how the production process is organized, thereby providing a focal point for identifying and prioritizing sources of emissions and waste (EPAp, 1996).
The process map should cover the main operations of the facility and any ancillary operations (e.g., shipping and receiving, chemical mixing areas, and maintenance operations). Separate maps can be generated for these ancillary operations. Another important area to cover is "intermittent operations" or operations that do not occur on a regular basis. The most common intermittent operations are cleaning and
Assistance providers should also help the facility to include operations that are upstream and downstream of the coating operation. For example, machining operations could have a major impact on cleaning operations. Pollution and waste issues often cross process boundaries. An understanding of the origins of the pollution can assist the facility in identifying opportunities for pollution prevention.
Using the information obtained in the facility assessment, the team should compile a list of P2 options that are technically feasible. Brainstorming sessions with the P2 team can provide innovative ideas. Researching case studies of other companies also can provide valuable information. Other potential sources of ideas include suppliers and consultants. At this point, all ideas should be taken seriously, and none should be rejected automatically for reasons such as "that's already been tried," or "it will never work," or "it's too expensive."
After all options have been identified, the team should screen the options based on the objectives and criteria that were established in the assessment phase. Each option should fit into one of the following categories:
This initial evaluation will assist the company in identifying a subset of options that deserve further investigation. Generally, the number of options requiring detailed information and study should be pared to a minimum (Ferrari, 1994).
When screening ideas, assistance providers should keep in mind that an important principle of excellence in manufacturing is maximizing the productivity of the coating process. Some pollution prevention options can increase productivity while others can decrease productivity, sometimes substantially. Technical assistance providers should be aware of how their suggestions can affect the productivity of the coatings process when screening options. By gaining information on these types of issues, technical assistance providers can provide better suggestions on pollution prevention options when assessing a facility.
Once a short list of options has been identified, the team should begin the process of deciding which options are appropriate for the facility. During this phase, the team should be clear on the company's objectives and criteria. Depending on the goals of the company, cost effectiveness might not be the overriding goal. The following questions should be asked when screening options:
In addition, a company that believes cost effectiveness is critical should consider the long-term costs associated with a particular option. For instance, the team might be inclined to disregard an option because the initial capital outlay is high; however, upon examining the total cost associated with the project, the team might find that the measure could yield impressive savings in several years (Dennison, p. 75). In order to identify the total costs associated with both existing and new processes, the facility could consider costs that traditionally have not been incorporated into capital acquisitions. For more information on identifying these costs, assistance providers can refer to Improving Your Competitive Position: Strategic and Financial Assessment of Pollution Prevention Projects, a training manual developed by NEWMOA for conducting financial assessments of pollution prevention projects.
Once the facility has determined its preferred option(s), the facility can pilot test the program prior to full facility implementation. A pilot test can highlight any installation or implementation issues. At this point, the technical assistance provider has completed most of his or her job. However, if issues arise in the pilot test phase, he or she can be called in to troubleshoot and suggest other alternatives. The technical assistance provider could brief the facility's P2 team on how to anticipate and prevent problems and issues during implementation of the new system. This could be useful because the cost to correct a failed system can greatly exceed the cost of proper initial implementation.
Once the new system is installed, the company's employees should be informed about the project and the importance of their cooperation and involvement. Operators should be trained on how to properly operate the system. Companies should update employees on the expected benefits of and the progress made in achieving the goals of the new system.
Frequent updates on the progress of the overall P2 program can increase a staff's stake in the program. In order to sustain employee interest in P2, facilities should encourage staff to submit new ideas for increasing the effectiveness of the program.
A few critical rules should be kept in mind when helping a company consider new projects:
Assistance providers can suggest that the facility develop a mechanism for soliciting input from all employees in the future. Communicating the success of the program also can keep employees involved. The facility can use the baseline information developed from the facility assessment phase to communicate any progress that has been made. Technical assistance programs can follow up with a facility (usually within 6 months to one year from their final visit) to report on the successes and failures of the company's P2 program and learn of new projects that the facility may have implemented.