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EnvironmentalUpdate
Avery Dennison Maintains Environmental Compliance Using Outsourced Program

December 1, 2002
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Companies, large and small alike, face significant regulatory requirements they must comply with to operate their facilities. The United States Environmental Protection Agency (EPA) and state regulatory agencies monitor this compliance through facilities' self-reporting requirements and periodic agency plant inspections or audits. In difficult economic times like these, companies are looking to maximize performance and cost efficiencies while still being compliant in all areas. Known as "lean manufacturing," this typically involves increasing machine efficiencies while potentially reducing labor, as well.

Such was the situation with label-making giant, Avery Dennison. Tough business conditions and the implementation of process changes to remain competitive in the industry resulted in significant changes in operations. A couple of years ago, the Avery Dennison facility in Quakertown, Pa., was going through just this type of restructuring process. According to Monica Hammer, Environmental, Health & Safety (EH&S) manager, Environmental Affairs for the Fasson Roll North America Division of the company, "The facility had experienced a change in the business mission that resulted in a downsizing of operations and employees. Due to the uncertain status, the site EH&S professional left the company, which ultimately created a gap in the EH&S process."

That vacancy, even though it was only for a short time, could have been costly, according to Susan Burkett, eCAP account manager with August Mack Environmental, Inc., Lancaster, Pa., a recognized leader in the environmental-services industry that provides environmental consulting, process engineering, construction management, and health and safety services to clients throughout the United States.

Label rolls on a slitter machine at Avery Dennison.

Environmental Audits

When Avery Dennison is faced with an environmental facility audit by a regulatory agency, the experience is similar to income tax audits for individuals. In the case of income tax audits, however, taxpayers are given considerable notification in order to get their records in order. With regulatory inspections, auditors are permitted to show up at a facility, any time of the day, any day of the year. Or they may choose to ignore a specific plant for a number of years before dropping in unannounced.

Chris Vlot is the air-quality specialist with the Pennsylvania Department of Environmental Protection and inspects the Avery Dennison Quakertown facility. According to Vlot, his supervisor at the EPA sets his schedule and agrees that it is intentionally varied to include that element of surprise. However, if your facility is like Avery Dennison's and requires a Title V air permit to operate, Vlot says, "You can count on an inspector's visit at least once per year."

With the full-time EH&S position vacant at Quakertown, Hammer was left looking for another way to maintain regulatory compliance at the facility. Burkett contacted Hammer to tell her about eCAP (www.ecapsolution.com), August Mack's innovative outsourcing environmental program, and Hammer was interested. With reporting deadlines soon approaching, the eCAP services seemed like good support for Avery Dennison's business needs.

According to Hammer, there were many things about eCAP that appealed to her. Some of the EH&S responsibilities were able to be transitioned to existing roles in the facility at Quakertown because it is a smaller plant, and process changes minimized the EH&S impact to employees and the environment. However, the site still didn't have the technical expertise to coordinate the environmental record-keeping and reporting on an ongoing basis. "We have integrated the health and safety end of it, and August Mack has helped us to fill the environmental aspects at a reasonable cost," said Hammer.

The eCAP Guarantee

eCAP is available at a fixed cost that is agreed upon at the start of a relationship. The unique thing about August Mack's eCAP outsourcing program, however, is that it comes with a 100%-satisfaction guarantee. According to Amy Holthouse, corporate marketing coordinator with August Mack Environmental, Inc., "If a facility is cited for being out of environmental compliance under an existing eCAP module, August Mack guarantees it will correct the violation and pay any fees incurred."

Avery Dennison label rolls stacked on pallets.

Plant Receives High Marks

Since management at Avery Dennison began outsourcing its regulatory needs to eCAP, it has been reaping big rewards in terms of its regulatory-compliance record. Since instituting eCAP at the Quakertown facility, Avery Dennison has undergone three inspections. The first was an air inspection. Vlot's report cited no violations and even noted how much he appreciated having eCAP's detailed monthly report as a point of reference. The second inspection occurred later the same year. It was a Resource Conservation Recovery Act (RCRA) inspection, which falls under Avery Dennison's eCAP Waste Generator's Module. On that particular audit, Avery Dennison also received a perfect score. The third inspection was another air inspection. Again, Avery Dennison received perfect marks.

Speaking of his inspections at Avery Dennison's Quakertown facility, Vlot says, "I've never had any issues with them whatsoever. Susan Burkett goes in every month and performs all of the calculations for their Title V air permit, which is what I come looking for. I am also looking for any unreported sources of emissions, and I have never discovered any at Avery Dennison. Avery Dennison keeps very good records, and it has done a lot over the years to reduce its emissions."

Avery Dennison is a Fortune 500 Company headquartered in Pasadena, Calif., and employs more than 17,000 men and women in more than 200 manufacturing facilities and sales offices in 39 countries around the world. The company's businesses are organized into two sectors. The pressure sensitive adhesives and materials sector encompasses the entire Fasson Roll Division, including the Quakertown plant. This particular sector is responsible for manufacturing Fasson-brand pressure sensitive base materials in roll form, which are sold to label converters and printers for a variety of industrial and commercial applications. The second sector is the consumer and converted products sector, which manufactures a wide range of Avery Dennison-brand products for both the home and office.

For more information about the eCAP program, contact August Mack Environmental, Inc., 8007 Castleton Rd., Indianapolis, IN 46250; phone 866-579-eCAP (3227); fax 317-579-7410; e-mail aholthouse@augustmack.com; or visit www.ecapsolution.com. Or Circle No. 75.

For more information about Avery Dennison, e-mail Ed Hribar at ed_hribar@averydennison.com. Or Circle No. 76.

eCAP Modules

The eCAP program consists of a number of different modules. Avery Dennison's Quakertown, Pa., facility uses the following:
  • Base Service Module --The Base Service Module includes all monthly site visits to the facility, maintaining an electronic database of all of its records and permits, 24-hour customer support, and support for regulatory inspections. The eCAP Base Service Module also includes the necessary monthly reports and a lot of data gathering for the other eCAP modules all rolled into one set fee. After every monthly visit to Avery Dennison's Quakertown plant, August Mack Environmental's Susan Burkett meets with Matt Reismeier, the facility's plant engineering leader. If there is an issue, he asks Burkett to show it to him so he can make sure the necessary adjustments get done properly and to the right piece of equipment.

  • Air Module: Title V air permits came to life in the 1990s when the Clean Air Act ammendments were passed that said, if a company emits a pollutant above a certain threshold level, then it must file for an air-operating permit. Avery Dennison is labeled as a major source facility because the company has the potential to emit over 25 tons of volatile organic compounds per year. As a result, Avery Dennison's Quakertown facility received a Title V air permit last year.

    Title V permits are very detailed, which is one reason Avery Dennison elected to purchase the eCAP Air Module. This module monitors Avery Dennison's compliance within the standards outlined in its Title V air permit. On a monthly basis, the eCAP Air Module makes sure that Avery Dennison's employees are correctly tracking the plant's air emissions. August Mack experts perform the monthly calculations based on those figures, and prepare and submit the facility's air-emission reports.

  • Wastewater Module -- Based on the industrial outside storage that is maintained at Avery Dennison's Quakertown facility, the corporation also opted to purchase eCAP's Wastewater Module for storm water. This particular eCAP module monitors the outside storage of raw materials and waste according to environmental regulations that require a facility to monitor the runoff of storm water on anything stored outside of a facility.

  • Waste Generator's Module --The Waste Generator's Module monitors hazardous waste at the facility. Federal regulations require hazardous waste be stored in a certain way and labeled according to their guidelines. Regulations also dictate that hazardous waste cannot leak and that it be disposed of within a certain number of days. You can determine if you have hazardous waste at your facility by determining if it is a "listed waste" according to the EPA's guidelines or if it demonstrates any of the following characteristics:
    • Is it ignitable?
    • Is it flammable? Does it pass the flashpoint test?
    • Is it corrosive? It is if it has a pH level greater than 12 or less than 2, or it corrodes metal at a certain rate.
    • Is it toxic?
    There are a lot of different tests for toxicity. The one most often applied is known as a Toxicity Characteristic Leaching Procedure (TCLP). According to this test, materials are placed into a simulated landfill, and if the waste leaches certain chemicals, then it is considered hazardous waste.

    If you know your waste came from a certain industry, you also must disclose that it is hazardous. Avery Dennison's hazardous waste stream contains benzene. The benzene component makes it characteristically hazardous via the toxicity test. With eCAP's Waste Generator's Module, August Mack experts check Avery Dennison's facility on a monthly basis to make sure its hazardous-waste containers are labeled properly and disposed of within the proper time-frame requirements.

  • Hazard Communication Module -- The final eCAP module at the Quakertown plant is what is known as the Hazard Communication Module, responsible for monitoring a facility's hazard communication program and its material safety data sheets (MSDS). This module tracks all chemical purchases and where those chemicals end up. This particular eCAP module also includes Tier II annual reports, which detail to the EPA and to the state storage of a facility's hazardous materials so that if an incident were to occur at Avery Dennison, the necessary steps and precautions are in place to protect its personnel.

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