When Environmental Responsibility Makes Good Sense
Environmental regulations are becoming increasingly stringent these days. Not only do companies have to scrutinize every aspect of their day-to-day operations, but they also have to make sure that the products they are selling or the byproducts of their operations do not pose an environmental hazard. And oftentimes, especially for manufacturers, this means instituting a change in the way business is done. Whether a company has been cited with an environmental violation or it has taken steps to eliminate a potential hazard, environmental responsibility is no longer subject to choice - it's now a matter of business survival.
Yet changing the way a product is made can be a daunting prospect, one which requires considerable time, effort and money. And it may be one that won't turn out right the first, second or even third time. Described below are the tales of two manufacturers faced with an environmental hazard and the steps they took to correct the situation. Their stories prove that although some problems may seem insurmountable at the onset, with patience and cooperation a viable solution can be found.
Back in 1989, when Jack Michaelides was asked to submit material data safety sheets - which describe the contents and components in each solution used in a manufacturing process - after a routine inspection by Connecticut's Department of Environmental Protection, he suspected that something was amiss. However, a year elapsed before this vice president of manufacturing for the Heli-Coil Division of the Black & Decker Corp. received notice that there was indeed a violation of the standards of the Clean Air Act.
The violation involved a process used to apply red ink onto a Heli-Coil stainless steel screw-lock insert, which was emitting volatile organic compounds (VOCs) regulated as a discharge under existing air regulations. The notice informed the company that it must either take remedial action to correct the problem or discontinue the practice. In response, Michaelides, a member of AMA's Manufacturing Council, immediately requested more information.
"The state took that response to indicate a very clear intent on our part to abide by the laws, that we acted in good faith for addressing the issue raised in the letter," he explains. It was clear to him, however, that the company would not be able to discontinue the coloring process, because the red color is used to meet a military standard, or make a quick correction to the VOC emissions. Upon hearing this news, the state informed Heli-Coil that it would be given a time period in which it would be obligated to take corrective action. The Department of Environmental Protection then referred the issue to the state court.
Heli-Coil was originally given a deadline of June 1, 1991, to come in compliance with air standards. (The deadline was later extended to August 1.) Also, the company was required to submit monthly progress reports to the court - or face steep fines: $500 a day for the first 10 days and $1,000 a day thereafter. "I guess anybody could have done [the reports], but because we were on a very tight timetable, I considered them to be my responsibility," he says. The reports detailed the steps that were being taken to correct the situation in adherence with a compliance schedule established by the court. However, once the reports were submitted, Michaelides received no feedback about how the company was doing.
Knowing that the simplest solution to the problem - eliminating the red coloring process - was not feasible, Michaelides and his team of engineers probed a variety of alternatives. The first step was to look at the suppliers of the components to the color solution that the company prepares. "We worked with suppliers for some time, looking at alternatives to each of the components that when used together would give us the right results, and likewise meet the terms of the emission limits. …