ASTM_E_2365_-_14.pdf

Designation:E236514Standard Guide forEnvironmental Compliance Performance Assessment1This standard is issued under the fixed designation E2365;the number immediately following the designation indicates the year oforiginal adoption or,in the case of revision,the year of last revision.A number in parentheses indicates the year of last reapproval.Asuperscript epsilon()indicates an editorial change since the last revision or reapproval.INTRODUCTIONThis guide provides a framework for the development of an environmental compliance assessmentprogram.It integrates environmental compliance,environmental risk classification and business riskmanagement for use in decision-making.It provides a flexible,technically defensible framework toprioritize environmental compliance and associated pollution prevention,with a wide applicability toa range of facilities and environmental pathways.The facilities that may find an environmentalcompliance performance assessment program useful and appropriate are domestic establishments thatperform work for consumers,business,government and other organizations.These include public andcommercial establishments,but they generally exclude individual households.This guide may not beappropriate where a primary manufacturing facility has already implemented a site-specific environ-mental management system(EMS).This guide could be used as a tool in conjunction with an EMS,to evaluate compliance and pollution prevention.1.Scope1.1 OverviewThis guide is an organized collection ofinformation and series of options for industry,regulators,auditors,consultants and the public,intended to measurecompliance with environmental performance standards againstestablished benchmarks.It focuses on compliance with air,water,waste prevention,waste management,and toxic reduc-tion standards for facilities in the United States.While theguide does not recommend a specific course of action,itestablishes a tiered framework of essential components,begin-ning with those standards where a deviation presents thegreatest potential public health,environmental,and businessrisks.In each identified pathway,at each tier or step ofanalysis,the guide outlines ways to identify complianceoptions and reduce pollution in iterative steps.The goal inusing the guide is to lower environmental,public health andbusiness risks from Tiers 1 and 2 to Tiers 3 and 4,by evaluatingthe performance standards described in this guide.While thisguide provides a simplified framework of explicit steps forusers,a qualified professional should conduct detailed,site-specific risk analysis.This guide may act as a starting point fororganizations with limited experience in systematic environ-mental assessment.As facilities develop their specific planframework,they will find that risk is weighted by more thanjust a few parameters.For each facility risk is the complexinteraction among location,size,history,surrounding commu-nity and ecological zones.1.2 Differences Among StandardsThis guide focuses oncompliance with environmental performance standards in theUnited States.As such it includes a unique,risk-based methodto analyze specific groups of legal requirements,as well as riskreduction techniques,sometimes called“pollution prevention.”1.2.1 Use of this guide provides a system to evaluate therelative priority of compliance and pollution prevention activi-ties.Unlike environmental management systems,it provides aframework to triage critical issues,based on consideration ofactual risk of harm to public health and the environment.1.2.2 Environmental regulatory requirements in the UnitedStates are administered primarily by the United States Envi-ronmental Protection Agency(USEPA)and the parallel Stateand Local Agencies with similar regulatory authority.Certainother Federal regulatory agencies and State and local counterparts may also have legal requirements relating to environmen-tal performance standards.Examples include the Departmentsof Transportation(DOT)and Agriculture(USDA)and theOccupational Safety and Health Administration(OSHA).Un-like certain international standards,this guide uses the majorgroups of environmental regulatory standards in the UnitedStates for air and water quality,waste management,releaseprevention,and toxic materials use reduction,in order toorganize the compliance analysis framework.1.2.3 This guide derives general information about regula-tory requirements from common elements of Federal,State and1This guide is under the jurisdiction ofASTM Committee E50 on EnvironmentalAssessment,Risk Management and Corrective Action and is the direct responsibil-ity of Subcommittee E50.05 on Environmental Risk Management.Current edition approved Jan.1,2014.Published February 2014.Originallyapproved in 2005.Last previous edition approved in 2005 as E236505.DOI:10.1520/E2365-14.Copyright ASTM International,100 Barr Harbor Drive,PO Box C700,West Conshohocken,PA 19428-2959.United States1 local programs,including statutes,regulations,guidance andpolicies