JULY/AUGUST 2007
Scrapyards that have achieved environmental excellence say it’s neither as hard nor as expensive as you might think.
By Kim Fernandez
The “junkyard” image haunts the scrap industry. A noisy, dirty, trash-filled lot with material floating in the breeze and draining into the ground or water is, unfortunately, what many people still picture when they think of a scrapyard. Thankfully, that kind of operation is becoming the exception, not the rule. Today’s scrap professionals understand the many ways scrap processing can affect the environment as well as what they need to do to keep the negative effects to a minimum.
The general public may be just catching on, but most scrap recyclers are diligent about their environmental efforts, from keeping contaminants out of stormwater to properly disposing of nonrecyclable materials. They not only know about local, state, and national environmental regulations, they go out of their way to comply with them. Still, not everyone has achieved environmental excellence. Despite their commitment and hard work, many facilities still fall short of complying with the many regulations and minimizing their facilities’ impact on the environment.
Those who’ve gone the extra mile say the journey doesn’t have to be expensive or even overwhelming. In fact, they say, putting a scrap facility into total compliance with environmental regulations can increase productivity and boost the bottom line. Environmental excellence, they say, is not just something to strive for. It’s the only way to run a business for long-term profitability.
Getting There
“I don’t see how you can be in business and ignore environmental regulations,” says Manny Bodner, president of Bodner Metal & Iron Corp. (Houston). His company made an all-out commitment to environmental compliance in 2002 and hasn’t looked back, adding staff and new procedures to improve its environmental standing.
Bodner chaired ISRI’s Operations Committee that year, and he and the other committee members found themselves charged with creating a compliance program for the industry that would give scrap recyclers something of a blueprint for environmental excellence, or at least compliance with regulations. (For more on the results of their work—the Recycling Industry Operating Standard—read “Bravo RIOS” on page 68.)
“As Operations Committee chair, I felt an obligation to participate,” he says. “It wasn’t something that was verbalized—I don’t think anyone said, ‘You ought to do this.’ But I wanted to be part of this program.”
Since then, Bodner has created and filled a full-time coordinator position to keep the company in environmental compliance. Though the decision ended up being a good one and a profitable one, he says, it wasn’t an easy decision to make.
“I resisted,” he says. “I didn’t want to fill the position. I believed that as a smaller company, we could fold [the coordinator job responsibilities] into our existing operations, that I could understand them and convey them to our staff. What I discovered was that it was all a foreign language. So I did what anyone would do—I went out and got a translator.”
Other companies have taken a different path to reach the same goal of environmental compliance. At Adams Steel (Anaheim, Calif.), it was an outgrowth of the company’s renewed devotion to employee safety, according to Cristi Rossi, Adams’ vice president of operations.
“Years ago, when we first made a commitment to our safety program and we really focused 100 percent on making our employees safe, we realized that environmental compliance went hand
in hand with employee safety,” Rossi says. “Complying with the regulations and making that part of your daily routine is just as critical as the safety part of the business. We felt that when we combined them and made them both important, our business would prosper. And we did this in the Dark Ages of scrap. It wasn’t a good time—the markets were the lowest they’d been in years.”
Adams initially hired one person to monitor safety, environmental, and compliance issues. Today, the company has a different coordinator for each of those three specializations. The environmental specialist and regulatory specialist spend a lot of time attending local, state, and national association meetings and keeping up with the requirements of new regulations and what might be on the horizon. They also spend a lot of time talking with employees, Rossi says, from management to the folks running the machines.
“We have weekly safety meetings where we also talk about environmental compliance and training. They’re very much intertwined with each other as far as how you process your scrap and what needs to happen for this or that,” she says. “We’ve really made it part of our daily routine.” For example, she says, when companies handle appliances in the proper manner, “they will be removing fluids, mercury switches, oils, and Freon according to regulatory requirements.” At the same time, she says, “correctly handling these items will limit health risks to your employees such as exposure to toxics [and] slips and falls from spilled oils and potentially prevent bodily injury by using proper equipment and tools.”
The company found that its profitability went up as its environmental compliance improved—the yard was more organized and it was easier and more efficient for employees to do their jobs. That’s not an uncommon finding, experts say.
Rossi points to another tangible benefit to being known for environmental excellence: When California lawmakers are considering new regulations, her company gets to weigh in and voice
its concerns and questions, explaining the scrap industry to those who might not have an in-depth understanding of it. “We’ve given ourselves a voice with our local government,” she says. “We work with all kinds of committees and all kinds of regulators.”
At What Cost?
Both Rossi and Bodner say committing their companies to environmental excellence did involve some costs. In her experience, “the biggest expense is the labor commitment,” Rossi says. Both companies hired additional staff, and Bodner also purchased some computer equipment. But neither company had to invest in a lot of specialized equipment.
That’s a trap many newly committed scrap companies fall into, says Bill Baumgartner, president of WZ Baumgartner & Associates (Franklin, Tenn.). They think they have to spend a lot of money on equipment, and that’s generally just not the case.
Most people in the industry “don’t want their stormwater to be out of compliance,” he says. “They go to a trade show and see an oil-water separator and they decide they should install one. Now that’s a great idea if the equipment fits the problem they are encountering. But what if your problem is suspended solids or soluble oil and not floatable oil?”
One client called Baumgartner for help with an oil-water separator he had installed when he couldn’t figure out why it wasn’t working. The installation and the design were correct, Baumgartner discovered, but the client’s problem was oil from turnings and busheling. The unit was designed to remove floatable oil and was not catching the water-soluble oil. It was an example of the right equipment in the wrong application. Essentially, the client “had paid for a $50,000 wide spot in his pipes,” Baumgartner says.
“In [his] enthusiasm, a yard owner will go to a conference and sit through a stormwater session and get ideas as to what he needs,” Baumgartner says. “You then have to apply the information you get effectively.” Achieving environmental excellence can be expensive, he adds, but “it absolutely does not have to be expensive.”
Of course, the costs are relative. “It depends where you’re starting from,” says Mike Place, president of CPI Environmental Services (Wheaton, Ill.). “The short answer is probably no, there’s not a lot of capital outlay. It’s more [a matter of] procedures and policies that you have to train the yard people in and make sure it’s all implemented.
“If you’re fairly compliant with the environmental regulations in your state—you’re already doing stormwater best management practices, you already have spill containment kits, you have containment for larger tanks—assuming you don’t have to invest in all of that, the cost isn’t prohibitive,” he says. As Bodner puts it, “You go through this exercise, you identify gaps, and you close those gaps.”
Many yards don’t realize that “a lot of environmental excellence is just good housekeeping,” Place says. “When your yards are in order, you’re having fewer safety incidents and less downtime. The workers are more productive and it takes less time to do things when you don’t have a bunch of stuff in your way. The star operations have good housekeeping. That doesn’t sound environmental, but it really is.”
Bodner can attest to that: His staff learned that most of their environmental issues stemmed from basic housekeeping, he says. For example, “we found there were items here such as wood products and nonrecyclables … that need to be processed in an appropriate way,” he says. “We tended to put those things to the side. We found that we cannot do that—we must maintain a clean house.” Once they implemented those changes, they fell into compliance relatively easily, he says.
Rossi contrasts what have been minimal expenses for environmental compliance with the potential costs of not complying. “On the downside … it’s not a matter of if that regulator will show up at your door, it’s when,” she says. “And these days, they’re not writing fix-it tickets. They’re giving citations. If you’re not putting the time into it … you’ll be paying huge fines. And that’s not to mention the work and effort you’ll have to put in” at that point to meet the standards. Instead, she says, “start at the beginning and make environmental compliance part of your daily routine.”
Bravo RIOS
“To one yard, environmental excellence might mean complying with the minimum environmental regulatory requirements,” says Reeva Schiffman, senior managing associate of First Environment (Boonton, N.J.). “To another, it might mean going above and beyond compliance. One way to achieve this would be by implementing a management system that conforms to the Recycling Industry Operating Standard,” which ReMA Services Corp. developed to help its members manage and improve their environmental performance along with their quality, health, and safety performance.
ReMA based RIOS on international standards such as ISO 9001 and 14001 and OHSAS 18001, but it streamlined them to focus specifically on the scrap industry. Participating companies “need not be in compliance with all EH&S regulations before they start to implement a [management] system,” says Schiffman, who helped ReMA develop the RIOS program. “In fact, implementation may help companies achieve compliance faster and more efficiently. Once a yard defines what environmental—or quality, health, and safety—excellence means, the system will help the organization get there.”
Bodner, who worked on RIOS’ development, is such a strong proponent of the program that he designed decals for his company’s hard hats and other pieces of equipment that feature his company logo with the words “Team RIOS—Recycling Industry Operating Standard” underneath it. The decals remind employees of the standards they’re trying to meet, he says, and they help get the word out to the surrounding community that his company takes its environmental concerns seriously.
“Visitors see the decal and become aware of it,” he says. “We had some visitors a few days ago. … As we were discussing the various areas of our facility, they pointed to the decals and asked, ‘What does that mean?’ It gave us an opportunity to explain the program and what we’re doing.”
It has also pushed his company forward, beyond meeting basic regulatory requirements. “The whole idea of quality, the whole concept of environmental excellence, is to continue to improve,” he says. “There has to be change. If there’s no change, why go through the program?”
What Works in Wisconsin
The Wisconsin Chapter of ReMA has partnered with the state’s Department of Natural Resources on an innovative “Green Tier” cooperative compliance program that both encourages scrapyards to strive for environmental excellence and gives them a bit of a break if they don’t get there right away.
“In the mid-1990s, when stormwater and group permits and all of that were coming out, WISRI got together and negotiated with the DNR for a group permit that implemented best management practices,” explains Darren Engbring, environmental manager of Miller Compressing Co. (Milwaukee).
Participating companies receive annual training on the permit’s 23 BMPs and are subject to monthly inspections. But instead of using a “gotcha” inspection process that imposes fines for noncompliance, the state instead allows recyclers to show they’re making progress on BMP implementation.
“This kind of got [us] away from … ‘This is the permit and you shall abide’” by it, Engbring says. “It was really more of an open dialogue about self-governing. It let us achieve the water quality levels in the state, but it also let individual companies put money into BMPs instead of into sampling and testing.”
The state rolled out the initial set of BMPs over 10 years: the first 16 or so in years one to five, the remainder in years six through 10. Members of the CCP pay a flat fee of $1,200 per site for the training and monthly inspections. The state receives reports that measure how well participants are following the BMPs.
“When you look at things over five or six years instead of one to two, you can really see where things are going,” Engbring says. Most of the potential violations the program measures have decreased even in the brief period since its implementation.
Sixty-three recycling companies participate in the CCP, which is working so well that other industries are now emulating it. “The auto salvage guys sort of grabbed onto the same concept,” Engbring says, and they are now working on their own partnership with the Wisconsin DNR. •
Kim Fernandez is a writer based in Bethesda, Md.