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950720 Pollution Prevention in the Hospitality Industry A Tool Kit for Environmental Management providedfor the use of Montana State University Extension Service Pollution Prevention Program developed by Recom Applied Solutions, Incorporated 2919 West 17th Street, Suite 207 Longmont, Colorado 80503 (303) 678-9603 in cooperation with U.S. Environmental Protection Agency U.S. Department of Energy U.S. Small Business Administration September 1, 1995

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Page 1: Pollution Prevention in the Hospitality Industrytowns water supply.He prevented the towns people from drinking contaminated water This is an example of simple, inexpensive, yet highly

950720

Pollution Preventionin the

Hospitality IndustryA Tool Kit for Environmental Management

providedfor the use of

Montana State University Extension ServicePollution Prevention Program

d e v e l o p e d b y

Recom Applied Solutions, Incorporated2919 West 17th Street, Suite 207

Longmont, Colorado 80503(303) 678-9603

in cooperation with

U.S. Environmental Protection AgencyU.S. Department of Energy

U.S. Small Business Administration

September 1, 1995

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Hospitality Industry

This Pollution Prevention in the Hospitality Industry, A Tool Kit for Environmental Management, isprepared for use by facilities throughout the hospitality industry. Companion documents may be

available for your area (see pages iv and v).

. . .111

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A Tool Kit for Environmental Management

Local Resource Manuals(may not be available in your area)

Automotive Resource Manual(Boulder & Denver Metro, Colorado, Area)

(950810)

Auto Body Shops(950700)

to Repair Shops(950710)

Hospitality Industry(950 720)

iv

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Hospitality Industry

Acknowledgements

This document is developed by Recom Applied Solutions, Incorporated, for the Montana State UniversityExtension Service. Following its original release, this document will be updated by Recom to removeerrors, incorporate new information, and acknowledge new pollution prevention programs. This docu-ment will be available to federal, state, and local pollution prevention programs. Those participating inRecom’s program have unlimited distribution rights within their business fields.

Pollution Prevention: The BusinessGuidebook to Increased Profits

(950600)

Pollution Prevention: The NativeAmerican Guidebook for Sustainable

Development(950650)

Your local pollution prevention program may or may not have all of the above pollution prevention toolkits, guidebooks, and resource manuals available for your region. Contact your local pollution preven-tion program coordinator for more information.

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A Tool Kit for Environmental Management

Senior Management Goals...l Understand pollution prevention conceptl Embrace it as the core of all business decisionsl Convenience all employees to support your decision

A Recom Applied Solutions, Incorporated,publication.

Copyright © 1995 Recom Applied Solutions,Incorporated, Longmont, Colorado.

All rights reserved. This publication, in wholeor in part, may not be reproduced by anymechanical, photographic, or electronic processor in the form of a sound recording, and it maynot be stored in a retrieval system, scanned,simulated, transferred, transmitted or other-wise copied, or incorporated in another publica-tion, whether for public or private use withoutprior written permission from the publisher.

The information contained herein is believed tobe accurate and reliable at the time of printing.Neither the authors, publisher, technical advi-sors, nor those who may distribute this publica-tion are to be held accountable for the suitabili-ty of recommendations or for the performanceof a system design, product, or procedure inparticular applications, and they will not beliable if possible levels of waste reduction arenot achieved. Furthermore, reference to tradenames or specific commercial products, com-modities or services does not constitute anendorsement or recommendation. Readersshould thoroughly investigate any design, pro-cedure, or product and independently concludesuitability or satisfactory performance beforepurchase or use.

The authors gratefully acknowledge the contri-butions of Dr. Michael Vogel and Mr. ToddMacFadden, Montana State UniversityExtension Service, for their contributions tothis document, without whose assistance andencouragement this document would not havebeen completed.

This document was originally prepared in partunder a contract with Montana StateUniversity Extension Service.

vi

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Hospitality Industry

T a b l e o f C o n t e n t s

Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .v

Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vii

Local Environmental Contacts, Pollution Prevention and Environmental Compliance . . .viii

UsingThisToolKit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .l

Pollution Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

The 12 Primary Wastestreams and Functions in the Hospitality Industry . . . . . . . . . . . 61. Landscaping and Landscaping Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . 82. Conferences.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..123 . O f f l c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 64 . H o u s e k e e p i n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 05 . F o o d S e r v i c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 46. Facility Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .287. Indoor Air Pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .328. Used Refrigerants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .369. Trash Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4010. Energy Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4411. Water Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5012. Vehicle Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

The 9-Step Pollution Prevention Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Environmental Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .57

The 8 Primary Environmental Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .58Clean Air Act and State Air Quality Regulations . . . . . . . . . . . . . . . . . . . . . . . . .60Clean Water Act and State Water Quality Regulations . . . . . . . . . . . . . . . . . . . . .62Emergency Planning and Community Right-to-Know Act . . . . . . . . . . . . . . . . . .64OSHA Hazard Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66Resource Conservation and Recovery Act and State RCRA Regulations . . . . . . .68

Environmental Regulations Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .70Technical and Financial Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .71

vii

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A Tool Kit for Environmental Management

1.

2.

3.

4.

5.

6.

7. Environmental Protection Agency. Region VIII. Pollution Prevention Coordinator,Hazardous Waste Manager (303) 294-l065

8. National Response Center

9. Resource Conservation and Recovery Act (RCRA) andSuperfund Hotline

Local Environmental ContactsPollution Prevention and Environmental Compliance

Montana Disaster and Emergency Service(or see your local telephone directory)

l-800-426-9440

Montana Fire Marshall(or see your local telephone directory)

(406) 444-2050

Local offices for environmental compliance information County Health Departments(see your local telephone directory)

State offices for environmental compliance information Montana Department of Environmental QualityWaste Management DivisionEnvironmental Remediation DivisionAir Quality DivisionWater Quality DivisionOccupational and Radiological Health Bureau

(406) 444-2544(406) 444- 1430(406) 444-5970(406) 444-3454(406) 444-2406(406) 444-3671

EPA Identification Number information. Hazardous Waste Program (406) 444- 1430

State pollution prevention program contactDr. Michael P. Vogel, DirectorMontana State University Extension ServicePollution Prevention ProgramTaylor HallMSU-Bozeman

(406) 994-3451

Bozeman, Montana 59717

l-800-424-8802

l-800-424-9346

. . .VIII

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Hospitality Industry

Using This Tool Kit

This is your environmental road map for addressing the regulatory, compliance, and pollutionprevention issues facing your hospitality business in the 1990s.

Use this manual and companion manuals as workbooks. They are designed to be incorporateddirectly into your business as true “environmental” tool kits, and they include checklists designedto reduce your regulatory exposure and shrink your environmental footprint.

a This manual is tailored for hospitality facilities which typically have 12major wastestreams and functions that contribute to waste generation.

Pollution prevention is a full-facility commitment; it begins with seniormanagement and it involves employees at all levels. Although this tool kitoffers general as well as specific suggestions, consider the suggestions ofyour employees; they can often be the most effective.

I HOW DO I BEGIN? I

a Start at the beginning of the next section entitled Pollution Prevention.Work your way straight through this section by moving through thechecklist for each of your wastestreams.

a When you need specific information such as names and contact telephonenumbers, or case history examples, refer to the Hospitality IndustryResource Manual (if available).

a If you have regulatory and compliance questions, turn to the secondsection in this manual.

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A Tool Kit for Environmental Management

POLLUTION PREVENTION IS the use of materials, processes, and practicesthat reduce or eliminate the creation of pollutants and wastes at the source. It

udes practices that reduce the use of hazardous and non-hazardous materials,energy, water, or other natural resources.

Achieved at the source through...• material substitutionl product changesl improved housekeepingl process changesl in-line on-site recycling

2

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Pollution Prevention

..in the mid-1700s an English doctor stopped a cholera epi-demic dead in its tracks by removing the pump handle from thetowns water supply. He prevented the towns people fromdrinking contaminated water This is an example of simple,inexpensive, yet highly effective pollution prevention. Instead oftreating the illnesses that resulted from the contaminated water,he stopped the spread of the disease at its source.

Removing the “pump handles” found in your business is what this workbook is all about. Whereare they? How can they be removed most cost effectively? Where do I start first? How muchwill it cost? These questions will be addressed in this workbook.

We recognize that you are in business to make a profit. However, a profitable, growing businesswith a solid balance sheet does not necessarily mean that your business is “against” the environ-ment, or you are ignoring pollution prevention opportunities.

In fact, a well-run, profitable business most likely is very green. One of the purposes of this man-ual is to help you avoid potential environmental problems and become greener, while payingattention to the facility’s bottom-line.

YOUR GOAL

Your goal as you work through this manual is to minimize the amount of non-hazardous and haz-ardous waste your facility produces by using sound pollution prevention methods. If you candramatically reduce the generation of pollution, you can significantly reduce your regulatory andcompliance burden. Although complete elimination of waste may not be possible, our goal is tohelp you arrive as closely as possible to this ideal situation. Records from thousands of facilitiesin the United States have proven that if you reduce pollution and the generation of waste, youwill also realize large savings.

3

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THE ADVANTAGES TO YOUR FACILITY

a Pollution Prevention Can Reduce Your:

l Regulatory burden, including recordkeeping, reporting, trackingl Worker safety risksl Waste treatment, transportation and disposal costsl Risk of criminal and civil liabilityl Current operating costs, especially raw material costs

a Pollution Prevention Can Result in:

l Increased business competitivenessl Positive business imagel Reduced waste disposal, operations, long-term liability and worker safety costsg Improved efficiency and operating practicesg Major positive impacts on your bottom line!

YOUR POLLUTION PREVENTION PROGRAM

The nuts-and-bolts section of your pollution prevention program starts on page 6 of this manualwith an overview of all your facility wastestreams. You can get started right now!!

a Begin at the Top...

l The facility owner or manager must be committed to pollution preventionand pass that commitment on to the employees.

l Post a Company Commitment Statement in your facility that all employees,including the owner, can sign on too. See the Hospitality Industry Resource Manual.

l Establish incentive programs to encourage employees to contribute ideasto the facility-wide program.

l Provide training programs for employees in pollution prevention, hazardousmaterial handling if appropriate, and emergency response.

a Assess All Wastes...

l Start by listing the sources, types, and amounts of all hazardous and non-hazardous wastes generated.

l Use this list to pinpoint wastes that can be minimized, or eliminated.

a Prioritize Wastestreams...

l Focus first on the wastestreams which can most easily be minimizedand that will have the greatest immediate effect.

l Build a list of all your facility’s wastestreams in the order you intend to attack them.

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Hospitality Industry

a Implement Pollution Prevention Options...

l Attack each wastestream on your list with what you judge to be the bestpollution prevention option (see this manual for ideas).

l Explore pollution prevention options for each waste that:

- improve procedures,- segregate wastes,- substitute materials,- modify processes, or- recycle, on-site and off-site.

I REMEMBER...

Your Pollution Prevention Program is an organized, comprehensive, and continual effortto eliminate waste and pollution from your facility. By every measure, it is simply goodbusiness and it is especially good for your bottom line. Most pollution preventionsuggestions presented in this manual have payback periods of less than two years. Allhave been proven in the “real world.”

Pollution prevention begins with commitment and good operating practices, and isfollowed by changes in facility materials and processes.

> Use this manual to identify and prioritize waste management areas inwhich your facility can improve.

> Try starting with Water and Energy Conservation. Implementation of ourconservation suggestions usually yields quick results with in short paybackperiods.

> Turn this page and actually try tackling one or two changesthat will reduce a wastestream in your facility.

. . . Go ahead! Cut your waste, and improve your profit!

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A Tool Kit for Environmental Management

3. Officeq Do you have this function? q Do you have this function?

See Page 16 See Page 20

q Do you have this function?See Page 12

1. Landscaping and Maintenanceq Do you have this function?

See Page 8

12. Vehicle Maintenanceq Do you have this function?

See Page 54

11. Waterq Do you have this waste stream?

See Page 50 10. Energyq Do you have this waste stream?

See Page 44

6 Hospitality Industry’s 12 Functions and Wastestreams

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Hospitality Industry

5. Food Servicesq Do you have this function?

See Page 24

6. Facility Maintenanceq Do you have this function?

See Page 28

7. Indoor Air Pollutionq Do you have this waste stream?

See Page 32

8. Used Refrigerantsq Do you have this waste stream?

See Page 36

q Do you have this waste stream?See Page 40

Hospitality Industry’s 12 Functions and Wastestreams 7

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A Tool Kit for Environmental Management

Use Creative IrrigationMethods

See Supporting Section

W A T E R

(see page 50)

Use Advanced DesignMethods

Using less water is great. Eliminating the use of pesticidescan minimize regulatory concerns and potential contamination.

8 Hospitality Industry Function: Landscape & Maintenance

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Hospitality Industry

Use Integrated PestManagement Methods

maintenance can not only save money,it can also conserve natural resources.

Hospitality Industry Function: Landscape & Maintenance 9

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Hospitality Industry

q 5. Pay attention to your landscape pest control. Becomeinformed to minimize the impacts to your soils and subsurface and sur-face water. Today this is known as Integrated Pest Management (IPM).IPM uses three different pest control tactics: biological, cultural, andchemical.

- Consider biological pest control whenever possible. This iswhere you use the natural enemies of your pest; i.e., usinglady bugs to control aphids.

- Next, consider the use of cultural or horticultural control.This approach relies primarily upon normal lawnmaintenance, although chemicals are sometimes used in this management tactic.One example is mowing high to shade out weeds.

- The last resort is the use of pesticides (which often include insecticides, herbicides,and fungicides). All pesticides are toxic to varying degrees, so be careful about theiruse around animals and humans. And remember, pesticides can also kill earthwormsand other beneficial organisms. If pesticides must be used, they should be chosencarefully and the least harmful chemical should be chosen.

q 6. All pests seek habitats which provide basic needs such as air, moisture, food, andshelter. For indoor pests, remove or control all potential food sources. Try to remove or controlaccess to their habitats. Control moisture as much as possible.

q 7. Remember that total elimination of pests is virtually impossible. Your goals shouldbe to control them, not to eradicate them. Consult a local, licensed specialist for specific rec-ommendations for your situation.

Hospitality Industry Function: Landscape & Maintenance 11

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A Tool Kit for Environmental Management

Use China and GlasswareInstead of Paper and

Disposables

Invite Attendees toParticipate in Conservation

Measures

Conferences can provide a significant wastestreamat high operating costs. Reducing these wastes can save money

and natural resources.

12 Hospitality Industry Function: Conferences

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Hospitality Industry

Recycle All Trash

REDUCTIONREUSE, AND

RECYCLING CANSIGNIFICANTLY

REDUCE \\/ASTESAT CONFERENCES

You can significantly reduce landfill wastesand conserve natural resources at conferences

Hospitality Industry Function: Conferences 13

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A Tool Kit for Environmental Management

lution prevention program and conservation successes is an excellentmeans of advertising a critical message.

2. Conferencesl Hosting large numbers of people over a period of several days isa focused consumption of natural resources.

l Developing a general facility pollution prevention plan that canbe applied to each conference and convention event will have

financial benefit as well as promotional advantages.

Using conferences and conventions to let others know of your pol-

aaa Pollution Prevention Checklist aaa

q 1. Consider pollution prevention for conferences and conventions as a full-facility, long-term activity.

q 2. Donate surplus meals to homeless shelters or other organizations that could benefit.

q 3. Collect food scraps and donate them to a local non-profit farm or other animal feeding placethat could use them.

q 4. Use china and glassware for break snacks, lunches, and other events to reduce the vol-ume of trash. Avoid using Styrofoam cups and plates.

q 5. Set up waste recycling centers for easy access by attendees. Collect paper, glass, alu-minum, plastics, and other common wastes. Arrange for a local recycling company to pick thesesegregated wastes up after the conference, or integrate these segregated wastes into your facility-wide recycling program.

q 6. Develop a recommendation checklist for each conference or convention organizingcommittee for conserving natural resources. This checklist could include a range of recommen-dations, including:

- Use paper with at least 50% recycled fibers, including at least 10% post-consumerwaste, for all announcements, flyers, advertisements, agendas, proceedings, etc.Perhaps you could include local stores that provide such materials.

- Use name badge holders produced from recycled plastic. Remind people to collectthem at the end of an event for use at the next event.

- Arrange for van transportation between the conference center and remote events toreduce vehicle emissions.

- Advertise any of your facility services for pick-up and drop-off at the airport or othermass transport centers, to reduce the perceived need of out-of-town attendees to rentcars. Include time schedules and methods of contacting your hotel/motel to makenecessary arrangements.

14 Hospitality Industry Function: Conferences

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q 7. Develop a natural resource conservation request form for allconference and convention attendees that stay at your facility.

q 8. Clean rooms only on request; not having to vacuum the roomreduces the need for energy.

q 9. Provide new linens on request to avoid unnecessary laundry,thus reducing the use of water and other materials. However, be sure toreplace linens on a nominal schedule to ensure a healthy environment forall attendees.

q 10. Remind attendees to turn-off lights and other electronicequipment (i.e., television) when the room is unoccupied.

q 11. Remind attendees to keep temperatures at their limit of comfort (neither excessivelytoo high or too low), to reduce the load on the air handling system, thus conserving energy.

q 12. Remind attendees to keep windows and outside doors in their rooms closed toreduce the load on the air handling systems, thus conserving energy.

q 13. Provide new shampoo, lotion, conditioner, etc., bottles on request; don’t automatical-ly replace partially used bottles, which wastes the materials and increases the waste volume.When partially-used bottles do remain, donate them to a local shelter or alternative facility.

q 14. Consider every conference and convention as an opportunity to save money and pro-mote the pollution prevention activities of your facility. Develop an announcement that you canpost which outlines all facility features that promote pollution prevention through naturalresource conservation, and which details your accomplishments. Be sure to include this in yourpromotional materials for future conferences and conventions.

P O L L U T l O N P R E V E N T I O N

P A Y S

Hospitality Industry Function: Conferences 15

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Conserve Energy in Public and Conserve and Recycle PaperOffice Lighting Products

See Supporting Section

(see page 44)

Paper Products

See Supporting Section

(see page 40)

Proper management of the office environment can savenatural resources and money.

16 Hospitality Industry Function: Offices

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You can minimize environmentalimpacts if you consider new

methodologies and technologies.

Hospitality Industry Function: Offices 17

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3. Offices

l There is potential for many cost saving changes in your facili-ty’s offices. Saving money through source reduction in officesprimarily involves energy and solid non-hazardous waste (trash)conservation/reduction.

l Approximately 70% of the office trash is recyclable waste paper.Making recycled paper uses 64% less energy, saves 35% water pollu-

tion, reduces air pollution by 74%, and uses 58% less water, than mak-ing new paper from virgin pulp.

l One ton of paper that is recycled saves 60 pounds of air pollutants, 4,100 kilowatt house (enoughto heat an average home for six months), and saves 7,000 gallons of water.

l While you may begin your source reduction program in your offices, the same approach and thesame ideas can be used throughout your facility for proportionally greater savings.

aaa Pollution Prevention Checklist aaa

q 1. Begin your reductions with a careful inspection of all the demands you place on yourenergy resource. First consider the lighting arrangements and intensities. Replace incandescentbulbs with fluorescent bulbs. Replace fluorescent magnetic ballasts with electronic ballasts. De-lamp fluorescent fixtures that have four bulbs remove two of them). You only need 20-50 foot-candles of light in normal office settings. Don‘t overlight; it wastes energy and money. You canfind more information about energy conservation in offices by turning to section II. HospitalityIndustry Wastestream: Energy Conservation, on page 46 of this tool kit.

q 2. Consider the electronic equipment in your offices. Turn off your computers and mon-itors at night and weekends when they are not used. Turn off your computer’s monitor when it isnot being used during the day; it uses one-half of the computer’s power needs.

q 3. At night and during weekends when no one is using the offices - turn the lights off: Inareas that are not continually occupied, consider occupancy sensors to turn the lights on/off.Keeping the lights off when no one is in the area saves money and a natural resource.

q 4. Another office energy saving idea is to merely turn the heat down a few degrees, andair conditioning up a few degrees, within a comfortable range. This lessens the load on your airhandling systems and conserves energy.

q 5. Consider using recycled printer and copy machine cartridges. Don’t throw away yourdepleted cartridges; recycle them and save money on your next cartridge, and reduce your waste

stream to the landfill.

18 Hospitality Industry Function: Offices

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A Tool Kit for Environmental Management

Hazardous Waste Disposal Bulk Products

Eliminate All HazardousCleaning Products

Buy in Bulk, EliminateIndividual Packaging

Wraps, Return Containers

Many standard cleaning products contain chemicals that areenvironmentally hazardous. Eliminating these products

reduces your hazardous waste and air pollutants,and promotes a healthier work environment.

20 Hospitality Industry Function: Housekeeping

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Hospitality Industry

‘et Up an Integrated ProductsPurchase, Use, and Training

Program

You can greatly reduce yourenvironmental “Footprint” if you use non-hazardous

cleaning products.

Hospitality Industry Function: Housekeeping 21

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A Tool Kit for Environmental Management

4. Housekeepingl Housekeeping is one of the largest routine tasks in the hospitalityindustry. It is also one of the most significant consumers of productsand natural resources. EPA estimates that there were three millionlodging rooms in America in 1988; they used 154 billion gallons ofwater at an estimated cost of almost $350 million.

Most facilities believe that housekeeping products are harmless; thisnot be true. Many are harmful to the environment.

l Improvements in reducing wastes and conserving natural resources in house-keeping should be a prime target for your pollution prevention program.

aaa Pollution Prevention Checklist aaa

q 1. The foundation of pollution prevention is management commitment, consistency, andemployee acceptance - all which result in long-term behavioral pattern changes. This is most pro-nounced in housekeeping activities. Involve your employees, but be sure to insist on compliancewith your new program. Consider training your personnel to minimize their fear of change andmaximize your success.

q 2. Begin your program with a comprehensive inventory of all cleaning products you haveon hand. List them by name and find out what they contain. You should have a Material SafetyData Sheet MSDS) for each product; find them and determine what’s in the product. Don’t bedeterred by scientific names and confusing language. Use the Chemical Abstract Service (CAS)number to help you understand that mysterious chemical.

q 3. As a first step, eliminate wherever possible, all products that contain regulated chem-icals (i.e., xylene, 1,1,1 -trichloroethane, phenols, chlorine, nitrobenzene, benzene, toluene, naph-thalene, chlorofluorocarbons). If you cannot replace them with non-regulated products that per-form the same task, be sure you at least do the following:

- Minimize the use wherever possible; restrict their use to authorized personnel only.- Buy in small quantities.- Keep all containers tightly closed.- Do not use these volatile solvents in open cleaning trays.

q 4. Carefully evaluate the additives in your laundry washing activities. Many facilities usea combination of products, they may not all be needed and you may not need to use them inthe quantities you are using today. Many case studies show that you can reduce the variety andquantity of products, and thus save time and money.

5. Involve your housekeeping staff in selecting alternative products. Employee accep-tance is essential to effective implementation of pollution prevention changes.

22 Hospitality Industry Function: Housekeeping

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q 6. Do not use cleaning products that are in prepackaged aerosolcans. This type of delivery system is expensive compared to other meth-ods and environmentally unsound regardless of the propellant.

q 7. Buy cleaning products in bulk (55-gallon drums, for exam-ple). Watch out for shelf-life waste that occurs by ordering more thancan be used during the life of the product.

q 8. Use refillable, rechargeable pump or spray dispensers inplace of commercial aerosol spray-cans. Refillable spray can “look-alikes” are now available and are very reasonably priced.

q 9. Set up a supply inventory program to issue cleaning products in refillable pump dis-pensers; exchange filled dispensers for empty ones. Track usage by individuals to identifyemphasis areas for training.

q 10. Minimize the use of bleach. Bleach is an excellent product for cleaning and sanitiz-ing, but it is also a dangerous product. There are alternatives with similar effectiveness but with-out the harmful characteristics.

q 11. Look for products that can do more than one task, which thus reduce the number ofdifferent products needed for housekeeping and facility maintenance.

q 12. Never purchase products that have a closed cup flash point of less than 140” F.

q 13. Look for products with-the lowest volatile content. This indicates how much of theproduct will evaporate into the air and create volatile organic compounds (VOCs).

q 14. Encourage your purchasing managers to buy only environmentally acceptable prod-ucts. Insist on a MSDS for each product. Decline to purchase any product that has toxic or otherregulated components. Establish a list of “approved” products.

q 15. Once you have set up your program, don’t let exceptions cause a backsliding effectdue to resistance to change. Eliminating hazardous materials in housekeeping is not only bene-ficial to the environment, but it is safer for your employees, it reduces your potential liability, andit saves money.

Hospitality Industry Function: Housekeeping 23

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A Tool Kit for Environmental Management

Paper Products

Establish Food ServiceRecycling Program

See Supporting Section

Eliminate CFCs in Freezers,Conserve Water

See Supporting Section

I I

I I

Pollution Prevention in food services can eliminate considerablewastes, conserve natural resources, and save money.

24 Hospitality Industry Function: Food Services

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Bulk Products

Buy in Bulk, EliminateIndividual Packaging

Wraps, Return Containers

in food services can achieve

Hospitality Industry Function: Food Services 25

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5. Food Servicesl Food services are common to almost all hospitality industryfacilities and functions. They include restaurants, bars, banquets,and other functions which involve the storage, preparation, serv-ing and cleanup of food related products.

l Pollution prevention in food services focuses on solid non-haz-ardous waste management and energy and water conservation.

l Recycling one aluminum can saves enough energy to to run a televi-sion for three hours; it also save equivalent energy to the production of 19

more. One glass bottle recycled saves enough energy to light a 100 watt bulb for four hours.

l Reducing the volume of this wastestream is the initial and primary objective. Less waste thatyou generate is less waste you have to manage.

l A secondary objective is to minimize the wastes sent to the local landfill. To do this, you canconsider different forms of recycling (sending the unavoidable wastes to another location whereit can be transformed into another product).

l Cooling and freezing requirements of food services have traditionally created a major source ofpotential air pollution and ozone depletion.

aaa Pollution Prevention Checklist aaa

q 1. Solid non-hazardous wastes are unavoidable in the hospitality industry, and especiallyin the food services areas. Establish a food services, if not full-facility, recycling program.

Collect all solid wastes, but rather than sending them to the local landfill, select recycling facili-ties that can accept your waste. Keep your recyclable materials as clean as possible. Shop aroundfor the most economical recycling company. Some of these suggestions include the following:

- Donate unused meals to a charity organization such as a homeless shelter.- Donate food scrapes to an organization that feeds animals.- Donate used linens to a shelter.

q 2. Buy your products in bulk, but be careful not to overbuy and lose money or increaseyour wastes because of an expired shelf life. When buying products, ask your distributor or yourmanufacturer to use a minimum amount of paper, cardboard, and wood in packaging. Insist thatyou send back all containers and shipping pallets. Corrugated boxes are often the largest singlesource of waste paper in your facility.

q 3. Use textile products instead of disposable products (i.e., napkins, hand towels, clean-ing towels). Use worn out cloths as rags.

26 Hospitality Industry Function: Food Services

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q 4. Consider advanced water conservation technologies andproducts that are available to your facility: C

- Flow restrictors in all sinks.- Low-flow aerators.- Restrictors in all kitchen sinks.- In-line flow reduction devices. A -- Low-flow basin faucets.

q 5. For additional water conservation ideas, consider reclaimingyour dishwashing rinse water.

q 6. Collect all aluminum cans and glass bottles from your bar;even the colored glass is recyclable. Use a large plastic trash can with a plastic bag liner.

q 7. A multi-area food service recycling program must have a facility management com-mitment for it to succeed. The management needs to be committed to this program, and must bewilling to invest nominal funds for collection bins and other containers, and must authorize timeto search for the most economical service providers to pick up your segregated materials.

q 8. Involving your purchasing office in the food service source reduction program is alsocritical. Purchasing standards must agree with your new approach in buying in quantity (again,watch for shelf-life wastes), reducing packaging wastes, and returning packaging and shippingcontainers.

q 9. Involve your food service employees. Listen to their ideas and source reduction sug-gestions. Employee buy-in is critical for a long-term success.

Hospitality Industry Function: Food Services 27

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A Tool Kit for Environmental Management

ChlorinatedCompounds

orHazardousCompounds

Cleanup SolventsSurface Prep Solvents

Bulk, Non-HazardousJ

See Supporting Section

Hazardous surface preparation and cleanup solvents are typically regulatedas hazardous wastes.

28 Hospitality Industry Function: Facility Maintenance

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AdvancedTechnologies

HVLP, HVSDLP, LPLV, TFANon-Hazardous Paint

Powder CoatingPaint Control

You can minimize evironmentalconcerns if you consider new

Hospitality Industry Function: Facility Maintenance 29

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A Tool Kit for Environmental Management

6 . F a c i l i t y M a i n t e n a n c e

l Facility maintenance often includes tasks that involve theremoval, preparation, and application of protective and decorativecoatings. This is an area which can generate hazardous solidwastes and air pollutants.

l Paint application wastes are comprised of leftover paints, dirtythinner from equipment cleaning, volatile organic compound (VOC)

emissions into the air, and dirty spray booth filters (if you have one),all of which have a significant impact on the environment.

l Other maintenance materials can also be hazardous and should be changed. Even watch forproducts you install in your facility - they too can reduce wastes.

aaa P o l l u t i o n P r e v e n t i o n C h e c k l i s t aaa

q 1. Improve the transfer efficiency of your paint guns and paint application. Using sprayguns for applying paint is a time saving method and can increase efficiencies:

- Standard air spray gun efficiencies typically range between 18% and 42%.Minimum acceptable rates for high efficient runs used properly in the hands of atrained sprayer should be 65% or greater.

- Since the broad industry introduction of High Volume Low Pressure (HVLP) paintguns in 1989, significant improvements have occurred in this technology.

q 3. Institute simple housekeeping practices throughout your facility. These represent sig-nificant pollution prevention options and include such basic steps as:

- Use tight fitting lids on all containers, and keep them closed.- Use leak-proof spigots to transfer material- Never pour paint or thinner from large containers to smaller ones.- Use smaller paint cups for smaller jobs to reduce the chance of over mixing paints.- Use Teflon@ paint cups for easy cleaning

q 4. If you use gun cleaners, always use the enclosed styles that traps and recycles 100%of the cleaner. Make the use of a formal paint gun cleaning system a rule for all paint guns. Neverclean guns by spraying solvent into the atmosphere.

q 5. Buy paint as well as other maintenance products in bulk to avoid high costs, but don’toverbuy and increase wastes because of an expired shelf life.

q 6. Using paint in spray cans can be expensive; consider brush or spray gun application.

When purchasing degreasing agents, surface cleaners, thinners, paint cleaning solvents,swimming pool cleaners, and industrial cleaners, check the MSDS and be sure the product:

Does not contain any hazardous chemicals to avoidgenerating hazardous wastes.

30 Hospitality Industry Function: Facility Maintenance

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- Contains no chlorinated compounds.- Has a flash point above 140°F (closed cup).

q 8. Do not purchase ANY material in aerosol spray can form.This type of delivery system is very expensive compared to other meth-ods and environmentally unsound no matter what the aerosol propellant.

q 9. Use more efficient paint stripping methods in place of solventstripping, such as media blasting with glass beads and carbon dioxidepellets. Cryogenic stripping is highly effective for stripping difficult-to-remove paint and greases from metal or plastic surfaces. The onlyresidue from this stripping procedure is the paint itself.

q 10. Use the highly effective vacuum sanding systems for totally containing all sandingand paint debris. Benefits include reducing the amount of sandpaper used and reducing to zerothe amount of repeat work on cares due to damage from in-house shop dust particles.

q 11. Use computerized paint mixing systems (e.g., DuPont’s) that can break a paint for-mula down to 1/16th of a pint and carefully meter the paint on a per job basis. Savings can rangeup to 50% less paint per task and result in significantly reduced cleanup costs.

q 12. Select the most efficient washing and drying machines when they need replacing; alsoreplace water heaters with the most efficient models possible - this can only translate into savedtime and money.

q 13. Look for recycled products when replacing items such as guest room waste baskets;purchase only recycled paper for paper towels and bath tissues.

q 14. When replacing carpets, consider products that are made from recycled materials.Avoid carpets and padding that contain toxic materials; they will eventually out-gas and con-tribute to indoor air pollution.

q 15. Wet carpets are ideal locations for mold, mildew, bacteria, and dust mites. Keep themdry, or dry them as soon as possible if they become saturated.

q 16. Replace guest room water devices with the latest technologies to conserve water. Fixall leaks as soon as possible. See II. Hospitality Industry Wastestream: Water Conservation,page 50, for more water-related suggestions.

q 17. Replace and maintain windows and insulation with the best possible practices to con-serve energy. See 10. Hospitality Industry Wastestream: Energy Conservation, page 44, formore energy-related suggestions.

Hospitality Industry Function: Facility Maintenance 31

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A Tool Kit for Environmental Management

Offensive Cleaner Odors

Ineffective Cleaners

Segregate and Control AirPollution Areas

Dust, dirt, spores, fungus, bacteria, and other microbiologicalcomponents are common sources of indoor air pollution.

Gases and offensive odors are also considered to be air pollution.

32 Hospitality Industry Wastestream: Indoor Air Pollution

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FacilityAir

HandlingSystems

Clean, Maintain, and OperateProperly

You can significantly reduce indoorenvironmental pollution if you use` advanced

ducts and operate your systems correctly.

Hospitality Industry Wastestream: Indoor Air Pollution 33

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I

A Tool Kit for Environmental Management

7 . I n d o o r A i r P o l l u t i o n

l A variety of forces can contribute to air pollution. The mostimportant concept , remember is that it is best addressed by pre-vention. Smoking, maintenance, cleaning, and other special activitiescontribute to air contamination and comfort problems. Reduce,

remove, or isolate the source.

aaa P o l l u t i o n P r e v e n t i o n C h e c k l i s t aaa

q 1. Housekeeping is an activity that can cause or contribute to indoor air pollution. Consider thefollowing suggestions to minimize this potential:

- Use cleaning products that do not contain chemicals that will volatilize into the air and causeconcern.

- Do not use chemicals that have an offensive odor.- Particulates often become airborne during cleaning (i.e., sweeping, vacuuming); use portable

HEPA (“high efficiency particulate arrestance”) vacuums verses low-efficiency paper-bagcollectors.

- Make sure storage locations for cleaning materials are kept clean and odor free.

q 2. Remodeling and repair activities, including installation of new particleboard partitions, car-pet or furnishings, and painting and roof maintenance, can be sources of indoor air pollution. Install tem-porary local exhaust fans; seal off the work areas, and seal off return air ducts from the work area.Accomplish the repairs and remodeling during off-peak times. Select materials (i.e. carpet, adhesive,paints, etc.) that do not emit odors, and that will not outgas over time.

q 3. Biological contaminants such as fungal, viral, bacterial organisms (whole organisms orspores) can result in allergies and other diseases. These are often caused by spills of water or beverages,cleaners, paints, varnishes, mastics and. special purpose materials onto carpeted areas. Remove the dam-aged materials and increase ventilation.

q 4. Mold and mildew growth due to moisture from condensation are other sources of indoor airpollution. Locate these sources, clean and disinfect them to remove the mold and mildew, and minim&efurther condensation by increasing the surface temperature in that area and retarding condensation.

q 5. Your heating, ventilation, and air-conditioning (I-WAC) system can also act as a source of bio-logical contaminants. Routine maintenance is required. Inspect for signs of corrosion or high humidity,clean drip pans and outdoor air intakes, and carefully use biocides, disinfectants, and sanitizers to avoidinducing additional air pollution inside the building.

q 6. Contaminants from outside air can enter your building and contribute to your indoor air pol-lution concerns. These could include soil gases such as radon, gasoline from underground storage tanks,and methane from closed landfills. It could also include outdoor air pollutants or odors from places such

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as dumpsters and parking areas. Remove or reduce the source; relocate build-ing air intakes. Extend building exhaust outlets so they are longer than build-ing air intakes.

q 7. Operate your HVAC according to its design specifications; obtain-ing more out of your unit than what if was designed for (as for new additions)may only introduce problems. Consult your HVAC specialist.

q 8. Maintain your HVAC according to the manufacturer’s directions.Change filters regularly and watch for deterioration of system components;repair or replace them immediately .

q 9. Be cautious about reducing the outdoor air damper control setting to save energy becauseyou can unknowingly create an indoor pollution problem.

Hospitality Industry Wastestream: Indoor Air Pollution 35

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A Tool Kit for Environmental Management

CFC System Service

Use Certified Specialists On-Site CFC Recycling

HCFCs

Replace CFCs With HCFCs

CFCs create a hazardous environmental situation. Only a certifiedspecialist should replace CFCs with less hazardous

HCFCs, or non-CFC refrigerants.

Hospitality Industry Wastestream: Used Refrigerants

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Replacing Compressor?Go to Non-CFC/HCFC Units

You can minimize your environmentalconcerns if you manage your

refrigerants properly.

Hospitality Industry Wastestream: Used Refrigerants 37

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8 . U s e d R e f r i g e r a n t s

l Cooling and freezer systems are critical elements of the hospi-tality industry wherever there are food- or bar-related services.These units have traditionally used what is known as Freon@.

l There is a large family of Freons®, mostly known for use inautomotive air conditioning units, home air conditioning systems,

and industrial freezer and air conditioning systems. They have alsobecome known by their chemical name “chlorofluorocarbons,” or

l CFCs have been implicated as major contributors to the destruction of the earth’s stratosphericozone layer. When CFCs are released into the atmosphere by faulty systems, routine maintenance,or disposal (before current regulations), their chemical components eventually arrive at thestratosphere and react with ozone. Multiple reactions deplete the ozone at this crucial layer - alayer that provides essential protection to man, animal, and plant life from harmful sun rays.

• The United States and many countries have outlawed new production of CFCs, thus reducingthe amount of this chemical that can be released. This has now become a critical issue within thehospitality industry, and other industries where cooling and freezing are necessary.

aaa P o l l u t i o n P r e v e n t i o n C h e c k l i s t aaa

q 1. Cooling and freezing systems typically use a Freon@ called R-12 (for medium tem-peratures) and R-502 (for low temperatures). Both are CFCs and on the list for elimination.

q 2. When service of your cooling and freezer systems as necessary, use only trained andcertified technicians.

q 3. Immediately repair all CFC leaks in your systems. Your service technician should testyour system to ensure that there are no hidden leaks.

q 4. You can often capture, recycle and reuse your R-12 and R-502. This is the best man-agement practice as well as best pollution prevention option. R-12 and R-502 should never bereleased to the atmosphere. The cost of R-12 has risen from about $2.95 per pound in 1992 toover $17.00 per pound in 1994 in some states.

q 5. Depending on your specific unit specifications, you can replace your R-12 CFCs witha less harmful chemical called R-401A or R-401B (MP39 or MP66). However, these chemicals,which are called HCFCs (hydrogenated chlorofluorocarbons,) are also to be eliminated in the nexttwenty years. If you change to HCFCs, don’t forget to ask if you need to change your systemsoil; a change from the normal mineral oil to a polyoestral oil is often required.

38 Hospitality Industry Wastestream: Used Refrigerants

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q 6. If your compressor needs to be replaced, you can now buycompressors that will use a non-harmful chemical. Look for units thatuse R-134A for your medium temperature uses, and R-404A (HP62) foryour low temperature systems.

q 7. Remember to operate and maintain your systems accordingto the manufacturer’s specifications and requirements. If you’re uncer-tain what these are, contact a local refrigeration specialist.

Part I - Introduction: Definitions 39

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A Tool Kit for Environmental Management

Reduce Public Area andFacility Waste

Reduce Guest Room Waste

Bulk Products

Buy in Bulk, EliminateIndividual Packaging

Wraps, Return Containers

Solid non-hazardous waste reduction is a full-facility task. Considerall possibilities to reduce wastes sent to landfills.

Send unavoidable, recyclable wastes to local recycler.

40 Hospitality Industry Wastestream: Trash

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All Landfill Wastes

Off-site Recycling of AllWaste Materials

A “zero” waste objective isa healthy goal, but needs careful

planning and management.

Hospitality Industry Wastestream: Trash 41

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A Tool Kit for Environmental Management

9. Trash Conservationl The generation of common landfill trash is one of the largestsolid wastestreams of a hospitality industry facility. It usuallyconsists of discarded items from product packaging and shippingcontainers, to waste paper, metal, wood, and even furniture andappliances.

l Recycling one aluminum can saves enough energy to to run a tele-vision for three hours; it is also saves equivalent energy to produce 19

more. One glass bottle recycled saves enough energy to light a 100 wattbulb for four hours.

l Reducing the volume of this wastestream is an initial and primary objective. The less waste yougenerate, is less waste you have to manage, and less waste that ends up in the local landfill.

l A secondary objective is to minimize the wastes sent to the local landfill. To do this, you willconsider different forms of recycling - sending the unavoidable wastes to another location wherethey can have it turned into another product.

aaa Pollution Prevention Checklist aaa

q 1. Solid waste reduction is the initial objective. For common paper, consider the follow-ing general measures that will lessen this wastestream volume:

- Print on the front and backs of paper.- Use computer mail and central bulletin boards to reduce copies; consider voice mail.- Distribute only the copies needed; don’t just send copies out because they are on a

distribution list; route copies of larger documents.- Reduce font sizes on printed materials; increase the margins.- Review multi-copy forms you use; do your really need each page?- Use on-screen editing to reduce the number of printed copies.- Keep mailing lists current; eliminate unnecessary copies.

q 2. Buy your products in bulk, but be careful not to overbuy and loose money and increaseyour wastes through expired shelf life. When buying products, ask your distributor, or call themanufacturer, to use the minimum in paper, cardboard, and wood in packaging. Insist you sendback all containers and shipping pallets. Corrugated boxes are often the largest single source ofwaste paper in your facility.

q 3. Institute a standard conference and convention program that will reduce the generationof unnecessary materials (see 2. Hospitality Industry Function.. Conferences, page 12, for somespecific suggestions).

42 Hospitality Industry Wastestream: Trash

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q 4. Solid non-hazardous wastes are unavoidable in the hospitali-ty industry. Therefore, a companion effort should be a facility-widerecycling program. Collect all solid wastes, but rather than sending themto the local landfill, select destinations that can use your wastes and turnit into a useful product. Keep your recyclable materials as clean as pos-sible. Shop around, recycle costs will vary. Some of these suggestionsinclude the following:

- Donate unused meals to a charity organization such asa homeless shelter.

- Donate food scrapes to an organization that feeds animals.- Donate products such as shampoo, lotion, conditioner, etc., to

a local shelter.- Don’t throw away your depleted printer and copy machine

cartridges - send them to a recycling center or turn them inon your next cartridge purchase for a rebate.

- Donate used linens to a shelter.

q 5. A facility-wide recycling program requires senior management commitment. Form acommittee to make sure there is follow-through and to share the load. Recycle programs arelong-term, so think long-term.

q 6. Do an inventory of what your throwing away. Use this to help shape your programand select your recycling service provider.

q 7. The collection system is a key element of your recycling program. Design it so thateveryone can participate, including personnel in offices, kitchens, bars, and maintenance, andeven your guests.

q 8. A successful recycling program requires constant feedback. Establish some form ofnotices to let everyone know its progress. Relate savings it back to the natural resources thathave been saved through the program.

q 9. Use textile products instead of disposable products (i.e., napkins, hand towels, clean-ing towels). Use worn-out wipers as rags.

q 10. Reduce the quantity of advertisements, notices, guides, etc., in the guest rooms.

q 11. Always separate your hazardous wastes from your non-hazardous wastes. Hazardouswastes require different managing, storing, transporting, and disposal methods. Mixing non-haz-ardous materials (i.e., water, paper, scrapers, cardboard, and other liquid products) into your haz-ardous wastes increases hazardous waste volume and all related costs.

q 12. Promote your solid non-hazardous waste reductions to your guests, conference andconvention planners, and internal staff. Let everyone know about your progressive environmen-tal management.

Hospitality Industry Wastestream: Trash 43

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A Tool Kit for Environmental Management

Consider Participating inEPA’s National Programs

Facility Lighting and HeavyElectrical EquipmentEnergy Conservation

Guest RoomEnergy Conservation

Conservation of energy begins with the smallest energy-consumingdevice. Use a full-facility approach because great savings

can often be obtained in all areas.

44 Hospitality Industry Wastestream: Energy

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Electronic EquipmentEnergy Conservation

Hospitality Industry Wastestream: Energy 45

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10. Energy Conservationl No single program will save you money faster than one whichincreases your facility’s energy efficiency.

l Most facilities can reduce energy use by at least 30% or more,with rapid paybacks.

l Replacing a common incandescent light bulb with an energy-effi-cient compact fluorescent has a payback period of less than one year.

l Switching one compact fluorescent for an incandescent bulb saves 158kilowatts per year per socket. Approximately 300 pounds of CO2, 1.4 pounds of SO,, and 0.8pounds of NO, pollution will also be saved per year per bulb.

l Major energy conservation ideas for your facility center on four areas: (1) lighting, (2) heatingand cooling, (3) office electronic equipment use, and (4) facility support equipment operation.

l Whatever your energy expenditure, cutting them will boost your bottom line. An immediate 20to 30% reduction in energy use is usually possible in most facilities. Energy management may beyour easiest route to increased profitability.

The Six Steps to Saving Energy Dollars in Your Facility

1. Tabulate your last two years of energy use and costs. Break down your energy use andcosts by natural gas consumption, electricity consumption, heating oil use, coal consumption, andother energy source uses. This record will become your baseline to gauge the effectiveness ofyour pollution prevention energy program.

2. Do a simple energy audit. Conduct a walk-through of your facility and take a good lookat how and where you use, and waste, energy. If you need help with the audit, call your local pri-mary energy provider. Ask your employees and co-workers for their support and ideas.

3. List energy reduction options. Tabulate the cost to implement and the net savings likelyto result from each energy saving option. Use the energy saving ideas listed in this section.

4. Prioritize your energy reduction options. Include simple energy saving ideas such assetting thermostats down two degrees.

5. Do each energy reduction option on your list. If you cannot afford to complete alloptions, do at least your top three. Implement one option at a time before moving on to the next.

Keep track of your energy savings. Match month to month against your previously tab-ulated two-year record. See if what you have done is working, how much you are saving, andwhere improvements can be made.

46 Hospitality Industry Wastestream: Energy

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aaa P o l l u t i o n P r e v e n t i o n C h e c k l i s t aaa

L i g h t n i n g

q 1. Replace all incandescent bulbs throughout your facility withhigh efficiency compact fluorescent bulbs. Where possible, convert to T-8 fluorescent tubes from incandescent bulbs.

- Dual fluorescent T-8 fixtures with bulbs can cost less than$10.

- Be sure to convert your drop-lights throughout the shop.- Compare total costs over 10,000 hours for a compact

fluorescent versus an incandescent bulb; savings per bulb isgreater than $25.00 (@ 9cents/kWh).

q 2. Remove unneeded lamps. “Delamping” can be highly effective since many buildingswere designed and built in an era when energy efficiency was not a high priority.

- Most mechanical repair work is done with drop-lights forlocal illumination. Area lighting can be reduced in most cases.

q 3. Remove two lamps of four-lamp fluorescent fixtures. In common four-lamp fixtures,you have the choice of removing either the two outer-most lamps or the inner pair. If the result-ing lighting is insufficient, consider re-lamping with two brighter, triphosphor or T- 10 lamps. Formaximum energy dollar savings when removing lamps, disconnect the ballast.

q 4. Make “flick the switch” your facility policy for all regularly traveled and used areassuch as restrooms, meeting rooms, lunch rooms, and storage areas. Use a label or sign next toevery switch to remind people to turn it off. Occupancy sensor switches can be especially use-ful.

q 5. Purchase simple occupancy sensors for less than $100. These can be highly energyefficient. The sensor turns the lights on when it senses someone coming into the room or area,and then turns the lights off several minutes (variable and controllable) after the person has left.

q 6. Install more efficient ballasts when replacing burned out ones. Purchase electronicballast. These use much less power than magnetic ballasts and can operate all the common typesof fluorescent tubes. Dimming ballasts are also now available in electronic versions.

q 7. Review all of your large-area and outside lighting requirements. HID (high intensi-ty discharge) lights are extremely energy efficient and perform exceptionally well in these areas.Consider switching to such HID lights as mercury vapor, metal halide, and sodium lights. Thebest sodium lights for most uses are the golden-white high pressure sodium (HPS) lights whichgive fairly good color rendition.

q 8. Contact EPA’s Green Lights voluntary program for excellent tips on energy reductionusing proven state-of-the-art technologies (202 233-9578).

Hospitality Industry Wastestream: Energy 47

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aaa P o l l u t i o n P r e v e n t i o n C h e c k l i s t aaa

H e a t i n g a n d C o o l i n g

q 1. Take measures to keep all access doors closed. Substantialheat loss or gain occurs when these doors are opened to let vehicles orpeople pass. Attacking this problem area with the following steps usu-ally leads to large and immediate energy savings.

- Install an automatic “electric eye” door opener/closer thatkeeps the door open only when a vehicle is passing.

- Cut a small, person-size door in large service doors if outsideaccess to the service area is through an overhead bay door.

- Wire heaters or air conditioners in the service area to turn off automaticallywhenever the overhead doors open.

- Install new flexible molding and weather stripping around each overhead doors atleast every three years.

q 2. Keep interior doors closed that separate general service areas from other areas wheretemperature is highly regulated. Use self-closing doors with weather stripping.

q 3. When installing or changing windows be sure to use at least double pane “low E”(low emissivity) windows with thermal resistance (R values) of two to eight. Single pane win-dow glass has a very low thermal resistance of only 0.9.

q 4. Maximize your heating and cooling cycles by installing small programmable ther-mostats in place of manual thermostats. These controllers can be purchased for under $90 andcan be programmed to control temperatures throughout the workday, and during off hours.Typical savings can reach up to 30% by minimizing the operation of your heating, ventilating,and air conditioning (HVAC) system. Keep all thermostats located in public areas locked. If notprotected in some way, settings can easily be changed incorrectly.

q 5. Reduce the heat loss from excessive exhaust fan operation. For example, in restroomsfans sometimes run continuously. Consider linking your occupancy sensors not only to yourlights, but also to your exhaust fans.

q 6. In rooms with high ceilings, install ceiling-mounted paddle fans to help “de-stratify”the warm air layer which collects near the ceiling. Very significant energy savings can be real-ized since the ground-level thermostats need not be set as high.

q 7. Service your air handling equipment regularly, and only operate within the manufac-turer’s specifications.

48 Hospitality Industry Wastestream: Energy

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E q u i p m e n t O p e r a t i o n

q 1. Carefully inspect all air compressor, delivervalves, connections and flanges, and quick-release valves. Check forworn air cylinders. Leaks in these areas are major sources of energy loss.

q 2. Seal all line leaks or replace the high pressure hose completely.This should be at the top of the list for compressor pollution preventionaction.

q 3. Lower your air compressor regulated line pressure to the bottom end of the opera-tional window. Pressures in excess of 80 psi will waste significant amounts of energy. If low-ering your pressure poses a performance problem, install a larger compressed air tank.

q 4. Operate your compressor at set periods for recharging your compressed air tank,preferably only in the early morning hours just before your mechanics come to work.

q 7. Make “turn it off’ a policy throughout your shop with reminder signs and equipmentshut-off timers where possible.

- Computers, copiers, printers should not be left on all day unless they areused constantly.

- Shut off all office equipment over night. Timers can be installed to ensure thatequipment is shut down at the end of the work day.

q 8. Install simple and inexpensive “Voltage Controller Monitors” on all of your facilityelectric motor-driven equipment.. These devices monitor motor energy needs and regulateincoming voltage so that appliance motors receive only the electricity needed.

q 9. When worn out equipment must be replaced, choose the most energy-efficientreplacement, properly sized to meet the needs of the job. New energy-efficient motors canreduce electricity consumption by up to 30% compared to similar motors manufactured 15 years.

q 10. When buying new computer equipment, buy only those that are endorsed by EPA’sEnergy Star Program. They automatically turn-off display monitors and other electronics whena programmable time has expired, and turn back on when they are accessed. This can be a greatenergy-saving technique in offices.

Hospitality Industry Wastestream: Energy 49

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A Tool Kit for Environmental Management

Water Alliancesfor Voluntary

Efficiency

Guest and Public Water Devices

Consider Participating in EPA’sNational Program

Use Advanced Technologies

Water conservation begins with the smallest water uses. Use advancedtechnologies and methodologies on a full-facility basis.

Learn about EPA’s voluntary program (WAVE).

50 Hospitality Industry Wastestream: Water

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GroundsMaintenance

Use Xeriscape and ConservationMethods

You can minimize costs and conserve anatural resource by applying advanced

methods and technologies.

Hospitality Iudustry Wastestream: Water 51

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11. Water Conservationl The hospitality industry consumed over 154 billion gallons ofwater (est) in the mid-1980s, at a cost exceeding $346 million.

l At that same time, an average lodging room in the United Statesconsumed 52,500 gallons, or 144 gallons of water per day.

l Today there is more concern for water conservation, and theimplementation of technologies can still result in significant improve-

ments in water conservation. Less water used reduces your operatingcosts, increases your profits, and conserves another natural resource.

The Six Steps to Saving Water Dollars in Your Facility

1. Tabulate your last two years of water use and cost. Break it down by water consump-tion and cost. This record will show you where your large water uses are, and will become yourbaseline to gauge the effectiveness of your pollution prevention water conservation program.

2. Do a simple water audit. Conduct a walk-through of your facility and take a good lookat how and where you use, and waste, water. Ask your employees and co-workers for their inputsand ideas.

3. List water reduction options. Tabulate the cost to implement and the net savings likelyto result from each water saving option. Use the water saving ideas listed in this section. Consultyour local vendors for additional water conservation ideas and products.

4. Prioritize your water reduction options. Target your vehicle washing area for waterconservation measures.

5. Do each water reduction option on your list. If you cannot afford to complete alloptions, do at least your top three. Implement one option at a time before moving onto the next.

6. Keep track of your water savings. Match month to month against your previously tab-ulated two-year record. See if what you have done is working, how much you are saving, andwhere improvements can be made.

52 Hospitality Industry Wastestream: Water

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q 1. One major source of waste originates from leaking toilets,sinks, bathtubs, and showers. Leaks are easy to find and easy to fix.Failing to fix them costs you money every day - often far more than thecost to repair.

q 2. Consider new, advanced water conservation technologies andproducts that are available to your facility:

- Low flow shower heads for each guest room. Thesereduce the amount of water used by guests while fullyresponding to their needs.

- Low flush toilets for each guest room and public restrooms. These also reducewater consumption without impacting your guest’s comfort.

- Flow restrictors in all sinks.- Low flow aerators.- Restrictors in all guest room sinks and kitchen sinks, and in public restrooms.- In-line flow reduction devices.- Low flow basin faucets.- Greywater to supply toilets.

q 3. If you have outdoor watering requirements for grounds maintenance consider theinstallation of a simple rain sensor. This device will automatically shut down your watering sys-tem during a rain event and cut water waste. Other ideas include:

- Using well water to irrigate.- Greywater for irrigation.- Capture rainwater from roofs and other collection points for irrigation.- Recover condensate from chilled water coils.

q 4. If you have a poorly insulated hot water storage tank or uninsulated distribution pipes(especially associated with your vehicle washing area), add an insulated jacket or “wrap” to yourhot water tank and tubular insulation on the pipes to reduce “stand-by” hot water heat loss. Ifyour hot water tank is hot or warm to the touch, it needs insulation.

q 5. Encourage your employees to conserve water by placing a self-stick “Please Turn Offthe Water” green label near each sink, bath, and shower faucet as well as hose outlets. Water con-servation should be everyone’s business.

q 6. Put splash rails around your swimming pool to minimize drain-off.

q 7. Serve water upon request only in your food service areas.

q 8. Reclaim your laundry water for reuse.

q 9. Reclaim your dishwashing rinse water

Hospitality Industry Wastestream: Water 53

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Some hospitality facilities have vehicle maintenance aswell as the more traditional tasks. If this applies to you,consider obtaining the Automotive Body Shop andAutomotive Repair Shop Tool Kits. Vehicle maintenancecan be a major source of hazardous waste generation aswell as air and water pollutants - all of which can be sig-nificantly reduced. These 17 wastestreams also includewater and energy conservation.

14. Body Repair

1. Fluids Managementq Do you have this waste stream?

7. Used Antifreezeq Do you have this waste stream?

q Do you have this waste stream?

8. Used Batteriesq Do you have this waste stream?

Engine

Transmission

Differential

6. Spent Filtersq Do you have this waste stream?

10. Used Oils & Lubricantsq Do you have this waste stream?

54 Hospitality Industry Function: Vehicle Maintenance

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3. Paint Booth Filtersq Do you have this waste stream?

5. Rags and Absorbentsq Do you have this waste stream?

9. Paint Handling and Cleanupq Do you have this waste stream?

12. Used Tires and Rubber Productsq Do you have this waste stream?

stream?

13. Vehicle Washing Wastewaterq Do you have this waste stream?

Hospitality Industry Function: Vehicle Maintenance 55

4. Parts Washersq Do you have this waste stream?

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POLLUTION PREVENTION IS JUST GOOD BUSINESS. It need not be expen-sive, nor put you at risk with your local environmental regulatory agency. And you nolonger must choose between being environmentally progressive at the expense of yourproduct quality nor your production rate. Reducing your environmental impact alsoreduces your environmental liabilities and environmental regulatory obligations!

56 The 9-Step Pollution Prevention Action Plan

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Environmental RegulationsAlmost every service or manufacturing business is subject to federal, state and local environ-mental regulations because of the products it traditionally uses to accomplish its tasks. Acrossthe United States, the U.S. Environmental Protection Agency (EPA) has treated the various fed-eral regulations as different programs, often with different inspection teams and enforcementresponsibilities. Except for a few states, the federal government has been delegated the respon-sibility to states for developing its own environmental laws, with companion regulations, inspec-tions and enforcement. In some cases, this has now been replicated at the local municipalitylevel.

Within this complex regulatory structure, the small- and mid-size service and business ownershave had great difficulty in not only understanding their regulatory obligations, but effectivelycoordinating with the appropriate inspection and enforcement personnel. At the same time, theenforcement actions of the federal and state environmental agencies have significantly increased,with resulting fines and even civil penalties. Even worse, because of these laws and regulations,the costs of hazardous waste management, transportation, and disposal has spiraled. The liabil-ity associated with using hazardous materials is almost boundless.

With all these pressures, the small- and mid-sized business owner must find a way to manage hisor her environmental concerns, not as a special issue, but as an integrated part of daily businessactivity. Using pollution prevention techniques and methodologies, many of the environmentalissues, challenges, and risks can be significantly reduced, while maintaining complete indepen-dence in building a business for the future. The more a business can do to eliminate its involve-ment in activities that come under the environmental scrutiny of the federal, state, and local gov-ernments, the lower the costs and risks.

However, during this transition period, owners and managers must be aware of the environmen-tal laws that might affect his or her activities. Being informed will help avoid problems andunnecessary expenses. The following sections of this tool kit are designed to bring an initialawareness to the business owner of the primary environmental laws that will certainly affect himor her until the cause for outside scrutiny has been successfully eliminated.

The following sections address eight primary laws, including those regulated by federal and moststate agencies. While each law has a reason for existing, every business owner must understandhow it affects the business operations, and he or she must take the necessary steps to fully com-ply with the associated obligations. This tool kit discussion identifies some of the major elementsof each law, with flags to the business owner for certain responsibilities.

. . . the small- and mid-size business owner must finda way to manage his or her environmental con-cerns, not as a special issue, but as an integratedpart of daily business activity.

Environmental Regulations 57

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Clean Water Act (Federal)See Page 82

Environmental Regulations

Clean Air Act (Federal)See Page 80

State Water Quality RegulationsSee Page 82

59

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Clean Air Act (CAA) (Federal)& State Air Quality Regulations

l The Clean Air Act (CAA) was passed by the United StatesCongress in 1970, as a vehicle for the prevention and control ofemissions into the air of substances that may harm the public

health or natural resources.

l This act includes regulations for both stationary sources of air pollu-tants (factories, businesses, etc.) and mobile sources (automobiles, trucks,

and airplanes).

. The U.S. Environmental Protection Agency has been delegated full national responsibility todevelop, inspect, and enforce all relevant regulations.

l Most states have been delegated the primary responsibility for inspection and enforcement ofsimilar air quality regulations and if they have equal to, or more stringent regulations than estab-lished under the federal CAA law.

l Under this law. the federal government is completely phasing out the availability of chemicalsthat adversely affect the earth’s ozone layer.

Air Emissions

a Many companies are subject to these air quality regulations since they routinely emit haz-ardous air pollutants in the form of volatile organic compounds (VOCs).

a Most states strictly regulate all such sources because they directly contribute to the forma-tion of ground-level ozone, better known as the “brown cloud.” These compounds are present ina variety of hazardous liquid products. They rapidly evaporate and then photochemically reactwith sunlight to form ozone pollution, or smog.

a Most states have listed over one hundred chemicals that it considers to be toxic (hazardous)air pollutants (a list is included in the Resource Manual).

a Most air permits holders are required to implement some form of Reasonably AvailableControl Technology (RACT) in order to minimize air emissions.

60 Environmental Regulations: CM

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Clean Water Act (CWA) (Federal)& State Water Quality Regulations

l The Clean Water Act (CWA) was passed by the United StatesCongress in 1972, to provide a vehicle for regulating the directand indirect discharge of pollutants into the country’s surface

waters. Direct discharges or surface discharges occur from indus-trial sources and municipal wastewater treatment plants.

l A federal program was developed by the U.S. Environmental ProtectionAgency (EPA) called the National Pollutant Discharge Elimination System

(NPDES) to regulate direct discharges.

l Most states have been delegated the primary responsibility for inspection and enforcement ofsimilar solid waste regulations.

Indirect Wastewater Discharges

a Industrial wastewater being discharged by companies are typically routed to the localPublically Owned Treatment Works (POTW) through city-owned sewer systems. Through localmunicipal codes, the POTW establishes quality constraints on all companies that discharge waste-water to them. These quality requirements not only include levels of acceptable chemicals, theyalso regulate wastewater pH, and the presence of oils.

a Industrial wastewater pretreatment processes may be required to consistently ensure thatthe discharge to the POTW is within acceptable limits.

a Any company that is issued a wastewater discharge permit must monitor the quality ofwastewater discharge to ensure that the limits are not exceeded at any time of operation.

a Stormwater discharges are regulated under the CWA and respective state regulations.These are focused on facilities where rainwater runoff is collected by the city’s storm drain sys-tem, and dumped into local surface water.

a Analysis of stormwater runoff may be required to verify runoff is within acceptable quali-ty limits.

62 Environmental Regulations: CWA

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q 1. Complete any wastewater discharge surveys released bylocal municipalities.

q 2. Survey your facility to see if you are discharging any-thing into the municipality sewer system except domestic dis-charges through kitchens, restrooms, etc. Note any work-relateddischarges and the constituents in the discharge. If you haveunused floor drains, seal them off to preclude accidental release ofregulated materials into the sewer system.

q 3. If you do discharge into the municipality’s sewer system, contact themunicipality regarding the need for a permit.

q 4. Complete permit requests as appropriate.

q 5. Prepare a plan to ensure that your discharges do not violate your discharge permit. Apretreatment system may be required.

q 6. Take periodic samples and conduct analysis of discharges to verify that they are with-in the discharge permit criteria.

q 7. Do not release any materials into the municipality’s storm drains.

q 8. If you have rainwater runoff from your facility that might contain regulated compounds,contact your local regulatory agency for possible stormwater permit.

q 9. Maintain all permit, analysis reports, and product usage records for up to five years.

q 10. Prepare and submit all required local and state water-related discharge reports.

Environmental Regulations: CWA 63

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Emergency Planning andCommunity Right-to-Know Act

(EPCRA) (Federal)

l In October of 1986, the President signed into law an act that forthe first time would require industries and businesses to report

chemical use information to the public and take part in local emer-This is known as the Emergency Planning and

Community Right-to-Know Act (EPCRA).

l There are four major parts of EPCRA, including: 1) emergency planning at the state and com-munity level, 2) emergency notification of chemical accidents, 3) community right-to-knowreports regarding hazardous chemicals, and 4) toxic chemical release reporting to the public.

l Under this law, Local Emergency Planning Committees (LEPC), and State EmergencyResponse Commissions (SERC) are required. Contact your state environmental regulatoryagency for references to your cognizant LEPC and SERC.

Community Responsibilities

a Companies may be required to take part in their community’s emergency planning processif they have “Extremely Hazardous Substances” (EHSs) above the designated “ThresholdPlanning Quantities” (TPQ) at their facility. Each EHS has been designated a TPQ which stipu-lates a storage level of concern if the entire quantity of the substance were accidentally released.The EPA has listed over 400 EHSs. Planning quantities can range from one pound to 10,000pounds.

a The second part of EPCRA requires companies to immediately notify national, state andcommunity emergency response groups in the event that a hazardous chemical is accidentallyreleased off-site above “reportable quantities” (RQ). The RQ for hazardous chemicals rangesfrom one pound (for EHSs), up to 10,000 pounds.

a The third part of EPCRA, the Community Right-to-Know part, concerns reporting theamounts of hazardous chemicals that are present on-site. Companies that have individual haz-ardous chemicals or EHSs on-site above specified thresholds must submit detailed information tocommunity and state planning groups. Reporting thresholds range from several pounds to 500pounds for EHSs, and up to 10,000 pounds for most non-hazardous chemicals.

a The last part of EPCRA is the Toxic Chemical Release section which requires companiesto report the type and amount of releases of toxic chemicals that occurs from their facility.

There are approximately 320 toxic chemicals, which, if a company uses in excess of a des-ignated amount in one calendar year, must provide the Toxic Release Inventory (TRI)

Form R. A company is exempt from this requirement if it has fewer than 10 full-timeequivalent employees.

64 Environmental Regulations: EPCRA

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q 1. Prepare a total list of all materials and quantities you purchased during the calendar yearthat are on the EPCRA lists subject to reporting.

q 2. If you exceed the EHS threshold planning quantities, you must prepare specific reportsfor the community and state emergency planning commissions.

q 3. If you exceed the reporting thresholds of the quantities of materials stored on site, youmust prepare specific reports.

q 4. If you employ more than ten full-time equivalent persons during the calendar year, andyou release (use) chemicals in quantities above the reporting thresholds, you must prepare a ToxicRelease Inventory (TRI) Form for your state and the EPA.

q 5. Keep records of all regulated chemicals purchased during each calendar year, togetherwith the quantities actually used during the year. These records can be used to track pollution pre-vention program progress, and used for determining reporting requirements under EPCRA.

Environmental Regulations: EPCRA 65

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OSHA Hazard Communication(HazCom)

l Federal law guarantees the rights of employees to know aboutthe chemical hazards present in their workplace. These rights areprotected by a national standard created by the OccupationalSafety and Health Administration (OSHA) called the Hazard

Communication (HazCom) Standard.

l The HazCom Standard was developed by OSHA in response to thegrowing number of companies using hazardous chemicals.

l It is estimated by OSHA that approximately one in every four workers is exposed to one or morechemical hazards. Exposure to hazardous chemicals can cause serious health problems and posepotentially dangerous situations in the workplace.

It is important to understand that HazCom does not apply to hazardous wastes, but rather to haz-ardous products or raw materials.

Hazard Communication

a Employee right-to-know begins by requiring chemical manufacturers to assess the hazardsposed by the substances they produce. Manufacturers must supply this hazard information to theirpurchasers by including a Material Safety Data Sheet (MSDS) with each substance sold. TheMSDS must have the identity of all hazardous chemicals included in the product, along with thephysical and chemical characteristics and health hazards posed by the chemicals.

a Under HazCom, each company must create a written program which identifies amongother things, the hazardous chemicals found on-site and the methods to be used to communicatethese hazards to employees.

a Each company must comply with standards for labeling containers of hazardous sub-stances. Each company must also maintain MSDSs at convenient places in the facility for easyaccess by all employees involved in working with hazardous materials.

a The HazCom standard is a performance-oriented rule. Almost all of the requirements arestated in terms of objectives to be achieved rather than methods or means an employer needs touse to achieve those objectives. For example, companies may educate their employees in anymanner they see fit, as long as the employees are informed of the necessary information. Thereis no mandated way to train employees, but they must demonstrate the appropriate work habitswhenever working with hazardous chemicals. This usually entails wearing protective clothing,safely handling chemicals, and knowing the appropriate response actions for accidental releases

66 Environmental Regulations: OSHA HazCom

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q 1. Request Material Safety Data Sheets (MSDS) with every product. Do not accept anyproduct sample without an accompanying MSDS.

q 2. Review your MSDSs and understand what chemicals you are bringing into your shopand what health and safety problems they may pose.

q 3. Make sure all containers of hazardous materials are labeled and the MSDS can be foundeasily in an emergency.

q 4. Organize all MSDSs by work area and make them available to all employees.

q 5. Develop a hazardous waste training plan.

q 6. Establish a hazardous waste training session for all employees that handle hazardouswastes. You can purchase good training aids that fulfill this need.

q 7 Keep records of when each employee is trained.

q 8. All records must be kept for at least five years.

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Resource Conservation andRecovery Act (RCRA) & StateHazardous Waste Regulations

A solid waste is any solid, liquid, or contained gaseous materialthat you no longer use, and either recycle, throw away, or store until

enough is accumulated for treatment or disposal. You, the generator,are fully responsible for determining if any of the wastes you gener-

ate are hazardous.

a A waste is considered hazardous under RCRA if it has been “listed” by EPA as one of over400 manufacturing process wastes or discarded chemical products.

a A waste may be a characteristic hazardous waste if it is ignitable (easily combustible orflammable, with a flash point of 140°F. or less), corrosive (dissolves metals or other metals, witha pH less than or equal to 2, or a pH equal to or greater than 12.5), reactive (unstable or under-goes rapid or violent chemical reactions with water or other materials), or toxic (a high concen-tration of heavy metals, solvents, or pesticides).

a Acutely hazardous wastes are regulated in smaller quantities, and are also subject to solidhazardous waste regulations. (See Resource Manual)

a You must determine in which category falls your chemical wastes, and you are responsiblefor all associated storage requirements and recordkeeping.

- Conditionally Exempt Small Quantity Generator (CESQG) generates no more than 220pounds of solid hazardous waste, or 22 pounds of acutely hazardous waste in any monthduring the reporting year.

- Small Quantity Generator (SQG) generates more than 220 but less than 2,200 poundsof solid hazardous waste, or 2 pounds of acutely hazardous waste in any month duringthe reporting year.

- Large Quantity Generator (LQG) generates more than 2,200 pounds of solid hazardouswaste, or 2 pounds of acutely hazardous waste in any month during the reporting year.

You are restricted to the amount of hazardous waste you can store on-site.- A CESQG may accumulate up to 2,200 pounds, after which the generator is reclassified

as a SQG and has 180 days to dispose of the waste.- A SQG may accumulate no more-than 13,200 pounds before it must apply for a storage

facility permit. Once a container has been tilled, it may not be stored on-site for morethan 180 days, or 270 days if the disposal site is more than 200 miles away.

- A LQG may not store more than 13,200 pounds before it must apply for a storagefacility permit. Once a container has been filled, it may not be stored on-site formore than 90 days.

68 Environmental Regulations: RCRA

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q 1. Identify all solid waste streams in your facility.

q 2. Determine which, if any, of your wastes streamshazardous. (See Resource Manual)

q 3. Counting all hazardous waste generated during anymonth during a calendar year, determine your generator size.

q 4. If you are a hazardous waste generator, apply forIdentification Number.

q 5. Store hazardous wastes in DOT-approved drums. Use 55-gallon drums to save money.

q 6. Minimize hazardous waste generation. Purchase only what you can use. Don’t makehazardous waste by contaminating non-hazardous wastes with regulated chemicals.

q 7. Do not mix hazardous wastes. Do not mix non-hazardous materials into hazardouswastes because it just increases the volume and your disposal costs.

q 8. Properly mark each hazardous waste drum. Date it when it is filled.

q 9. Move all hazardous waste storage drums to a separate, controlled area and keep itlocked. Segregate all waste drums in storage to minimize accidental mixing if leaks occur.

q 10. Inspect the hazardous waste storage area at least weekly for bulging or leaking drums.

q 11. Select permitted, reliable hazardous waste hauler and disposal facilities. Incineratewastes if at all possible to reduce future liability. Never let anyone dispose of it in an unautho-rized manner. Remember, you are responsible for it for many years after disposal.

q 12. Properly prepare, or thoroughly verify, all hazardous waste manifests when shippinghazardous wastes off-site. Remember, you cannot keep more than the allowable quantity on-site.

q 13. Install appropriate facility and personal safety equipment for emergency response.

q 14. Develop emergency response plan and post emergency numbers.

q 15. Keep all records (manifests, analysis reports, etc.) for at least five years. Preparerequired reports to EPA and your state.

Environmental Regulations: RCRA 69

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A Tool Kit for Environmental Management

Pollution Prevention can save your businessmoney, increase facility safety, increase workerhealth, and reduce environmental liabilities.

Pollution Prevention can significantly reduce theenvironmental obligations of your business.

70 Environmental Regulations

Page 78: Pollution Prevention in the Hospitality Industrytowns water supply.He prevented the towns people from drinking contaminated water This is an example of simple, inexpensive, yet highly

Hospitality Industry

There are many sources for technicalcompliance, and financial assistance.

Use them to your advantage!!r

Professional and trade associations.

I Trade journals and environmental publications.

Local and regional universities specializingin pollution prevention.

I I

I Technical consultants and non-profit assistance.I

Department of Energy and Small Business Administration.

Federal, state, and special topic pollution preventionclearinghouses and on-line databases.

Your best source for all forms of assistanceand referral are pollution prevention

programs at the local, state, and federallevel. They are there to assist you in

decreasing your environmental footprint.Dust them! Call them!

Technical and Financial Assistance 71

Page 79: Pollution Prevention in the Hospitality Industrytowns water supply.He prevented the towns people from drinking contaminated water This is an example of simple, inexpensive, yet highly

A Tool Kit for Environmental Management

This pollution prevention tool kit docu-ment is a part of a series that has been pre-pared for a variety of industries and areavailable to support local, state, and feder-al source reduction programs.

nformation, contact...Recom Applied Solutions, Incorporated

2929 West 17th Street, Suite 207Longmont, Colorado 80503

(303) 678-9603(303) 678-9606 FAX

Recom is a small business that has been advancing the concept of pollution prevention since the 1980s.Recom works with companies of all sizes, from all industries, offering pollution prevention programs andtechnical assistance. As a part of an integrated outreach program, Recom offers federal and state agency pol-icy development and program integration, and training.

Please contact Recom if you have any suggestions you wish tooffer or corrections and improvements you may recommend.

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