Architectural Grille Environmental Management System

Environmental Management System

Architectural Grille

ENVIRONMENTAL MANAGEMENT SYSTEM ARCHITECTURAL GRILLE

PROGRAMS for SUSTAINABLE PLANNING and DEVELOPMENT

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PRATT INSTITUTE PROGRAMS FOR SUSTAINABLE PLANNING & DEVELOPMENT

Professors Jaime Stein Amy Anderson Jenn Becker

Student Consultants Susanne Antonuccie Natan Apavatjrut Leonardo Arias Lora Barnhill Joe Blankenship Elizabeth Bowler Amy Bzdak Osi Kaminer Jessica Nepomiachi Nicole Tarpey Michael Transue

Environmental Management System

Architectural Grille

TABLE OF CONTENTS INTRODUCTION........................................................................................................................1 Overview of Architectural Grille.......................................................................................1 What is an Environmental Management System?..........................................................1 Why Develop and Implement an EMS Plan?..................................................................2 Overview of ISO 14001...................................................................................................2 How to Use this Manual..................................................................................................3

TERMS AND DEFINITIONS.......................................................................................................3 METHODOLOGY.......................................................................................................................5 SCOPE.......................................................................................................................................7 ENVIRONMENTAL POLICY STATEMENT.................................................................................7 What is an Environmental Policy Statement?.................................................................7 Architectural Grille Environmental Policy Statement.......................................................8

STRATEGIES FOR EMPLOYEE ENGAGEMENT.....................................................................7 COMPLIANCE/ LEGAL REQUIREMENTS.............................................................................10 ENVIRONMENTAL ASPECTS AND IMPACTS......................................................................10 Environmental Aspect: Energy...............................................................................................14 Environmental Aspect: Solid Waste......................................................................................24 Environmental Aspect: Water.................................................................................................35

ADDITIONAL OPPORTUNITIES: EMERGENCY PREPAREDNESS..............................................46 ADDITIONAL OPPORTUNITIES: MARKETING...............................................................................53

EMS REVIEW AND UPDATE OF PLAN.................................................................................55

Environmental Management System

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INTRODUCTION The Pratt Institute Programs for Sustainable Planning and Development’s (PSPD) Sustainable Business Studio aims to teach student consulting teams how to design an Environmental Management Systems (EMS) by providing direct experience working with a local manufacturer in Brooklyn, NY. The Summer 2012 Student Consulting Team worked with Architectural Grille to develop an EMS plan based on the International Organization for Standardization (ISO) 14001 standard.

Overview of Architectural Grille Architectural Grille is a high-end custom manufacturer of bar and perforated grilles used for HVAC systems. Architectural Grille also fabricates decorative screens, artwork, furniture and fixtures in all varieties of materials and finishes. Architectural Grille has been in business since 1945, is family owned and operated and is currently located in a 50,000 square foot facility in Gowanus, Brooklyn.

Architectural Grille prides itself on using cutting-edge technology, including laser cutting, waterjet cutting and CNC punching machines in their production processes to ensure the highest quality products.

Furthermore, Architectural Grille re-uses many metal materials, including metals to decrease waste and provide a Green Grille product, made from 90% reclaimed, pre-consumer aluminum. Architectural Grille employs roughly 50 staff. The organization chart in Appendix I 9.1 outlines leadership and staff.

Source: Architectural Grille http://www.archgrille.com

What is an Environmental Management System?

An environmental management system is a framework to assist an organization in articulating its environmental values, identifying its significant environmental aspects and impacts and determining targets to reduce those impacts overtime. When integrated into the organization structure and overall business operations an EMS will help reduce risks by preventing pollution prevention and ensuring compliance. An EMS also provides an opportunity for organizations to be more efficient and organized.

An EMS plans supports integrating environmental issues into business decisions and practices across the organization-- from day-to-day staff to senior leadership. Furthermore, an EMS plan provides a platform for a business or organization to initiate and expand their efforts to green products and operations.

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More specifically an EMS: • Establishes a set of criteria for measuring environmental improvements • Reduces costs associated with production • Creates opportunities to generate revenue • Guides companies to use materials more efficiently • Improves employees’ working conditions by creating more sustainable environments

Why Develop and Implement an EMS Plan?

Most EMS models, including the ISO 14001 standard, are based on the on the “Plan, Do, Check, Act” model. By following the four steps, the plan is grounded in continual improvement and can be changed over time according to the needs of Architectural Grille. Other reasons why businesses choose to engage in an EMS process include: • Opportunities for marketing business operations alongside environmental goals • Opportunities for cost savings • Enhances reputation of being a more responsible industrial neighbor to community members, customers and investors Source: National Institute of Environmental Health Services.

• Greater understanding of compliance http://www.niehs.nih.gov requirements for evolving regulations and policies • Reduced environmental impact from production processes

Overview of ISO 14001 ISO 14001 is the world’s most recognized framework for environmental management systems. ISO 14001 guides organizations to better manage the impact of their activities on the environment and to demonstrate sound environmental practices. By providing a set of overarching standards and criteria applicable to all types of companies, ISO 14001 enables organizations to establish an effective environmental management system that is particular to its specific needs and objectives. Companies can also choose to have their EMS certified and recognized worldwide for performance standards1.

Using ISO 14001 can provide assurance to company management and employees as well as external stakeholders that environmental impacts are continuously measured and improved based on a widely accepted framework. Furthermore, ISO 14001 supports organizations in the development and implementation of an environmental policy and short and long term objectives that takes into account legal requirements and information about significant environmental aspects.

Benefits of using ISO 14001 can include: • Reduced cost of waste management • Savings in consumption of energy and materials • Lower distribution costs • Improved corporate image among regulators, customers and the public 1 For more information on IS0 14001 Certification visit: http://www.iso-quality-manual.com/eH-the-iso-certificationprocess.html

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In developing an EMS for Architectural Grille, Pratt student consultants worked with the company to guide their efforts through the planning stages of an environmental management system.

How to Use this Manual This manual is intended to give Architectural Grille a technical explanation of each strategy proposed by the Student Consulting Team. At the same time, it is intended to be user friendly and provide information in a clear and accessible manner.

To use this manual, first refer to the introductory pages, which explain the methodology that the Student Consulting team used to establish both baseline information and arrive at specific conclusions. It also outlines the scope of work. Second, refer to the environmental policy statement and the 3 categories that identify significant aspects and impacts, or in other words, areas where the Student Consulting team believes Architectural Grille’s can become even more sustainably adept. These sections are coded by color and assigned as follows: Energy is labeled in green, Solid Waste is labeled in brown, and Water is labeled in blue. Each of these sections identifies an objective and provides targets with subsequent action plans, in order to best recommend how each can be realistically implemented.

The next section discusses additional opportunities that the Student Consulting Team found to be important, which are Emergency Preparedness (labeled in red) and Marketing (labeled in orange). The last section discusses how the EMS should be reviewed and updated. Finally, an appendix at the end of the document provides quick access to key charts, graphs and also gives further explanations of a few specific issues.

TERMS & DEFINITIONS This section will identify certain terms and phrases used in Environmental Management Systems plans and used throughout this document based off of ISO 14001 general guidelines and the New York State Department of Environmental Conservation’s “Understanding and Implementing an Environmental Management System” guidebook. Additionally, common acronyms used throughout this report will be identified here.

1.1 Environmental Management System (EMS) Part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects. A continual cycle of planning, implementing, reviewing and improving the actions that an organization takes to meet its environmental obligations.

1.2 ISO 14001 The International Organization for Standardization – a worldwide federation of national standards bodies (ISO member bodies). Widely accepted, ISO 14001 is the official international standard for environmental management systems.

1.3 Environmental Policy (Statement) A company’s statement of intentions and principles in relation to the overall environmental performance of the business. The policy provides a framework for action and for setting environmental objectives and targets.

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1.4 Commitment to Compliance The organization’s commitment to achieving and maintaining regulatory compliance. This commitment is reflected in documented practices and procedures that ensure that regulatory compliance is a top priority of the organization and EMS. 1.5 Continual Improvement Recurring process of enhancing the EMS in order to achieve improvements in overall environmental performance consistent with the organization’s environmental policy.

1.6 Environment Surroundings in which an organization operates, including air, water, land, natural resources, humans, etc. and their interaction.

1.7 Environmental Performance Measurable results of an organization’s management of its environmental aspects.

1.8 Environmental Aspects An element of an organization’s activities, products, or services that can interact with the environment.

1.9 Environmental Impacts Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services.

1.10 Environmental Objectives Overall environmental goals, consistent with the environmental policy that an organization sets itself to achieve.

1.11 Environmental Target Detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.

1.12 Gap Analysis or Preliminary Review A review of an organization’s current environmental performance done in advance of, or at the beginning states of, planning the EMS. The review should cover three key areas: legislative and regulatory requirements, identification of significant environmental aspects, and an examination of all existing environmental management practices.

1.13 Pollution Prevention Use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission, or discharge or any type of pollutant or waste, in order to reduce adverse environmental impacts.

1.14 Noncompliance and Corrective/Preventative Action A corrective (or preventive) action taken to address and rectify (or prevent) a deficiency or noncompliance with environmental standards, regulations, or the EMS. 1.15 Emergency Response and Preparedness Program A program that plans and prepares for emergencies, such as employee injuries or hazardous chemical spills.

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METHODOLOGY From the week of May 17, 2012 through August 2, 2012 a group of eleven Pratt Institute Graduate students enrolled in the Programs for Sustainable Planning and Development’s summer 2012 Sustainable Business Studio developed the following Environmental Management System based on the International Organization for Standardization’s 14001 principles and guidelines. The overall goal of the Sustainable Business Studio was to introduce students to the concepts of Environmental Management Systems and to provide an opportunity for practical experience by working directly with a local New York City manufacturing company – in this case Architectural Grille – in a consulting capacity to design an EMS. During that timeframe the student consultants – whose areas of knowledge and expertise encompassed the fields of environmental systems management, city planning and law – consulted with Architectural Grille management and owners in order to gain insight on the company’s production, business and management process in order to produce a relevant EMS. The Sustainable Business Studio contained four phases – overview, discovery, analysis and delivery.

During the first three weeks of the project (overview) students were introduced to and reviewed the concepts of environmental management systems planning, conducted original research to gain insight into existing best practices and interacted with professionals in the sustainability field in order to more fully understand the implementation process. The second phase of the Studio (discovery) included an initial client meeting on June 7, 2012. The purpose of the initial client meeting was to introduce the participants of the studio to Architectural Grille management, review the scope of work to be conducted over the following weeks and finally to tour the production area in order to gain familiarity with products, process and areas of opportunity. The remainder of the discovery phase of the Studio centered on environmental analysis of Architectural Grille’s production process and operations, understanding current permits used by Architectural Grille and identifying rules and regulations that will assist Architectural Grille in going above and beyond minimum compliance thresholds.

For the duration of the third phase of the Sustainable Business Studio (analysis) students identified specific targets and recommendations for Architectural Grille. This process included identifying and evaluating the Environmental Aspects and Environmental Impacts (terms and definitions 1.8 and 1.9) related to certain activities in Architectural Grille’s production and operations. The identification of significant Environmental Aspects and Environmental Impacts was based off of student knowledge of materials procurement, production process (including machines used and the finishing process), packaging and distribution of materials and overall knowledge of products used and facility management.

After identifying each area’s Environmental Aspect and Impact, an overall rating was assigned. This rating (1 to 9, with 9 being the highest) was based off of a series of rankings (each 1 to 3, with 1 being low and 3 being high) which looked at the severity (the degree of negative environmental impact), frequency (how often based on time) and the probability (likeliness of activity occurring) of each Environmental Aspect and Impact. After each area’s activity was ranked in terms of severity, frequency and probability the rankings were summed and the overall rating determined.

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Example of Methodology: Environmental Impact s

Environmental Aspects - Elements of a business’ activities, services or products that can interact with the environment.

- What client can control or influence.

- Can be positive or negative

- Any change to the environment from business’ activities either positive or negative that result from the environmental impacts

Cause

Effect

Ranking - Based on Environmental Impacts - Four Categories used to give overall rankings: - Severity: degree of negative environmental impact - Frequency: how often based on time - Probability: the likeliness of it occuring - Rating: the sum of the 3 previous categories

Example: Area Production

Activity

Environmental Aspect

CNC Laser

Use of Energy

Environmental Impact Depletion of Natural Resource

Severity

Frequency

2

3

Probability

3

Rating 8

Upon completion and review of the initial ratings of Environmental Aspects and Impacts, student consultants met once again with Architectural Grille management on June 28, 2012 to review initial findings and fill any knowledge gaps related to production and operations. Following this meeting consultants revisited the Environmental Aspects and Impacts and identified three significant Environmental Aspects with high rankings– the use of energy throughout the production and operations process, solid waste generation and releases to water. Additional areas of opportunities were also identified based on the rating system and from input from Architectural Grille leadership– front office operations and emergency planning preparedness. See Appendix A 1.1 for a complete analysis of all of Architectural Grille’s Environmental Impacts and Environmental Aspects.

In addition to the review of initial Environmental Aspects and Impacts, students delivered and reviewed an initial draft of Architectural Grille’s Environmental Policy Statement (terms and definitions 1.3) on the second client meeting on June 28, 2012. The Environmental Policy Statement was crafted by students in the weeks leading up to the June 28th meeting based off of student knowledge of Architectural Grille’s current practices, goals and objectives, areas for improvement and the principles of ISO 14001.

Following this meeting, individual students engaged Architectural Grille in order to refine the policy statement. See Appendix B 2.1-2.3 for copies of handouts given at each client meeting, including an overview of Environmental Impacts and Aspects and the initial draft and explanation of Architectural Grille’s Environmental Policy Statement.

In the concluding weeks of the Sustainable Business Studio’s fourth phase (delivery) student consultants created detailed action plans (including helpful resources and available incentives) to assist Architectural Grille in meeting established environmental objectives and targets. Finally, student consultants created and delivered a visual presentation and detailed technical report for Architectural Grille on August 2, 2012. This document represents Architectural Grille’s Environmental Management System as prepared by Pratt Institute’s summer 2012 Sustainable Business Studio.

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SCOPE As stated in the Introduction section above, this report utilizes the ISO 14001 framework to detail an Environmental Management System for Architectural Grille. The Environmental Management System, as stated in its name, only focuses on the environmental aspects of an organization. Therefore, other necessary systems like human relations and health and safety standards are outside the scope of ISO 14001. Furthermore, ISO 14001 is focused on what the organization or business can control.

An Environmental Management System plan is not a stagnant document or piece of work – it is constantly evolving. This report fulfills the initial Plan stage of the cycle. After Architectural Grille adopts this EMS, it is up to Architectural Grille to implement (do) the plan. After plan implementation, Architectural Grille must then check the plan and evaluate its effectiveness in meeting the set objectives and targets.

Once Architectural Grille evaluates the EMS, any adjustments that will strengthen the EMS must then be implemented (act). The Plan – Do – Check – Act cycle allows Architectural Grille to utilize the EMS and truly make it their own depending on the needs of the company. Once the Architectural Grille management team receives and discusses the report, the consultants recommend that the company: • Adopt the report as part of Architectural Grille’s everyday operations • Integrate the recommendations into the procurement, production, shipping and future financial planning of the company • Inform employees and create visual cues and check-ins to ensure their comfort with new processes • Check to ensure that the recommendations are having the effect that are intended • Update the plan so that it continues to work for the organization, improves on current targets, determines new Environmental Aspects and Objectives The scope of this EMS plan has focused on the procurement, production, shipping and office areas of Architectural Grille. Further, the scope is limited by current technology, so changes will be necessary in the future to keep up with industry standards and to make improvements in Architectural Grille’s environmental aspects.

ENVIRONMENTAL POLICY STATEMENT What is an Environmental Policy Statement?

According to ISO 14001, an environmental policy statement provides a framework for setting and reviewing environmental performance commitments, objectives and targets intended to guide the actions of a company’s management, employees, customers, and suppliers.The policy statement is the key communication tool and vision statement for the EMS. What are the key Elements of an Environmental Policy Statement?

• A call to action (the policy) • A justification for the policy • Those to whom the policy should apply • Those responsible for implementing the policy • How the policy should be implemented and evaluated • Include guiding principles if necessary

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ARCHITECTURAL GRILLE ENVIRONMENTAL POLICY STATEMENT The below statement has been crafted by the consultants in conjunction with leadership of

Architectural Grille. It is subject to review and change at any time.

Architectural Grille is committed to continual environmental improvements and pollution prevention through compliance with environmental laws and regulations. Further, Architectural Grille strives for continuous improvements by going above and beyond these minimum thresholds whenever possible. Architectural Grille strives to be a socially and environmentally “good neighbor,” providing the utmost quality and environmentally sound product to the consumer base. This policy applies to all Architectural Grille employees, staff, those responsible for implementation in each department, and the top level of management. Implementation of the Environmental Management System (EMS) and Environmental Policy Statement will be executed by top management and integrated into all levels of the organization. Through Architectural Grille’s commitment to the EMS plan, Architectural Grille will continuously “plan, do, check and act” in order to evaluate, act upon and evaluate changes in the EMS program as proposed by Pratt Institute students as related to energy use, water use and solid waste contributions in the areas of procurement, production, shipping and office operations.

Architectural Grille Guiding Principles include: • Commitment to pollution prevention • Compliance with all prevalent legal and voluntary requirements • Commitment to continued investment in innovation through technological advancement in order to produce the highest quality product for our consumer base • Commitment to recycling, reuse of materials, and waste reduction in order to maximize business efficiency, environmental sustainability, and cost reductions • Commitment to manage chemicals effectively and minimize potential environmental health impacts • If possible, a commitment to expand our business in a way that provides for the creation of additional job opportunities for the local community

Implementation Team:

Date

_______________________

______________

_______________________

______________

_______________________

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STRATEGIES FOR EMPLOYEE ENGAGEMENT A successful Environmental Management System must include a commitment at all levels of the company – from top management to day-to-day workers. In order for an EMS to be successful, all employees should be involved in the process of planning, implementing, evaluating and enacting new parts of the ever-evolving EMS. The employees should understand why and how the process works, and what the goals are for the company at that specific time and going towards the future. Employees at every level of Architectural Grille must take pride and ownership in this plan in order for it to be successful.

In order for all employees to feel as though they are part of the EMS process, Architectural Grille must commit to developing strategies for employee engagement. Employee engagement should inform all employees about the plan, gather feedback regarding the plan and its effectiveness and allow room for additional input.

For example: • Creating an EMS team, including individuals at all levels of Architectural Grille, who will be responsible for implementing, reviewing, updating, and enacting changes upon the EMS • Developing an EMS training package for existing and new employees • Organizing team members to monitor specific objectives set in each area • Hosting quarterly company-wide meetings related to the EMS with ample time for review and input • Posting of signs on the production and shipping floors and front office informing staff about the EMS and specific objectives and targets • Celebrating success! When an objective’s target is met, let all employees know through e-mails, newsletters, official internal reporting mechanisms or company-wide meetings For more information on best practices for training adults in Environmental Systems Management plans, please refer to Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations, U.S. EPA, 2001 pages 39-422.

2 Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations, U.S. EPA: www.epa.gov/owm/iso14001/ems2001final.pdf

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COMPLIANCE/ LEGAL REQUIREMENTS As stated in the overview, a critical component of any Environmental Management System is maintaining compliance with current laws and regulations. In adherence to ISO 14001 standards, Architectural Grille’s Environmental Policy Statement has established a commitment to going above and beyond minimum thresholds for compliance. Identifying and accessing available resources related to the legal and regulatory requirements support the company’s commitment to environmental goals. In order to guide Architectural Grille in meeting and surpassing compliance thresholds, Pratt consultants evaluated all current permits utilized by Architectural Grille and researched additional laws and regulations at the local, state, and federal level that currently affect Architectural Grille or may in the future. A detailed spreadsheet noting current permits, valid dates for the permit, and issuing parties for permits is located in Appendix C 3.1. Details for new compliance regulations that are or may be applicable to Architectural Grille, including timeframe for compliance, description of regulation and how it affects Architectural Grille are listed below as well as in Appendix D 4.1.

In order to maintain an up-to-date compilation of legal and regulatory requirements, the leadership of Architectural Grille should visit the National Metal Finishing Resource Center web site for comprehensive information on industry standards at least once per year3.

Law/Regulation

NYC Community Right-to-Know Act

Timeframe

Submit Annually every March 1st

NYC DEP

NYC Local Law 84: Submit Annually every May 1st Benchmarking of energy and water

(Began in 2011)

NYC DEP & NYC DOF

Went into effect NYC Local Law July 1st, 2010 85: NYC Energy Conservation Code NYC DOB

3

Description

How it relates to Architectural Grille

All premises which, at any point during a calendar year, hold a hazardous substance at an amount at or above the threshold amount specified

by City regulations must file a Facility Inventory Form and pay the applicable fees.

Architectural Grille does not meet the required thresholds for mandatory submittal of a Facility Inventory Form.

However, an above compliance measure would include annual substance report consisting of quantities, storage container size and location of each substance.

Benchmarking measures the energy and water consumption of the following buildings: - Building more than 50,000 gross sq ft - Two or more buildings on the same tax lot that together exceed 100,000 gross sq ft - Two or more buildings held in a condominium form of ownership that together exceed 100,000 gross sq ft

Architectural Grille must complete an annual energy benchmark report to the DOF by May 1 of each fiscal year. Must be completed using Portfolio Manager software provided by the EPA. Owners of all buildings larger than 50,000 square feet must comply or result in escalating fees.

Requires that any element of the building directly affected by additions, alterations and/ or renovations must adhere to the New York City Energy Conservation Code (NYCECC).

The NYC DOB will not issue building permits without documentation of compliance, including an energy analysis by a registered professional.

National Metal Finishing Resource Center: www.nmfrc.org/

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NYC Local Law 87: Energy Audits & RetroCommissioning

Timeframe

Description

How it relates to Architectural

Energy efficiency reports must be filed by owner in calendar year determined by tax block number.Energy audit and retrocommissioning must be completed within 4 years of filing energy efficicency report

Applies to buildings greater than 50,000 sq ft in area. Affects basebuilding systems: Envelope, HVAC, Service hot water, Lighting and electrical, Elevators & escalators.

Requires owners of buildings to meet Benchmark criteria to perform the following: Audits: Evaluation of potential energy upgrades (retrofits), including initial cost and annual energy savings Retro-Commissioning: Repairs, cleaning, and adjustments to equipment, controls and sensors to improve performance

Audit and retro-commissioning performed and filed in an Energy Efficiency Report every 10 years.

Staggered deadlines, beginning 2013 through 2022. Department of Finance will notify owner 3 years prior to deadline.

Upgrade to current code by January 1st, 2025

Requires building owners to upgrade building’s lighting systems to meet current code by 2025, or whenever a renovation is pursued, whether it touches electrical systems or not, whichever comes first. By the same time-frame, sub-meters of electrical consumption must be installed in all tenant spaces of 10,000 sq ft or more and building owners need to provide tenants with monthly electricity consumption statements

Architectural Grille will be required to comply by 2025. In addition, if Architectural Grille undergoes renovation, they must upgrade lighting systems to comply with current code.

NYC Commercial Recycling Law

Enacted in 1992

All commercial businesses or Architectural Grille will need to comply tenants are required to recycle. with all applicable recycling and This applies to businesses who sanitation laws have their waste collected by a private carter or recycler

Resource Conservation and Recovery Act

Enacted in 1976

Requires that hazardous waste Architectural Grille may utilize of any quantity be disposed substances listed as hazardous waste of under Land Disposal under the EPA definition Restrictions

NYC DOF

NYC Local Law 88: Lighting Retrofits and Submetering NYC DOB

NYS DEC

Acronyms: NYS DEC - New York State Department of Environmental Conservation NYC DOB - New York City Department of Buildings NYC DEP - New York City Department of Environmental Protection NYC DOF - New York City Department of Finance

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ENVIRONMENTAL ASPECTS & IMPACTS A number of factors were examined in order to determine Architectural Grille’s significant Environmental Aspects and Impacts. This process informed the consultants’ work and was the basis for the following objectives, targets and action plans as they relate to the use of energy, solid waste generation, and releases to water.

As described in the methodology section of this report, a number of factors were evaluated in Architectural Grille’s production, packaging, distribution and facilities management process in order to discover Environmental Impacts and Aspects. The consultants noted all materials, machines and personnel involved in Architectural Grille’s production process (inputs), where each material went at each stage of production and finally what the end result (or outputs) was (see process map in Appendix E 5.1). This exercise enabled the consultants to prioritize specific areas of focus for the EMS: • • • • • •

Procurement Production Finishing Delivery Facility Office

Once each area was identified, each activity (and “sub-activity) as it related to each area was fleshed out. Again, this yielded several activities involved in Architectural Grille’s operations: • Use of shipping services such as UPS, Yellow Freight, etc.

• Use of raw materials and other products • Use of machinery such as the Powder Coating machine, the CNC Laser Punch, Water Jet, and Laser Jet machines • Welding, sanding, priming and application of various finishes • Use of chemicals used in production and machine and facilities maintenance • Use of office equipment and supplies such as computers, copiers and paper • Packaging final products • Use of climate control devices such as the air conditioning systems • Disposal of product packaging received and shipped After these activities were identified, Environmental Aspects (or Aspects) were identified: • • • • •

Use of raw materials and natural resources Emissions to Air Use of energy and energy emitted Solid waste generation Releases to water through various channels

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Building on these Aspects, Architectural Grille’s Environmental Impacts (or Impacts) were examined: • • • • • •

Air pollution and contributions to global warming Depletion of natural resources Contributions to landfill Hazardous fumes Water pollution and tax on sewer system Deforestation

Based on the analysis of the above areas, activities, aspects and impacts, the consultant team moved forward with recommendations relating to energy, waste, and water. For a more concise explanation of this process, please refer to Appendix B 2.2.

The following section of the report details specific objectives, targets, detailed action plans and resources for Architectural Grille.

Environmental Objectives (terms and conditions 1.10) are overall environmental goals, consistent with the environmental policy, that an organization sets itself to achieve.

Environmental Targets (terms and conditions 1.11) are detailed performance requirements, applicable to the organization or parts thereof, that arises from the environmental objectives and that need to be set and met in order to achieve those objectives.

Action plans are the means, steps, and timeframes for completion of environmental targets and objectives. These should include any compliance requirements.

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ENVIRONMENTAL ASPECT: ENERGY Objectives, Targets, Action Plan, & Resources

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ENERGY AREAS

Administration, Production, Facilities Management

OBJECTIVES

TARGETS

Objective 1: Reduce Energy Usage Target 1: Reduce 20% of electricity use by 2015.

Target 2: Initiate reduction campaign to support electricity reductions by October 2012.

Target 3: Upgrade lighting system to comply with LL88: Lighting upgrades and sub-metering by 2020.

Target 4: Reduce 10% of natural gas usage by 2015 (smaller percentages of utilities are natural gas)

Energy use is a significant aspect of Architectural Grille’s daily operations that yields many opportunities for cost-saving upgrades and conservation measures. Areas within the company that exhibit highenergy consumption are production, finishing processes, and facilities management. For the purpose of this document, the aspect of energy is characterized by its source, either as electric energy or use of natural gas. Identifying the source from which the energy comes from is key to formulating targeted action plans to mitigate further depletion of natural resources and other environmental impacts. The goal of this section is to provide guidance for Architectural Grille in maintaining its current good practices in the aspect of energy use while highlighting opportunities where the company may extend their practices beyond the level of compliance and generate energy and cost savings.

To determine the extent that energy consumption has on Architectural Grille in terms of costs, utility bills from the most recent year (2010-2011) were examined. The total annual cost of electricity for the observed year was $131,482. This amounted to almost 90% of the total annual utility costs. See chart 1. A breakdown of energy use by type indicated that 72% of total energy cost was from electric energy use while 17% came from natural gas (ConEdison, Utility Bills, 2011). Aside from utility bills, other indicators alluded to the fact that the aspect of energy consumption offers an array of opportunities for savings in costs and resources. For example, the company has already expressed interests in cleaner energy technologies such as solar panel installations and consistently strives to keep informed about the latest innovations that can increase efficiency in their business operations. This kind of forwardthinking and eagerness to build upon the company’s sustainability profile through new technology affirms that energy consumption should certainly be a focus in Architectural Grille’s environmental management system.

By identifying high energy-consumption areas within the company, objectives that Architectural Grille should aim towards are revealed. Accompanying each objective is a target, along with action plan steps detailing what Architectural Grille can do to achieve its environmental goals. In addition to the action plan steps resources are listed to offer Architectural Grille guidance and information on available incentives or financial assistance.

Chart 1: Annual Utility and Waste costs 2010-11

Source: ConEdison Utility Bills, 2011

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ENERGY Objective 1: Reduce Energy Usage

Source: http://www.excelbuildersmn. com

Target 1: Reduce 20% of electricity use by 2015

Source: http://www.indiegogo.com/theurbanconversion

Source: http://greenenergyutilitiesllc.com/

Action Plan Step 1. Establish baseline of current annual energy consumption by performing an energy audit per NYC Local Law 84, (benchmarking energy consumption) by January 31, 2013 NYC Local Law 84 requires that buildings exceeding 55,000 gross square feet benchmark their annual energy consumption using an EPA approved benchmarking tool to be submitted every May 1st to the NYC Department of Finance and EPA (refer to compliance section for more details) (source). In order for Architectural Grille to track energy use and identify cost savings generated from retrofits, a baseline of their current energy usage must be established. A list of resources towards the end of this section is intended to assist the company in contacting a professional to perform the energy audit along with available financial incentives from the City and private companies.

Step 2. Submit Annual Energy Benchmark Report per NYC Local Law 84 NYC Local Law 84 requires to submit energy benchmark report by May 1 of each year to the New York City Department of Finance using the Federal Energy Start Benchmark tool, Portfolio Manager4.

Step 3. Initiate the process of replacing existing appliances and electronic equipment with Energy Star products by January 31, 2018 Energy Star offers an array of products such as commercial appliances, computers, lighting, heating and cooling equipment. Architectural Grille may visit the Energy Star website to browse through products. (See Appendix F 6.1 for complete list of office equipment currently held by Architectural Grille and suggested phase-out cycle).

Step 4. Paint the entire roof white to mitigate “Heat Island Effect” and maintain cooler temperature within the building by May 2013 (in time for summer 2013)5 White roofs are considered “cool roofs” and studies have shown that they are effective in reducing 4 Portfolio Manager Tool: http://www.energystar.gov/index.cfm?c=evaluate_performance.bus_portfoliomanager

5 The term “heat island” describes built up areas that are hotter than rural areas due to buildings, roads, and other infrastructure in place of trees and vegetation. The annual mean air temperature of a city with 1 million people or more can be 1.8–5.4°F warmer than nearby rural areas. Heat islands can affect communities by increasing summertime peak energy demand, air conditioning costs, air pollution and greenhouse gas emissions, heat-related illness and mortality, and 16 water quality. Source: EPA Heat Island website: http://www.epa.gov/heatisld/

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air-conditioning costs. This low-cost measure (and sometimes subsidized through certain governmentfunded programs) yields great benefits to Architectural Grille in the form of monetary savings while positively impacting the environment since a reduction in energy consumption leads to a decrease in the amount of carbon dioxide being emitted into the air.

Step 5. Research “Waste Heat Recovery Technologies” to capture heat generated by machines for reuse (particularly powder-coating equipment) There are different types of “Waste Heat Recovery Technologies” available to Architectural Grille.

However, the company’s facility must be evaluated for feasibility before a system can be selected and put in place. Some key factors that must be considered are the amount, temperature, quality and composition of heat loss from the equipment. This evaluation should be conducted by a professional.

Step 6. Conduct inspection to ensure that the building envelope and associated elements (i.e. windows and doors) are properly sealed to prevent heat loss during colder months The purpose of evaluating the building envelope is to identify problems such as air or water leakage that may be compromising the building’s performance. If these issues exist, the building’s heating and cooling systems are placed in overdrive as they have to work harder to maintain optimal temperature in the building’s interior space. Solutions to problems within the building envelope range in price and labor depending on the extent of damage. Hence, it is ideal to identify the problem at its earliest stage.

Step 7. Continue exploration of solar panel installation Step 8. Perform price comparison between conversion of voltage and no-action A price comparison between going forth with the conversion and leaving conditions as is may reveal whether or not there are actual cost-savings and other benefits to the company with the conversion of voltage. Architectural Grille should consult with an electrician or engineering professional on other alternatives as well.

Responsible Party (Target 1) • • • • • •

Step 1: Joe Leto /Facilities Management and Anthony Jr. Giumenta/Owner Step 2: Anthony Macchiarola/Top Management Step 3 & 4: Fred D’Antoni/Procurement and Anthony Giumenta Jr./Owner Step 5: Stephen Giumenta/Owner Step 6 & 7: Joe Leto /Facilities Management and Anthony Giumenta Jr./Owner Step 8: Anthony Giumenta Jr./Owner and Stephen Giumenta/Owner

Review and Measurement (Target 1) Each lead staff member, as detailed in the action plan steps will review action plan steps bi-annually.

Bi-annual energy audits in January and June from implementation of action plan steps, through 2015 and annually thereafter. Monitor energy usage through monthly utility bills to look for changes and/or abnormalities.

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ENERGY Objective 1: Reduce Energy Usage

Target 2: Initiate Energy Savings campaign to support electricity reductions by October 2012

Action Plan Step 1. Assign lead front office staff to create and manage staff public awareness campaign by end of August 2012 Top Management should assign staff to research and implement a staff-led public awareness campaign.

Step 2. Create and implement building-wide awareness campaign via signage (particularly in administrative office settings), staff meetings, office management and office protocol by September 2012 The staff-led public awareness campaign should utilize signage, staff meetings, and ensure that public awareness campaign is integreated with office policy.

Step 3. Implement campaign to turn off computers and other appliances when leaving the office October 2012 To save energy, all computers that can be turned off without disrupting office or production processes should be turned off at the end of the day.

Step 4. Program thermostat to maintain office temperature of 75 degrees Fahrenheit during summer months and 68 degrees Fahrenheit in the winter months by October 2012 A moderate temperature mitigates extremes in the workplace but also saves energy by keeping the thermostat a constant temperature.

Step 5. Encourage personnel to turn off lights in unoccupied building spaces by October 2012 Throughout the staff-led energy saving public awareness campaign, leadership should encourage staff to shut off lights in unoccupied building spaces.

Responsible Party (Target 2) • Anthony Giumenta Sr./Owner • Vimarie Tilelli/Front Office Review and Measurement (Target 2) Assigned lead staff should check computers and appliances at close or start of business day for the first month to ensure all equipment has been turned off. Spot-checks to random computers should be conducted every 2 weeks for the first 6 months to ensure staff compliance. Monthly staff meetings or lunch meetings should be held to discuss any concerns and staff suggestions regarding energy reduction program. Anthony Giumenta Sr./Owner should oversee the lead front office staff implementing staff campaign plan. The consultants recommend that energy usage from electric bills be analyzed monthly to check for energy reductions. For example, if campaign begins October 2012, check previous month’s energy bill (September 2012), in addition to October 2011 for comparison with current bill.

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ENERGY Objective 1: Reduce Energy Usage

Target 3: Upgrade lighting system to comply with LL 88: Lighting upgrades and sub-metering by 2020

Source: http://www.paranormalradioshow.net

Source: http://www.renewablechoice.com/

Action Plan Step 1. Assign staff to review monthly the New York City PlaNYC website to learn about compliance with LL88: Lighting Upgrades & Sub-metering and concurrently look at Green Light, New York website for energy efficiently education and specific training6 (See Compliance Section below) Architectural Grille staff and leadership should become familiar with Local Law 88 and necessary compliance. Green Light, New York provides trainings entitled “Overview of the [NYC Greener, Greater Buildings Program] Lighting Upgrade Law & Energy Code lighting requirements; Retrofitting Lighting Systems for Energy Savings and Code Compliance; and an Introduction to Lighting Controls”7.

Step 2. Consult with professional to conduct audit for building-wide lighting upgrades by May 31, 2013 In order to make the necessary changes to comply with Local Law 88, a professional lighting consultant should be contracted in order to conduct an audit and explore options for lighting upgrades.

Step 3. Install occupancy sensors for lighting Prior to making comprehensive lighting upgrades, lighting sensors can be installed to automatically shut on and off lights that are in not in use.

Step 4. Upgrade to energy efficient lighting throughout the entire facility by 2020 (five years prior to mandated compliance with Local Law 88, 2025) As per compliance with Local Law 88, building-wide lighting upgrades should be installed to improve energy efficiency.

Responsible Party (Target 3) • Step 1: Anthony Macchiarola/Top Management; Anthony Giumenta Jr./Owner

• Step 2: Joe Leto/Facilities Management and Anthony Giumenta Jr./Owner • Step 3:Fred D’Antoni/Procurement, Joe Leto /Facilities Management and Anthony Giumenta Jr./Owner

6 7

NYC Greener, Greater Buildings Program: http://www.nyc.gov/html/gbee/html/plan/ll88.shtml Green Light NY Training Information: http://www.greenlightny.org/

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• Step 4: Fred D’Antoni/Procurement will be responsible for purchasing the light bulbs • Step 4:Anthony Giumenta Jr./Owner, Anthony Giumenta Sr./Owner will work with an installation company • Step 4: Joe Leto /Facilities Management and the porters will replace new bulbs when necessary Review and Measurement (Target 3) Joe Leto/Facilities Management, Anthony Giumenta Jr./Owner, Anthony Giumenta Sr./Owner to review feasibility of lighting upgrades and utility bills after lighting upgrades. Lighting audits to be completed prior to and following any lighting upgrades to monitor changes in energy use.

ENERGY Objective 1: Reduce Energy Usage

Target 4: Reduce 10% of natural gas usage by 2015

Action Plan Step 1. Consult with ITAC or the New York State Pollution Prevention Institute or other heating expert to gauge baseline natural gas consumption during Winter 2012/13 Establishing a baseline of the amount of natural gas used for the purposes of heating Architectural Grille’s facility is a critical first step in being able to move forward with identifying and improving upon inefficiencies related to heating and to exploring ideas for alternative heating methods.

Step 2. Identify areas in the facility where heat may escape and repair/address by Winter 2012/13 In conjunction with the energy audit performed as related to NYC Local Law 84 and consultation with ITAC, the New York State Pollution Prevention Institute or other heating expert, Architectural Grille should repair any identified areas of the building or processes that allow heat to escape from inside the building. This process will work towards a more efficient use of natural gas.

Step 3. Consult with ITAC or the New York State Pollution Prevention Institute regarding the possibilities of utilizing excess heat from the powder coating oven to assist in heating Architectural Grille’s facility by Spring 2013 Both ITAC and the New York State Pollution Prevention Institute are familiar with waste heat recovery technologies and techniques and available incentives. The New York State Pollution Prevention Institute engages in cost-sharing studies that could help Architectural Grille explore whether this is a viable option. Waste to heat recovery is dependent on many factors including age of machine, duct-work throughout building and areas of the building to be heated. This ultimately may not be a viable option for Architectural Grille, but this process should be explored with experts to determine its feasibility.

Step 4 . Build heat recapture system to complement existing heating system if professional study proves it to be a viable option by Spring 2015 If the professional study in Step 3 of this target deems waste to heat recapture from the powder coating oven a possibility Architectural Grille should act accordingly and construct said system.

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Responsible Party (Target 1) • Step 1 & 2: Stephen Giumenta/Owner and Joe Leto/Facilities Management • Step 3 & 4: Stephen Giumenta/Owner

Review and Measurement (Target 1) The above objective and target centers around Architectural Grille’s facility and a newly installed piece of equipment related to production. As such, Joe Leto and Stephen Giumenta will be responsible for oversight of this objective and target. Bi-annual energy audits established in Objective 1 will assist Architectural Grille in monitoring and correcting natural gas usage and efficiencies. If a heat recovery system is constructed, Architectural Grille should monitor its effectiveness annually thereafter.

Compliance - Energy Use8 NYC Local Law 84: Benchmarking - Benchmarking of energy and water use to begin May 1, 2011 and then by every year thereafter. Benchmarking requires the use of an EPA approved Benchmarking tool to measure the energy and water intensity of a building. As it appears in the records of the department of finance, benchmarking is required for the following buildings: • A building that exceeds 50,000 gross square feet • Two or more buildings on the same tax lot that together exceed 100,000 gross square feet, or • Two or more building held in the condominium form of ownership that are governed by the same board of managers and that together exceed 100,000 gross square feet Architectural Grille must complete an annual energy benchmark report to the Department of Finance by May 1st of each fiscal year. Building owners must complete using Portfolio Manager software provided by the Federal Environmental Protection Agency (EPA). Failure to benchmark by May 1 will result in a violation and a penalty of $500. Continued failure will result in additional violations on a quarterly basis and a penalty of $500 per quarter with a maximum of $2,0009.

NYC Local Law 85: NYC Energy Conservation Code - Went into effect on July 1, 2010. This requires that any element of the building directly affected by additions, alterations and/or renovations must adhere to the New York City Energy Conservation Code (NYCECC). The NYC Department of Buildings will not issue building permits without documentation of compliance, including an energy analysis by a registered professional. If Architectural Grille were to embark on any changes to their building envelope, the business would be required to comply with the above law.

NYC Local Law 87: Energy Audits & Retro-Commissioning – Commences in 2013; determined by the building’s tax block number, and every 10-years thereafter. This applies to buildings greater than 50,000 sq. ft. in area. It affects base-building systems such as the envelope, HVAC, service hot water, lighting and electrical, elevators & escalators. It requires owners of buildings to meet the Benchmark criteria by performing the following:

• Audits to evaluate potential energy upgrades (also referred to as retrofits), including initial cost and annual energy savings • Retro-commissioning which involves repairs, cleaning, and adjustments to equipment controls and sensors to improve performance

8 All compliance information can be found at the New York City Greener, Greater Buildings Program: www.nyc.gov/GGBP 9 Local Law 84 violations and fee schedule: http://www.nyc.gov/html/gbee/html/plan/ll84_comply.shtml#deadlines

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Architectural Grille must perform audits and retro-commissioning to be filed in an Energy Efficiency Report every 10 years. The deadlines are staggered, beginning 2013 through 2022. Department of Finance will notify owner 3 years prior to deadline.

NYC Local Law 88: Lighting Retrofits and Submetering – Upgrade lighting systems to meet current code by January 1, 2025.Requires building owners to upgrade their entire building’s lighting systems to meet current code by January 1, 2025, or whenever a renovation is pursued, whether it touches electrical systems or not, whichever comes first. In addition, by this same time-frame, sub-meters of electrical consumption must be installed in all tenant spaces of 10,000 square feet or more and building owners need to provide tenants with monthly electricity consumption statements.

Architectural Grille must upgrade lighting system to comply with current code by 2025.

Resources - Energy 1. Green Energy Solutions is an independent energy consulting company serving the north east United States. Their solutions range from upgrades and retrofits of a buildings energy infrastructure to the implementation of new alternative energy producing technologies. Their services are available to those in New York City, the five boroughs, Long Island and Westchester County New York. Contact information-Website: http://www.greenlogic.com/.

2. Associated Renewable offers a free multi-year energy benchmarking service per NYC Local Law 84 (requiring benchmarking). Contact information- Website: http://www.associatedrenewable.com/ 3. NYSERDA’s Industrial and Process Efficiency Program: The Industrial and Process Efficiency Program is a performance based program for manufacturers and data centers that promotes energy efficiency and process improvements through energy saving projects related to the facility or production process (including lighting upgrades or equipment upgrades). Manufacturers must pay into the Systems Benefits Charge in order to be eligible and incentives are calculated based on cuts in electrical or natural gas usage. Benefit incentive caps are up to $5 million per year for electrical incentives and up to $1 million per facility per year for natural gas incentives and are capped at 50% of project cost.

Manufacturers must use the Consolidated Funding Application. NYSERDA has three specific contractors -- CHA, ERS, and Willdan Energy Solutions -- who are focused on working with manufacturers and data centers to educate them about the program, its benefits, and the requirements for participation and the application process. Contact information- Website: http://www.nyserda.ny.gov/Funding-Opportunities/ Consolidated-Funding-Application.aspx. Email: IPEOutreach@nyserda.ny.gov. Phone Number: (585)232-5610 ext. 290.

4. Alex Wortman (of ERS consulting) ) can be contacted regarding the Industrial and Process Efficiency Program. ERS can assist with paperwork and the application process, meetings, technical assistance, project development and NYSERDA support (at no cost to the facility). Email: awortman@ers-inc.com Phone: (212)789-8182 Ext. 287 Basic Program Overview given by Alex Wortman at ITAC workshop on June, 2012 can be viewed online10. For more information, visit the Frequently Asked Questions11 and Program Overview12 section of the website.

10 ITAC PowerPoint Presentation: http://www.itac.org/Events/files/ERS.pdf 11 NYSERDA FAQ: http://www.nyserda.ny.gov/Page-Sections/Commercial-and-Industrial/Programs/Industrial-andProcess-Efficiency/FAQs.aspx 12 NYSERDA Program Overview: http://www.nyserda.ny.gov/Page-Sections/Commercial-and-Industrial/Programs/ Industrial-and-Process-Efficiency.aspx

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5. NYSERDA’s FlexTech program: FlexTech’s goal is to increase productivity and economic competitiveness of participating facilities by identifying and encouraging the implementation of costeffective energy efficiency, technical evaluations, process improvement analysis, energy master plans, retro-commissioning, and development of peak load curtailment plans (PLCPs) as well as combined heat & power (CHP) projects. Of particular interest to Architectural Grille may be FlexTech’s “General Energy Feasibility Studies,” which include decision-making assistance regarding equipment replacement, upgrade recommendations, energy-related design assistance, and engineering support and analysis13. Eligible applicants include New York State industrial and commercial facilities. Must have $75,000/yr in utility costs and pay into the electric or gas System Benefits Charge (SBC). For most studies, NYSERDA will contribute fifty percent (50%) of the eligible study costs, up to the lesser of either $1,000,000 or ten percent (10%) of the participating facility’s annual energy costs, based on an approved Scope of Work. Applications are being accepted through December 31, 2015 or until funds are exhausted. Applicants must use the Consolidated Funding Application and applicants can use a NYSERDA FlexTech consultant, or an independent service provider14,15. Additional helpful information is provided on their website16.

6. New York State Pollution Prevention Institute (NYSP21) is a New York State research and technology transfer center. The mission of the Pollution Prevention Institute is to provide state-wide, comprehensive and integrated program of research and technology development and diffusion, outreach and training specifically through reductions in emissions to the environment and waste generation and the efficient use of raw materials, energy and water. Programs and services offered by the Pollution Prevention Institute include directly working with companies in developing cost-effective and environmentally preferable solutions. Dave Fister, email: drfasp@rit.edu; Phone: 585-475-5398; Website: http://www.rit. edu/affiliate/nysp2i/.

7. ITAC: Industrial + Technology Assistance Corporation Matthew Goodman, Sustainability Specialist; Email: MGoodman@itac.org; Phone: 212-809-3900; Website: www.itac.org

13 FlexTech Program Information: http://www.nyserda.ny.gov/Page-Sections/Commercial-and Industrial/Programs/ FlexTech-Program/Eligible-FlexTech-Projects.aspx#feasibilityStudies 14 Consolidated Funding Application: https://apps.cio.ny.gov/apps/cfa/ 15 FlexTech Consultants Information: http://www.nyserda.ny.gov/Page-Sections/Commercial-and-Industrial/Programs/~/media/Files/EERP/Commercial/Programs/FlexTech/flextech-consultants-expertise.ashx 16 FlexTech Program Overview: http://www.nyserda.ny.gov/Page-Sections/Commercial-and-Industrial/Programs/ FlexTech-Program.aspx

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ENVIRONMENTAL ASPECT: SOLID WASTE Objectives, Targets, Action Plan, & Resources

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SOLID WASTE AREAS OBJECTIVES TARGETS

Production, Shipping, Office Objective 1: Reduce Solid Waste Objective 2: Increase Sustainability in Purchasing Objective 1 Target 1: Reduce garnet waste 50% by the end of 2014 Target 2: Recycle 100% of powder coat waste by 2013 Target 3: Isolate powder coat process from other production process by the end of 2014 Target 4: Reduce paper usage 50% by 2014 Objective 2 Target 1: Implement rag recycling by 2014 Target 2: Use 30% more sustainable packaging & paper by 2014 Target 3: Increase recycled content of paper used 10% per year starting in 2013

Architectural Grille is already integrating several key processes for reducing the flow of materials to the landfill: • Recycling nearly 100% of metal scraps and shavings • Purchasing a nitrogen generator to eliminate weekly canister replacement • Re-using some of the cardboard and pallets received with supplies to package outgoing deliveries • Installing supplies vending machines to track use of common items • Installing electric hand-dryers instead of using paper towels The solid waste Architectural Grille disposes of makes a direct contribution to landfills and depletes natural resources. Even if the actual amount of waste Architectural Grille creates does not add up to a very large number, this aspect is significant because waste stockpiles or is disposed of daily. The consultants focused on this aspect and subsequent impact because of the frequency in which it occurs.

This section details solutions for ways to divert or slow the continual accumulation of solid waste.

Architectural Grille’s production processes necessarily use a lot of raw materials and produces significant waste. Therefore, the primary objectives of the EMS as related to solid waste include: • Eliminating unnecessary waste wherever possible • Re-using as many production materials as possible • Increasing re-use or reduce impact of materials used in packaging The objectives, to decrease landfill flow and increase sustainability in procurement, were identified not only to reduce Architectural Grille’s land pollution through use of landfill resources, but also to save Architectural Grille money by recycling various items and re-using others in order to decrease spending and reduce the current trash carting bill, which currently adds up to 9,527 pounds of trash per month.

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SOLID WASTE Objective 1: Reduce Solid Waste

Target 1: Reduce garnet waste 50% by the end of 2014

Action Plan Step 1. Invest in an abrasive recycling system by the end of 2013

Garnet is a non-hazardous waste stream and is not a problem

to dispose of, however Architectural Grille could create less

waste and use this natural resource less by investing in an abrasive recycling system. It is possible to reclaim garnet with the addition of an abrasive recycling machine that prepares

garnet for reuse. As the waterjet cuts metal, only the core of

the jet is being used, which means 50 to 70 % of the abrasive

is not used and is just falls into the tank. WardJet makes a

machine, which costs around $60,000, meant to be compatible

with all waterjet systems17. If Architectural Grille uses around

5,000 pounds of abrasive a month and spends $250 per month

to clean out the tank, the savings would be $720 at 50 percent

recovery.

Step 2. Connect the garnet recycling system to the Waterjet system

Once machine is purchased, the Wardjet needs to be connected

to the Waterjet system in order to work effectively. It only takes WardJet Abrasive Recycling System

three minutes for the abrasive to travel through the recycling Source: http://www.wardjet.com

process and back to a hopper for reuse. Inside the machine there is a screen that washes the abrasive. Garnet that is not the right size for use falls through the holes in the screen and into a waste receptacle. The usable abrasive remains above the screen, goes through a dryer, and lands into a silo, where it is ready for reuse. The manufacturer suggests a mix 50% new to 50% recycled garnet back into the waterjet for a consistent cut.

Responsible Party (Target 1)

• Step 1: Fred D’Antoni/Procurement manager will be responsible for purchasing the abrasive recycling system. Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/ Top Management and Rich Cammarata/Production manager will set aside the funds to purchase the WardJet machine • Step 2: Rich Cammarata/Production manager will implement the steps necessary to integrate the WardJet machine into the production process. The staff operator of the waterjet machine will be in charge of running the Wardjet machine

17

Wardjet Information: http://www.wardjet.com/wardpro.html

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Review & Measurement (Target 1) Tracking the amounts of garnet waste generated before and after implementation will give an accurate picture of waste and natural resource savings. The more garnet being recycled, the more savings Architectural Grille will observe as compared to the past year before installation of the abrasive recycling system.

SOLID WASTE Objective 1: Reduce Solid Waste

Target 2: Recycle 100% of powder coat waste by 2013

Action Plan Step 1. Set up recycling system for mixed color used powder coat by end of 2012 Architectural Grille has a waste stream of mixed-color used powder that is necessary to dispose of. Instead of disposing this waste, the consultants recommend that Architectural Grille send this waste out to a recycler of plastics and polymers. The consultants have identified a company Polyflow that will recycle this waste into a raw material for other manufacturers18. Polyflow will try to connect small waste producers to other sources in their region, and coordinate a larger shipment. Polyflow will try to connect small waste producers to other sources in their region, and coordinate a larger shipment.

Polyflow may subsidize the cost of shipment and the consultants suggest that Architectural Grille should contact Polyflow directly for more information.

Step 2. Reduce future powder coat waste by installing a powder recovery booth to capture and isolate colored overspray for reuse by the end of 2020 Since Architectural Grille plans on expanding the amount and variety of powder coat jobs in the future, a more sustainable model would be to reuse their powder coat on-site. The plan for reducing future waste from the powder coat process should reduce the amount of waste by reclaiming and reusing powder overspray. This can be achieved by installing a powder recovery booth to capture and isolate colored overspray. When powder coat colors are separated, they can be recycled back into the hopper for reuse, with a ratio of 70% new to 30% used powder. There are filter cartridge and hyper cyclone separator type recovery booths. Architectural Grille should consider specific needs, such as the number of colors and frequency of color change, to decide which system is best. The Powder Coat Institute provides resources and information on re-use techniques and booth enclosures options19.

18 Polyflow Information and Contact: 39 S. Main St. Ste. 606, Akron, OH 44308: http://polyflow.co/index.php. To contact, email Mike Dungan, mdungan@polyflow.co 19 Powder Coat Institute: http://www.powdercoating.org/index.cfm

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Responsible Party (Target 2)

• Step 1: Rich Cammarata/Production manager should coordinate and information-share with Polyflow to implement a recycling system • Step 2: Fred D’Antoni/Procurement manager will be responsible for purchasing the powder recovery booth. Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/ Top Management; Rich Cammarata/Production manager will set aside the funds for the purchase

Review & Measurement (Target 2) Architectural Grille should track the amounts of powder coat waste generated before and after implementation. Tracking these amounts of powder coat waste will give an accurate picture of waste savings. The more powder coat being used, the more savings Architectural Grille will observe, as compared to purchased amount over the past year before installation of the powder recovery booth system.

SOLID WASTE Objective 1: Reduce Solid Waste

Target 3: Isolate powder coat process from other production processes by the end of 2014

Action Plan Step 1. Test the particulate accumulation in all areas of production to observe the travel path of powder coat by the end of 2012 Powder Coating is a very low VOC (volatile organic compound) process – the lowest of any spray finishes at Architectural Grille and is free of HAPs (hazardous air pollutants). It is a clean process that allows exhaust air from the coating booth to be returned to the factory. Inevitably not all of the powder coat is captured by the filtration system, allowing some powder to accumulate on the floor. The spray booth is open on both sides, and the opening allows this accumulated powder coat to possibly spread to other areas of production, such as the adjacent shipping area. This possible dispersal of powder coat throughout the factory can be harmful to workers outside the powder coat area, as breathing in particulates is a health risk. Also, it is not beneficial to leave the powder coat process open to external dust or dirt.

Step 2. Enclose powder coat process by the end of 2014 Enclosing the powder coat process into a separate room will prevent the power coat overspray from being dispersed into other production areas, eliminating a risk of particulate inhalation. It will also prevent unwanted dust and dirt from other areas of production from getting into the powder coat process, which could prevent a perfectly smooth finish. The enclosed room would allow for the setting of a specific temperature and humidity, as required by the powder coat manufacturer for optimal results. The use of energy for the curing oven would also be more manageable if it were in an enclosed area.

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Responsible Party (Target 3) • Step 1: Rich Cammarata/Production manager should work with a consultant to undertake the particulate testing • Step 2: Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/Top Management; Rich Cammarata/Production manager will confer on a layout and plan to submit to the Department of Buildings and Fire Department. Management team will also have to set aside funds for the purchase

Review & Measurement (Target 3) Architectural Grille should measure the amount of powder escaping to other areas before and after enclosure is installed. They should check the temperature and humidity of the enclosed room daily and compare it to the temperature fluctuations in the rest of the production area. Architectural Grille should compare the finish quality of grilles powder-coated before and after installation of enclosure.

SOLID WASTE Objective 1: Reduce Solid Waste

Target 4: Reduce paper usage 50% by 2014

Action Plan Step 1. Set-up two-sided printing on all copies By implementing this practice, Architectural Grille will be able to reduce the amount paper utilized monthly in the procurement and production processes.

Step 2. Set up file share and Dynamics CleanPrint software Architectural Grille should implement a file share system to eliminate unnecessary printouts and save time. By setting up a file share, all documents can be made available to a database and open to the necessary personnel. If the document must be edited or revised, this can be accomplished without printouts and easily emailed.

Dynamics Clean Print software allows personnel to print content, while being environmentally responsible and reducing costs by saving on paper ink through toning down the output and eliminating navigation bars in the actual print out. This software is free20.

Step 3. Attend JobBOSS training to learn more about options for integrating online billing and other paper-saving ability Local trainings are held several times per year in the tri-state area. Architectural Grille should send at least one staff person to ensure that the company is fully utilizing the functionality that it offers, including web-based billing.

20

Format Dynamics “Dynamics Clean Print” software Information: http://www.formatdynamics.com/cleanprint-4-0/

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Responsible Party (Target 4)

• Vimarie Tilelli/Front Office Manager will be responsible for evaluating these options and training office staff • Administrative staff will be responsible for learning the new systems and implementation

Review & Measurement (Target 4) Architectural Grille should do a cost analysis in six months to see whether paper use has been decreased and by what percent. If no savings have been achieved, Architectural Grille may want to consider another round of office employee training.

SOLID WASTE Objective 2: Increase Sustainability in Purchasing

Target 1: Implement Rag Recycling by 2014

Action Plan Architectural Grille can recycle rags used in finishing processes that have been soiled with oils or chemicals. The only local rag recycling program that could be located at this time are sold by ITU (Industrial Towel & Uniform, Inc.) through its partner AbsorbTech, LLC, which provides a full range of industrial launderable products called SorbITs from its plant in Pennsylvania. AbsorbTech delivers the SorbITs microfiber towels and sponges and picks them up once they are soiled. Then they recover reusable fluids and solvents, launder the towels and deliver clean ones to Architectural Grille. The AbsorbTech facility utilizes advanced processing systems for wastewater, VOC emissions and other environmental controls to keep the chemicals from the water stream.

Step 1. Contact AbsorbTech for a complimentary no obligation trial of system and products AbsorbTech offers new customers the option to test out their launderable line of absorbents (microfiber towels and sponges) for free. Architectural Grille should contact the company to have a sales meeting and choose the products that would work best for their processes21.

Step 2. Implement Rag Recycling Program Once Architectural Grille chooses the best SorbITs product for its processes, Architectural Grille should perform a cost comparison to current rag costs as well as disposal costs. The cost will vary on the amount utilized monthly and the various products available. Architectural Grille should test out the product for one year, then determine whether the same number of rags were used annually or more or fewer, and the cost compared to rag usage If financially feasible, Architectural Grille should integrate reusable permanently.

Responsible Party (Target 1) • Fred D’Antoni/Procurement manager will be responsible for purchasing the Sorbits products

• Fred D’Antoni/Procurement manager will be responsible for establishing a training team from the various machine operators/handlers, including the finishing department.

• Finishing staff and porters would be responsible for putting soiled rags in the proper location for collection 21

SorbIts website: http://www.itu-at.com/Products/SorbIts.html. Phone Number: 888-729-4884

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Review and Measurement (Target 1) ITU will send data reports, at intervals agreed-upon in the purchasing contract, to Architectural Grille with the number of gallons of solvent recovered as well as the number of rags saved from landfill for Architectural Grille to use in its environmental reporting. The number of total rags used in one year can be measured to ensure that using SorbITs does not increase overall rag purchasing, and possibly demonstrate fewer rags used per year due to increased quality of rags.

SOLID WASTE Objective 2: Increase Sustainability in Purchasing

Target 2: Use 30% More Sustainable Packaging by 2014

Action Plan Step 1. Switch to biodegradable solutions for bubble and plastic wraps Bubble wrap and plastic wrap are made of plastic polymer film. This material is considered ecologically toxic, as it takes hundreds of years to disintegrate. Because plastic polymer film breaks down slowly, bubble wrap and plastic wrap cause a significant environmental problem by taking up space within landfills.

Both plastic wrap and bubble wrap contain d2w, or oxo-biodegradable plastic technology, this is also called controlled-life plastic. Once decomposition has occurred, the only byproducts that results are small amounts of CO2, H20 and biomass that are not unhealthy for soil.

EcoBox offers Bio-bubble, which is 100% degradable bubble wrap22. There are no extra costs for BioBubble and performance is equivalent to regular bubble wrap. ½ inch bubble – 12’ x 25’ roll perforated every 12 inches, 1-3 rolls cost $25.25. ½ inch bubble 24’ x 125’ roll, perforated every 12 inches, cost $47.62.

Step 2. Purchase Biodegradable Packing Peanuts An additional alternative is biodegradable packaging peanuts made up of aerated starch, which can be reused, composed or simply disposed of by dissolving in water. This product eliminates the negative environmental impact of polystyrene peanuts because it is non-toxic. One brand, the MIGHTY I, produced by StarchTech has a unique “I” shaped design that creates an interlocking cushion of packing peanuts, which be used for packing sharp, pointed and fragile products23. It provides the receiver with disposal alternatives different from any other packing.

22 Ecobox Company website: http://www.ecobox.com/. Phone Number: 1-800-267-8711. Email: sales@ecobox.com or purchasing@ecobox.com.

23 Contact Dean Bartels, sales staff at StarchTech, by phone at: 800-597-7225(PACK) or by email at dean@ starchtech.com. For dealer locations, visit website: locations: www.starchtech.com

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Step 3. Recycle Incoming Cardboard Increase the ability to re-use incoming cardboard as a filler and wrapping product instead of plastic. This can be accomplished by using a cardboard shredder, which perforates cardboard into a flexible, weblike wrapping filler material, which can replace bubble wrap. Cardboard shredders have specialized rolling cutters that are similar to a paper shredder, except they perforate, pad, and cut the cardboard to the proper size and then the cutting cylinders process it into packing material. One model, the HSM ProfiPack 425 is an easy to use floor standing cardboard shredder is capable of shredding sheets up to 3/4” and 16” wide24. It also slices the side of wider cardboard so that the additional width may be fed through again. This or a similar machine would save Architectural Grille money by reducing the waste generated by incoming materials as well as the expense of new packaging. This shredder has a small footprint at only 27 x 19 x 38 inches, making it easy to fit into the current shipping space. The average cost of HSM ProfiPack 425 is $5,000. If it can be used to replace 50 rolls of 300-yard industrial bubble wrap per year, which costs about $25 per roll, the machine cost would be recouped in four years.

Responsible Party (Target 2) • Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/Top Management would evaluate the cost of each step and compare to current practices including the disposal cost of the non-recyclables • Fred D’Antoni/Procurement manager will be responsible for the shipping material purchases; Vimarie Tilelli/Front Office Manager would be responsible for office paper purchases • The Shipping department staff would be responsible for determining when to shred incoming cardboard, which products it would work best with, and the maintenance of the machine.

Review & Measurement (Target 2) Architectural Grille can measure the amount of biodegradable bubble wrap/plastic and starch-based peanuts purchased against non-biodegradable products previously purchase. These amounts can be recorded, showing how much waste has been diverted from the landfills. Together, these new solutions should account for 30% of the total packaging used during the 2014 year.

SOLID WASTE Objective 2: Increase Sustainability in Purchasing

Target 3: Increase Recycled Content of Paper Used by 10% Per Year starting in 2013

Action Plan Step 1. Evaluate recycled-content paper options Recycled paper is available from both Staples and WB Mason with different degrees of recycled content, from 10% to 100%. By utilizing recycled paper in the office printers, any communication sent out, can state, “this document was printed on recycled paper” or you may utilize the recycled-content logos available by the paper manufacturer.

Step 2. Purchase Recycled Paper for Copy Machines, Printed Catalogs and Brown Paper Wrapping The catalogs should be printed on recycled paper, and recycled papers are available in coated as well as uncoated stocks. There are a large variety of papers available today that carry both a recycle and 24

HSM Cardboard shredding machine: www.hsm-shredder.com

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wind power logo (paper is made in a factory that utilizes wind power). In addition, there are Forest Stewardship Council (FSC) certified papers. FSC paper is grown in sustainably managed paper forests.

These logos can be put on all catalogs and materials printed for Architectural Grille.

The wrapping paper used for shipping should also be of recycled-content. Brown paper is the easiest to convert to recycled-content as less bleaching is required, and it may not carry additional costs.

Responsible Party (Target 3) • Office Manager Vimarie Tilleli will be responsible for maintaining the spreadsheet and evaluating the paper options • Procurement Manager/Fred D’Antoni will be responsible for purchasing the paper Review and Measurement – Target 3 Architectural Grille should maintain a spreadsheet of paper supplies that are regularly ordered. Every purchase should be researched with one to three sustainable options presented along with the option that Architectural Grille normally purchases. Whenever a recycled-content option is chosen, the level of recycled-content should be noted so that calculations may be made throughout the year to ensure goal is met. The Recycled Paper Environmental Calculator tool (see Resources below) can help Architectural Grille determine levels of sustainability and find ways to talk about the savings with employees and customers.

Compliance-Solid Waste The New York Fire Department (FDNY) Certificate of Fitness for Spray Finishing and Dipping OperationsC-30 is required. FDNY permit for Spraying/Dipping utilizing flammable or combustible materials, Fire Code sections 1504 and 1507 are also required and must be renewed yearly.

The FDNY oversees the powder coat process in New York City. The Certificate of Fitness and necessary permit must both be present to continue operations. Architectural Grille’s ventilated powder coat booth is in compliance with the FDNY, and a more advanced enclosed room for powder coat would also be in compliance. A new spray room would need approval from the Department of Buildings and plan approval from the Office of Technology Management of the Fire Department of New York.

Resource Conservation and Recovery Act (RCRA) RCRA requires that hazardous waste of any quantity be disposed of under Land Disposal Restrictions, and that facilities that treat, transport and dispose of hazardous waste be permitted by the NYC Department of Environmental Conservation. Once the hazardous waste is created, it must be entered into the Hazardous Waste Manifest System which tracks waste from creation to disposal.

Currently, it is unlikely that Architectural Grille is generating any hazardous waste. And if it were, it would be exempt from use of the Hazardous Waste Manifest System and NYC DEC permits requirement because businesses that generate, but do not store or treat, hazardous wastes do not fall under the regulation. However, it is possible that one or more chemicals used in Architectural Grille’s finishing process or machine cleaning and repair processes could be listed as hazardous waste under the EPA definition, and Architectural Grille would thereby generate hazardous waste. Architectural Grille can take advantage of the DEC’s Small Business program to catalogue its chemicals and determine its hazardous waste generation, after which it would have a 90-day penalty-free compliance period if hazardous waste is found.

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NYC Business Recycling laws require high grade office paper, newspaper, magazines, catalogs, phone books (includes materials generated by customers), and corrugated cardboard be recycled and kept separate from trash and designated construction waste. It may be commingled with designated and non-designated paper; wood materials, textiles and bulk materials.

Resources - Solid Waste 1. New York State’s Environmental Investment Program (EIP) provides funding assistance for projects that will have measurable environmental improvement for a commercial business or not-for-profit organization. These improvements can be from pollution prevention, waste reduction, reuse, recycling or the development/deployment of sustainable products and process technologies. Architectural Grille should apply after the planning stage, but before initiating project. This program is through Empire State Development and the contact is Antonio Rodriguez, at (212) 803-2283. http://esd.ny.gov/ businessprograms/EIP.html 2. New York State’s Industrial Effectiveness Program (IEP) provides grants up to $50,000 for projects involved with productivity improvements for small and medium sized manufacturers. This program is through Empire State Development and the contact is Isaac Joseph Elliston, (212) 803-2317. http:// www.esd.ny.gov/BusinessPrograms/IEP.html.

3. For updates on new sustainable packaging options, the following two websites can be used for reference, www.greenerpackage.com; www.sustainablepackage.org.

4. EPA Environmental Purchasing Program website: http://www.epa.gov/epp/index.htm 5. EPA Recycled-content Purchasing http://www.epa.gov/osw/conserve/materials/paper/resources/ buy_recycled.htm 6. Recycled Paper Environmental Calculator: http://calculator.environmentalpaper.org/home

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ENVIRONMENTAL ASPECT: WATER Objectives, Targets, Action Plan, & Resources

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WATER AREAS OBJECTIVES

TARGETS

Production, Facilities Management Objective 1: Reduce Water Consumption Objective 2: Improve Water Quality Objective 3: Divert Stormwater Runoff Objective 4: Raise awareness for the community-at-large of potentially harmful chemicals in water stream Objective 1 Target 1: Reduce water consumption 10% by 2016 Objective 2 Target 1: Reduce pollution in water & thereby improve water quality Objective 3 Target 1: Divert 365,000 gallons per year from flowing into the Gowanus Canal Objective 4

Target 1: Reduce the discharge of harmful chemicals into the water stream

There are various processes that utilize water, including the manufacturing, finishing and office related activities at Architectural Grille. The abundant use of water for facilities operations contributes to the depletion of natural resources that led to the generation of solutions to incorporate responsible water use and behavior. Furthermore, the treatment of storm water run-off is paramount for a facility like Architectural Grille, as the building is adjacent to the Gowanus Canal.

Architectural Grille currently utilizes processes to help reduce the amounts of water used: • Implementing the Waterjet cutting machine that automatically reuses water • Utilizes 1.6 gallons per flush (gpf) toilets, per industry standard However, Architectural Grille can still benefit from other water-related opportunities. The primary goals of the environmental response in this aspect are: • To reduce overall consumption of water where possible • Minimize potential pollution from entering sewer system • Divert and re-use stormwater run-off • Raise community awareness of Architectural Grille The objectives, to Reduce Water Consumption, to Reduce Water Pollution/Improve Water Quality, to Divert Stormwater Run-off and to Create a Database of Substances on Site were chosen to assist in meeting the water goals for Architectural Grille. These objectives target specific reductions in water consumption as well as potential water pollution, which could significantly lower the water bills while promoting Architectural Grille as an industrial leader in environmental stewardship.

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WATER Objective 1: Reduce Water Consumption

Target 1: Reduce water consumption 10% by 2016

Action Plan Step 1. Immediately educate staff to promote responsible water use To immediately alleviate excess water use and raise awareness to promote future improvements, all Architectural Grille staff should be educated utilizing methods such as water use fact sheets or signage materials at water stations. The educational promotions should concentrate on responsible water use for facility operations such as bathroom sink and toilet use as well as factory floor fixtures such as the large trough-basin sinks.

Step 2. Replace all existing flush urinals with waterless urinals by end of 2014 There are approximately 50 staff members at Architectural Grille, the majority of which (roughly 40) are male employees who utilize urinals. Estimating that 20 of those 40 male individuals will be at the facility on any given work day, and assuming that those 20 individuals will use and flush a urinal twice daily, renders 40 total urinal flushes per day. The existing urinals at Architectural Grille utilize 1.6 gallons per flush, resulting in 64 gallons of water used per day to flush urinals. Practicing a 260-day work year (52 weeks x 5 days a week), results in 16,640 total gallons needed to flush the urinals at Architectural Grille for one year.

To reduce water consumption, Architectural Grille should replace all existing urinals with Zero Flush waterless urinals by the end of 2014 to save the water that would normally be required for urinal flushing25. Zero Flush urinals utilize a sealant technology that is more buoyant than water and allows the urine to pass through it acting as a physical barrier as well as an odor barrier. The Zero Flush urinal technology does not require the use of water or electricity and the maintenance is minimal, including only replacing the trap filter and the sealant barrier solution every 15,000 uses. In addition, the Zero Flush technology incorporates recyclable filter traps and biodegradable sealant solution in the function of their products. The Zero Flush white porcelain products range in size and price from approximately $250 to $400 each26. Architectural Grille should replace all 4 of their existing flush urinals with the smallest Zero Flush urinal model ZF-501 at $250 each, a $1,000 investment to reduce water consumption by more than 16,000 gallons annually, resulting in lower water bills for Architectural Grille. In fact, Architectural Grille consumes an average of approximately 172,000 gallons of water annually for the operations and management of the industrial facility. If they invested in and installed Zero Flush waterless urinals, Architectural Grille would result in an immediate reduction of approximately 9% of the total annual water consumption, on average.

Step 3. Install sub-metering water systems by end of 2014 Architectural Grille should install water sub-meters by the end of 2014 to delineate the water consumption of the different manufacturing and facility processes. Understanding how much water various stations utilize will help pinpoint excess usage and areas of opportunity for reduction. Architectural Grille 25 Zero Flush Waterless Urinals: http://www.zeroflush.com/index.php 26 Green Building Supply. Zero Flush Waterless Urinals: http://www.greenbuildingsupply.com/All-Products/EnergyWater-Air-Toilets-Urinals/ZeroFlush-Waterless-Urinal

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should install sub-meter products similar to a 1” Top Load Multi-Jet Bronze Waterworks Meter at all stations consuming water27. These meters have a sensitivity to low flow reads and are unaffected by particulate build-up that hinder the accuracy of other meter types. The Multi-Jet Waterworks meter costs approximately $200 and is easy to install and maintain.

Source: http://wetheadmedia.com

Source: http://esubmeter.com

Step 4. Install automatic sink faucets by end of 2015 Architectural Grille should install automatic sink faucets in the restrooms and on the factory floor of the facility by the end of 2015 to help reduce water consumption. The implementation of automatic faucets will eliminate the problem of forgetting to turn water off, while improving the overall efficiency of the system. Implementing faucets similar to a MAC Automatic Touchless Faucet will cost approximately $200 and will require no setup or programming28.

Step 5. Install automatic motion sensors for water sprayers for powder coat process by end of 2015 The powder coat process consists of two areas that constantly spray water onto the product as it passes by the spray nozzles. Architectural Grille should install infrared motion sensors at the water spray components of the powder coat process by the end of 2015 to minimize water consumption by only spraying when a grille is passing through the area. Implementing a sensor such as the Sharp IR Package model GP2D120 will allow ample detection room if installed inside the water spraying areas29.

As a grille passes through on the moving track, the IR technology will sense the grille, and automatically turn the water on; as the grille leaves the water spray, another sensor can turn off the water. These infrared sensors are extremely inexpensive at approximately $15 each and would be easy to install and tie into the on/off switch for the water spray. This strategy, along with the installation of automatic faucets, could feasibly save an additional 1% annually (1,720 gallons) of the total water consumed at Architectural Grille. Therefore, the total potential reduction in water consumption is feasibly 10% of total water by the end of 2016. Further reductions in water consumption can be achieved with the successful installation of water catchment devices (see storm water objective).

Responsible Party (Target 1)

• Joe Leto /Facilities Management; Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/Top Management will be responsible for educating staff on water use, installing waterless urinals, water sub-meters, automatic faucets, motion sensors at water spraying areas of powder coat process • Fred D’Antoni/Procurement manager will procure above products

27 Submeter Solutions, Inc. Master Meter Water Meters: http://esubmeter.com/index.php?cPath=22_30_89&osCsid=0990bc5825b0b05205a091e46d06d7d9 28 Electronic Faucets. 2008. http://www.electronicfaucets.com/instaufaflva.html 29 Acroname Robotics. Sharp IR Rangers Information. 2012.

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• Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner will release the funds necessary for products

Review and Measurement (Target 1) Once systems are installed, Architectural Grille should annually monitor and record the sub-meter water readings at each facility process. By annually measuring water consumption per activity compared to previous years Architectural Grille can determine if the water reduction action plan has been effective.

WATER Objective 2: Improve Water Quality

Target 1: Reduce Pollution in water and thereby improve water quality

Action Plan Step 1. Measure water quality at the patina and powder coating stations to get baseline information In order to assess the quality of water that flows from the patina and powder coating stations at the Architectural Grille facility (since these are the only two procedures that do not reuse water and instead route excess water into sewer pipes), it is essential to understand the various methods of measuring quality. The U.S. Geological Survey identifies six major ways to define quality: (1) measuring water temperature which also dictates the level of dissolved oxygen (2) measuring pH which is evidence of acidic or basic conditions that either support or discourage aquatic life (3) measuring specific conductance which is water’s potential to conduct an electrical current and thereby reveal the amount of dissolved solids in water (or the amount of dissolved matter with an ionic charge) (4) measuring turbidity which indicates the amount of solids suspended in water based on the “cloudy or opaque” characteristics of water (5) measuring dissolved oxygen which is often indicated by the speed of water movement as well as water temperature (6) and measuring hardness which is defined by the amount of dissolved calcium and magnesium present in water.

For the purpose of this EMS, it is recommended that Architectural Grille only examine the level of “specific conductance” which indicates total dissolved solids (TDS) and “turbidity” which reflects suspended solid levels (TSS). Generally speaking, when high TDS and TSS measurements are detected, traces of minerals, salts and metals are present in water and are usually byproducts of nearby facilities that release organic waste, industrial waste and sewage. To synthesize TDS measurements, calculating the sum of total ions (cations and anions) determines the level of pollution. Pure water is not a good conductor of electrical current and therefore the higher the level of conductance, the higher the amount of dissolved solid material. In contrast, measuring TSS is an evaluation of suspended particulate matter that is measured by overall water transparency and opacity.

Architectural Grille can get baseline data about the TDS and TSS levels in their water, specifically at the patina and powder-coat stations, by using two monitoring devices and taking consistent measurements.

To collect data on TDS, using a Handheld Electrical Conductivity Tester such as the HM Digital EC-3, can indicate water quality over time; this type of product ranges from $25-59 per tester and only one device is needed to take multiple reads. To ensure efficacy of the product, it should be replaced every 6 39

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months30. To find TSS, using a product like a “turbidity test kit” will measure the opacity of water. A specific product like the LaMotte Turbidity Test Kit comes with 50 individual tests and costs $6531.

Step 2. Filter-out TDS and TSS in water In order to mitigate high levels of TDS and TSS in water that flows from the patina station and powder coating machine, Architectural Grille can use a “two-tier” filtration system. A product like the “OmniPure K5655 Inline Deionization Filter” at a price of approximately $3050, can be inserted into a 3/8”- 1/4” water line that is connected to these stations.

Source: http://www.grainger.com

This product will “deoinize” water by reducing its charge, and thereby filtering out dissolved solid material32. A second product like the “GE Clear Whole House System” ranging around $50 has the ability to filter out small sand Source: http://www.tdsmeter.com/ and sediment when placed in 3/4” pipe33. If each of these products are installed together to create two levels of filtration in the pipes that feed into the floor drains at both the patina and powder coating station, it is anticipated that water pollution will be reduced.

Responsible Party (Target 1)

• Step 1: Fred D’Antoni/Procurement manager is responsible for measuring water quality • Step 1:Fred D’Antoni/Procurement manager should train staff and educate team members on the procedure for continuously measuring water quality • Step 3: Rich Cammarata/Production manager with particular assistance from Fred D’Antoni/ Procurement manager is responsible for installing suggested filters and monitoring performance

Review and Measurement (Target 1) Architectural Grille should monitor the quality of the water every six months using the two aforementioned monitoring devices that measure TDS and TSS. By checking these measurements on a consistent six month basis, Architectural Grille will determine if filtration devices are working accurately and if the overall action plan is effective.

30 Western Digital. Water Testing Instruments: http://www.tdsmeter.com/ 31 GHC Specialty Brands, LLC. LaMote Turbidity Test Kit: http://www.grainger.com/Grainger/LAMOTTE-Water-TestKit-3VDR1?gclid=CMislq6otbECFYao4AodTVoAaA&cm_mmc=PPC:GooglePLA-_-Test%20Instruments-_-Water%20Quality%20Testing-_-3VDR1&ci_src=17588969&ci_sku=3VDR1&ef_id=oIFPsTqF0iYAAFFQ:20120725170806:s 32 Filters Fast, LLC. OmniPure K5655 Inline Deionization Filter: http://www.filtersfast.com/Omnipure-K5655-Inlinewater-Filter.asp 33 The Home Depot. GE Clear Whole House System: http://www.homedepot.com/Kitchen-Water-DispensersFilters-Whole-House-Systems/h_d1/N-5yc1vZaqz5/R-202073874/h_d2/ProductDisplay?catalogId=10053&langId=1&storeId=10051#product_description

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WATER Objective 3: Divert Stormwater Runoff

Target 1: Divert 365,000 gallons per year from flowing into the Gowanus Canal

Action Plan Step 1. Determine the exact size and specification for cistern system that will divert target water volume The size for a proposed cistern system at Architectural Grille can be determined by taking into account the following: for every inch of rain and for an average year of rainfall, which is 42” in New York City, runoff can be measured as a function of roof square footage. The Architectural Grille facility is housed in building with an area of 100,000 ft^2. Although other tenants occupy the building as well, Architectural Grille has primary control over the functionality of the roof. See Appendix G 7.1 for how to calculate runoff.

The entire facility has a runoff of about 2,618,000 gallons per year that equals approximately 7,172 gallons per day, if it were to rain daily. Based on this number, it is reasonable for Architectural Grille to divert 1,000 gallons per day that translates to 365,000 gallons per year. Because Architectural Grille lacks an excess of space around the building footprint, the installation of a product like a “waterhog tank” is recommended because waterhogs are modular, compact and can be assembled to reach whatever gallon holding capacity is desired. This product can be “tacked” onto the building facade itself or can be placed to rest against a building. The product comes in rectangular tanks where the standard size for each is 20” x 9.5” x 71” with a holding capacity of 51gallons each. A transparent material should be chosen if possible to increase the feasibility of visually assess how much water fills in each tank. In order to divert approximately 1,000 gallons of water every time it rains from directly entering the canal, 20 waterhogs should be installed and connected together. Each waterhog and fittings costs $338. For a total of 20 tanks, Architectural Grille would need to spend $6760 on this installment34.

Step 2. Re-Use collected water Not only does installing the “waterhog” product take into account the limited space concerns at Architectural Grille, these specific tanks are ideal for the facility because they can be fastened to the wall in a variety of ways. It is proposed that “waterhogs” be secured to the wall at an elevated height to allow water to drain and potentially be routed from cisterns through the building for indoor toilets use.

This can help offset the 16,640gallons used per year for toilet flushing alone. Even if just 1/4th of the 365,000gallons of storm water captured per year is utilized in this way, the 89,000gallon fraction can help reduce total water consumption at Architectural Grille. Additionally routing water into the building instead of directly draining it into the canal will help mitigate the high influx of water that otherwise overtaxes the sewer system and contributes to flooding of the Gowanus during rain events Step 3. Filter collected water Water collected in water tanks can also flow through a “bio-remediation” landscape that will help to purify it before entering the canal. By creating a planter-bed directly adjacent to the canal and underneath the water tanks, using a combination of soil, rocks, and specific plant communities, Architectural Grille 34 Aquabarrel LLC. Rainwater Hog from Aquabarrel: http://www.aquabarrel.com/product_rain_barrel_complete_rainwater_hog.php

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has the unique opportunity to create a bio-remediation or “constructed wetland system.” These vegetation systems have the ability to sequester certain salts and metals out of water and facilitate the slower percolate of water, either into soil or into the canal.

Because the day to day operations at Architectural Grille also dictate that the back doors of the facility need to be kept open during normal business hours (which face the canal), building this bio-remediation plant system can also ensure that particulate matter from the production floor, that may get swept or washed outside, does not enter the canal when it rains.

By installing this vegetated planting area, Architectural Grille can capture Source: http://rainwaterhog.com any particulates that might unknowingly end up outside and filter them through the plant system as a way of keeping them out of the waterway. In sum, a constructed wetland serves two purposes for Architectural Grille:

1) It supports increased water filtration because water can drain out of the water tanks overtime and percolate through soil, thereby reducing the overall volume of water into the canal 2) It helps to make sure water is not carrying harmful matter because the roots of plants and the combination of rocks and soil will intercept that process. By consulting a landscape architecture firm such as, Future Green 35, which is located in the Gowanus neighborhood and develops many projects of this nature, there is a unique opportunity to “slow and sink” water which would otherwise run off the impervious patio surface at Architectural Grille very quickly.

Section Drawing of Architectural Grille’s Building with cistern system

Responsible Party (Target 1)

35

• Step 1: Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Macchiarola/Top Management are responsible to purchase and install the cistern system • Step 2: Fred D’Antoni/Procurement manager is responsible for consulting with a plumber to install and hook up manual valves that allow water to drain from into the building through appropriate pipes • Step 2: Fred D’Antoni/Procurement manager is responsible to train a staff member to check that the valve that either allows cisterns to drain manually or routes water into the building, remains open. This should be checked on a bi-weekly basis.

• Step 3: Anthony Giumenta Jr./Owner; Stephen Giumenta/Owner; Anthony Giumenta Sr./Owner Future Green Landscape Architects: http://futuregreenstudio.com/

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is responsible for consulting with a landscape architecture firm to discuss designs for a vegetated outdoor space with bio-remediation potential • Step 3: A staff member who is routinely near the back doors of the facility should be responsible to manually drain cisterns on a bi-weekly basis. As per the plumber’s recommendation, cisterns will need to be manually drained on a bi-weekly basis or after heavy rains, by hooking up a garden hose to the overflow valves located at the bottom of each tank.

Review and Measurement (Target 1) Architectural Grille should monitor how much water is captured in the “waterhog” holding tanks on a consistent basis for the first four months after installation, during the rainy season. Because automated sensors that calculate water volumes are very expensive, this can be done informally by taking visual assessment of how much water is in each tank, assuming that transparent “waterhogs” are purchased.

Said assessments would require a staff member to look at the tank on a specified day every two weeks and keep a record of what percentage of each tank is filled with water. Though weather conditions will vary, if this is done consistently, Architectural Grille will get a clear and visible idea about how valuable it is to capture water considering the tanks will likely remain full and water will be able to be reused.

WATER Objective 4: Raise awareness for the community-at-large of potentially harmful chemicals in water stream

Target 1: Reduce the discharge of harmful chemicals into the water stream

Action Plan Step 1. Create a database of cleaning products used in the facility and chemicals used in production process by end of December 2012 Architectural Grille currently meets all standards for disposal of office and production chemicals into the water stream. However, industrial and office cleaning products tend to contain numerous harsh chemicals, yet are the easiest to replace. The ability to change these quickly and without interruption to the manufacturing process or imposing a learning curve on employees is a ‘quick win.’ Coupled with relatively low costs, the company will be able to tout a significant contribution towards environmental responsibility.

Office Products Green cleaning is more common than ever before and biodegradable cleaning products are already available on the market. Furthermore, independent tests have shown that these products are just as effective at cleaning as the harsher products we have used for many years. The Environmental Protection Agency (EPA) lists safe cleaning products on the Design for the Environment (DfE) list to help users search for safe and effective products36. This will help Architectural Grille eliminate harmful chemicals that are entering the water stream. Lastly, using biodegradable products can enhance the company’s public relations, as Architectural Grille can portray themselves as a good neighbor to the 36

Environmental Protection Agency, Design for the Environment.

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community .

37

Chemicals in Production Process There are many different chemicals used separately and in combination as part of the manufacturing process. The company should create and regularly update its database of these chemicals, highlighting additions or subtractions to the list. Further, Architectural Grille should set a goal of reducing or eliminating the use of hazardous materials wherever possible, starting with those used in the highest volumes. Where possible, Architectural Grille should replace hazardous materials with chemicals and compounds that are more environmentally friendly.

Every liter of contaminated water pollutes 8 liters of fresh water38. If Architectural Grille can replace all chemicals with those that are more environmentally friendly; this represents another opportunity to reach green goals. The company should highlight this in informational brochures, annual reports, shareholder events, or any other public media opportunities. There are many positive stories to be told about the intersection between commerce and environmental friendliness. For example, the powder coating process contains no solvents and any overspray is retrieved and reused, thereby eliminating paint from the waste stream39.

Step 2. Replace currently used cleaning products and chemicals used in production process with environmental biodegradable alternatives by end of 2012 Responsible Party (Target 1)

• Step 1: Vimarie Tilelli/Front Office; Joe Leto /Facilities Management will be responsible for gathering information and creating cleaning product database • Step 1: Fred D’Antoni/Procurement manager will be responsible for gathering information and creating chemical product database and replace all with environmental products • Step 2: Fred D’Antoni/Procurement manager will be responsible for procuring biodegradable cleaning products

Review and Measurement (Target 1) Top management will review and update lists once a year or whenever greener chemical can replace current chemical on the list. Top management will determine whenever the environmental policy statement needs to be update with new environmentally sound chemicals to keep enhancing the company’s environmental policy.

37 Bio-Pac. Bio Pac: Biodegradable Cleaning Products. http://www.bio-pac.com/Environmental Protection Agency.

Labeled Products and Our Partners. http://www.epa.gov/dfe/pubs/projects/formulat/formpart.htm SunBrite. Product Line. http://www.sunbrite.biz/Products.htm 38 Environment, health, Safety & Quality. One Liter od wastewater pollutes about eight liters of freashwater. http:// dramarnathgiri.blogspot.com/2012/07/one-liter-of-wastewater-pollutes-about.html 39 Environmental Protection Agency. Design for the Environment an EPA Partnership Program. http://www.epa.gov/ dfe/pubs/projects/formulat/label.htm Environmental Protection Agency. Facility Detail Report. http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_ facility?p_registry_id=110019749450 Metalast. Metalast TCP-HE Now Available. http://www.metalast.com/hot_news/index.html Powder Coating Specialists. Powder Coating FAQ. http://www.powdercoatingspecialists.com/faq/

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Compliance Capturing and re-using water would classify Architectural Grille as going above and beyond water quality compliance. The aforementioned types of applications, whether it is the use of stormwater for toilets or the filtration of stormwater through a constructed wetland, could give Architectural Grille the reputation of being “a good neighbor” within the community. Since both of these strategies are well above the normal industrial requirements for handling on-site water, this is an excellent opportunity for Architectural Grille to market themselves as a environmental leader in the Gowanus area.

Regardless of intent, stormwater runoff from impervious surfaces can very easily mix with discharge that inadvertently results from industrial activities i.e. it is possible that particulates which contribute to water contamination may get swept out of the back door at the Architectural Grille facility. To ensure that none of the procedures occurring at manufacturing facilities like Architectural Grille lead to the pollution of stormwater, which ultimately enters into New York’s natural waterways, permits are issued by the State Department of Environmental Conservation. It is advised that Architectural Grille pursue a Multi-Sector General Permit for Stormwater Discharge. This would require Architectural Grill to develop a Stormwater Pollution Prevention Plan (SWPPP) that discusses the Best Management Practices (BMPs) Architectural Grille could employ.

A viable BMP would be the construction of the aforementioned vegetated filtration system that will help to filter particulates out of stromwwater before entering into the already contaminated Gowanus Canal.

By keeping further pollutants out of the water, Architectural Grill can highlight to it’s neighbors that they are taking direct action to better the community’s water system. Secondly, reuse of stormwater for other purposes such as grey water pumped into the building for toilets, is also a justifiable BMP because it keeps potentially polluted stormwater from running off impervious surfaces and entering waterways all together.

According to the EPA Office of Water, the first step in obtaining this permit is to develop a Stomwater Pollution Prevention Plan (SWPPP) and submit a Notice of Intent to the DEC. By obtaining this permit, Architectural Grille will not only achieve compliance for industrial on-site water requirements, this is an excellent opportunity for Architectural Grille to market themselves as an environmental leader in the Gowanus area.

Resources - Water 1. US Geological Survey Website: http://ga.water.usgs.gov/edu/characteristics.html 2. EPA. Constructed Wetlands Website: http://water.epa.gov/type/wetlands/restore/cwetlands.cfm 3. Moshiri, Gerald, PhD. University of West Florida. Constructed Wetlands for Water Quality. 1993.

4.

Department of Environmental Conservation. Stormwater. 2012. Accessed 27 July 2012. http:// www.dec.ny.gov/chemical/8468.html 5.

US Environmental Protection Agency. Industrial Stormwater Fact Sheet Series. 2006. Accessed 27 July 2012. http://www.epa.gov/npdes/pubs/sector_c_chemical.pdf

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ADDITIONAL OPPORTUNITIES: EMERGENCY PREPAREDNESS

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EMERGENCY PREPAREDNESS OBJECTIVE TARGET

Objective 1: Create Emergency Preparedness Program Target 1: Implement full emergency preparedness program by the end of 2013

OSHA requires all businesses with a fire extinguisher to have an Emergency Action Plan (EAP). An EAP requires businesses to have procedures for reporting emergencies and evacuations, and informing employees of these procedures. Emergency preparedness goes above and beyond this requirement as it looks at the business more holistically.

All businesses are threatened with the potential of natural disasters and technological hazards. It is therefore important for businesses to be prepared to minimize impacts to the business and the surrounding environment.

Emergency preparedness can: • • • • •

Reduce injuries Prevent or minimize environmental impacts Protect employees and neighbors Reduce asset losses Minimize downtime

Architectural Grille is located in a Category 1 storm surge zone, a vulnerable area that is susceptible to storm surges. During a Category 1 storm (winds sustained at 74-95 mph) or higher, the area where Architectural Grille is located would be inundated with water. Architectural Grille is situated on the Gowanus Canal, making it essential to consider procedures that would prevent contamination during a disaster.

The area is also a designated Superfund site, meaning it is an uncontrolled hazardous waste site, in which the federal government is committed to cleaning up these sites to protect the environment and health of residents (see case study: Superfund Unique Situation). Once, the site is cleaned up and no longer hazardous, it will be imperative for businesses and residents in the neighborhood to reduce potential threats that would cause recontamination. Emergency preparedness can help minimize this concern.

Therefore, an additional objective in this EMS is to create an emergency preparedness program for Architectural Grille.

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EMERGENCY PREPAREDNESS Objective 1: Create Emergency Preparedness Program

Target 1: Implement full emergency paredness program by the end of 2013

Action Plan Step 1. Create Emergency Action Plan (EAP) by the end of 2012 First step, is to create an EAP as OSHA requires that all businesses with fire extinguishers have one.

An EAP must be in writing, kept in the workplace, and available to employees for review. The EAP is more basic than a full emergency preparedness program, but is a necessary first step, as OSHA requires it. An EAP must include40: • Procedures for reporting a fire or other emergency • Procedures for emergency evacuation (including type of evacuation and exit route assignments) • Procedures to followed by employees who remain to operate critical plant operations before they evacuate • Procedures to account for all employees after evacuation • Procedures to be followed by employees performing rescue or medical duties; • The name or job title of every employee who may be contacted by employees who need more information about the plan or explanation of their duties under the plan Employers must designate and train employees to assist in a safe and orderly evacuation of other employees. The employer must review the EAP with each employee. Architectural Grille should ensure that their EAP meets OSHA requirements and review it by the end of 2012.

Step 2. Begin a full emergency preparedness program by first assessing the threats and risks of most significant hazards and their impacts An EAP is required by OSHA, however Architectural Grille should go above and beyond the requirement of an EAP to create a full Emergency Preparedness Program, which will help prepare their business, mitigate impacts, and educate employees to a greater extent.

To start to develop an emergency preparedness program, Architectural Grille should conduct a risk assessment, identifying all potential threats and risks to their business. These include natural hazards such as floods, hurricanes, earthquakes, extreme heat, severe weather, winter storms, and more.

Risks also include fires, blackouts, and data loss or technical malfunction. Architectural Grille should determine the most significant threats (ones most likely to occur) that would affect business operations and the surrounding environment. To help identify these threats the Office of Emergency Management (OEM) has a Ready New York Business campaign that helps identify specific threats in the New York City area for businesses41.

40 OSHA. Evacuation Plans and Procedures. 2012: http://www.osha.gov/SLTC/etools/evacuation/index.html 41 Office of Emergency Management, NYC. Ready New York, Business. http://www.nyc.gov/html/oem/html/businesses/businesses.shtml

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After identifying the most significant hazards, a Business Impact Analysis (BIA) should be conducted. A BIA predicts the consequences of disruption of business and evaluates the impact of disasters. To help write a BIA, FEMA’s Ready Campaign for businesses gives detailed steps and ways to do your own BIA. Their website also contains a BIA questionnaire for survey managers and other employees within the business to help establish a BIA 42.

Step 3. Develop strategies for prevention/deterrence and risk mitigation The BIA will help provide the basis for investment in recovery strategies as well as investment in prevention and mitigation strategies. Impacts to consider include, (but not limited to): • Lost sales and income • Delayed sales or income • Increased expenses (e.g., overtime labor, outsourcing, expediting costs, etc.)

• Regulatory fines • Environmental contamination • Data loss • Worker injury OSHA has resources for hazard prevention, including a free on-site consultation for small businesses.

OSHA also provides many resources to evaluate and improve workplace safety. Also, many insurance companies provide free workplace safety, property loss prevention, and other assistance.

Risk mitigation is an imperative part to emergency preparedness. There are many strategies that can reduce damage from hazards. Some examples include, computer network safety and backup systems to help secure electronic information. Insurance is a way to reduce the financial impact on a business interruption and loss or damage to the facility. Specific mitigation strategies should be developed for AG based on results of the most significant threats and BIA. Step 4. Create and write a detailed emergency program by the end of 2013 After determining significant threats, impacts, and mitigation strategies, a detailed emergency program should be created and written. The written part of the program should include resources needed for responding to emergencies; procedures to protect people, property and the environment; evacuation, sheltering in place and lockdown; as well as plans for other types of threats identified in risk assessment.

It should also include recovery strategies to overcome disruption of business. Supporting documents that could be needed additionally in the emergency program include emergency call lists, building and site maps indicating water lines, gas lines, water main valves, exits stairways, fire extinguishers, etc.

Step 5. Implement Emergency Preparedness Program, test, and exercise emergency preparedness program After the program is written, Architectural Grille should conduct testing and exercises to evaluate the effectiveness of the program, make sure employees know what to do and find any missing parts. There are many benefits to testing and exercises, which include: • Train personnel; clarify roles and responsibilities • Reinforce knowledge of procedures, facilities, systems and equipment • Improve individual performance as well as organizational coordination and communications 42

FEMA, Ready Campaign. http://www.ready.gov/business-impact-analysis

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Unique Situation: Superfund Designation and its Impacts on Architectural Grille Architectural Grille’s location places it directly alongside New York City’s newest Superfund-designated site, the Gowanus Canal. Superfund designation is the popular name for property covered under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 42 U.S.C. §§9601, et. Seq. The Superfund Act was passed into law in 1979, when President Carter reacted to several oil and hazardous waste spills by proposing legislation that would charge fees to the oil and chemical industries, combined with federal appropriations, in order to create a fund which could be used to help in clean-up efforts in the case of a future spill or hazardous waste site.

In the case of the Gowanus Canal, three manufactured gas plants located on the canal generated the majority of the hazardous waste in the canal that led to its designation, each of which is currently owned by the National Grid gas and electricity company. A feasibility analysis on the clean-up options was performed by the Environmental Protection

Agency, which oversees Superfund actions, and published in 2010. Based on the report, one long-term remedial phase will be carried out. Remedial means that not only will the contaminants be removed, but that the site will be brought to a healthy level for activity on the canal.

After a two-year study of the contaminants, EPA found that the most hazardous chemicals are contained in a ten-inch thick tar-like sludge at the bottom of the canal (EPA Feasibility Study 2010). However, contamination was also found in the ground of the former facilities, and contributed by the Combined Sewer Overflow, which turns the canal into an open sewer.

In order to perform a full remediation, the EPA plans to dredge the canal, and has already begun removing contaminated soil from the former gas facilities.

Architectural Grille can expect dredging behind its facility in the next two years, which may or may not affect the covered patio area behind the facility.

It’s possible that machinery and possibly workers will be placed alongside the canal, and that additional trucking traffic will occur. Architectural grille’s

delivery truck may or may not be able to move as freely in and out of the back bay area onto the side road.

Further, the EPA is working with the city to re-design the sewer so that the Combined Sewer Overflow does not re-contaminate the canal( EPA Feasibility Study 2010). This may impact Architectural Grille’s front street sewer hook-up, and may change Architectural Grille’s current system of pumping waste. It may also require Architectural Grille to treat or filter oil from its waste water, or absorb its rainwater into its current sewer system input.

This is important as the canal is impacted by not only past pollution, but re-pollution from surrounding stormwater run off. Once the site is free of contamination, it will be essential to prevent recontamination to the canal.

To find out more about how the clean-up process may affect its business, Architectural Grille should check the Community Advisory Group page every few months to participate in any future community meetings involving the remediation actions.

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• Evaluate policies, plans, procedures and the knowledge and skills of team members • Reveal weaknesses and resource gaps • Comply with local laws, codes and regulations Combined, steps one through five create an Emergency Preparedness Program for Architectural Grille.

Responsible Party (Target 1) • Anthony Giumenta Jr./Owner;Stephen Giumenta/Owner; Anthony Macchiarola/Top Management will be responsible for implementing and creating the EAP per OSHA requirements; conducting risk assessment and Business Impact Analysis; determining mitigation strategies; creating and implementing Emergency Preparedness Program.

Review and Measurement (Target 1) Once emergency program is created, Architectural Grille should test Emergency drills that should be practiced every three months, with updates to the emergency program annually based on the success of tests and exercises. Full-scale exercises of emergency preparedness program should be practiced every six months. Below is an example of reviews of the emergency plan and drills, and how often they should be conducted: Management Orientation/Review Employee Orientation/Review Evacuation Drill Full-scale exercise Evaluate/update emergency plan

Every 6 months Every 6 months Every 3 months Every 6 months Annually

The specifics of these and whether or not there should be more exercises will depend on the outcome from the risk assessment and impact analysis used to create the emergency preparedness program.

Compliance OSHA 29 CFR 1910.157 OSHA requires an Emergency Action Plan (EAP) if fire extinguishers are required or provided in the workplace. An EAP covers designated actions employers and employees must take to ensure employee safety from fire and other emergencies (OSHA 2012).

Resources (Emergency Management) 1. To help create an Emergency Preparedness Program, FEMA. Emergency Management Guide for Business and Industry. 1993: http://www.fema.gov/business/guide/index.shtm 2. To help create an Emergency Preparedness Program for businesses look into FEMA’s ready campaign. FEMA. Business. 2012: http://www.ready.gov/business 3. Look into OSHA for potential for free on-site consultations. OSHA. Small Business. 2012: http:// www.osha.gov/dcsp/smallbusiness/index.html 51

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(Gowanus Canal Superfund Designation) 1. Environmental Protection Agency, Gowanus Canal Superfund Community Advisory Group: http:// www.epa.gov/region2/superfund/npl/gowanus/cag.html 2.

Environmental Protection Agency, Gowanus Superfund web page (check for updates periodically): http://www.epa.gov/region02/superfund/npl/gowanus/ 3.

Environmental Protection Agency, Gowanus Canal Superfund Fact Sheet: http://www.epa.gov/ region02/superfund/npl/0206222c.pdf 4.

Environmental Protection Agency, Gowanus Canal Remediation Feasibility Study: http://www. epa.gov/region2/superfund/npl/gowanus/pdf/20111219_Gowanus_Canal_Draft_Text.pdf

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ADDITIONAL OPPORTUNITIES: MARKETING

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MARKETING Architectural Grille demonstrates a great commitment to maintaining their existing clientele and seeking out new potential business relationships. Some of their current efforts include attending tradeshow conventions to network with architects and other professionals in the industry, distributing samples and brochures of their products to designers, and the latest notable effort: developing an environmental management system to enhance their company’s sustainability profile.

To continue on this successful path in the metal manufacturing realm, listed below are various recommendations that Architectural Grille should consider in order to elevate marketing strategies: 1. For the next batch of business cards printed, Architectural Grille can try adding a “Quick Response” code onto the cards to make it easier for potential clients to access their website via their Smartphones.

• The “Quick Response” code, also referred to as “QR” provides a direct and instant link to the company’s website through a general app that is available for download • Some advantages to incorporating the QR code onto AG’s business cards are: the ability to track the number of hits on the company’s website, the ability to make information more readily available for individuals visiting the website, which includes the catalog.

Quick Response Source: http://www.qrstuff.com/images/sample.

2. To grow their client base, Architectural Grille can obtain a list or gain access to a database of New York City and Long Island architects and other relevant industry professionals who are environmentally conscious of their practices and share the same philosophy or goals as Architectural Grille.

• Upon receiving these contacts, Architectural Grille may want to send out postcards with a link to their website (via the QR code mentioned previously) and possibly make an “introductory offer” to entice potential clients to try their products • Architectural Grille should also state explicitly that the company has a line of “green products” and are continuing to explore greener alternatives within their general business operations and products as well • Since Architectural Grille has already initiated the process of formulating an environmental management system, they should display their EMS “policy statement” in the office as well as on marketing materials, as well as on their website. This statement alone sets them apart from other companies within the same industry.

• Architectural Grille’s Website should also include any sustainable procedures they put in place on their website. They can add a tab called “Sustainability” and list their best practices. For example, “all paper purchased for office and shipping use is recycled.; We use recyclable cardboard, biodegradable bubble wrap.” If all the computers are Energy Star, this can be added to list. As you continue to add these sustainable practices, you should include on your website, and any advertising you produce for the company.

3. Network with local real estate agents or interior designers (particularly in the Brooklyn, New York City and Long Island areas).

4.Personally visit local architectural firms and other relevant companies likely to use their products and distribute samples.

• Architectural Grille should learn about potential clients and the nature of their work beforehand in order to bring appropriate samples that appeal to the clients’ styles and budgets • For these visits, Architectural Grille should always bring samples of their “green products” to stimulate environmental awareness among other industry professionals

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EMS REVIEW AND UPDATE OF PLAN As stated throughout this Environmental Management System plan, a critical component to its success is a formal review of the plan. The formal process of reviewing Architectural Grille’s EMS should aim to evaluate the effectiveness of the overall plan, as well as each individual objective and target. The overall plan and its components should be evaluated and reviewed regularly – bi-annually or quarterly – by Architectural Grille’s top management team and the team(s) established to carry out the EMS. While it is necessary to review the overall effectiveness of the EMS, it is not necessary to review each and every component at the same time. For example, Architectural Grille may decide to review objectives and targets related to solid waste and energy during the first quarter of 2013, and then review objectives, targets and other components related to water quality, emergency preparedness and marketing during the second quarter of 2013. It is important, however, that each component of the EMS is reviewed at least once a year. This process will ensure that the EMS remains updated to Architectural Grille’s needs and continues to be cost effective.

Some of the questions that should be posed throughout the review process include: • What progress has been made in meeting the targets set forth in the EMS? • What are any concerns about the EMS and how should they be addressed?

• Is the EMS still valid for and relevant to Architectural Grille at that certain point in time?

• Should the environmental policy be updated?

• Are roles and responsibilities understood or are adjustments needed?

• Are regulatory requirements being met?

• How have any changes implemented as a result affected Architectural Grille’s products?

• Should new objectives and targets be set?

• Have any stakeholder concerns been expressed?

• How could the EMS be improved?

Finally, formal documentation of the EMS reviews should take place. This task should be assigned to a member of the top management team and all reviews should be available for future consultation by other staff or members of the EMS team. This process of continual evaluation and improvement helps the EMS stay relevant to Architectural Grille’s growing needs and realities and avoids the mitigates crisis management.

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