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FLEXO Magazine : April 2009
PLANTS & PROCESSES Compliance Criteria By Robert Fricke mental awareness. Media play about unrecoverable environmen- tal waste has surrounded an industry that relies on physical goods manufacturing. Major corporations are now demanding that print suppliers develop and implement sustainable practices to reduce their environmental and carbon footprints. All this attention has brought the perfect storm to our industry. As our trade associations have never walked away from a chal- lenge, they responded in a collaborative eff ort—rolling out a new sustainability verifi cation program to all printers, the Sustainable Green Printing (SGP) PartnershipSM A . SGP gives printers a stan- dardized methodology to develop and implement their own sustainability management practices and advocate environmental stewardship. An outside SGP auditor then verifi es these practices every two years. If the minimum sustainability practices are veri- fi ed, the printer can promote their sustainability eff orts to all stakeholders (employees, customers, and the public). SGP verifi ca- tion allows a verifi ed printer to use the SGP logo on its printed products and promotional materials. NOT FOR EVERYONE SGP certifi cation is not just a stamp of approval. It requires a printer to build a sustainability approach into all parts of its daily business. It requires management commitment and adequate resources to ensure success. That means all employees must make a substantial eff ort to develop the required practices and then maintain those eff orts and practices on an ongoing basis. In short, it is not for the faint at heart. MAJOR SGP COMPONENTS SGP certifi cation is divided into three major components: 1. Environmental, health, safety (EHS) compliance 2. SustainabilityManagement System (SMS) 3. Mandatory Best Management Practices (BMPs). Industry, regulatory agency, print buyers, and environmental community stakeholders who developed the SGP methodology recognized from the beginning that some baseline eff ort had to be required of printers. That baseline is EHS compliance. Printers then implement sustainable practices on top of the EHS eff ort to gain recognition above their peers. If a printer is not in compli- ance with the EHS regulations, then how can a printer be consid- ered a superior environmental performer? 50 FLEXO APRIL 2009 sense of urgency has prompted the printing industry to aggressively move to not only advocate but implement smart business practices of sustainability and environ- THE BIG PICTURE EHS requirements can be divided into two categories: major rules and regulatory nuances. For the printing industry, there are about 20 major rules that are potentially applicable to a printer as provided in Table 1. Then there are those regulatory nuances—those less com- monly known individual requirements buried in the regulations. For example, there is the annual requirement to notify employees of their right to access medical and exposure records that may be held by the printer or a contracted third party (29 CFR 1910.1020). WHAT DO I DO FIRST? First, you have to establish a Sustainable Management System (SMS). This is a system that spells out company eff orts to achieve its goals relative to sustainability and it contains a section specifi - cally addressing EHS compliance (see FLEXO March, page 50). The EHS section needs to detail how the printer is going to establish, implement and maintain procedures to achieve and maintain EHS compliance. The procedures need to detail responsibilities, train- ing, and a mechanism to periodically check one’s compliance sta- tus on an annual, monthly, weekly, and if necessary, a daily basis. There are industry consensus management systems out there that a printer can use as a basis like ISO 9001, ISO 14001, ISO 18001, and ANSI Z10. SGP does not require you to put any of these standards into place, although they would be a plus. However, you need a management system that contains the com- mon elements found in all of those standards. Since SGP requires that you have written documentation of how your EHS manage- ment system works, you can use the common elements of these standards as a table of contents. A printer need not have this as a single document. Individual written standard operating practices (SOPs) can be used as well. The key is ensuring that the common elements are adequately defi ned to show how the company incorporates EHS into its daily business practices. For smaller printers with a compact manage- ment structure, the procedure will be brief—that is, compared to a large printer, where EHS compliance is more resource intensive and duties may be spread out across departments and individuals. REQUIRED DOCUMENTS At a minimum, a printer should have the following plans: Hazard Communication; Lockout/Tagout; Emergency Action, and PPE Hazard Assessment. These are the same documents OSHA will generally ask for during a random inspection of a printer. Each document should be reviewed annually for accuracy and completeness. In the case of Lockout/Tagout, the annual review www. f le xography. org