ASTM E2365-05
(Guide)Standard Guide for Environmental Compliance Performance Assessment
Standard Guide for Environmental Compliance Performance Assessment
SCOPE
1.1 OverviewThis guide is an organized collection of information and series of options for industry, regulators, auditors, consultants and the public, intended to measure compliance with environmental performance standards against established benchmarks. It focuses on compliance with air, water, waste prevention, waste management, and toxic reduction standards for facilities in the United States. While the guide does not recommend a specific course of action, it establishes a tiered framework of essential components, beginning with those standards where a deviation presents the greatest potential public health, environmental, and business risks. In each identified pathway, at each tier or step of analysis, the guide outlines ways to identify compliance options and reduce pollution in iterative steps. The goal in using the guide is to lower environmental, public health and business risks from Tiers 1 and 2 to Tiers 3 and 4, by evaluating the performance standards described in this guide. While this guide provides a simplified framework of explicit steps for users, a qualified professional should conduct detailed, site-specific risk analysis. This guide may act as a starting point for organizations with limited experience in systematic environmental assessment. As facilities develop their specific plan framework, they will find that risk is weighted by more than just a few parameters. For each facility risk is the complex interaction among location, size, history, surrounding community and ecological zones.
1.2 Differences Among StandardsThis guide focuses on compliance with environmental performance standards in the United States. As such it includes a unique, risk-based method to analyze specific groups of legal requirements, as well as risk reduction techniques, sometimes called "pollution prevention."
1.2.1 Use of this guide provides a system to evaluate the relative priority of compliance and pollution prevention activities. Unlike environmental management systems, it provides a framework to triage critical issues, based on consideration of actual risk of harm to public health and the environment.
1.2.2 Environmental regulatory requirements in the United States are administered primarily by the United States Environmental Protection Agency (USEPA) and the parallel State and Local Agencies with similar regulatory authority. Certain other Federal regulatory agencies and State and local counter parts may also have legal requirements relating to environmental performance standards. Examples include the Departments of Transportation (DOT) and Agriculture (USDA) and the Occupational Safety and Health Administration (OSHA). Unlike certain international standards, this guide uses the major groups of environmental regulatory standards in the United States for air and water quality, waste management, release prevention, and toxic materials use reduction, in order to organize the compliance analysis framework.
1.2.3 This guide derives general information about regulatory requirements from common elements of Federal, State and local programs, including statutes, regulations, guidance and policies. Since agencies may have overlapping authorities and different emphasis for particular issues such as waste management, the user should consult the applicable program for detailed interpretation of specific requirements in a particular jurisdiction.
1.2.4 Pollution prevention is a specific term used in United States environmental compliance management programs. The term usually refers to source reduction actions. Unlike the term "prevention of pollution," which is used in certain international environmental management standards, pollution prevention does not generally include end-of-pipe or top-of-stack control actions.
1.3 Limitations of this GuideGiven the variability of the different types of facilities that may wish to use this guide, and the existence of State and Local regulations that may impose requirements great...
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Designation: E2365 − 05
StandardGuide for
1
Environmental Compliance Performance Assessment
This standard is issued under the fixed designation E2365; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
INTRODUCTION
This guide provides a framework for the development of an environmental compliance assessment
program. It integrates environmental compliance, environmental risk classification and business risk
management for use in decision-making. It provides a flexible, technically defensible framework to
prioritize environmental compliance and associated pollution prevention, with a wide applicability to
a range of facilities and environmental pathways. The facilities that may find an environmental
compliance performance assessment program useful and appropriate are domestic establishments that
perform work for consumers, business, government and other organizations.These include public and
commercial establishments, but they generally exclude individual households. This guide may not be
appropriate where a primary manufacturing facility has already implemented a site-specific environ-
mental management system (EMS). This guide could be used as a tool in conjunction with an EMS,
to evaluate compliance and pollution prevention.
1. Scope just a few parameters. For each facility risk is the complex
interaction among location, size, history, surrounding commu-
1.1 Overview—This guide is an organized collection of
nity and ecological zones.
information and series of options for industry, regulators,
auditors, consultants and the public, intended to measure 1.2 Differences Among Standards—This guide focuses on
compliance with environmental performance standards against compliance with environmental performance standards in the
established benchmarks. It focuses on compliance with air, United States.As such it includes a unique, risk-based method
water, waste prevention, waste management, and toxic reduc- to analyze specific groups of legal requirements, as well as risk
tion standards for facilities in the United States. While the reduction techniques, sometimes called “pollution prevention.”
guide does not recommend a specific course of action, it 1.2.1 Use of this guide provides a system to evaluate the
establishes a tiered framework of essential components, begin- relative priority of compliance and pollution prevention activi-
ning with those standards where a deviation presents the ties. Unlike environmental management systems, it provides a
greatest potential public health, environmental, and business framework to triage critical issues, based on consideration of
risks. In each identified pathway, at each tier or step of actual risk of harm to public health and the environment.
analysis, the guide outlines ways to identify compliance 1.2.2 Environmental regulatory requirements in the United
options and reduce pollution in iterative steps. The goal in States are administered primarily by the United States Envi-
using the guide is to lower environmental, public health and ronmental Protection Agency (USEPA) and the parallel State
businessrisksfromTiers1and2toTiers3and4,byevaluating and Local Agencies with similar regulatory authority. Certain
the performance standards described in this guide. While this other Federal regulatory agencies and State and local counter
guide provides a simplified framework of explicit steps for
parts may also have legal requirements relating to environmen-
users, a qualified professional should conduct detailed, site- tal performance standards. Examples include the Departments
specific risk analysis.This guide may act as a starting point for
of Transportation (DOT) and Agriculture (USDA) and the
organizations with limited experience in systematic environ- Occupational Safety and Health Administration (OSHA). Un-
mental assessment. As facilities develop their specific plan
like certain international standards, this guide uses the major
framework, they will find that risk is weighted by more than groups of environmental regulatory standards in the United
States for air and water quality, waste management, release
prevention, and toxic materials use reduction, in order to
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ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
organize the compliance analysis framework.
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
1.2.3 This guide derives general information about regula-
ity of Subcommittee E50.05 on Environmental Risk Management.
toryrequirementsfromcommonelementsofFederal,Stateand
Current edition approved Oct. 1, 2005. Published November 2005.
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