Sustainability Practices Checklist

Engage an outside auditor or certified energy manager (CEM) to walk the plant and quantify savings opportunities — lighting, HVAC, compressed air, motors, process heat. A Level 2 audit yields measure-by-measure savings and payback, which feeds the capex request. Attach the final audit report to this step.

EPA publishes ENERGY STAR Plant Energy Performance Indicators (EPIs) for several sectors — auto assembly, glass, food, cement, etc. If yours is covered, score the plant; below 75 means you are below median peer performance and have meaningful headroom.

HID and T8 retrofits to LED typically pay back in 18–30 months including utility rebates. Specify integral occupancy sensors in low-traffic areas (toolroom, mezzanines, dock) for an additional 15–30% reduction. Pull the rebate forms from your utility before purchase, not after.

Compressed air is one of the most expensive utilities per delivered horsepower; leaks of 20–30% of output are typical in older plants. Use an ultrasonic leak detector during a quiet shift, tag every leak, and schedule repair to maintenance. HVAC: verify economizer operation, check setpoints against occupancy, and confirm filter PM is current.

Roof-mount PV, ground-mount, or virtual PPA — each has different capex and accounting treatment. ITC and state incentives change annually; price out a 12-month look ahead. If the roof is older than 15 years, factor reroofing into the project, since panels live 25+ years.

Weigh and categorize each dumpster pull for 30 days — cardboard, mixed metal scrap, plastic resin, MSW, hazardous. The output is your true waste baseline; most plants find that 40–60% of MSW is divertible to recycling streams that pay or break even.

Mixed scrap goes for landfill prices; segregated 304 stainless, 6061 aluminum, and copper pull premium scrap rates. Label gaylords or hoppers at the source. For plastic injection scrap, keep regrind separated by resin and color or it is unsellable.

Status drives almost every RCRA obligation. VSQG (under 100 kg/month), SQG (100–1,000 kg/month), or LQG (1,000+ kg/month). Calculate from the past 12 months of manifests. Status changes mid-year if generation jumps; document the calc and re-check quarterly if you trend near a threshold.

LQGs must file the Biennial Hazardous Waste Report (Form 8700-13 A/B) by March 1 in even-numbered years for the prior odd-year activity. State agencies in many states use the EPA RCRAInfo platform; some run their own. Pull manifest totals by waste code (D001, D008, F005, etc.) before starting.

Returnable totes and reusable pallets cut wood-pallet disposal and corrugate purchases. Coordinate with top inbound suppliers and your largest outbound customers; the gating step is usually the partner's willingness to manage return logistics, not the totes themselves.

Pull the past 12 months from EPA's e-Manifest system and reconcile against your shipping logs. Missing TSDF return copies after 35 days (45 for rail) require an Exception Report. Verify the TSDF on your manifests is still permitted — facility closures happen and orphaned waste is the generator's problem.

A single utility meter at the curb tells you nothing about where water goes. Sub-meter the parts washer, cooling towers, chiller make-up, and any once-through process cooling. Most plants discover that cooling-tower blowdown and washer overflow account for the majority of consumption.

Walk every fitting, valve, and packing gland during a planned shutdown. Tag and write CMMS work orders for each finding. Glycol drips are easy to dismiss as minor — they are not, especially in closed-loop chilled water where loss triggers compressor short-cycling.

For machine-shop or stamping coolant, centrifuge or membrane recycling extends fluid life from 3–6 weeks to 6+ months and cuts hazardous waste manifests proportionally. Vendors include Eriez, Hennig, Fluid Recycling Services. Calculate payback against current disposal and concentrate purchase.

Cycles of concentration (COC) drive both water use and chemical cost. Below 3 cycles wastes water; above 7 risks scaling. Train the maintenance tech responsible for tower chemistry to read the conductivity controller and log COC weekly.

Normalize water draw to production output (gallons per pound shipped, gallons per part, gallons per dollar of revenue — pick what fits your product). Trend month over month. Spikes that don't track production usually mean a leak or a fouled cooling-tower controller.

EcoVadis is the de facto standard for buyers requesting supplier sustainability scores; if your customers ask for it from you, it makes sense to ask it of your tier-1s. For small suppliers without budget, send a short self-assessment covering ISO 14001 status, energy intensity, and conflict-minerals policy.

Conflict Minerals Reporting Template is the RMI standard form. Public-company customers under Dodd-Frank Section 1502 will pass the request down. Track which suppliers have returned current-year CMRTs and which gave you last year's; an old CMRT is treated as no CMRT during a customer audit.

Local sourcing reduces inbound freight emissions and lead time, and supports LEED MR credits if your customer is building a certified facility. Watch the qualification cost — re-PPAPing a stamping or machined component to a new supplier often costs more than a year of the freight savings.

Pull current ISO 14001 certificates and confirm scope and expiration on each. Common gotcha: a supplier's parent corporation is registered, but the plant shipping to you is not in scope. Read the scope statement on the cert.

At contract renewal, include a Supplier Code of Conduct covering forced-labor prohibition, REACH/RoHS substance restrictions, conflict minerals due diligence, and right-to-audit. Coordinate language with legal and procurement before pushing it to suppliers.

Scope 1 = direct combustion (natural gas, propane, diesel, refrigerant leakage). Scope 2 = purchased electricity and steam. Use the GHG Protocol Corporate Standard with EPA emission factors (eGRID for electricity by subregion). Document boundaries and data sources for any future CDP or customer disclosure.

If you are SIC/NAICS-covered and exceed 25,000 lb manufactured/processed or 10,000 lb otherwise used (1 lb for PBT chemicals, 100 g for dioxin) for any listed chemical, you owe a Form R. Check chromium, lead, nickel, copper, glycol ethers, and any solvent on the list.

TRI Form R is due July 1 for the prior calendar year. File via EPA TRI-MEweb. Penalties for non-filing can reach $50,000+ per chemical per day, and EPA actively cross-references with state air permits and RCRA manifests, so under-reporting is detectable.

Diesel forklifts indoors trigger 1910.178 ventilation issues and CO/NOx exposure. Lithium-ion electrics now match LPG runtime in a single shift and cut Scope 1 to zero for that fleet. CARB-state plants face accelerating diesel restrictions; budget for replacement on the natural fleet refresh cycle.

EPCRA Section 312 — any hazardous chemical on site at or above 10,000 lb (or TPQ for EHS, often 500 lb) at any point during the prior year requires Tier II to your SERC, LEPC, and local fire department by March 1. Most states use Tier2 Submit; a few have their own portals (e.g., CA CERS, TX STEERS).

The COO or plant manager signs the report before it goes to customers, the website, or any voluntary disclosure (CDP, EcoVadis). Attach the final PDF, capture executive notes on next-year priorities, and digitally sign.