The quantity of raw materials purchased should be compared to the quantity of final product leaving the plant. Anything unaccounted for needs to be assessed within the following three categories: 1) air emissions; 2) liquid wastes; and 3) solid wastes. How is your company managing these wastes? Have determinations that prove exemptions been conducted? Where's the documentation? If not exempt, do you have a permit? Can you document compliance with permit conditions? Just because you don't have any notices of violation doesn't mean your company is in compliance. If your company is audited by an agency, then you'll find out.

It's nearly impossible to be 100 percent in compliance with all applicable regulations. How confident is your company that it won't be fined if audited? Has your company evaluated its regulatory liabilities, and does it know whether it's best to be passive (ignorance is bliss) and wait for the agency to audit and then react to their deadlines and fines? Or would it be better to be proactive, understand the extent of their liabilities, form their own priorities and budget to get things under control according to their own schedule?

Most companies fall somewhere within the ranges of being reactive to proactive, and probably conduct their business between the extremes described in Figure 1 in the "Green" Materials Management Continuum.

See No Evil, Hear No Evil — We Don't Know! Environmental Stewardship in Everything We Do! We react to inspections. We are proudly prepared for visits, tours and inspections. We react to spills and releases to the environment, if serious. We strive to eliminate the potential for spills or releases to the environment. We use our failure mode effects analysis process to spill-proof our processes and procedures. We promptly remediate any spills that occur and use our root cause analysis and team-based analytical problem-solving skills to reduce the possibility of recurrences. We don't go looking for trouble! We use plan-do-check-action and continuously seek opportunities for improvement. Not aware of any environmental issues. We evaluate the potential impacts of our processes, products and activities on our surroundings (the community and the natural environs). Ignorance is bliss! There's no substitute for knowledge! Not important to our immediate customers. Our neighbors, community and the natural environment are customers too! We will treat them as part of our system, as we rely on each other more than we know. Our competitors don't, so we can't afford to spend money on an Environmental Management System (EMS). Good business includes less wasted resources and less emissions. We have a working EMS, which makes us more competitive! Regulators probably won't come here soon, so we can comply when they finally tell us specifically what to do. We need to understand the requirements of our community, state and country in order to function smoothly in them. Our EMS will stand on its own even if the regulators don't visit. We are proud to show our facility to any customer or community member, including regulators. We did that quality stuff last year. Don't expect us to do anything this year. We strive to learn and improve continuously. We build on the foundations of our past successes. Figure 1. "Green" Materials Management System Continuum

From another perspective, can your company move toward prevention (improved environmental performance) within existing continuous improvement processes? Regulatory compliance concerns will be reduced as we improve our process efficiencies. In order to position ourselves to get full credit for some of the things we do, we have to develop a systematic method of documentation, cross-indexing, document control, retrieval and retention.

Environmental systems within an operation need to be supportive of the aim of the overall system. Failure to address environmental aspects internally can lead to the effects of internal system failures being felt by the larger confining system; i.e., customers, neighbors, community, public servants (regulators) and/or the natural environment. Examples of this would be: cost of failure, prevention and appraisal.

Traditional measurements in environment, quality, safety and accounting often simply reported past conditions. The challenge is to let your measurements (from any disciplinary perspective) serve as a living voice of the process. How are we doing? Where are opportunities for improvement in aspects critical to customers? How can we measure the improvement? How can we institutionalize what we learn?

A company that reduces or eliminates the quantity of wastes by process material or procedural improvements and/or re-use, recycling or sale of a by-product becomes "greener" and more cost efficient in the process. "Waste not, want not" does make practical sense.

Can your company show how "green" it is by accessing documentation from the files? By eliminating wastes and documenting exemptions, the need for permits is reduced, thereby reducing requirements to prove compliance.

Controlling your company's destiny by properly managing materials of concern can make practical business sense. How much does your company have under control?

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