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.This activity could be less efficient, more costly for the source, and morerisky due to the need to transport the waste to a different site.The interviews and case studies completedfor this research effort did not yield sufficient evidence to determine the likelihood of this situation actuallyoccurring or creating friction around lean implementation efforts.The Clean Air Act and Lean ImplementationThe case studies and interviews suggest that potentially the greatest area of environmental regulatory frictionthat can arise during lean implementation relates to air permitting under the Clean Air Act.Organizationsimplementing advanced manufacturing techniques are typically engaged in making rapid, and often iterative,changes to processes and equipment.The conversion from a batch and queue mass production layout to acellular layout generally entails significant movement of equipment, where production activities arerearranged so as to link process steps in the order needed to create a continuous, one-piece flow to make theproduct.For example, Goodrich Aerostructures representatives reported that the company used a 5-daykaizen event to rearrange a 100,000 square foot facility.In addition to the movement of equipment undersuch a conversion, new, right-sized, mobile equipment is often introduced to replace larger, less flexibleequipment.Such changes in the location and type of equipment, particularly where the process hasassociated air emissions or the potential to  debottleneck air emissions elsewhere, can often trigger the needfor a major or minor New Source Review construction permit and/or a modification to an existing airoperating permit.In addition to the major operational and equipment changes that often accompany the conversion to cellularmanufacturing, ongoing rapid continual improvement events often identify changes to equipment and4956 percent of petitions were withdrawn; 15 percent denied; and 13 percent remained incomplete or inprocess.RCRA Hazardous Waste Delisting: The First 20 Years (June 2002).Lean Manufacturing and the Environment October 2003 | Page 39equipment location.In some cases, this may involve an iterative process where the performance changesfrom an operational or equipment modification are measured, and based on that information, additionalmodifications are made to further optimize the process.In most cases, organizations seek to complete actionsidentified during kaizen rapid improvement events within one week.The need to make rapid operational andequipment changes can also arise when existing product designs are modified or new products are introducedinto the factory for production.To accommodate these different rapid change scenarios, right-sizedequipment is often built on wheels or easy-to-move skids.Friction often arises due to the time frames that are typically associated with permitting planned changes,or modifying permits to accommodate them.New Source Review permitting processes in many jurisdictionsoften take from three to nine months, or longer.These changes are typically significantly out of alignmentwith the time frames associated with lean implementation efforts, where an organization desires to make thechange within one week.This results in situations where either environmental performance improvementsare constrained or delayed, or the risk of potential non-compliance with air permitting requirements isincreased.The Clean Water Act and Lean ImplementationThe interviews and research for this project did not identify instances where Clean Water Act regulationsand requirements create significant friction for lean implementation.One area surfaced during the interviewswith lean experts, however, that may warrant further investigation by the EPA.Several lean expertsindicated that, over the past few decades, many small and medium-sized companies outsourcedenvironmentally sensitive processes, such as metal finishing and painting, to avoid dealing with theregulatory and environmental and safety management complexities that can accompany these processes.Increasingly, companies implementing lean are finding that such outsourcing can substantially lengthenproduction flow time, leading them to investigate bringing these processes in-house.The interviews suggestthat as they contemplate this change, businesses are often not aware of more environmentally friendlytechnologies, such as citric acid based passivation as an alternative to nitric acid based passivation,50 that mayreduce wastewater discharge pollutants and volumes.In addition, even right-sized environmentally friendlytechnologies may trigger federal effluent limitations (e.g., metal finishing) that require a source-specificNPDES permit (for direct dischargers) or compliance with categorical standards for indirect dischargers, bothof which involve more rigorous monitoring requirements.Several lean experts suggested that guidance andother efforts to facilitate the implementation of environmentally friendly technologies in processes such asmetal finishing, painting, parts cleaning and degreasing, and chemical treatment may aid companies inreducing production flow times while improving overall environmental performance.As the above discussions of the relationship between lean implementation and RCRA, Clean Air Act, andClean Water Act requirements highlight, there appear to be two key implications that are likely to be ofinterest to environmental management agencies.First, lack of regulatory precedent or clarity aroundacceptable compliance strategies for lean operating environments can increase the risk of non-compliance50Passivation is an industrial process that involves the chemical treatment of stainless steel for the purposeof enhancing corrosion resistant properties [ Pobierz całość w formacie PDF ]