AND SAFETY REPORT
BROWNING-FERRIS INDUSTRIES, INC.
. CHAIRMAN'S LETTER
CHAPTER I. Corporate Commitment: The EHS Management Program
Council for EHS Excellence
Environmental, Health and Safety Staffing
Health and Safety Training
Operational and Technical Support
CHAPTER II. Environmental Performance: The Record
Health and Safety Results
New Landfill Regulations
Closed Facility Management
Collection and Transfer
CHAPTER III. Waste Minimization and Recycling: Our Commitment in Action
SInternal Recycling Program
Oil Recycling, Antifreeze, Truck Wash Water
Conservation of Resources
Leachate Minimization Program
CHAPTER IV. Examples of Special Initiatives:
Wildlife Habitat Enhancement Council
APPENDIX Environmental, Health and Safety Policy
Council for EHS Excellence
*Please note that most BFI statistical information is collected by fiscal year; some
information is collected by calendar year. Except where otherwise indicated, informa-
tion is for the fiscal year. The information provided in this report relates to BFI's North
William D. Ruckelshaus
Chairman and CEO
We are pleased to present BFI's first report on its environmen-
tal, health and safety (EHS) programs. We will periodically
update this report.
The American waste services industry continues to undergo changes
stemming from a fundamental shift in public opinion. As public aware-
ness and concern about waste generation and disposal have increased,
so has the demand for legislative and regulatory action. In turn, the
political system has responded. The once homogeneous waste stream has
been segmented into a number of tributaries, each with its own rules and
regulations, each needing to be managed differently.
Companies like BFI have worked hard to adapt to this changing land-
scape. BFI has made great strides in the last several years, and we feel
good about our achievements. This report is a measure of how far we
have come, and it defines the challenges in the years ahead.
The report describes in some detail the extent and scope of our com-
mitment to excellence in meeting environmental, health and safety goals.
We believe our ability to survive and succeed as a business depends in
large part on exceeding public expectations regarding health, safety and
the environment in every aspect of our operations. We are committed to
that. In many cases, our internal standards go beyond simple regulatory
Our commitment to excellence begins right at the top and is shared
and reinforced at every level of management. In the past several years,
we have focused our efforts on the development of programs that fully
integrate environmental performance into all aspects of our business.
We strongly believe that the key to consistent performance is making
sure our people are trained and that the processes to ensure compliance
are clear and supportive of our goals. We believe we have come a long
way toward meeting these requirements for success. You can see it in
the attitude of our people and in the record of their achievements.
Our managers receive intensive training, designed to give them the
knowledge and tools necessary to manage their facilities and operations
in the most environmentally sound manner, with careful attention to
the health and safety of our workers and the public.
We then provide our managers with broad technical, policy and
operations support from our corporate and regional offices. This
includes engineering support, laboratory support, facility design services,
EHS regulatory compliance assistance, legal counsel, community rela-
tions expertise, and task forces to handle specialized issues like landfill
gas. This support also includes corporate EHS policies and detailed
operational manuals for each business segment in the company.
To reinforce this system, we have created a set of compensation
incentives we believe are compelling in their ability to motivate BFI
managers and employees. A manager's compensation is tied directly
to environmental performance. The company has also created strong
incentive programs for injury-free and accident-free operations.
Finally, our independent audit program validates operational
performance throughout the company; the action-plan tracking system
provides for problem identification, correction and improvement.
The total system is being fully integrated into our operations. We
have begun to comprehensively measure our performance and raise our
standards as the existing ones are met. We intend to add new measures
as appropriate. Measurement and continuous improvement are critical
to the success of our program.
BFI is constantly looking for better ways to manage its EHS programs;
consequently, we often work with other companies to examine their
programs. BFI is a charter member of GEMI, the Global Environment
Management Initiative, a program that brings together leading compa-
nies from around the world to share environmental experiences.
In addition to being a major environmental services company, we are
also a large corporation that consumes resources and generates wastes.
The company is committed to a strong internal recycling program at
Small our facilities and to the purchase of products with recycled content
to help establish permanent markets for the materials our recycling
This report will also describe our efforts to manage our use of energy
as efficiently as possible and to minimize the wastes we generate. These
programs are in their beginning stages, and future reports will document
our continued progress.
In this report, we provide an extensive discussion of the citations at
our solid waste landfills, since that is the area of our operations most
highly regulated and subject to the most scrutiny. In 1991, there were
13 citations at our 100 active landfills, nine of which resulted in the
payment of $56,034 in penalties.
Though the data are not complete, preliminary results for 1992
confirm our continued improvement. While we are not happy with any
violations, our improved record of compliance is substantial and signifi-
cant. These results are impressive and validate our program to achieve
Also in 1991, a penalty of $600,000 was paid to settle a dispute with
the U.S. EPA that occurred several years ago but which was only recent-
ly resolved. It arose over what type of material the company should use
in groundwater monitoring well casings at one closed landfill. We dis-
agreed with the government's decision (believing there were adverse
We have created a set
of compensation incentives we
believe are compelling in their
ability to motivate BFI managers
and employees. A manager's
compensation is tied directly to
Our Corporate Mission Statement
contains these words: "We will carry
out our mission efficiently, safely and
in an environmentally responsible
manner with respect for the role of
government in protecting the public
interest." No other corporate mission
statement contains that commitment,
and it is critical to how we conduct
our business at BFI.
effects associated with the government's choice) and instead installed
well casings we believed were superior. The government resented that
rebuff and took action. That fine is the price we paid-a costly lesson.
We will do everything possible to make sure thatwon't happen again.
Our Corporate Mission Statement (adopted after that incident), printed
on the following page, displayed on the walls at every BFI office and
literally etched in stone in our headquarters lobby, contains these words:
"We will carry out our mission efficiently, safely and in an environmen-
tally responsible manner with respect for the role of government in
protecting the public interest." No other corporate mission statement
contains that commitment, and it is critical to how we conduct our
business at BFI.
Recently, BFI held its first "stakeholder" meeting at our Houston
headquarters. We brought together for a day representatives of public
and private sector customers, environmental and public interest group
leaders, investors and investor groups, local community representatives
We described for them our EHS programs and solicited their sugges-
tions for improvement and change. It was a most enlightening and
productive experience of enormous value to our senior managers, all of
whom attended the meeting. It has already resulted in changes at BFI to.
make us more responsive to community concerns and more conscious of
the responsibility we have to encourage a permanent recycling industry.
This report seeks to document our extensive efforts to achieve environ-
mental, health and safety excellence, but it cannot provide the complete
picture of what we are doing or answer every question. If you would like
more information about our programs, we want to hear from you.
William D. Ruckelshaus
Chairman and Chief Executive Officer
OUR MISSION is to provide the highest quality waste collection, transportation,
processing, disposal and related services to both public and private customers
worldwide. We will carry out our mission efficiently, safely and in an environ-
mentally responsible manner with respect for the role of government
in protecting the public interest.
To be successful, a corporate environmental, health and safety
management program must be fully integrated into the
operations of the company at every level. It must reflect the
commitment of the senior management and be part of every
employee's responsibilities. Finally, to ensure effective implementa-
tion, the program must be derived from a strong and clear policy.
While BFI has a long-standing, successful and fully integrated
program to manage worker health and safety, the primary emphasis
of this report will be on our environmental programs. We will also
present information about our health and safety program, because it
demonstrates a high degree of achievement and provides a model for
full integration of our environmental program.
Excellence in our EHS program is BFI's goal, and we believe we are
well on our way to achieving it. In this chapter, we will outline the
structure of the company's environmental, health and safety manage-
ment program, and discuss the function of each element in it.
Council for Environmental, Health and Safety Excellence
BFI's Environmental Policy Committee was established in early 1989.
Its goals were to review existing
The responsibility for meeting environmental, health company policies related to the
and safety requirements rests with regional and district environment and to develop a
new, comprehensive environ-
managers. The corporate office provides overall
mental policy for the company.
program guidance, technical and operational support, Recently, the mission of the
training, accountability and validation programs. Committee has been expanded,
partially in response to the
stakeholder meeting mentioned in the Chairman's Letter. To reflect
its new role, the Committee is now called the Council for
Environmental, Health and Safety Excellence.
The Council will guide the company in designing, implementing,
communicating and monitoring programs aimed at achieving
continuous improvement in BFI's EHS performance. The Council
provides continuous oversight of the implementation of EHS
policies. The Council meets regularly to review environmental issues
facing the company.
All Council policy recommendations and actions are reviewed by a
senior management group consisting of the Chairman and CEO, the
President, the General Counsel and the Chief Financial Officer.
SThe Council is chaired by J. Gregory Muldoon, Senior Vice President
for Corporate Development. He reports directly to BFI's Vice
Chairman, Norman A. Myers. The Council represents a broad cross -
section of BFI's management, operational and technical disciplines. A.
list of current Council members is provided in the appendix.
BFI has a decentralized corporate structure for managing all its
operations. We conduct our business in some 480 operating locations
called districts in eight regions in North America. The company
believes that the manager closest to the customer and the facility is
best able to make the right decision. The responsibility for meeting
environmental, health and safety requirements rests with regional
and district managers. The corporate office provides overall program
guidance, technical and operational support, training, accountability
and validation programs.
The chart on this page illustrates this structure and the lines of
Environmental, Health and Safety Staffing
The company is committed to providing the resources and staffing
necessary to meet both internal and external requirements in the
areas of environmental, health and safety (see charts on page 9).
For environmental compliance, those resources have grown steadily
over the last several years.
Key to BFI's environmental management program is a series of
structured comprehensive training programs. Every program not only
builds environmental awareness at every level of the company, it also
reinforces the management structure by which the EHS programs are
BFI developed the Awareness and Compliance Tools for
Environmental Performance (A.C.T.) program for company-wide
training in each business area. A.C.T. training is based on a team
approach to recognizing and solving environmental issues. The goals
O of the program are to increase awareness of environmental perfor-
mance, create responsibility for environmental excellence in every
BFI employee, introduce the policies and systems the company has
put in place, and provide the needed regulatory knowledge base.
.... .c .....
Chief Executive Officer
Chief Operating Officer
-......- ..... ....-.-- .....
------------- -i- -----------
.-..-- ..... ... ---............. -
Special Wastes Manager
Market Development Manager
Community Affairs Manager
Risk Management/Loss Control
Health & Safety
Council for Environmental
Health & Safety Excellence
Environmental Audit Department
*The exact mix of poritlam depends upon th type of
operating In the district.
Compliance 7 10 13
Audit 3 5 5
Support* 93 106 115
-------...--- ... ---------
Compliance 10 20 22
Compliance 5 20 28
--------------------- ----------- ------
Total 118 161 183
--------------. -.-...-.-. ........ .....
* Profesionals In corporate otcfe Include: Environmntal
Engners, Environmental Law, Government Affair, and
A.C.T. training was introduced to all landfill employees in 1990.
The training features 13 modules, including video sessions and group
exercises; it requires about 40 hours to complete. The program also
includes sessions with local regulators to give employees a better
understanding of regulatory needs.
A.C.T. training for each business segment landfill, medical waste
and solid waste incorporates the same cross-functional team
approach, while being customized for the particular business area.
The A.C.T. training is provided for all new employees, with ongoing,
periodic updates for all affected employees. BFI has also developed a
Spanish language version of the same program.
All landfill employees completed A.C.T. training in early 1992;
A.C.T. training for medical waste facility employees began in May
1992 and will be completed by May 1993. A.C.T. training for
solid waste employees (including collection, recycling and transfer
station operations) begins in January 1993 and is scheduled for com-
pletion by September 1994.
By the end of 1994, virtually every facility and district employee ih
the company, more than 22,000 employees, will have participated in
a specific environmental training program.
The company is preparing a series of special skills programs for
1993. These are programs that explore particular areas in greater
depth and can be thought of as advanced A.C.T. training. Two pro-
grams scheduled for implementation next year will deal with inter-
nally generated waste and pollution prevention. Regular seminars
are conducted to inform managers of new or proposed regulations
which may affect their operations.
The box on the next page lists the A.C.T. training modules for
landfill personnel. Training programs for medical waste employees
and for solid waste collection and transfer stations employees are
similar and equally comprehensive.
THEA TTRANIG ODUESFO LADPLf PESO NE
Landfill Employees Trained: 2,017
Training Hours Per Employee 40
Total Hours of Training (1992) 80,680
Medical Waste Employees 2,000
Training Hours Per Employee 18
Total Hours When Completed (1993) 36,000
Collection Company Employees 18,000
Training Hours Per Employee 15
Total Hours When Completed 270,000
Training Starts January 1993.
- - - - - - - - -
Corporate 73 71 68
Regions 34 46 43
District 174 174 139*
----...--- --------L -------- ---------
Total 281 291 250
-------------- t -------- ------- ------
*Deoras due to consoflidton of distrifte.
Health and Safety Training
BFI's company-wide safety program trains employees to recognize
health and safety hazards and to protect themselves and the public.
BFI has tracked corporate-wide injury rates and vehicle accident rates
for over 13 years. Company databases also include medical and
industrial hygiene information. These databases also provide feed-
back information for the training programs.
BFI achieves improved safety performance through training of
hourly workers as well as managers and supervisors. The three-
pronged safety program consists of BFI-tailored training materials,
commercial training videos and support materials provided to our
operations, and formal workshops and technical seminars conducted
by safety personnel. BFI's video and support materials for our sub-
stance abuse education and prevention program have proven so effec-
tive that the National Safety Council now makes this video available
to other businesses.
The average new operational employee spends seven to 10 full days
in vehicle and classroom training. Each district holds monthly safety
meetings for all operational personnel and their supervisors.
BFI's ongoing seminars and safety manager workshops provide
hands-on, interactive training for supervisory personnel. Regular
technical seminars are designed to inform safety managers of new
or proposed regulations that impact their operation or the materials
handled at their sites. Safety managers at our medical waste process-
ing facility, for example, are now receiving training on the new
regulations regarding bloodborne pathogens. More importantly,
managers are trained to teach other employees safe medical waste
handling procedures that meet the federal regulations as well as
BFI's own standards.
BFI and the National Safety Council combined their resources in
1991 to create the "Safety Manager Professional Development
Program." The joint effort is the first such program for the Council,
a non-government, not-for-profit, public service organization
dedicated to the reduction of accidental deaths, injuries and illnesses.
The BFI/NSC program has become a model for other companies
willing to invest in an extensive, nationally-accredited professional
~-_--e- ~~ ___~___~~~~~~
Operational and Technical Support
Managers at BFI avail themselves of an array of technical and oper-
ational support services from our corporate office. These services are
designed to provide specialized expertise not available in our dis-
tricts. Some examples:
Our technical service departments in Houston supervise
and support our extensive and growing groundwater
monitoring programs and company-required waste
acceptance testing for all our landfills.
Corporate engineering provides our regions and districts
with skilled design and engineering services. All our
facilities and equipment are designed with worker safety
and environmental integrity as top considerations.
The storm water management program, described in
more detail in Chapter I, was created and tested by BFI's
corporate environmental staff before being adopted by all
Landfill gas recovery operations are supervised from our
9 headquarters, providing centralized guidance and
support for individual landfill managers.
Driver training programs and updates are created and
monitored by corporate support staff.
BFI believes that providing certain services from a central
location allows for the development of a high degree of compe-
tency and expertise, and allows for the kind of monitoring,
measurement and oversight that become the basis for change
BFI's Environmental Auditing Department (EAD) is responsible
for the systematic environmental auditing of all BFI facilities in
North America. The purpose of the environmental auditing program
is to validate the effectiveness of the company's other environmental
management systems. While auditing can help identify and correct
situations that do not conform to regulations or company policies,
H auditing is not a means to implement daily compliance. Facilities
have their own management systems designed to ensure compliance
and achieve environmental excellence when auditors and government
inspectors are not present.
A.C.T. training goes
beyond the classroom
to on-site demonstrations
that take a team approach
Jim Candler, Wendy D'Attilio
and Lincoln Romain walk a solid
waste landfill site during an audit.
"Because direct responsibility rests with the
district managers, a system of self-audits or
self-inspections is integral to the EHS pro-
gram. Self-audits are the mechanism by which
managers conduct their daily business and
ensure that their operations meet regulatory
standards and conform to company policy.
Managers of various facilities are required to
conduct facility inspections personally on a
regular basis. Self-audits and the required
facility check lists are powerful tools and rep-
resent the day-to-day implementation of the
EHS management system.
The Environmental Auditing Department is separate from the
operations and compliance support groups of the company, with the
Divisional Vice President, Environmental Auditing and the four
full-time environmental auditors reporting directly to the General
Counsel. Overall environmental experience of these individuals
ranges from nine to 19 years, with three individuals having prior
regulatory enforcement experience.
A total of 55 audits were conducted during the 12-month period
from October 1991 through September 1992. All business systems
and geographic regions within BFI's North American operations are
subject to review by the EAD.
Audits are multi-media in scope: control systems for waste genera-
tion, surface water, groundwater and air are reviewed. A standard-
ized review of specific safety and health control systems is also con-
ducted. It is important to note that auditors review not only for con-
formance with federal, state and local regulations and permits, but
for conformance with company-established policies and procedures
as well. In addition, if an auditor has a suggestion for improvement
that is not specifically required by a regulation, permit or company
policy, he or she is still expected to identify the issue in the formal
audit documentation for consideration by management.
Many findings are acted upon right away, but other items require
that an action plan be developed and implemented. Facility managers 4
are required to develop an action plan for each finding that cannot be
resolved immediately. Their draft plan is reviewed by regional and
Lb I L ~_~
corporate personnel before being made final. All action plans must
include both corrective and preventive measures to assure that prob-
lems do not recur.
All data related to audit findings, actions taken or planned and
follow-up activity are computerized using a BFI-developed program.
This system allows ongoing monitoring of progress and long-term
performance trend analysis.
Training and auditing are among the essential elements of an envi-
ronmental management program. Creating the right incentives and
feedback loops for managers make that program successful. BFI has
developed a program for landfill district managers that links their
compensation, and that of their supervisors, to environmental perfor-
BFI, like many other companies, compensates most of its managers
through a system of salary and bonus, with the bonus often compris-
ing a significant amount of total compensation. The bonus award is
tied to meeting certain goals each year.
At BFI, we have directly tied bonus awards for our managers to
environmental performance. The environmental component of the
bonus acts as a multiplier to determine the size of the bonus; it is
not just another item on a list of goals to be met. The size of the
multiplier is determined by a manager's performance in meeting 20
specific compliance and EHS performance-related goals. Below a
certain level of achievement, a manager receives no bonus compensa-
tion, regardless of positive performance in other areas.
The program began in fiscal year 1991; during that year, 90% of
landfill managers received some bonus compensation, reflecting a
high level of environmental achievement.
As part of our commitment to continuous improvement, the
expected level of achievement is raised each year. A similar compen-
sation program is presently being implemented for solid waste
collection district managers and other facility managers.
Regional Vice Presidents' bonus compensation is tied to the envi-
I ronmental performance of their district managers as well as to other
environmental performance criteria.
(July 1990 thro Sptnm* 1992)
Total Facilities 102
*Inluds sipel wrvic, closed hard warte
IaMk ncyNg md cnpo tMW fathNl
n this chapter, we will discuss the different business operations
that constitute BFI, our compliance record and the regulatory
framework in which each business operates.
As a general matter, the number of environmental violations have
trended downward in the past years; we are proud of that achieve-
ment. Increased training, employee awareness and concerted manage-
ment attention are key reasons for that trend. Our company goal is
In the area of health and safety, the trend data are much more
extensive, with the same downward direction. The goal, too, is the
same: zero violations and accidents.
While zero violations may seem impractical and may never be
achieved, given the complexity of laws and regulations, we are deter-
mined to strive for perfection through continuous improvement in
all our EHS programs.
The audit results described here are indicative of the strength and
effectiveness of our programs.
In our landfill operations, audit results of nine facilities audited
prior to the A.C.T. training for landfill personnel in 1991 provided a
baseline against which to compare results from 14 different facilities
audited after that training.
The average number of environmental findings (defined as regula-
tory, company policy and management discrepancies) per facility
before training was 17.3; after training, that number was reduced
almost 50% to 9.04. If OSHA issues were included, the results were
20.3 versus 12.6. We believe these improvements were due not only
to increased training but also to implementation of other programs,
such as the bonus incentive plan described earlier.
The number of action items (corrective steps to be taken) com-
pleted on time increased from 41% to 77% after training; and the
average number of days to complete all action items fell from 198
to 71, an improvement of 65%. Some corrections are made quickly
or on the spot. Implementation of procedural changes to prevent
recurrence may require not only rewriting procedure but also
scheduling training. Some items may require regulatory or other
~_ __L1~ _
IU.S. POPULATION DENSITY
BFI's solid waste, medical waste, recycling and collection operations are strategically located to serve the population centers of the country.
(Reprinted with permission of American Demographics, July 1991.)
I ~g) -~ II
1.5 -- ------------------------
10 -------e e wu wr -aye -
- - -
5 --------- ---------------------
*The Bureau of Labor Statistics measures 200,000
hours worked, or approximately the number of hours
100 employees would work In a year.
Finally, the average number of findings that involved regulatory
issues was cut almost in half after A.C.T. training from 13.9 to 7.3.
As noted earlier, medical waste employees are just completing their
A.C.T. training; employees in our collection, transfer station and
recycling operations will begin their training in January of 1993.
Audits of seven hauling companies in 1992 revealed an average of
11.4 findings per facility, of which over one-half involved issues
covered by OSHA. Audits of five medical waste facilities in 1991 and
1992, before receiving A.C.T. training, revealed an average of 15.8
findings per facility; approximately one-half were non-regulatory in
nature, and about one-third were OSHA-related.
Health and Safety Results
As the accompanying chart clearly demonstrates, the BFI Health and
Safety Program is having a significant, positive impact on our people.
The average number of lost-time injuries has declined more than
50% in the last 10 years. BFI's record is better than the average for
all industry, as compiled by the Bureau of Labor Statistics. In fact,
our rate for 1992 is at 5.91, continuing the downward trend shown
on the accompanying chart. We attribute that level of performance
to superior and continuous training of our workers.
In 1991, the company had 148 OSHA citations, as a result of
Agency inspections or employee complaints, at its more than 450
operating locations in the United States. They included equipment
deficiencies, material handling concerns, information deficiencies,
lack of protection devices and enforcement concerns. Less than one -
third were considered "serious" under OSHA guidelines. All viola-
tions have been corrected or accounted for; the company paid a
total of $55,000 in OSHA penalties in 1991 and $18,000 thus far
New Landfill Regulations
On October 9, 1991, the U.S.EPA issued its final regulations under
Subtitle D of RCRA, setting forth minimum federal standards for
municipal solid waste landfills. Subtitle D is a federal rule intended
for implementation by the states.
Included in the Subtitle D Rule are location restrictions; operating
and design criteria, including liner, groundwater monitoring and
leachate collection system requirements; gas management require-
ments; corrective action requirements for
closure and post-closure care and financial
While the majority of the requirements of
Subtitle D are to become effective October
9, 1993, some parts of the rule have differ-
ent implementation dates. The closure
requirement (which specifies the type of cap
required to be installed at a landfill upon
closure) was effective on October 9, 1991.
The groundwater monitoring requirements
are to be phased in over a five-year period,
beginning October 9, 1993. The financial
assurance requirements will become effec-
tive on April 9, 1994. Certain requirements
of these new rules, such as the liner and
leachate collection requirements, affect only
new facilities and expansions of existing
BFI has a comprehensive program to
ensure that each landfill we own or operate will meet Subtitle D
standards as they are implemented by each state. A recent survey
of our facilities indicates that most already meet the expected
Except in those few cases where states have granted exemptions,
all BFI landfills have full groundwater monitoring systems. In addi-
tion, all operating BFI solid waste landfills have radiation screening
programs to prevent any radioactive waste from entering the facility;
BFI policy prohibits the disposal of radioactive waste at its facilities.
All BFI transfer stations and landfills employ workers who are
trained to visually inspect all waste loads to prevent the disposal of
prohibited wastes, including hazardous wastes, vehicle batteries, etc.
The number of enforcement actions against BFI landfill facilities
has shown a steady decline, as has the amount of fines levied for
those violations. Our goal is to eliminate them altogether. We
believe the results presented here demonstrate our commitment to
sation is tied directly
inspects the site in
We believe the
results presented here
commitment to environ-
In its active solid waste landfill operations during calendar year
1991, the company paid fines totaling $56,034 resulting from settle-
ments and consent orders; there were 13 citations at BFI's 100 facili-
ties. BFI will never be happy with any fines or violations. The goal of
our EHS programs is zero violations.
The $56,034 in penalties were paid to settle nine of the following
citations. Corrective actions were taken in every case.
A portion of a landfill access road was built with demolition
debris. Massachusetts. $13,700.
Waste characterization sheets were not updated, and required
samples for certain wastes were not obtained at a landfill in
A settlement agreement was reached with the State of Louisiana
for seven alleged permit violations that included surface water
runoff, leachate control, daily and final cover, vector control,
records management and maintenance of collection basins and
groundwater systems at a solid waste landfill. $10,000.
A small portion of landfilled waste was left uncovered at the
end of day at an Illinois landfill. $500.
Adequate drainage was not provided on a landfill access road.
We failed to apply for a permit modification to use an alternative
material (different grade of gravel) in the construction of the
leachate detection zone at a Pennsylvania landfill. $12,000.
We failed to comply with certain sediment control requirements
at a Maryland landfill. No penalty.
Sediment was discharged into surface waters from a sediment
control pond during cleaning operations at a Pennsylvania
We accepted waste in violation of permit limits for one day at
a Pennsylvania landfill. $1,259.
Topsoil was removed from a site for landfill use without a
proper zoning permit at an Ohio landfill. No penalty.
A Massachusetts landfill exceeded permit limits on daily disposal
tonnages in 1988. $1,000 penalty paid in 1991.
A California landfill's contractor's crew were not adequately
trained in gas control or collections systems safety and did not
have approved safety equipment. No penalty.
A Louisiana landfill was ordered to repair and upgrade monitor
wells. BFI completed the work. No penalty.
While the data are not yet complete, our record for 1992 will show
Closed Facility Management and Remedial Activities
BFI manages its closed solid waste landfills, those facilities which
may be involved in some way with the Superfund program under
CERCLA, and sites undergoing monitoring and remedial action,
through its Department of Environmental Remediation and Closure
Activities (ERCA). The company also manages certain closed
facilities from its discontinued hazardous waste business in this
Virtually every major company in this country is involved in some
way with the Federal Superfund program. BFI is no different; most
of the company's involvement comes from transporting waste to
various disposal facilities. It is BFI's policy to work cooperatively
with other Potentially Responsible Parties (PRPs) and the govern-
ment to reach settlements at sites where there is actual BFI involve-
ment just as quickly as possible.
BFI has been named as a PRP at 67 sites listed on the National
Priorities List (NPL); of that number, six were actually owned or
operated by BFI.
The company has negotiated full settlements with the government
with regard to 45 of the sites and partial settlements at seven addi-
tional sites. Fifteen sites remain in which the extent, if any, of BFI
exposure has yet to be determined.
In addition, the company has been asked by the government to
provide information with regard to its potential involvement in 57
other sites. For 38 of those sites, it has been determined that BFI had
no involvement. For the remaining 19 sites, BFI's involvement, if any,
is still to be determined.
The company's situation with regard to Superfund changes fre-
quently, and the number of sites involved may increase or decrease
depending on EPA findings now and in the future. It is company pol-
icy to cooperate completely with all authorities involved.
Total Caseload 124
(As of Oct. 1,1992)
Total Closed Facilites 61
As of October 1992 the company is managing 61 closed facilities,
of which 42 are closed solid waste landfills. Management for these
facilities has traditionally been the responsibility of districts and
regions. This year, BFI instituted a program to centralize the control
and oversight of all closed solid waste landfills in the ERCA
Department; that effort will be completed by the end of 1993.
As facilities are brought into this new system, maintenance and
monitoring data are reviewed to ensure that no additional activity
In 1991, two penalties totaling some $657,000 were paid by the
company to settle citations at its closed facilities. The Chairman's
Letter discusses the $600,000 penalty paid to resolve the well-casing
dispute. An additional $57,000 penalty was paid to settle a citation
at the same facility involving naturally occurring iron exceeding
permit discharge limits.
The company manages four closed hazardous waste disposal sites
that were part of CECOS, BFI's hazardous waste subsidiary which
ceased operations in early 1990.
The sites, located in Louisiana, Ohio and New York, have all begun
closure operations under RCRA requirements. Formal closure plans
have been filed for three sites, and closure plans for the fourth site
are included in a permit application. One plan has been approved in
The company also manages 15 miscellaneous sites, either old
mixed-use sites or sites that have come into the company's possession
through acquisition. These are sites that require ongoing monitoring
after remedial action to correct identified problems. In most of the
cases, activity has included installing or upgrading leachate collection
systems, landfill gas extraction systems and landfill caps.
Collection and Transfer
Collection and transfer operations have traditionally not involved
significant regulation. In the past several years, that has changed.
Two areas in those operations, storm water management and under-
ground storage tanks, are now subject to regulation.
Storm Water Management
In 1991, the EPA issued regulations that required certain industrial
and other facilities to manage storm water run-off. The regulations
required that such facilities eventually have permits specifying con-
trols and management practices.
In response, BFI conducted a research and development project to
determine the "best practices" for storm water management at its
collection, transfer and recycling facilities. BFI found that relatively
simple refinements in vehicle maintenance, as well as regular sweep-
ing of parking lots, and expeditious clean-up of oil leaks and spills
were effective in bringing storm water run-off within acceptable
standards. Those "best practices" have been systematically shared
throughout the company. As a result, 40% of our facilities meet our
best-practice standards so far. In many cases, these facilities have
reduced run-off contaminants by over 85%.
Underground Storage Tank (UST) Remediation
In anticipation of Subtitle I of RCRA, BFI conducted a company-
wide evaluation of underground and above-ground fuel storage tanks
and developed recommendations and a schedule for implementation.
The technical requirements of the survey were designed to ensure
that all existing UST's were identified and either upgraded or
replaced in advance of the 1998 deadline. In addition, BFI examined
the overall use of its tanks, and, where low usage was determined,
the tanks are being removed.
BFI has chosen to go beyond EPA minimum requirements by
installing double-walled tanks and double-walled piping where new
tanks are required.
BFI operates the largest medical waste collection and disposal
business in North America. BFI owns or operates 23 regional treat-
ment sites, and serves more than 75,000 health care customers,
including more than 1,900 hospitals.
The company employs a mixture of incineration and autoclave
(high temperature pressurized treatment) technologies to treat med-
ical wastes at its regional facilities.
BFI operates incinerators at 10 sites, autoclaves at 10 sites and
both an incinerator and an autoclave at three additional sites. The
company processes approximately 21 million pounds of medical
waste each month.
Number of UST Tanks Removed: 0
.-- -- -- --.--...........-.- .-.----- ....
Percent of Total Tanks Removed:
(by September 1992) W
26 Tanks Were Replaced 0
(All with Double-Walled Tanks).
Total Number of Tanks:
- - - - - - - - - .
BFI medical waste
facilities use comput-
erized control systems
to carefully monitor
operations to ensure
safety and compliance.
Next to solid waste disposal, medical waste services may be the
most regulated business we operate. Though there is no federal legis-
lation regulating medical waste, most states have enacted laws to
control medical waste. In addition, other federal agencies have imple-
mented regulations affecting health care workers that impact this
business; the recent OSHA
bloodborne pathogen rule is an
BFI medical waste employees
receive intensive training at all
levels. All employees at our
medical waste facilities are cur-
rently undergoing the A.C.T.
environmental training pro-
gram (see page 7). In addition,
every medical waste employee
receives a minimum of eight
hours of safety training each
year. Incinerator operators received an additional four days of train-
ing to meet federal and certain state examination requirements.
Medical waste safety managers receive three additional days of spe-
cial training each year.
*The one violation with a penalty for the medical waste services
business in 1991 involved a subsidiary in New York State that was
cited for operating a transfer facility without a proper permit. The
company had applied for a new permit pursuant to proposed regula-
tions, but those regulations took effect before the new permit was
issued. The company paid a $25,000 penalty.
In 1991, the New Jersey Department of Environmental Protection
and Energy (NJDEPE) alleged that a BFI subsidiary failed to properly
fill out medical waste tracking forms for waste destined for a BFI
incinerator in Pennsylvania. Measures have been put in place to
correct the problem, and no penalty was imposed.
In January 1992, a BFI subsidiary operating a medical waste
incinerator in Ohio paid a penalty of $416 for exceeding permit lim-
its for metals in its waste water. Those exceedences were detected
during a cooperative testing program between the local government
and BFI. Corrective measures have been implemented.
a Nothing has defined change in the waste services industry more
clearly than the growth in the public demand for recycling.
In 1988, BFI served 40,000 residential recycling customers; today,
we serve more than 3.1 million. The number of BFI material recov-
ery facilities (MRF) has also expanded from two to 67 during the
same period. BFI also provides some 40,000 commercial customers
with recycling services, up from 30,000 in October 1991. We have
committed significant resources to this business because BFI's goal is
to be the leader in solid waste recycling.
Recycling centers and processing facilities must meet the same
environmental worker safety standards as other commercial opera-
tions, so close attention is paid to compliance with OSHA regula-
tions. Managers of these facilities are expected to achieve the same
level of performance excellence and compliance. Accountability will
be achieved through the use of compensation incentives similar to
those now in place for our landfill managers. Self-audit requirements
and regular BFI audits ensure the oversight necessary to keep these
facilities at a high level of performance.
BFI undertakes special programs to respond to the specific recycling
needs of our customers.
BFI operates both vehicle and household battery collection pro-
grams at 31 collection centers in six regions. An increasing number
of states now ban vehicle batteries at landfills and mandate their
return to dealers through deposit systems. BFI supports such
BFI operates 26 used oil collection programs from six regions as
part of its recycling services. We are able to provide it when and if
our customers request the service. We have developed systems and
techniques to guarantee the safe collection, storage and transfer of
Used oil. We have, for example, provided curbside residential used
oil collection in San Mateo, California, for over five years.
Households '40,000 nA a rin
Recyclerles 1 a 67
Curbside Programs 10 4m2 s
Volume of :useooo
Materials Collected: an
*yew to date
Windrow composting, shown
here, requires regular turning of
the organic waste.
BFI Organic Waste Services
BFI, primarily through its subsidiary Resource Conservation
Services (RCS), is involved in the collection, processing and disposal
of a wide range of municipal and industrial organic wastes. They
include yard wastes, food and food processing wastes, certain
agricultural wastes, ashes and sludges from sewage treatment plant
and industrial facilities suck as paper mills. BFI uses a wide variety of
processes to handle these wastes, including land application and com-
posting. Through its various programs, BFI processed more than
775,000 cubic yards of organic waste in 1991, putting much of it to
more productive use and preserving valuable landfill space.
BFI operates a number of composting facilities at its landfills to
handle yard waste; it operates a dedicated compost facility in New
England that successfully processes a wide range of commingled
organic wastes. BFI operates land application programs in Maine,
New Hampshire and
BFI is involved in
a number of unique
projects with super-
market chains and
restaurants to collect
and compost their
Many states now
require some type of
permit for compost-
ing facilities. Except
for some concern
odors, our facilities
have operated with-
out violations for the last two years.
Effective odor management is a critical factor in composting opera-
tions. BFI takes a comprehensive approach to odor minimization,
beginning with the siting process selecting a location for compost-
ing with compatible neighboring land uses proper site design and
the selection of a composting technology suitable to the location. BFI
composting facilities also employ good housekeeping and process
At the BFI Hawk Ridge facility in Maine, neighbors keep odor con-
trol logs. Through the logs, we are better able to monitor results of
BFI Tire Recyclers
Transforming a waste problem into a source of energy is the business
of BFI Tire Recyclers. BFI's processing of waste tires produces an
alternative fuel source that can be used in power plants and paper
mills and removes this troublesome material from the waste stream.
Currently, more than 30 states in the U.S. have some form of
legislation mandating alternatives to landfilling whole scrap tires.
Cutting up tires before landfilling has been one way to reduce the
handling and volume problems tires present. BFI's process creates a
high-grade Tire Derived Fuel (TDF) to be mixed with coal or wood
chips for use by power plants and paper mills. The TDF contains a
higher BTU value per pound than many types of coal; the use of the
mixed fuel reduces the levels of certain pollutants, such as sulfur
dioxide, that would result from burning 100% coal. The company
currently operates three of these facilities in Ohio, Georgia and
BFI provides street and lot sweeping, portable toilet and septage ser-
vices at certain districts around the country. These services represent
a small part of BFI's overall waste services business. This business is
now in the process of being sold.
The biggest part of the toilet and septage business generally involves
the collection of waste from septic tanks and portable toilets and the
permitted disposal in municipal sewage treatment plants. In April
1992, a special services subsidiary reached a $1,600,000 settlement
with the City of Philadelphia involving the alleged unauthorized dis-
posal of certain septage wastes at city waste treatment facilities.
The subsidiary is authorized to continue disposing of waste at those
The company has undertaken an extensive examination of proce-
dures at our special services operations to guarantee compliance with
company policies. We have also accelerated our training program for
special services employees.
American Ref-Fuel is a joint venture between BFI and Air Products
and Chemicals, Inc. of Allentown, Pennsylvania, formed to develop
and operate waste-to-energy facilities.
American Ref-Fuel operates the following facilities:
Facility Design Throughput Start-up
Hempstead, 2319 tons per day 1989
Long Island, NY
Essex County, 2277 tons per day 1990
Preston, CT 600 tons per day 1992
American Ref-Fuel's plants are designed to meet the most stringent
environmental standards; the company uses high temperature -
controlled combustion and lime scrubbers with electrostatic precipi-
tator or baghouse filtration technologies to remove airborne contami-
nants from the smokestack exhaust.
All American Ref-Fuel plants have continuous stack emission moni-
toring and report all data to regulatory authorities; for 1991 the
company-wide performance exceeded 99.9% of permit requirements.
In 1990, the company sought and entered into an Administrative
Consent Order which allowed the New Jersey facility to start-up and
operate while permitting, designing and constructing a nitrogen oxide
control system. A stipulated penalty of $200,000 as provided for
under the Order was paid in 1991.
In New Jersey in 1991, the company received an administrative
penalty assessment for alleged exceedences of opacity, sulfur dioxide,
mercury and oxygen emissions limits. The company has appealed the
proposed penalty, and the matter is currently in litigation. The com-
pany had reported to the authorities sulfur dioxide exceedences over
a two-week period and traced the cause to unauthorized loads of
construction material brought to the facility.
American Ref-Fuel has intensified waste inspection procedures and
has taken action against the offending haulers. The company has also
worked with Essex County and local governments within the County
to remove household and other batteries from the waste stream.
within the last three years, BFI has initiated a number of CHAPTER III.
waste reduction and recycling programs for the various WASTE MINIMIZATION
wastes it generates in its operations. The company has AND RECYCUNG:
also instituted conservation programs to address the resources it con- OUR COMMITMENT
sumes. Because of BFI's membership in the President's Commission IN ACTION
on Environmental Quality, several districts will participate in a
comprehensive waste reduction/pollution prevention pilot program
BFI is committed to encouraging the development of permanent
recycling markets. BFI has taken an active role in state and national
legislative debates; we have supported minimum content legislation
for newsprint, for example, and we support elimination of govern-
ment subsidies for virgin materials that create unfair economic
advantage over recycled material.
We are managing our purchases of certain materials used in our
business to give preference to recycled or recyclable materials. We
have also entered into a number of joint marketing agreements with
major users of recyclable materials.
All bins used by BFI in its curbside recycling collection program
(now serving approximately 3,100,000 households) have a minimum
post-consumer HDPE plastic content of 25%. The feedstock comes
from milk jugs collected
BFI is committed to encouraging the development of permanent recy
in. our programs.
Virtually all of the cling markets. We are managing our purchases of certain materials us
company's publications in our business to give preference to recycled or recyclable materials.
and stationery are
printed on recycled paper. BFI's 1991 Annual Report was printed on
recycled paper, supplied by Patriot Paper Company, manufactured
from post-consumer paper supplied from BFI recycling programs.
The company is now reviewing its purchasing specifications for
other products it uses in quantity, such as lubricants and steel con-
tainers, to determine if products with recycled content can be
Internal Recycling Programs
Most of BFI's district locations have active recycling programs that
involve a variety of materials. At the corporate office, recycling has
been carefully tracked because the money from the recycled materials
BFI has set a goal to recycle
100% of its used oil.
funds an employee-organized community charity program. In 1991,
the company collected for recycling over 180 tons of various materi-
als from the corporate office.
011 Recycling, Antifreeze, Truck Wash Water
BFI is researching the market for suitable oil recyclers to supply BFI
vehicles with recycled oil for use in its trucks and equipment. The
company is com-
mitted to using
recycled oil in all
of its trucks and
l 9. A equipment, pro-
vided use of the
does not void
ranties. BFI han-
dles its own oil
company goal is
Sd-. to recycle 100%
of the motor oil
it uses. Data
from the largest
recycler BFI uses
show it received more than 78,000 gallons of motor oil from BFI in
1991; that oil was processed primarily into lube stock and fuel.
BFI has reduced its annual consumption of antifreeze by approxi-
mately 90%. As part of its operating requirements, the company has
moved from annual replacement of antifreeze to replacing antifreeze
every two years. The company is studying the further reduction of
antifreeze use on a longer time frame by using filtered antifreeze until
it is no longer effective. BFI is developing a network of vendors that
recycle antifreeze. Districts are encouraged to return used antifreeze
to these vendors for recycling. d
Conservation of Resources
BFI has undertaken two initiatives to reduce consumption of energy.
The Green Lights program is a USEPA-sponsored program whereby
businesses agree to survey all facilities and install energy efficient
lighting systems. Green Lights is a flexible partnership between the
public and private sectors. It is expected to reduce lighting electricity
usage at our headquarters by 60%.
The Energy Management System is a computerized program to
reduce overall energy use at corporate headquarters. BFI is installing
this system concurrently with the adoption of the Green Lights pro-
gram. The company expects to realize energy cost savings equal to its
investment in both programs within 28 months.
BFI is involved in the development of an alternative fuel vehicle
program with Mack Trucks, Gas Research Institute, Southwest
Research Labs and the Boston Gas Company. The pilot program will
convert a truck engine to use compressed natural gas or liquefied nat-
ural gas. BFI will supply and maintain the collection truck during its
use in the test period; the company is also responsible for detailed
record-keeping. BFI will pilot the use of alternative fuels in its smaller
trucks upon finding a suitable vendor. BFI is also actively involved in
a venture with Intermountain Chemical in Denver, Colorado, which
will use landfill gas to produce methanol to be used as a clean-burn-
ing additive for gasoline.
I-mollutionPre n rtionProgram
(for BFI VOec"es)
Program Status Goal
------------------- .-,- -
Oil Fitter Recycling 0
Antifreeze Re-Use 0
Battery Recycling 0 0
- - - - - -
Methane into Energy
The natural degradation of refuse produces a mixture of gases (pri-
marily methane and carbon dioxide) that must be monitored and
controlled to prevent odors and accumulations which could lead to
fire or explosions. Methane is also recog-
Four landfills presently recover gas for energy genera- nized as a potential contributor to the
tion, producing the energy equivalent of approximately greenhouse effect. BFI has an active pro-
400,000 barrels of oil per year. gram to address the generation of
methane at its landfills. At present, BFI
has methane gas collection systems at 45 of its landfills; another 10
systems are under construction. Four landfills presently recover gas
for energy generation, producing the energy equivalent of approxi-
mately 400,000 barrels of oil per year.
Through Browning-Ferris Gas Services Inc. (BFGSI), the company
is actively pursuing market development programs that put landfill
gas to beneficial use. Currently there are 19 landfill sites in some
stage of market development. BFGSI has formed a partnership,
Alternative Power Limited Partnership (APLP), with Pearce Landfill
Gas Power, Inc., a company with extensive experience in using lean-.
burn engines to generate electricity. Through this partnership, BFGSI
has designed systems to bring methane-produced electrical power on
line for commercial use.
BFI has negotiated contracts with electric utilities in four states to
generate electricity from landfill gas at six facilities. These projects
will produce enough electricity to serve more than 17,000 house-
Where the volume or quality of gas generated is insufficient for
other uses, BFI flares this gas using systems which have destruction
rates in excess of 99% for methane and non-methane organic.
Leachate Minimization Program
* Approximately 57 million gallons of leachate from BFI landfills were
managed at BFI landfills during calendar year 1991. Leachate is pro-
duced as a result of three factors: precipitation that comes into con-
tact with solid waste, the natural moisture content of the waste itself
that is released during compaction, and the moisture generated from
the biodegradation of organic matter.
BFI seeks to minimize the production of leachate through a number
of management practices. Most of the leachate generated in 1991
was collected and treated at publicly owned municipal sewage treat-
ment plants. BFI is evaluating and, in some cases, implementing pre-
treatment technologies to remove metals and organic from leachate
prior to its being treated off-site. Some BFI landfills are fully treating
their leachate using advanced waste water treatment plants sufficient
to meet stringent permit requirements. For example, BFI's Greentree
Landfill, located in DuBois, Pennsylvania, has a $4 million leachate
treatment plant consisting of a sequential batch reactor, activated
carbon beds and chemical precipitation technology. The treated
b leachate consistently meets stringent discharge requirements.
John Siggins takes a ground-
water sample at Greentree
Landfill, Pennsylvania. With
its on-site leachate treatment
system, the treated leachate
meets some of the most strin-
gent discharge requirements.
More than 8,000 copies of the
MOBIUS curriculum have been
provided to educators for use
throughout North America and in
87 other countries through the
Wildlife Habitat Enhancement Council
BFI became a member of the Wildlife Habitat Enhancement
Council (WHEC) in 1989 in an effort to demonstrate the pos-
itive impact that BFI facilities can have on the environment.
WHEC is a national conservation organization designed to help cor-
porations improve and utilize their lands for wildlife.
BFI has made a commitment to establish at least one wildlife habitat
at a BFI facility in each region. By mid-1992, three habitats had been
dedicated: North Shelby Landfill, Millington, Tennessee; Katy
Wildlife Habitat, Katy, Texas; and Charlotte Motor Speedway,
Harrisburg, North Carolina. Aber Road Landfill in Cincinnati, Ohio,
was recently certified. Additional habitats are planned for Old
Dominion Landfill and King & Queen Landfill in Richmond,
Virginia, in 1993; Sunshine Canyon Landfill in Sylmar, California,
in 1993; Woodlake Landfill and Flying Cloud Landfill in Eden Prairie,
Minnesota, in 1994; and Quad Cities Landfill in Bettendorf, Illinois,
These habitats provide BFI with an opportunity to involve facility
neighbors and local and state officials in a cooperative effort to
enhance the natural wildlife population in the community. Civic
groups, school groups, Boy Scouts and Girl Scouts have all participat-
ed in projects at BFI's wildlife habitats. In May 1991, David Clabo,
District Manager of the North Shelby Landfill, was awarded the
Environmental Law Institute's annual business category award for
outstanding efforts to conserve wetlands.
MOBIUS An Environmental Curriculum for Elementary Students
The MOBIUS solid waste curriculum for elementary school students
was developed for use in school districts, primarily in states where BFI
Entitled "Understanding the Waste Cycle," the MOBIUS curriculum
is a complete program for elementary grades four through six. It was
reviewed and tested by teachers and resource libraries and is designed
to teach children about all aspects of solid waste, from generation to
recycling, reduction and disposal. It was field-tested in school districts
in three states and Canada.
The program consists of the MOBIUS curriculum: "Understanding
the Waste Cycle"; a MOBIUS Fun Book of educational puzzles and
activities for children in kindergarten through third grade; and a
, 'Amalp .'
support service provided by BFI, including a toll-free 800 number.
MOBIUS takes its name from the German mathematician, Augustus
F. Mobius, who described the concept of a continuous loop with only
one side. MOBIUS was chosen as the name because it represents the
environmental cycle and is an internationally recognized symbol for
recycling and the environment.
In the past year, more than 8,000 copies of the curriculum have
been provided to educators for use throughout North America. The
MOBIUS Program has been introduced to schools in 45 states and
Canadian provinces. In addition, BFI recently provided copies of the
MOBIUS curriculum to the U.S. Peace Corps for use in environmental
education programs in the 87 countries where it has field services.
In 1990, BFI initiated the Community Partnership Program in New
York State. The program has as its goal the siting of new, environ-
mentally-sound, integrated waste disposal facilities in a state facing
an acknowledged, but unmet, landfill capacity shortfall.
S The program is designed to reduce the delays and confrontation in
the siting of solid waste disposal facilities through broad community
The Community Partnership Program is based on three principles:
The community must have the initial and fundamental choice
as to whether or not to host a facility.
BFI starts with no preselected site; we will look for a
site only after a community decides to host a facility.
The community must share in the economic benefits from the
operation of the facility.
The program was introduced through a mailing to all local govern-
ment officials in the state, inviting them to contact BFI if they were
interested. More than 80 communities have responded. At the
invitation of two communities, BFI set up offices in towns and began
an extensive outreach and information campaign. In both cases, by
petition and referendum, BFI was asked by the towns not to look for
a site. As promised, BFI closed its offices.
Recently, BFI has been asked, through a referendum, to return to a
community in western New York to establish a landfill and recycling
center. We are in the process of identifying sites and preparing a
proposal for the town.
BFI recently provided
copies of the MOBIUS
curriculum to the U.S.
Peace Corps for use in
programs in the 87
countries where it has
The Aber Road Landfill, a closed
hazardous waste disposal site, was
recently certified as a Wildlife
Enhancement Habitat Council site.
Volunteers built a lake and
worked to reforest the area and
increase bird populations.
AND SAFETY POUCY
It is the company's policy to:
Comply with all applicable environmental, health and safety
laws and regulations, minimize adverse environmental
health or safety effects from the company's business activities
and take positive action toward achieving a cleaner
Adopt administrative and operational standards where
protective laws do not exist or where the company believes
existing laws or regulations may not be fully protective of
health and the environment;
Cease to operate a facility or process, temporarily or perma-
nently, if necessary, to conform to this policy in a manner
consistent with the highest industry standards or otherwise
to control environmental, health or safety risks;
Work constructively with host communities and appropriate
regulatory agencies in the implementation of this policy.
To carry out this policy, the company will:
Conduct appropriate training and audit programs to ensure
that all employees are equipped with necessary information
relevant to their duties within the company to implement
this full policy;
Pioactively identify and control hazards to health, safety
and the environment resulting from its operations;
Conduct appropriate information sharing programs to
communicate the significant operating aspects of the
company's facilities with employees, the surrounding
communities and appropriate regulatory agencies;
Utilize cross-company quality committees to identify and
develop, where appropriate, additional company environ-
mental, health and safety policies which are more protective
than existing laws and regulations;
Encourage those affiliations where the company would not
be the majority owner to adopt policies comparable to this
Environmental, Health and Safety Policy;
Require each business segment to develop specific plans,
programs and procedures appropriate to that segment to
ensure effective implementation of this policy;
Work constructively with trade associations, elected officials,
governmental agencies and others to develop equitable
and effective laws and regulations to protect human health
and the environment;
Conduct reviews of new facility designs and construction
specifications to assure that appropriate environmental,
health and safety controls are in place.
Every employee is expected to adhere to the spirit as well as to the
letter of this policy. Should there be any question concerning the
lawfulness or protectiveness of any activity, then the employee should
consult his/her immediate supervisor, any higher level of management
or the General Counsel's office of the Corporate Legal Department.
Any employee who, within the scope of his or her duties, engages in,
authorizes or fails to take reasonable steps to prevent violations of
environmental, health and safety laws, regulations, permits or orders
applicable to any of the company's operations or facilities, shall be
subject to appropriate disciplinary action (which may include cen-
sure, reduction in pay, suspension or discharge). The company will
not take disciplinary action against an individual on the basis that
he/she exercised his or her responsibilities under this policy by con-
sulting management and or the office of the General Counsel.
Managers have a special obligation to keep fully informed about
health, safety and environmental requirements applicable to their
operations and to take all reasonable and appropriate steps to ensure
that the activities of their employees comply with this policy.
Managers are further obliged to consult with legal counsel and to
advise their supervisors promptly should any adverse situation con-
cerning this policy come to their attention.
Adopted April 1991
B rowning-Ferris Industries, Inc. is one of the largest publicly
held companies engaged in providing waste services.
Subsidiaries and affiliates collect,-transport, recycle, treat and
dispose of commercial, residential and municipal solid waste and
industrial wastes. BFI subsidiaries and affiliates collect, process or
dispose of solid waste in 45 states, Australia, Canada, Italy, Hong
Kong, the Netherlands, New Zealand, Puerto Rico, Spain, the United
Kingdom and Venezuela.
BFI's medical waste collection, treatment and disposal business is
the largest in the United States, serving more than 75,000 medical
waste customers. BFI owns or operates 23 treatment centers. Medical
waste services also include a collection and disposal program for
obsolete or outdated pharmaceutical materials.
BFI provides collection for a wide variety of recyclable materials,
including used oil, paints, tires and paper mill sludge, in addition to
glass, aluminum, steel, tin, plastics and paper. BFI provides recycling
collection services to approximately 3.1 million households and to
40,000 commercial customers. The company operates 67 material
recovery facilities to process recyclable materials collected by us
BFI subsidiaries also are involved in resource recovery facilities,
portable restroom and sweeping services.
BFI subsidiaries and affiliates have approximately 29,400 employees
around the world, operating in approximately 590 districts. In 1992,
the company disposed of approximately 24 million tons of waste in
the 96 U.S. landfills it owns or operates. BFI provides collection
services to approximately 700,000 commercial and industrial cus-
tomers, and more than 6.9 million households including 1.3 million
households in Europe.
Council for EHS Excellence
Mark C. Brantley
William S. Crumley
John J. DiNapoli
Bruce A. Gantner
Jonathan J. Greenberg
Pamela E. Harris
James C. Maher
Gerald F. Murphy
John W. Oneacre
Ronald V. Pfeifer
James E. Stone
Stephen J. Uthoff
Senior Vice President for Corporate Development
Divisional Manager, Memphis Division,
Mid America Region
Regional Compliance Manager, Southeast Region
Divisional Vice President, Landfills, Northeast Region
Divisional Vice President, Environmental Compliance
Senior Vice President and General Counsel
Director, Environmental Policy
Director of Loss Control Services
Regional Operations Manager, Midwest Region
Regional Operations Manager, Pacific Region
Director, Civil Engineering/Geoservice
Regional Vice President, Southwest Region
District Manager, Anne Arundel/Howard County
Solid Waste, Atlantic Region
Divisional Vice President, Planning and Analysis
(For more information, please address inquiries to Gregory Muldoon,
Chairman of Council for EHS Excellence, Browning-Ferris Industries, Inc.
757 N. Eldridge, Houston, Texas 77079)
Patriot Paper made the recycled paper for this report using waste paper collected by BFI. 0