ASTM E2365-21

Standard Guide for Environmental Compliance Performance Assessment

SIGNIFICANCE AND USE
4.1 This guide may be used for environmental compliance performance assessment in the United States in a wide variety of applications and is not particularly limited to one type of user. The following groups of users may find the guide particularly helpful:  
4.1.1 Small businesses or enterprises;  
4.1.2 Service industries;  
4.1.3 Federal, state or local facilities and regulators, including departments of health and fire departments;  
4.1.4 Financial and insurance institutions;  
4.1.5 Waste managers, including liquid and solid waste haulers, treatment, recycling, disposal and transfer;  
4.1.6 Consultants, auditors, inspectors and compliance assistance personnel;  
4.1.7 Educational facilities;  
4.1.8 Property, buildings and grounds management, including landscaping;  
4.1.9 Non-regulatory government agencies, such as the military; and  
4.1.10 Specific industrial sectors such as dry cleaners, printers, photo processors, laboratories, health care, and vehicle fueling, maintenance and delivery.  
4.2 This guide is intended as a first step in crafting simplified management goals for assessing compliance with a wide variety of multimedia environmental performance standards. The framework describes a process by which the user may categorize current waste management, air quality, water, and release prevention practices in order to manage the risks associated with noncompliance. The technique classifies common environmental performance standards into tiers based on relative risks to human health, the environment and business operations. The tier classifications found in this guide reflect the general requirements of State, Federal and local compliance and enforcement programs. These authorities generally classify groups of similar environmental performance standards according to the significance of any noncompliance within each group of standards.
Note 1: Users in the United States are encouraged to review the EPA’s Audit Policy Program: Frequently Asked...
SCOPE
1.1 Overview—This 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 Standards—This 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 preven...

General Information

• Status: Published
• Publication Date: 31-May-2021
• ICS: 13.020.10 - Environmental management
• Technical Committee: E50 - Environmental Assessment, Risk Management and Corrective Action
• Drafting Committee: E50.05 - Environmental Risk Management

Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E2365 − 21
Standard Guide 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 framework, they will find that risk is weighted by more than
just a few parameters. For each facility risk is the complex
1.1 Overview—This guide is an organized collection of
interaction among location, size, history, surrounding commu-
information and series of options for industry, regulators,
nity and ecological zones.
auditors, consultants and the public, intended to measure
compliance with environmental performance standards against 1.2 Differences Among Standards—This guide focuses on
established benchmarks. It focuses on compliance with air, compliance with environmental performance standards in the
water, waste prevention, waste management, and toxic reduc- United States.As such it includes a unique, risk-based method
tion standards for facilities in the United States. While the to analyze specific groups of legal requirements, as well as risk
guide does not recommend a specific course of action, it reductiontechniques,sometimescalled“pollutionprevention.”
establishes a tiered framework of essential components, begin- 1.2.1 Use of this guide provides a system to evaluate the
ning with those standards where a deviation presents the relative priority of compliance and pollution prevention activi-
greatest potential public health, environmental, and business ties. Unlike environmental management systems, it provides a
risks. In each identified pathway, at each tier or step of framework to triage critical issues, based on consideration of
analysis, the guide outlines ways to identify compliance actual risk of harm to public health and the environment.
options and reduce pollution in iterative steps. The goal in 1.2.2 Environmental regulatory requirements in the United
using the guide is to lower environmental, public health and States are administered primarily by the United States Envi-
businessrisksfromTiers1and2toTiers3and4,byevaluating ronmental Protection Agency (USEPA) and the parallel State
the performance standards described in this guide. While this and Local Agencies with similar regulatory authority. Certain
guide provides a simplified framework of explicit steps for
other Federal regulatory agencies and State and local counter
users, a qualified professional should conduct detailed, site- partsmayalsohavelegalrequirementsrelatingtoenvironmen-
specific risk analysis.This guide may act as a starting point for
tal performance standards. Examples include the Departments
organizations with limited experience in systematic environ- of Transportation (DOT) and Agriculture (USDA) and the
mental assessment. As facilities develop their specific plan
OccupationalSafetyandHealthAdministration(OSHA).Simi-
lar to the ISO 14001:2015 standard, this guide uses the major
groups of environmental regulatory standards in the United
1
States for air and water quality, waste management, release
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
prevention, and toxic materials use reduction, in order to
ity of Subcommittee E50.05 on Environmental Risk Management.
organize the compliance analysis framework.
Current edition approved June 1, 202
...

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: E2365 − 14 E2365 − 21
Standard Guide 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
1.1 Overview—This 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 Standards—This 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
This guide is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct responsibility
of Subcommittee E50.05 on Environmental Risk Management.
Current edition approved Jan. 1, 2014June 1, 2021. Published February 2014September 2021. Originally approved in 2005. Last previous edition approved in 20052014
as E2365–05.–14. DOI: 10.1520/E2365-14.10.1520/E2365-21.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
1

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E2365 − 21
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 l
...