- December 01, 1995, Watson, John W.
If you generate less waste, you will have less waste to dispose of. It's common sense, and it's cost-effective, but some companies still need convincing.
In response to President Clinton's oft-repeated rallying cry to "re-invent government," the US Environmental Protection Agency (EPA) has refocused its regulatory mandates away from traditional end-of-pipe controls. EPA's Common Sense Initiative is indicative of this attempt to forge partnerships with industry in an effort to develop cost-effective and flexible environmental regulatory programs. At the heart of these initiatives is an understanding that the focus of regulation should be on preventing the generation of waste at the source - referred to in EPA parlance as "Pollution Prevention" - rather than focusing on waste disposal issues.
Pollution prevention is not a new concept. In 1990 Congress passed the first federal Pollution Prevention Act. The primary objective of the Act is the development of environmental protection measures designed to prevent or reduce pollution at the source.
In 1991 EPA launched its first significant pollution prevention initiative - the 33/50 Program. This is a voluntary program under which companies were encouraged to reduce their emissions of 17 toxic chemicals 33% by 1992 and 50% by 1995. As 33/50 winds to a close, the program is getting mixed reviews. The latest results indicate that total emissions reductions achieved by the almost 1,300 companies that participated totaled almost 685 million lb.
While toxic releases have declined, EPA remains concerned about the lack of meaningful progress in reducing the amount of waste being generated by US industries. EPA's data indicates that last year, while facilities made progress controlling the release of toxic chemicals - primarily through recycling efforts - the amount of waste generated by industrial operations actually showed a slight increase.
As EPA continues to evaluate what the next generation of 33/50 programs will look like, it remains clear that pollution prevention will be important watchwords for environmental regulations as we approach the year 2000 and beyond. More than 30 states have passed pollution prevention laws calling for, in many cases, mandatory reductions in waste generated during industrial operations.
To a large segment of industrial America, however, pollution prevention remains an ill-defined and elusive concept. For others, pollution prevention has meant new ways of doing business that improve the bottom line and, at the same time, reduce pollution.
For the converting industry, the challenge is to understand how companies have successfully implemented the concept of pollution prevention into their operations and what resources are available to assist companies in these important efforts.
What is Pollution Prevention?
EPA defines pollution prevention as any "use of materials, processes or practices that reduce or eliminate the creation of pollutants or waste at the source." This definition encompasses any in-plant practice that prevents pollutants from entering any waste stream or from being released into the environment. Such activities may include changes in the design of products or industrial processes, raw material modifications or substitutions, wastewater reductions, in-process recycling or the reuse of process materials and measures designed to improve energy efficiency.
The passage of the Pollution Prevention Act in 1990 provided the federal imprimatur on the concept of pollution prevention as a regulatory strategy. Forward-thinking companies, however, have for a long time been integrating pollution prevention principles into their environmental management programs with astounding success.
The benefits of implementing a pollution prevention program are many. In the age of multimillion-dollar site cleanups and retroactive, no-fault liability for waste disposal, programs designed to reduce or eliminate waste production requiring off-site recycling or disposal simply make environmental sense. Waste reduction also alleviates compliance costs and the sector specter of EPA oversight.
The pioneers of successful pollution prevention - 3M, DuPont and Dow Chemical - have shown undeniably that successful programs can yield tremendous economic dividends. By looking for ways to reduce raw material use, to eliminate waste disposal and to increase operating efficiencies, cost savings can be realized. Many times the costs of pollution prevention can be recouped in a short period of time through the implementation of a variety of discrete and simple pollution prevention activities.
A Problem of Perception
If the benefits of pollution prevention are so obvious and the results readily achievable, why is it that, to most companies,it remains only a distant pipe dream?
A recent study conducted by Illinois State Univ. researchers found that problems of perception are the primary roadblocks to pollution prevention innovations. Environmental programs have always been viewed by corporate managers as costly impediments to productivity and profitability.
The study also found that traditional accounting practices fail to adequately measure the economic impact of waste production and disposal costs. This makes the task of selling a company on the benefits of pollution prevention difficult.
Corporate managers have also cited product quality and customer satisfaction concerns as additional barriers to the implementation of workable pollution prevention strategies. Any suggestions regarding the reformulation of products or the substitution of raw materials in the manufacturing process will likely be viewed with considerable skepticism. Many government-initiated pollution technology assistance programs have also been underused or ignored as a result of the uneasiness associated with bringing the regulators closer to a company's operations.
Implementing a Program.
Despite these obstacles, many companies have implemented successful pollution prevention programs. The programs generally include a number of common elements. The first and perhaps most important step is engendering management support.
A recent benchmarking study conducted by a number of corporations with "best in class" pollution prevention programs acknowledged that strong management support is critical to the success of any program. Selling management on the virtues of pollution prevention, however, may be a difficult task as corporate downsizing continues to squeeze programs perceived to be economic liabilities. The ability to detail the cost-effectiveness of any pollution prevention initiative will undoubtedly be critical to the program's chances of meeting management approval.
The next step is to assemble a qualified team, ideally comprising a diverse group of company professionals with a wide range of responsibilities and expertise. Key personnel to consider are representatives from maintenance, production, purchasing, environmental/health/safety, engineering and legal departments. These people must have knowledge of manufacturing operations and the processes that use raw materials and generate waste.
Once a team is assembled, a written plan should be prepared to memorialize management's commitment to the program and recognize that all employees should be encouraged to participate in waste reduction efforts. The plan should include a description of employee training programs that will be offered as well as the structure of any incentive programs to reward employee participation in pollution prevention initiatives.
The most important part of any plan will be the establishment of goals. Such goals may include a general commitment to replace all toxic substances used in operations with nontoxic substitutes. A company may also wish to establish more waste-specific goals as more information is generated regarding process operations.
At the outset of any new pollution prevention program, one goal ought to be a commitment to completing a comprehensive characterization of unit processes of a company's operations to understand what raw materials are being used and where in the process waste is being generated. This goal can be satisfied by gathering information regarding the multimedia waste generated during each production process and then back-tracking to determine the sources of the waste. Another method companies may use to accomplish this goal is to track the fate of raw materials from the point they enter the process until they exit as waste or product.
Only by completing this process evaluation will a company be able to identify the full range of available pollution prevention opportunities. Once these opportunities have been identified, they can be prioritized and implemented. Any and all actions taken should also be carefully documented so that pollution prevention successes and cost savings can be effectively communicated to management.
As the converting industry is keenly aware, tremendous pressures are being placed on industry from all segments of society to reduce waste and to develop environmentally friendly products and packaging. The challenge is to overcome the obstacles to pollution prevention and develop strategies to achieve the laudable goals of waste reduction as well as the economic benefits resulting from both more efficient and more cost-effective operations.
It is important to understand that help is available for companies wishing to implement pollution prevention initiatives. One of the key elements of the federal Pollution Prevention Act and many of the state laws that have followed has been the recognition that the regulated community can benefit from technical assistance and educational training on pollution prevention goals and strategies. Much of the federal and state funding has been directed at developing resources to assist companies in these efforts.
At the federal level the Pollution Prevention Information Clearinghouse is a free, nonregulatory EPA reference and referral center for the dissemination of information and resources. The Clearinghouse is located within the EPA headquarters library in Washington, DC, and can be contacted at 202/260-1023. Also available from the Clearinghouse is EPA's Pollution Prevention Directory, which includes information regarding federal and state programs in pollution prevention as well as a wide range of technical assistance partnerships and other resources.
The National Pollution Prevention Roundtable has prepared its Pollution Prevention Yellow Pager, which includes information on various state and local programs. A copy of the Yellow Pages is available from the Roundtable in Washington, DC, at 202/466-7272.
Excellent resources are also available at the state and local levels. State pollution prevention offices have developed many resources, including extensive technical assistance programs, to assist both small and large companies in their efforts. In Illinois, for example, the Illinois Hazardous Waste Research and Information Center has been created as a nonregulatory office of the Illinois Dept. of Natural Resources. Its mission is to provide technical and other assistance to companies involved in waste management and pollution prevention efforts. The Center's activities include conducting on-site assessments, working with industry sectors on studying pollution prevention technologies, and providing training and education on pollution prevention issues through workshops, conferences, seminars and newsletters. Similar programs are available in many other states.
For converters, technical assistance will come from the results of EPA's current work with the printing industry on the Common Sense Initiative. EPA's Design for the Environment Program is also working on a collaborative technical study with the Screen Printing Assn. International on pollution prevention alternatives associated with print screen cleaning operations. For information call EPA's Design for the Environment Program office at 202/260-1678 or contact the Pollution Prevention Information Clearinghouse.