3970 01
STUDY OF INDUSTRY MOTIVATION FOR
POLLUTION PREVENTION
DRAFT
April 23, 1997
by
ManikRoy
Ohad Jehassi
U.S. Environmental Protection Agency
Pollution Prevention Policy Staff
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Office Prevention. Pesticides and Toxic Substances
TABLE OF CONTENTS
" ' ' ES-1
Executive Summary ............................................ ^ ........... _
The Prevalence of Pollution Prevention ../.... .............. - ............... "-*
Traditional Environmental Regulatory Programs . . . : ........ ' ..... ..... ES"-->
Technical Assistance ........ ......... ............... ---- : ......... E ~
Poliution Prevention Planning ......... :...... ...... ............ -. ...... zb-4
Motivators Not Directly Related to Public Policy ................ ............ tb-4
The Respondents and Their Firms : ---- , : ...... ..... ............... ........ ES-5
Issues for Further Study ......... : ---- ............ " ..... ....... ..... V ESo.
Chapter One: Introduction . .......... ..... ..... ............. .......
1.1" Examining Pollution Prevention Hypotheses ...... ............... 1--J-
1.2 Reaching the Right Respondents
1.3 The Challenges . . ........ ............. ......... ..... . 1'T
Chapter Two: Findings ......... .............. ---- ---- .......... ...... ..... ^"j
2.1 Introduction ........ .................. ......... .......' ---- . . . .- ---- ^-i
2.2 Major Findings .................................................. 2"2
2.2.1 Major Finding #1: Pollution Prevention Activities Are Being
Practiced Widely by Large Manufacturers and Printers ....... 2-2
2.2.1.1 Reported Pollution Prevention Activities ........... 2-2
2.2.1.2 How Printers' Size Affected Pollution
Prevention Activity ......... ......... ....... ?-3-
2.2.1.3, How Tri Respondents' Size Affected Survey Responses ..... 2-4
2.2.1.4 Tri Reports by Large Manufacturers ............... 2-5
2.2.1.5 Other Interpretations . ---- ................... ......... .2-6
2.2.2 ' Major Finding #2: Regulatory Programs Are Almost Unrivaled in
Capturing the Attention of Core Business
Decision Makers. ........... ....... ................. 2"'
2.2.2.1 Reported Pollution Prevention Activities .......... ..... 2-7
2.2.2.2 ' Reported Importance of Regulatory and Assistance
Programs ...... ............ ....... ..... 2"9
2.2.2.3 Reported Importance of Government as a Source of
Information ........... ......... .......... ... 2-1 5
2.2.2.4 Other Aspects of Business Activities ---- ........... ...... 2-18
2.2.2.5 Size.... ........... .................... .....2-19
2.2.2.7 Other Interpretations ........... ........... ... 2-21
2.2.2.8 Observations Without Obvious Interpretations ...... 2-22
n
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1 2.3
' Major Finding «: Technical Assistance Is a Significant Influence
on a Finn's Pollution Prevention Activity. . . ... ..._. ..... ; 2-22
?. -> 3 1'. General Observations , > . . ,". ..... "-..' ...." ' 2-2j
- :. " SVsize ..... .;.....;..'.......,.,... -A:', ..... .,.-,....2.27
. 2.2.3.3 Other Interpretations ...... ............... *--°
2.2.3.4 Observations Without Obvious Interpretations ...... : 2-28
2.2.4 ^ .Majpr Finding #4:. Government Requirements Perceived as
"'"- " Requiring Pollution Prevention Planning Are Reportedly Very
\ ; Influential. ;,.................-... v- /- ^
2,2.4.1 General Observations ..... ............. ...... .......... ^»
2.2.4.2 Other Planning-.... ............... ---- .....";..... .^"^
2.2.4.3 Other Interpretations . . ...... ..... ---- ..... .......... 2-31
- 2.2.4.4 Importance of Being Subject to Massachusetts/New Jersey
Planning Requirements ......... ................ 2"31
23 Minor Findings . . . . ..... ........... ..... ...........
2.3.1 Minor Finding #1: Employee Morale-and Productivity, Input.
[ -. , Materials, and Customer Preferences Are Top Concerns for
: Production Managers. ...... ..... ---- ---- ....... 2'34
' 2.3.1.1 General Observations ... ..... ................... v-- 2-3
.........
2.3.2 Minor Finding #2: Tri Respondents Cite Corporate Policies and
Management Directives as Very Important in Getting Them to -.
' Consider Environmental Issues ...... ................... 2-38
233 Minor Finding #3: Printers Are More Likely To Cite Their
Personal Interest and the Interest of Their Family and Friends as
- Very Important in Getting Them to Consider .
Environmental Issues ...... '. . ..... ......... ......... 2-38
' 9.TQ
2.3.3.1 Size .......... . ..... ,.--..., ...... .................. ._^^
2.3.4 Minor Finding #4: Vendors and Company Employees Were Cited
, \- as Very Important Sources of Information. ................ 2-40
Chapter Three: Issues for Further Study ................. ..... ......... ' ' ' ' ' " ^
3.1- Introduction ..... ... ...... ---- ---- : ' : -.- :.' '' '/ '-' ' ' ' ' ' "
32 Issues and Recommended Approaches ..:.. ... ------- ........ ..... .....
'- ; 3.2.1 How much pollution was actually prevented as a result of the reported -
, pollution prevention activities? ..... ......... ---- ....... ...;... 3-1
3.2.2 What reforms to the environmental regulatory system would make
respondents' jobs more productive economically
and environmentally? ...... ...... ...... .......... .............
3.23 By what measure do respondents gauge their own "good environmental
-. .citizenship"?. ...... : ....... ..... ..... ..........;..-
in
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" ,2.4 What leads TRI business managers to issue environmental policies.and
directives, and how do they evaluate the success of production managers
in achieving the objectives of those policies and directives? 3-4
3.2.5 Which company employees are important sources of environmental
information and[where do they get their environmental information? .3-7
3,2.6 What role do customers play in driving environmental issues? ' .. 3-8
3.2.7 What "pollution prevention planning requirements7' influenced the
decision-making?
Appendix A: Research Methodology , ^"j
. A.I. Summary '' "
A.2. Sample Selection A-i-
A.3. Preparation of Survey Instrument A'^
A.4. -Pretest and Revisions ^
A.5. Administration of Survey : A"3
A.5^1. Survey Protocols A"3
A.5.2. Disposition of Completed Survey , A'4
A.5.3 Evaluation of Possible Nonrespondent Bias A'6
A.5.3 1 Coded Reasons for Refusal : A-7
A.5.32. Tested Differences among Tri Manufacturers A-7
A.5.3.3 Tested Differences among Printers A-8
A.6. Post-survey Weighting A~j*
A.7. Linkage of Independent Information A"9
A.8. Environmental Permits : ; ^
A.8.1 EPA,Permit Data on Printers ......... :....... A-9
A.8.2. Epa Permit Data on Tri Manufacturers A'10
A.9. Compliance History i ' = A"j |
A.10. Facility Ownership by a Fortune 100 Company A'11
A.I I., Waste Reduction Normalized for Production -.. . A-11
A. 12. Post-survey Statistical Testing of Correlations and Results ... A-12
Appendix B: Sample Selection Weighting, Post-survey Weighting
and Statistical Analysis ." ..- R"I -
B.I Basic Sample Selection Weight ti~^
B.2 Nonresponse Adjustment Weight , B-2
B.3 Estimating Percentages or Proportions " " R 4
B.4 Estimation of Proportions for Subgroups , B'4
Appendix C: Industry Motivation Survey C-l
IV
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' . ,. DRAFT ' March 31. 1997
STUDY OF INDUSTRY MOTIVATION
POR POLLUTION PREVENTION.
Pollution Prevention Policy Staff
U.S. Environmental Protection Agency
''"-. '.-,' , J EXECUTIVE SUMMARY ; '"' ''"...
This document "A Study of Industry Motivation for Pollution Prevention," reports on a
study undertaken by the Pollution Prevention Policy Staff (PPPS) of the U.S. Environmental
Protection Agency (EPA), and co-sponsored by the Department of Commerce (DOC),
Department of Defense (DQD), and Department of Energy (DOE). The study had three -
objectives:1 ; .." ,. .
1) Improve the understanding by Federal agencies of whether and how
environmental issues influence core business decisionsparticularly involving
production process operation in order to better understand how various factors,
including public policy, motivate pollution prevention in industry.
"2) Improve the understanding of these factors by others with a professional interest
-'' in U.S. environmental policy e.g., those in state and, local government, ;
industry, environmental and community groups, labor, and academia as well as
'by members of the general public with an interest in environmental policy.
' " 3) . Achieve the above through a debate that relies on the best factual information -'
available, while seeking to improve the quality of that information and its
--, interpretation. '
PPPS started its work oh this study by spending one year on a prototype study through
which it developed a questionnaire and a basic methodology. PPPS then hired a.professional
survey company to refine the methodology, and to interview more than 1000 business people
anonymously 520 randomly-selected lithographic printing, companies (most of which were -
' very small businesses), and 516 randomly-selected production managers representingthe larger^
manufacturing companies reporting to the Federal Toxics Release Inventory (TRI). The research
ES-v
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compam also gathered information from EPA data sources about the extent to which each of the
surveyed businesses was affected by the environmental regulatory system. The following , .
findings are based on statistical analyses of those data.
The Prevalence of Pollution Prevention
The survey found that pollution prevention activities are being practiced widely by .
printers and laree'manufacturers; however, we are unsure whether such activities have become
the first resort of these businesses in meeting their environmental responsibilities. Specifically:
64% of printers reported implementing pollution prevention activities'. Of these:
90% modified or substituted chemicals;: !
73% modified image-making or prepress operations;
69% implemented good operating practices; and
58% modified press operations.
85% of large manufacturers (TRI facilities) included in this survey reported -
implementing pollution prevention activities2. Of these:
i ']; " ' , , , ;
96% implemented good operating practices;
93% modified production related processes;
91% improved materials handling practices;
76% substituted chemicals or raw materials or modified their product; and
64% modified cleaning or degreasing operations.
" For the large manufacturers reporting to TRI, however, no association was found between
the reporting of pollution prevention activities and the actual percent of TRI chemical waste
reduced (normalized for production), one quantitative indicator of pollution prevention.
1 This motivation study reflects a higher incidence of reported pollution prevention
activity (64%) than that reported to the 1994 TRI Public Data Release (41.9%) because the motivation
study interviewed only lithographic printers. These printers generally do not report to TRI. Most
printers reporting to TRI are part of the industry's gravQre sector.
2 This motivation study reflects a higher incidence of reported pollution prevention
activity (85%) than that reported to the 1994 TRI Public Data Release (32%) for three reasons. First, the
motivation study asked about pollution prevention activity over a two-year period, versus the one-year :
period reported to TRI. Second, the motivation study interviewed production managers, individuals
actually responsible for performing pollution.prevention, whereas the TRI data relied on information
reported by company environmental, health, and safety staff. Third, the motivation study asked
respondents about all pollution prevention activity (both TRI- and non-TRI-reported chemicals) versus
TRI's questioning of pollution prevention for only the TRI-reported chemicals at a facility.
ES-vi
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Traditional Environmental Regulatory Programs
The survey showed that traditional environmental regulatory programs were almost
unrivaled in making business decision makers aware of their environmental obligations. That
said, the ability of these programs to facilitate business-efforts to meet those obligations might
still be improved. ' - . . , ^
For large manufacturers,-contact with.enforcement personnel was associated with
reduction in TRI waste normalized for production.' Also, the use of certain types of pollution -,
prevention activity by large manufacturers was associated with the amount of interaction, the
large manufacturers had with the regulatory system or with technical assistance organizations.
' Environmental regulatory requirements ranked near the top of issues considered very
important by the-production managers in their overall job responsibilities. .Environmental
regulatory requirements were ranked nearly last on the list of issues printers considered very s
important, although very few printers reported considering environmental issues not at all
important..- '" - , . '
Environmental enforcement actions were reportedly among the most important factors in
getting respondents to first consider envkonmental issues in their jobs.. - ;.
Interaction with the regulatory system was also related to an increase in the reported
importance of: 1) company environmental policies and management directives, 2) pollution
.control and waste disposal costs, and, for large manufacturers, 3) the environmental impacts of
their products during use or disposal.' Also,.production managers ranked government.
requirements as one of the strongest influences on their final choice of equipment and operations;
these requirements were ranked in the middle by printers.
Government publications and assistance providers did not rank high among reported
sources of environmental information about alternative practices or technologies.. Despite this
finding,' contact with assistance and enforcement organizations increased the reported importanqe
of government, publications and assistance providers as sources of environmental information. -
Although advice from government employees ranked at the bottom of the list of strong
influences in the final choice of equipment and operations, interaction with both the regulatory
system and technical assistance organizations increased the reported influence of this advice.
Also, contact with regulatory and assistance personnel increased the reported influence of the
compliance costs on the final selection of equipment or operations.
. ES-vii
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Technical Assistance
Most printers and production managers recently having contact with technical assistance
proarams reported implementing pollution prevention activities as a result of those contacts^ For
printers contact with technical assistance programs was related to an increase in the reported
importance of environmental issues in overall job responsibilities, as well as an increase in the
reported importance of the cost of input materials and the availability of environmental
technology information. A greater number of production managers contacted by technical
assistance'organizations reported that pollution control or compliance costs were a strong
influence in their final choice of equipment and operations.
Pollution Prevention Planning
Almost half the printers and two-thirds of the production managers reported conducting
their evaluations of environmental alternatives as part of government-required (Federal, state,
local) pollution prevention plans (see page 2-27).
Motivators Not Directly Related to Public Policy
: '
Employee morale and level of productivity, and the sources, quality, and cost of raw
materials topped the list of issues that printers and production managers reported as being very
important to their job responsibilities. Trends in customer preferences, for the respondent s .
product was ranked near the top, although it was ranked below environmental regulatory
requirements by production managers.
Printers ranked the environmental interest of the respondent, family, and friends at the top
of the list of factors along with environmental enforcement actions as very important for
first getting them to consider" environmental issues in their jobs.
Printers ranked vendors and suppliers at the top as sources of environmental information
about alternative practices or technologies. Company employees were ranked at the top by
production managers, well ahead of vendors and suppliers. . .
. Total Quality Management (TQM) plans and materials or chemical accounting reports
were mentioned frequently in connection with evaluations of alternative practices and .
technologies. These chioces were ranked behind only government-required pollution prevention
plans.
Production efficiency and other non-environmental benefits were ranked highest among
issues reported by printers and production managers as very important in influencing the final
choice' of equipment and operations. For printers, the top rank was shared by availability ot .
information on particular practices and technologies. Information availability was ranked near
the top by production managers.
ES-viii
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The Respondents and Their Firms
Of the 5^0 printers surveyed. 3,8% were company owners. 19% were presidents, 13%
were general managers, and 13 °/i were operations 'or production managers. Of the remaining
17%. all seemed to be in core business functions such as production or sales, and none reported
themselves to be environmental specialists of any sort..
Twenty-eight percent of the printers reported having 1-2 production employees, 25% had
3-4 production employees, 24% had 5-7 production employees,'12% had 8-19 production
employees and 10% had 20 or .more production" employees on an average shift. An increase in
printing company size was associated with an increase in pollution prevention.activities as well
as interaction with regulatory and technical assistance programs. For. this reason, some of the
observed associations between printers' responses and interaction with regulatory and assistance
programs may be partly a result of company size.
Of the 516 large manufacturers contacted, 61% of the respondents reported themselves to
be productions or operations managers; 17% had some other position in operations, ;
manufacturing, or engineering; 10% were owners or top managers; 5% managed environmental
affairs; and most of the rest were in core business functions such as quality management or
product planning. .
. Twenty-three percent of the large manufacturers had 1-19 production employees, 28%
had 20-40 production employees,"24% had 41-100 production employees, and 25% had 100 or
' more production employees on an average shift. Of the 5% of TRI respondents working in
Fortune100 companies, most had more than 100 production employees on an average shift.
Issues for Further Study
_,
The above findings illuminate the hypotheses that underpin pollution prevention policy,
yet they raise many questions as well, m the course of carrying out this study, the researchers
developed approaches for answering these questions,_and hope to conduct a study with such
refinements at some point in the future.
ES-ix
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CHAPTER ONE
INTRODUCTION
. ,,.,, M
This document. ?A Study oflndu to
s,udy undent by the Polluuon
for Pollution Prevention," reports on a
° S. Environmental Protectio h
C) Depattmerit of
d.
pubUc poUcy, motivate poUution prevenuon in industry,
interpretation.
PPPS
which i,.dev«lop«d a
company to refine the methodology
ymously - 520
,000 busi««» p«ple
ng industry (composed
co
about DM exu« to which
The
of the research methodology.
The su^'ey r«ul« and ote infonnation
statistical analysis, and EPA's preliminary «««»«?"""
environment* poUcy expem and *e JJ
Pollution Prevention Roundtable and the
the second chapter
of the National
^« C«<
, findings compnse
of
the findings.
appendices.
1-1
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.Portion prevention" [nvo.ves incorporaring eoviroomenta. .onsideraHons
into core business decisions - .
Prevention. Act, EPA defines "pollution prevennon" as:- ,
' - \
(a) Source reduction"- being any practice which reduces:.
emissions) prior to recycling, treatment, or disposal; and
the hazards to public health and the environment associated with the release of
such substances, pollutants, or contaminants.
(b) ' other practices that r^
or
_ protection of natural resources by conservation.
used throu^iout this report. . .
premise of this behavioral approach is fourfold:
»-?^~£Z^
services, from environmental considerations.
2) To the exten, », abusing m«s«o its
1-2
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»
mce cost-effective and protective strateg.es.
4) Th5bes,»ayio assess EPA's effectiveness tapro^gpoUution prevention is .omth,
:' come« of tne core business decision maker.
'- aia* . on pase -7 Crates this ^^^^^^
,he product and process designers, ^Pme"' ^^^SonseTvation and Recovery Act
Currently, the Clean Air Act,-Clear, Water ^ £dj^a^"f naardous waste respectively
address air emissions, discharges to water and * V^J^,,, ^K up ft. business into
.
^
issu« conftont
implications. ,...,. - -
EPA's challenge is to enable and encourage the core
In promoting P°^uUon P"^^de^0^
decisionrnakersto weighenviroi««*«^conaaerai10 ...,.^^.
weigh'the other issues.
are stated below:
/ .
1-3
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Promonon of Pollution .Prevention . ,; _ ; .
' "r H ..... ^^^.nH lUhiiitv motivates poUutioh prevention by raising the
the business to address en° .. h prevention of ail emissions.-water
,enS no, «o be cove^ by Superb
Uability.) , ' . .
considerations in core business decisions.
missed. ...
pollution prevention. ^
prevention-measures they otherwise might nave missed.
makers.
1-4
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provides
otherwise be available for years.
Inhibition of Pollution Prevention
leads
and
T
smdy
groups
1-5
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1.2 REACHING THE RIGHT RESPONDENTS
exists of how environmental issues are integrated into ;
': industry segment, several steps were
. . .
First the su^ev was d irected toward produaion line decision makers^ Second, .in
-
first question about job responsibilities., -
^s±rr^^J&^
themselves to be environmental specialists of any sort.
programs may be partly a resuh of company size.
Of the 916 large manufiaurets co«ac<«
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1 3 THE CHALLENGES
te
some types of businesses than others, ^*£%%tet of some policy approaches might be
" ies base, on a* ^
»
help "EPA and its stakeholders meet those challenges:
1-7
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'Exhibit 1 .
Pollution Preveotion from the Busings Point-of-View
1-8
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CHAPTER TWO
FINDINGS
2.1 INTRODUCTION
This chapter discusses the findings of the "Study of Industry Motivation ^ Pollution -
Prevention." and summary of the comments received by reviewers of the August 16, 1996.draft
of this study.
The findings are stated in the following way. First, the Pollution Prevention Policy
Staffs interpretation of a set of statistical evidence is stated in plain English m italics. Each plain
IrSsSrpretation that is not self-explanatory is then followed by the statistica 1 evidence on
which lit is based. In those cases where reviewers had alternative interpretations, their comments
are listed at the 'end of the section.
All the statements represent a statistical relationship with a chi square p-value of .05. The
chi square p-value is a measure of how strongly two variables are related to each other For
example assume that 60% of small firms and 70% of large firms report practicing pollution
prevention. A chi-square p-value of .05 means a 5% probability that no difference exists
between small and large firms and that the survey results are due to the random selection of
vaSn wkin the Jmple. In a few cases, we present statistical relationships at the chi square.
p-value of .10 (marked by an *). In those instances, there is a 10% chance that the reported
values were due to a random result In the few cases where we found strong relationships that we
could not interpret, we placed them at the end of each section for the reader s interest Another
statistic, the confidence interval or confidence limit, is used to characterize die robustness of
the s *«nred
,
ra es and fractions within th, sample. A 95% confidence limit means
within our sample group matches the statistics for the entire population of U.S _fac htie wrth a
5% probability of error. Unless otherwise noted, the 95% confidence interval for all value*
presented is less than positive or.negative 10% (i.e., observed statistics for our sample group are
assumed to be less than 10% greater or lesser than those for the U.S. population, with a 3 /o
probability of error). .
< A few terms are used for brevity. The word "printers" refers to the ,520- respondents from
the lithographic printing companies surveyed. The phrases "large manufacturers or TRI
respondents^' refer to the 516 respondents chosen at random from the list of large manufacturing
companies reporting to the Federal Toxics Release Inventory, 90% of whom told the surveyors
that they were involved in managing or implementing production at some level. The term
"RCRA generators" refers to companies registered with EPA as hazardous waste generators. The
term "Technical assistance organizations" refers to government-funded organizations in the
business of providing information and assistance in addressing environmental issues.
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Finally strong associations exist between firm size and the respondents' answers.
'Because larger printers tended to have more "interaction with regulatory and assistance programs,
direct causality between observed patterns of printer responses and either firm size or interaction
with regulatory or assistance programs could not be determined in every instance. With the TRI.
respondents, no association was found between size and contact with assistance programs, and
reported contact with regulatory personnel actually decreased with increasing firm size.
2.2 MAJOR FINDINGS
2.2.1 Major Finding #1: Pollution Prevention Activities are Being Practiced
Widely by'Large Manufacturers and Printers.
this section assesses tie extent to which pollution prevention is-being practiced in the
lithographic printing industry and among large manufacturers (more precisely, manufacturers
reporting to the Federal ToxicsJlelease Inventory (TRI)).
Pbllutiori prevention defies precise measurement: Because the "right" type and amount of
pollution prevention is different for each firm, obtaining precise measurements of industry's
progress towards me optimal level of pollution prevention is very difficult. ,
2.2.1.1 Reported Pollution Prevention Activities
The primary indicator of pollution prevention activity was respondents' reports of
pollution prevention practices. A few Federal environmental programs require businesses to
report their pollution prevention activities qualitatively. The information gathered on pollution
prevention activities in this survey differed from those reports in two primary respects. First, this
survey did not question the environmental, health and safety specialists located at an industrial
facility or environmental staff at the corporate level.. Rather, the survey focused on production
managers: those individuals responsible for making the day-to-day decisions that have the
greatest impact on both the production and waste generated at a facility production managers.
Consequently, we would expect a more complete reporting of pollution prevention activities
from them. - . . , ." '.. ,
Second, respondents were asked to report their pollution prevention practices using
language intended to be familiar to them, rather, than to environmental experts. For example, not
even the words "pollution prevention" were used in the pollution prevention practices section of
the survey. Throughout this report, whenever.respondents are said to have "implemented
pollution prevention activities" in general, or to have implemented particular types of pollution
prevention activities, it is because they responded positively to the questions in Appendix C. .
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When asked whether pollution prevention activities were implemented: .
/; 64% of printers reported implementing pollution prevention activities.
Of these: .
. 90% modified or substituted chemicals,
.' 73% modified image-making or prepress operations,
69% implemented good operating practices, and
58% modified press operations.
it) 85% of large manufacturers reported implementing pollution prevention
activities. .
, Of these:
96% implemented good operating practices,
93% modified production related processes,
. . 91% improved materials handling practices,
76% substituted chemicals or raw materials or modified their product: and
64% modified cleaning or degreasing operations.
? 9 1 ? H"w Printers' Size Affected Pollution Prevention Activity
One variable long thought to explain much of the pollution prevention-related behavior of
businesses is the size of the facility or corporation. To explore the issue further, printers were
asked how many production personnel work on an average shift. Of the printers, 28% reported
having 1-2 production employees, 25% had 3-4 production employees, 24% had 5-7 production
employees 12% had 8-19 production employees, and 10% had 20 or more production employees
on an average shift. (In the following discussion, these size categories will be referred to below
as "size quartiles," occasionally grouping the largest two size categories).
The reported frequency of printers' pollution prevention activities was related to firm
size. In particular: ..-_--., ' ' ,
i) More larger than smaller printers reported pollution prevention, activities.
Pollution prevention activities were reported by:
'., _ >
51% of printers in the first size quartile,
57% in the second quartile, and
- ' 77% in the third and fourth quartiles. .
.2-3
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-» ->'' 1 ; Hnvv TRI ResponHents' Size Affected S"rvev Responses .
To explore the effect of facility' and corporation size on pollution prevention-related
behavior the production managers were asked how many production personnel work on an
average shift. Researchers also identified those respondents working in facilities owned by .
Fortune! 00 corporations.1 '.-..' "..".;"'
Of the large manufacturers (which employed "the TRI respondents) 23 % had 1-19
production employees, 28% had 20-40 production employees, 24% had 41-100 production
employees and 25 % had 100 or more production employees on an average shift at that
facility (Each of these size categories is.referred to as a "quartile" in the following section.)
Most of the Fortune 700-owned facilities had more than 100 production employees on an
average shift. Fortune JOO-owned facilities were represented by 16% of the facilities in the
first size quartile, 14% in the second quartile, 14% inthe third quartile, and 56% in the fourth
quartile. ' . ..^,J...." '-.:-,.=*--.« ..^s^.^i*^-:-*.*-^-. ; . ,. .
The reported frequency of pollution prevention activity at TRI facilities was- relatedto
facility size. In particular: .
i) The larger manufacturers reported pollution prevention activities more
frequently. TRI respondents reporting pollution prevention activities included'.
76%oftherfirst size quartile, .
80% of the second quartile,
93% of the third quartile, .and ".
"'''. 90% of the fourth quartile. ,
No association was found between size of TRI facilities and the actual amount of waste reduction
as reported to the TRI. (A chi square p-value of 0.31 was calculated by crossing the number ot .
production employees and the percent of waste reduced normalized for production as reported to
the TRI.) As noted .in section 2,2.1.4, this resultmay,be due to the shortcomingsof the reported
TRI data on this matter. . ",' ,
ii) All FortimelQQ respondents reported mod^ing production-related processes,
compared with 93% of the other TRI respondents. ;
Hi) More larger than smaller manufacturers reported chemical substitution. TRI
. respondents who reported substituting chemicals or raw materials or modifying
their products included:
1 The Fortune 100 consists of the one hundred largest revenue-producing American
companies as rated by Fortune Magazine.' , '
2-4
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. 62°b of the first size quartile.
. 74% of-the second quartile.
81% of the third quartile. and
83% of the fourth quartile -
iv) More Fortune 100 respondents than other TRI respondents reported chemical
substitution: . . ,
93% of Fortune100 TRI respondentsreported substituting chemicals or
raw materials or modifying their products, compared with 75% of the
other TRI respondents. . ' . .
v) More 'larger than smaller manufacturers reported cleaning process change* TRI
' respondents that reported modifying cleaning or deceasing operations included;
, . 51% of the first size quartile, .
* 56% of the second quartile,
66% of the third quartile, and
. 77% of the fourth quartile
vi? More Fortune 100 than other TRI respondents reported improved materials
handling:
99% of Fortune 100 TRI respondents reported improving materials
handling practices, compared with 90% of other TRI respondents,
2.2.1.4 TRI Report? hv Large Manufacturers
f. . , i
" One indicator of pollution prevention used here was drawn from reports by large
manufacturers to the TRI of the amount of toxic chemicals entering the waste stream prior to
Svcling, treatment, transfer, disposal, and release. For each respondent, TRI chemical waste
eported for 1994 was subtracted from waste reported for 1993. To account for how much waste
eduction (or increase) was due to changes in the level of production activity, the change in waste
SSL w muhi^ by the activity index reported in 1993 and divided by the activuy
index reported in 1994. The whole was then divided by the 1993 waste number to create a
percentage measure. (A more detailed explanation can be found in Appendix B.)
As discussed in the 1994 TRI Public Data Release, "thorough and accurate assessment of
[pollution prevention] progress requires more detailed information than is included in [the TRI
" reporting-formj." TRI can pro-vide only a broad indication of whether source reduction is
2-5
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occumno but does not measure actual quantities of source reduction.' 'Despite this limitation.
the calculation of changes in waste generation produces the best available quantitative data on
industrial progress in preventing pollution. No such data, however flawed, are even available for
small businesses such as printers. Collecting such data for printers, or collecting more precise
data for large manufacturers, was beyond the scope of this study., .
; - '"'''.'': ' '
Keeping these issues in mind, the data tell us the following:
i) No association was found between TRI waste generation and pollution prevention
activities. The number of large manufacturers that reduced their TRI waste
normalized for production was nearly the same as the number of large
manufacturers that increased their TRI waste normalized for production: .
25% of TRI respondents reduced waste normalized for production by more
, . than 14%, ; -' ". ' '
23% reduced by 0%-14%, 2% reported no change, '
. . 20% increased waste normalized for production by 0%-14%, and
. 25% increased by more than 14%.
-) 7 1 S Other Interpretations . .
Kevin Mills of the Environmental Defense Fund agrees with EPA's finding that pollution
prevention activities are being practiced widely by printers and large manufacturers but adds that,
"we cannot be sure that these pollution prevention practices are being done for the right reasons
(i.e., that the environment is on par with cost and quality in'guiding product and process
'changes)." . . .-'-.. - .'
. Dale Kalina of P R. Donnelly and Sons believes that, "the correlation between pollution
prevention and TRI reporting is unclear and may be misleading. Many pollution prevention
initiatives may significantly reduce wastewater discharges, air emissions, or waste generation,
yet not impact TRI reporting at all if the pollution prevention initiatives are in areas where TRI
chemicals are not used or, in certain cases, where the pollution prevention activity actually
introduces a TRI chemical into a process where it had not been previously used." ,
Mr Kalina also notes that the pollution prevention activities reported by "printers need to
be closely scrutinized. All four of the [pollution prevention activities listed] are routine business
operations for printers." Mr. Kalina believes the pollution prevention rate among printers to be
higher because, "it would be very surprising if none of these activities had occurred over a two
. year period for any printer." '
2A detailed discussion of this distinction appears in Appendix B.
. '".'':'' ' -2-6 ' -
-------
f,:-.rv Miller of rh* Illinois Waste.Management and Research Center believes that not all
the reported "pollution prevention activities" may result in actual pollution prevention, and that
EPA is assuming a areat deal by listing the printer-reported changes as pollution prevention
activities Mr. Miller states that, "while one type of waste might have been reduced as a result of
undertaking these activities, other types of waste may have been increased. Companies often
don't think comprehensively on a multi-media level. And they don't quantitatively measure the
amount of waste reduced or the actual-costs and economic benefits."
MirhaelEckoftheU.S.Armv is not surprised by the lack of association between
reported pollution prevention activities and actual TRI reduction because, "the low hanging fruit
is mostly gone and the pollution prevention being done generally affects a small amount pf the
waste stream." Mr. Eck believes that "we need better ways to measure pollution prevention
results and [also need] some measure of environmental management costs."
For the recommended approach for exploring these issues further, see section.3.2.1.
2.2.2 Major Finding #2: Regulatory Programs are Almost Unrivaled in Capturing the
Attention of Core Business Decision Makers. '-...
Programs that set and enforce limits on the waste materials that can be released into air,
water and land rarely favor pollution prevention explicitly over other methods of limiting the
releases' Nevertheless, traditional regulatory programs, which establish the context in which
businesses decide to prevent pollution, are argued to be both motivators and inhibitors of
pollution prevention. The many statistical observations discussed in the remainder of this
subsection suggest that traditional environmental regulatory programs are almost unrivaled in
brineing the attention of business decision makers to their environmental obligations. There may
be room, however, to improve the programs' effectiveness in facilitating business efforts to meet
those obligations! .
Two types of information on respondents' involvement with regulatory" programs were
gathered for this study. First, respondents were asked if they had been contacted by someone
enforcing regulations. Such personnel could have included inspectors from EPA, OSHA, and
state and local agencies. Second, records of each respondent's EPA permits, inspections, and
enforcement actions were gathered from EPA databases. ..
2.2.2.1 Reported Pollution Prevepti"" Activities
i) Pollution prevention activities were reported more frequently by respondents with
air or water permits:
89% of TRI firms with air or water permits reported pollution prevention
activities, as opposed to 77% of RCRA-registered firms, and 84% of firms
not currently known to be in these regulatory systems.
2-7
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ii) Improved materials handling was reported more frequently 'by respondents .
inspected: -, . ; .
93% of TRI respondents inspected by EPA within the past two years
reported improving materials handling, as opposed to 88% of those not
. inspected. . / ''.:-'.. . "
Hi) - Improved materials handling was reported more frequently by respondents with '
enforcement actions:
99% of TRI respondents in firms that had faced an'EPA enforcement
action in the past two years reported improving materials handling, as
/ opposed to 91% of those-without enforcement actions. (
iv) Production-related process modifications were reported more frequently by
respondents with enforcement actions:
100% of TRI respondents with enforcement actions reported modifying
production-related process, compared with 93% with no enforcement
actions. .. ' :
v) Improved materials handling was reported more frequently by respondents not in
the RCRA or air or water permit systems:
'i ".''' '
96% of TRI firms not currently known by EPA. to be in RCRA or air or
water regulatory systems reported improved materials handling, as
opposed to 91% of those with air or. water permits, and 88% of
- RCRA-registered TRI firms. ' .
vi) ' (}ood operating practices were reported more frequently by respondents not in .
the RCRA system: . .
96% of TRI firms with no recorded interaction with regulatory programs
and 98% of those with air or water permits reported implementation of
good operating practices, asopposed to 91% of TRI respondents with only
RCRA registration.
2-8
-------
-,"-,-,-, Reported Importance nf Regulatory- and Assistance Programs
Aspects of the reeulatory system were among the issues mentioned most frequently as
important determinants of environmental decision making. In particular:
Environmental regulatory requirements ranked near the top of issues considered to . ,
be very important by the production managers of large manufacturers-(see Figure
Environmental enforcement actions were among the most important factors in
getting both TRI respondents and printers to first consider environmental issues in
their jobs (see Figure 3).
Government requirements ranked among the top issues for production managers .
and in the middle for printers as strong influences on the final choice of
equipment and operations (see Figure 5).
On the other hand, environmental concerns were ranked nearly last on the list of
issues printers considered very important (see Figure 2). This finding may be due
to the relatively little interaction between the typical small printer and the
regulatory system, as compared with large manufacturers reporting to the TRI.
Contact with the regulatory system increased the reported importance of both the
igulatory system and assistance programs on various aspects of environmental decision making.
i) Enforcement actions were reported as being very important more often by TRI
respondents with enforcement actions:
76% of TRI respondents with recent enforcement actions reported that
enforcement actions against their companies were very important in first
getting them to consider environmental issues in their jobs, as opposed to '
64% of TRI respondents with no enforcement actions.*3 .
it) Enforcement actions were reported as being important more often by printers
-with enforcement actions:
88% of printers reporting contact with enforcement personnel reported
environmental enforcement action against their company as being
somewhat or very important in first getting them to think about
environmental issues in their work, as opposed to 75% not contacted. *
re
3Results with a chi-square p-value of .10 are indicated by an-asterisk.
' 2-9 ' . ";
-------
.Hi) Similarlv, environmental regulatory requirements ranked near the top of issues
considered to be very important by the production managers of large ,
manufacturers: , ' . V "
\ - - ' '
'..'' 82%ofTRI production-managers ranked possible environmental
jegulatory requirements as very important in their job responsibilities,
, 'surpassed only by 88% for employee morale and level of productivity; and
86% for the sources, quality, and cost of raw materials and inputs;
70% ranked possible environmental impacts of,their products during use
or disposal as very important, well above the, 48% for bottom-ranked
"technological advances in manufacturing the product;"
Fewer than 2% considered environmental concerns to be not at all
important. .
iv) Also, a greater number of'production'managers reporting contact-with
enforcement personnel ranked the environmental impacts of their products as
being very important to their job responsibilities: _'
-. . . "'' 72% of TRI respondents'who reported being contacted by enforcement
personnel ranked the possible environmental impacts of their products
during use or disposal as .being very important in their job responsibilities,
compared with 46% of those not contacted by enforcement personnel;
. 88% of TRI- respondents and 66% of printers, reported that government
requirements were strong influences on their final choice of equipment and
operations. Government requirements were ranked among the top of the
list of such influences for TRI respondents and in the middle, of the list for
printers. ,
v) Government requirements were ranked as a strong influence by more printers
reporting contact with enforcement personnel. -
Of the printers contacted by enforcement personnel, 78% reported that
government requirements were a strong influence in their final choice,
compared with 56% of those not contacted. . ,
2-10
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Figure 1:
Environmental regulatory requirements ranked near the top of issues
considered to be very important by the production managers of large
manufacturers.
Factors in Job Responsibilities
Morale &. Productivity
Riw Materials
ENVIRON REGS
Customer Preferences
r Product Envr Impacts ^
; t
Competitors' Products '-I
Insurance. Liability T|
Neighbors'Attitudes
Capital Costs -]
Tech Advances -»
Percent of Production Managers reporting factor as "very important"
Figure 2: Environmental concerns were ranked nearly last on the list of issues printers
considered to be very important. .
Factors in Printers Job Responsibilities:
Morale & Productivity
" Raw Materials -
Customer Preferences
Insurance, Liability -
Competitors'Products
Capital Costs
Neighbors' Attitudes
PRODUCT ENVR IMPACTS
ENVIRONMENTAL REGS
Tech Advances
20 *0 60
Percent of Printers ranking factor as "very
SO
important*
100
2-11
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Figure 3: Environmental enforcement actions were among the most important factors in
getting respondents to first consider environmental issues in their jobs.
Factors
Percent of respondents who reported that the factor was
"very important" in getting them to first consider
environmental issues in their jobs .-."-..
Awards Programs
Customer Demands
Input Material Costs
Community Interest
Personal, Famfly,
Friends
Govt-Req'd P2 Plans
rs
Compliance Costs
Company Policy or
Directive
ENFORCEMENT
, ACTIONS
10
20 30 40 50 60 70
Q Printers '
'rj Printers: Enforcement Actions.
I Production Managers. |
i Prod Mgr: Enforcement Actions ; |
2-12
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Figure 4: Government publications and assistance providers did not rank high among reported
sources of environmental information about alternative practices or technologies. However,
contact bv assistance and enforcement organizations apparently increased the recognized
importance of government publications and assistance providers as sources of environmental
information. "
Percent of respondents who reported that the source of
' information was very important in teaming about alternative
Sources of information practices or technologies to address environmental issues. >
Internet
GOVERNMENT
EMPLOYEES
Assistance Orgs
Other Companies
GOVERNMENT
PUBLICATIONS
Customers
Consultants
Employees .
Trade Assoc
Vendors
.Q Praters
Drinters: Govt Information
I Production Managers
I Prod Mgr: Govt Information
2-13
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Figure 5- Government requirements ranked among the top for production managers and
the middle for printers as strong influences on the final choice of equipment and
in
operations
Factors
Percent of respondents who reported that the factor was very
important in influencing their final chpice of equipment or
operations.
- Gpvt.Advfce
Customer Demands
Employee Willingness
Input Costs
Capital Availability
Compliance Costs
Prod Efficiency \
Info Avapabflity
Gpyi
REQUIREMENTS
Q Printers
n Printers: Govt Reqs & Advice
I Production Managers
I Prod Mgr. Govt Reqs & Advice
2-14
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vi) Government requirements were ranked as a strong influence by more TRI
respondents recently inspected: ' .
97% of TRI respondents inspected by EPA in the past two years reported
government requirements to be a strong influence on their final choices of
equipment or operations, as -opposed to 84% of those not inspected.
Only one observation runs contrary to this general trend:
vii) More production managers not facing enforcement actions ranked environmental
regulatory requirements as important to their job responsibilities:
83% of TRI respondents that had not faced recent enforcement action
companies that had faced recent EPA enforcement actions.
» ** . , ' ' '
22.2.3 R$Ported Impotence of finvernment ** a Source of Information
. -, ......... ....... , ...... ;,>* ....... j , .., ,,- ,(,- .
i) Government employees and publications were not among the sources of .
information most often reported as very important:
, . 14% of TRI respondents and 6% of printers cited government employees
as very important sources of environmental information about alternatives
practices or technologies, placing this source at the bottom of the rank of
environmental information sources;
44% of TRI respondents and 22% of printers reported that government
employees were somewhat important sources;
24% of TRI respondents and 18% of printers repohed that government
publications were very important sources of information, placing them in
the middle rank of such sources;
. 49% of TRI respondents and 39% of printers reported that government
publications were somewhat important sources;
i .-..
TRI respondents and printers both ranked government advice at the
bottom of a list of influences on the final choice of equipment and
operations. .
245
-------
ii) Government 'employees were reported to be important sources of information
more often by TRI respondents recently inspected; , ,
' 63% of TRI respondents recently inspected by EPA reported that
government employees were very important or somewhat important
sourcesof environmental information about alternative practices or
technologies, compared with 52% of those not inspected. . ,
Hi) government employees were reported tope important sources of information
more often by TRI respondents reporting contact with enforcement personnel:
., 61% of TRI respondents reporting contact by enforcement agencies
. ' reported that government employees were very important or somewhat
important sources of environmental information, compared with 38% of
those not contacted by enforcement personnel. \ .
iv) Government publications were reported to be important sources of information
more often by printers reporting contact with regulatory personnel:
25% of printers reporting contact with regulatory personnel reported
government publications to be very important sources of information,
compared with 13% of those not contacted. ..-..-
v) Government publications -were reported to be important sources of information
more often by TRI respondents recently inspected:.
78% of TRI respondents inspected recently by EPA reported that
government publications were very important or somewhat important
sources of information, compared with 68% of those not inspected.
vi) Government advice was reported to be a strong influence more often by TRI
respondents recently inspected:
35% of TRI respondents inspected by EPA in the past two years reported
that advice from government employees was a strong influence, on their
final choice of equipment or operations, as opposed to 26% of those not
inspected. ,
2-16
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vii) Government advice was reported to be a strong influence more often by TRI
respondents reporting contact with enforcement personnel:
33% of TRI respondents who were contacted by enforcement personnel in
the previous two years reported that advice from government employees
was a strong influence, compared with 9% of those not contacted. .
viii) Government advice was reported to be a strong influence more often by printers
reporting contact with enforcement personnel:
. 30% of printers reporting contact with enforcement personnel reported that
'. advice from government employees was a strong influence in their final
choice, compared with 7% not contacted.
ix) ' Contact with enforcement personnel apparently increased the str-ength of opinion
about government publications as a source of environmental technology
information:
25% of the TRI respondents reporting contact with enforcement personnel
ranked government publications as very important and 27% ranked
government publications as not important at all, compared to respondents
not contacted, of whom only 9% said government publications were very
important and 17% said they were not important at all.
Similarly, 27% of TRI respondents contacted by technical assistance
organizations reported government publications to be very important while
28.% reported them as not important at all, compared with 17% and 24%,
respectively, for respondents not contacted by technical assistance
organizations.
x) The smallest and largest manufacturers seemed to consider government
employees to be more important sources of environmental technology Information
than did the middle size range of manufacturers. TRI respondents reporting that
government employees were very important sources of environmental information
about alternative practices or technologies included:
20% of the first size quartile,
8% of the second quartile,
12% of the third quartile, and
17% of the fourth quartile.
Note that the technical assistance organizations discussed in section 2.2.3 likely represent
a subset of the government employees and publications discussed here.
2-17
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'-> > -> 4. Other Aspects of Business Activities ..' ' ' ,
The regulatory system apparently had an impact on other reported influences on business
life.
i) More TRI respondents with enforcement actions reported, company environmental
policies and directives as being important: ' . : -
100% of TRI respondents facing EPA enforcement actions in the past two
years reported that company environmental policies or management
directives were very important or somewhat important in first getting them
... to consider environmental issues in their work, .as opposed to 94% of TRI
respondents with no enforcement actions.
iij 'More printers reporting contact with enforcement personnel reported company
environmental policies and directives to be very important:
. 91 % of printers reporting contact with regulatory personnel ranked a . ,
company environmental policy or- management directive as somewhat or
veryimportant in first getting them to think aboutenvironmental issues in
their work, compared with 69% of those not reporting such contact.
ui) More TRI respondents inspected by EPA reported company environmental
policies or directives to be very important:
78% of TRI respondents inspected by EPA in the past two years reported
. that company environmental policies or management directives were very
important in first getting them to consider environmental issues in their
work, as opposed to 66% of those not inspected.
/v) ' More TRI respondents in the air, water, or RCRA systems reported compliance
costs to be very important:
65% of air or water permit holders reported that environmental protection
or waste disposal costs were very important in getting them to first
consider environmental issues in their jobs, compared with 62% of those
registered only with the RCRA program, and 52% of those not in any of >
these regulatory programs. *
2-18
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v) The rep.ortea' importance of other job responsibilities was related to enforcement-
actions:
1% of TRI respondents with enforcement actions reported that the attitude
of the company's neighbors and community was not at all important in
their job responsibilities, compared with 6% of those without enforcement
actions; *
72% of TRI respondents with enforcement actions reported that
technological advances in manufacturing their products were a very
important factor in their job responsibilities, compared with 47% of those
without enforcement actions;
65% of TRI respondents and 57% of printers reported environmental
enforcement actions tolbe very importantln getting them to first consider
environmental issues in their jobs, placing the issue near the top of the,
, rank of such issues.
vi) Influence of self, family, and friends was reduced by interaction with the ,
regulatory system.
60% of TRI respondents not registered with the RCRA, air or water permit
systems; 53% of those with air or water permits; and 48% of those
registered with the RCRA program only reported the interest of self,
family and friends in the environment to be very important.
2.2.2.5 Size
Firm size is often hypothesized as influencing firm behavior. The picture is clouded in ,
.the case of printers, because contact with the regulatory system increased with increasing size.
The larger the printer, the greater the likelihood^ being registered as a hazardous 'waste.
generator. Printers registered with the RCRA program included: .
2% of the first size quartile, -
3% of the second quartile, and
4% of the third quartile.
The fourth quartile distribution included:
14% of the second largest size category, and
23% of the top size category. *
' 2-19
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The laraer the -printer, the greater the likelihood of reported contact by regulatory
personnel. Printers reporting being contacted by .'someone enforcing regulations, such as .
inspectors from EPA. OSHA. or state or local agencies, included: .,
. 28% of the first size, qiiartile,: . .
-.' .41% of the second quartile, and .
. . . . 44% of the third quartile.
The foiirth quartile distribution included: ; . .'
43% of the second largest size category, .and
50% of the top size category '
(1 %' of printers were known, through EP A's database, to have been visited by an EPA inspector,
and fewer than 1% were known to have been subject to a recent enforcement action. As a result,
no association between these variables and firm size could be observed.)
Due to the direct relationship between printer size and the likelihood of contact with
regulatory and/or technical assistance programs (see next section), the following observations
may be due more to such contact than to printer size considered in and of itself. (Contact with
such programs increased their reported influence; therefore, we believe that program contact,
rather than firm size, was predominant.) . , '- _
i) More larger printers reported environmental regulations to be important.
Printersreporting possible environmental regulatory requirements as important to
their job responsibilities included:
," 48% of the first size quartile,
51% of the second quartile, and
. . 57% of the third quartile.
. fourth quartile distribution included: ,-
'..'.'. 59% of the second largest size category (with 8-19 production employees),
' and. . : ... . .
72% of the top size category (more than 19 production employees).
1 ''''.'
ii) . The smallest and largest printers were more likely to report compliance costs-.as
being very important. Printers reporting compliance costs as very important for
first getting them to consider environmental issues in their jobs included:
53% of the first size quartite,
41% of the second quartile,
-'. 2-20
-------
32% of the third quartile. and " '
. 49% of the top quartile. ' '.
Hi) More large printers reported government requirements to be a strong influence in
'the final selection of equipment and operations. Printers reporting government
requirements to be a strong influence in their final choice of equipment or
, operations included:
. 58% of the first size quartile,
. 61% of the second quartile, and
64% of the third quartile.
The fourth quartile distribution included: . , .
« 88% of the second largest size category, .and
71% of the top size category.
In contrast with printers, TRI firm size was inversely related to reported contact with
enforcement personnel. TRI respondents comprising 93% of the first size quartile, 85% of the
second quartile, 88% of the third quartile, and 81% of the fourth quartile reported contact with
enforcement personnel. This result may be due to production managers being more insulated
from the regulatory system at larger facilities.
to) Environmental regulations seemed most important to production managers from
the smallest and the largest manufacturers. TRI respondents reporting' '.hat
possible environmental regulatory requirements were very important to their job
responsibilities included:
89% of the first size quartile, '
78% of the second quartile,
77% of the third quartile, and, .
» 85% of the fourth quartile. ;
2.2.2.7 Oth?r Interpretations .
TCathrvn Barwick of the California Department of Toxic Substance Control believes that
this study suggests that "government still, even in these days of deregulation, has a strong role to
play as a motivator for environmental improvement."
' Ms Barwick notes that this study suggests room for improvement with respect to the
integration of pollution prevention into enforcement. Ms. Barwick believes that technical
materials may have a greater effect when distributed in concert with enforcement activities.
2-21
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. nale K-alina ofP R rinnnellv and Sons is not surprised by the "correlation between
recent inspections and the value of government employees' environmental information, [He .
believes] this is probably due to the need of the inspected facilities to address issues raised-by the
inspectors.. Who better to ask advice of than the person who tells you you have a problem?" .
T.isa Doerr of Titirens for a Better Environment (Minnesota) noted that customer .
demands reportedly ranked next to last in importance in influencing the final. choice of
equipment and operations. Taken at face' value, this statistic would suggest that customer
demand is not an effective motivator. Ms. Doerr theorizes that this result simply reflects that
customers did not make demands; and if they had made demands, "customer demands would
have ranked at the top of the list instead of nextto last."
2.2.2.8 Observations Without Obvious Interpretations
-'"*". / ' - . , .
90% of TRI respondents with air or water permits reported raw materials
to be very important in their overall job responsibilities, compared with
' 80% for the non-permit holders. ,
of TRI respondents reporting- contact by enforcement personnel cited
employee morale and level of. productivity as being very important in their
: overall job responsibilities, compared with 97% for those not reporting
enforcement visits.
66% of TRI respondents reporting contact by enforcement personnel cited
cost and quality of competitors' products as being very important in their
overall job responsibilities, compared with 84% of those not contacted.
72% df TRI respondents with only a RCRA, identification number and no
. permits reported cost and quality of competitors' products to be very .
important to their job responsibilities, as opposed to 65% of respondents
' wim ah- or water permits and 63% of respondents not- in any of these
regulatory programs. .'... " " . -- ' .
For the recommended approach to exploring these issues further, see section 3.2.2.
2.2.3 Major Finding #3: Technical Assistance is a Significant Influence on a Firm's
Pollution Prevention Activity.,
Dozens of government-funded organizations across the country provide environmental
assistance and information to business. Most of these organizations are based in state or local
agencies, universities or business assistance centers, and many receive some Federal funding.
The establishment of such technical assistance organizations is the oldest and most prevalent .
public policy approach intended specifically to promote pollution prevention.
-. ' '-' , -2-22 ' '"" ' '.' "',' .
-------
Respondents were asked in particular about contact they had with the following four
types of technical assistance organizations: assistance programs based in regulatory-agencies,
university programs, government technical assistance or compliance office programs, and
programs based in a business assistance or development office.
2.2.3.1 General Observations . .
/) Most printers and production managers recently contacted by technical
assistance programs repofted implementing pollution prevention activities as a
result of those contacts.
of those recently in contact with a technical assistance program, 61% of
printers and 53% of production managers reported implementing
pollution prevention activities as a result of those contacts.
Printers
43% of printers reported contact with technical assistance organizations.
Of those that reported contact with one of the four types of organizations
mentioned above, 61% reported that their pollution prevention activities
were made as a result of their contacts. Activities varied by type of
assistance-providing organization.
60% of printers contacted by assistance programs based in regulatory
agencies reported that their pollution prevention practices were made as a
result of their contacts with the organizations, compared with 56%
contacted by a university program, 54% contacted by a government
technical assistance or compliance assistance office, and 44% contacted by
a business assistance or development office. ..
In a related observation, 72% of printers reporting contact with a technical
assistance organization said that they implemented pollution prevention
activities, as compared with 59% of the printers not contacted.
TRT Respondents
65% of T&I production managers reported contact with technical
. assistance organizations. ,
Of those that reported contact with one of the four types of organizations
mentioned above, 53% reported that their pollution prevention practices
.2-23
-------
were-made as a result of the contacts.. Percentages varied by type of
assistance-providing organization. / -. . . .
. 68% of TRI production managers having contact with assistance programs
based in regulatory agencies reported that their pollution prevention
practices were made as a result of their contacts with the organizations,
'.-.- compared with 62% haying contact with a university program, 55%
' ' having contact with a government technical assistance or compliance
assistance office, and 51% having contact with a business assistance or
development office.
u) Printers in contact with 'technical assistance programs were more likely to report
environmental regulatory requirements as being very important:
64% of printers contacted by technical assistance organizations reported
possible environmental regulatory requirements to be very important in
their job responsibilities, compared with 48% of printers not contacted.
Hi) Printers in contact with technical assistance organizations were more-likely to
report customer preferences as being very important:
72% of printers contacted by technical assistance organizations reported
customer preferences to be very important in first drawing their attention
to environmental issues, compared with 64% of printers not contacted.
iv) Printers in contact with technical assistance organizations were more likely to
report input material costs as being important:
86% of printers-having contact with technical assistance organizations
reported input material costs as a somewhat important or very important
factor in first getting them to consider environmental issues in their jobs,
compared with 77% of printers not contacted. , . .
v) Printers in contact with technical assistance organizations were more likely to
report availability of information as being a strong influence:
87% of printers contacted by assistance organizations reported that '
availability of information on the particular practices and technologies had
a strong irifluence on their final decision, compared with 76% of those not
' " '. contacted. *
2-24
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Fieure 6- Percent of those printers and production managers in recent contact with a
technicai assistance program who reported implementing pollution prevention act,v,t,es
as a result of that contact, by location of program.
Business Assistance
Tech/Compliance
- Assist ,
Universfty
Regulatory Agencies
10
i< i, nn1 iiiiiii
20 30 *0 50 60 . 70
I Printers Q Production Managers
Location of the Technical Assistance Program
2-25
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vl) Printers in contact with technical assistance organizations were more likely to
report advice from government employees as being a strong influence:
,.: 23% of printers contacted by assistance organizations reported that advice
from government employees had a strong influence on their final decision,
compared with 13% of printers not contacted. *
vii) Production managers managers in contact with technical assistance .
organizations were more likely to report advice from government employees as
being a strong influence:
34% of TRI respondents in contact with an assistance organization
' reported advice from government employees to be a strong influence on
' their final decision, compared with 25% not contacted by assistance
organizations.*
viii) Printers in contact with technical assistance organizations were more likely to
report that assistance organizations were important sources of information:
47% of printers contacted by technical assistance organizations reported
"organizations providing assistance, such as universities or extension
programs" to be very important or somewhat important as sources of ..
environmental information about alternative practices or technologies,
compared with 29% not contacted.
ix) Production managers in contact with technical assistance organizations were
more likely to report that assistance organizations were important sources of
information:
66% of TRI respondents contacted by assistance organizations reported
assistance organizations to be very important or somewhat important
sources of information, compared with 51% of TRI respondents not
reporting contact with assistance organizations.
x) . Production managers in contact with technical assistance organizations were
; more likely to report that government advice was a strong influence.
34% of TRI respondents in contact with assistance organizations reported
. advice from government employees to be a strong influence, compared
with 25% of TRI respondents not contacted by assistance organizations. *
2-26 .
-------
xi) Printers in contact with technical assistance organizations were more likely to
report that government advice was a strong influence. .
" . 23% of printers contacted by assistance organizations reported that advice
from government employees was a strong influence in'the final choice of
equipment or operations, compared with 13% of printers not contacted.*
2.2.3.2 Size
i) Larger printers were more likely to come in contact with technical assistance
programs. Printers reporting contact with technical assistance organizations
included:
34% of the first size quartile,
37% of the second quartile,
52% of the third quartile, and '
50% of the top quartile. .
ii) No association was found between TRI employment and reported contact with
technical assistance organizations.
The chi square p-value produced by crossing TRI firm size and contact
with technical assistance organizations was 0.53.
Hi) Similarly, no association could be found between TRI firm size and recorded EPA
inspections (the chi square p-value being only 0.19). Only 3% of TRI
respondents' firms were known to have been subject to a recent enforcement
action, so no association between firm size and this variable could be observed.
? T r-snfoer Interpretations
fiary Miller of the Waste Reduction Institute theorizes that one reason technical
assistance.organizations are effective is that "the organizations that contact them tend to be more
progressive and open to change."
Finally, the apparent paradox exists that government employees and publications ranked
relatively low in several areas, while printers and large manufacturers reported implementing
pollution prevention activities as a result of c6ntact with technical assistance organizations. This
apparent contradiction might be explained by the fact that personnel and publications specific to
technical assistance are likely to be a small fraction of the',contact that business people have with
government employees and publications. .
2-27
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1 1
Observations Without Obvious Interpretations ' _ ;
82% of TRI respondents having contact with technical assistance - ^
organizations reported the sources, quality, and cost of raw materials to be
very important in their job responsibilities, compared with 95% of the
respondents not having contact.. '
2.2 4 Major Finding #4: Government Requirements Perceived as Requiring
Pollution Prevention Planning are Reportedly Very Influential.
Fifteen states require large businesses to develop pollution prevention or waste
minimization plans. These planning requirements vary'widely from those in Massachusetts and
New Jersey which specify in detail the elements of the plan, to those that make no such
specifications: laaddition, all generators,of large quantities of hazardous waste (RCRA Large
Quantity Generators) are required by Federal law to certify that they have programs in place to
minimize waste. An interim final guidance on the elements of "waste minimization
program-in-place" was published by EPA in 1992. . ' .
7741 General Observations ' ..
/; Almost half the printers and two-thirds of the'production managers reported
conducting their evaluations of environmental alternatives as part of
government-required pollution prevention plans.
Printers , ' " , v .
" . 47% plus or minus 18.6% of printers reported writing up a plan or memo,
or making a presentation to management, when evaluating environmental
information on alternative practices or technologies.
Of these, 89% reported that the evaluations were conducted as part of, or
" to nieet the requirements of, government-required pollution prevention .-
plans.
TRI Respondents ' ' .
.1 77% of TRI respondents reported writing up a plan or memo or making a
presentation to management when evaluating environmental information
on alternative practices or technologies:
Of these, 87% reported that-the evaluations were conducted as part of, or
1 " to meet- the requirements of, government-required pollution prevention.
,/'." : 2-28 '' V ' - ; '.'-.''
-------
Figure 7: How environmental alternatives were .evaluated
Type of Evaluation
Percentage of respondents reporting that they conducted their
evaluations as part of the following:
"*
'
ISO 14000
Trade Assoc Program
ISO 9000
j Total Cost Accounting
Materiab Accounting
Total Quality Mgt
REQUIRED P2
PLANS
10 20 30 40 50 60 70 80 ;
rj Printers
Q Printers: Govt-Req'd P2 Plan
I Production Managers
I Prod Mgr: Govt- Req'd P2 P Ian
' 2-29
-------
. ii) 59% of 'TR1respondents reported that state government pollution prevention
planning requirements were very important in getting them to think 'about
environmental issues at their job: ; ...-
,'"'' '. planning requirements ranked behind only company environmental' ._
policies or management directives (73%), environmental enforcement ,.
actions (65%), and the company's environmental protection or waste
:. . . . disposal costs (63%), and'ahead of five other factors. .
.For the recommended approach for further exploring this issue, see section 3.2.7.
.2.2.4,2 " Other Planning .. - " .. ..
i) T.QMplans and materials or chemical accounting reports were mentioned
frequently in connection -with evaluations of alternative practices and
technologies: " . .
47% of printers reported writing up a plan or memo, or making a
presentation to management, when evaluating environmental information
on alternative practices or technologies, These evaluations were most
' often conducted to meet the requirements of:
Government-required pollution prevention plans (89%)
Total quality management plans (75% ±.19.4)
__ Materials or chemical accounting reports (67% ±21.3)
"__.-; Industry or trade association programs (54% ± 27.3)
, . ' Total cost accounting reports (52% ± 24.7)
' ISO 9000 (46% ±27.0), and
ISO 14000 (12% ±19.8).
'' . 77% of production managers reported writing up a plan or memo, or
making a presentation to management, to describe the changes
recommended. These evaluations were most often conducted to meet the
. requirements of: . "\
Government-required pollution prevention plans (87%),
]. TQM plans (67%), \
Material or chemical accounting reports (66%),
Total cost accounting reports (60%),
. : ; ISO 9000 (45%)-
' ' .. _L' Industry or trade association programs (41%), and
ISO 14000(6%).
2-30
-------
-> > 4 ' 'Q%r Interpretations
rfor. vfjiw nf the Illinois Waste Management and Research Center questions whether
respondents understood tbele^'pollution prevention planning." Mr. Miller states that the
number of printers and production managers claiming to conduct *^°^" . '
part of pollution prevention planning requirements is much higher than he has observed in the
field (See 3. 2.7). .
o -) d 4 Importance of Being Subject to Massachusetts/New Jersey Planning Requirements
Production managers in Massachusetts (MA) and New Jersey (NJ) answered several
questions differently than production managers in similarly-sized firms in the rest of the country
For the most part, we were unable to interpret the observed relationship between TRI respondent'
location, TRI waste reduction, and reports of pollution prevention activities. Many such
relationships were observed, however, and they are provided here for the interest of the reader.
i) Being in MA and NJ apparently increased the strength of opinion about the
importance of trends hi customer preferences.
74% of TRI respondents from MA and N J reported that customer
preferences were very important to their job responsibilities, and 7%
reported customer preferences as not at all important, compared with 70%
and 0% for the rest of the country, respectively. *
ii) Being in MA and NJ apparently reduced the strength of opinion about the attitude
of company neighbors towards the company.
59% of TRI respondents from MA and NJ reported that neighbors'
attitudes were very important to their job responsibilities, and 0% reported
neighbors' attitudes as not at all important, compared with 62% and 7%
from the rest of. the country, respectively.
iii) Among production managers from the smallest manufacturers (i.e., those with
1-19 production employees per average shift), more from MA and NJ,
representing 64 companies, reported recently substituting chemicals or raw
materials or modifying their products:
77% of TRI respondents from MA and N J reported recently substituting
chemicals or raw materials or modifying their products, compared with-
60% of TRI respondents from the rest of the U.S.. *
2-31
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iv) ' Differences also existed among production managers from manufacturers with
20-40 production employees per average shift (which included 44 companies
from MA and NJ): - . ,
95% of TRI respondents in MA and NJ reported implementing pollution
; prevention activities, compared with 79% of TRI respondents in the rest of
. , .the U.S.; and ' ' ' ' .. - . > : ;
69% of TRI respondents from MA and NJ reported that techno logical
advances in manufacturing their products were very important in their job
responsibilities, compared with 49% of TRI respondents from the rest of
; the U.S.*" ' .- '' .-.':" ' . .
v) Among production managers with manufacturers employing 41-100 production
employees per-average shift (including 30 from MA and NJ):
"'..'.-- . ' , .- '
' 0% of TRI respondents in MA and NJ reported that the sources and cost of.
capital were not at all important to their job responsibilities, compared
with 7% of .those in the rest of the-U.S.;
0% of TRI respondents in MA and NJ reported that trends in customer
preferences for their products were not at all important to their job .,,
responsibilities, compared with 8% of those in the rest of the U.S.;
60% of TRI respondents hi MA and NJ .reported that the company's cost of
input materials was very important in first getting them to .consider
environmental issues in their jobs, compared with 37% of TRI respondents
in the rest of the U.S.; and , : .
76% of TRI respondents in MA and NJ reported that state government
pollution prevention planning requirements were very important in first
getting them to consider environmental issues in their job responsibilities,
compared with 52% in the rest of the U.S.
vi) Among production managers in the largest manufacturers (with more than 100
production employees per average shift, including 14 from MA or NJ):
100% of TRI respondents from MA and NJ reported that the sources,
quality, and cost of input materials were a very important part of their job
responsibilities, compared with 87% of TRI respondents from the rest of
. . ''.. the..U.S.; ' . ", ' . * . " . - .
2-32
-------
48% of TRI respondents from MA and NJ reported that trends in customer
preferences for their products were very important in their job
responsibilities, compared with 79% of TRI respondents from the rest of
the U.S.;
39% of TRI respondents from. MA and NJ reported that state government
pollution prevention planning requirements were very important in first
getting them to consider environmental issues in their jobs, compared with
61% of TRI respondents from the rest of the U.S.*; and ,
46% of TRI respondents from MA and NJ reported that company
employees were very important sources of environmental information
about alternative practices or technologies, compared with 52% of TRI
respondents from the rest of the U.S. * ,
vii) Among manufacturers employing 20-40 production employees per average shift:
30% of TRI respondents in MA and NJ, compared with 26% of TRI
respondents in the rest of the country, reduced TRI waste normalized for -
production by more than 14%; ,
1 1% of TRI respondents in MA and NJ, compared with 21% of TRI
respondents in the rest of the country, reduced TRI waste normalized for
production by 0%- 14%;
* " ,',',"' J' ' ,
8% of TRI respondents in MA and NJ, compared with 30% of TRl
respondents in the rest of the country, increased TRI waste normalized for
production by 0%- 14%; and
" ' ' , ,','"". '' 's
5 1% of TRI respondents in MA and NJ, compared with 23% of TRI
respondents in die rest of the country, increased TRI waste normalized for
production by more than 14%.
»
viii) Among manufacturers with more than 1 00 production employees per average
shift: ..'."' ,
36% of TRI respondents in MA and NJ, compared with 24% in the rest of
the country, reported reducing TRI waste normalized for production by
" more than 14%;
28% of TRI respondents in MA and NJ, compared with 24% in the rest of
the country, reported reducing TRI waste normalized for production by
2'33
-------
0% of TRI respondents in MA and NJ, compared with 23% in the rest of
the country, reported increasing TRI waste normalized for production by
0%-14%;arid . , , ' ;
36% of TRI respondents in MA and NJ, compared with 27% in'the rest of
the country, reported increasing TRI waste normalized for production by
more than 14%. . ' .
2.3 MINOR FINDINGS
2.3.1 Minor Finding #1: Employee Morale and Productivity, Input Materials, and
Customer Preferences are Top Concerns for Production Managers.
2.3.1.1 General Observations .
i) Employee morale and level of productivity were at the top of the rank of issues
~ cited as being very important in the job responsibilities of both printers and
production managers of large manufacturing businesses:
93% of printers and 88% of TRI respondents reported employee morale.
and level of productivity to be very important in their job responsibilities.
- Similarly, 71% of printers and:66% of TRI respondents reported that the
" willingness and ability of employees to make changes was very important
in influencing the final selection of equipment or operations. This issue
ranked near the top of such issues for printers and near the bottom for TRI
respondents. "
ii) ' The sources, quality, and cost of raw materials ranked near the top of the list of
issues that printers and production managers reported as being very important to
their job responsibilities: ,
86% of TRI respondents and79% of printers reported the sources, quality,
and cost of raw materials to be-very important to their job responsibilities.
On the other hand, 45% of TRI respondents ahd'43% of printers reported
that the cost of input materials was very important in first getting them to
consider environmental issues in their jobs, ranking this issue in the
middle of the field. .
2-34
-------
Also, 71% of f RI respondents and 69% of printers reported that cost of
input materials was very important in influencing final choices of
equipment and operations, ranking this issue near the bottom of the field.
in) Production efficiency or other non-environmental benefits were ranked at the top
of issues reported by printers and production managers as being very important
in influencing the final selection of equipment and operations:
89% of TRI respondents and 80% of printers reported mat production
efficiency or other non-environmental benefits were very important in
influencing the final choice of equipment and operations, ranking them at
the top of such issues.
iv) " Trends in customer preferences for the respondent's product was ranked near the
top of issues that both printers and production managers reported as being very
important to their job responsibilities:
72% of TRI respondents and 68% of printers reported that trends in
customer preferences for the respondent's product were very important to
their job responsibilities, ranking this issue near the top of the field;
'>,,', ' .
28% of TRI respondents and 24% of printers reported that customers were
very important sources of information about alternative practices or
technologies for addressing environmental issues. This source placed
third or fourth on the list of such factors.
' I ' ' ' \ : f" *" ' '
Conversely:
61 % of TRI respondents and 54% of printers reported that customer
demands or willingness to accept changes in products were very important
in influencing the final choice of equipment or operations. This factor was
ranked near the bottom of the list;
37% of TRI respondents and 27% of printers reported that customer
demands were very important in first getting them to consider
environmental issues in their jobs. This factor was ranked near the bottom
of the list. ,
For the recommended approach for exploring these issues further, see
section 3.2.6.
2-35
-------
v) Several-other aspects of private markets were not,among the most frequent factors
cited by respondents: .. . ,' ...
75% of TRI respondents and 70% of printers reported that availability, of"
capital for process changes was very important in influencing their
selection of equipment or operations. This issue was ranked in the middle
of such factors; ..-.' . .
66% of TRI respondents and.62% o'f printers reported that insurance, -
liability, or risk management were very important factors in their job
responsibilities. This issue was ranked near the middle of their lists;
56% of printers and 51 % of TRI respondents reported that the sources and
, cost of capital were very important to their job responsibilities. This" factor
was ranked near the bottom of the list;
. 67% of TRI respondents and 59% of printers reported that the cost and .
quality of competitors' products were very important factors in their job
responsibilities. This issue was ranked in the middle of such factors; and
52% of printers and 48% of TRI respondents reported that technological
advances in manufacturing their products was a very important factor in
their job responsibilities. This issue was ranked at the bottom of the list.
2.3.1.2 Size
i) A greater number of the larger printers reported that employee morale and level
of productivity were very important. Printers reporting employee morale and
level of productivity as being very important to their job responsibilities included:
83% of the first size quartile,
. 93% of the second quartile, .
98% of the third quartile, and
100% of the top quartile.
ii) A greater number of the largest printers reported that cost and quality of
competitors'products -were very important:
« 65% of printers from the top size quartile reported that cost arid quality of
competitors'products were very important to their job responsibilities,
compared with 56% to: 57% of the printers in the three lower size quartiles.
2-36
-------
Hi) No easily explained trend emerges from the association between printer size and
the reported importance of customer preferences. Printers reporting that the trend
in customer preferences for their products was a very important'factor to their job
responsibilities included:
67% of the first size quartile,
58% of the second quartile,
78% of the third quartile, and .
71% of the top quartile.
iv) More Fortune 100 respondents than other respondents reported the cost and
quality of competitors'products to be very important:
77% of Fortune 100 TRI respondents reported that the cost and quality of
competitors' products were very important factors in their job
responsibilities, compared with 66% of other TRI respondents.
v) Similarly, the cost and quality of competitors'products were.reportedly more
important than other factors to fewer of the smallest manufacturers.
Manufacturers reporting that the cost and quality of competitors1'products were
very important factors in their job responsibilities included:
53% of the first size quartile,
. 73% of the second quartile,
71% of the third quartile, and
68% of the fourth quartile. *
vi) The importance of trends in customer preferences for the product seemed to
increase with firm size. TRI respondents reporting that the trend in customer
preferences for the product was a very important factor in their job responsibilities
included: . .
!.,''' ' ' ! ' . '*
67% of the first size quartile,
71% of the second quartile,
70% of the third quartile, and .
78% of the fourth quartile
2-37
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2.3.2 Minor Finding #2: TRI Respondents Cite Corporate Policies and Management
Directives as Very Important in Getting Them to Consider Environmental Issues.
i) Corporate environmental policies or management directives were ranked by TRI
respondents as being the most important factor (mentioned by 73% of
respondents) in getting them to first consider environmental issues in their jobs..
ii) Similarly, Fortune 100 respondents were more likely than other respondents to
cite corporate environmental policies or management directives as being very
important:
94% of Fortune 100 TRI respondents reported that corporate
environmental policies or management directives were very important in .
first getting them to consider environmental issues in their jobs, compared .
with 71% of the other TRI respondents.
Hi) The largest printers were more likely to cite corporate environmental policies of
management directives as being important. Printers reporting company
environmental policies or management: directives as very important in first getting.
them to consider environmental issues in their jobs were:
3 8% of the first size quartile,
29% of the second quartile, and
36% of the third quartile.
The fourth quartile distribution included:
56% of the second largest size category, and
68% of the top size category. ,
. For the recommended approach to exploring this issue further, see section 3.2.4,
2.3.3 Minor Finding #3: Printers Are More Likely to Cite Their Personal Interest and the
Interest of Their Family, and Friends as Very Important in Getting Them to
Consider Environmental Issues.
i) . Along with environmental enforcement actions, printers ranked the interest of
self, family, and friends in the environment at the top of the list of factors
considered to be very important in first getting them to consider environmental
issues in their jobs. ' . .
2-38
-------
58% of printers reported the interest of self, family, and friends in the
environment as being very important in first getting them to consider
environmental issues in their jobs;
53% of TRI respondents reported the interest of self, family, and friends in
the environment as very important for first getting them to consider
. environmental issues in their jobs, ranking this interest in the middle
among such factors;
50% of TRI respondents and 38% of printers reported community interest
or concern as being very important for first getting them to consider
environmental issues in their jobs, ranking this interest in the middle
among such factors;
56% of TRI respondents and 55% of printers reported that the attitude of
neighbors and the community toward their business was a very important
factor in their job responsibilities, ranking this attitude at the bottom
among such factors.
For the recommended approach to exploring this issue further, see section 3.2.3.
2.3.3.1 Size
i) The environmental impact of products was important to a greater number of the
smallest and largest printers. The percentage of printers reporting possible
environmental impacts of their products during use or disposal as a very important
factor in their job responsibilities included:
56% of the first size quartile, , . . .
46% of the second quartile,
52% of the third quartile, and
61% of the top quartile.
No easily explained trend emerges from the association between printer size and
the reported importance of the attitudes of company neighbors. Printers reporting the
attitude of company neighbors and community toward their businesses as a very
important factor in their job responsibilities included:
58% of the first size quartile,
61% of the second size quartile, and .
45% of the third quartile.
2-39
-------
The fourth quartile distribution included: :
59% of second largest size range (8-19 production employees)* and
50% of the largest size range (more than 20 production employees). *
ii) The environmental impacts of products seemed most important to the smaller.
manufacturers. TRI respondents reporting that the possible environmental impact
of products during use or disposal was a very important factor in their job
responsibilities included:
79% of the first size quartile, .- '
'.'.. ' . 73% of the second quartile,
59% of the third quartile, and - . - ^ '
' 67% of the fourth quartile.* ; ' '
2.3.4 Minor Finding #4: Vendors and Company Employees Were Cited as Very
Important Sources of Information.
. i) Company employees were most often cited as very important sources of
environmental information by production managers:- ,
51% of TRI respondents reported that company employees were very
important sources of information about alternative practices or
technologies for addressing environmental issues. This source was ranked
at the top by TRI respondents and near the top by printers (39% of printers
reported the same). .-..',
r. v. t - '
ii) As sources of information about alternative practices or technologies for
addressing environmental issues; vendors and suppliers were ranked at the top by
printers and near the top by production managers:
53% of printers and 3 9% of TRI respondents reported that vendors and
suppliers were very important sources of information about alternative
practices or technologies for addressing environmental issues.
in) Other private sources of information were cited as important:
45% of printers arid 26% of TRI respondents reported that trade
associations, publications, or conferences were very important sources of
' such information, ranking them near the top for printers and in the middle
for TRI respondents. -
2-40
-------
* 23% of TRI respondents and 16% of printers reported that consultants
were very important sources'of such information, ranking them in the
middle for such sources;
17% of TRI respondents and 14% of printers reported that other
companies were very important sources of information about alternative
practices or technologies for addressing environmental issues.. This source
was ranked near the bottom of the list.
iv) Among factors reported as very important in influencing the final selection: of
equipment or operations, availability of information on particular practices and
technologies was ranked at the top of the list by printers and near the. top of the
list by production managers: .
81% of both printers and TRI respondents reported that availability of
information on particular practices and technologies was very-important in
influencing their final choice of equipment or operations. This factor was
ranked at the top of the list by printers and near the top of the list by TRI
- respondents.
For the recommended approaches for further exploring the role of employees as sources
of information, see section 3.2.5. .
The findings discussed in this chapter are significant and cast much light on the
hypotheses discussed in chapter one. They raise many questions as well. The following chapter.
recommends approaches for addressing the most important of these questions.
2-41
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2-42
-------
CHAPTER THREE
ISSUES FOR FURTHER STUDY
3.1 INTRODUCTION
This chapter proposes approaches for the next iteration of the Study of Industry
Motivation for Pollution Prevention. The next phase would refine our understanding of seven
questions raised by the findings discussed in the previous chapter: .
1. How much pollution was actually prevented as a result of the reported pollution
prevention activities?
2. What reforms to the environmental regulatory system would make respondents'
jobs more productive economically and environmentally?
" 3. By what measure do respondents gauge their own "good environmental
citizenship"? '
.-',''., \ ' ,
4. What leads top corporate managers to issue environmental policies and directives,
and how do they evaluate the success of production managers in achieving the
objectives of those policies and directives?
5. Which company employees are important sources of environmental information
and where do they get their environmental information?
6. What role do customers play in driving environmental issues?
7. What do respondents perceive to be "pollution prevention planning
requirements"?
The 1996 survey instrument is assumed to be the starting point for the next survey. Each
of the above issues is discussed below as modifications to the 1996 survey.
3.2 ISSUES AND RECOMMENDED APPROACHES
3.2.1 How much pollution was actually prevented as a result of the reported pollution
prevention activities?
Eighty-seven percent of TRI respondents and 68% of printers reported implementing
pollution prevention practices. (See Section 2.2.1.) It was not clear, however, how much
pollution was prevented as a result of these activities, and existing data sources do not provide
much information on the issue.
3-44
-------
' - '
After being asked about the pollution prevention activities performed in their facilities,
respondents would be asked the following questions to indicate the approximate impact of
pollution prevention practices: - , . -
'Of the activities you just mentioned, which were the two mtist important? -
Please estimate the total savings or costs 'due to each activity.. ' _ ;
Please estimate the reduction in environmental impact due to each activity.
Following this, the employee who filled out the company's TRI form would be asked the
following questions: . ., .,.. , '
Are you familiar with your company's efforts to [describe the two activities]?
- ' ' / . ', ' r .
' - Please estimate the net costs or savings due to these activities.
Please estimate the reduction in the environmental impact of 'each, including the impact
upon TRI release if possible. . .
3.2.2 What reforms to the environmental regulatory system would make respondents' .
jobs more productive economically and environmentally? ,
- ' " - ' "*"*"" - - '
The environmental regulatory system was reported by respondents as a prime motivator
in nearly every question asked. (See Section 2.2.2.) At the same time, however, government
advice and government sources of information were ranked relatively low. One interpretation of
this finding is that while effective in getting the attention of production decision-makers,
environmental regulatory programs are not as effective in helping decision-makers respond to the
requirements.
/ " . ' ' ' ".''." : I
This interpretation is supported by other statements made by industry representatives in
support of proposed reforms to the environmental regulatory system. Given the limited resources
of EPA and its stakeholders, it would be useful to learn which of the proposed reforms would be
most productive, so that the Agency could give them the highest priority.
To gauge the relative value of reform options, respondents would be asked the following
questions: ;
"In the past two years, have you faced environmental regulatory requirements that were .
especially troublesome* or that for some reason led you to miss opportunities to greatly
; reduce the environmental impact of your facility? Please describe one or two examples
briefly: . "
. ' ' '. ..'.' '/. 3-45 ;' '..--.-''.. .'
-------
I'm going to read a list of factors that might have made'your work easier in this case.
Please rank these factors by the order of the benefit they would have provided you in
these specific cases. [Two or more factors can be tied for any one position]:
1. One-stop shopping: Having all the environmental regulatory requirements faced
by your company available to you through one government point of contact.
2. Plain English explanation: Having the environmental regulatory requirements
explained in publications in plain English.
3. Compliance and technical assistance: Having a government-subsidized consultant
provide compliance and technical assistance for a small fee.
4. Negotiated standards: Being able to negotiate with the environmental agency over
1 specific regulatory requirements, possibly reducing their restrictiveness.
5. Customer Specifications: Being able to negotiate with a customer over product
specifications, possibly reducing their restrictiveness.
6. Research and Development: Having a research and development laboratory
attack a specific technological problem your company faced.
3.2.3 By what measure do respondents gauge their own "good environmental
citizenship"? .
Fifty-eight percent of printers and 53% of TRI production managers reported that, "The
interest you [i.e., the respondent], your family, and friends have hi the environment" was very
important in first drawing their attention to environmental issues in their jobs. (Printers cited this
factor most often as being very important.) This "peer pressure" aspect of environmental
motivation is very poorly understood. (See Section 2.3.3).
To better understand the peer pressure aspect of environmental motivation, respondents
would be asked the following questions: . ,
When asked, "How important were eacri of the following factors in initially getting you
to think about environmental issues at this job?" (already in the 1996 survey instrument)
respondents would be offered the following options: .
1. The interest your family and friends have in the environment.
2. Your interest in the environment [always asked as the last option].
(This choice would replace the single option from the 1996 survey: "The interest you,
your family, and friends have in the environment.")
Respondents who report '#1, above, as being very important would be asked:
3-46
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. How important do you think each of the following factors are in your family 'sand
friends'assessments of your companies environmental performance? .
.A. News accounts of acts of environmental excellence or goodcitizenship, by your
company. > ,
B. News accounts of environmental enforcement actions against your company.
C. News accounts of your company's TRI releases. [Don't ask this of printers],
D. News accounts of your industry's environmental performance.
E. Your own reports of your company's environmental performance.
F. Environmental or community groups' reports of your company's environmental
performance. :
G. Environmental or community groups' reports of your industry's environmental
performance.
H. .Advertisements about your company's or industry's environmental performance.
Respondents who report that #2 in the first question, above, is very important would be
asked: . '. -'-. . ' - - ; - . . '
Please rank the following in their importance to you in assessing your "own company's
environmental performance: .
A. Basic Compliance: Compliance with environmental regulatory requirements.
B. Government Recognition: Government recognition or awards for environmental'
excellence. ,
C. Industry Recognition: Recognition for environmental excellence given'by your
peers in industry. . > -
D. Public Recognition: Recognition for environmental excellence given by
environmental or community groups.
E. Comparison with Peers: Your comparison of your.company's performance with
your peers in industry on the basis of objective facts, such as number of
enforcement actions, .amount of pollutants released as shown in the toxics
Release Inventory, environmental superiority of products, etc. .
3.2.4 What leads TRI business managers to issue environmental policies and directives,
and how do they evaluate the success of production managers in achieving the
objectives of those policies and directives?
Seventy-three percent of TRI production managers reported that some sort of
management policy, directive, or program was very important in first getting-them to consider
environmental issues in their job, making this the most frequently cited factor. (See Section
2.3.2.) This result suggests that the most important government policies may be those that
3-47
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influence top managers. To learn which top management directives are most influential, and to
then learn top managers' motivations for issuing such directives, the following questions would
be asked: ,
When asked, "How important were each of the following factors in first getting you to
think about environmental issues at this job," (already in the 1996 survey) three of the options
offered to TRJ product managers would be: .
1. A corporate environmental policy or directive;
2. A directive from your plant's top management;
3. An internal environmental audit or training.
(These three options would replace the single option from the 1996 survey: "A company
environmental policy or directive from your boss or top management to consider environmental
issues in your daily work or to conduct an internal environmental audit or training.")
In cases where respondents report that #2 or #3, above, are very important, surveyors
wquld ask the plant managers at the respondents' facilities the following question:
' ...» |PI|, , - i ' . i
Which of the following factors would you consider to be the primary responsibilities of
your production managers?
' " ' s . '
A. Meeting production deadlines.
B. Meeting customer specifications.
C. Keeping production costs down. .
D. Developing new business for the company.
E. Staying up to date on the latest production technologies.
F. Acquiring raw or input materials.
G. Maintaining employee productivity and morale. .
H. Staying up to date on trends in customer preferences for your products.
I. Ensuring compliance with environmental requirements.
Which of the following factors are important in approving new products or services to be
produced by your facility?
A. The facility currently has equipment technically capable of producing the
products.
B. The facility currently has equipment with the physical capacity to produce the
products.
C. The facility currently has employees adequately trained and prepared to produce
the products.
D. If the facility does not currently have the capacity in equipment or people to
produce the products, the cost, of expanding the capacity is covered entirely by a
3-48
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currently identified customer. .'. - . .
E. Producing the product will not require applying for a new environmental permit.
' F. Producing the product will not increase the waste or pollution generated by the
' - ' facility.
, G, The product itself will not pose an environmental challenge to downstream users.
i .' .
How important were each of the following factors in initially getting you to think about
environmental issues at this job?
A. The interest your family and friends have in the environment. ..
~ B. The interest your company's neighbors have in your company's environmental
impact. '
C. A corporate environmental policy or directive from your management:;
D. An internal environmental audit or training required by.;corporate management.
E. Customer demands.. '-... ,
. F. Your company's cost of input materials.
G. Environmental enforcement actions against your company (always ask this
question before the next).
. ... H. Environmental regulatory requirements faced by your company.
I. Voluntary government programs, such as 33/50 or Green Lights.
J. Stockholder demands.
K. Your company's environmental protection or waste disposal costs.
L. Yourpersonal interest in the environment (ask this question last).
In those cases where production managers reported that #1 "A corporate environmental
policy or directive" was very important, or where plant managers report that C. or D., above, are
important, researchers will contact the corporate management of those respondents to secure a
copy of the corporate environmental policy or directive. The CEO of the corporation would then
be asked the following question, in writing:
How important were each of the following factors in getting the corporation to address
environmental issues through [title of the corporate environmental policy or directive]?
A. , The interest your family and friends have in the environment.
B. The interest your company's neighbors have in your company's environmental
impact.
C. Customer demands.
D. Your company's cost of input materials. . . .
E. Environmental enforcement actions against your company (always ask this
. question before the next).
F. Environmental regulatory requirements faced by your company.
G. Voluntary government programs, such as 33/50 or Green Lights.
H. Your company's environmental protection .or waste disposal costs.
" ' - ':..-' ' 3-49; " . . " -
-------
I. Your personal interest in the environment (ask this question last).
3.2.5 Which company employees are important sources of environmental information,
and where do they get their environmental information1?
Fifty-one percent of TRJ production managers reported that company employees were
very important sources of environmental information about alternative technologies and
practices, making this the top-ranked source of information (see Section 2.3.4).
To learn which company employees are providing the information, employees at TRI
facilities would be asked the following question's:
TRI production managers asked, "how important were the following sources of
information in finding out about alternative practices or technologies for addressing any
environmental issues in your work" (already in the 1996 survey) would be offered the following
three options:
1. Company employees specializing in environmental issues;
2. Production equipment operators or managers;
3. Other company employees.
(These three options would replace the single option used in the 1996 survey: "Company
employees.")
The employee who filled out the TRI form would be asked:
How important were the following sources of information in finding out about the
environmental characteristics of production technologies .and practices?
1. Government employees;
* 2. Consultants;
3. Vendors and suppliers;
4. Government publications;
5. Trade associations, publications or conferences;
6. Organizations providing assistance such as universities or extension programs;
7. Customers;
8. Other companies;
9. Your company's employees;
10. - the Internet.
Both TRI production managers and environmental specialists would be asked:
3-50
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Do you feel that you have adequate access to credible and useful information on the
environmental performance of equipment, operations and products?
3.2.6 What role do customers play in driving environmental issues?
, Customers reportedly played an important role in environmental decision-making for a
sizeable minority of the respondents. Twenty-five to thirty-five percent of the respondents
(depending upon the question asked) reported that customer demands were very important in first
drawing their attention to environmental issues, and that customers were very, important sources
of environmental information (see Section 2.3.1.1). ,
At the same time, the potential influence of customers could be even greater. About 70%
of respondents reported that trends in customer preferences for their products were very
important in their overall job responsibilities (see Figures 1 and 5). Most respondents also
reported that customer demands were very influential in their final choice of equipment and
operations. ,
To better understand the role customers can and do play in driving environmental
decision-making, respondents would be asked the following questions:.
\
Respondents reporting that customers were very important in first drawing their attention
to environmental issues would be asked:
Please give two examples df customer demands that drew your attention to .environmental
issues. , '.-..
Are these examples related to the two process changes you mentioned earlier? [See
above.] .
, - . . \
[If not, then:]
Did these customer demands lead you to make changes that greatly reduced the overall
environmental impact of producing that product?.
Respondents reporting that customers were very important in overall job responsibilities,
but not in first.drawing them to environmental issues,-would be asked:
If a customer came to you with a request to reduce the environmental impact of your .
operations or of the product, -would you be able to accommodate the request?
Respondents reporting that customers were a very important source of environmental
. information would be asked: " ', .'.--,
' ' - '- " " " 3'51 '' - '-""' '
-------
Please give two examples of cases where the customer provided useful information.
Did you act on that information?
Respondents reporting that customers were very influential in the final choice of
equipment and operations would be asked:
Did the customers ' demands make it easier or harder to use equipment or operations that
were better for the environment?
All the above respondents would be asked:
Were any of the customers just discussed here government or U.S. military customers?
3.2.7 What "pollution prevention planning requirements" influenced the decision-
making? .
Two-thirds of TRI production managers and more than 40% of printers reported .
evaluating information on alternative practices or technologies for addressing environmental
issues as part of government-required pollution prevention plans. These respondents could have
been referring to a number of planning requirements (see Section 2.2.4). The following
questions would be asked to understand which planning requirements were influential.
The above-mentioned respondents would be asked:
Do you know specifically which pollution prevention planning requirement?
[If no, prompt with the following list:]
, A. [Common name of the state pollution prevention or waste minimization planning
requirement.]. ' , , .
B. The RCRA Waste Minimization Program requirement (which you have to certify
to having on the RCRA manifest)
C. Spill and leak prevention planning .. .
D. Stormwater runoff pollution prevention planning
E. .Evacuation or emergency planning
F. Planning done as part of applying for a permit
Did you generate useful information as part of the planning exercise?.
EPA hopes to carry out a study with such refinements at some point in the future.
3-52
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3-53
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APPENDIX A
RESEARCH METHODOLOGY
A.L SUMMARY
To conduct out this study, EPA familiarized itself with prior work on the issue, spent a
year carrying out a prototype study, and developed a questionnaire and a basic methodology
based on'the prototype. (See "Prototype Study'of Industry Motivation for Pollution Prevention*"
EPA lOO-R-96-001.) An EPA-hired professional survey company worked with the Agency to
refine the methodology and completed more than 1,000 interviews of production staff at
randomly selected lithographic printers and TRI manufacturing .facilities. The research company
also gathered information from other sources about the extent to which each of the surveyed
businesses was affected by environmental policy. ' '
The survey results and other information were .analyzed statistically. The statistical
analysis and EPA's preliminary interpretations were then sent or made available to hundreds of
environmental policy experts, industry representatives, and the general public via E-mail and
through direct mailings to organizations and trade associations.
A.2. SAMPLE SELECTION
This study was intended to identify factors motivating pollution prevention, as well as
their prevalence and effectiveness. Although the respondent sample selection was chosen
randomly, both the sample source and selection methodology differed for printers and TRI
manufacturers. The printer sample was selected randomly (within facilities reporting Standard
Industrial Category 2752 - Commercial Lithography as their primary SIC code) from a business
database maintained by Dun and Bradstreet (D&B). The extracted information included facility
name, the unique D&B number, state, and'telephone number. There are estimated to be 54,000
lithographic printers in the U.S. Dun and Bradstreet, thought to be the most comprehensive
listing available, contains 42,226 listings of businesses reporting a primary SIC code of 2752.
Among the reasons that some of the lithographers may not be contained in this particular subset'
of the D&B database are: (1) stand-alone lithographers may list the SIC code of the finished
product (e.g., SIC 2711 - Newspaper) instead of the printing process used; and (2) in-plant
operations may not classify themselves as lithographers unless it is their primary business line.
The sampling strategy for the printing sector included a larger number of completes (75
completes) for each of the four most active Great Printers states (IL, MI, MN and WI) so that we
. could estimate proportions plus or minus 10% with a 95% confidence interval that characterizes
baseline conditions for the Great Printers Project.1 Two hundred completes established a
'The Great Printers Project, co-sponsored by the Environmental Defense Fund (EDF),
Printing Industrie.? of America (PI A), and Council of Great Lakes Governors (CGLC), is
A-l
-------
sufficient sample size for .printers throughout the remaining U.S. Four replicates (each replicate
size was equal to N(completes)/.75, which accounts for standard nonresponse and erroneous
information contained in the source database) were selected randomly for .each of the five strata
(IL, MI, MN, WI, and the remainder of the U.S.). These strata were chosen to collect baseline
information on five states where Great Printers initiatives are now beginning; they were not
expected to be significantly different than printers throughout the U.S. Consequently, no.
separate analyses are presented in this report for the various strata of printers. The post-survey
weighting compensates for the oversarripling of facilities from the four Great Lakes states.and
allows it to be incorporated with responses from all other states as a nationwide survey. The
information will be used as a baseline for future assessments of the impact of the Great Printers
1 ' ' J - ' ' ' ' " '
Project. ' - . '.,,
The sample of manufacturers was selected randomly from the 1994 Toxics Release '
Inventory following the public data release in April 1996, when the information is essentially
frozen following data quality reviews. The Toxics Release Inventory database contains every
reporting TRI manufacturer. The only limitation related to the source of information for sample
selection was therefore the rate of compliance by large manufacturers with TRI. The extracted
information included facility name, the unique TRI number, reported D&B number, reported
NPDES permit number(s), reported RCRA/EPID number(s), state, address, telephone number,
and 1993 and 1994 waste generation and productivity index.
The sampling~strategy for TRI manufacturers included a larger number of completes (75)
for Massachusetts and New Jersey. As a result, we could narrow the 95% confidence interval to
plus1 or minus 10% for proportions characterizing the two states with the most extensive state
pollution prevention planning requirements. Approximately 350 completes for TRI
manufacturers throughout the remaining U.S. would provide us with the same confidence
interval for facilities in that population. As with the printers, four random replicates were
generated for each of the three strata (MA, NJ, and the remainder of the U.S.).
A.3. PREPARATION OF THE SURVEY INSTRUMENT
The survey instrument was based on the questionnaire developed during the prototype
study and was designed to collect as much information as possible while minimizing respondent
burden in a survey of between 10 and 13 minutes in length. Respondents were promised
anonymity and were offered a telephone number that they could call to request a copy of the
survey results. We did not solicit detailed facility information but focused on respondents'
recollection of recent experiences and opinions. Although the study was investigating pollution
prevention motivation, EPA recognizes that this topic is integral to facility operations. Particular
efforts were therefore made in the wording and sequencing of questions to minimize respondent .
investigating potential improvements in regulatory implementation and environmental
protection. - '-..-' ,
'.'.'" .' ' ' A-2: '".' '' '
'-.10
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bias associated with anticipating "correct" answers. (For example, respondents were queried
about particular process changes rather than asked questions using the term "pollution
prevention.") Several iterations of the survey were circulated to reviewers within EPA, a private
firm involved in tracking environmental markets, academics, and government personnel at other
agencies. Clearance for the study was sought and received from the Office of Management and
Budget as required by the Federal Paperwork Reduction Act. (OMB generic clearance No. .
2070-0034. EPA No. 1170.)
Screener questions were used to ensure that the facility was involved in manufacturing or
lithographic printing and that the interview would be conducted with an appropriate staff person.
The questionnaires used for printers and TRI manufacturers differed only in the description of
possible process changes and screener questions. For both populations surveyed, it was critical
to conduct the interview with individuals involved in production line decision-making, not those
whose primary responsibility was either environmental affairs or environmental compliance. A
screener question requested an individual with day-to-day responsibility for production/printing
operation decisions. Because printers are typically very small operations, we first requested to
speak to the owner if there were fewer than 20 employees on site (as reported in the D&B
dkabase). There was some concern that respondents might not participate because the study was
sponsored by governmental agencies. To determine if there was strategic non-response due to
government involvement, all those refusing,to participate were prompted with an open-ended
follow-up question asking them to explain why. See Administration of Survey section regarding
results of open-ended query for refusals. '
A.4. PRETEST AND REVISIONS
A total of 22 pretests each was administered to printers and TRI manufacturers in the first
week of June. Asa result of the pretest, the survey was revised to clarify parts of the
questionnaire and to reduce the time required to participate. Most significantly, a detailed list of
pollution prevention activities drawn up specifically for lithographic printers and a more general
list for TRI manufacturers was collapsed into a series of four to five categories with listed
examples. (For example, printers were asked, "In the last two years, have you made any changes
in your image making processes, such as: switching to computer image editing, installing
countercurrent washing, or alternative platemaking?") During the pretest, each item on the list
was read as a separate question. Using the revised instrument, each list was read in its entirety
unless the respondent answered during the listing. Similarly, lists of items used within several
lines of questions were shortened by combining items. The number of prompts used in ranges
was reduced from four to three: "very [important/valuable]," "somewhat [important/valuable]"
and "not [important/valuable] at all," Finally, a number of wording and grammar changes were
made to reduce the reading comprehension level required.
A.5. SURVEY ADMINISTRATION
A.5.1. Survey protocols
' A-3 ' ' ' '
7/
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The telephone survey was administered following well-tested .protocols of a national
survey group,. All interviewers were experienced in administering surveys of establishments.
' Interviewers were trained in the specific information needs of the study and were provided
background on the types of facilities they would be contacting. Constant supervision was .
provided by senior survey research staff. The survey was entered into Computer Assisted
Telephone Interviewing (CATI) software so that (1) the order of items on all lists Within the .
survey would be rotated, and (2) data were entered as the survey was administered. .
To meet the goal of completing the study before the end of the Federal fiscal year on
September 30th (including the linkage and analysis of survey data with outside information ,
sources, peer review, and revisions), the survey itself had to be completed by the' end of June, a
period of three weeks. The survey could not be started until the first week in June due to the fact
that EPA received a budget very late in the fiscal year. The most important implications of such
a compressed .schedule were: (1) fewer call attempts were.made to each number; and (2) at least .
one call was attempted to most facilities contained in the four replicates. Consequently, the
response rate is far lower than would be expected if the survey period had been longer; this is
taken into account in the statistical weighting and subsequent analysis of the survey results. The
response rate for printers was 24% and the response rate for TRI. respondentswas 21%. .
A.5.2. Disposition of Completed Survey
, * = *
In total, there were 516 completes for the TRI manufacturers and 520 completes for
printers. The compressed survey period (three weeks), while not desirable, was needed to issue
survey results by early August following OMB approval in early May. This schedule resulted in
larger samples (2,672 manufacturers and 2,668 printers) being used in order to achieve the
number of completes desired. As would be expected under such conditions, the response rate
was far -lower than it would have been had the survey period been longer. The overarching
reason for low response rates is that the facilities with a busy signal, no answer, time arranged for
a call back, or an individual riot available at the time of the call (48% of the manufacturers
sample and 34% of the printers sample) were not called back once the desired number of
completes was reached. Several other dispositions (the status of calls, e.g., refused to participate,
language barrier) may also have caused.non-respondent bias. Not knowing the impact of .
including particular disposition groups of nonrespondents on the survey results, we grouped .
together all facilities thought to be in-scope to test for possible nonresponse bias. The table
below provides, the final disposition of all calls. .
A-4
7-
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Surveys Ended with 55% Pending Callbacks and 16% Refusals
TOTAL SAMPLE
Unobtainable, business not in
scope, wrong number,
going/gone out of business
Subtotal
Completes
Nonrespondent Subtotal
FINAL DISPOSITION*
No answer
Busy
Appointment set-lip " t
Person not available* \
\ 4|4
General callback (
Answering machine * '**
Break off
Final other
Language barrier
Respondent not available during
study
Gatekeeper/Other refusals
TRI Manufacturers
2,670
242
2,425
516
1,909
(79%)
12
? * ' ' , \ 10,
r (i* ' *, -' *,i» t $7 £
»*fy > ,f ^ft*:}
cw'i'-Av/":^ >» ,
U^Ci. '*' fe^'" .24^;
37
20
?
30
366
Printers
2,668
496 '
2,172
520
1,652 .
(76%)
13
,. -v - 41
;. . ''i/i^* ^' 3s ,
£fe>fV; *'' ',;»* %""A''*»9'?»
f'S*.** v»> «'&.*& » t «>*.<> * '
w n *> ^-^
U* - ^ »" ;! ** tio
* f * . ', ll*
$ i-f -» -29
U
38
19
. . '3
47 .
273
* Callbacks would occur for dispositions in shaded rows
A-5
-.73
-------
Facilities with any of the final dispositions for which the interviewer would typically
make another call attempt (shaded in the tablp above)r^e not expected to, but may be
significantly different than those facilities willing to respond. Typically, Abt Associates will
make 20 call attempts to a person'before assigning them as unreachable. The following table
summarizes the number of attempts made to recall facilities at the time 'the survey was
completed. It shows that there were a great many pending call backs when the survey was
completed. . . ,. ,
Final Disposition and # of Attempts
for Pending Callbacks at End of Survey Period
Number of
Attempts
.1
2 .-''
3
4
5 '
6
7 .
8 ,
9
10
11-12 ,
13-15
16-20
No answer
1
1
'' . 3
3
3 '
, 2
1
2
6
. 3
Busy
.1
1
14-
5
Appointment
made
64
,. ' 32
18
15 -
8
11
8
7
.".' 4
5
6
3-
1
Person not
available
1,067
-341
183
132
9,1
64
47
34.
25 *
19
23
8
1.
General
callback
49
,17
16.
5,
' 12
13
7
5
5 ...
3
,74 . .
17 .
4 '
Answering
machine
3
2-
' . . 5 .
8
2
1
29,
3
A.5.3 Evaluation of Possible Nonrespondent Bias .
For survey results to be used with confidence, it is critical to determine that the facilities
. interviewed are representative of the population as a whole. It is important to demonstrate that
nonrespondents are essentially similar to the facilities agreeing to participate in the survey. To
identify any dissimilarities between respondent and nonrespondents of this survey, a number of
comparative analyses were undertaken. Given that we do not know what nonrespondents would
report, we must use known characteristics of the sample facilities to compare respondents to
. nonrespondents". Ideally, the evaluation of possible nonrespondent bias would include many ;
-------
metrics of parameters possibly affecting facility behaviors and opinions, but this was not possible
for the Pollution Prevention Motivation Survey due to the limited information available from the
databases from which samples were drawn. .
We began the examination of nonrespondent bias by reviewing the reasons given for
nonresponse to determine if government sponsorship of the survey might have affected
participation. Next,-we examined differences between the few known characteristics of both
respondent and nonrespondent facilities for TRI manufacturers and printers separately. From the
survey itself, it was determined that facility size (employment) was strongly associated with
many of the factors motivating pollution prevention. For TRI manufacturers (employment is not
reported to TRI), we examined the number of Form Rs filed per facility (as an indicator of
facility size and complexity of operations), as well as the percentage of facilities in each group
reporting source reduction activities in Section 8 of Form R. In the case of the printer sample,
We aire limited to the parameters contained in the Dun & Bradstreet database. Consequently, we
compared the number of employees on site for each group. The remainder of this section
presents:
coded reasons for refusal; -
tested differences among TRI manufacturers; and -
tested differences among printers. .
A.5.3.1 Coded Reasons for Refusal
EPA was initially concerned that facilities might be more likely to refuse to participate
knowing that the survey was sponsored by EPA than if the survey was administered by an
independent organization. To meet contractual requirements, Abt Associates' interviewers
identified themselves and stated that the survey was performed under EPA contract. In part to -
test for the effect of EPA sponsorship, we asked all those refusing to answer if they would
provide us with their reason for refusal. Approximately 60% of the 639 refusals provided a
reason. A review of the reasons for refusal showed that Too Busy/No Interest topped the list
(72% of specified refusals). Corporate policies against participating in telephone surveys
accounted for 19% of specified refusals. In all but ten cases (3% of specific refusals),
sponsorship by EPA and/or the government was not cited as the reason for refusing to participate
in the survey.
A.5.3.2 Tested Differences Among TRI Manufacturers
Number of Form Rs Filed. A second test of difference between respondents .and
nonrespondents was performed using the number of TRI Form Rs filed by facilities. This factor .
is associated with facility size and complexity of operations (bqth of which are associated with
facilities' ability to pursue and interest in pollution prevention), the nonrespondents filed an
average of 3.3 forms (standard deviation of 4^3). Respondents filed an average of 3.1 forms
(standard deviation of 3.5). The first quartile.(l~ form), median (2 forms), and third quartile (4
" ' ' -' ' ' ^A-7 '
-------
forms) were the same for both groups. . _v -. ---,'-.
TRI-Reported Source Reduction. The prevalence of facilities reporting source reduction
in Section 8 of Form" R was examined as another key indicator of bias in the sample. Of the.
22,744 TRI facilities filing for 1994, 32.3% reported that they undertook source reduction for at
-least one of the chemicals for which a Form.R was filed. In comparison, 33.0% of survey . .
respondents reported source reduction on at least'one of their 1994 Form Rs. The close
proximity of these values is a strong indication that.the respondent pool is representative of the
TRI universe as a whole and that nonrespondent bias is not present. '
Taken together, this review of TRI information indicates little difference between
respondent and nonrespondent facilities, and thus a low likelihood of nonrespondent bias.
A.5.3.3 ' 'Tested Differences Among Printers : .
Facility-Size. Examining employment at the facilities (as reported to the D&B database,
from which the sample was pulled) reveals that the populations of responding facilities arid
nonrespondents are essentially equivalent,. The respondents had, on average, 15 employees, with
a standard deviation of 38. Nonrespondents had an average of 12 employees, with a standard
deviation of 32. The median employment was six for respondents and four for nonrespondents.
The mode, of most frequently reported value, for both groups was three employees. These
values indicate that the respondent and nonrespondent populations do not differ significantly in
size. Facility size is strongly associated with resources available and other factors thought to ,
influence pollution prevention.
Based on this information, nonrespondent bias does not appear to be present in the
survey of lithographic printers. ,
A.6. POST-SURVEY WEIGHTING
. For the sample selection of printers, there were five strata. Illinois, Michigan, Minnesota,
and Wisconsin were treated as four separate strata, and the establishments in the rest of the states
were grouped into a single stratum. For the sample selection of TRI manufacturers, there were
three strata: Massachusetts, New Jersey, and establishments in the rest of the U.S. There is a
basic sample selection weight for each establishment in the sample that is considered a .
' completed call. This weight is derived by taking the ratio of the number of establishments in a
stratum population, divided by the number of establishments selected in the sample (total of all
replicates). This denominator includes completes, nonrespondents, out of business, put of scope,
no production,, and so on. The effects of the low response rate, which affect post-survey
' weightings, confidence intervals of point estimates, and p-values for chi-squared analyses, are
explicitly taken into account throughout the statistical analysis. A detailed discussion of the
weighting protocols and derived values is included in Appendix B. .
A-8
-------
A.7. LINKAGE OF INDEPENDENT INFORMATION
To test a number of hypotheses about the possible effect of certain facility characteristics
on facility behavior and decision-maker attitudes, information from outside sources was linked to
each of the facilities surveyed. This information included:
environmental permits; .
compliance history; ' .
facility ownership (by Fortune 100 company); and
one-year change in waste generation (as reported to TRI for the years 1993-1994):
The methodologies used to link surveyed facilities to facility information from other
sources are described below. Percentages presented in the following section are for the
unweighted sample and may not match percentages presented in the results section, where each
facility's responses have been weighted.
A.8. ENVIRONMENTAL PERMITS
The first step to determine if the presence of environmental permits affected a facility's
performance or decision-making was to identify all major regulatory permits associated with
each facility. This permit linkage was performed using permit linkage routines recently
developed by the Office of Enforcement and Compliance Assurance (OECA). Individual
facilities were never identified to EPA staff.
A.8.1 EPA Permit Data on Printers
The D&B number was retrieved along with the contact information from the D&B
database as part of the original sampling effort. The D&B number was then used in a linked
query of EPA's Integrated Data for Enforcement Analysis (IDEA) system. The IDEA system .
links the databases of all major environmental media programs (e.g., Clean Air Act - CAA,
Clean Water Act - CWA, Resource Recovery and Conservation Act - RCRA) at the facility level,
in addition the D&B database. The linkages contained in IDEA are based on .an address-match
established by EPA's Facility Indexing System (FINDS). In 1995, Dun & Bradstreet developed a
separate beta-test linkage using their own name- and address-matching algorithms. Each system
has the capability of linking multiple permits to each.facility (as represented by its unique. D&B
number). For the printers surveyed, the unique permits identified in the D&B beta-test and
IDEA were combined for each D&B number, yielding the greatest coverage of permits.
Following these procedures, a CAA, CWA, or RCRA permit was identified for just 12.5% of
printers (most of which have a RCRA ID only):
' A test was conducted to ensure that the majority of printers were, in fact, out of EPA's
permit system rather than in the system but not readily linked to their D&B numbers. Assuming
that printers were most likely to require a RCRA identification number, we undertook a search of
A-9
" 77 ' .
-------
the 39,226 individual RCRA identification numbers in New York state for the 18 New York
printers surveyed and identified just one permit-(~5%), which indicates that the automated
linkages may slightly under-represent the existence of permits. Further individual record
searches for approximately 450 printers were not undertaken due to time constraints.
Linked Permits/Program IDs for Surveyed Printing Facilities
i '
Linked Permits/Program IDs
None Identified
RCRA only
Air and RCRA
Number of Facilities
455
59
6
Percentage of 520
Surveyed
Printers .
8.7.5
11.3 .
1,1
A.8.2. EPA Permit Data on TRI Manufacturers
: The TRI manufacturers were linked to program permits somewhat differently. As with
the printers, a unique identification number, in this case the TRI ID, was used in a linked IDEA
query to identify program permits associated with those facilities. Each facility filing Form R
under the Emergency Planning and Community Right-to-Know Act (EPCRA) must report all
RCRA and NPDES numbers. These numbers were extracted and combined with all unique
IDEA linked permits. Program permits were identified for approximately 90% of TRI facilities.
Approximately 56% of facilities were identified with multiple permits. While not deemed
necessary, additional automated linkages are possible using the D&B number (also reported on
Form R) to search D&B's beta-test database.
Linked Permits/Program IDs for Surveyed TRI Manufacturers .
Linked Permits/Program IDs
None Identified
Air only
Water only - , -
RCRA only
Air and Water
Air and RCRA
Number of Facilities
50
10
, 15
152 .
V ; .. ; 4
,95-
Percentage of 5 16 TRI
Manufacturers Surveyed
' 9.7
1.9
2.9
29.5
' , : 0.8
18.4
A-10
-------
Water and RCRA
Air. Water and RCRA
77
113
14.9 /
21.9
A.9. COMPLIANCE HISTORY
Using the permit linkages described above, the number of inspections and enforcement
actions under any of the three media programs within the past two years were extracted from
IDEA. The function that selects enforcement actions uses only major state and Federal actions.
The flag for actions include administrative actions and judicial or criminal actions, but not the
much more frequent Notices of Violation. Rather than use the actual number of inspections and
actions, the data analysis was performed using a flag indicating if one or more inspections had
occurred in the past two years and another flag indicating if one or more enforcement actions had
occurred. Approximately 55% of the TRI facilities were inspected, and 4% were subject to at
least one major enforcement action. Less than 2% of the printers were inspected with only two
actions in the past two years. Of note, an inspection does not necessarily always precede an .
enforcement action (which can occur, for example, as a result of missing a filing deadline).
A.10. FACILITY OWNERSHIP BY A FORTUNE 100 COMPANY
The ultimate parent D&B number of all Fortune 100 companies was extracted by
searching, by company name, a D&B database leased by EPA. As described above, the D&B
number for all surveyed printers was taken from D&B during sampling and is reported for 430
(88%) of the 516 TRI manufacturers on Form R. The ultimate parent D&B number for each of
the facilities was then extracted from a D&B database leased by EPA and matched to those of the
Fortune 100 companies. Approximately 5% of the TRI manufacturers and none of the printers
were owned by a Fortune 100 parent.
A.11. WASTE REDUCTION NORMALIZED FOR PRODUCTION
Facilities must report annually to TRI the amount of each TRI chemical generated as
waste prior to treatment, recycling, use as energy, offsite transfer, or release. In addition, they
must report an activity index with which year-to-year changes in waste generation can be
normalized to account for changes introduction. While changes in waste generation from 1993
to 1994 do not match the period referenced in the survey ("the past two years"), 1994 is the most
recent year for which TRI reporting is available. These data elements were used to calculate a
percent change for each TRI respondent as follows:
Waste93*A.I.(93_94)
A-ll
-------
where: _ , . - . " ' ' . ' ,"
Waste = . sum of values of waste generation reported in Sections 8.1 through 8.7 of Form
.'- R; '-/' ' \ ; ,-'.- ' .
A.I.(93.94) = Activity Index representing change in production level from 1993 to 1994
(Section 8.9 of Form R).
Rather than attempting to find statistical associations related to the calculated, percentage
change in unit waste generation of individual facilities, the distribution of these values was used
to create four quartile categories of change in waste generation: more than 14% decrease in unit
waste generation, 0-14% decrease, 0-14% increase in unit waste generation, or more than 14%
' increase. This approach reduces the impact of including some of the extreme outlier activity
index values (thought to occur when the decimal point is dropped erroneously by the filer when
completing Form R), There were, at most, seven such outliers; there were no negative activity
index values for the survey sample).
A.12. POST-SURVEY STATISTICAL TESTING OF CORRELATIONS AND RESULTS
The weighted frequencies (of proportions) presented in the findings section of this report
were calculated for the responses to each question using the SAS statistical software package. In
addition, a number of cross tabulations tables were generated to ascertain associations among
. specific variables (question responses and/or facility characteristics) using SAS.
,. _ ' - . ; v - . -. - - ,
Standard errors of the estimates depend on the sample size and the sample design used for
the survey. For example, the standard error of a sample percentage based on a stratified random
sample of a certain size may be smaller than the standard error of the percentage based on a
simple random sample of the same size. Standard errors must therefore be estimated taking into
account the sample design adopted for the survey. For computing the standard errors in this
survey, we have used the Survey Data Analysis software (SUDAAN, which was developed and
is maintained by Research Triangle Institute) specifying the proper design. SUDAAN takes into
account the stratification of the population and the disproportional allocation of the sample to
strata while computing the standard errors.' Further details are provided in Appendix B.
A-12
-------
APPENDIX B
SAMPLE SELECTION WEIGHTING, POST-SURVEY WEIGHTING AND
STATISTICAL ANALYSIS
B.I BASIC SAMPLE SELECTION WEIGHT
The sample selection of printers involved five strata. Illinois, Michigan, Minnesota, and
Wisconsin were treated as four separate strata and the establishments in the rest of the states were
grouped into a single stratum. The sample selection of TRI manufacturers involved three strata:
Massachusetts, New Jersey, and establishments'in the rest of the U.S. A basic sample selection
weight was assigned to each establishment in the sample considered to be a complete. This
Weight was derived by taking the ratio of the number of establishments in the population in a
stratum, divided, by the number of establishments selected in the sample (total of all the three
replicates), including completes, nonrespondents, out of business, out of scope, no production,
etc.
Let Nh be the number of establishments hi the hth stratum. Let nh be. the number of
establishments selected in the sample. The sample selection weight for all establishments in the
sample in the h* stratum is Nh/ nh . The sample selection weights are given for the five strata in
the printing industry andTRI manufacturers.
Selection Weights for Printers
Stratum
Illinois
Michigan
Minnesota
Wisconsin
Rest of U.S.
Number of
Establishments in the
Population ( Nh )
2,446
1,558
860
882
36,480
Number of
Establishments in the
Sample (n^
400
400
400
400
1,068
Selection Weight
' (Nh/nh)
6.115
3.895
2.15
' 2.205
34.16
B-13
-------
Selection Weights for TRI Manufacturers
f
Stratum
Massachusetts
New Jersey
Rest of U.S.
Number of
Establishments in the
'Population' ( Nh )
: 541
. - . . 673
21,529 ..
. Number of
Establishments in the
Sample (nh)
400
400
1,872
Selection Weight
(Nh/nn) '
1.353
1.683
-.1.50
B.2 NONRESPONSE ADJUSTMENT WEIGHT
Nonresponse adjustment to the selection weight is to be made within each stratum. Out of
nh units in the hth stratum, let there be n,,h completes, n^ nonrespondents, and noh out of business,
out of scope units. The nonresponse adjustment is then given by the ratio: -
"cH+nnrk
ch
The overall weight attached to each establishment considered to be complete in the sample is
given by the product of the two weights, and is:
wh=-
n
ch
It is therefore important that we clearly identify the two groups, namely, the nonrespondents and
the out of business establishments that include no production establishments. The following table
shows the selection weight, nonresponse adjustment, and the overall weight. -
B-14
-------
Overall Weights for Printing Facilities
Stratum
Illinois
Michigan
Minnesota
Wisconsin
Rest of U.S.
Selection .
Weight
6.115
3.895
2.15
2.205
34.16
Number
in Sample
(nj
400
400
400
400
1,068
Number of
Completes
(nch) '
76
78
80
80
206
Number of
Nonrespond
ents (n^)
. 231
256
278
284
603
Nonresp.
Adjust.
4.039
4.28
4.475
4,55
3.927
Overall
Weight
(Wh)
'24.701
16.679
9.621
10.033
, 124.15
Overall Weights for TRI Manufacturers
Stratum
Massachusett
s
New Jersey
Rest of U.S.
Selection '
Weight
1.353
1.683
11-.50
Number
in Sample
(Hh)
400
400
1,870
Number of
Completes
(HCH)
75
78
363
Number of
Norirespoh-
dents (rU)
295
278
1336
Nonresp
Adjust.
4.933
4.564
4.68
Overall
Weight
TO
6.672
7.679
53.827
B.3 ESTIMATING PERCENTAGES OR PROPORTIONS
,r ',',,''' ;,,"''' ' ' ' ' '
Suppose that we are interested hi estimating a percentage. For example, the percent of
establishments that said'"yes" to the question, "In the last two years, have you made any changes
to your printing operations?"
" ' ' ' ,i ' ' Ji' ' ? "
These percentages are estimated by using the data from the completes, along with the
weights derived earlier. Let ych be the number that say yes to this question in the hth stratum.
The percentage is estimated by taking the ratio ph = [ Wh ych / Wh ly ] 100: the ratio of
establishments that said yes to the total number of completes multiplied by 100. If we want an
estimate for the whole population, then we use the ratio: . .
'B-15
-------
100
This ratio is computed by attaching the overall weight to each complete and then
allowing the variable yich take a value of 0 or 1, depending upon whether the-ith establishment in
the hth stratum says yes to this question or not. The variable is summed all establishments and
divided by the sum of the weights taken over all completes.
The variance of the stratum estimate ph is obtained by computing: -
Y '-v n nckMl-Pj
, v(ph)=(\-) - .
The variance is based on only the number of completes. The standard error of the estimate ph
is given by \Jv(p). The variance of pis given by:
E Wfn;
The denominator is the square of the sum of the weights taken over all completes. The standard
error of the estimate p is given by \jv(p).
B.4 ESTIMATION OF PROPORTIONS FOR SUBGROUPS
To estimate a proportion for a subpopulation or domain, for example, according to the
regulatory status of establishments in the EPA databases, the procedure described below is used.
Let the domain of interest be d Then the overall proportion of establishments saying yes
' in a specific domain is given by . , .
B-16
-------
We have thus identified all the establishments belonging to the domain or having a specific
regulatory status. Of those answering yes to a particular question, we use the overall weights
calculated originally to calculate the proportion as follows:
"cdH
The variance of pdh is given by:
The variance of pd is given by:
The stcoidard errors of the estimates are given by \jv(pd}) and
The following Appendix C presents the actual survey.
B-17
-------
APPENDIX C
INDUSTRY MOTIVATION SURVEY
IF 20 OR MORE EMPLOYEES: .' : .
WHEN CALL IS ANSWERED, SAY: ".'.'". .: .
Could I please speak with the person in charge of managing (lithographic), production on/a day-
to-day basis? TERMINATE IF NO LITHOGRAPHY OR PRODUCTION AT THIS
LOCATION. ; .
IF FEWER THAN 20 EMPLOYEES: ., - .
WHEN CALL IS ANSWERED, SAY: . ' .
Could I please speak with the president or owner of the company? IF NOT AVAILABLE/SAY:
Could I please speak with the person in charge of managing production on a day-to-day basis?
TERMINATE IF NO LITHOGRAPHY OR PRODUCTION AT THIS LOCATION:
WHEN CONNECTED TO ELIGIBLE RESPONDENT, READ INTRODUCTION.
Hello, my name is . I'm calling from Abt Associates, a national survey
research company. We are conducting a confidential survey of managers at 500
(printers/manufacturing facilities) nationwide. The study is sponsored by Department of
Commerce, Department of Energy, and Department of Defense through an Environmental
Protection Agency contract. We are trying to identify factors associated with successful and
efficient operations, such as inventory controls, quality management and new technologies. We
need your input to help these .agencies know when their services can be most useful and when .
government should get out of the way. Participation in the study is voluntary and yo'ur answers
will be kept in strictest confidence. . . '
Just to confirm thatwe're talking to the right person, are you involved in making
production line decisions, such as changes in (printing inks/materials) or equipment to improve
product quality? ' '
YES (CONTINUE)
, NO (ASK FOR NAME AND PHONE NUMBER OF APPROPRIATE PERSON;
RECORD AND ASK TO BE TRANSFERRED. WHEN CONNECTED, READ
INTRODUCTION.)
IF REFUSED, ASK: That's fine, do you mind telling me why? .
P2 Motivation Survey C-18 July 24,1998
-------
We are interested in learning what things affect decisions to alter production processes at
your facility. As I ask the questions, please keep in mind that I am not an expert on your
processes.
In your job responsibilities, how important are the following factors? Is/Are (READ
ITEM) very important, somewhat important, or not important at all?
Very Somewhat Not Imp.
Imp. Important at All
3 2 1
3
3
3
3
2
2
2
2
a) Cost and quality of competitors'
products
b) Employee morale and level of
productivity
c) The sources, quality and cost of raw
materials and inputs
d) The sources and cost of
capital
e) Technological advances in
manufacturing your
product
f) Trends in customer preferences for
your product
g) Attitude of your company' s neighbors
and community towards your
business
h) Possible environmental impacts of
your products during use or
disposal .
i) Possible environmental regulatory
requirements
j) Insurance, liability or risk
management
IF BOTH h AND i = 1, SKIP TO QUESTION 11
IF MANUFACTURER AND h OR i > 1 SKIP TO QUESTION 2TM.
IF PRINTER AND hORi>l CONTINUE .
P2 Motivation Survey
C-19
July 24,1998
27
-------
2P QUESTION FOR PRINTERS ' , .
We would like to learn about any recent changes you may have made to your '
lithographic printing operations. In the last 2 years, have you made any changes to your
' printing operations, however small? , ' -
YES ; .... 1
NO (SKIP TO Q 11) ....2
DON'T KNOW(SKIP TO Qll) ..'.". 3
REFUSED(SKIPTOQll) .. ..4." ,
I will read a list, please say yes if you have made any of the following changes in the past 2
years. Have you... '''..
INTERVIEWER; IF YES TO ANY ENTER 1. YOU MAY STOP READING AS SOON AS R
SAY'S "YES". . .". , :' , ' . ' ' .-
. YES NO DK
Implemented good operating practices such as: 1 2 8
change work practices to extend film developing bath life, ,
changed from small volume containers to bulk containers to minimize
discarding of empty containers; ' .
began using alternative packaging to reduce amounts used or wasted;
adopted inventory controls or better labeling procedures to reduce :
disposal of outdated chemicals;
1 28
Modified or substituted chemicals such as less toxic
inks, vegetable-based inks, inks with lower or no VOCs that is volatile
organic compounds, fountain solutions lower in VOCs or alcohols,
adhesives lower in VOCs such as water-soluble adhesives, prepress
chemicals or films that are less toxic or generate less waste, or blanket
and roller washes lower in VOCs.
]Vtpdified image-making or prepress operations j 2 8
such as switched to computer image editing; changed to countercurrent
washing chemicals; adopted alternative platemaking technologies that
reduce waste such as laser, waterless, or non-silver plates..
' "-""" *,. '
Modiiied press operations such as made mechanical or 1 2 8
equipment adaptations such as ink levelers, web break detectors,
registration systems, fountain chillers automatic blanket washers; .
started using alternative binding techniques which create less waste or
pollution; or started using alternative printing chemistries such as water- :
developed lithographic plates. .. _ .
SKIP TO QUESTION 3
P2 Motivation Survey C-20 July 24,1998
" ' ' '
-------
2TM QUESTION FOR TRI MANUFACTURERS
Implemented good operating 1 2 8
practices such-as: improved maintenance scheduling, .
record keeping, or the production schedule to minimize
equipment and feedstock changeovers; or
improved inventory controls, or labeling to reduce .
disposal of outdated chemicals?
Improved materials handling practices 1 28
such as: improved storage and transfer procedures,
installed overflow alarms, automatic shut-off valves, or
. Vapor recovery systems, or implemented an inspection or
monitoring program to prevent spills and leaks?
Substituted chemicals or raw materials 1 2 8
or modified your product such as: used more pure raw
materials, or used substitute chemicals or materials
reducing pollution or waste generation;
changed to aqueous cleaners from solvents or other .
materials; or
changed the composition of your product, product
specifications, or product packaging to reduce waste
streams or pollution?
Modified production related processes 1 2 8
such as: instituted recirculation within a process,
modified equipment, or layout, used a different process
catalyst to reduce pollution or waste generation;
improved draining equipment or procedures to reduce
dragout from chemical or rinse tanks; or
improved rinse systems, equipment or operation to
reduce water use, wastewater or .waste generation; or
improved surface preparation, coating spray systems or
application techniques to reduce po.llution or waste .
generation. . .
P2 Motivation Survey C-21 July 24,1998
" ' '. , . 7~>!
-------
Modified cleaning or degreasing
operations such as: changed cleaning, degreasing, '
stripping or cleaning operations or equipment to reduce
pollution or waste generation; or
changed to mechanical stripping or cleaning devices'
from solvents or other materials. .
3. We would like to learn about how you make your decisions to change your production
operations. WeM like to ask you about what might have first made you think about
environmental issues, then where you get information on process changes, then how you
decide on what change to make, and finally how the final decision was made.
*.*,-
Let's start with what made you first consider environmental issues. How important were
each of the following factors in first getting you to think about environmental issues at this
job. Was/were (READ ITEM) very important, somewhat important, or not important at all?
(ROTATE)
a) The interest you, your family, and friends have in
.the environment
b) Community interest or concern
c) A company environmental policy or directive from
your boss or top management to consider
environmental issues in your daily work or to
conduct an internal environmental audit or
training . .
d) Customer demands
e) Your company' s cost of input materials
i ' - . .__
f) Your company's environmental protection or waste
. . disposal costs
g) Environmental enforcement actions against your
company
h) Government programs that provide awards or
recognition for environmental
ex:cellence '
i). State government pollution prevention planning
requirements
Very Somewhat Not Imp.
Imp. Important At All
3- 2 - 1
3
3
3
2
2
2
2
DK
8 -
8
8
P2 Motivation Survey
C-22
July 24,1998
- -' y o
-------
P2 Motivation Survey C-23 July 24,1998
-------
4. For the changes that you have made to production processes, how important were the
following sources of information in finding out about alternative practices or technologies for
addressing any environmental issues in your work?
Were/Was-(READ ITEM) very important, somewhat important or not important at all as_a .
source of information about alternative-practices or technologies to address environmental
issues. . . , , '
; , . Very Somewhat Not Imp.
, ' - Imp. Important " At All -
Government employees 3 2 1
Consultants ' 32 1
. " ' '
Vendors and supptiers 3 2. . 1
Government publicati6ns 3 21'
Trade associations, publications or - 3 2,1
conferences .
j - Organizations providing assistance such as 3 2 1
universities or extension programs :
Customers
Other companies
Your company' s employees
the INTERNET
! "
Oth^r (SPFPTFV)
3
3 '
3
3
2
2
2
2
1
1
1.
l V
'
IF LESS THAN 20 EMPLOYEES FROM SAMPLE DATA, SKIP TO Q. 10.,
5. Nnw we'd like to know how your company evaluates information on
alternative practices or technologies for.addressing environmental issues. Do you usually .
write up a plan or memo or make a presentation to management for describing the changes
you are recommending and their pros and cons?
; YES ........:.......;...... ......;.,;,...... i
NO (SKIP TO Q.7) ,....,....: 2
. . DON'T KNOW (SKIP TO Q.7) ,.;... 8
P2 Motivation Survey . C-24 , ... July 24,1998
' " "-
-------
6. Were these evaluations conducted as part of, or to meet, the requirements of...
YES NO DK-
Total quality management or TQM 1 28
plans?
ISO9000? 1 2 8
ISO14000? 1 2 .8
Industry or trade association prograrns 1 2 8
Total cost accounting reports? 1 2 8
Material or chemical accounting reports? 1 28
Government-required pollution prevention 1 2 8
plans? - - '
7. What is the job title of the highest ranking person in the company who must
approve technical process changes when there is little or no investment involved?
CIRCLE ONE, DO NOT READ ENTIRE LIST UNLESS NECESSARY.
CHAIRMAN OF THE BOARD 1
PRESIDENT/CEO 1 .....:........... 2
"OWNER : 3
CHIEF FINANCIAL OFFICER/CFO 4
CORPORATE ATTORNEY/LAWYER 5
PLANT MANAGER -.'...' 6
PRESS OPERATOR/LINE SUPERVISOR /-.- 7
QC MANAGER ':.:;. -,. ' .- 8
OTHER (SPECIFY) ..'...: .96
P2 Motivation Survey C-25 July 24,1998
. . i j
</pre><hr><pre>
-------
,8. O*VEST>When there is a significant capital or operating investment is it-the same person?
YES (SKIP TO Q. 10) / ..:.... 1
NO .;.............!'...;;..::....'..._..".::...,,... ........,".......-..'...... ,.2
9. <SIGNOFF>Who has to sign off on or approve capital or operating investment decisions?
CIRCLE ONE, DO NOT READ ENTIRE LIST UNLESS NECESSARY.
CHAIRMAN OF THE BOARD . . .;. . . . ... .:........... .'. .... 1
PRESIDENT/CEO . .. v ... :-, . .2
OWNER .:....,......:... , 3
CHIEF FINANCIAL OFFICER/CFO ....:.....:.....,......,. 4
CORPORATE ATTORNEY/LAWYER '....... .- 5.
PLANT MANAGER ......'......... ..,. ....... : ,.......:....:...-... 6
PRESS OPERATOR/LINE SUPERVISOR , ,. :".... 7
'. QC MANAGER v..... 8
OTHER (SPECIFY) ........ j. ,...-. -96
P2 Motivation Survey C-26 July 24,1998
' '
</pre><hr><pre>
-------
10. We've gone over information sources and how you evaluated changes to your operations
related to environmental issues. Now we want to 'get an idea of what drove the Final decision.
I'm going to read a list of factors that could have influenced your final choice of equipment or
operations. Please tell me whether each was a strong influence on your fmaldecision,
Was/Were (READ ITEM) a strong influence on your final decision?
(ROTATE, EXCEPT "Production efficiency..." SHOULD ALWAYS BE LAST).
Government requirements<DECISIONA>
Advice from government employees<DECISIONB>
Availability of information on the particular practices
and technologies<DECISIONC>
Willingness and ability of employees to make
changes<DECISIOND>
Customer demands or willingness to accept changes
in products<DECISIONE>
' ' ' ' . . ' ' '
Availability of capital for process
changes<DECISIONF>
Cost of input materials<DECISIONG>
Cost of pollution control options or other compliance-
related costs<DECISIONH>
' Production efficiency or other benefits not related to
the environment<DECISIONI>
ES
1
1
1
1
1
1
1
1
NO
2
2.
2
2
.. 2
2
2
2
DON'T
KNOW
8 ,
8
,8
s:
' 8
8
8
8
8-.
SKIP TO QUESTION 12
P2 Motivation Survey
C-27
July 24,1998
'
</pre><hr><pre>
-------
\\. iiow influential are the following sources of information on environmental issues?
Is/Are (READ ITEM) very influential, somewhat influential, or very influential?
; -(ROTATE) , . ' , . ,. . - . , ' . .
i -..... Very Somewhat Not Inf.
. Inf. Influential At All
Government employees<INFLUNTA>
Consultants<INFLUNTB> .. '
Vendors and suppliers<INFLUNTC>
Government publieations<INFLUNTD>
Trade associations, publications or.
conferehces<INFLUNTE>
. Organizations providing assistance such as . ;
universities or extension programs<INFLUNTF>
Customers<INFLUNTG>
Other companies<INFLUNTH>
Your companies employees<INFLUNTI>
the INTERNEt<INFLUNTJ>
nthf-r (SPP^TT;iv) <n\TFT T TNTi;r>
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3
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P2 Motivation Survey G-28 July 24,1998
' ' '
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ALL RESPONDENTS SHOULD ADDRESS THE REMAINING QUESTIONS
« i' ' i' i : '' i i , ' "' 'l
12. <CONTACT>Now I have some questions about contacts your company may have had with
government agency employees regarding any aspect of your production operations. ,
In the past 2 years, have you been visited or contacted by someone enforcing regulations
such as inspectors from a regulatory agency such as EPA, OSHA or a state or local agency?
YES :. ..:......,.
NO .(SKIP TO Q.15) ..:
13. <HOWCON>How were you contacted READ LIST. MULTIPLE RESPONSE.
By telephone
Mail
III person at your facility
In person, outside your facility . .
' NO OTHER MENTIONS
Ml" , , , | ' , ' . , , ' , '
IF NO OR DON' T KNOW TO ALL ITEMS IN QUESTION 2, SKIP TO Q. 15.
14. <REGULAT>Earlier you identified changes to your production operations. Were any of
these changes made as a result of your contacts with regulatory enforcement personnel?
YES
NO .
15. <ASSIST>In the past 2 years, have you been visited or contacted by any organizations
providing assistance on environmental matters?
YES I......... ...... 1
NO (SKIP TO Q.25) - 2
P2 Motivation Survey , C-29 . July U, 1998
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. - - . .. ;
16. Do you know if they ;were from a... ' ' "'..''
.'.'- - YES NO DK
a.
regulatory agency<FROMA> .1 --2 .8
b. ' .government technical assistance office such as your 1 2 .8
state's technical assistance office or compliance .
assistance office<FROMB> .
c. ..' business assistance or development office such as a 1 2 -8
- Small Business Development Office or extension
service<FROMC> ' ' , .
d. university program<FROMD> . 1 28
IF NO OR DK TO ALL, SKIP TO Q.25
n.IFNQ.TOq.ie.a, SKIPTOQ.19.IF YES TO Q.16.a,... ;.
<INDIVID>How were you contacted by the individual from 'the regulatory agency providing
assistance? READ LIST. MULTIPLE RESPONSE ' . '
i . ' _ (
, BY TELEPHONE ." " ' '
MAIL ' " ' ; ..' . -. .
IN PERSON AT YOUR FACILITY ' '
IN PERSON, OUTSIDE YOUR FACILITY
NO OTHER MENTIONS ..
IF NO OR DON'T KNOW TO ALL ITEMS IN QUESTION 2, SKIP TO Q. 1 9.
1 8 . <CHANGES 1 >Were any of the changes you mentioned earlier made as a result of your
contacts with this organization? , , ,
YES ........ ......... .............'.... ........... . ... ----- ....;.......!
NO , ....... ;........................... ..... .......... .......... . ..... . . . 2
P2 Motivation Survey C-30 July 24.1998
''''' '
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19, IFNOTOQ.16.D. SKIP TO Q.21. IF YES TO Q.16.B,... ;
- " " . . ,i' ' i ! " ! i ,;' ' ' ' ' ' i ' '
<TECHNIC>How were you contacted by the individual from the government technical
: assistance or compliance assistance office? READ LIST. MULTIPLE RESPONSE. .
BY TELEPHONE ' " "
. ' MAIL ' ^ ' ' / " _ . '' , ', ' ' ''.
IN PERSON AT YOUR FACILITY
IN PERSON, OUTSIDE YOUR FACILITY
NO OTHER MENTION .
IF NO OR DON'T KNOW TO ALL ITEMS IN QUESTION 2, SKIP TO Q.21. '
20. <CHANGES2>Were any of the changes you mentioned earlier made as a result of your .
contacts with this organization?
YES
HO .
21. IF NO TO Q.16.C, SKIP TO Q.23, IF YES TO Q.16.C,...
<BUSINESS>How were you contacted by the individual from the business assistance,
development office or extension service? READ LIST. MULTIPLE RESPONSE
BY TELEPHONE
MAIL
IN PERSON AT YOUR FACILITY .
IN PERSON, OUTSIDE YOUR FACILITY
NO OTHER MENTION
IF NO OR DON'T KNOW TO ALL ITEMS IN QUESTION 2, SKIP TO Q.23
22. <CHANGES3>Were any of the changes you mentioned earlier made as a result of your
contacts with this organization? .
YES ..................... . ...... .- ....... .:.... ............ ....'.... ..... 1
NO ............ ............... . ....... ........... ........... :....:.. 2
P2 Motivation Survey C-31 . July 24.1998
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23. IF NO TO Q.16.d, SKIP TO Q.25, IF YES TO Q.16.d,...
.' <UNIVERSE>How were you contacted by the individual from the university program?
READ LIST. MULTIPLE RESPONSE. ' ;"
BY TELEPHONE . .
MAIL
IN PERSON AT YOUR FACILITY
IN PERSON, OUTSIDE YOUR FACILITY
NO OTHER MENTION , . .
IF NO OR DON'T KNOW TO ALL ITEMS IN QUESTION 2, SKIP TO Q.25 ,
24. <CHANGES4>Were any of the changes you mentioned earlier made as a result of your
contacts with this organization? .
YES .-'..:......: .' 1
NO ........................... v. 2
Finally, I have a couple of questions for background purposes only.
25. <PERSONEL>How many production personnel work on an average shift?
26. <JOBTITLE>What is your job title? _
27. <STRENGTH>In terms of competiveness and financial strength, do you feel that your
company is stronger, about the same, or less strong than it was two years ago?
_-STRONGER
_ ABOUT THE SAME . -
_ LESS STRONG .....-
_ DON'T KNOW : "
28. <YEARS>How many years have you been in your current position?
Those are all the questions that I have. Thank you very much for your time.
P2 Motivation Survey C-32 July 24,1998
'
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