SPA/60.0/J-93/452
Industrial Pollution Prevention!
A Critical Review
Harry Freeman, Teresa Marten, Johnny Springer, Paul Randall,
Mary Ann Curran and Kenneth Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
' . Cincinnati, Ohio
"An. ounce of prevention is worth a pound of cure." Trite? Maybe, but 'this proverb is
coming to be increasingly recognized as>a rallying cry for:U.S. environmental prograirs.
The Administrator of the U.S. EPA has stated, "A new sense of urgency and resolve to
improve the quality of the environment has taken root in our country., Despite the
complexity of the environmental challenge—or perhaps because of it—we are falling back
on some simple and common sense ideas. .One of them is pollution prevention." The U.S.
Congress passed the Pollution Prevention Act in October 1990. Pollution prevention is
clearly a concept that will ;be of increasing importance to U. S. companies and.to the public
agencies that are responsible for regulating those companies. In this critical review the
authors present the current state of knowledge regarding pollution prevention approaches
to environmental improvement, explore the state of development.of various private and
public approaches to encouraging the adoption of pollution prevention strategies, highlight
selected clean technologies and clean products, and examine various technical and
economic! issues related to the concept of pollution prevention. < ' .
Upon being invited by ike A& WMA to present this critical
•review of the literature published over the past four years.
We began compiling copies of papers, articles, reports, and
books to determine where we have been and where we are
going with pollution prevention in the U.S. We looked for
'important contributions to the developing body of informa-
tion on the subject. We stopped at 472 such sources,
recognizing that our first conclusion was that there has been
an awful lot written on the subject in just the last few years.
We believe that this phenomena reflects that the pollution
prevention mind-$et is being incorporated, into more and
more traditional technology and policy publications and
literature. In the interest of being able to complete the task in
the time provided, we decided to limit the review to pollu-
tion prevention in the industrial sector. This should not be
interpreted to mean that we believe this is the only sector in
which pollution prevention is appropriate. Instead we be-
lieve it should be highlighted because this sector is the one of
most interest to members of the Association.
Industrial pollution prevention is many things to many
people and covers a very broad spectrum. We have struc-
tured this review to provide coverage of those elements of the
spectrum that we believe are important: Our conclusions are
summarized in a section near the end of the review. We hope
you find our review and our list of references useful.
The Authors
618
EPA Administrator Reilly has stated that one "of his four
priority themes at the EPA is'pollution prevention and that
treatment and disposal of wastes is not enough; pollutants
must be prevented firom being generated in the first place.
"We have learned the inherent limitations1 of treating and
burying wastes. A "problem solved in one part of the
environment may become a new problem in another part.
We must curtail pollution closer to its point of origin so that
it is not transferred from place to place. We must consider
the full range of prevention options—from greater energy
efficiency to stronger incentives for producing less harmful
substances to expanded recycling to natural resource conser-
vation. Pollution prevention means a massive change in
America's habits of waste generation and disposal, as well
as other changes in our production and consumption
practices that must become second nature to all of us."l
Redirecting our environmental improvement efforts from
an end-of-the-pipe focus to one that strives to eliminate
pollutants at the source is an important change that
individuals other than Administrator Reilly support. '
The EPA Science Advisory Board (SAB), an independent
group of distinguished scientists and 'academicians, stated
in a 1988 document that "EPA should shift the focus of its
environmental protection strategy from end-of-the-pipe
controls to preventing the generation of pollution"2 and
followed with ^the observations that many "of the most
serious environmental problems facing this country will not
be solved through the use of end-of-pipe controls alone. In
some cases, like ground-level ozone, end-of-pipe controls
J. Air Waste Manage. Assoc,
-------
have already been applied, but more needs to be done. In
some cases, like indoor air pollution, end-of-pipe controls
simply are not appropriate or practically feasible. And in
some cases, like hazardous waste disposal, end-of-pipe
controls are becoming more and more expensive. The SAB
notes that if we hope to protect the environment and
human health from environmental problems like strato-
spheric ozone depletion, hazardous wastes, and surface
water and estuarine pollution, we have to begin controlling
pollution long before it reaches the end of the pipe. We have
to prevent pollution at the source.2 • •
' President Bush, in an October 1990 address, said "Envi-
ronmental programs that focus on the end of the pipe or the
top of the stack, on cleaning up after the damage is done,
are no longer adequate. We need new policies, technologies,
and processes that prevent or minimize pollution—that
stop it from being created in the first place."3 In consider-
ing the question from a more global viewpoint, Frosch and
Gallopoulos* note that people create new technologies and
industries to meet human needs more effectively and at
lower cost but these technologies may have unexpected side
effects which may today have global impacts (i.e., the case of
chlorinated fluorocarbons). Even though such technologies
have undoubtedly improved the quality of life for many
people, leading to better standards of living in many parts of
the world than they were even 20 or 30 years ago, there is a
need for new production technologies to produce a similar
quality of life with less waste. "There is no other side of
town where the modern equivalent of tanneries can be put,
no open space beyond the valley gates where garbage can be
dumped and no harm done.'M The fact that by the year
2030, 10 billion people are likely to live on this planet
should be an incentive for us to emphasize products,
processes, and materials of production that are more envi- .
ronmentally friendly. There is a need to establish an
industrial ecosystem that functions similarly to biological
ecosystems in which systems work synergistically to opti-
mize energy and minimize wastes.4
Deland reports that at least in the U.S. there is not a
linkage between economic development and environmental
degradation. Since 1970', while America's population grew
22 percent and our gross national product expanded nearly
75 percent, energy use, thanks to investments in energy
conservation and efficiency, rose, less than 10 percent.
During this period of social growth, levels of airborne lead,
soot, carbon monoxide, and sulfur dioxide dropped sharply
and other emissions leveled off. Our rivers and streams,
several of which were literally aflame in the 1970s, were
rendered largely fishable and swimmabk. Studies of the
United States and other nations found the net economic
effect of stronger environmental laws to be small. In short,
one of the great achievements of the past 20 years was to
demonstrate that a growing economy and a clean, safe
environment are not incompatible. They can— indeed they
must—go hand-in-hand. He further states that programs
must continue. "The time has come for a new course to
emphasize pollution prevention not pollution control."5
1 Terminology
The EPA defines pollution prevention as "the use of
materials, processes, or practices that reduce or eliminate
the creation of pollutants or wastes at the source. It
includes practices that reduce the use of hazardous materi-
als, energy, water, or other resources and practices that
protect natural resources through conservation or more
efficient use."6 The idea underlying the promotion of
pollution prevention is that it makes far more sense for a
generator not to produce waste than to develop extensive
treatment schemes to insure that-the waste poses no threat
to the quality of the environment." For the purpose of this
review the authors use the EPA definition of pollution
prevention which does not include off-site recycling as
pollution prevention. It should be noted that not including
recycling in the definition is not meant to imply that it is not
worthwhile or that it should not be actively encouraged. It
is clearly preferable to many other waste management and
disposal options and contributes to establishing the same
sustainable society for which a pollution prevention pro-
gram is designed. The shorthand term for pollution preven-
tion, "P2," is used at times in this review in keeping with
the P2 spirit of conserving ink and paper.
While "pollution prevention" is coming to be the most
widely accepted term in the U.S. for such strategies and
processes, there are other similar terms that have been
used in the past and are to varying degrees still in use in the
U.S. and elsewhere. Van Weenen compiled the exhaustive
list of similar terms shown in Table I.8
Waste Minimization (WM). WM is defined by the EPA as
the reduction, to the extent feasible, of hazardous waste
that is generated or subsequently treated, sorted, or dis-
posed. It includes any source reduction or recycling activity
undertaken by a generator that results in either (1) the
reduction of total volume or quantity of hazardous waste,
or (2) the reduction of toxicity of hazardous waste, or both,
so long as such reduction is consistent with the goal of
minimizing recent and future threats to human health and
the environment.9
It should be noted that WM specifically includes recycling
and though the Agency encourages the minimization of all
wastes as opposed to just RCRA hazardous wastes, it is
primarily a hazardous waste related term. Consequently,
its usefulness as a broad term to describe multimedia waste
Table I. Van Weenen's. waste reduction terms.
Organization, Polity *
Strategy; management; research; procedures; activities:"
—"Reflection"
—Anticipate-and-prevent strategies
—Avoidance Strategy
—Front-end resource management
—Waste prevention research
—Product assessment procedure
—Preventative activities
—Humane chemistry
—Source reduction
—Source control -»; ..-^
Technology • ' ; '«'
Technology, technological " '•
' —New technologies , ' , •
—Environmental technology ' .
—Prevention aimed enviromental technology
—Process integrated environmental technology
—Appropriate technology
—Clean technologies
-^-Cleaner technologies
• —Non-waste technology
—Low- and non-waste technologies
—Low-waste technology
—Low-polluting technology
—Pollution control technology
—And-on technologies
—End-of-pipe technologies
—Recycling technologies
—Waste treatment technologies
—Purification treatment
—Cleaning up technology
Waste, Pollution
Prevention; avoidance; minimization; reduction:
—Waste prevention
—Waste avoidance
—Waste minimiation
—Waste reduction
—Pollution prevention
—Pollution reduction
—Recycling
May 1992
Volume 42. No. 5
619
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stream reduction has been seen as limited. Also, the term
has been criticized by some as not being sufficiently focused
on source reduction because it included recycling tech-
niques.10 This criticism is succinctly stated as, "the most
serious problem is that any definition that includes waste
management including waste treatment and recycling away
from the products site, will probably divert attention away
from the goal of waste reduction. The broadly accepted goal
of minimizing the amount of hazardous waste put into the
land should not obscure the even more fundamental good of
reducing the generation of hazardous waste."
Since the reduction of RCRA hazardous waste a.ap
increasingly important part of: the EPA's enforcement of
RCRA and since the term, WM, is often used by the Agency
in that context, it will continue to be a part of the language
of pollution prevention. In the current RCRA biennial
report, a report required of all hazardous waste generators,
waste minimization refers to source reduction and recycling
activities, and excludes treatment and energy recovery, \
Although there is a trend in the U.S. to accepting
"pollution prevention" and its EPA definition as the norm
for the' movement, that there is still a problem is illustrated
by the fact that names chosen by the states to describe their
agencies work in the field include 14 with pollution prevenr
tion in the title, 11 with waste reduction in the title, and 7
with waste minimization in the title.12 '
Pojasek notes "it is easy to get the impression that there
is a distinct battle going on between those who use the
terms 'waste minimization' and 'waste reduction . He
, sees the question of definitions as one of progression, not
unlike other staged evolution of terms. Waste minimization
is seen as often one dimensional in that its primary focus is
most often on regulated hazardous wastes. "Waste
reduction" involves a much more direct measure to prevent
waste discharges to any media-at the source. Pollution
prevention is the term that broadens the concept to include
products as well as processes.13 An entirely different perspec-
tive on the question of-terms is presented by Butner.
"Waste min.has two syllables, pollution prevention has six.
Let's practice what we preach." '
"Beyond the many technical issues contained within the
pollution prevention concept, there is one that involves the
psychological side. While it may seem noble to many to
prevent the release of pollutants, nevertheless, the phrase
is full of the negative and associated •with the idea of
preventing, stopping, or holding back something. This does
not sit well in a go-get-em kind of a society. The focus really
should not be on "don't do," but on "do better, more wisely,
more cleverly, more efficiently-," more eloquently." As such,
the concept begs for a more positive name. Sustainable
growth or sustainable development seem to be on the right
track, but a really dynamic representation, one that belongs
in the twenty-first century, is needed." u
That this debate about terminology has gone on too long
is illustrated by Dr. Larry Ross in reviewing the manuscript
"for this review. Dr Ross states "enough already; should
move as much of this section to an Appendix where scholars
some time in the 21st century can ponder what the big deal
was." Dr. Ross proposes that regardless of the term chosen
that it reflect a results-oriented rather than a process-
oriented approach. "An excellent contender might be de-
fining pollution prevention as activities that have the
potential to transform industry from material intensive,
high throughput processes to systems that use fuel and raw
materials highly efficiently, .rely on inputs with low environ-
mental costs, generate little or no waste,.recycle residuals,
and release only benign effluents."15 ,
Benefits of Pollution Prevention
Answering the question, "Why should you'undertake
' pollution prevention," in a manual to help the generator
make cost comparisons'on the basis of costs and benefits of
pollution prevention, the authors of EPA's Pollution Pre-
vention Benefits'Manual state, "Pollution.prevention can
help you achieve the following:16 .
• Improve your firm's "bottom line." :
•'•!'- Make compliance with environmental regulations eas-.
ier. -i
. Demonstrate a proactive commitment to genuinely pur-
suing a pollution prevention program. * '
P2 is a compelling strategy for many .reasons. If no pollu-
tion is generated, there are no pollutants to be managed.
Thus, future problems are avoided, such as the problems
which occur when previously accepted land disposal meth-
ods are discovered to be major sources of .environmental
contamination. Preventing pollution before it occurs also
prevents situations that not only might endanger members
of-the community, but workers involved in the manage-
ment of pollution as well.11
One of the significant benefits of P2 is that it is often an
economical approach. When wastes are reduced or elimi-
nated, cost savings in materials result and more products
are produced from the same starting materials. The close
examination of manufacturing processes needed to plan a
successful pollution prevention approach can produce a
number of side-benefits as well, such as significant improve-
ments in energy and water conservation, and improved, or
more consistent, product quality. . .
P2 can also lead to large savings in regulatory and
compliance costs, which are lowered as less pollution is
produced. Frequently, the dominant cost savings come
from reduced future liability, for the pollution. Ever since
passage of the federal Resource Conservation and Recovery
Act with its mandate/that manufacturers have "cradle to
grave" responsibility-Tor the wastes that they generate, and
enactment of the joint and several liability provisions of the
federal Comprehensive. Environmental Response, Compen-
sation, and Liability Act (better known as Superfund),
waste producers have been subject to the possibility of
unlimited liability for any harm caused by their wastes.
This liability includes even future problems caused by
wastes managed using the best, current practices. Because •
waste site cleanups can cost hundreds of millions of dollars
each, these liabilities can dwarf all other costs associated
with waste generation, which makes pollution prevention
even more compelling. • • „„_ ' ,v i- 'i j
The environmental advantages of P2 approaches include
improving effectiveness, minimizing uncertainty, avoiding
cross-media transfers, and protecting resources. These are
detailed below.11.
In a dissenting view on the idea that clean development is
preferable; for everyone, even the poor, the Economist,
while recognizing that environmental policy is immensely
complicated notes the greatest cause of misery in the third
world is poverty. "This must guide the priorities of poor-
country governments and aid donors alike. If clean growth
means slower growth, as it sometimes will, its human cost
will be lives blighted by a poverty that would otherwise have
been mitigated. That is why it would be wrong for the World
Bank or anybody else to insist upon rich-country standards
of environmental protection in developing countries. Often,
policies that favor growth (such as setting world-market
prices for energy and other resources) will lead to a cleaner
environment, too; such policies should be vigorously pro-
moted But when a trade-off between cleaner air and less
poverty has to be faced, most poor counties will rightly want
to tolerate more pollution than rich countries do,,in return
for more growth. So the migration of industries, including
"dirty" industries, to the third world is indeed desirable.
Not because life there is cheap; if anything, for the opposite
reason Those who insist on "clean growth everywhere
mun either deny that there is ever a trade-off between
growth and pollution control—or else argue that imposing
.) Air Waste Manaoe. Assoc
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rich-country standards for clean aar worldwide matters
more than helping millions of people in the third world to
"escape their poverty t7
Public Pollution Prevention Programs
Federal Activities
The Congressional Office of Technology Assessment,, in
pointing out that federal government environmental pro-
grams continue to be misdirected, concluded, "although
there are many environmental and economic benefits to
waste reduction, over 99 percent of federal and state
environmental spendmg is devoted to controlling pollution
after waste is generated. Less than one percent is spent to
reduce the generation of waste, "6
Although elements of the strategies and technologies
that are now coming to be denned as pollution prevention
have been present in other media activities, the seeds for
the current pollution prevention movement in the U.S. are
more prominent in the Resource Conservation and Recov-
ery Act, the federal law for regulating the management and
disposal of solid and hazardous wastes in the U.S.
The U.S. Congress specifically stated in the 1984 Hazard-
ous and Solid Waste Amendments to the Resource Conser-
vation and Recovery Act: "The Congress hereby declares it
to be the national policy of the United States that, wherever
feasible, the generation of hazardous waste is to be reduced
or eliminated as expeditiously as possible. Waste that is
nevertheless generated should be treated, stored, or dis-
posed of so as to minimize the present and future threat to
human health and the environment."7
'Other organizations, including the U.S. Congressional
Office of Technology Assessment, the National Academy of
Sciences, the EPA's Science Advisory Board, tha Environ-
mental Defense Fund, and the Natural Resources Defense
Council have issued strong statements in support of pro-
grams to encourage the development and adoption of waste
minimization strategies. The EPA's position on the subject
was succinctly detailed in its 1986 Report to Congress:
"E.PA still has much to learn about waste minimization
and recognizes that the cooperation of private and public
waste generators will be invaluable as it moves'"toward-the
development of sound long term policy. It also believes,
however, that the incentives and trends within the hazard-
ous waste management system are unmistakable, and that
the program presented here comprises the most positive
and constructive steps that can be taken at this time
Aggressive action in favor of waste minimization is clearly
needed, but a major new regulatory program—at least for
the present—does not seem desirable or feasible.
"Incentives of waste minimization are already strong, so
EPA must capitalize on them. Most lacking is access by
generators'to the information that will demonstrate the
economic benefits of waste minimization to industry, over-
come logistical problems, and help develop creative new
approaches. This can be provided by a strong technical
assistance and information transfer effort, which can achieve
through voluntary means what would be inefficient and
possibly counterproductive to attempt through regulation.
Unfortunately, non-regulatory programs have often failed
at EPA for lack of statutory or regulatory deadlines and
institutional advocacy, For such a program to work, it must
be given strong organizational support within the Agency.
EPA is willing to make this commitment, and seeks support
from Congre&s to ensure its success.1'"1
The federal government influences the development and
adoption of pollution prevention strategic^ and technolo-
gies m three ways. Fir^t as a policy maker, the federal
government ha? the regulatory authority to promote pollu-
Mayl992
Volume 42, No 5
tion prevention in the private sector Second, as the actual
.operator of many manufacturing facilities and other public
facilities such as national parks and large office complexes,
the U.S. government can reduce the generation'of pollu-
tion. Third, as a consumer and large purchaser of products
and services it can influence and create markets for environ-
mentally sound products and technologies.'1
The major federal agencies involved in industrial pollu-
tion prevention are the U.S. EPA, the Department of
Defense, and the Department of Energy. However, as the
pollution prevention ethic is-incorporated into all of the
nation's organizations, other federal agencies are also
becoming involved.
Commoner, in endorsing the EPA's pollution prevention
policy statement (January 1989) notes that the evidence of
present control programs demands a shift to the new
"preventative policy." He urges the Agency to refocus its
thinking towards P2. He cites an example of the Agency's
not doing this as the Administrator's decision not to require
source separation for a proposed incinerator in Spokarie.19
Commoner also points out that the government could
create massive demands for P2 technologies through speci-
fying smog free engines in the $5 billion of vehicles it
pu rchases annually.19
Irwin states that the institutional capacity of the govern-
ment to protect the environment might be greatly enhanced
by a "better law." The Conservation Foundation has .
drafted a law that combines elements for, all federal environ-
mental laws to deal with all forms of pollution from a multi
media perspective. Highlights from the proposed law are:20
« A Cabinet-level Department of Environmental Protec-
tion, organized by function and with a single mission: to
improve the overall quality of the environment as effec-
tively and efficiently as po/sible.
• One primary standard (prevention of unreasonable risk)
for taking environmental action, regardless of the source
of the pollutant or the location into which it is dis-
charged.
• A shift from media-specific concerns (e.g., air, water,
solid waste) to a broader focus on releases to all media
from the four types of sources: mobile sources, point
sources, nonpoint sources, and substances and articles.
• A comprehensive, integrated system for regulating sub- •
stances including new and existing pesticides and other'
' chemicals. . ..». ,£•-•.'
• A single-permit system governing permissible releases of
pollutants, to all parts .of the environment for major ,1 ,>,
'facilities. .-' • ?
• No permit issued unless the applicant uses, to the
" maximum extent practical, available methods for reduc-
ing total releases to the environment.
• Integrated grant assistance to state and local govern-
ments to help deal with cross-media environmental .
problems.
Speth suggests that an EPA organized along sector-based
lines such as transportation, manufacturing, housing, en-
ergy, and agriculture might be better equipped to bring
about the technological change needed for a P2 revolution
than an agency organized as it currently is along media
lines, i.e., air pollution, water pollution, etc. He persua-
sively notes, "In the future, EPA must come 'inside,' and
environmental factors must be integrated into the basic
design of our transportation, energy, and other syste'ms. A
new type of cooperation among the private sector, EPA,
traditional Cabinet agencies, and environmental advocates
must be formed. Together, we must work upstream to
change the products, processes, policies, and pressures that
give rise to pollution."21
It is useful to note that some authors are critical of the
pa>t and current role of government as a participant in the
pollution prevention scene. Hirschhorn and Oldenburg
note, "in the new environmental sti'uggle. the role of
621
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government; V\as become more often questioned, particu-
larly in the United States, which has emphasized the heavy
hand of government regulation. The traditional methods of
waste management and pollution control have been increas-
ingly regulated by government! In 1985 there were about
7,000 pages of federal environmental laws and regulations;
by 1988 there were 10,000 pages. More than any other
nation, the United States has used government end-of-pipe
regulation embedded in a complex web of legal rules and
procedures to try to achieve environmental objectives, It is
inevitable that more and more pollution control regulations
will be created. Other nations rely more on cooperation
between government and industry to achieve national
environmental goals. But the U.S. regulatory effort has
revealed the limitations of its strategy as much as its
achievements. Government regulatory programs are plagued
'by problems of noncompliance, litigation, loopholes, and
slow implementation that are continually revealed, by the
press and environmental organizations."
The authors further state, "clearly, public lack of confi-
dence in government programs in the U.S. and other
nations has been a, political force in stimulating the new .
green and grassroots environmental movement.22
Pollution Prevention Act of 199013
• In the fall of 1990the'U.S. Congress passed the Pollution
Prevention Act of 1990. As stated in the Act national policy
is: ' . " . • .
• The Congress hereby declares it to be the national policy
of the United States that pollution should be prevented or
reduced at the source whenever feasible; pollution that
cannot be prevented should be .recycled in an environmen-
tally safe manner, whenever feasible; and disposal or other
release into the environment should be employed only as a ,
last resort and should be conducted in an environmentally
safe manner.
, The Act directs the Agency to:
• Establish standard methods of measurement of source
reduction. • .
'• Ensure that the Agency considers the effect of its
.existing and proposed programs on source reduction
efforts and shall review regulations of the Agency prior.
and subsequent to their proposal to determine their
effect on source reduction.
• Coordinate source reduction activities in each Agency
Office and coordinate with appropriate offices to promote
' source reduction practices in other federal agencies, and
generic research and development on techniques and
processes which have broad applicability.
• Develop improved methods of coordinating, streamlin-
ing and assuring public access to data collected under
federal environmental statutes.
• Facilitate the adoption of source reduction techniques by
businesses. This strategy shall include the "use of the
Source' Reduction Clearinghouse and state matching
grants provided in this subtitle to foster the exchange of
information regarding source reduction techniques, the
dissemination of such information to businesses, and the
provision of technical assistance to businesses. The
strategy shall also consider the ca'pabilities of various .
businesses to make use of source reduction techniques.
• Identify, where appropriate, measurable goals which
reflect the'policy of this subtitle, the tasks necessary to
achieve the goals, dates at which the principal tasks are
to be accomplished, required resources, organizational
responsibilities, and the means by which progress in
meeting, the goals will be measured.
'•'• Establish an advisory, panel of-technical experts com-
prised of representatives from industry, the states, and
public interest groups, to advise the Administrator on
ways to improve collection and dissemination of data.
• Establish a training program on source reduction oppor-
tunities, including workshops and guidance'documents,
for state and federal permit issuance/enforcement. and
inspection officials working within agency program of-
;, fices. ' . .
• Identify and make recommendations to Congress to
'••"- eliminate barriers to source reduction including the use
of incentives and disincentives. . .
• Identify opportunities to use federal procurement to
encourage source reduction.
• Develop, test and disseminate model source reduction
auditing procedures designed to highlight source reduc-
tion opportunities.
• Establish an annual award program to recognize a
company or companies which operate outstanding or
innovative source reduction programs.
The Act further directs the Agency to establish, a state
grants program and to establish a Source Reduction Clear-
inghouse to facilitate the transfer of poEution prevention
information. An important part of the Act is a requirement
that all generators who are required to file an annual toxic
chemical release form under Section 313 of the Superfund
Amendment and Rcauthorization Act of 1986 (SARA) must
include with that filing a "toxic chemical source reduction
and recycling report for the preceding calendar year."23
These reports should enable the EPA to better identify the
level of pollution prevention taking place and to identify
areas that might benefit from increased attention. <
Finally, the EPA is directed to provide biennial reports to
the- Congress on the status of activities undertaken to
implement its strategy to promote pollution prevention.23'
Clean Air/kct Amendment of 199024
The federal Clean Air Act was amended in 1990. The
Amendments, ..with over 750 pages of text, incorporate
innovative strategies and a preventive approach to tackle
some of the most serious air pollution problems, including
toxic air emissions, acid .rain, urban smog, and strato-
spheric ozone depletion.
Unlike earlier versions of the Clean Air Act, the 1990
Amendments mention "pollution prevention" in a number
of places. The Amendments add a primary goal to the Clean
Air Act "to encourage or otherwise promote reasonable
federal, state, and local government actions, .consistent
with the provisions of this Act, for pollution prevention."
The Amendments also require that EPA "conduct a basic
engineering research and technology program to develop,
evaluate, and demonstrate nonregulatory strategies and
technologies for air pollution prevention." The Amend-
ments encourage pollution prevention in other ways. Title.I
requires promulgation of Best Available Controls for vola-
tile organics in consumer and commercial products, defined
as '.'.. .the degree of emissions reduction that the Adminis-
trator determines. . . is achievable through the application
of the most effective equipment, measures, processes, meth-
' ods, systems or techniques, including chemical reformula-
tion, product or feedstock substitution, repackaging, and
directions for use, • consumption, storage and disposal."
Several of these are P2 approaches; Title II of the Amend-
ments addresses provisions relating to mobile sources,
including sale of cleaner burning reformulated gasoline in
the most smog-ridden cities beginning in 1995. Title III
requires EPA to promulgate Maximum Available Control
Technology (MACT) standards, for Hazardous Air Pollut-
ants that ".:.. require the maximum degree of reduction in
emissions..'. through application of measures... including
measures which (A) reduce the volume of, or eliminate
emissions of, such pollutants through process changes,
substitution of materials or other modifications. . ." Title
IV establishes a system of buying and.selling allowances for
622
J. Air Waste Manage. Assoc.
-------
elusion fiiated :o acid rain content that give utilities an
.nwntive 'a pursue pollution prevention strategies to re-
due* emissions Title VI requires EPA to prepare a report
to Congress identifying sources of methane emissions, and
activities, substances, and processes that could reduce
methane emissions and that are economically and technolog-
ically justified,-''
Finally, the Amendments require that production of
chlorofluorocarbons CFCsi and haJons be phased out
beginning in two years and that EPA ban the use of unsafe
substitutes for these chemicals,11
U.S. Environmental Protection Agency
On January 26. 1989. EPA published a draft Pollution
Prevention Policy Statement (54 FR 3845) in the Federal
Register While the Agency had been previously using
source reduction as a key element in some of its programs,
this Policy Statement clearly established source reduction
as a preferred option for organizations, facilities, and
individuals. In fact, the term "pollution prevention" was
officially used by the Agency for the first time in this
document. Previously, the term "waste minimization" had
been used to describe efforts associated with the hazardous
waste program, but the phrase substitution was made in
order to emphasize the applicability of a polluf ion preven-
tion approach to a wide range of programs. In addressing
any given environmental problem, pollution prevention is
to be considered the approach of first choice.l:
Further policy guidance was provided by the National
Advisory Committee for Environmental Technology Trans-
fer, In its 1990 report, the Committee recommended pollu-
tion prevention as the alternative to an end-of-pipe philoso-
phy, The Agency's "The Solid Waste Dilemma: An Agenda
for Action" report published in 1989 recommends using an
integrated waste management approach which has source
reduction as its most preferable element for reducing the
municipal solid waste problem. The strategy further states
that one of the Agency's goals was to manage 25 percent of
the nation's municipal solid waste through source reduc-
tion and recycling by 1992.25
The strategy states: "This Pollution Prevention Strategy is
not -an attempt to either expand or supersede existing
authorities and programs. EPA will continue to proceed
with regulation development, permitting, and enforcement.
and its other responsibilities as required by law. The
Pollution Prevention Strategy will help the Agency to
reorient its use of authorities to give preference to -cost-
effective and environmentally protective prevention ap-
proaches, in addition to recycling, traditional treatment,
and disposal."'-6
To date, in implementing its pollution prevention strat-
egy, the Agency has:
• Established an Office of Pollution Prevention to coordi-
nate the Agency's P2 activities in all of the media and
regional offices.
• Established the American Institute for Pollution Preven-
- tion through a cooperative agreement with the Univer-
sity of Cincinnati to support the Agency's pollution
prevention program. Institute members% are volunteers
from industry and academia with expertise in pollution
prevention.
• Established the Pollution Prevention Information Clear-
inghouse. The Clearinghouse disseminates pollution pre-
vention information to federal, state, local and interna-
tional government; industry and trade associations:
public and private institutes; public interest groups; and
academia. The Clearinghouse also provides access to
pollution prevention information in other countries. It
does this-through its sister system, the International
Cleaner Production Information Clearinghouse, which
is cosponsored by the United Nations Environment
Program and EPA. Access to PPIC services is available
by calling one of its telephone hotlines, or through its
computerized informatidri /etwork. [Note: Readers may
obtain information about'the Clearinghouse by calling
(703)821-4800.]
• Established a special program to support pollution pre-
vention projects throughout the Agency. This program
was funded by setting aside two percent of the Agency's
FY 91 and 92 budgets. Examples of the projects receiving
support are listed in Table II. •
EPA Pollution Prevention Strategy
In February 1991, EPA issued a Pollution Prevention
Strategy »56 FR 7849) which clarifies its pollution preven-
tion position and the Agency's objectives in this area.26 The
strategy is designed to serve two purposes: (1) to provide
guidance and direction for efforts to incorporate pollution
prevention within EPA's existing regulatory and non- .
regulatory programs, and (2) to set forth a program that
will achieve specific objectives in pollution prevention within.
a reasonable time frame.
Regarding the first objective. EPA believes that in order
for pollution prevention to succeed, it must become a key
component of the Agency's primary mission of protecting
human health and the environment. To achieve this, the
Agency's goal is to incorporate pollution prevention into
every facet, including enforcement actions, regulations,
permits, and research and development.
To address the second objective. EPA has implemented
the 33 50 Program, which is discussed elsewhere in this
review,
In the strategy that EPA states as its specific goals is to:
* Investigate and. where possible, eliminate barriers to
cost-effective investments in prevention in existing and
new regulatory programs.
• Encourage voluntary actions by industry that reduce the
ntt?d for EPA to take action under statutes like the Toxic
Substances Control Act.
Table II. Examples of the 2 percent set-aside projects to
promote national pollution prevention.
Pollution Prevention
By and- For Small
Businesses
Demonstration of
Volatile Organic
Chemicals Area
Source Prevention
Options
Promoting Pollution
Prevention in
Enforcement
Settlements
Lead Pollution
Prevention
Consumer Product
Comparative Risk:
Market-Based"
Pollution
Prevention
Provide awards of $25,000 each to
small businesses to demonstrate
innovative approaches to pollution
prevention.
Cooperative ventures with industry to
identify, develop, and demonstrate
prevention techniques that reduce
VOC emissions from area sources.
Will include demonstrating the
viability of reducing VOC emissions
through alternative coating materials
and processes.
Use enforceable agreements to commit
violators to undertake appropriate
source reduction or recycling '
activities.
Reduce human exposures to lead via a
comprehensive program to eliminate
or reduce further additions of lead to
the environment. Program will
encourage the use of lead substitutes
and explore the use of regulatory
authorities to discourage the mining
of lead.
Develop a methodology to
comprehensively evaluate the
, environmental consequences of
consumer products throughout all
phases of the products' life-cycle
May 1992
Volume 42 No 5
623
-------
. Devised a strategy for reducing lead exposures for che
population The lead pollution prevention program in- ,
eludes exploring market-based .incentives to, restrict,
eliminate lead use; using regulatory legislation (£uch as
the Toxic Substances Control Act, or TSCA) to,,reduce
.lead in current and future products; and. identifying and
encouraging the use of cleaner technologies for'mimng,
smelting, and processing lead.
Established the "Pulp and Paper Cluster' to address the
multimedia pollution problems associated with the pulp,
. paper and paperboard industry. The primary goal of the
Cluster is to ensure that EPA documents regulating and
guiding this industry are oriented towards pollution
prevention.
Initiated the 33/50 program, a program to encourage
those industries reporting toxic releases under the lox-
ics Release Inventory to voluntarily reduce their emis-
sion rates for 17 selected chemicals. This.program is
reviewed elsewhere in this article. . \
Continued to pursue pollution prevention strategies'
through enforcement of environmental regulations.
> Continued to consider pollution prevention options un-
der the authority granted to it by the Federal. Insecticide,
Fungicide and Rodenticide Act (FIFRA) and the Toxic
•Substance Control>Act (TSCA). Under FIFRA, since
1985 over 3Q chemicals have been canceled or restricted.
Under TSCA. more than 10 percent of all new chemicals
proposed for manufacture over the last 12 years have
been banned, restricted, or withdrawn from manufac-
•' ture or use. ' .
• Developed a policy statement that states pollution preven-
tion (along with recycling) is to be encouraged "as a
means of achieving and maintaining statutory and regu-
latory compliance and of correcting outstanding viola-
tions when negotiating enforcement settlements," Some .
examples of recent enforcement settlements that incor-
porate pollution prevention considerations are shown in
Table III.- ' . . •
• Established a pollution prevention research program.
within the Office of Research and Development which is
currently supporting the development, evaluation, and
demonstration of clean products and clean technologies
through cooperative arrangements with many states
and universities.27 ,
Table III. Three 1990 pollution prevention enforcement
. settlements. -
1 Sherex Polymers (Lakeland, FL) agreed to pay a fine of
; $252iOOO for failing to filea TSCA Premanufacture No-
tice for a new chemical. This fine would have been
$42,000 higher if EPA had not reduced it in exchange for ,
Sherex's agreement to install equipment within 12
months that would-reduce existing filter cake waste by
500.000 pounds per year and would increase in-process
recycling of the fatty acids by approximately 250,000
pounds per year. '
2 3-V Chemical i Charlotte, NO violated TSCA by import-
ing a chemical that was subject to a testing requirement
without making arrangements to test the chemical. EPA
agreed to reduce the final penalty by $31,000 in exchange
for a binding commitment by 3-V to implement a leak
detection and repair program and to install in-process
recycling equipment to reduce the generation of 1.1.1-
tnchloroethane and dichloromethane at the source.
3. Seekonk Lace Company i Harrington. RI) used acetone to
dissolve acetate threads that held lace strips together.
They failed to meet reporting requirements as mandated
under the Federal Emergency Planning and Community
Right.to-Know Act In exchange for a $10.000 reduction
'in the fine. Seekonk made process changes, virtually
eliminating the use nf acetone in the process.
I
U.S. EPA Pollution Prevention Research Program
Since 1988 the U.S. EPA has supported the Pollution
Prevention Research Program ^PRP) to encourage the
development and demonstration of techniques and technol-
ogies for reducing the generation of pollution. Today the _
EPA's Risk Reduction Engineering Laboratory (RREL) in
Cincinnati and the EPA's Air and Energy Environmental
Research Laboratory in Research Triangle Park, North
Carolina, share'the responsibility for that program. The
Risk Reduction Engineering Laboratory's P2 activities are
focused on the scientific issue, "How should consumer and
industrial products be designed and manufactured and
used so that their manufacture, use, and disposal will have
a minimal effect on the environment." fU
' ' The RREL program supports projects to improve the
understanding of pollution prevention options for resolving
environmental problems, and projects that demonstrate ;.
innovative pollution prevention approaches and technolo-
eies It includes studies and research and demonstration
projects that are designed to further the utilization of
source reduction and recycling as preferable environmental
improvement strategies. Projects within the program are
supported through in-house activities, contracts with out-
side organizations, and cooperative agreements with univer-
sities, and other governmental agencies.
' Among the major projects within the program is the
Waste Reduction Innovative Technology Evaluations
(WRITE) program. The WRITE program began in FY 90 in
cooperation with state and local governments to identify
and evaluate innovative pollution prevention applications
in order to encourage widespread use of effective technolo-
gies Participants are the states of California, Connecticut,
Illinois, Minnesota, &<& Jersey and Washington, and Erie
County New York. Some thirty-five individual evaluations
are in various stages of completion A summary of these
evaluations is shown in Table IV. • .
Another EPA/ORD laboratory, the Air and Energy Envi-
ronmental Research Laboratory in Research Triangle Park,
supports pollution prevention research that focuses on
-. developing P2 solutions for air pollution related environmen-
tal problems. The program includes projects in the follow-
ing areas:
1 Global Warming Prevention—Projects include solar
energy applications, alternative fuels, and methane
2 Stratospheric Ozone Protection—Projects include devel-
' oping substitutes for CFCs and HCFCs for residential -
and commercial refrigeration, space heating and cool-
ing automobile air conditioners, and rigid foam insula-
tion Work is also underway to examine potential
equipment changes to increase energy efficiency in
these applications. • ,1-1 j-
3 Indoor Air—Research is underway to develop building
operating and maintenance procedures which inhibit
the growth of biocontaminants. '
4 Mr Toxics—Work is underway on a report to Congress
regarding- pollution prevention options for reducing
emissions of volatile organic chemicals from consumer
and commercial products.
, EPA Program Offices
EPA's program offices are developing initiatives that are
likelv to produce regulations that will influence industrial
" waste generators to adopt industrial pollution prevention
practices. The Agency is revising the TSCA program to
move away from single chemical regulatory actions and
'cowards multimedia, multichemical, approaches involving
both regulatory and nonregulatory approaches.
J. Air Waste Manage. Assoc.
-------
Table fV. '-Vja« R.Muc:.on Innovative Technology Evaluation WRITE summary of projects.
Cleaner technology
Gjdperattng program being evaluated
Industrial process
Waste stream
being reduced
Date
report
available
California Environmental Protec-
tion Agency
Contact, Robert Ludwig
916 324-26591
EPA Project Officer
Lisa Brown <513 569 7634)
Illinois Hazardous Waste Research
and Information Center
Contact Dr GaryMdler
217 333-89421
EPA Project Officer-
Paul Randall 513 569-7673)
Minnesota Technical Assistance
Program
Contact Cindy McComas
'612,625-4949)
EPA Project Officer-
Teresa Harten .513 569-7565)
Mew Jers«y Department of Environ-
mental Protection
Contact: Dr Mohamed Elsaady
(609/292-8341)
EPA Project Officer;
J. Springer (513/569-7542)
Printed circuit board line
with spray nnsing and
copper recovery
Sulfuric acid anodizing
Robotic painting
Plastic bead blast strip-
ping
CFC recovery
Advanced reverse osmosis
Alternative oil filtration
systems
Electronic photography
Water-based inks
Alkaline zinc plating with
zinc recovery
Soy oil inks and alterna-
tive cleaners
Vacuum evaporative re-
covery of plating rinse
waters
Ultrafiltration
Drag out reduction
Drag out reduction
Zinc chloride plating (sub-
stitute for cadmium)
Carbon-based through-
hole coating
("Blackhole")
Electrodialytic qhromium
recovery ("lonsep")
Mobile or site recycling
for metal working fluid
Oil sorbent recycling
Cold compressed air spray
gun
Zero discharge—waste
water recycling/reuse
Printed circuit board
manufacturing
Chromic acid anodizing
line
Paint mixing and painting
Chemical solvent strip-
ping
Solvent degreasing
Nickel plating line
Diesel engine operation
and maintenance
Photograph developing
Narrow web flexographic
printing
Cyanide based zinc plat-
ing
Offset printing
Plating rinse waters 1 92
"Job-shop" plating opera-
tion
Degreasing of commercial
steel components
Eltctroless copper line in
printed circuit board
manu factoring
Cleaning and etch units in
flexible circuits manu-
facturing
Cadmium plating ,
Electroless copper elec-
tronics plating in elec-
tronics manufacturing
Chromate etchant bath
and hard chrome plat-
ing line
Machining
Machinery, etc
Electronic circuit board
testing
Plating
Chromic acid contaminated 1/92
waste stream
Paint wastes 1/92
Methylene chloride/paint 1/92
stripping waste
CFC wastes 1.'92
Nickel contaminated waste 4, 92
stream
Engine oil and oil filters 6/92
Photographic (silver contami- 12/92
nated waste)
Solvent air emissions, waste 10< 92
inks
Cyanide and zinc contami- 12/92
nated waste stream
Waste ink and aromatic pe- 12/92
trolcum based cleaner
wastes
Nickel plating rinse waters 4:93
Oi! and grease contaminated 4/ 93
wastewaterj
Copper contaminated waste 4/92
stream
Chromium and copper con- 10/92
laminated waste stream
Cadm^iqf contaminated 12,92
waste'streams
Copper contaminated waste 2/93
streams
Chromium contaminated 2,93
waste streams.
Waste metal working fluids 3/92
Waste cutting, lubricating 3/92
fluids
CFC wastes 9/92
Plating waste waters and 10/92
sludges •
The Air Program is developing maximum achievable
control technology 'MACT) standards for hazardous air
pollutants with emphasis on pollution prevention.
Water Program activities include reviewing Best Avail-
able Technology • BAT) regulation to insure the inclusion of
pollution prevention technologies in industrial effluent
Standards under the Clean Water Act; and working on new
industrial water effluent guidelines that take into account
source reduction options available to facilities.11
33/50 Program
The 33 50 Program, administered by the Office of Toxic
Substances, is a voluntary pollution prevention initiative
that builds on the Agency's pollution prevention policies
and programs. It aims, through voluntary source reduction,
to reduce the release and off-site transfer of 17 chemicals
and chemical compounds (see Table V for the list of 33/50
chemicals' used in manufacturing, from an aggregate of 1.4
billion pounds in 1988 down to 700 million pounds in
1995—a 50 percent reduction. Voluntary goals have been
set for a 33 percent reduction by 1992 and at least a 50
percent decline by 1995, as measured by the Toxics Release
Inventory (TRI). The list of chemicals was drawn from TRI
based on the following considerations: high production;
high releases and off-site transfers; potential for pollution
prevention; and potential for a wide range of health and
environmental effects. Of the 3,000 companies emitting one
or more of the 33/50 chemicals, EPA has contacted 600
with the largest TRI releases and transfers to ask that they
voluntarily develop programs to reach the targeted reduc-
tions. One of the major approaches to achieve these reduc-
tions will likely involve source reduction and substitution of
less toxic chemicals. EPA will publicly report on the status
of company commitments each year, focusing on source
reduction actions and chemical use substitutions.
EPA reported in November 1991 that the Agency was
very encouraged by early resuJts of the program. Thus far
almost 300 companies have committed to an overall reduc-
tion of at least 262 million pounds of pollution by 1995.
Several thousand additional companies have been invited to
participate.
May 1992
Volume 42. No, 5
625
-------
Table IV. ''Continued)
Cooperating program
Connecticut Technical Assis-
tance Program
Contact: Rita Lomasney
• • ' 203-24 Ir0777j
EPA Project Officer:
Lisa Brown (5 13/569-7634)
Erie County Department of En-
vironment and Planning
Contact: Paul Kranz
(716/858-7897)
EPA Project Officer:
Paul Randall (513/569-7673)
State of Washington Office of
Waste Reduction
Contact: Robert Burmark
(206/438-7370)
EPA Project Officer:
Ivars Licis (513/569-7718)
s
33, 50 Support
Cleaner technology'
being evaluated
Automatic aqueous
washer
Newspaper ink recycling'
Ion exchange for cadmium
recovery
Ion exchange for chro-
mium recovery
Water based inks and
"Corona" treater
Ultrasonic aqueous clean-
ing. • ' '.- ,
Closed loop mechanical
paint stripping
Acetone recycling and
substitution
Recycling of electric arc -.
furnace dust and
byproducts
Solvent substitute and
closed loop recycling '
"Mart" power washer
Sodium bicarbonate paint
stripping
Small-scale solvent recov-
ery
Alternative cleaners
,, ' Industrial process
Metal parts cleaning
Printing, publishing
Plating
Plating ,
Flexographic printing
Degreasing
Paint stripping
Fiberglass fabrication
Electric arc steel making
Automotive parts cleaning
Automotive parts cleaning
Paint stripping
Small quantity solvent
users ' ,
Parts cleaning
Waste stream
being reduced
Solvent and alkaline cleaning
waste
Used ink
Cadmium contaminated plat-
ing rinse water and sludge
Chromium contaminated
plating rinse water and
sludge .- '
Solvent ink waste and air
emissions
CFC wastes
Paint and lead contaminated
Acetone and still bottoms ,
Electric arc furnace dust and
foundry, wastes
CFC's and chlorinated sol-
vents
CFC's and chlorinated sol-
vents
Paint contaminated chlori-
' nated solvents
Used solvents
Chlorinated solvents
Date
report
available
• 5/92
7/92
12/92
12/92
9/92
4/93 •
6/93
2/93
10/92
4/93
1/93 '
9/92
9/93
9/93
SPA's Green Lights Program
In January 1991, the U.S. EPA announced its new Green
Lights program. Lawson and Kwartin write that Green
Lights is a program that encourages major" U.S. corpora- •
tions to install energy-efficient lighting wherever it is
profitable, and only where it maintains or improves lighting
quality. By using energy-efficient lighting technologies and
designs, less energy and electricity are demanded, and less
pollution is generated by power plants.
By encouraging corporations to install energy-efficient
lighting, Green Lights will produce multiple national bene-
fits. Corporations will save energy and increase their profits,
the air pollution caused by electricity generation will be
significantly .reduced, and the country's energy needs will
decrease. The program will also increase demand for quality
energy-efficient lighting products and services, improve
consumer knowledge about those products and services,-
and clarify the role lighting can play in protecting the
environment. ,
Guided by the principle that energy-efficient lighting is
"a bright investment in the environment," Green Lights
addresses the critical national issues of energy efficiency,
pollution prevention, and economic competitiveness for
both/major corporations and the lighting industry.
The authors further note that the benefits of a successful
Green Lights program are many, and that many people will
receive those benefits. ' ,
Green Lights corporations will profit by lowering their
electricity bills, improving their lighting quality, increasing
worker productivity, preventing pollution, and being pub-
licly recognized for their work to protect their environment
through energy-efficient lighting.
Because of the high visibility of Green Lights and its
corporate Partners, energy-efficient lighting and the retro-
fitting processes will develop higher public profiles, raising
awareness of the many environmental and economic bene-
fits of installing energy-efficient technologies and designs. •
The Green Lights program can set a precedent by demon-
strating how a cooperativei nonregulatory partnership be-
tween government and industry can be? effective in achiev-
ing national goals witH minimal red tape. At a time when
those goals include protecting the environment, saving
energy, improving national energy security, and increasing
profits and competitiveness, Green Lights can be an impor-
tant model program for the present and the future.30
Waste Reduction Evaluations at Federal Sites
The Department of Defense is cooperating with the EPA
and other federal agencies in the Waste Reduction Evalua-
tions at Federal Sites (WREAFS) program, a program
coordinated by EPA's Risk Reduction Engineering Labora-
tory. The two main objectives of this program are to
evaluate pollution generating processes at federal facilities
for source .reduction and recycling opportunities, and to
enhance the adoption of pollution prevention and recycling
through technology transfer to the public and private sector
'via project reports, project summaries, conference presenta-
tions, and workshops.
The WREAFS program is best described as a series of
assessments to find ways to reduce or prevent pollution.
Often, these opportunities can be implemented by the
facility without extensive engineering changes. Other times,
research, development, and demonstration projects must
be conducted before the options can be implemented. The
WREAFS program also involves evaluating the technical
and economic feasibility of the options and the subsequent
ranking of these options. Each federal facility retains the
discretion to implement the recommendations arising from
these assessments.
Waste minimization options have been identified under
the WREAFS program for a range of military and industrial -
processes at the departments of Agriculture, Defense,
Energy, Interior, Transportation, Treasury and Veterans
Affairs. Seven of eleven WREAFs projects are with DOD
under the branches of the Air Force, Army and Navy. A
summary of selected WREAFS projects is shown in Table
626
J. Air Waste Manage. Assoc.
-------
Table V. 33 50 program pnority chemicals.
ChermcaJ
Major reporting industries
Benzene Colorless liquid, Exists naturally in crude oil and coal. Chemically manufactured in
oil refineries, chemical plants and as a by-product of steel production. Principle use as a chem-
ic*J intermediate in production of styrene, phenol, detergent alkylates, aniline and chiorozen-
zenes Used in smaller amounts in gasoline, inks, paint thinners and as a degreasmg agent.
Cadmium Sc Cadmium Compounds—Heavy metal. By-product of smelting other metals such as
zinc and copper Chief uses are for plating metals, batteries, pigments, and as a minor additive
to some plastics, .
Carbon Tftrachlonde—Chlorinated organic Produced and used as a raw material in the pro-
duction of CFC's. also used in the production of dyes, drugs and lubricants.
Chloroform—Colorless liquid. Used as an intermediate in the manufacturing of cnlorofluoro-
carbons. also as an industrial degreasmg agent. By-product of some processes involving chlo-
rine, such as paper manufacture.
Chromium & Chromium Compounds—Naturally occurring heavy metal, processed from im-
porwd chromite ores Major use is as an alloy component for stainless, tool and specialty
steels Other uses are; plating for steel, catalyst, water treatment additive, component of some .
artist paints and other pigments and dyes, and some magnetic tapes.
Ctanidt & Cyanide Compounds—Hydrogen Cyanide, a colorless pale blue liquid, is the major
'cyanide-based raw material. Used as a chemical intermediate in the manufacture of other
chemicals which in turn are then used to produce nylon, to extract gold and silver from ore,
and lo produce herbicides. Cyanide is also wjdely used in electroplating operations.
Lead & Lead Compounds—Blue white solid in elemental form. Produced with other metals in
domestic mines and also as a result of recycling lead products. About 80% of all lead is used to
manufacture batteries. Other uses include radiation shielding, ammunition and cable cover-
ings and as a component for pigments.
Mercury & Mercury Compounds—Heavy metal and naturally occurring element. Produced at
mining operations Used in thermometers, specialty batteries (e.g., for wristwatches) and in
mercury-vapor lamps. In the chemical industry, it is used chiefly as a catalyst. Other uses in-
clude pigments, lubricating oils, and dental amalgam.
Methytene Chloride—Also known as dichloromethane, methylene chloride is a sweet smelling
colorless liquid. Produced in large quantities for wide use in industrial processes. Some of
these uses include paint stripping, metal cleaning and foam blowing. It is used in smaller
amounts as a solvent for Pharmaceuticals and in some consumer products such as paint re-
mover, spray paint, adhesives, tire cleaners, etc
'Methyl Ethyl Ketone >MEK)—A colorless liquid with a pleasant, pungent odor. Produced domes-
tically and used as a solvent for coatings, in adhesives, magnetic tapes and printing inks.
Methyl hobutyl Ketone i.WB/O—Colorless liquid used as a solvent protective coatings, adhe-
Jives, inks and the extraction of rare metals.
Xukel & Nickel Compounds—A. naturally occurring element whose ore is present mostly in the
sulfide form. Used as a component in alloys because of its corrosion resistance and strength.
Major consumers are the chemical and aircraft industries. Other uses are in automobiles,
household appliances, batteries, dyes and catalysts.
Tetrachloroethylene—Also known as-perchloroethylene (PERC), tetrachlorpethyiene is a clear,
sweet smelling liquid. Over 90^c of its use is as the primary cleaning agent in dry cleaning pro-
cesses. Used to a lesser degree in metal degreasing, as a chemical intermediate, solvent and
textile processing agent. Consumer solvent uses include brake cleaner, adhesives, wood
cleaner and silicone lubricant.
Toluene—A sweet-smelling organic liquid which occurs naturally as a component of crude oil,
and a isolated during industrial refining. Used chiefly as a component of gasoline, a chemical
raw material, a common industrial solvent and a component of paints, adhesives and other
chemical products.
UJ-Tnchloroethane—Also known as Methyl Chloroform, 1,1,1-trichloroethane is an organic
liquid with a sweet, sharp odor. Produced by the chemical industry for use as a common de-
greasing agent and solvent in both industrial and household use. It can be a component of
spot removers, shoe polish, typewriter correction fluid, inks, cleaners for brakes, battery ter-
minals, audio equipment, tires and other common products.
Tnchloroethylene—A clear, sweet-smelling volatile liquid. Primary use is in industrial metal
degreasing; also used as a solvent in typewriter correction fluid, adhesives and paint remover.
Xvtenes all homers 1—Colorless liquid with slightly sweet odor. Usually manufactured as a
'mixture of three types called Ortho-, Meta-. and Para-Zylene. Contains about 20"£ ethyl ben-
zene Produced in'oil refineries and chemical plants. Principle use is as an intermediate for
other organic chemicals m the production of plastic soft drink bottles, polyester fibers and
other products
.Chemicals; Petroleum and Coal
Chemical Manufacturing; Pri-
mary Metals; Fabricated Met-
ais
Chemicals
Paper; Chemical Manufacturing
Primary Metals Industries; Fab-
ricated Metal Products; Chem-
ical Manufacturing; Machin-
ery
Chemicals; Petroleum and Coal
Chemicals; Primary Metals; Fab-
ricated Metals; Electronics;
Transportation
Chemicals
Chemicals; Electronics; Fabri-
• cated Metals; Transportation;
Rubber and Plastics
r i
Chemicals; Transportation; Fab-
. ricated Metals; Rubber and
Plastics; Furniture; Electron-
ics '
Chemicals; Transportation; Fab-
ricated Metals; Rubber and
Plastics; Electronics; Furni-
ture
Primary Metals; Chemicals;
Transportation; Fabricated
Metals; Machinery; Electron-
ics
Primary Metal Industries; Fabri-
cated Metal Products; Chemi-
cal Manufacturing; Electron-
ics; Transportation
Chemicals; Fabricated Metals;
Transportation; Rubber and
Plastics; Paper; Furniture
Electronics; Chemicals; Trans-
portation; Fabricated Metals;
Machinery; Primary Metals;
Rubber and Plastics
Fabricated Metals
Electronics
Chemicals
Transportation
Rubber and Plastics
Primary Metals
Machinery
Chemicals
Transportation
Fabricated Metals
Petroleum and Coal
Furnityre
Electronics
Primarv Metals
May 1992
Volume <*2, No. 5
627
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Table VI. Waste reduction evaluations at federai sites selected projects.
Cooperating agency
Location i£PA report.*i
P2 options & evaluation areas
U S. Navy
U.S. Coast Guard
U.S. Army
Dept. of Veterans Affairs
U S. .Air Force
Philadelphia Navy Shipyard
(EPA 600 S2-90'046, 2/91) •
NUWES Kevport. Washington
, 'EPA,'600'S2-9K030.9 91'
Governors Island. New York .
• EPA 600;S2-90'062. 2'91>' . •
Ft, Riley, Kansas• , '-
:EPA 600 S2-90'031.-8'90>
Fitzsimmons .Army Medical Hospital. Colorado
-------
jus *as'.«? There ire states :hat have no laws dealing
•itrec'.Jv A-un pollution prevention, yet they have gone on to
buifd Tijjor pollution prevention programs, •'
State Facility Planning Requirements
A new requirement appearing in the legislation of 13
states is to require that a "facility plan" be 'developed.
AJmost alJ of these facility planning statutes require indus-
tnaJ facilities to submit pollution prevention plans which
must be updated periodically. Most facility planning stat-
utes cover the facilities that are required to report federal
Toxics Release Inventory ; TRI> data. These facilities must
use their TRI data when preparing state pollution preven- '
tton plans. Some of the statutes expand their coverage to
include large- and small-quantity hazardous waste genera-
tors, or holders of specific types of environmental permits
Out-o.-state generators may aJso fall under the scope of the
planning statutes,11
The chemicals covered by facility planning statutes vary
However, chemicals covered by many of the laws are also
covered under the Toxic Releases Inventory. In addition
hazardous wastes covered by the Resource' Conservation
and Recovery Act and chemicals covered under the Compre-
hensive Environmental Response. Compensation and Liabil-
ity Act are sometimes covered by the statutes, and some
state legislatures require-coverage of additional sets of
chemicals.
A state's programs are really t-.- best indicator of how
active it is in the pollution prevent- - arena. Although a law
may be on the books, unless therr ,.-e programs putting it
into practice (and funding to support the programs) little
progress can be made at the state-level. State pollution
prevention programs show at least as much variety as state
laws. Some programs are mature, independent and well-
established within the state's environmental hierarchy
and administer a variety of initiatives dealing with pollu-
tion prevention. Other programs consist of little more than
a coordinator who tries to pull together the pollution
prevention aspects of the other state environmental pro-
grams and whose main job is education about the benefits of
pollunon prevention. Some states delegate their pollution
prevention programs to outside groups, such as universities
or other research centers, which they supply with state
lunding.11 . •__. .
e'ements ^ state' Programs are shown in
Local Govemm«« Programs
While states have taken the lead in industrial pollution
prevention policy m most areas of. the country, local govern-
ments have also been involved, particularly in those loca-
tions where more responsibilities are delegated to the local
government level.,
Some examples are:
• California—Local governments in California have played
a major role in industrial pollution prevention. This is in
large part because the State of California delegates more
toccIT toucountles than ^ typical in other states. A
ISBb bill authorizes counties to prepare hazardous waste
management plans. A significant element of these plans
is an analysis of the potential of industrial source
reduction.
' f/ty °f,LnS ^S*1*5—Un<*er its Hazardous & Toxic'
Materials Project the city requires its agencies to adopt
the waste reduction hierarchy as a policy
• California Counties of San Diego and San Bernadino
have developed model "multi-agency" pollution preven-
tion programs to ensure a more comprehensive strategy
ix? used by businesses and to avoid "media transfer "
Table VII. Typical elements of sute pollution prevention
programs
Information cleannghouse
Research and development
Technical assistance; regulation interpretation
On-site technical assistance
Financial assistance to industry
Financial assistance to local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Review prevention plans
Work with academia to promote pollution prevention
Awards program
May 1992
Volume 42 No 5
• Erie County, New York—Erie County emphasizes educa-
tion and technical'assistance in its pollution preventipn
program. The Erie county technical assistance program
has been operating since 1985 and has targeted 4000
small and medium-sized businesses located in the County
Technical assistance includes: an information center
and a quarterly newsletter.
Local governments can also promote pollution prevention
through publicly owned treatment works (POTW's) POTW
inspectors have a very thorough understanding of discharg- -
ing industries and are an excellent mechanism for encourag-
ing source reduction options to generators. By takine
advantage of this mechanism, local governments can pro-
mote pollution prevention through means that are both low
cost andI effective and in ways-that are not possible at the
state and federal level. Th4 rf.S. EPA convened a workshop
m February 1992 to develop a network of individuals
interested in promoting pollution prevention in POTW's
and to share, information on progress, obstacles and re-
source needs. Among the findings of the workshop was that
traditionally, owners and operators of POTW's, as well as
state and federal regulators, have placed .an emphasis on
t^r^o™?'! rauh!r than °n con*™«°n and preven-
tion. POTW s have had pre-treatment programs, including
sampling efforts, inspection and enforcement programs!
MWPP, sludge management programs and various water
conservation efforts.35 •
P2 in Other Countries
Pollution prevention is receiving widespread emphasis '
internationally within multinational organizations and
within individual countries. The driving force behind this
emphasis is the concept of sustainable development and the
hold that this concept has over planning strategies 'and
long-term solutions to global limits and north-south eco-
nomic issues. The June 1992 United Nations Conference on
Environmental Development (UNCED) in Brazil will un-
doubtedly spend a great deal of time on pollution preven-
tion. • '
The European Community has designed some of its rules
and programs around pollution prevention. The Organiza-
tion for Economic Cooperation and Development (OECD) ''
S£J ™ ™™P.^a "^LMsesanent on pollution preven- .
t on. The United Nations Environmental Programme has a
clean technologies program and the United Nations Indus-
rial Development Office, UNIDO) just held a major interna-
tional conference on sustainable development. Joining this
group of international bodies is the North Atlantic Treat?
?ngChalfe 'Ni^WhiC0h HaS a non-military CommittS
on Challenges of Modern Society which has just begun a
multi-year p.lot study called "Pollution Prevention Strate-
gies for Sustainable Development" in which 14 countries
629
-------
are involved in an information exchange progranvon podu-
tion prevention policy, education and technology.
Individual countries have taken their own initiatives in
developing pollution prevention programs. Canada has the
Green Plan^5 and The Netherlands has the National. Envi-
ronmental Policy Plan (NEPP).36 Denmark and The Neth-
erlands are extensively studying life-cycle accounting" ap-
plied to a host of consumer and commercial products. .
A very interesting .approach to using the regulatory
system in Germany to encourage P2 is reported by Nels of
German Federal Environment Agency. The 1986 Waste Act
. empowers the German government to bring its influence to ,
bear on waste generation prior to the production and use of
products.
The options, if necessary to increase recycling and to
simplify waste treatment, include:
' • Subjecting certain products to mandatory labeling or
separate handling.
• Requiring the manufacturers to reclaim their products
once they become waste.
• Imposing bans or restrictions on marketing.
Although these regulations are valid for all wastes, the two
main aims are: .
• To reduce the pollutant content of waste and thereby
enable more recyclingrjf these pollutant free waste.
• To reduce the amount of household waste by reducing all
kinds of packaging material. .
In carrying out the second of the above options, the German
government has passed an ordinance to require, by January
1993, that commercial dealers have to accept for recycling
all returned packaging in or near shops.37
Industrial P2 Programs
Reflecting both an interest in saving money and avoiding
increasingly stringent environmental end-of-the-pipe •regu-
lations, and responding to the concern on- the part of the
consuming public for more environmentally friendly activi-
ties, many of America's industries have adopted pollution
prevention with a vengeance and have initiated broad
programs. The EPA reports in its "Pollution Prevention
1991: Progress on Reducing Industrial Pollutants" docu-
ment on the P2 programs for 24 major companies whose
program, goals, and accomplishments are company wide.
Six of these programs are highlighted in Table VIII.11
The Chemical Manufacturing Association (CMA) reports
a "quiet revolution that the chemical industry is conduct-
fag within its own operation to improve its performance. As
part 'of the CMA Responsible Care Program, the industry
has adopted a Waste and Release Reduction and Manage-
ment Code that contains 10 management practices that
provide a framework for reducing waste generation and
releases to the environment. These practices are:38 •
• Commit the organization
• Inventory wastes and releases
• Evaluate potential impacts •
• Educate and listen to employees and the public
'• Establish a reduction plan, goal, and priorities
> • Implement the reduction plan
• Measure program
« Communicate program
• Integrate reduction concept'in planning
• Practice outreach
The CMA notes "improved performance will take time,
money, and hard work. As we move down this road, we
invite others to pick up the challenge and join us."38
Reflecting the widespread popularity of pollution preven-
tion programs, the A&WMA compiled descriptive articles of
successful programs in 12 different industries.39 The EPA
has published a-summary of 20 successful P2 projects. The
10 industries featured include metals fabrication, manufac-
turing of non-electric machinery, lumber products, electron-
ics, '.textiles, petroleum fuel products, chemical products,
printing and publishing, and transportation.40 Reddington,
reporting on the program at Monsanto to reduce air
emissions by 90 percent states that in the first year (1988),
a 17 percent reduction was achieved and that 1989 brought
the total reduction of 1987 emissions to 36-38 percent. He
remains confident that the goal is achievable.41-42
Zosel reports that 3M has saved $500 million since 1975,
and achieved a 5 percent reduction in pollution per unit of
production.43 . • •
Nichols reports that results of waste reduction programs
are mixed. In a very extensive paper, the author reviews
successes but identifies areas in which more can be done by
the nation's industries.44
In, a widely cited and quoted report, Sarokin and others
report on the wasfe reduction/pollution prevention prac-
tices at 29 industrial organic chemical plants. The report
finds examples of waste reduction being practiced, but also
finds that "despite the extensive interest and verbal sup^
port industry and government have given to the concept of
waste reduction, this report finds such .initiatives still all
"too rare. Much more can (arid inevitably must) be done in •
this crucial area. While the kinds of waste reduction options
documented here are interesting and exciting, the real
impact of the practices could not be quantified in most
cases. The information was seldom available on total plant
wastes or on individual waste streams so that reductions
could be measured. What is more, the information on .
chemical use and discharges of wastes to air, land and water
was fragmented and piecemeal at best. Clearly, if govern-
ment or the public is to have a useful picture of toxic waste
problems we all face, and to assess progress in managing or
reducing these problems, the specific data available to the
public on industry's chemical uses and discharges must be
improved."45 ^
Berglund and Lawson, in a very practical article, outline a
somewhat broader configuration for a pollution prevention
program than is normally cited. They believe that success-
ful pollution prevention demands attention to eight aspects
of a manufacturing operation. They are: product design,
process design, plant configuration, information and con-
trol systems, human resources, research andjJevelopment,
suppliers' role and relationship, and organization. They
state that three major functional areas entail numerous
aspects of implementation, and have a wide range of tie-ins
with the economy at large.46
Evanoff includes in his conclusions after exploring hazard-
ous waste reduction opportunities in the aerospace indus-
try that:47
1. The elimination of nearly all forms of land disposal can
be realized; several facilities have already achieved this
milestone.
' 2. Zero discharge (defined as no manifested hazardous
waste being shipped from a facility) is an achievable
goal.
3. Waste minimization solutions are generally extremely
cost effective by both traditional and risk-management
accounting technologies.
• 4. Effective waste minimization in a company requires top
management commitment, resource allocation, and a
goal-oriented program approach.
5. Material producers and vendors should be encouraged
to work with manufacturers in recycling waste prod-
ucts/excess materials.
6. Segregation of.metallic and organic wastes is the key to
effective recycling or resource recovery. ' '
J. Air Waste Manage. Assoc.
-------
Table VIII. C'3mpan>-wide pollution prevention programs and goals.
Scope
Goal
Accomplishments
Amoco
Waste Minimization
Program U9831
Chevron
Savy Money and Reduce
Tox.cs Program
(SMART. 1987»
Dow
Waste Reduction Al-
ways Pays (WRAP,
19(36)
General Dynamics
Zero Discharge (1985)
•IBM
Monsanto
Priority One (TR1
wastes) •
Primary focus on minimizing
hazardous waste disposal,
also minimize and track
non-hazardous wastes.
SMART adopts EPA's hierar-
chy, with an emphasis on
industrial source reduc-
tion, toxic chemical use
substitution, and recycling
for hazardous and nonhaz-
ardous solid wastes.
Industrial source reduction
and onsite recycling.
Industrial source reduction,
toxic chemical use substi-
tution, recycling, treat-
ment, and incineration.
Industrial source reduction
and toxic chemical use sub-
stitution are priorities, fol*
lowed by recycling/reuse/
reclamation, incineration,
detoxification, and disposal
in a secure or sanitary
landfill, in that order.
Source reduction, re-engir
neering, process changes,
reuse, and recycling to re-
• duce hazardous air emis-
sions and TRI solid, liquid
and hazardous wastes.
Eliminate the generation and dis-
posal of hazardous wastes.
Reduce hazardous waste generation
by 65% by 1992 and recycle what
is left.
Find nontoxic alternatives to toxic
materials and processes
Devise safer operating procedures to
reduce accidental releases.
Ensure that pollution reductions in _
one area don't transfer pollution
to another.
Increase management support for
waste reduction activities, estab-
lish a recognition and reward sys-
tem for individual plants, compile
' waste reduction data, and com-
municate info, on waste reduction
activities
Decrease SARA 313 air emissions by
50% by 1995, when compared
with 1988.
Decrease toxic air emissions (Ibs/yr)
by 14% by Jan., 1991 (baseyear
Dec. 1988).
Have no RCRA manifested wastes
leaving company facilities.
Pledged to eliminate ozone deplet-
ing chemicals from IBM products
and processes by end of 1993 and
to recycle 50% of solid waste by
1992.
A 90% reduction in hazardous air
emissions from 1987 to 1992.
A 70% reduction in TRI solid, liquid,
and gaseous wastes from 1987 to
1995. •
Between 1983 and 1988, Amoco re-
duced its hazardous waste by
86%, saving the company about
$50 million.
From 1987 to 1990, Chevron re-
duced hazardous waste by 60%
and saved more than $10 million
in disposal costs.
Case study: Chevron used to dispose
of tank bottoms in landfills. It
now uses a centrifuge to separate
oil from waster, it reuses the oil
from waster; it reuses the oil and
treats the waster, leaving only a
small amount of solid to be land-
filled (less than 5% of the original
sludge). .
SARA 313 overall releases are down
from 12,252 tons in 1987 to 9,659
tons in 1989, a 21% reduction. •
Off-site transfers are down from
2,855 tons in 1987 to 2,422 tons
in 1989, a reduction of 15%. Air
emissions for 1989 showed a 54%
decrease from 1984.
Nearly 40 million Ibs. of hazardous
waste discharge eliminated from
1984 to 1988 (approx. 72%), while
sales increased from $7.3 billion
Y tf $9.35 billion over same period.
Hazardous waste generation was
reduced 38% from 1984 to 1988;
84% of IBM's hazardous waste
was recycled in 1988; 28% of all
solid waste from IBM United
States operations was recycled
1988; IBM U.S. emissions were
reduced 20% from 1987 to 1988;
and, IBM U.S. had a decrease of
25% in its CFC emissions between
1987 and 1988.
From 1987 to 1990, Monsanto
achieved a 39% reduction in haz- ;.:
ardous air emissions. ' ' .• :••
Source; Ref, 36
7.' The ultimate success of any waste reduction program
depends upon effective and continuous employee _sup-
port. .
Goldney found that although reducing waste is everyone's
responsibility, top management's commitment is key to a
successful waste minimization program.48 Bayer, in target-
ing process modification to prevent pollution, reports invest-
ing a sixth of capital spending for "prevention, reduction
and recycling" in order to meet the environmental chal-
lenge.49
Pojasek points out that in implementing a company
waste reduction program that the manager must work with
a full "menu." i.e.. that all options are considered. The
initial screening of alternatives should examine the follow-
ing?
• Implementation and feasibility
• Risk to production and quality control
* Regulatory considerations, e.g.. permits
• Costs and return on investment
• Environmental protection and health risks
He further states that proper care should be taken to clearly
communicate the program-to the following participants:00
« Management
• Employees and the public
• Production personnel
• Regulators
• Insurers
» Consumers
Waste reduction tracking and reporting are difficult due to
the nature of R&D activities and the types of wastes they
generate. Accurate, meaningful comparisons between dif-
ferent organizations or across time-frames requires more
than a cursory investigation. The future challenge is to
develop new or modified processes which incorporate waste
May 1992-
Volume 42, No. 5
631
-------
Table DC Pojasek's fifteen milestones to pollution prevention.'
1. Promulgation of Management Initiatives '..',-
2. Assemble the Pollution Prevention Implementation
Teams '
3. Select the Pollution Prevention Program Elements
4. 'Determine How Pollution Prevention Will Be Measured
5. Establish a Solid Economic Base . '
6. Prepare Process Flow Diagrams and Materials Balances
• 7. Establish a Materials Tracking System
8. Provide for Technology Transfer
9. Set Specific Pollution Prevention Goals
10. Verify the Process Flow Diagrams and Materials Bal-
ances
11. Establish Pollution Prevention Teams at the Worker
Level - '••'..
12. Provide Engineering and R&D support
13. Implement Pollution Prevention Options
- -14. Give Recognition to Those Involved '
15. Do It Over Again . -
Source: Ref. 8
reduction within the processes inherent designs. Besides
long-term waste reduction, increased organization competi-
tiveness .and personal recognition are but two of the
rewards which can result from such an effort.51
Pojasek suggests that in.order to reach pollution preven-
tion, the fifteen example milestones shown in Table IX
must'be attained. It should be noted that inj-ecognition'of
the fact that pollution prevention takes time.* the last point
is "do it over." He states that "Repetition of the 15
milestones makes the pollution prevention program perpet-
ual. If pollution prevention isn't ingrained in the organiza-
tion, - it will never reap the benefits of the program
envisioned."13
The recognized need to rr.inimizi wast*
•i
. PLANNING AND ORGANIZATION
Get management communer*
Set overal usewment program goal*
Organize assessment program task force
AMenment Digitization
eVkd COfTeflKfTMnt to pfOC90^ f
ASSESSMENT PHASf
• Cotect prece** and lactty data
• Priortize and select asseesment target*
• Select people lor aueeament team*
• Review data and imped tie
• Generate option* -
• Screen and select option* lor further study
Assessment report ot
. selected options
Select new •
aneaiment target*
and reeveJuete
previou* option*
FEASIBILITY ANALYSIS PHASE
> Tecnneal avaloation
• Economic evaluation
• Select options for implementaliorl
Rnal report, including
recmiunended options i i
IMPLEMENTATION
Justify project* and obtain funding
Installation (equipment)
knplementaten (procedure)
Evaluate performance
Repeat the proceea
Figure 1.
Successfully implemented
waste ffunimizaton projects
The EPA waste minimization assessment procedure.
Pollution Prevention Assessments
A major element in an industrial pollution prevention
program is carrying out periodic assessments to identify
opportunities for reducing wastes.7'52'53 These assess-
ments, originally called waste minimization assessments
and later pollution prevention assessments, have been the
subject of much of the pollution prevention literature.54-M
Waste Minimization Assessment (WMA). A waste minimiza-
tion assessment is a systematic planned procedure with the
objective of identifying ways to reduce or eliminate .waste.
The steps involved in conducting a waste minimization
assessment are outlined in Figure 1. The assessment
consists of a careful review of a plant's operations and waste
streams, and the selection of specific areas to assess. After a
s'pecific waste stream or area is established as the WMA
•focus, a number of options with the potential to minimize
waste are developed and screened. Third, the technical and
economic feasibility of the selected options are evaluated.
Finally, the most promising options are selected for imple-
mentation.56
There are many manuals that present guidance and
suggestion to those interested in carrying out assessment.
. A selection of these manuals is shown in,Table X. There are
also many industry-specific manuals and guidance docu-
ments that have been provided by federal, state, and local
waste reduction programs.* 7~61
Pojasek proposes an'alternative approach for assess-
ments as the prescriptive approach recommended by the
EPA and most states in their respective manuals.- Calling
his approach a descriptive approach, the author outlines ah
approach that is less dependent on standardized forms and
more dependent upon the individual's learning about the
source of waste and tha interrelationships between waste
generating prof^essesT'^nis latter approach makes the pro-
cess, rather than the waste stream, the central focus and
can lead to substantial waste reductions. The author con-
cludes "incorporating the descriptive audit approach into
pollution prevention audits can help companies move be-
yond firstrtier opportunities to achieve fundamental reduc-
tion in waste generation. It is expected that 'Use of the
descriptive approach will increase as the shortcomings of
the prescriptive approach become more apparent."54-•5S« ^
Many accounts of assessments that nave successfully
identified waste reduction opportunities are reported in the
literature. Typical of such reports is one by Wolf, Yazdani
and Yates concerning studies carried out at the Los Angeles
International Airport.63 "•'•:*'• . ••"..'
Since 1989 the EPA'has supported a project to have
faculty and students at the Colorado State University,
University of Louisville, and the University of Tennessee,
carry out assessments at manufacturing facilities in their"
• respective areas. A summary of some of their findings is
shown in Table XI. The EPA has also produced a series of
pollution prevention reports that contain the results of
assessments carried out under the sponsorship of the
California EPA.64-75
Current Issues
r "'"p.
Nothing is ever easy and the development of the program,
strategies, and technologies to achieve environmental qual-
ity improvement through pollution prevention is no excep-
tion. There are; many areas that represent issues around
which well informed and well intentioned individuals dis-
agree. In this section we review observations on those
issues that are generating the most interest currently.
Precisely defining these issues relevant to other apparently
similar ones has proven difficult since everything is related
to everything else. We beg the reader's indulgence for those
instances where our "issues" overlap a little.
632
J. Air Waste Manage. Assoc.
-------
Table X. Pollution prevention manuals.
Title
Industrial Waste Minimiza-
tion Manual
Industrial Waste Audit and
Reduction
Clean Technologies
Do there currently exist strategies and processes that can
b« utilized as "clean technologies" to bring about increased
utilization of ?T
The case for encouraging clean technologies according to
Heaton, Repetto, and Sobin is that the realities of demo-
graphic momentum and increasing economic growth leave
technological transformation as the primary strategy for
avoiding environmental degradation. Technological trans-
formation means widespread, continuing development and
adoption of ever less polluting and more' resource-efficient
products, processes, and services. Technological change has
contributed most to the expansion of wealth and productiv-
ity. Properly channelled, it could hold the key to environmen-
tal sustainability as well. They suggest that technologies to
reduce environmental problems while raising economic
productivity exist. Studies of major sectors of the economy
demonstrate clearly that far-reaching environmental im-
provements could be made immediately. For example,
many opportunities in industrial pollution prevention and
improved energy efficiency are highly profitable today. A
variety of new renewable energy technologies, already
commercially available, are becoming more widely competi-
tive with conventional fossil fuels. They state environmen-
tal regulations should be reformed to encourage technologi-
cal change. Relying on "best available technology" standards
tends to entrench existing control technologies at the
expense of long-term innovation. Regulations have largely
been uncoordinated across media (air, water, and land),
have focused on "end-of-pipe" pollution controls instead of
pollution prevention options, and have provided no incen-
tives for doing better than standards dictate. Cumbersome
administrative procedures also impede innovation.76
Included in the EPA's definition of pollution prevention
1 is the use of materials and processes that lead to reduced
multi-media pollution. These materials and processes con-
stitute what is often referred to as clean technologies and
these are the technical foundation upon which reduced
generation rates will be based. Some clean technologies are
common to many industries. Others are closely related to
producing a particular product, and are utilized by a
smaller part of the industrial sector.
The literature contains many articles and papers that
address production processes in many industries. A compre-
hensive review of these articles is beyond the scope of this
review. However, to provide some concrete examples of
Table XI. Summary of waste minimization assessments US EPA/University City Science Center Program.
Available from
Profiting from Waste Reduc-
tion in Your Small Busi-
Waste Minimization Oppor-
tunity Assessment Manual
lEPA/625/7-88/003)
Writing a Waste Reduction
Plan: Changing Your Com-
pany's Course Towards
Better Waste Management
Waste Minimization: Manu-
facturers' Strategies fork t
Success ' /
Audit & Reduction Manual
for Industrial Emission
and Wastes
Center for Hazardous Materi-
als Research, October 1989
Univ. of Pittsburgh Applied
Research Center
320 William Pitt Way
Pittsburgh, PA 15238 •
412-826-5320
1 (800) 334-CHMR
Cost: $40
Ontario Waste Management
Corporation, 1989
Attention: John Richmond
2 Bloor Street West, 11th
Floor
Toronto, Ontario, Canada
M4W3E2
416-923-2918
Cost: $40
Alaska Health Project, 1988
1818 W. Northern Lights,
Suite 103
Anchorage, AL 99517
907-276-2864
Cost: Free (available through
the PPIC)
CERI, US EPA
Cincinnati, OH 45268
Cost: Free
University of Tennessee
Center for Industrial Services
226 Capitol Blvd., Suite 401
Nashville, TN 37219
615-242-4816
National Association of Man-
ufacturers
1331 Pennsylvania Avenue
Washington, D.C. 20004
Cost: $30
UNIDO
Vienna International Center
Box 300
A-1400 Vienna, Austria
Facility
tmanufacturer.'plant)
MeUl Parts Coating Plant
Outdoor Illuminated Signs
Rebuilt Railway Cars & Components
Brazed Aluminum Air coolers
Heating, Ventilating and Air Conditioning
Equipment
Bumper Refinish'ing Plant
Printed Circuit Boards
Multi-layered Printed Circuit Boards
Paint Manufacturing
Aluminum dns
Example of waste minimization opportunity
Reduce primer -partial pressure
Improve spray equipment
Use template for letter fixation
Use mechanical fixation
Reduce generation of paint chips
Retrain spray personnel
Minimize overspray
Reduce paint carryover
Alternate fastening
<
. Reduce rinse volume
Install filter
Reduce Water Usage
Segregate acid soap
Recycle waste copper sulfate
Reduce water usage
, Recycle Cu waste
Reuse rinse water
Pipe-cleaning system
Eliminate mercury additive
Use non-hazardous wash
Estimated
saving* Implementation
($/yr) -cost($)
2997
8529
1980
5260
33514
4820
2143
4347
73197
.
1089
1690
5840
23470
400
2670
1090
1270
11110
. 5580
177400
2900
6000
195
1500
13500
3500
0
2790
6400
10
810
200
300
0
, 250
0
650
1600
0
0
May 1992
Volume 42. No. 5
633
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»*
Table XJIL
generation.
Example of operational changes W reduce waste
• Reduce raw matenaJ and product loss due to leaks, spills,
drag-out, and off-specification process solution.-
• Schedule production to reduce equipment cleaning. For
example, formulate light to dark paint so the vats do npt
have to be cleaned out between batches,
• Inspect parts before they are processed to reduce number
of rejects.
• Consolidate types of equipment or chemicals to reduce
quantity and variety of waste. .
• Improve cleaning-procedures to reduce generation of dilute
mixed waste with methods such as using dry cleanup tech-
niques, using mechanical wall wipers or squeegees, and
using "pigs" or compressed gas to clean pipes and increas-
ing drain time. •
• Segregate wastes to increase recoverability.
• Optimize operational parameters (such as temperature,
pressure, reaction time, concentration, arid chemicals) to
reduce by-product or waste generation.
• Develop employee training procedures on waste reduction.
• Evaluate the need for each operational step and eliminate
steps that are unnecessary.
• Collect spiUed or leaked material for reuse.
what are considered dean technologies in various indus-
tries, the following comments are offered.
Hunt, in overviewing waste reduction techniques, catego-
rizes the options as managing inventory, modifying produc-
tion processes, reducing >• waste volume, and recovering
waste: Managing inventories is a very useful strategy for
. industrial pollution prevention since it results in significant
decreases in amounts of materials used and waste products.
Modifying production processes would be considered a
classical clean technology approach. Hunt further divides
the category into improving operations procedures, chang-
ing to less hazardous materials and modifying or changing
equipment.77 Some examples of P2 practices or processes
are listed in Table XII, XIII, and XIV.™
Obprny, et al., report that as part of the U.S. DOE's
commitment to minimizing waste at the national laborato-
ries and its production agencies, the Sandia Laboratory has
embarked on a program to reduce and, where feasible, to
eliminate hazardous liquid waste by-products of cleaning
processes used iri the manufacture of electronic assemblies
and precious machine parts. Examples of clean technologies
Table XHL Example of waste reduction through material
change. ' . ; .
Source
Technique
Household Appliances
Printing
Textiles
Air conditioners
Electronic components'
Aerospace
Ink manufacture
Plumbing fixtures
Pharmaceuticals
Eliminate cleaning step by selecting
lubricant -compatible with next
process step
Substitute water-based ink for sol-
vent-based ink
Reduce phosphorus in waste water
by reducing use of phosphate-con-
taining chemicals. Use ultraviolet
instead of biocides in cooling tow-
ers.
Replace solvent-containing adhe-
sives with water-based products
Replace water-based film-developing
system with a dry system
Replace cyanide cadmium-plating
bath with a non-cyanide bath.
Remove cadmium from product.
Replace hexavalent chrome-plating
bath with a low-concentration '
trivalent chrome-plating bath.
Replace solvent-based tablet-coating
' process with a water-based pro-
cess.
discussed are: (1) alternative solvents used to remove solder
flux residues during- electronics assembly manufacture, (2)
alternative solvents used in ceramic header fabrication, and
(3) alternative manufacturing processes that eliminate the
need for solvent cleaning of precision optical components
prior to mounting.79
Richardson, reporting on clean technology options for the
textiles industry, documents a cost-effective pollution pre-
vention option for removing a toxic liquid discharge. A
North Carolina company used biocides in the air washer in
an attempt to control algae growth. The basic "blow down"
and periodic cleaning from this system was discharged to a
small stream. Following stream analysis, which indicated
the discharge to be aquatically toxic, the North Carolina
Division of Environmental Management revoked the dis-
charge permit. When the city refused to allow the discharge
into the sewer system, the company was faced with a
serious problem. The air wash system was necessary for the
carding, spinning and winding operations and some form of
disinfection was required to control algae growth within the .
system. After a review of available options, a decision was
reached to install an ultraviolet disinfection system on the
air wash system. This closed-loop system sqlved two prob-
lems. It eliminated the discharge and the use of the
biocides. The payback period for 'the project was 1.77
years.80
A popular target for pollution prevention strategies is
often industrial solvents.81'93 Brown and Springer deter-
mined that using a terpene based cleaner in place of
methanol and TCA appeared to be an environmental suc-
cess in a metal finishing application.94 D. Wahl and Peter-
son note in reporting results from foursolvent projects that
though changing an industrial process is frequently cited as
the most desirable^way to reduce waste for true pollution
prevention, the benefits of recycling, however, tend to be
more obvious and often affect waste volumes dramatically.
Therefore, promoting and supporting the hierarchy of
process change requires a recognition of the time and effort
to complete a more critical technical evaluation. It also
necessitates realizing the long-range benefits of process
change.95 .
Many authors believe that zero discharge of hazardous
wastes is possible.47- ^ 97 Early and Edison, in supporting
the potential of the concept, state "Designing for zero
releases is an all-encompassing philosophy. It considers all
aspects of a chemical process from conceptual design to
final operation and should be addressed in programmatic
fashion. Narrowly focusing on just a single element of the
design process may result in overlooking many other areas
which can remedy an easily solved release incident. Resolv-
ing to be proactive must become a standard philosophy for
• design and operations. Proactiyity should set the, tone for
years of safe, productive "zero release" operation."97
Randall concludes in a .paper on the surface coating
industries that the paints and coatings industry will con-
tinue to see changing technologies for an environmental
era. Manufacturers of architectural coatings under increas-
ing environmental regulations will continue to reduce the
VOCs contained'in their coatings by displacing oil based
products with water based coatings. In particular, the paint
industry will center its research upon reformulations and
increasing the efficiency of coating applications and meet-
ing stricter environmental regulations via .water based
paints, powder coatings, high'-solids enamels, reactive di-
luents, and radiation curable coatings.
Pollution prevention methods are making significant
contribution to the effort to reduce the VOCs and paint
wastes and sludges through source reduction methods such
as process/production techniques, good manufacturing prac-
tices,'and material substitutions. The coating industry's
comprehensive efforts of utilizing source^ reduction and
recycling techniques will be important towards the goal of
634
si. Air Waste Manage. Assoc.
-------
reducing these pollutants Reauchonzauon of the Clean Air
Act wiil :ontmue these efforts to cut emissions farther and
faster The future will encompass technological advances
with low cure powders, faster curing processes, improved
application systems, and ultimately cutting emissions levels
to reduce their contribution to ozone formation in the lower
atmosphere.98 Such new technologies as those cited by
Randall for this industry are being replicated in other
industries.
MacPherson, in the proceedings of Environmentally Con-
scious Manufacturing: Recent Advances, states "Environ-
mentally conscious manufacturing can be thought of as
Clean Manufacturing. These are processes that contribute
neither toxic nor non-toxic waste to the environment. They.
must also be both energy efficient and cost effective.
Although it seems impossible now to have entirely "clean"
manufacturing, it is possible to drastically cut the genera-
tion of all waste from nearly all processes. Further, much of
what we call "waste" is potentially an unused by-product
that could be further processed or refined and sold as a
product or reused in the process. Toxic waste generated as a
by-product of manufacturing can often be dramatically
reduced through better process control, or avoided entirely
by an alternate process."99
A much studied industry to identify opportunities for
pollution prevention is the plating industry. In an excellent
overview of the subject, Eoecke points out that implement-
ing source reduction in a plating operation can be described
as a series of loops, touching first on process modification,
then on material substitution, then perhaps to operating
practices. If a starting point was to. be given, however, it
would probably be to gather as much data as possible on
what is being done in the operation at a given time, and why
it's done that way, Then the possibility is much greater that
the pitfalls pointed out in this paper can be avoided. 10°
Springer and Baker, in a report describing the evaluation
of cleaners for solvent substitution at an Air Force facility
conclude that the aircraft manufacturing industry is per-
forming substantial research to find replacements for 1,1,1-
trichloroethane and trichloroethylene. As a result of canvass-
ing various businesses within the aircraft manufacturing
industry, it was found that cleaner performance criteria
were highly specific yet analogous between businesses.
Based on these similarities, facility personnel were able to
select a cleaner for pilot, testing as a replacement for
trichloroethylene, obviating the need for extensive bench
scale testing.101
Measuring Pollution Prevwition
Why should pollution prevention be measured? How
should accomplishments be measured? What existing data
, bases can be used? How can pollution prevention measures
be incorporated into the larger environmental data report-
ing scene? How much priority should P2 measurement
receive given that it might drain resources from implemen-
tation activities? Authors addressing these and similar
measurement-based issues have generated many papers.
Andrews, in a National Research Council background
paper, asks:
I. What are we trying to measure? Waste reduction is now
an increasingly popular concept, but different users of
it have different measurement'needs. Are we trying to
measure overall national progress in reducing waste or
merely local progress in reducing discharges to local air.
water, and landfills; to measure physical amounts of
wastes reduced or reductions in toxicity and other
adverse environmental effects; to measure the effi-
ciency of a single industrial plant or to be able to
compare across plants, products, or economic sectors?
No single number is useful for all these purposes:
multiple measurements are necessary.
Table XTV. Example of production process modifications for
waste reduction.
Process step
Technique
Chemical Reaction Optimize reaction variables and improve
process controls.
Optimize reactant-addition method.
Eliminate use of toxic catalysts.
Improve reactor design.
Filtration and Eliminate or reduce use of filter aids and
washing disposal filters.
Drain filter before opening.
Use countercuirent washing.
Recycle spent washwater.
Maximize sludge dewatering.
Parts cleaning Enclose all solvent cleaning units.
Use refrigerated freeboard on vapor de-
greaser units.
Improve parts draining before and after
cleaning.
Use mechanical cleaning devices.
Use Plastic-bead blasting.
Surface finishing Prolong process bath life by removing con-
taminants.
Redesign part racks to reduce drag-out.
Reuse rinse water.
Install spray of fog nozzle-rinse systems.
Properly design and operate all rinse
tanks.
Install drag-out recovery tanks.
Install rinse water flow control valves.
Install drip racks and drainboards.
2. What differences in measurements might be required
in different types of decision units (e.g., extraction and
agriculture, primary ^materials processing, secondary
manufacturing and product formulation, packaging/
container producers, and recycling/reuse businesses;
offices, institutions, and public agency activities; large
integrated firms versus small specialized firms)? Is
waste reduction best pursued and measured by target-
ing specific "high-risk" substances throughout, their
processes of extraction and use (e.g., chlorofluorocar-
bons, lead, and chlorine); by targeting particular stages
of the waste generation process (extraction, manufactur-
ing, commercial use, consumer use, and waste manage-
ment); by targeting particular sectors; industries, or
firms that are especially wasteful, especially hazardous,
or especially attractive for opportunistic waste reduc-
tion; or by targeting product characteristics and specifi-
cations? What measurements would help to clarify'
these priorities?1^2
Recognizing that measurement can easily turn into an end
rather than the means to the end it is supposed to be, Craig,
Baker, and Warner state "one goal- of the Agency is to
minimize the resources needed to measure progress in
order to avoid detracting from the actual implementation of
pollution prevention."1"3
Although large quantities of data have been collected
over the last decade by federal and state governments, as
well as private industry, the need to collect data on source
reduction activities and their effects on waste and release
quantities to assess pollution prevention progress has only
recently been recognized. Total reported releases and trans-
fers to Toxics Releases Inventory (TRI) chemicals were 7.0
billion pounds in 1987, 6.5 billion pounds in 1988, and 5.7
billion pounds in 1989. However, TRI does not contain
information on why releases and transfers change from
year to year and the pollution prevention information is
optional. Thus, there is not sufficient evidence to conclude
that there is a downward trend, or even that physical
quantities are decreasing. In many cases, these apparent
reductions are due to changes in reporting practices—
accounting methods, estimation procedures and interpreta-
May 1992
Volume 42. No 5
635
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tion Of the forms and instructions—rather than 'actual
physical changes in quantity. The 1988 TRI nationalI report
noted that of the 10 facilities reporting the largest absolute
decreases from 1987 to 1988, only a few of them could
actually attribute the reductions to something other than
reporting changes.11 ''-.., - i ' » u
In addition to the limitations which are particular to each
database there are other limitations to the data that apply
to most or all of the databases, that should be kept in mind
when looking at the data and the conclusions drawn from
them, such as:
I • Adjusting for production level is a complex task, and this
. adjustment is not always appropriate. Overall produc-
tion does not always influence waste quantity. For
example, rainfall and surface area may both affect water
pollution levels. Factors other than production quantity
can also influence waste quantity, and meaningful pro-
duction ratios 'can be difficult to calculate in a complex,
multi-product facility. .' .
• Increases in absolute and adjusted waste generation,
despite source reduction actions, can result if the source
reduction is applied to just one source of the waste while
other sources at the facility increase and are not subject
to source reduction. ' •
• Effects of pollution prevention projects may not become
apparent for several years, yet each of the data collection
forms only consider changes in waste generation during
the calendar year in which a source reduction activity is
implemented. Thus, the long-term value of some source
reduction activities may be underestimated. Over time
each database will have annual data over several years.
• Metering devices are not always available to measure the
quantity of waste generated, so that quantities are often
' estimated. Neither estimates nor metering devices may
be very accurate, and significant error rates are possible.
This is particularly true for nonpoint source wastes.
• Data quality in the early years of starting up a database
will not be as good as data from later years.
. • Differences in interpretation of requirements among
respondents may result in two similar facilities provid-
ing widely divergent responses to the same question.
• Changes in reporting requirements, and in respondents
understanding of them, introduce uncertainty. Some
changes in quantity reported are due to changes in the
way the wastes were measured or the accounting prac.
tices used by the facility, rather than actual changes in
the quantities generated. Substantial differences in re-
ported quantities can result from changes in definitions
of terms used in the reporting form. This can include
changes in reporting criteria, changes in regulatory -
definitions, or clarifications to instructions. ,
• A few large facilities can unduly influence aggregate
measure of pollution prevention or waste generation and
distort regional and even national trends.
• The value of throughput studies for pollution prevention
depends to a large, extent upon the use to which the
chemical of concern is put in the particular process
•under, investigation. Mass balance studies are most
useful when the chemical under consideration repre-
sents a raw-.material that is incorporated into the
product. They are somewhat1 less applicable to studying
chemicals 'that are used as reagents, and may be of little
or no use when the compound of concern is a byproduct
of the reaction.11
In observing the limitations relevant to dilute wastes
Butner emphasizes that limits of accuracy may result 'in
• measurement uncertainties that are of comparable magni-
tude to the release. "This is a very important point that
needs to be recognized in policy."104 .
Pojasek and Coli. in an excellent paper on'establishing a
workable measurement program, confirm the importance
'of the measurement issues by noting that central to debates
around implementing new pollution prevention regulations
is the requirement for companies to meet mandatory
pollution prevention goals.10* The authors state that a
"loss tracking system" is a key element in any viable
pollution prevention, program and explore various ways to
design such a system.
A typical loss tracking system:
• Uses process flow diagram as the grid system.
• Accounts for all inputs (raw materials), losses (waste),
, 'and outputs (products). \
• Interfaces with existing manufacturing, production, ac-
counting, and environmental compliance systems.
• Operates on a personal computer (PC) using a database
management system.
• Allows multiple end users to develop their own reports
and queries. . . -
This system will provide a standardized procedure for
tracking and recording material usage and various process •
losses. Data entry can be made by those who supervise the
operation of each process. Once the data have been entered,
the system can provide reports for individual plants, corpo-
rate-wide summaries, and between-plant comparisons.
The system should collect all the data needed to measure
pollution prevention progress. These include:105
• Material purchases and use by unit operation.
•• Material throughput for each unit operation.
• Generation of losses from each unit operation.
• Loss classification by medium (air or water, for exam-
, Pie). . . :
• Scrap and defective product generation.
• Recycled material.
• Production outputs. :
Karam, Craig, and Curry describe how the TRI can help
identify pollution prevenTiqft opportunities in the manufac-
turing sector. The authors first provide background infor-
mation on the TRI, highlight those TRI data elements
relevant to measuring pollution, and review some of the
limitations of the TRI. They then present four different
pollution measures, describe how these measures can be
calculated using the TRI and supplemental data as neces-
sary, and discuss how environmental managers and regula-
tors can use suck measures to target pollution prevention:
opportunities and measure progress.10*. -?'"•,?'
That the TRF is not adequate to sufficiently measure
pollution prevention is weD documented.los-ul Hearne and
Aucott very eloquently make the point and include several
example scenarios as emphases that the TRI currently
structured as a multimedia release database, is unable to
- effectively track pollution prevention progress. TRI can
only quantify changes in annual releases, which is not
comparable to pollution prevention. The U.S. Environmen-
tal Protection Agency's (EPA) proposed TRI rule changes
include critical data elements for source reduction calcula-
tions, but the proposal will still fail to provide a complete.
picture of all potential pollution prevention impacts at a
facility. This article discusses the current limitations of the
TRI and how it could be expanded into a materials account-
ing survey, which includes chemical throughput data to
measure pollution prevention. This approach could turn
the TRI into a powerful vehicle for promoting and measur-
ing pollution prevention achievements in the U.S.
The authors end with the observation that Congress and
EPA have billed pollution prevention as one of the Agency s
"top priorities for the 1990s. The Agency, in response, has
moved in the right" direction by enhancing the existing
multimedia release database to distinguish toxics source
reduction progress. But it must go beyond indirect end-of-
pipe measures in order to actively promote and encourage a
" nationwide prevention mandate. At this stage, the EPA s
most important contribution to pollution prevention would
be to transform TRI into a materials accounting system.
Bolstridge, in a paper describing the measurement data
J. Air Waste Manage. Assoc.
-------
required of generators by the Pollution Prevention Act
'PPA>, explores the wiy this data will impact environmen-
tal "programs and regulatory requirements far into the
future. She notes that while the PPA doesn't greatly
increase the number of data items on the Section 313
report, the data required provides unprecedented types of
information. Based on past experience with the Section 313
data, it can be expected that the PPA information will be
applied by a variety of users who are performing many
types of analyses for very different reasons, and highlights
that for the first time facilities will be providing informa-
tion under the PPA for public and regulatory review
concerning the amounts of chemicals involved in their
internal operations. Striking a somewhat ominous tone the
author notes that despite the lack of available guidance and
instructions for completing the first year's reports under
the PPA, the data can be expected to be extensively used in
legislative and regulatory development. "After all. Con-
gress developed the toxic chemical provisions of the Clean
Air Act, and the PPA itself, based on concerns raised by the
first of Section 313 data reported." She concludes that at a
minimum, the data can be expected to influence environmen-
tal legislative and regulatory initiatives and agendas for the
next ten years. It is essential that reporting facilities
consider what their data are saying about their operations
and their industries. The availability of information in the
computer database will greatly facilitate comparisons be-
tween facilities with similar operations, as well as within
industries, and geographic areas and facilities that do not
adequately consider the information that they are provid-
ing may find themselves at odds with other regulatory
programs, or at a loss to explain discrepancies in future
year's projections.112
Cost Effectiveness .
Is P2 cost effective? How should companies go about
determining if P2 is cost effective?
"Escalating waste disposal costs, increasingly stringent
waste reduction regulations, and heightened public aware-
ness have dramatically increased the financial burden of
waste management and pollution control on industry. To
respond to these pressures, environmental, production, and
financial managers are seeking to reduce waste generation,
and air and water pollution at the source through materials
substitution, process modification and on-site recycling."113
Thus begins a report on Total Cost Assessment, prepared
by the TeUus Institute for the Northeast Waste Manage^
ment Officials Association (NEWMOA). There is some
indication that the greatest savings opportunities are real-
ized in the years after a pollution prevention program has
heightened employee/operator awareness. As a program
matures, there are fewer pollution prevention opportuni-
ties recognized that will pay back their capital investment
within one or two years. This is the result of picking the
"low-hanging fruit." wherein improved management prac-
tices and production efficiencies have reduced the majority
of the pollutant generation.
For example, in 1988 Purcell wrote that from 1976 to
1988, "3M had saved three hundred million dollars through
waste minimization, not to mention cutting waste water
emissions by 1.4 billion gallons per year."114 Purcell also
notes that "fully one-third of those savings are attributable
to just one year—1986."L u
By 1990, 3M's net savings reached $500 million, but the
literature does not indicate that the S200 million saved
from 1988 through 1990 came about due to new projects.
These could be continuing savings from opportunities
already implemented.
Compliance with today's environmental regulations is no
guarantee against future liability. It is important to identify
responsibility centers for various wastes in order to develop
waste minimization opportunities and as a key step to
recognizing and estimating future costs. The manner in
which a firm recognizes costs is critical to the deasion-
making on whether to implement new reduction opportuni-
ties. Referring again to NEWMOA, "Pollution prevention
depends heavily on changes in the way firms invest capital
in technologies which eliminate pollution, rather than
control it after generation. When evaluating pollution
prevention investments, firms typically analyze only the
direct costs of equipment, raw material, labor, and waste
disposal. Less obvious costs associated with'waste treat-
ment, permitting and reporting, liability; and benefits from
improved corporate and product image are normally omit-
ted. By neglecting these less obvious financial impacts, a
firm may underestimate the benefits from the pollution
prevention project and ultimately reject the investment."113
In their Total Cost Assessment, NEWMOA puts forth the
convincing argument that providing capital for pollution
prevention projects pays off in longer terms. The argument
is advanced that there are "hidden costs" that firms must
recognize: "These costs are considered hidden in the sense
that they are commonly not allocated to their source—
production process or product—but instead charged to an
overhead account. Firms often omit these costs from conven-
tional project financial analysis."113
R.W. MacLean of General Electric writes that the ".rue
costs" of waste management must include .the potential for
future liability arising in several areas:
« Corrective action costs under RCRA at company-owned
(on-site) treatment, storage, or disposal facilities.
• Site remediation costs at third-party (off-site) treat-
ment, storage, or disposal facilities for which the waste
generator becomes liable under CERCLA.
« Liabilities arising out df claims seeking compensation for
bodily,injury and/or-property damage, including the
costs of legal defense.
« Liabilities arising out of claims seeking compensation for
natural resources damages, as well as the litigation costs
of these claims.115
MacLean goes on to report that "industry is becoming
increasingly sensitive to these liability issues because of the
enormous costs of Superfund cleanups.. In fact, the poten-
tial costs are large enough to concern companies even
though their waste disposal costs may only represent a
small fraction of .their manufacturing • costs. Managers
realize that their companies may bear a disproportionate
share of cleanup costs because of the strict, joint, and
several liability provisions of common law and RCRA. In
addition, the costs of remedial work, often demanded as a
negotiated precondition to property transfers during corpo-
rate acquisitions and divestitures, are skyrocketing."115
• The difficulty here is that it is not clear to what extent the
implementation of P2 strategies will truly mitigate liability,.
either for part actions or future actions. This is an interest-
ing policy frontier.1CM '
For firms seeking ways to anticipate events and to
develop an accurate decision-making process from which to
determine the true value of a capital investment in a
pollution prevention project, the literature offers the Total
Cost Assessment (TCA). A TCA is a comprehensive finan-
cial analysis of the long term costs and savings, from a
pollution prevention opportunity or R&D project implemen-
tation. TCA looks beyond short-term paybacks based on
direct costs and examines the "hidden" and liability costs
described earlier in this paper. NEWMOA describes the
features of a TCA method, "First, a desirable TCA system
encourages and helps the user to include a complete set of
costs and savings and provides the flexibility to tailor the
level of the analysis to the needs of the firm, project type,
and size.
"Second, the simpler the method, the less time it takes to
learn and use, the better. Environmental managers, project
May 1992
Volume 42. No. 5
537
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engineers and others responsible for,financial analysis of
pollution prevention projects usually have little extra time
to learn or use complicated tools. Many do not have a
sophisticated understanding of computers or financial ter-
minology. A system that requires only rudimentary com-
puter skills and basic knowledge of, financial language and
calculations will probably find greatest receptivity.
"Finally, to allow users maximum flexibility to conduct
the analysis manually or with the use of a computer, the
availability of both software and hard copy worksheets is
desirable. While computerized tools clearly introduce some
flexibility and speed, there should be options available for
those who prefer less automated methods of project
\ evaluation."113
A second"method is the EPA manual entitled, "Pollution
Prevention Benefits Manual" prepared by the Office of
Solid Waste. The EPA manual is designed to compare cost
'between various pollution prevention alternatives to a
current industrial practice through a cost hierarchy:
TierO—Usual Costs: e.g., equipment, labor,
and materials
Tier 1—Hidden Costs: e.g., compliance and per-
. mits
Tier 2—Liability Costs: e.g., penalties/fines and
future liabilities
Tier 3—Less Tangible Costs: e.g., consumer responses
: " and employee relations
The hierarchy progresses from the most conventional
• and certain costs in Tier 0 to the most difficult to estimate
and lest certain costs in Tier 3'. At each tier, the user first
analyzes all costs associated with the current and alterna-
tive P2 project and then calculates key financial indicators
of the economic viability of the P2 project. The results of
the financial calculations for each tier are added a tier at a
time, until either the result concludes that the P2 alterna-
tive meets the investment criteria (i.e., hurdle rate) of the
firm, or all tiers (0 through 3) have been completed. For
example,, if the results of the Tier 0 financial calculation
indicate that the alternative strategy meets the- firm's
investment criteria, the user may choose not to continue to
include Tier 1-3 costs. If, however, the result falls short of
the investment criteria, then the user may proceed to
calculate and add the Tier 1 results to the Ties 0 results and
soon."113 ,
Another available TCA tool is EPA's Waste Minimization
Opportunity Assessment Manual which consists pf a series
of data collection sheets and a profitability worksheet for
calculating several financial indicators. •' . ' '
The data collection sheets contain the following entries:
1. Capital costs, including: r
a. purchased process equipment
. b. materials • '.'•->••
c. utility connections
d. site preparation
e. estimated installation' . .
f. engineering and procurement
g. start-up ,
h.. training .
i. permitting " ' . '
j. initial catalysts and chemicals
k. working capital
1. equipment salvage value
2. Incremental operating costs and revenue, including:
a. waste disposal ' ' ,
b. raw material consumption
c. ancillary catalysts and chemicals ' ,
d. labor costs •"
e. maintenance and supplies •
f. insurance and liability ,
g. increased/decreased production -
h. marketable by-products
The .profitability worksheet assists the user in calculating:
a. cash flows of the investment
b. payback period • ' . '
c. annual cash flow " - '
d. present value cash flow
•"„, e. net present value
This cost analysis tool is rather simple yet comprehensive
and does not come with computer software.
One. method not evaluated by NEWMOA was designed
for the U'.S. Army. "The U.S. Army has established a policy
of achieving a 50 percent reduction in hazardous waste
generation by the end of 1992. To assist the Army in
reaching this goal, the Environmental Division of the 'U.S.
Army Construction Engineering Research Laboratory
(USACERL) designed the Economic Analysis Model for
'Hazardous Waste Minimization (EAHWM). The EAHWM
was designed to allow the user to evaluate the life cycle costs
for various techniques used in hazardous waste minimiza-
tion and to compare them to the life cycle costs of .current
operating practices. The program was developed in C
language on an IBM compatible PC and is consistent with
other pertinent models for performing, economic analyses.
The potential' hierarchical minimization categories used
EAHWM including source reduction, recovery ard/or re-
use, and treatment. Although treatment is.no longer an
acceptable minimization option/its use is widespread and
has therefore been addressed in the^model. The model
allows for economic analysis for minimization of the Army's
six most important hazardous waste streams. These in-
clude solvents, paint stripping wastes, metal plating wastes,
industrial waste-sludges, used oils, and batteries,and bat-
tery electrolytes. The EAHWM also includes a general
application which can be used to calculate and compare the
life cycle costs for mjhijfiization alternatives of any waste
stream, hazardous or lion-hazardous. The EAHWM has
been fully tested and implemented in more than 60 Army
installations in the United States.u? .
TCA offers technical assistance officials and industry
managers a perspective on pollution prevention invest-
ments beyond that offered by conventional project financial
analysis techniques. By expanding both the coverage of
costs and time frame within which they occur, TCA serves
as a vehicle for comparing current -versus alternative
pollution prevention practices over the long term. At the
same time, the process of data collection typically requires
managers to ask questions in ways whkh-add substantial
insights into where and how costs are incurred in pollution
management. This in" itself can be an invaluable step
toward understanding the components of pollution genera-
tion and management costs which typically escape standard
' engineering and cost accounting systems. '
For the readers information, the AIChE Center for Waste
Reduction Technologies is- currently reviewing proposals
for a study to determine "Estimates of the True Current
and Future Cost of Waste Emissions." This S30K study is
to summarize the various estimates already available
' through previous work and existing sources. The project is
to be initiated in April 1992.117 .
Incentives to Encourage Pollution Prevention
Assuming that pollution prevention, in lieu of more end
of the pipe controls is a good idea, what incentives should be
pursued ^to make it happen?
Heaton, Repetto, and Sobin urge that economic incen-
tives should be employed in tandem'with regulation to
encourage technological transformation. Pollution charges
that reflect the full social and economic costs of production,
consumption, and waste disposal would provide long-term
incentives for investments in clean technologies. Emissions
trading also deserves wider use.76
638
J. Air Waste Manage. Assoc.
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Levin notes that debate is already rising over the best
mechanisms; pollution fees, marketable permits, or the
negative incentives of command and control regulations all
can effect desirable changes. He goes on to suggest that
whatever incentives are adopted, they are likely to be
adopted incrementally and will supplement regulations
rather than displace them.l18
Scagnelli, in a paper that explains current legislative and
regulatory initiatives in several states, suggests a uniform
model state approach towards pollution prevention. Observ-
ing that a uniform state model is critically needed, he
suggests that goals or targets for hazardous waste genera-
tion for all industries should be pursued but such goals
should b« simply that—goals rather than statutorify or
regulatory mandated targets. States should establish grant
programs to fund waste reduction programs and provide
special technical assistance in waste minimization, includ-
ing trainingusing the resources of colleges, universities and
engineering schools. States should also establish informa-
tion clearinghouses to facilitate the transfer of technology
for hazardous waste reduction. Fees for hazardous waste
disposal on a per pound basis should be established to fund
these programs.119
The federal government can, through preferential pur-
chases, produce a significant incentive to encourage recy-
cling, and indirectly, pollution prevention. To date, the EPA
has published five guidelines, designating the following
specific items containing recovered materials for procure-
ment by government agencies:
• Paper and paper products
• Lubricating oils
• Retreaded tires
* Building insulation products
• Cement and concrete containing fly ash
EPA has established several mechanisms for assisting
federal and non-federal agencies in setting up programs and
for helping vendors market their recovered' materials to
producing agencies. These include a telephone hotline and
frequently updated lists of manufacturers and vendors of
products designated in the guidelines.120 This program
would appear to be a prototype .activity for using the
massive power of government purchasing to encourage
environmentally friendly production processes.
Bergeson and Campbell, in an excellent review of current
Congressional and EPA activity focusing on incentives,
note that in the past several years, both the Congress and
the U. S. Environmental Protection Agency (EPA) have
shown increasing interest in using incentive-type ap-
proaches to regulate the environment, either alone or
coupled with the more traditional command and control
regulations. An EPA task force has been set up specifically
to consider the use of incentive-type regulations. 121 Several
reasons underlie the increased interest in the use of incen-
tives as a means of regulating the environment. The
Congressional Research Service iCRS), a research arm of
Congress, identified three of these in a June 1989 report.122
First, the potential increase in the direct costs of compli-
ance presented by new environmental initiatives now being
considered makes the use of less costly incentive mecha-
nisms more attractive.
Second, the CRS report states that "existing regulatory
approaches appear inadequate or simply inappropriate for
managing some of the diffuse and complex pollution prob-
lems that are increasingly apparent—from toxics and pesti-
cides to global concerns about stratospheric ozone depletion
and climate alteration.
Third, the federal budget deficit makes it difficult for
Congress to authorize and appropriate funds for new
programs to address environmental problems. Incentive-
' type mechanisms may provide a source of revenue in
addition to achieving modifications of polluting activities
without a significant increase in funds.
The CRS Report found, that economic incentives will
"harness the marketplace to work for the environment,
rather than against it," because incentives "can stimulate
private firms and individuals to take actions that serve their
economic interest while fostering the goals of environmen-
tal policy."
The following incentives being discussed in Congress and
at the EPA were identified:
• Taxes, including tax credits deductions ,
» Marketable pollution privileges
• Deposits and refunds
• Information disclosure provisions
• Subsidies
Hagel concludes about using existing regulations that, "the
key obstacle to attaining greater emphasis on pollution
prevention in the permitting process appears to be doubt on
the part of permit writers and reviewers, their supervisors
and managers, and legal staff responsible for counseling
them on the limits of their duties and authority about their
standing to initiate discussions of pollution prevention as
part of permitting." Apparently more can be doae by the
EPA using its current authority to encourage P2.123
Barriers to Pollution Prevention
What "barriers" exist in the current regulatory and
cultural structure to inhibit P2?
There have been many studies to identify barriers to
pollution prevention. In fact,- in some people's opinion,
there are too many. "I don'Lwpnt to hear anything more
about the need for barrier studies."124
The question often asked is: Are there barriers to pollu-
tion prevention, and if so, what are they? There apparently
are barriers to pollution prevention, and they range from
the concrete complex issues of technology and regulations
to the simple yet abstract matters of mindsets and seman-
tics. Despite the wide array of contributing factors to the
impediment of pollution prevention progress, these factors
can be summarized under two principal barriers. There are
government as well as corporate barriers to pollution
prevention. Concerns pertaining to governmental barriers
are lodged in three primary areas: regulations, approach to
pollution prevention, and defining concepts of pollution
prevention.
According to Byers, "legislative and regulatory barriers
are still viewed by many as the major obstacles to pollution
prevention, waste reduction, and waste minimization."125
The regulations and policies that are drawing close scrutiny,
are the Resource Conservation and Recovery Act and EPA's
Pollution Prevention Policy Statement as well as others.
Smith states,. "A common criticism of environmental regu-
lations is they are so Byzantine that it is easy to go afoul of
one regulation while trying to comply with another. In
minimization, industry and government experts agree that
sometimes regulations can inhibit progress."126
Frosch and Gallopoulos echo this sentiment with the
statement that federal hazardous waste regulations often
make waste minimization more difficult than disposal.4
After taking a sampling of opinions, a more incisive look
at the regulations is in order, starting with the Resource
Conservation and Recovery Act. According to Byers, "The
Resource Conservation and Recovery Act (RCRA) regula-
tions are based on a command and control strategy, proba-
bly the only strategy which could have changed the coun-
try's waste management practices. But this strategy is
restrictive, punitive, and in the case of pollution prevention/
waste minimization, counterproductive.125
The RCRA "derived from" rule states that any material
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Volume 42. No, 5
639
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of the economic and cuhura] banners to pollution preven-
tion that exist .n the corporate sector: "These non-technical
factors include, competing production priorities, belief that
legally required pollution control is good enough, lack of
management support to allocate people's time and capital
for waste reduction, lack of rewards for successful waste
reduction, accounting systems which do not allocate total
environmental costs to production profit centers, incom-
plete data on the exact sources and amounts of environmen-
tal wastes, and the difficulty of simultaneously spending
resources on regulatory compliance and waste reduction."126
Some pollution prevention projects will require a higher •
initial capital investment than the pollution control and
treatment option. The cost advantage will accrue over time
because of improved efficiency and reduced pollution con-
trol, treatment, and disposal costs. However, the payout
time may be longer than the company typically accepts.
This can be a barrier even if the option reduces cost over the
long run. If benefits such as reduced liability and improved
image are factored in, pollution prevention projects may be
acceptable even if the payout time is unfavorable.
Sometimes the economics of the pollution prevention
project are good, but the company cannot afford the capital
expenditure, In other cases, the volume of waste generated
may not justify a large capital expenditure.130 Smith alsq
recognizes the importance of cost accounting in accurately
depicting the success of pollution prevention initiatives:
"The failure to recognize the true cost of hazardous waste
generation also impedes efforts to reduce waste. This
includes not only the inability to identify specific disposal
costs, but also the difficulty of factoring in costs from future
liability and benefits from public approval.126
Exacerbating the problems created by the inability to
accurately cost account and the lack of resources is the lack
of economic incentives discussed by Smith, "A lack of
economic incentives is closely related to lack of resources. It
raises the issue that many waste minimization projects do
not offer enough of a return on investment to warrant their
development, "For every 100 projects that could minimize
waste, maybe 10_ of them are cost effective," Benforado said.
"The other 90 will have some benefit, but they may not pay.
you back."126 Ervin ajso identifies the lack of sufficient
economic incentives for pollution prevention.131
While technology limitations and economic issues provide
bona fide obstacles to pollution prevention, cultural.issues
have a less apparent but equally insidious effect on pollu-
tion preventifcn. Cultural issues have a negative effect on
pollution prevention by spawning an inertia that paralyzes
the thought process which yield creative pollution preven-
tion solutions to waste problems. The literature recounts
many views which contribute to this inertia. Ervin states
that the sheer scope of the change needed is overwhelm-
ing,iat Smith presents a diametrically opposite view. "As
with any new idea, one of the-biggest barriers to minimiza-
tion's acceptance is simply a lack of perceived need."126
Smith goes on to point out that, "Many companies tend to
resist change, either through attitudinal blocks or through
administrative barriers."126
In an excellent overview of the subject of barriers and
incentives, the DOE's Industrial Waste Program notes the
legislation enacted by Congress to promote human health
and preserve the environment and the regulations drawn-
from them play a substantial role in motivating industry to
reduce waste, Tvpically, however, these laws (including
RCRA, CERCLA.' the Clean Air Act, and the Clean Water
Act) promote waste reduction indirectly by limiting the
options that industry previously favored. The restrictions
imposed by these laws and regulations increase waste
reduction activities much as they stimulate other actions
deemed acceptable by regulators, such as waste treatment.
Other laws, such as those enacted to protect workers or
encourage research and development, play a relatively
minor role in promoting industrial waste reduction. -32
The literature presents a convincing documentation of
the inveterate problems created for pollution prevention in
the industrial sector in the areas of technology limitations,
economic barriers and cultural issues. While pollution
prevention has a foothold in the societal awareness, these
issues and problems must be vigorously addressed if pollu-
tion prevention is to be woven into the very fabric of society.
Lite Cycle AnatysH (LCA)
What contributions can Life Cycle Analyses make to
encouraging the adoption of P2? • .
Pollution Prevention through Life Cycle Analysis, or
LCA, is a departure from evaluating waste management
(source reduction and recycling) options which look mainly
at single issues, such as recyclability or reduced toxicity. By
taking a broader view, LCA's pull all of these issues
together so that both downstream and upstream effects are
factored in. Pollution prevention can take place at any stage
in the product life cycle, and changes at any stage can have
positive or negative impacts on waste generation at other
stages. An analogous case is government programs that
have typically focused on releases to a single medium (air,
water, or land). Although designed to reduce releases to one
environmental medium, these programs can increase re-
leases to other media. For example, when hazardous waste
incinerators install air. pollution control equipment, they
may generate large quantities of hazardous wastewater.
from scrubbers.133
Other names for LCA include "product life cycle
assessment," "ecobalance," and resource and environmen-
tal profile analysis (REPA)."JTHe Society of Toxicology and
Chemistry (SETAC) defines-LCA as looking holistically at
the environmental consequences associated with the cradle-
to-grave life cycle of a process or product.136 The 3M
Company defines their life cycle approach as looking at how
waste can be reduced or eliminated starting with the point
of generation in the manufacturing operation, to its process-
ing, treatment or ultimate disposal as a residual hazardous
waste.133* At Procter & Gamble, LCA has two facets: (1)
LCA is an attitude, or a state of mind, that displays an
acceptance by manufacturers of consumer products that
they must share responsibility for the environmental bur--
den of their products over their entire lifetime—from
design to disposal, from "cradle-to-grave;" and (2) LCA-is a
quantitative tool which helps ensure that real—rather than
superficial—environmental improvements are identi-
fied. Mod EPA's definition of LCA involves examining the
environmental releases and impacts of a specific product by
tracking its development from a raw material, through its
production, and its eventual disposal.134
LCA is a "snapshot" of inputs and outputs. It can be used
as an objective technical tool to identify and evaluate
opportunities to reduce environmental impacts associated
with a specific product, process or activity. This tool can
also be used to evaluate the effects of various resource
management options designed to create sustainable sys-
tems. LCA takes a holistic approach by analyzing the entire
life cycle of a particular product, process or activity, encom-
passing extraction and processing raw materials, manufac-
turing, transportation, and distribution; use/reuse/mainte-
nance; recycling and composting; and final disposal.13S
One of the major findings of a 1990 LCA workshop held
by the Society of Environmental Toxicology and Chemistry
(SETAC) was the consensus that complete LCA's should be
composed of three separate, but interrelated, components:
(1) Life-Cycle Inventory, (2) Life-Cycle Impact Analysis and
(3) Life-Cycle Improvement Analysis. This finding is built
on the knowledge that existing LCA efforts have focused
primarily on the inventory component. Considerable re-
May 1992
Volume 42. No. 5
641
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search'is needed to develop the impact and improvement
analysis components. The research needs identiEed at the,
workshop for the inventory .component related to the
categories of data base development and methodology refine-
ment.136 " . !•<• i
Table XV summarizes some of the better known life-cycle
inventory assessments that have been conducted in the
U.S. and released to the public. „
As can be seen in Table XV, most LCA studies are usually
performed to compare different products, for example, a
plastic bottle with a glass battle. In product comparisons
such as these, the user is interested in determining which
product within a certain category causes the least amount
of environmental burden. Product comparisons like this are
mostly used for marketing purposes and for helping consum-
ers with making purchasing decisions. In comparing the
environmental burdens of two products, the results typi-
cally lead to an "apples-to-oranges" comparison. For in-
stance, one product may be a significant water polluter'
while the other takes up valuable landfill space when
disposed. Many times, local or regional concerns play a
significant part in making the choice. So, which is "better?"
Many times it is left up to the consumer to decide which
product to select. ,
A second category for performing LCA's is as a decision-
making tool for industry. Most often this is conducted by a
product manufacturer who compares the current product
to modifications to the same product. The LCA helps by
making it possible to determine if changes are in fact'an
improvement or only a shift of environmental burden from
one area to another. This type of "greening up" of products
has been used over the years by many companies, such as
the P&G's surfactant study listed in Table XV.
While many experts in the area agree that LCA's are
useful for identifying opportunities for pollution preven-
tion, without an agreed upon approach, the results are not
always consistent. In a 1990 study sponsored by Procter &
Gamble, A.D. Little found that cloth diapers consume more
than three times as much energy, cradle-to-grave, as dispos-.
ables do. But a study sponsored by the National Association
of Diaper Services reported that disposables consume 70
percent more energy that cloth diapers do. The discrepancy
can be traced largely to accounting methods. For example,
Table XV. Life cycle assessments in the U.S.
Client (reference)
Coca-Cola (140a) .
EPA(140b)
SPI U40c)
Unk-. (138)
EPA(140d) .
P&G (140k)
P&G(140d)
Unk. U40e>
P&G (-1400
Council for SW So-
lutions (140g)
American Paper
Institute U40h)
Council for Solid
Waste Solutions '
Practitioner
MRI
MRI
MRI
MRI
MRI
Franklin
Franklin
Franklin.
A.D. Little
Franklin
Franklin
Franklin
Product
Beverage Contain-
ers
Beverage Contain-
ers
Plastics •
Beer Containers
Milk Containers
Laundry Detergent
Packaging .
Surfactants
Softdrink Delivery
Systems
Cloth & Disposable
Diapers
Foamed Polysty-
rene & Bleached
Paperboard
Cloth & Disposable
Diapers
Grocery Sacks
Year
1969-
1974
1974
1974
1978
1988
1989
1989
1990-
1990
1990
1990
Vinyl Institute
Council of State
Governments
(37)
Chem Systems Vinyl Packaging 1991
Tellus Packaging 1991
the study favonng disposables counted .co-generation, as an
energy credit reducing the bottom line energy usage. The
other study did not count co-generation because it produces
air pollution.137 . • . .
Data collection is another tenuous area when performing
LCA's. Data may be unobtainable due to their confidential
nature {proprietary data) or due to lack of methodology'or
lack of resources for obtaining data. Methodologies differ
widely in their treatment of missing data.138 Fava et al.
(1991) stress that default values must not be calculated as
zero, and that for non-detectable data the detection limit
should be used as the value.136 In a review of some thirty
life cycle studies, Beruhe, et al., found many other weak-
nesses in- the use of life cycle data. They found that the
sources of information are rarely presented, except very
briefly. Furthermore, it is hard, if not impossible, to obtain
detailed basic data for the entire life cycle of each system •
studied. In such cases, more generic data, from national
data bases, industrial averages and so forth, or professional
judgments, whether validated or not with the industry
concerned, may help to complete the information. However,
in several studies, it is impossible to determine which data
comes from detailed sources and which is derived from
general sources or based on professional judgments. More-
over, it is impossible to determine whether the uncertainty •
of the data has a significant impact on the final results of
the study.139 • •
Just as there are concerns with adequate data sources,
concerns have been expressed about the method being
employed. The controversial life-cycle analysis of a host of
packaging materials, conducted by Tellus Institute, Inc.,
uses a unique weighted-averaging method that takes into
account environmental disposal costs as well as traditional
disposal costs tbMe/ermine a package's environmental
impact. This study, -Ihowever, has come under a host of
criticism mainly due to its-use of 20-year old data and
improper assumptions.1'*0 '
The Environmental Action Foundation sums up the
dilemma by pointing out that life cycle analysis is still in its
infancy. Specifically, methods developed to date do not
provide the necessary data on'iwhich to base decisions about
product choices. They go on to say that although there are
certain problems with life cycle analysis, there are also
efforts underway to improve the process.37
L€A's can be, and should be, used when assessing the
environmental profile of products. Inventory 'information
alone may be used to identify opportunities to decrease
environmental releases; energy, arid material use. This type
of internal use requires a "less'is best" approach to identify
where the data can be minimized, that is, where the amount
of pollutants or the amount of energy that is used can be
reduced. Impact analysis adds another level so that not only
are quantities evaluated, but so are their relative environ-
mental consequences. Equal amounts of Pollutant A and
Pollutant B being released may imply eqUal importance
until an impact analysis shows that Pollutant A has much
, higher health risks associated with it than Pollutant B.
Recognizing relative hazards helps manufacturers priori-
tize areas for action in order to get the best results for their
.investments. However, translating the numbers from a life
cycle inventory into human health or ecological impacts is
not well understood. It is not necessary for all LCA's to
include impact analysis. Its inclusion depends of the objec-
tives of the study and the intended use of the information.
If impact analysis is desired, it is necessary to clearly define
what is considered an impact in the context of an. LCA.
Previous impact definitions have been mixed and range
from human health risks to the effects of habitat alteration.
No consensus is yet available for evaluating life cycle
impacts.141 , -
The future direction of LCA's is certainly an upward
trend with more manufacturers realizing the need to look
642
J. Air Waste Manage. Assoc.
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at their products from cradle-to-grave. It is anticipated also
that as data become more accessible to potential users, the
cost of doing an LCA mil go down since much of the cost is
in the labor involved in collecting data. Consequently, more
users will be able to apply the LCA tool to more products.
However, members of the SETAC LCA Advisory Group—an
international panel of scientists representing government,
academia, industry, and environmentalists—say that the
assessment methods need to be further researched before
drawing conclusions about specific products. Also, assess-
ments could be misused by those seeking a market advan-
tage. The Advisory Group strongly supports the "internal"
use of LCA inventories by companies examining their own
processes in an attempt to make improvements in product
design. However, the LCA model is not developed to the
point where "external" judgment can be made about the
relative environmental impact of some processes and prod-
ucts, »M
Several offices within the U.S. Environmental Protection
Agency have been studying life-cycle methodology since
1990 m an effort to develop a uniform approach to conduct-
ing LCA's. This type of non-regulatory "standard" will
provide guidance to life cycle users as well as reduce the
tendency for studies to result in apparently contradictory
conclusions. The EPA's Office of Research and Develop-
ment, through its Risk Reduction Engineering Laboratory
in Cincinnati, Ohio( developed a guidance manual for
conducting and evaluating life=cycle inventories in October
1991. This work was done in coordination with the Office of
Air Quality Planning and Standards, the Office of Solid
Waste and the Office of Pollution Prevention. The inven-
tory manual is intended to be a practical guide to conduct-
ing and interpreting the inventory, and it provides a
template for generalizing the inventory development pro-
cess by describing a set of rules which assist in making
necessary assumptions regarding assessment boundaries,
data quality and coverage, and equivalency of use in a
consistent fashion. It as written in a manner to be useful to
a broad audience. The approach outlined in the manual is
descriptive rather than prescriptive, that is, it is not a
"cookbook." At this time, it appears that a more stepwise.
approach would require application within a specific indus-
try because the variations among different industries pro-
hibit making the generalized statements that are needed in
a precise, step-by-step method.135 The final life-cycle inven-
tory manual will be published in the Summer 1992.
With continued research into refining LCA methodology
and making life-cycle data more accessible, LCA's have the
potential of becoming a powerful tool for helping to reduce
the environmental burdens associated with a product,
process, or activity. Both manufacturers and consumers are
realizing the need to look at the cradle-to-grave environmen-
tal consequences of the products they make and use. LCA's'
are being used not only in the United States, but in several
European countries and Canada as well. An LCA will not
provide all the answers, but used along with other sources
of information, such as cost accounting, it contributes
much needed information in a comprehensive decision
process,
Management and Business
Are American business executives aware of their environ-
mental responsibilities and if not, on what basis can a
pollution prevention ethic be effectively integrated in man-
agement and business? While many engineering and techni-
cal opportunities for pollution prevention have been es-
poused and demonstrated, has it yet become a part of
business management?
"Every day, business managers make countless decisions
that affect the environment: where to locate facilities, what
types of raw materials to utilize, how to organize produc-
tion processes, even what goods to produce. But mounting
public concern over the environment has constrained man-
agers' freedom in making these decisions. Every aspect of
modern business—including financial policy, marketing,
competitive strategy, and research and development—is
increasingly influenced by environmental considera-
tions.
•142
As James Post of the Corporate Conservation Council
(CCC) notes, business decision-making invariably results in
environmental impacts. However, American corporate man-
agement has been slow to institutionalize environmental
considerations in education and training, finance (see his
paper, "Cost Effectiveness"), technology development, mar-
keting and on-the-job implementation. The CCC is particu-
larly concerned about raising awareness through training
new managers and business students, particularly through
case histories. However, the CCC notes that: "there is little
reason to' be optimistic about the level of environmental
awareness exhibited by newly trained managers. The Corpo-
rate Conservation Council's survey of business schools
showed that they have paid little attention to natural
resource and environmental concerns. Indeed, it is a rela-
tively rare program that offers even a few environmental
examples among the hundreds of company case studies read
and discussed by business students.""2
The CCC recommends several approaches to remediate
the situation through: the appointment of* a Presidential
Commission on Environmental Education; a federal Omni-
bus Environment Education Bill; use of government Envi-
ronmental Enforcement Agencies to provide information
materials; solicitation of support from educational founda-
tions; and enlistment of environmental advocacy groups as
partners in the education of corporate managers.
While education of business students is a critical compo-
nent in establishing environmental ethics for the future
corporate America, an important question is what can be
done to integrate environnientalism into current executive
decision making. As is noted elsewhere in this review, cost
savings has been used as the driving incentive to implement
a pollution prevention method, albeit typically requiring
short payback periods in order to attract capital invest-
ment. Ann Rappaport of Tufts University concurs that
although "(t)he practice of pollution prevention among
corporations is growing,... existing practice falls short of
what is technologically feasible and environmentally and
economically desirable."143
Educational opportunities exist in many areas. Several
universities are designing environmental modules into
undergraduate engineering curriculum and establishing
graduate degrees in the area. The EPA has established the
National Pollution Prevention Center with the University
of Michigan, charged with developing pollution prevention
-curriculum for undergraduate programs, including busi-
ness schools. Other nonprofit groups such as the Center for
Hazardous Materials Research (University of Pittsburgh)
have been providing training workshops and seminars.
Also, the Management Institute for Environment and
Business has published a reader as a supplement to an
existing survey course in Production and Operations Man-
agement.
.Does educational opportunity necessarily result in pollu-
tion prevention progress within established commercial
enterprises? The lack of literature detailing any refinement
of environmental values with traditional management struc-
tures suggests not. Education is necessary to train future
managers, but their values would not be sustainable against
corporate or institutional disinterest. To date, the litera-
ture shows scattered progress in implementation of pollu-
tion prevention alternatives, examples of which are pre-
sented throughout this paper. These case histories invariably
exhibit short payback periods, demonstrating general corpo-
Volume 42, No. 5
643
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rate commitment to reducing costs and liabilities, and not
to long term, environmentally benign management.
Since it is difficult to find standard industrial and mana-
gerial approaches to pollution prevention, it may be better
to shift the discussion to examine the influences 'that may
move corporations toward developing and transferring
pollution prevention technology. -
Rappaport draws two important conclusions that focuses
our understanding of corporate behavior on this issue:
"Pollution prevention developments from product redesign
or reformulation occur when multiple interests within the
organization are identified, and motivated to work together.
It is unrealistic to expect that pollution prevention will
drive product redesign or reformulation in the absence of
other strategic or competitive gains. The challenge for a
company is to develop a general system, such as total
quality management, that seeks continuous improvements
in products and searches for pollution prevention opportu-
nities each time changes are made to products and pro-
cesses. ' -.. • , '
Opportunities for capturing the "low hanging fruit" in
pollution prevention, the common sense or improved mana-
gerial actions, may continually emerge as the company's
products and processes change. The view of progressing up
a hierarchy of pollution prevention stages may -actually
result in lost opportunities if companies fail to seek contin-
• uous improvement in all aspects of pollution prevention,
particularly as product modifications may open up new
opportunities for improved management, or common sense
actions."1'43 , ,
Despite the growing environmental awareness of Ameri-
can executives, establishment of pollution prevention as an
integral part of quality management is still lagging. Univer-
sities and business schools have crossed the threshold to
developing education modules, which will have positive
effects for the future. The challenge today is to move
, industry, perhaps through trade associations or particu-
larly pro-active corporations to re-evaluate corporate Stan-.
dards of decision-making in terms of strategic and competi-
tive values. Once convinced of the efficacy of such values
and implementation of Total Cost Assessments for capital
investment, corporations might break down institutional
barriers that block technology development and implemen-
tation. •'.-•. - •
Product Design . ,
• Can products be designed to enhance pollution preven-
tion and recycling? -'
As discussed above, concern for reducing environmental
. effects of technology has moved in recent years up'the
process line from end of pipe waste treatment and disposal
to source reduction and recycling of hazardous waste and,
more recently, multimedia pollution prevention. This mo-
mentum in the direction of increasingly early stages of
production continues with current, efforts to conceive of,
design and develop products and processes which are more
environmentally compatible. As Eekles has pointed out,
environmental effects are largely fixed at design and thus
waste prevention should start during design.144
There seems to be a consensus growing among design
engineers and industrial designers that environmental
.considerations must become inherent in product and pro-
cess design. The Summer 1990 issue of Innovation: The,
Journal of the Industrial Designers Society of America14*11
was devoted entirely to environmental design. In an article
by Steinhilber, an industrial designer and member of IDSA,
the author relates his response to an interviewer who had
asked whether industrial designers- should really concern
themselves with environmental. issues. Steinhilber's re-
sponse was, "Only" if we're concerned about the survival of
the planet." . .
Many strategies for environmental design have been
developed. These strategies incorporate traditional design
criteria for meeting functional requirements at low cost,
while adding environmental considerations to the criteria.
The environmental components of these strategies can be
thought of as falling on a continuum that begins with the
very limited and specific, such as design for recyclability,
disposability, or remanufacturability, and ends with a
comprehensive, life cycle design strategy.
Single Criterion Design, Design fpr~X (DFX). Some of the,
single dimension environmental issues that have been the
objective of environmental design and a listing of references
include:
Design Objective
Disassembly
Recyclability
Remanufacturability ,
Reliability
Durability
Process waste minimization
References
145-147
14S-159 '
160-165
166
167-171 .
172-176
An example of a single criterion design is that described
by Ahlert177 jn which he proposes a mass balance oriented,
method for process waste minimization—designing hazard-
ous waste out of industrial, especially chemical manufactur-
ing processes. He states that the design goal of eliminating
hazardous waste from the process does not differ substan-
tially from traditional design goals of high yield and product
purity and performance at maximum net profit.
Two other examples of the use. of relatively limited
environmental design strategies are the design for disassem-
bly and recyclabijfttf goals that are becoming important in
the automotive ana appliance industries, in Europe and
perhaps soon in the U.S. Holusha189a reports on the
German trend to produce automobiles and appliances that
are'more easily recyclable and disposable, partly through
uniformity in plastic resin use, use of non-toxic materials
and an increase in ease of disassembly. Stix178 supports this
in his article about the Volkswagen auto recycling plant in
Leer, Germany. Germans already recycle about 75 percent
of the material'in cars, either as scrap metal or as refur-
bished second hand parts. Mixed plastics parts replacing
steel parts are becoming problematic as they,are more
difficult to recycle. To solve this problem the auto industry
has begun to stamp plastic parts with a government code
which identifies the specific resin used, thereby improving
recyclability. VW has also begun to redesign using fewer
parts to increase reusability. An example given by Stix is
the redesign of the plastic fuel tanks used in the. VW Golf;
the new design has 11 fewer parts than the old design.
Design for Life Cycle. In contrast to single or limited
dimensional environmental design strategy, life cycle de-
sign assumes no single approach to be appropriate for all
projects. Instead, selection of the best strategy or combina-
tion of strategies is based on satisfying life cycle design
requirements. Effective strategies for life cycle design can
only be developed after project objectives have been refined
and characterized. The specification of design requirements
is the most critical step in achieving risk and environmental
impact reduction. An excellent discussion of the central role'
of requirements formulation and the needs analysis is
-contained in Cause and Weinberg179 and Oakley,180 al-
' though they do not treat environmental requirements
directly. Brown181 also discusses this key aspect of design
from a corporate perspective..
The net effect of the product life cycle is the consumption
of resources and the conversion of these resources into
residuals which accumulate in the earth and biosphere. Life
644
J. Air Waste Manage. Assoc.
-------
cycle design s*eks,only to optimize the resource efficiency in
this system since a completely environmentally friendly
product does not exist. Key principles of life cycle design
are;
• Recognition of all activities involved in product and
process design from extraction of raw materials to the
ultimate fate of residuals.
* Inclusion of environmental requirements at the earliest
stages of product development.
• Cross-disciplinary development teams.
• Recognizing environmental impacts as a measure of
quality,
U.S. EPA's L
-------
dissecting the TUR debate. The term is often used inter-
changeably with source reduction, waste minimization and
pollution prevention. But the key point to realize-about
TUR is that it focuses on the use of toxic chemicals and not
on the waste associated with their use." Smith continues to
say '-'the central part of the -argument about TUR is that
industry rejects the premise that using less .toxic com-
pounds will necessarily result in less waste, whereas envi-
ronmentalists accept this premise wholeheartedly."191
Smith provides many of the viewpoints of industrial
experts in the TUR debate. Smith says "companies have
been waging a major attack on the concept with fact sheets,
position papers, and speakers aplenty. Industry is doing its
best to, convince Congress that mandated TUR could put an
end to life as we know it." Smith cites a position paper by
the Chemical Manufacturer's Association written as testi-
mony on Baucus's RCRA bill, S.976. It states "If laws are
adopted that randomly curtail or eliminate materials that
happen to be toxic, the ripple effect would be gigantic.
Products that help feed, clothe and house us may no longer -
be available or may come at dramatically higher prices.
TUR mandates could deprive us of products that heal,
protect and transport us."191 •
' Part of the confusion in the debate appears to be whether
government is considering voluntary or mandatory TUR. If
government is give.n the authority to set mandatory reduc-
tion goals, it brings up the issue of their expertise: how can
regulators hope td~ offer useful process advice to all of
industry with its tens of thousands of processes? Smith
cites industrial experts from Dow, Monsanto, CMA, SOCMA,
and others to present many of the concerns on this impor-
tant issue.191
Besides the proposed TUR legislation at the federal level,
there are several states that have enacted strong TUR laws.
In 1989, Massachusetts enacted the Toxics Use Reduction
Act. Roy and Dillard notes the definition of TUR in the act
as: "in-plant changes in production processes or raw mate-
rials that reduce, avoid, or eliminate the use of toxic or
hazardous substances or generation of hazardous by-
products per unit of product, so as to reduce risks to the
health of workers, consumers, or the environment without
shifting risks between workers, consumers, or parts of the
environment." By-products are defined as all non-product
outputs of toxic or hazardous- substances generated by a
production unit, prior to handling, transfer, treatment, or
release.192 - -.
Roy and Dillard note that the goal of the act is to reduce
the use of toxic and hazardous chemicals in Massachusetts
and to slash the amount of hazardous waste industry
generates by 50 percent over the 10 year period 1987 to
1997. The Massachusetts law includes chemical use report-
ing, numerical goal setting for use reduction, a toxics users
fee, technical assistance, R & D, and also provisions about
company trade secret protection. Through a council on
TUR, the law encourages coordination of all state regula-
,-tions and reporting and programs concerning toxics. In
addition the law creates an advisory board and develops a
licensing program for TUR planners who wish to consult
businesses.
The Blackstone project has been an important model on
measuring ,TUR on a state-wide basis. Roy and Dillard
describes the objectives of the project that includes evalua-
tion of 28 metal intensive manufacturing facilities located
in the service area of the Upper Blackstone POTW near
Worcester, Massachusetts. The data acquired under this
project was reviewed in a report by Tufts University
(Harriman et al.) that attempted to identify and evaluate
available measurement methodologies for tracking progress
in TUR and recommended methods that .the state environ-
mental agency (DEP) can use to meet its'needs.192-193
Wise and Gray reviewed the TUR issues in the newly
enacted New Jersey Pollution Prevention Act. The act
defines TLTR and how it will be measured. Wise and Gray
note that the act attempts to distinguish between source
reduction and recycling and the current TUR and source
reduction programs. The act says "source reduction focuses
strictly on activities undertaken during the production
process to eliminate or reduce the Ipss from the process of
i .the hazardous materials being used. When hazardous mate- •
rials leave the production and support processes and are of
no further value to that particular operation, then they
become hazardous wastes. Like source reduction, these
toxics are reduction encompassing activities undertaken
during production. Although the methods for achieving
toxics use reduction and source reduction are similar, TUR
or elimination of the initial use of the chemical is more
comprehensive than the pure waste focus or source reduc-
tion. TUR is intended to encompass all three destinations of
a substance in a production process: in the product, in
wastes, or losses from the process, or consumed 'by a
chemical reaction with another chemical.'.'194
Like New Jersey and Massachusetts, a handful of states
are pioneering new TUR programs designed to prevent the
array of potential hazards with the use of toxic chemicals.
These states are attempting to pave the way for passage of
TUR laws on the federal level (i.e., Baucus and Sikorski
bills) which may set in motion a TUR program on a national
level. This will be bothersome to industry depending on
which direction the TUR legislation goes.
Research Ne«ds
A topic that continues to generate attention from the
technical commui^itj^is what research is needed to further
the advancement bfpollution prevention in the U.S.? '
The EPA Science Advisory Board has stated, "the EPA,
should1 shift the focus of its environmental protection
strategy from end-of-the-pipe controls to preventing the
generation of pollution," but though it recommended the
EPA's R&D budget be doubled over.the next five years and
that a portion of this budget go-to pollution prevention, it
was not very specific.2
Cohen and Allen, in describing an integrated research
effort aimed at addressing long term research needs, pro-
pose a useful structure for viewing research needs. They
note that waste minimization for industrial processes is
evolving, with at least three generations, of activity appar-
ent. Initially, waste minimization programs focussed on
good housekeeping practices, inventory-control and minor
changes in operating practices. This generation of waste
minimization resulted in impressive reductions of waste,
but the methods are rapidly reaching their limits. A second
generation of waste minimization is underway. In this
second generation, current technologies are being used to
modify processes, reducing effluents. These retrofit opera-
. tions employing current technologies will also reach their
limits, howfever, and a third generation'of waste minimiza-
tion activity is inevitable. In this third generation, highly
selective separation and reaction technologies, specifically
designed for waste minimization applications, will be em-
ployed. Further, new methods for process synthesis will be
developed which minimize effluents (maximizing mass effi-
ciency), evolving in the same way as energy efficient process
design methods.
They then propose a sequential program that has as its
three primary elements:19**
«_ Identification of target stream.
• Development of design objective and process synthesis
methodologies for waste minimization.
646
J. Air Waste Manage. Assoc.
-------
Development ol New Unit Operations for Waste
Minimization.
Licis, the EPA project officer for a study to identify
industrial research opportunities concluded that, for the
industries investigated as part of this study, seventeen'were
identified as ones with wastes with significant potential for
environmental impact and ones for which opportunities
tend to exist for waste and/or toxicity reduction. The
following recommendations emphasize those industry ar-
eas.
Seventeen Priority Industry Segments:
• Textiles; recovery of dyes and scouring agents from
wastewater,
• Wood preserving: investigations of new, less toxic preserv-
ing agents.
* Pulp and paper: improved recovery of- coated stock;
restoration of fiber strength in recycled paper; process
changes-improvements.
• Printing: minimization in pre-press photographic chem-
istry through the use of computer technology; solvent
recovery.
• Chemical industry: solvent reuse, substitution.
• Plastics: segregation of scrap plastics; compatibility.
* Pharmaceuticals: solvent reuse, substitution.
• Painting: low and non-VOC painting techniques; im-
proved application technology.
• Ink manufacture: low and non-VOC inks; elimination of
metallic pigments.
* Petroleum exploration • refining: improved recovery of
usable oil from drilling mud and processing wastewater.
• Steel industry: reuse of tar decanter sludge and electric
arc furnace dust; reuse of recovered calcium fluoride.
• Non-ferrous metals: isolation of arsenic contamination
to allow reuse of stack dusts; improved hydrometallurgi-
cal processes minimizing sulfur oxide emissions.
« Metal finishing: non-cyanide plating systems; improved
chemical recovery from cyanide plating processes.
• Electronics: "clean" fabrication techniques that elimi-
nate or minimize degreasing solvent use.
* Automobile refinishing/repair: reductions in solvent
losses in various operations.
* Laundries/dry cleaning: improved solvent recovery.
"Within each industrial segment considered a priority area,
there are one or more concepts, problems, or opportunities.
H is recommended that, with further refinement and
updating, these can serve as one basis for the development
of EPA research projects for the future."l95
A survey of some 38 research organizations in the U.S. on
their ongoing R&D in hazardous waste management found
that only 28 of a field of 529 projects could be described as
waste reduction. The results of the survey are shown in
Figure 2.196 Such a survey does not provide much support
to a contention that the R&D community is increasing its
focus on pollution prevention.
The EPA, in a March 1990 Report to Congress entitled
"Pollution Prevention Research Plan," outlined six goals
, for its pollution prevention research program:
1. Stimulate private sector development and use of prod-
ucts that result in reduced pollution.
2. Stimulate private sector development and implementa-
tion of technologies and processes that result in re-
duced pollution.
3. Expand the reusability and recyclability of wastes and
products and the demand for recycled materials.
4. Identify and promote the implementation of effective
'socioeconomic and institutional approaches to pollu-
tion prevention.
5. Establish a program of research that will anticipate and
address future environmental problems and pollution
prevention opportunities.
6. Conduct a vigorous technology transfer assistance pi o-
gram that facilitates pollution prevention strategies
and technologies.
"Achievement of these goals requires a research program
that covers six major" program areas: (1) product research,
(2) process research, (3) recycling and reuse research, (4)
socioeconomic and institutional research, (5) anticipatory
research, and (6) technology transfer and technical
assistance."197 f f
A very useful compilation of specific research needs is
reported in Table XVI by DOE's Industrial Waste Reduc-
tion Program. This information resulted from a conference
held in July 1991 in which representatives of member
companies of the AlChE's Center for Waste Reduction
Technologies identified priority waste reduction opportuni-
ties.198
In a study commissioned by the U.S, DOE's Office of
Waste Reduction, the authors found that the consensus of
all interviewees was that a federal role in a research
program to develop .waste minimization technologies was
Project Category
BIOLOGICAL TREATMENT
TRANSPORT/FATE!
RISK ANALYSIS
PHYSICAL/CHEMICAL
THERMAL TREATMENT
REMEDIATION TECH
WASTE REDUCTION
RECOVERY/REUSE
SAMPLING/MONITORING
POLICY ANALYSIS
EDUCATION
WASTE CHARACTERIZATION
SOLIOIF/STABIL
LANDFILL DESIGN
WASTE MGMT MODELS
FACILITY SITING
Total Numtwr of Protests * S3*
Number of Projects
Inventory from Ml«ct»d c»nt«rt In U.S.
Figure 2. Research and development projects (1990),
May 1992
Volume 42. No. 5
647
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essential However, they were quite careful'in defining that
rote, The federal government should not develop technolot-
gies that are specific to a particular industry, even if the
impact on pollution prevention is significant. Rather, it
should carefully craft a set of applied research programs
that are generic in nature. The results of this applied
program could then be utilized by a broad range of indus-
tries to develop pollution prevention strategies relevant for
specific plants and processes. The study further identified
major generic research issues that would be beneficial to
waste minimization technology development programs.
Those areas are:
• The development of process technology to replace poten-
tially toxic chemicals such as halogens in the pulp and
paper industry and in other industrial processes using
solvents.
• The development of corrosion-resistant, biodegradable,
and more durable materials. These materials should use
environmentally benign raw materials in the manufac-
turing process, and their disposal or recycling potential
must be environmentally sound.
• The recovery of dilute contaminants in high-volume
waste streams, which is critical to many recycling and
waste remediation processes. Innovative separations
technologies are essential to achieve this cost-effectively.
• The implementation of sensors and process control
technologies to improve efficiency and reduce waste
generation. ~
• The development of technologies to recover value-added
products from industrial wastes and used products.
Technology to recover mixed plastics, process sludges,
waste acids, spent catalysts, and metal-bearing waste
streams are important research areas.
• The implementation of more selective process technol-
ogy that reduces wastes by reducing (1) raw material
inputs, (2) energy inputs, and (3) waste generation. This
selectivity can be gained through the use of more
selective catalysts or through the use of process design
tools for optimizing process conditions.199
P2 Training and Education
How can (should?) the educational culture and establish-
ment be modified to incorporate pollution prevention consid-
erations into curricula development?
As pollution prevention continues its progress towards*
becoming a dominant strategy for industrial and regulatory
environmental effort, it is clear that the educational back-
ground required of environmental professionals and deci-
sion makers must change. Universities and institutions
charged with educating the next generation of decision
makers, and training institutes responsible for providing
more short-term pragmatic training courses must change.200
How much of this is happening and how much more needs
to happen is the subject of much discussion.
Allen and Bakshani found from a survey of pollution
prevention education at universities in the U.S. that:
1. Although pollution prevention education is occurring
in a large number of academic disciplines, it is heavily
concentrated in engineering departments, particularly
chemical and environmental engineering. The survey
indicates 16 percent of the chemical engineering (Ch.E.)
departments (25 out of 155) are active in pollution
prevention education or roughly 20 percent of the 3,712
Ch.E. graduates (class of 1990) were exposed to pollu-
tion prevention at some level.
2. Even in disciplines where pollution prevention educa-
tion is concentrated, it tends to be taught as a special-
ized senior elective or graduate course, rather than as
an underlying principle that is part of the core curricu-
lum.
3. Pollution prevention education is rare in the socoal
sciences and liberal arts.
4. Most pollution prevention curriculum development is
being done by individuals or small groups, in isolation,
at their home institutions.
5. Comprehensive pollution prevention and environmen-
tal education efforts have emerged at a few universities.
Most of these efforts are associated with research
centers. .
6. The definition of pollution prevention varies widely.
The lack of consensus on the meaning of pollution
prevention means that there is no general agreement
on the elements and intellectual content of pollution
prevention. This lack of definition will hinder the
transfer of curricular materials among universities.200
Shen proposes to stimulate discussion of current and future
needs through a broad-based approach to promote environ-
mental education and training in the principles and practice
of multimedia pollution prevention. He states "the chal-
lenge is how to integrate air-water-land pollution manage-
ment through waste prevention prior to the application of
waste treatment and disposal techniques." Shen suggests
that an education and training plan for multi-media pollu-
tion prevention may be divided into technical and non-
technical areas. Cross-disciplinary training must be avail-
able for them to understand the importance of multimedia"
pollution prevention principles and strategies, as well as to
carry out such principles and strategies.
Environmental professionals dedicated to multimedia
pollution control also need to have a broad education and
sound understanding of:201
1. Characteristics of pollutants in waste streams.
2. Cross-media natur^ df the movement, distribution,
fate, and effect of pollutants that have entered the
environment.
3. Coordinated management or gaseous, liquid, and solid
wastes so problems are not shifted unduly from one
medium to another.
4. Use of source reduction and recycling prior to waste
treatment and disposal.
5. Environmental impact and cost-effectiveness of solu-
tions.
6. Intelligent and automated information and data man-
agement systems.
7. Role of ethics in decision-making.
8. Societal system such as current environmental laws
and regulation.
9. Environmental sociology, public relations, and commu-
nications.
10. Use of risk assessment and management tools. •
To facilitate .the incorporation of pollution prevention
thinking into engineering curricula, Allen, with support
from the EPA, the American Institute for Pollution Preven-
tion and the Center for Waste Reduction Technologies of
the American Institute for Chemical Engineers has devel-
oped a very useful set of homework and design problems.
The set contains 21 problems for the following six areas:202
• Life cycle analyses
• Identifying and prioritizing pollutants from industrial
sites
• Selecting environmentally compatible materials
• Design of unit operations for minimizing waste
• Economics of pollution prevention
• Process flowsheeting for minimization of waste
Friedlander notes, in supporting the incorporation of pollu-
tion prevention principles into the engineering curriculum,
that industry faces the challenge of satisfying societal needs
while meeting ever-tightening regulation of environmental
side effects. This calls for new approaches in engineering
May 1992
Volume 42. No. 5
649
-------
design, basic research, and education. Chemical engineers
have a vital role to play in this effort. In plant design, there
is a growing emphasis on waste reduction (pollution preven-
tion)" rather than end-of-pipe treatment and disposal. But
waste reduction needs a fundamental conceptual base to
facilitate research and teaching; this conceptual; base is still
being developed. Innovative approaches to consumer prod-
uct design are required, especially for items widely dis-
persed throughout .society. Engineering education should
incorporate environmental constraints into the routine
design procedures of existing engineering disciplines. The
environmental consequences of technology and the basis of
the regulatory standards should be part of the engineering
curriculum.203
Kirsch and Looby report on a creative educational pro-
gram to actually have engineering students working in
small generator's facilities. In 1988, University City Sci-
ence Center began a pilot project to assist small and
medium-size manufacturers who want to minimize their
, formation of hazardous waste, but who lack the in-house
expertise to do so. Under agreement with the Risk Reduc-
tion Engineering Laboratory of the" U.S. EPA, the Science
Cenfier established three waste minimization'assessment
centers at Colorado State University, the University of
Tennessee in KnoxvUle, and at the University of Louisville.
.Each waste minimization assessment center is staffed by
engineering faculty and students who have considerable
direct experience with process operations in manufacturing
plants and who also have the knowledge and skills needed
to minimize hazardous waste generation. The waste minimi-
zation assessments are conducted at no out-of-pocket cost
to the client. Several site visits are required for each client
served. The waste minimization assessment centers' staff
locate the sources of hazardous waste in each plant and
identify the current disposal or treatment methods and
their associated costs. They then identify and analyze a
variety of ways to reduce or eliminate the waste. Specific
measures to achieve that goal are recommended and the
essential supporting,technological and economic informa-
tion is developed. Finally, a confidential report which
details the waste .minimization assessment center's find-
ings and recommendations,'including cost savings, imple-
mentation costs, and payback times is prepared for each
client manufacturer.204 •
Foecke provides an overview of training primarily from a
state perspective. He observes that whatever the thrust of a
state's training activities in pollution prevention, some
basic ideas and approaches seem to hold consistently across
many state efforts. Three basic types of subject matter for
pollution prevention training can be found in current
efforts. Introductory training is being performed in the
widest variety of venues for the widest variety of audiences.
Industry-specific or process-specific training is seen as
critically important, but lags a bit for want of proven
• material. Assessment training is currently rather special-
'ized, but may be'gaining ground as a powerful tool for
rooting pollution prevention attitudes deeply within organi-
zations. , ,
Introductory training in pollution prevention can more
aptly be described as education, in the sense that this kind
of training does not impart skills so much as jt attempts to
inform, persuade, promote, or encourage, in various mea-
sure, about pollution prevention. :
Industry specific and process specific training: is instruc-
tion tailored to a particular industry or process. Assessment
training principally concerns itself with preparing individu-
als to review facilities, identify pollution prevention op-
tions, and, in some cases, assist in the implementation of
those options. Nearly every state pollution prevention
program has a training component as part of its charter to
promote pollution prevention, and all are increasing'their •
activity in this area as training tools are developed.
Training for pollution prevention is stilf at an early stage
of development at the state level, but rapid progress is being
made. All parties agree that training is important, and
issues of technical content, approach, evaluation, and appli-
cability are being resolved as experience is accumulated.
State-level training activities have the advantage of being
close to their aydiences and their needs, which leads to
well-focused and appropriate training products.205
The EPA has published a report, "Pollution Prevention
Resources and Training Opportunities in 1992," which lists'
a wealth of sources for pollution prevention training.206
Conclusions'
1. Terminology. The term "pollution prevention'' is
currently the most popular term in the U.S. for
describing those strategies and technologies that re-
duce the generation of pollutants at the source. How- •
ever, the term waste minimization will continue to be.
used,, especially for discussions of RCRA hazardous
waste streams, and waste reduction will continue to be
used since DOE and the AIChE Center for Waste •
Reduction Technologies prefer this term. Also, fur-
ther terminology changes to more" positive terms like
sustainable growth and total resource management
will probably occur.
2.. In industrially developed countries like the U.S., there
are usually bottom line savings realized by pursuing
pollution prevention strategies, especially if, long-term
liabilities for possible clean up actions can be taken
into consideration. However, in the short term, many
of the potential savings are dependent upon a strin-
gent regulatory program being in place to discourage
cheaper, fe*t hot as environmentally friendly treat-
ment and cEsfWsal options being pursued. It should be
emphasized that there are usually other cost effective
waste management strategies that do not fit the
narrowdefinition of pollution prevention. These should
not be overlooked by a too rigid adherence to the waste
management hierarchy.
3. While\ there are those who persuasively point out
deficiencies in current federal P2 efforts, it is con-
cluded that the federal government is promoting
pollution prevention. The EPA has undertaken a wide
range of creative approaches such as the 33/50 pro-
gram, the Pollution Prevention Research program,
: and the Green Lights program. The Executive Agen-
cies appear to be carrying out .the intent of the
Congress, as outlined in the Pollution Prevention Act
of 1990. However, given the continuing wide discrep-
ancies of federal funds being allocated to clean-up
activities relevant to pollution prevention activities,
we can only conclude that the EPA's funding decisions
• do not represent much adherence to the waste manage-
ment hierarchy. Programs within the Department of
Defense and Department of-Energy can be cited as ,
model activities.
4. State pollution prevention programs continue to ex-
pand and provide ideas for encouraging pollution
prevention that the federal government should re- •
main aware of. The requirement by several states for
"facility plans" that outline an industrial facility's
pollution prevention program is notable. The incorpo-
1 ration of such requirements into national legislation
.will have an enormous effect on reducing generation
rates throughout the country. There is also a need for
model P2 state legislation to remove interstate incon-
sistencies.
5- Active local pollution prevention programs seem to be
the exception rather than, the rule. There are several
/ in California that report successes. An obvious area
that local programs can become involved is around
publicowned and operated treatment works (POTWs),
650
J. Air Waste Manage. Assoc.
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6 Many European countries have pollution prevention
programs, and some of these programs 'are more
supportive of P2 than U S. programs in that there are
more direct subsidy programs to facilitate the adop-
tion of environmentally friendly technologies. The
whole area of pollution prevention appears to be an
area that could be used as a mechanism to strengthen
international bonds and commitments to improve
world-wide environmental quality.
7, There is no shortage of successful impressive indus-
trial pollution prevention programs. The literature is
full of reports from primarily large companies on their
impressive results. Some authors believe that much
more can be done, especially in reducing toxics.
8. Based on the preponderance of case studies cited in
the literature, the area with the most potential for P2
returns for small manufacturers appears to be replac-
ing organic-based solvents with either less toxic sol-
vents or aqueous-based cleaners.
9. Achieving zero discharge, at least for hazardous wastes,
is possible in selected industries. Those searching for
solutions to waste discharge problems should not rule
out obtaining a zero discharge without at least consid-
ering the possibilities. It should be recognized how-
ever that a price for zero discharge may have to be paid
in increased energy consumption.
10, How does one measure pollution prevention is the
biggest P2 issue currently facing the industrial commu-
nity. Using the TRI reports is inadequate, but it is
currently the best alternative. Establishing and facili-
tating the acceptance of a credible system for measur-
ing P2 on a micro and macro basis should be of the
highest priority to those charged with getting P2
strategies adopted nationwide. Also it is important
that participants in the measurement issue resolution
maintain clarity on the difference between "internal"
measurement techniques to provide necessary informa-
tion to the facility and "public" measurement tech-
niques to provide information to the surrounding
public. Industry must be involved as an active partner
in this'effort.
11. A P2 project's cost effectiveness depends on what
alternative costs are considered. The Total Cost Anal-
• ysis discussed in the body of the review offers a useful
approach for determining this.
12. Concerning barriers to P2 implementation, the litera-
ture presents a convincing documentation of problems
created for pollution prevention in the industrial
sector in the areas of technology limitations, economic
barriers and cultural issues. While pollution preven-
tion has a foothold in the societal awareness, these
issues and problems must be vigorously addressed if
pollution prevention is to be woven into the very fabric
ofsociety.
13. There is quite a difference of opinion on whether, or
even if, incentives are needed to encourage pollution
prevention. One incentive, preferential purchasing by
government to encourage the adoption of pollution
prevention strategies did have considerable support.
More information is needed before endorsements of
other approaches could be given by the reviewers.
14. The literature presents a convincing documentation
that existing environmental regulations in too many
instances inhibit the adoption of pollution prevention
strategies. There are suggestions for improvement.
However, at a minimum, regulatory agencies may
have to relax the rigidness of some media specific
regulations if we are to realize the benefits of the
increased adoption of long-term pollution prevention
solutions. Also, a little more stability in the regulatory
environment would be useful. An uncertainty in plan-
ning assumptions is almost always a disincentive to
action. Industry intransigence is associated in the
literature as an impediment to the adoption of pollu-
tion prevention strategies.
15. Life Cycle Analyses (LCAs) have the potential of
becoming a powerful tool for helping determine the
environmental effects of manufacturing, using, ano*
disposing of products. However, work is needed to
improve the practicality of the technique and reduce
the rather exorbitant cost involved with carrying out
an LCA. This is definitely an idea that has a great
future in environmental decision making.
16. Regarding pollution prevention assessments, there
are many excellent guidance manuals available. It is
an apparent general truism that a company's taking
the time to carry out assessments usually identifies
opportunities for reducing wastes and saving money.
17. Designing pollution prevention considerations into
products is a very popular topic within the environmen-
tal community and within certain industries. There is
an evolving appreciation within the design community
of the importance of environmental considerations.
This is a veiy important area that will generate
continuing interest throughout the world.
18. States are passing toxic use reduction legislation that
may be paving the way for federal legislation. There is
not 'much information to determine if this is the best
way to go. Some evaluations of recently implemented
state programs are needed.
19. The question .of research-needs is very source specific.
Undoubtedly the development of cleaner technologies
and processes will lead to improved environmental
quality. Clean product research, i.e., research to de-
velop products that cause less environmental prob-
lems both in their manufacture and use should receive
a high priority. Tips will involve a refocusing of much
of the largely process oriented research being cur-
rently supported.
20. Pollution prevention is slowly being incorporated into
the higher education culture. However, it appears to
be mostly in the engineering curricula. Programs to
modify other higher education programs (public policy
programs, business schools, and design programs)
may produce more benefits in the long run.
21. There is a need for the utilization of better informa-
tion technology for moving P2 information from place
to place, making it easily accessible and useful. Cur-
rent efforts in this area, while commendable, are
falling short. ' •
Futyre Projections
There is an apparent commitment on the part of the
private sector and on the part of the environmental move-
ment and the regulators to pursue pollution prevention and
sustainable development options for solutions.11'131-209
There are elements of pollution prevention in the new
Clean Air Act Amendments and there will be more empha-
sis on pollution prevention and waste minimization in the
reauthorized RCRA.207
It is becoming more acceptable to at least speak in terms
of zero discharge of some wastes.96 However, some authors
continue to urge caution in abandoning other environmen-
tally sound options such as treatment.208' 209 Hahn points
out that "elected officials and the EPA are beginning
to develop a new agenda that is more responsive to the
public's demands for environmental progress as well as
demands of environmental groups. This agenda includes a.
greater concern for man's relationship to the planet and
"sustainable" development."208
We close this review with observations about the future
from two individuals with much credibility on environmen-
tal subjects.
May 1992
Volume 42, No. 5
651
-------
Gerald Kotas, director of EPA's Pollution Prevention
Division, writes ''central to the Pollution Prevention Act is
the premise that source reduction of wastes and other
pollutants is complementary to improvements in efficiency
and competitiveness. For the moat part our-, pollution
prevention efforts to date have involved- easily accessible
measures:—such as better .housekeeping and inventory.,
control—that save money and resources with fairly short '
payback periods. We have found that once businesses
clearly see the volume of materials that are routinely
wasted through releases to the environment, they begin to
make the link between source reduction and efficiency
improvements.
"As progress is made on the technological side o£ pollu-
tion prevention, there is a growing recognition of the need
for prevention to become an integral part of our basic
philosophy of environmental protection. Pollution preven-
tion must become the strategy of first choice in addressing
any environmental problem..Creating this new "pollution
prevention ethic" requires a shift in the perspectives of
those whose activities affect the environment. Without
question, this is a massive undertaking, and one that will
continue to challenge society in the years ahead."?10
Finally, Michael Deland,. chairman of the Council on
Environment Quality, writes that 'as America's economy-
grows more global in character, industry leaders find yet
another reason to practice pollution prevention: to position
themselves more-competitively in- the global market. The
demand for "greener" goods and services, already valued at
$50 bUlion to $60 billion a year by the U.S. Department of
Commerce, is growing hot only in the United States and
Europe but also worldwide.
It should also be clear that our real motive is not just
short-term economic gain, but rather a deeper commitment
to our'children and to future generations. The nation's
commitment to1 a cleaner, safer environment is strong and
enduring. The timeless wisdom that "an ounce of preven-
tion is worth a pound of cure" is a challenge not just for
"business" or for "government," but for you and me and
every member of the human family. Our success in moving
beyond the problems of the past, such as cleaning up our
mess after the fact, and getting on with the'challenge of the
future—pollution prevention, at home and abroad—
depends ultimately on whether you and I redouble our
personal efforts toward that end. Our challenge is that
simple and that important.5
Acknowledgments
We could not have prepared this review without the help L
of many people who advised us on what articles should be
included and in many cases provided us with copies of the
articles for our use. Our sincere thanks to Bob Pojasek,
David Allen, Shelley. Hearne, Jerry Kotas, Lee Byers, Terry'
Foecke, Dave Benforado, K.C. Lee, Dick Conway, Walter
Stahel, David Thomas, J.C Gomez, Chuck Marshall, J.C.
van Weenen, David Hindin, Al In'nes, Robert Ludwig,
David Wann, Marvin Fleischman, Robert W. Hahn, Greg
Keoleian, and the staffs of the EPA's Pollution Prevention
. Information Clearinghouse, the AWBERC Library in Cin- •
cinnati, and the Waste Reduction Resource Center for the
Southeast in Raleigh, NC. We also appreciate our EPA
colleagues in the Pollution Prevention Research Branch
who assumed some of our duties while we were preparing
the manuscript.
We'would like to offer a very special thanks to those
individuals who reviewed the final draft manuscript and
gave us the benefits of their comments. They are Ann
Rappaport, Larry Ross, Scott Butner, Deborah Hanlon,
Betsey Shaver, Ron Berglund, Linda Pratt, and Art Purcell.
Finally we would like-to acknowledge and offer a huge
"thank you" for the most significant contributions that we
received, those of Rita Bender and Ruth Cora, our secretar*
ies in the Pollution Prevention Research Branch, whose
assistance, patience, thoroughness, and good humor during
a two-month manuscript preparation stage went way be-
yond our fondest expectations. What we did to deserve such
outstanding members of our EPA team escapes us. Thank
you. . • ' •
The authors of this Critical Review are employees of the,
U.S. Environmental Protection's Risk Reduction Engineer-
ing Laboratory whose support for this effort is appreciated.
Opinions and conclusions in the article are those of the
authors. No official support for these conclusions by the
U.S. EPA is intended or should be inferred.
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